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Janet Travis

From: "Dan Blair" <air@gilanet.net> To: "Pat Mariella" <patricia.mariella@gric.nsn.us> Cc: "Russell Betsuie" <rbetsuie@gilanet.net>; "Leroy Wtlliams" <williams@gilanet.net>; "Janet Travis" <jtravis@gilanet.net> Sent: Tuesday, July 05,2005 12:53 PM Attach: GRlC Tribal Implementation Plan Comments.doc Subject: Fw: Romic comments to draft TIP



### ----- Original Message 

### ----- From: "Micki Schultz" <MickiS@omic.com> To: <air@gilanet.net> Cc: "EricFuller" <EricF@romic.com>; "WayneKiso" <WayneK@roinic.com>; "Gary Bowling" <GqB@,romic.corn> Sent: Thursday,June 30,2005 2:40 PM Subject: Romic comments to draft TIP

>

### Please accept the attached document 

### as Romic Environmental Technologies' >

### formal comments to the draft Tribal ImplementationPlan. Ifyou have >

### questionsregarding these comments, please contactme, Micki Schultz, at > 

### 520-796-6250,or mickis@romic.com <mailto:mickis@romic.com>



### . > >

### I also would like to meet with GRDEQ to discuss existing emissions controls > 

### and recordkeeping requirements already in place at Romic under 40 CFR 264 > 

### SubpartsAA, BB and CC. > > 

### <<GRIC Tribal ImplementationPlan Cornments.doc>> >

## GRIC Tribal Implementation Plan Comments -

## Romic Southwest -

## 6/29/05 Micki Schultz (520) 796-6250 

### L Part V. Area Source Emission Limits Summary, Specifics, second paragraph: Statement: In addition, any industrialfacility with an unpaved parking lot with traffic exceeding 20 vehicles per day must acquire a permit. Questions: 1.Is this a separatepermit specifically for parking lots? or, Will this be a section ofthe overall permit? 2. Is 20 vehicles an average or an absolute maximum number? Is it based on the number of employees assigned to that area, (the usual parking traffic) or must it include the infrequent event where additional visitors may converge for a meeting and there are additional cars on a given day? The SanJoaquin Valley Unified Air Pollution Control District uses a standard of "50 average annual daily trips," which would be roughly equivalent to 25 vehicles per day, but put in more measurable/implementable/enforceable terms. So, as an alternative,we would propose wording of "forty average annual daily trips" in lieu of "20 vehicles per day." Ifthe average number of vehicles is calculated on an annual basis, it accommodates the occasional event with a higher-than-normal number of vehicles.

I1 Part V. Area Source Emission Limits, Section 

### 2, General Requirements for fugitive dust-producing activities Section 4 Unpaved Parking Lots: Same question as #2 above regarding the 20 vehicle per day limit.

III. Part VI 

### - Generally Applicable Individual Source Requirements for Existing and New Sources, I Overview, Specifics, second paragraph. Statement: For example, the emission control unit used to control VOC emissions from the Romic, Inc. distillation tower is required to reduce VOCs by at least 

### 85%using carbon adsorption. Comments: 

### 1.Romic feels that in addition to being incorrect, this type of statement should not be used to single out a particular company in the ordinance.No other sections of the ordinance mention specific facilities.Please deletethis statement entirely.

### 2. Romic's distillation process emissions are controlled by a VOC condenser system,not carbon adsorption. Romic does not rely on carbon adsorption for process VOC reduction except as a backup to the VOC condenser unit in the event of a system failure during a process 

### run.



### IV.Part 

### IV

### - Section 2.0 

### VOC Usage, Storage and Handling: Comments: 1.Definition 2.16,VOC, needs to be revised as it is too inclusive. It would appearto include all solid organic compounds (paper,wood, plastics, etc) as well as oils and other liquids of low vapor pressures that don't readily evaporate and are not usually associated with VOCs. "Volatile" impliesreadily evaporated. The South CoastAir Quality Management District does include the word, "volatile"in its definition ("VOC" is any volatile compound of carbon..

