# C FINAL I PLAN FORATTAINMENT OF 

# 1 THE

# 24-HOUR PMfo STANDARD 

# 1 MARICOPA COUNTY 

# I PM,oNONATTAINMENTAREA

A@Quality Division Arizona DepaNnent ofEnvironmental Quality in Cooperation With Maricopa County Environmental Services Department May, 

### 1997--

. - TABLE 

### OF CONTENTS EXECUTIVESUMMARY 

## ....................................... ES-1



## ............................................ 1.0 INTRODUCTION 1 1.1 Ober v

### . EPA 

### ............................................ 1



## ............................... 1.2 Overview of Microscale Study 3 1.3 Overview of Attainment Demonstration 

## .........................5



### ........................................ 1.3.1 Approach 5 2.0 DUST CONTROL PRACTICES IN MARICOPA COUNTY 

### ................ 7 2.1 Rule 310. Open Fugitive Dust Sources 

## .........................7 2.2 MCESD Implementation and Enforcement of Rule 310 

## ...............9 2.2.1 Earthmoving Permit Application 

## .........................9 2.2.2 MCESD Enforcement Staff and Activities 

## ..................10 2.2.3 MCESD Inspector Training 

### ........................... 13 2.2.4 MCESD Databases 

### ................................ 10 3.0 RESULTS OF MICROSCALE STUDY 

## .............................14 3.1 

### Air Quality Modeling Results 

### .............................. 15 3.1.1. East Chandler Site 

### ................................ 16



### ....... 4.0 EVALUATION OF DUST CONTROL MEASURES FOR DESIGN DAYS 20 4.1 Control Measures 

### ...................................... 21



### ........... 4.2 Discussion of Control Measures and Implementation Issues 23 4.2.1 Salt River Site. October 16. 1995 

### ....................... 23 4.2.2 Gilbert Site. April 9. 1995 

## ............................23



### .......................... 4.2.3 Maryvale Site. April 9. 1995 27 4.2.4 West Chandler Site. April 9. 1995 

### ...................... 28 5.0 PROPOSED BEST AVAILABLE CONTROL MEASURES


### ................ 29 5.1 Regulatory Requirements 

### ................................. 29 5.1.1 Reasonable Further Progress and Quantitative Milestones 

## .......29 5.1.2 BACM Analysis


### .................................. 30

TOC-I

### TABLE OF CONTENTS.CONTINUED 5.2 Implementing Agencies 

## ..................................31 5.2.1 Agricultural Community 

## ............................. 31 5.3 BACM Commitments and Enforceability Documentation 

## .............31 5.3.1 Maricopa County Environmental Services Department 

## ..........32 5.3.2 Cities and Towns of Maricopa County 

## .................... 35


### . 5.3.3 Arizona Department of Environmental Quality 

## ...............35 5.3.4 Agricultural Community 

## ............................. 36



### .............................. 6.0 ATTAINMENT DEMONSTRATION 37



### .......... 6.1 Salt River Site. October 16. 1995: Attainment Demonstrated 37



### ............ 6.2 Gilbert Site. April 9. 1995: Attainment Not Demonstrated 38



### ............. 6.3 Maryvale Site. April 9. 1995:Attainment Demonstrated 38



### ....... 6.4 West Chandler Site. April 9. 1995: Attainment Not Demonstrated 39


### FIGURES

...................... Figure 1-1 Maricopa County PM.. Nonattainment Area 4



### ............................ Figure 2-1 Current Dust Control Plan Form 11



### ........................... Figure 5-1 Improved Dust Control Plan Form 34 

### TABLES TABLE 3-1: 24-Hour PM,, Exceedances in 1995



### ....................... Maricopa County's Monitoring Network 16 TABLE 3-2: Air Quality Modeling Results for Maximum Concentration at Salt River Site



### ........................... onOctober 16. 1995. DesignDay 18 TABLE 3-3: Air Quality Modeling Results for Maximum Concentrationat Gilbert Site



### .............................. on April 9. 1995. Design Day 18 TABLE 3-4: Air Quality Modeling Results for Maximum Concentrationat Maryvale Site



### .............................. on April 9. 1995. Design Day 19 TABLE 3-5: Air Quality Modeling Results for Maximum Concentrationat West Chandler



### ........................... Site on April 9. 1995. Design Day 20 TABLE 4-1: PMloEmission Control Measures for Sources



