Page 1 of 1 

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: "Eric Fuller" <EricF@romic.com>; "Wayne Kiso" <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 Implementation Plan. If you have 

> questions regarding these comments, please contact me, 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 

> Subparts AA, BB and CC. 

> 

> <<GRIC Tribal Implementation Plan 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 industrial facility with an unpaved parking lot with traffic 

exceeding 20 vehicles per day must acquire a permit. 

Questions: 

1. Is this a separate permit specifically for parking lots? or, Will this be a section of the 

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 San Joaquin 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." If the 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 delete this 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 appear to 

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" implies readily evaporated. 

The South Coast Air 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 atmospheric photochemical 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 of pressure in the definition given. 

3. Limitation and Standard 3.1 : Operations Involving Heat. 

Is this intended to include distillation operations where non-contact steam is used in a 

heat exchanger to evaporate solvent in a fully enclosed system that subsequently 

condenses the 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: Operations Involving 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 

standard to 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 

distillation unit process vents. The unit is designed in accordance with 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 containing VOC" 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, cardboard triwall boxes or 

Supersacks. During transportation to Romic, it is possible for solid debris to occasionally 

rub a hole in the plastic liner, or perhaps the customer may not tie the liner tightly enough 

to be vapor tight prior to sealing the box or the sack. Romic does not unpack these 

triwalls and supersacks to 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 requirement to include other VOC containing solids such as filters and 

debris in addition to the wipes mentioned. 

Also, where spent filters containing solvents are drained to remove free liquid, this 

should be done in a covered container to minimize evaporation of 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 storing VOCs. 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 1.5 psia 

(77.5 mm Hg). Materials with a true organic vapor pressure less than 1.5 psia 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. Specifications for 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 determined by the ownerloperator based on applicable 

codes, standards and recommendations. " 
As a TDS facility, Romic is subject to the storage tank emission standards of 40 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. 

1 1. Specifications for Loading of VOC 4.3, A, 2 

Should the "and" be an "or" between "compressor" and "fuel-gas system"? 

12. Specifications for Loading of VOC 4.3, B 

Since loading pipes are typical of "Bulk Plants" and "Bulk Terminals", please indicate 

this clarification in this section to further describe what is intended by this section. 

Loading/unloading of 4,55 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 stationary bulk 

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 of the rail car. These rail cars would not 

be able to meet the "installed requirement of the 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 emissions are 

allowed. In reality, transfer operations generate fugitive emissions. These fugitive 

emissions are difficult to 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 Wtive emissions from the attachment and 

disconnection of transfer 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 10,000 ppm 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 completely free of "gaseous leaks" or an 

occasional drip due to their constant motion and less-than-perfect seals inherent to 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 1 part per trillion. Its 

unpleasant odor can be smelled at levels that do not contribute to air pollution. It should 

also be noted that less-than-pleasant odors (significant to some people) 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 determining compliance. 

14. Monitoring and Inspection Requirements for VOC Storage and Transfer 5.3 A, 

Loading Facility Inspections 

Is this intended only for loading facilities with throughput greater than 40,000 gallons per 

day that have loading racks and vapor recovery systems? 

For facilities with throughput between 200 and 40,000 gallons per day that do not have 

loading racks or vapor collection or drsposal systems, a visual inspection of the transfer 

equipment on a quarterly or semi-annual basis may be appropriate. Ths type of 

documented inspection can help a facility justify expenditures to maintain transfer 

equipment in good shape. 

15. Recordkeeping and Recording 5.4, A, 1 Current Lists 

Romic requests that its detailed waste profiles, required under RCRA regulations as 

waste determinations, be sufficient to satisfy this requirement rather 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 great recordkeeping 

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 of the 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 of the waste and describes its physical properties. 

Romic's computer system can quickly produce the profile details for each tracking 

number, and there should not be a need for a separate list of VOC content information to 

show that we have knowledge of the 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 complying with this requirement? 

Add "or recycling" after "disposing", and change "on each day of disposal" to "for each 

offsite shipment". Unless any of the facilities on the reservation are permitted to actually 

dispose of VOC-containing materials on their sites or in their processes, it may be more 

clear that it is intended for facilities to properly dispose of these wastes offsite if you say 

SO. 

18. Recordkeeping and Recording 5.4, B 1 Storage 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 Reid vapor 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 guesses by the generators who are familiar with 

their own processes. 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 

estimates are acceptable. 

Romic has provided "worst case" calculations to the EPA to determine the maximum 

potential operating pressures of its storage tanks. These tanks are also equipped with 

Level 1 controls 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 of Level 1 controls minimizes vapor emissions to 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 satisfy this requirement? 

20. Determination of Compliance 6.1 

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 guesses by 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 of the Director1 Department, to determine compliance". 

22. Test Methods 6.2 A 1 

Please allow engineering estimates1 generator 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 of these 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 15 to 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 120 CFM. 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 flow rate 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 determining compliance. 

Please provide for a de minimis amount of effluent, such as the 3 lbthr or 3.1 tonslyear 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% of nextto-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 for just compliance testing, or are you expecting this 

kind of accuracy also in our processes (that don't need it)? Must all temperature 

measurements be accurate to less than +I- 0.5 degrees F, 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 

approval by the administrator to 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 1 to 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 emissions based on measured data, emissions factors, process 

throughput, operating hours, and other factors as best applicable." This would allow the 

use of engineering estimates similar to those reported in the TRI report for air emissions. 

3. Part 11, Permit Requirements, Calculation of Emission Fees 1 1.5 (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 sufficient for non-Title 

V sources so an annual per-ton fee is not necessary? On p. 72, an $1 1.75 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 calendar year 

rather than a permit cycle calendar year. All of our other governmental reporting is 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 if the total emissions 

from that source are under 10 tonslyear for 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?