..). Maricopa County rules include the qualifier, "which participates in atmosphericphotochemical reactions"to exclude solids and materials of low volatility. 2. Definition 2.15,Vapor Loss Pressure may be a typo. It looks like you are describing a Vapor Loss System. There is no description ofpressure in the definition given. 3. Limitation and Standard 3.1: Operations Involving Heat. Is this intended to include distillationoperations where non-contact steam is used in a heat exchangerto evaporate solvent in a fully enclosed system that subsequently condensesthe pure vapors as product? The process condensers are designed to recover VOC as liquid, and are inherent to the process, which does not involve oxygen. 4. Limitation and Standard 3.1:OperationsInvolving Heat. Although distillation does not appear to be included in the processes described in 3.1, please note that under 40 CFR 264.1032(a)(l),organic emissions from TSD distillation process vents are limited to 3 lbhr or 3.1 tons/year unless controls are utilized. This is the standardto which Romic has been performing. 

### 5. Limitation and Standard 3.4:Required Emission Reductions,D. Romic uses a VOC reduction condenser system to reduce excess emissions from its distillationunit process vents. The unit is designed in accordancewith 40 CFR 264.1032(a)(2). The outlet exhaust from this unit is a 20 

### ft. high 2 inch pipe. The test methods set forth in subsection 6.2 are not appropriate for a 2 inch pipe. 6. General Operating Requirements 4.1, A, 1: The statement "Vapor-tight containers shall be used for the storage of spent or fresh material containingVOC" should have the qualifier "liquid" added before the word "spent". As a TSD, our liquid wastes arrive in vapor-tight DOT containers such as drums or totes, and we would be able to comply with this requirement. However, many of our VOC-containing solids such as solvent wipes, resins, plastics, filters and solvent

### contaminated debris arrive in DOT cubic yard, plastic-lined, cardboardtriwallboxes or Supersacks. During transportation to Romic, it is possible for solid debristo occasionally rub a hole in the plastic liner, or perhaps the customermay not tie the linertightly enough to be vapor tight prior to sealing the box or the sack. Romic does not unpackthese triwalls and supersacksto inspect the condition of the liner, and therefore cannot guarantee that these proper DOT shipping containers are, indeed, vapor tight. Maricopa County air rules only require that VOCs be stored in closed containers.This would cover tri-wall boxes and such.

7. General Operating Requirements 4.1, A, 2: 

### Please expand this requirementto include other VOC containing solids such as filters and debris in additiontothe wipes mentioned. Also, where spent filters containing solvents are drainedto remove free liquid,this shouldbe done in a covered containerto minimize evaporationof the solvent. 8. 

### General Operating Requirements 4.1, A, 3: 

### The definition of organic solvent in this regulation includes both hazardous waste solvents and non-hazardous waste solvents. A generator should not be required to manage non-hazardous waste solvents as hazardous wastes. Certainly,the paperwork and allowed storage times would be dfferent for these two categories of wastes. Please add "or recycled" after the word "disposed. We want to encourage recycling where possible.

9. 

### Specifications for Storage of VOCs, 4.2 A&B The draft TIP rule requires controls on any tank with a capacity of more than 40,000 gallons storingVOCs. The Maricopa County air rules upon which the draft TIP is based include exemptions for tanks storing liquids with a vapor pressure of less than 1.5psia (77.5 mm Hg). Materials with a true organicvapor pressure less than 1.5psia are deemed to pose an insignificant environmental impact in Maricopa County, a nonattainment area; a similar provision should be more than adequate for an attainment area. 10. Specificationsfor Storage of VOCs, 4.2 

### B - 

### Storage Capacities Between 250 and 40,000 Gallons Please add a fourth category: "(4) or be equipped with a conservation vent so that the device remains in the closed position whenever the tank 

### internal pressure is within the internal pressure operating range determinedby the ownerloperatorbased on applicable codes, standardsand recommendations."As a TDS facility, Romic is subject to the storage tank emission standards of40 CFR 264.1084 (Subpart CC), and is equipped with conservation vents as Level 1 controls under 40 CFR 264.1084 (c)(3)(ii) in addition to the submerged fill pipes.