### ....................... Contributingto Design Day Exceedances 21

### I
I TABLES, CONTINUED
TABLE 4-2: Application of Added Control Measures to Attain 24-Hour PM,, NAAQS at



## .................. I Salt River Site on October 16, 1995 Design Day 24 TABLE 4-3: Application of Added Control Measures to Attain 24-Hour PM,, NAAQS at Gilbert Site on April 9, 1995 Design Day 

### .......................25 TABLE 4-4: Application of Added Control Measures to Attain 24-Hour PM,, NAAQS at Maryvale Site on April 9,1995 Design Day 

## .....................26 TABLE 4-5: Application of Added Control Measures to Attain 24-Hour PM,, NAAQS at West Chandler Site on April 9, 1995 Design Day 

## .................27
LIST OF APPENDICES A Technical Support Document B ENSR Report 

### - Evaluation of Fugitive Dust Control in the Marico~a County PM,, Nonattainment Area, dated March 1997 C Text of the Maricopa County Rule, Rule 200 Permit Requirements; Text of the Maricopa County Rule, 310 Open Fugitive Dust Sources; Maricopa County Rule 310 Completeness Checklist; and Maricopa County Rule 310 Public Hearing Documentation D Correspondence E Best Available Control Measures (BACM) Commitments and Documentation F Public Hearing Documentation G Responsiveness Summary and Copies of Comments

### EXECUTIVE 

### SUMMARY
The 

### U.S. Environmental Protection Agency (EPA) designated the portion of Maricopa County that encompasses the greater Phoenix Metropolitan Area as a ModeratePM,, Nonattainment 

### Area by operation of law under the 1990 Clean Air Act Amendments. The Moderate Area Plan developed by the Maricopa Association of Governments 

### (MAG), the Arizona Department of Environmental Quality (ADEQ), Maricopa County Environmental Services (MCESD) and the Arizona Department of Transportation(ADOT) and submitted to EPA November 15, 1991, did not demonstrate attainment of the PM,, NAAQS by the Clean Air Act (CAA) deadline of December 31, 1994. EPA, however, deemedthe Plan "incomplete", which afforded Arizona time to develop additional control measures that would address the sho~tfall 

### in PM,, emission reductions. Even with the additional control measures, the Moderate Area Plan still fell short of demonstrating attainment of the PM,, NAAQS. In accordance with Section 1880of the CAA, the deadline for the State to demonstrate attainment of the PM,, National Ambient Air Quality Standards (NAAQS) for this area was December 31, 1994;however, Arizona demonstrated to EPA that it was impracticable for this areato attain the annual PM,, NAAQS by the specified deadline. No demonstration was made for the24-hour PM,, NAAQS because at that time an accurate assessment of the causes of the historical exceedances was not possible. The sources of the 

### PM,,emissions that caused the exceedances appeared to be local in nature, and site-specific emissions data were not available for those days. In order to address the specific causes of and necessary controls for 24-hour exceedances, the Phoenix PM,, Microscale Field Study (Microscale Study) was designed in 1994 and conducted throughout 1995. On July 28, 1994, EPA proposed to approve the Moderate Area Plan and published its final approval of the Moderate Area Plan on April 10, 1995. 

### In response, the Arizona Center for Law in the Public Interest (ACLPI) formally filed suit on the Moderate Area Plan on April 27, 1995. Amidst the discussions and litigationconcerning the approvability of the Plan, EPA reclassified the Maricopa County 

### PM,, Nonattainment Area to serious effective June 10, 1996,based upon its finding the area failed to attainthe PM,, NAAQS by the December 31, 1994,deadline. Later, on May 14, 1996,the Court of Appeals for the Ninth Circuit found that the Moderate Area Plan failed to address the 24-hour PM,, standard as required by the CAA 

### [Oberv.EPA, 84 F3d 304 (9th Cir. 1996)l. As a result, the Court mandated that EPA require "the State to submit a separate demonstrationof the implementationof all 'reasonably available control measures' targeting the 24-hour standard violations; attainment and 'reasonable further progress' for the 24-hour standard." In September 1996, in response to the Court's mandate, EPA and ADEQ agreed that ADEQ would submit a "Limited" Serious Area PM,, Plan to EPA by April 18, 1997 and a "Full" ADEQ ES-1 May 7,1997Serious Area Plan by December 10, 1997. The Microscale Study became the basis for this "Limited" Plan. The "Limited* Plan deadline was subsequently revised to May 9, 1997 (see Appendix 

