# G¶
ALCOA -. .- 

# -- Alcoa Engineered

.... ..

### _ . .,. .,....,-.- 

### Products 

# -
;, .I I I ',I F'imalw Operations 

### JUL 

### 1 1 2005

.,, 

### ! 1 

## ?A i 6833 ~est~willsRoad Box 5050 1 1 Chandler. AZ 85226 USA I"

.....,-...----- ---------I c.':; ;..

... : '. ", *,.-:,,- '1:::,-'.! Tel: 1520796 1098

I ., ,...
. I. I Fax: 1480598 2278 r,,k.1. ' '

. ,.
. . I 

# _ ."

.. 

### SEND VIA CERTIFIED MAIL

Gila River Indian Community Department of Environmental Quality P.O.Box 97 Sacaton, 

### AZ 85247 

### Subject: Comments on Gila River Indian Community (GRIC) 

### Tribal Implementation Plan 

### (TIP) for 

### Air Quality Management
Dear GRIC Representative:
Please find the enclosed comments on the Gila River Indian Community (GRIC) Tribal ImplementationPlan (TIP) for 

### Air Quality Management. These formal commentshave been prepared and submitted on behalf of Pimalco. Pimalco is 

### located on the Lone Butte Industrial park of the GilaRiver Indian Community and is currently permitted as 

### a Title V source by U.S. EPA.
These comments arebeing submitted 

### in accordance with the public notice requirements specified by the Gila River Indian CommunityDepartment of Environmental Quality. If you have any questions or need additional information, please contactMs. Amy Vasquez of my staff at 1-480- 598-2294or via email at arny.vasquez @alcoa.com. Sincerely

### ,



# fl-~ 4-

Donald 

### J. Nelson LocationManager Pimalco

### Pimalco Comments on Gila River Indian Community (GRIC) Tribal ImplementationPlan (TIP) for 

### Air QualityManagement.
Part I1 -

### PERMLIT REQUIREMENTS
Comment#1- Eliminate the definition and use of "ultra-hazardous airpollutant" as it relates to permitted releases of air pollutants. Section 112(r)(3) ofthe Clean Air Act was intended for accidental release prevention, not permitted releases ofhazardous air pollutants.
Based on this, the ordinance should only address Criteria and 

### HAP air pollutants in the context of the CAA. The "serious potential health effects" are based on accidental releases above a specified threshold, not pettedemissions. The 300 lbslyear is arbitrary and capricious with no scientificbasis. 

### Part I1 -

### PERMIT REQUIREMENTS -

### Introductionand Overview Concept

### #6 -The permit ordinance regulates two broad categories of air pollutants.
The ordinance goes on to specify a special subcategoryof hazardous airpollutants which are "ultra-hazardous airpollutants". The introduction and overview goes on to note that "These are hazardous air pollutants that EPA has designated because of their serious potential health effects. For these ultra-hazardous air pollutants, the draft ordinance establishes a lower threshold (300 lbslyr) for triggering a requirement that the source install Best Reasonable and Demonstrated Technology (l3DRT). 

### 1.0 DEFINITIONS -

### Ultra-hazardous air pollutant Ultra-Hazardous 

### Air Pollutant - Delete the definition and use of "ultra-hazardous air pollutant" as it relates to permitted releases of airpollutants. Rcgulatcd Air Pollutant -Dclctc rcfcrcncc to 'hltra-hazardous air pollutant" Significant 

### - Delete reference to "ultra-hazardous airpollutant" 

### 2.1.C.l.c De mimimusExemption Delete reference to "ultra-hazardous air pollutant" 

### 4.2.A.2.d Non Title V Permit Standards Delete reference to 'hltra-hazardous airpollutant" 

### 5.1.A.8 Changes Requiring a SignificantPermit Revision Delete reference to "ultra-hazardous air pollutant"

Page 2 6/29/2005 6-27-2005 TIP Comments.doc

### Part 

### I1 

# - Section 

### 11.7 -

### Accelerated Application Processing Fee

- - Comment #2 -Eliminate the section for "Accelerated Application Processing Fee" and replace it with 'Time PeriodsFor Determination On Permit Applications". The current ordinance does not provide for any time period for reasonable review of apermit application. As such, any permit couldbe held indefinitely unless the permit applicant chose to pay the proposed "Accelerated Application ProcessingFee". As such, the "Accelerated Application ProcessingFee" can become a de-facto 50% surcharge forpermitreview.
As a componentof assuming primacy of the air programs from U.S. EPA, 

### GRIC should establish specific timeperiohfor determination onpermit applications. This would eliminate any subjectivity or differences in permit application approvaltime frames from source to source and provide a uniform structure for approval. Proposed language for "Time Periods for Determination on Permit Applications" isprovidedbelow:


### 11.7 TIME 

### PERIODS

### FOR DETERMIINATIONON PERMITAPPLICATIONS (a) GRIC shall approve or deny an application received by GRIC within the following number of calendar days from receipt of such application: Title 