11. Specifications for Loading of VOC 4.3,

### A, 2 Shouldthe "and" be an "or" between "compressor" and "fuel-gas system"? 12. Specifications for Loading of VOC 4.3, B Since loadingpipes aretypical of "Bulk Plants" and "Bulk Terminals", please indicate this clarification in this section to further describe what is intended by this section. Loading/unloading of4,55 gallon drums a day from a tank truck with a hose has much less of an environmental impact than loading 39,950 gallons from a stationarybulk loading facility. Please remove the word "installed" and leave the statement as "operated" to maintain the 97% submerged factor. Due to safety concerns associated with railcar bottom fill valves, Romic loads its rail cars from the top hatch with a truck-mounted flexible hose connected to a manual submerged fill pipe (stinger) designed to reach to the bottom ofthe rail car. These rail cars would not be able to meet the "installed requirement ofthe ordinance since the hose and stinger are not installed,but manually inserted.
13. Specifications for Loading of VOC 4.3, C The absolute statement "No liquid or gaseous leaks shall exist during loading or unloading operations." seems to be an unintentionally extreme and not reasonably achievable statement. This statement implies that absolutely no fugitive emissionsare allowed. In reality, transfer operations generate fugitive emissions. These fugitive emissions are difficultto quantify, and I don't know of any operations that can actually measure them in a meaningful way, or prevent them. Transfer operations generate some Wtiveemissions from the attachment and disconnection oftransfer lines, and the displacement of air in containers /tanks /vehicles /railcars during the transfer. Under 40 CFR 264.1050 (Subpart BB) Air Emission Standards for Equipment Leaks, a leak is either a visible drip, or a vapor reading of greater than 10,000ppm from permanently installed ancillary equipment such as pumps, valves and piping. Flexible hoses and quick connect couplings typical of a transfer operation would not be expected to be completelyfree of "gaseous leaks" or an occasional drip due to their constant motion and less-than-perfect seals inherentto their design.What is the definition of visible fumes?Is a visible fume a cloud of colored material, or fine particulates like smoke, or is it the invisible shimmer lines that rise off a black railcar when the hatch is opened on a hot summer day? If so, how does one open the hatch of a railcar on a hot summer day without allowing some vapors to escape? What is a significant odor, and how is it to be determined?Various materials have various odor thresholds.A mercaptan can have an odor threshold of 1part per trillion. Its unpleasant odor can be smelled at levels that do not contributeto air pollution. It should also be noted that less-than-pleasant odors (significant to somepeople) may also be generated from transfers of waters that are not VOCs at all. There are some organic solvents that have no odor or such mild odor that you could stand in a puddle of it and not smell anything. Basing a standard on something as subjective as odor invites debate with inspectors, and would cause difficulty in determiningcompliance.

14.Monitoring and InspectionRequirements for VOC Storageand Transfer 5.3 A, LoadingFacility Inspections Is this intended only for loading facilitieswith throughput greater than 40,000 gallons per day that have loadingracks and vapor recovery systems? For facilitieswith throughputbetween 200 and 40,000 gallons per day that do not have loading racks or vapor collection or drsposal systems, a visual inspection ofthe transfer equipment on a quarterly or semi-annual basis may be appropriate.Thstype of documented inspectioncan help a facility justify expendituresto maintain transfer equipmentin good shape. 15. Recordkeeping and Recording 5.4,A, 1Current Lists Romic requests that its detailed waste profiles, required under RCRA regulations as waste determinations, be sufficient to satisfy this requirementrather than having to constantly maintain and update a list of chemicals with VOC content in pounds per gallon, with non-precursors and water subtracted out. It would be a greatrecordkeeping burden, with no benefit to the resulting air quality, for Romic to have to make and keep current such a list. Our chemicals change daily, and the composition ofthe material in our tanks can change several times per day as waste comes in and is shipped out. Romic has another way of keeping this information to track VOCs. The waste Romic receives daily ranges from small bottles in lab packs, to pails, drums, totes and tanker trucks, all which can contain VOCs. Each inbound container is assigned a unique bar-coded tracking number, which links the inbound manifest to the waste profile. The waste profile is generated and certified by the waste generator (our customers),and details the composition ofthe waste and describes its physical properties. Romic's computer system can quicklyproducethe profile details for each tracking number, and there should not be a need for a separatelist of VOC content informationto show that we have knowledge ofthe materials we handle.16. Recordkeeping and Recording 5.4, A 2, Monthly Usage Records Romic's distillation logs record the details of each batch of solvent, antifreeze or water distilled, and the 