### D, Marcus, 1996and 1997). The "Limited" Plan is required to: Address exceedances ofthe 24-hour NAAQS that 

### occurred at fivemoniton in 1995 during the PMlo Microscale Study. (East Chandler, West Chandler, Gilbert, Maryvale and SaltRiver); Document the development of emissions inventories and air quality modeling tl, quantify contributions of sources to the exceedances; Identify, document and evaluate all RACM, Best Available Control Measures 

### (BACM) and other controls to reduce emissions from the contributing sources; Demonstrate attainment of the 24-hour standardby application of RACM, BACM and other controls as soon as practicable but no later than December 31, 2001; The contained provisions for quantitative milestones to measure reasonable further progress, and

@ Include fully adopted and enforceable control measures with schedules for their implementation. Five sites were selected to characterize effects on PMloconcentrations from sources of fugitive dust emissions that are typical and located throughout the Maricopa Coun' PMloNonattainment Area. One site, East Chandler, was dropped from 

### the study due to lack of confidence 

### in the emissions inventory data. Modeling and data review of the results from the Microscale Study indicated that local fugitive PM,, emissions from sources such as earthmoving and windblown emissions from such sources as unpaved parking lots, agricultural areas, construction sites, disturbed open areas, and industrial sites arethe predominate causes ofexceedances of the 24-hour standard 

### in Maricopa County. Maricopa County's Rule 310 is applicable to the fugitive emission sources addressed in the Microscale Study. Strengthening the enforcement of Rule 3 10would be the logical first step inthe consideration ofpotential control measures. Additional RACM and BACM that address fugitive PM,, emissions must also be evaluated. The control measures that are identifiedto demonstrate attainment of the 24-hour standard at the microscale sites would be applied to similar sources throughoutthe Maricopa County PM,, Nonattainment Area to achieve compliance for the entire region. Proposed BACM to be adopted and implemented regionally to reduce emissions from sources 

# e( contributing to violations of 24-hour PMloNAAQS atthe four microscale sites are: May 7,1997Improvements to the Maricopa County Dust Control Plan checklist and guidelines to ensurethat dust control 

### is implemented at all times, even on weekends and prior to high wind conditions. IncreasedMCESD inspectionresources,to improve enforcementof Rule 310requirements for vacant 

### areas and unpaved roads and on weekends, as well 

### as for earthmoving projects. Development of a pilot program by MCESD for weekend inspection of fugitive dust sources. Revision of MCESD's "Guideline for Earthmoving Inspection Checklistn to include additional detail more closely following the revised Dust Control Plan. The standard operating procedure, Air Pollution Inspection Procedures has been revised to instruct stationary source inspectorsto review a source's dust control plan and inspect the fugitive dust sources to determine its compliance with Rule 

### 3 10. Designation of a staffperson by MCESD to interact with cities, towns and other agencies and be the lead coordinator for dust control. MCESD has developed a Rule 3 10training package. MCESD will initially offer training at least once per quarter, but may revise that schedulebased.upondemand. Training will begin 

### in June 1997. Participation by MCESD in a regional program with participation from the cities and other agencies within Maricopa County to identify ways to use existing City ordinances to increase enforcement on vacant lands and unpaved parking areas. This group will also work with Natural Resources Conservation Service (NRCS) to develop feasible control i measures for agriculture. 5 Development of a protocol to implement improved coordination among the cities and MCESD adoptedby cities in Maricopa County to improve dust control. The format ofthe agreement is a resolution adopted by the respective city councils. Pursuit of a Memorandum of Agreement by the NRCS, MCESD and ADEQ to establish a formal process 

### to address fugitive dust on agricultural land while refining the roles, 

# I objectives, and schedule of this partnering process. 

### In summary, proposed BACM strategies provide for attainment of the 24-hour PM,, NAAQS at two of the four sitesevaluated, Maryvale and Salt River site. The other two sites, West Chandler 

# 16 and Gilbert, were affected by significant contributions from agricultural sources and unpaved parking areas. Adequate control mechanisms to address these sources are currently under development.