### V Sources (1) Two hundred seventy (270) days for an application concerning an air pollution construction permit for a significantpennit revision application that is a result of a major modification (2) One hundred twenty (120) days for an application concerning an air pollution application for other significant permit revision application. (4) Forty-five (45) days for an application concerning a minor permit revision (5) Forty-five (45) days shallbe added to the time period established in this subsectionif GRIC determines that a public hearing should be held
Non-Title V Sources (1) One hundred twenty (120) days for an application concerning an air pollution construction permit for a non-minor permit revision application. (2) Forty-five (45) days for an application concerning a minor air permit revision application. (b) GRIC shall approve or deny an application filed with GRICwithin the time period described under subsection (a) unless: (1) GRIC enacts a statute that imposes a new requirement on permit applications that makes it infeasible for GRIC to approve or deny the application within the applicable time period specified 

### in subsection (a); or 

### (2) GRIC and an applicant, in regard to a particular permit application, agree in writing to extend the time period allowed under subsection (a). (c) The time period described under subsection (a) shall begin and end asfollows: (1) The time period begins on:

Page 3 6/29/2005 6-27-2005 TIP Comments.doc(A) the date an application and a required fee is received and stampedreceivedby GRIC; or (B) the date marked by GRIC on a certified mail return receipt accompanying an application and a required fee; whichever is earlier. (2) The time period ends on the date that GRIC's decision to approve or deny an application is issued. (d) The time period described under subsection (a) may be suspended if: (1) GRIC receives a written request from an applicant to suspend processing of the application so that an issue related to an application can be resolved or additional information concerning an application can be provided; or 

### (2) GRIC mails a request for additional information to the applicant describing the reasons the application is not complete after determining that any of the following apply: (A) An application does not contain all of the information or documents,required by rules adopted that GRIC needstoprocess the application. (B) An application contains provisions that are not consistent with an applicable rule or law. (C) An applicant fails to pay the required fee or submits a check that is not covered with sufficientfunds. (e) The time period described under subsection (a) shall be suspended on the day the applicant receives GRIC's request for additional information. (f)The time period described under subsection (a) shall resume: (1) on the date GRIC receives, and stamps as received, the information or payment completing the application; or (2) on the date marked on the certified mail return receipt that accompaniedinformation orpayment completing the application; whichever is earlier. (g) If an applicant's response does not provide all information requested in the request for additional information, GRIC shall notify the applicant within fo~ty-five (45) calendar days after receiving the response. If GRIC finds an application to be incomplete after reviewing an applicant's response to a second or subsequentrequest for additional information, GRIC shall: (1) deny the application pursuant to subsection (j); or (2) choose to issue a further request for additional inform&tion; however, the time period described in subsection (a) may not be suspended unless the applicant agrees in writing to defer processing of the application pending the applicant's response to the request for additional information. (h) GRlC shall inform a source ofthe status of GlUC's review of the source's application or shall issue a request for additional information: (1) within thw(30) calendar days of the day an application concerning an air pollution construction permit for a minor source or a minor modification was filed with GRIC; and (2) within forty-five (45) calendar days of the day an application concerning an air pollution construction permit for a major source or major modification was filed with GRIC.

Page 4 6/29/2005 6-27-2005 TIP Comments.doc

### (i) GRIC may deny a permit applicationbecause the application is incomplete if an applicant: (1) fails to submit, within sixty (60) calendar days of receipt of a request for additional information, the requested information or a schedule for providing the requested information; (2) 

### does not adhere to the schedule submitted under subdivision 

### (1); or (3) fails to submit, within thlrty 

### (30) calendar days ofreceipt of a request for payment, a required fee or submits a check that is not covered with sufficient funds. (j) 

### GRIC may deny a permit application because it contains provisions that are not consistent with applicablerules or laws. 

### (k) A permit application fee for renewal of an operatingpermit or an annual fee for an operating permit is nonrefundable. (1) If 

### GRIC does not issue or deny a construction permit, registration, or permit revision within the time period specified under subsection (a), GRIC shall automatically refund the permit, registration, or permit revision application fee paid by the applicant, except as described in subsection (m)(2). (m) Upon expiration ofthe specifiedtime period in subsection (a), GRIC shall do the following: (1) Provide the applicant with a written determination of whether the time period specified under subsection(a) 

### has expired. (2) 

### Ifthe time period under subsection (a) has expired, GRIC shall refund the applicant's application fee within thirty (30) calendar days of the expiration of the time period specified 

### in subsection (a). GRIC shall not refund the application fee if, within thirty (30) calendar days of the expiration of the time period specified in 

### subsection (a), GRIC determines: (A) one (1) or more of the proposed emissionsunits is in operation without prior written authorizationfrom GRIC; or (B) construction 

### has commenced on one (1) or more of the emissions units without prior written authorization 

### from GRIC. (3) If the applicant is eligible for a refund of the application fee, GRIC shall do the following: (A) Continue to review the application. (B) Approve or deny the application as soon as

### practicable. (C) Not bill the applicant for additional charges related to the application. (D) 

### Issue a 

### schedule to the applicant for making a final determination on the pending application.

Page 5 6/29/2005 6-27-2005 TIP Comments.doc

### Part 

### VI 

# - Section2.0 -

### VOC USAGE, STORAGEAND HANDLING
Comment #3 -Modify the language regarding disposal of dirty cleanup solvent to specify that it shouldbe disposed of ashazardouswaste if it is listed or exhibits the characteristicsof hazardous waste. 