### data is maintained in the computer system. Will it be necessary to maintain these as "monthly" records, or is the stored data sufficient? The computer will provide printed data for whatever time period is desired, as-needed, for inspection purposes.



### 17.Recordkeeping and Recording 5.4, A 4, Records of Discarded Materials Are manifests and bills-of-lading acceptable for complyingwith this requirement? Add "or recycling" after "disposing", and change "on each day of disposal" to "for each offsite shipment". Unless any of the facilitieson the reservation are permitted to actually dispose ofVOC-containing materials on their sites or in their processes, it may be more clear that it is intended for facilitiesto properly dispose of these wastes offsite ifyou say SO.
18. Recordkeeping and Recording 5.4,

### B 1Storage Records Romic manages waste materials in its tanks, and the tank compositions can change from hour to hour as materials are added to and drawn from the tanks. To be required to maintain "accurate" records of "true or Reidvapor pressures of each stored liquid in our tanks would be a huge burden, and may not be possible to achieve. Romic uses a system of customer generated and certified profiles to identify the components of the waste received. These are by no means "accurate" and are usually based on engineering estimates or best guessesby the generators who are familiar with their own processes. Wastes have a much wider compositionrange than a purchased product with specificationsand MSDSs available. There are no regulatory requirements in the EPA regulations to completelydefine waste compositions, and engineering estimates are acceptable. Romic has provided "worst case" calculationsto the EPA to determine the maximum potential operating pressures of its storagetanks. These tanks are also equipped with Level 

### 1controls as defined in 40 CFR 264.1084 (Subpart CC). The combination of a worst case calculated analysis, appropriately designed and certified tanks, and the installation ofLevel 

### 1controls minimizes vapor emissionsto the environment from our storage tanks. It would not provide any additional benefit to the environment for Romic to have to determine accurate composition and vapor pressures for each liquid in each tank. Please allow for an "alternate" recordkeeping requirement acceptable to the administrator.As mentioned before, Romic assigns a unique bar-coded tracking number to each container of waste that enters the facility, and this tracking number links the inbound manifest, the profile, the process andlor the outbound manifest. From this tracking number, Romic can determine where the material is stored, and whether the material was processed, consolidated, or shipped offsite as-is. Romic's tank composition records are based on these tracking numbers.



### 19.Recordkeeping and Recording 5.4,B 2, Loading Facility Records Are manifests, with DOT proper shipping names, and bills-of-lading acceptable documentation to satisfythis requirement?

20. Determination of Compliance 6.1 Romic uses a system of customer generated and certified profiles to identify the components ofthe waste received. These areby no means "accurate" and are usually based on engineering estimates or best guessesby the generators who are familiar with their own processes. Romic cannot guarantee that the generators determined their wastes in "final form", and the composition did not change when it became a waste. Wastes have a much wider composition range than a purchased product with specifications and MSDSs available. There are no regulatory requirements in the EPA regulations to completely define waste compositions, and engineering estimateslgenerator knowledge are acceptable. Please make the same allowance for waste compositions in the ordinance.

2 

### 1. Test Methods, general: Please add a general statement to the effect that "In the event that these methods are infeasible or not applicable, the owner or operator may use an alternative method, subject to the approval ofthe Director1Department, to determine compliance".

