## Responses to Comments Submitted by Alcoa Inc. Addressing the GRIC TIP

GRIC Public CommentPeriod July 1,2006thru July 31,2006



### RESPONSES TO PIMALCO Comment: "Section Summaries

## - Part 11: 

### Permit Requirements

# - (C) General Concepts in the Permit Ordinance

# - (4) Emission limits and emission standards This sectionnotes that the basis of emission limits are predicated upon Techcal Support Documents (TSD)and that the TSD's will be presented with specific ordinances in the near future". Sincethe TSD forms the basis for regulatory framework. these TSD's should be provided for review. 

### Response: "The Technical Support Documents for source category-specific ordinance have been and continue to be available at the GRIC DEQ offices and will be provided electronically upon request.

### " Comment : 

### "Part 

### 11Permit Requirements

## - 1.0

### Definitions

## - Ultra Hazardous air pollutants: Pimalco previously commentedon the Tribes newly defined ultra hazardous air pollutants which include chemicals listed at 112 (r) for accidental release prevention. Section 112r chemicalswere intended for accidental release prevention under CAA and were not intended as a permit parameter. Based on this, the ordinance should only address criteria and hazardous air pollutants as defined in the Clean Air Act and should not be included as a permit parameter. Specifically,the ordinance indicates a regulatory threshold of 300 pounds for permitting purposes. This threshold has no technology or health based standard and appears to be arbitrary and capricious with no scientific basis. Based on this, Pimalcorequests that the concept of "ultrahazardous air pollutants"be removed from the ordinance.


### Response: "The ordinance provides more stringent regulation of what are called ultrahazardous air pollutants. This is a characterization (as "extremely hazardous substances") adopted in Section 112 of the Clean Air Act. The reason that certain hazardous air pollutants were chosen for this designationis amply documentedin the legislative history of Section 112 and the community would be glad to provide references to this documentation ifrequested."

### Comment: Part V

# -Area Sauree Emissian Limits This section refers to fugitive dust producing activities that generate emissions.Under the CAA, an "area source" is a source that emits less than major source thresholds of hazardous air pollutants. Because of this, Pimalco is concernedthatthis duel meaning may lead to confusion and ambiguity. Pimalcorequests that this sectionbe renamed to "Fugitive Emissions Limits" 

### Response: "We agree with this comment and have amendedthe ordinance accordingly".



### Comment: Part 

### VI Exemptions to the Degreasing and Solvent Metal Cleaning Ordinance Response: "We agree with this comment and have amended the ordinance accordingly." 

### Comment: Part 

### VI Exemptions to the Degreasing and Solvent Metal Cleaning Ordinance Response: "We agree that the exception requires clarification. It has been limited to solvent cleaning operations specifically regulated by 'another Section in thsPart

### VI."' Comment: Part VII Secondary Aluminum Production Ordinance Response: "This comment took us aback. The emission decrease requirement for VOCs in the proposed ordinance was specificallyincorporated at the cornmenter's suggestion. It provides significant flexibility. Now the commenter is requesting an additional level of flexibility. The community does not believe that additional flexibility in this case is either warranted or necessary." 

### Comment: Part 11

### Accelerated Permit Processing Response: "We agree that it is desirable to have permit processing deadlines in the ordinance and eventually the community will adopt such deadlines. However, this is a new and unprecedented program for a tribe to adopt and implement and we simply lack adequate experience as far as processing permits to be able to adopt meaningful processing deadlines. We would note that non-Indianjurisdictions have typically had twenty or more years experience processing air quality permits before processing deadlines were adopted, so giving the Community at least some limited time to create the necessary track record hardly seems unreasonable." The decision to pay the extra fees necessary for accelerated permit processing is entirely within the discretion of the permit applicant. Payment does two things (neither of which requires processing deadlines): (1) Gives the applicant a priority position inthe processing queue. 

### (2) Provides the resources necessary to contract with an outside thrd party to assist in the permit processing.

### Whether these benefits justify the 50% 

### surchargeis uptothe permitapplicant."