May 7, 1997

### 3.0 

### RESULTS OF 

### MICROSCACE STUDY ADEQ conducted air quality modeling for the 

### 1995 exc-m &ys shown in Table 3-1 ~hh modeling process is described 

### as follows: Defining amicroscalemodeling domainfor eachmonitoring site. This domainwas a rectangular geographic 

### area that included all PM, emissions that were expected to have an identifiable impact. Characterizing the activities and diurnal profile of each source within each modeling domain. Estimating PM,, emissions from all sources within each microscale modeling domain. Using a "screening* 

### air quality model to estimate ambient PM,, impacts at the monitor from the sources in the modeling domain. Refining the definition of the modeling domainfrom examination of the screening results. This refinement frequently decreased the sizeof the domain. Evaluating and validating model performance for the design cases by comparing the modeled results with the monitored 24-hour PM,, concentration. Selecting a subset of days for each monitoring siteto serve as "design cases* for evaluation of additional control measures to reduce PM,, concentrations. Reviewing the modeling results for the design cases to identify the location within each microscale modeling doinain where the modeled PM,, concentration

### was the highest on each designday. The demonstration of attainment of the 24-hour PM,, standard requires that control measures be implemented to reduce the modeled concentrationat this 

### maximum concentration location to or below the level of the standard. This location was not always the location of the PM,, monitor. Therefore, the maximum value was sometimes higher than the monitored value. Determining, from the modeling, the contributionsof individual source categories to the maximum concentrations.

May 7, 1997

### 3.0 

### RESULTS OF

### MICROSCACE STUDY ADEQ conducted air quality modeling for the 1995exme shown 

### in Table 3-1. his modeling process is described 

### as follows: Defining a microscale modeling domain for each monitoring site. 

### This domain was a rectangular geographic 

### area that included 

### all PM, emissions 

### that were expected to have an identifiable impact. Characterizing the activities and diurnal profile of each source within each modeling domain. Estimating 

### PM,, emissions from all sources within each microscale modeling domain. Using a "screening" air quality model to estimate ambient 

### PM,, impacts at the monitor from the sources in the modeling domain. Refining the definitionof the modeling domain from examination of the screening results. This refrnement frequently decreased the size of the domain. Evaluating and validating model performance for the design cases by comparing the modeled results with the monitored 24-hour 

### PM,, concentration. Selecting a subset of days for eachmonitoring site to serve as "design cases" for evaluation of additional control measures to reduce 

### PM,, concentrations. Reviewingthe modeling results for the design cases to identify the location within each microscale modeling doinain where the modeled 

### PM,, concentration was the highest on each design day. The demonstrationof attainment of the 24-hour 

### PMlo standard requires that control measures be implemented to reduce the modeled concentration at this maximum concentration location to or below the level of the standard. This location was not always the location of the 

### PM1, monitor. Therefore, the maximum value was sometimes higher than the monitored value. Determining, from the modeling, the contributions of individual source categories to the maximum concentrations.

ADEQ 14 May 7,1997

### TABLE 3-1 24-Hour PM,, 

### Exceedances in 1995



# I West Chandler 

# I 4/9/95 

# I 462.5 

# 1

East Chandler

12/11/95

. . . . . .. ., . . . . . . . . . . . . .. , , . . .. ., . ., ,. ..... . .. . . . . . . . . , . . . . ., .. . . , . , . ::: ..: :;..,: :.> :..:...:.:.:. .::.....:.,. .. ., . . . . . ..... . . ... . , . ......... 156.5

,, . . . . , . , ........ :. ... ...................... ...........,....... >.....,... ................................. :. . :.:.:.:: ... :.::,:.,.:::<: ,,:::;j :.::?<::;:.

........................ ...................... :::: .'''

. ... .:+:... ' .. .... . . . .. . . . . .. .. . . . . . . .. . . . . . .. .. . . . . .. . . .. .. ., , .. . . . .. .::. . ... .. . . ......,,..,. , .,.,.........,., ..,, ..,:.*::::: ... . ..................... .. . . . .. .. ..:..:.

. ..'.'.

. . ..

.......................................

. . . .: . ::...:. ......
. . . . . . . . . . . .. . ,.. . ,. .,. ,., , , ,.... .. < ... ... ... .. ... , . . . . , . , ,.. .. , . .... . . ., . . . .. .,.;, . . . . , ,.,.......... : ,.. . ... .. .... . ... ,.. . .. . . . ... . . .. . . . . .... . .. ... .......... . . . . .,., ;,,
,E*ee&&e,,&$s &t~&.~&m~*.j,,'& ,wjj&i,@&,&'&g;;+,,;;, &: s$&;$&,iw 

### a?&$:;.,:;:,;:;::;;;;;;;, :,::;;;;;: 

### :::y :;::; 

### :,:;.;y: :.;;:;.;::; NOTE: The 24-hour PM,, NAAQS is 150 pg/m3- 6/28/95* 7/30/95*

Salt River

ADEQ 15 May 7,1997 160.0 251.7

8/3/95 6112/95 7120195

### * 7/26/95 8/1/95 169.3 165.4 166.3 165.2For a more detailed discussion of the methodology of how sources were inventoried and apportioned for the four sites, please refer to the Technical SupportDocument, 