22. Test Methods 6.2 A 

### 1 Please allow engineering estimates1generator knowledgelgenerator generated profiles for waste compositions. 23. Test Methods 6.2 A 3 VOC emissions through Romic's VOC emission reduction unit cannot be measured by any ofthese test methods. A review of the methods in Appendix A indicated that the methods there require a minimum measurable exhaust diameter of 4 inches. The Romic unit has a 2 inch inlet and outlet pipe. Please allow for another acceptable method of determining compliance.24. Test Methods 6.2 A 4 Romic7s VOC emission reduction unit's normal operating flow rate is 15to 20 CFM. The unit was designed in accordance with 40 CFR 264.1032 (Subpart AA) requirements for a "worst case" condition of a high loading at 120CFM. The unit has never operated under those conditions, and is unlikely that it ever will. It may not be possible to prove efficiency compliance under actual operating conditions with the low flowrate and the small outlet pipe. These test methods are designed for larger flows, larger loadings and larger units. Please allow for another acceptable method of determiningcompliance. Please provide for a de minimis amount of effluent, such as the 3 lbthr or 3.1tonslyear as stated in 40 CFR 264.1032, the standard for distillation process vents, below whch efficiency testing is not required. It does not make sense to have to do expensive efficiency compliance testing to determine that it is not possible to remove 85% ofnextto-nothing in the unit.

25. Test Methods 6.2 A 5 Again, the Appendix A test methods are not appropriate for 2 inch pipes. Please allow for an alternate determination. 26. Test Methods 6.2 A 6 Is this kind of accuracy required forjust compliance testing, or are you expectingthis kind of accuracy also in our processes (that don't need it)? Must all temperature measurementsbe accurate to less than +I- 0.5 degreesF, and what has that got to do with 25 degrees C? Is ths a typo?

27. Test Methods 6.2 

### B
In general in this section, please allow for alternate procedureslmethods subject to approvalby the administratorto make these determinations,especially where the word "shall" is used.

V. 

### Part 

### II, Permit Requirements

1. Overview,page 6: There is a reference to Part VIII, Hazardous Pur Pollutants, but it is not included in this draft package.2. Part 11, Permit Requirements,4.4-Non-title 

### V Permit Content item 7 (page 3 1) Please allow us until May 1to complete the annual emissions inventory, rather than March 3 1. This would better space the emissions report in between the RCRA Generator Report and the Tier 11s due March 1, and the TRI report due June 30. I would appreciate the extra time, especially since I have not seen what is required for the report. Also ,please consider rewording to allow flexibility in determining emissions: "The emissions inventory shall be determined using actual emissions where available, or the best estimate of actual emissionsbased on measured data, emissions factors,process throughput, operating hours, and other factors as best applicable." This would allow the use of engineering estimates similarto those reported in the 

### TRI report for air emissions.

3. Part 11, Permit Requirements, CalculationofEmission Fees 11.5(page 74) This section implies but does not actually mention a per-ton emission fee. Is a per-ton emission fee expected for non-Title

### V sources? Is the annual fee sufficientfor non-Title 

### V sources so an annual per-ton fee is not necessary? On p. 72, an $11.75 actual emission fee is indicated for Title

### V sources. On p. 74, there is a mention that an "annual fee is calculated,but there is no mention of what the fee will be for non-title 

### V sources. Also, please base the "actual emissions calculations" on a Jan 1 -Dec. 3 1 calendaryear rather than a permit cycle calendar year. All of our other governmental reportingis based on the Jan. -Dec. year, and it would help those of us who prepare the reports to better utilize our data if it is on the same time basis. Maricopa County does not charge a source a per-ton emissions fee ifthe total emissions from that source are under 10tonslyearfor certain pollutants. Will there be such an allowance in the ordinance for small sources?

4. Page 79, Table E (page 79) Is fuel burning equipment meant to include gas-fired hot water heaters, building heating units andlor small steam boilers? Is there a BTUIhr maximum, below which they would be considered insignificant?