### 4.0 REOUIREMENTSFOR HANDLING. STORAGE AND DISPOSAL OF MATERIALS CONTAINING VOCS
4.1 

### GENERAL OPERATING REQUIREMENTS: 

### 3. Dirty cleanup solvent shall be disposed 

### in accordance with hazardous waste statutes if the solvent ahibits the characteristicsof or is listedas a hazardous waste.



### Part

## VI - Section3.0 

## -DEGREASINGAND 

### SOLVENT METAL CLEANING
Comment #4 -Modethe language regarding exemptionsto the Degreasing and Solvent Metal Cleaning Ordinance to adequately ensure that the Volatile Organic Compound language under the Aluminum Processing ordinance takes precedence over the Degreasing and Solvent Metal Cleaning Ordinance language. 

### 1.0 APPLICABILITY
1.2 

### EXEMPTIONS 

### A. Solvent cleaning and Volatile Oraanic Comuounds operations specifically regulated by this part or bvPart 

### C71-Sourcdcateporv s~ecific emission limitsfor aistinaand new sources 

### Part VII 

# - Section 

### 1.0

# - Secondary Aluminum Production
Comment #5 - Add the definition of RUNAROUND SCRAP as follows: 

### 2.0 

### DEFINITIONS
2.7 RUNAROUND SCRAP: Is defined at 40 CFR 63.1503 and means scrap materials generated on-site by aluminum casting, extruding, rolling, scalping, forging, forming!stanlping, cutting, and trimming operations and that do not contain paint or solid coatings. Uncoatedlunpainted aluminum chips generatedby turning, boring, milling, and similar machining operationsmay be clean charge if they have been thermally dried or treated by a centrifbgal cleaner, but are not consideredtobe runaroundscrap.

Page 6 6/29/2005 6-27-2005 TIP Comments.docComment #6 - Add the word culendarto 3.2.B. Volatile Organic Compounds as follows:
3.2 

### VOLATILE ORGANIC COMPOUNDS B. Each source subject to this Section shall demonstrate annually by February 15that for the peceding calendaryear total VOC emissionswere reduced by at least 3% of the VOC baseline emissionrate. This demonstration shallbe required each pear for five (5) consecutiveyears after issuance of the source's initial permit pursuant to Part 11 for a total VOC reduction of

d at least 15% fiom the VOC baseline emissionrate.

Comment #7 - Add the words utilizinpmaterialother than cleancharpe to 3.5.A. OPERATING REQUREMENTS 

### - LABELING as follows:
3.5 

### OPERATING REQUIREMENTS A. 

### RAW 

### MATERIALS: The owner or operator of a Group 1 furnace utilizinp material other than clean charee shall institute a scrap inspectionprogram that shall be approvedby the Department and that shall include the elements described in 40 C.F.R §63.1510@). A Group 1 furnace shall be charged only with material that has been determined acceptablepursuant to the scrap inspection program.
Comment

### #8 - Modify the Source Testing and Monitoringlanguage under Section 4.1.A to recognize that a source shall be exempt fiom the performance test requirements of this subsection ifperformance tests that comply with the performance test provisions of this subsection were conductedprior to the effective date ofthis Section.


### 4.1 

### SOURCE TESTING AND MONITORING A. Unless otherwise exempt under this subsection,within 90 days prior to the submittal by a source subject to this Section of its initial permit application pursuant to Part 11,the source shall conductthe performance tests on any Group 1 or Group 2 furnace, using the test methods prescribed by 40 C.F.R. 

### 8 63.1511(c). The tests shall demonstratecompliance with the emission limits, standards and operating requirements set forth in subsection 3.0 ofthis Section. No later than 45 daysprior to such testing, the owner or operator shall notify DEQ ofthe test date and submitthe sitespecific test plan to DEQ. A source shallbe exempt fromthe performance test requirements of this subsectionifperformance teststhat comply with the performance test provisions ofthis subsection were conducted prior to the effective date of this Section.

Page 7 6/29/2005 6-27-2005 TIP Comments.doc

### Electr.onic.Codeof Federal Regulations:

Runaroundscrap means scrap materials generated on-site by aluminum casting, extruding, rolling, scalping, forging, forminglstamping, cutting, and trimming operations and that do not contain paint or solid coatings. Uncoatedlunpainted aluminum chips generated by turning, boring, milling, and similar machining operations may be clean charge if they have beenthermally dried or treated by a centrifugal cleaner, but are not considered to be runaround scrap. 

### Page 1

### of 

### 1