### Appendix A. 3.1 

### Air Quality 

### Modeling 

### Results This section presents the modeling results and identifies control measures that could be implemented to reduce the modeled concentrations to or below the 150pg/m3level ofthe 24-hour PMloNAAQS. ADEQ selected the following design cases: October 16, 1995, at the Salt River monitoring site; and April 9, 1995, at the Gilbert, Maryvale and West Chandler monitoring sites. Tables 3-2 through 3-5 presentthe contributions of fugitive dust emission source categoriesto the 

### maximum modeled concentration within the modeling domains for each of the design cases along with ADEQ's estimate of the PM,, background concentration. The tables also indicate the estimated PMloemission control efficiency for each source category on the design day. The largest contribution at the Salt River site on October 16, 1995, was from earth moving activities during remediation work at the 19thAvenue Landfill. ADEQ's review of video tapes of operations at the landfill indicated that, although water was applied during the earthmoving activities, the amount was not adequate to wet the soil to the depth of cuts, so emissions from travel of scrapers over the freshly exposed surface was essentially uncontrolled. The April 9, 1995, design day was a Sunday, and most of the PMloemissions were caused by wind action on exposed, disturbed surfaces, when active operations were not taking place. The greatest contributionof emissions at the Gilbert site were windblowndustfromagricultural aprons (the land next to the agricultural fields generally used for travel of farm equipment), and unpaved parking and disturbed areas. At Maryvale, windblown dust from a city park construction area dominatedconcentrations. Windblown dust from an agricultural field was the greatest contributor at the west -Chandlersite, along with windblown dust fromnearby road construction, vacant land and agricultural aprons. 3.1.1. 

### East Chandler 

### Site Exceedances occurredon June 28 and July 30, 1995. No reliable information on emissions sources was found and no further evaluationwas conducted for those days. ADEQ 16 May 7,1997

### TABLE 3-2 Air Quality 

### Modeling Results 

### for Maximum 

### Concentration at Salt River Site on October 16,1995, Design 

### Day

ADEQ 17 May 7, 1997 

### Contributionto PM,, Concentration (dm3) 10.4 2.4 2.7 1



### .O 50.8

3.6 0.3 

### 5.1 

### 0.1 12.6 

### 89.0 78.3 

### 167.3 Source Category Estimated PM,, Control Efficiency on Design 

### Day Industrial haul roads Industrial yards Surface mining Other industrial activities Earth moving Paved roads Trackout Unpaved roads Paved parking lots Unpaved parking areas 

### Total Background 

### Total with Background 

### 50% 

### 50% 

### 10% 

### 50% 

### 10% 0% 95% 

### 0% 0% 0%

### Air 

### QualityModelin

Source Category Agricultural aprons Disturbed areas Unpaved parking areas Unpaved roads Paved roads 

### Total Background 

### Total with Background TABLE 

### 3-3 

## : Results for Maximum Concentration

### at GiIbert 

### Site on April 9,1995, 

### Design Day

Estimated PMloControl Contributionto 

### PM,, Efficiency on Design Day

. 

### Confearstion Ipg/m? 0% 55.6 0% 14.2 0% 51.3



### TABLE 3-4 Air Quality Modeling Results for Maximum Concentration at Maryvale Site on April 9, 1995, 

### Design Day Source Category Disturbed cleared areas (city park construction) Paved roads - 

### Estimated PMloControl Contribution to PM, Efficiency on Design Day Concentration (Icg/m3) 0% 414.3
0% 2.6 Unpaved roads 

### Total 0% 0.1 417.0 Background

May 7,1997 90.0 

### Total with 

### Background 507.0

### TABLE 3-5 Air Quality 

### Modeling Results 

### for 

### Maximum Concentration at West 

### Chandler Site on April 

### 9, 

### 1995,Design 

### Day

May 7,1997 

### ContributiontoPM,, 

### Concentration 

## - @g/m3) 

### Source Category Estimated PM,, 

### Control Efficiency on 

### DesignDay Agricultural fields Vacant land 

# . Agricultural aprons Road construction Paved roads Unpaved roads 

### Total Background 

### Total with 

### Background

> 

### 0% 0% 0% 0% 0% 0% 194.7 28.1 21.7 68.7

0.2 

## - 0.5 313.9



### 80.0 

### 393.9