Summary of Comments and Responses on the GRIC TIP 

submitted by Maricopa County Environmental Health Services 

The GRIC DEQ Air Quality personnel met with the new Director and personnel from 

Maricopa County Environmental Health Services On June 28,2005 to gather comments 

on the GRIC TIP. Maricopa County Air Quality personnel reviewed the proposed GRIC 

TIP and provided numerous comments on the ordinances. A summary of the comments 

and responses are included below. 

Maricopa County suggested that GRIC revise the Table of Contents to ensure that the 

name of the Part listed in the Table of Contents match the heading in each of the Parts 

throughout the document. The GRIC Air Program will review and revise headings and 

Table of Contents as appropriate. 

The format of the heading in Part I should be revised to match the heaQngs in Parts IIVII. Air quality personnel will review and revise as appropriate. 

The County suggested several grammatical and format revisions throughout the TIP 

ordinances. The Air Program will review and revise the TIP as appropriate. 

Maricopa County suggested revising Part I, Section 2.3 "Incorporated Materials" to 

include a revised date for referencing amended provisions of 40 Code of Federal 

Regulations. The Air Program will revise this section from July 1,2001 to May 13, 

2005. In addition, the Air Program will include references to the new 40 CFR's 

promulgated up to May 13,2005 in sections 7 and 8 of Part 11. 

Maricopa County personnel suggested that GRIC change the adoption date in Part 11, 

Section 7.1 (B) from November 1,2004 to a more current date and include all the New 

Source Performance Standards (NSPS) in 40CFR, Part 60. The GRIC Air Program will 

revise Section 7.1 (B) to include the adoption date of May 13, 2005 and include any new 

NSPS provisions or any provisions that were not included in the draft Part 11, Section 7.0. 

Maricopa County also recommended deleting Part 11, Section 7.1 (B) (9) since it is a 

federal register notice that applies to medical waste incinerators and not a federal rule. 

The GRIC Air Program will delete Part 11, Section 7.1 (B) (9). 

Maricopa County personnel suggested that GRIC change the adoption date in Part 11, 

Section 8. I (A) and (B) from November 1,2004 to a more current date and include all the 

National Emissions Standards for Hazardous Air Pollutants (NESHAPs) in 40CFR, Parts 

61 and 63. The GRIC Air Program will revise Section 8.1 (A) and (B) to include the 

adoption date of May 13,2005 and include any new NESHAPSs provisions or any 

provisions that were not included in the draft Part 11, Section 8.0. 

Maricopa County personnel suggested that GRIC revise Part VI, Section 2.0 (VOC 

Usage, Storage and Handling ordinance) and Section 3.0 (Degreasing and Solvent metal 

Cleaning ordinance), to include the recently revised EPA definition of Volatile Organic 
Compound (VOC). The GRIC Air Program will replace the definition of VOC in the 

draft VOC Usage, Storage and Handling ordinance and the Degreasing and Solvent Metal 

Cleaning ordinance with the updated EPA definition. 

Maricopa County personnel suggested that GRIC revise Part VI, Section 2.0 (VOC 

Usage, Storage and Handling ordinance), Section 3.0 (Degreasing and Solvent Metal 

Cleaning ordinance) and Part VII, Section 2.0 (Aerospace Manufacturing and Rework 

Operations), to include the revised definition of Non-Precursor Organic Compound 

which includes exclusions promulgated by EPA on November 29,2004. The GRIC Air 

Program will replace the definition of Non-Precursor Organic Compound in the draft 

VOC Usage, Storage and Handling ordinance, the Degreasing and Solvent Metal 

Cleaning ordinance and the Aerospace Manufacturing and Rework Operations ordinance 

with the updated EPA definition. 

Maricopa County suggests adding test method language to Subsection 5.0, of Part VII, 

Section 2.0 for determining VOC content in coatings. The GRIC Air Program will 

include the following language, "Coatings: The VOC content of coatings (less water and 

less nonprecursor organic compounds) as applied shall be determined by manufacturer's 

supplied data or Method 24 of 40 CFR part 60, Appendix A. If there is a discrepancy 

between the manufacturer's formulation data and the results of the Method 24 analysis, 

compliance shall be based on the results from the Method 24 analysis. For waterborne 

(water-reducible) coatings, only manufacturer's supplied data can be used to determine 

the VOC content of each formulation". 

Maricopa County recommends adding a fence line standard to Part VII, Section 3.0 

(Nonmetallic Mineral Mining ordinance). This requirement was added to the revised 

Maricopa County Rule 3 16 to meet the Salt River SIP requirements because monitoring 

indicates a direct contribution to violations of the NAAQS from Non-Metallic Mineral 

Mining operations in the Salt River area. Since GRIC is a rural Community very different 

from the Maricopa County metropolitan area and monitoring does not indicate any 

impact on the NAAQS from particulate matter emissions generated by Non-metallic 

mineral mining operations at GRIC, the Community does not see any air pollution benefit 

from implementing this requirement. If future conditions change at GRIC and emissions 

from Non-Metallic Mineral Mining do begin to show an impact, GRIC may revise the 

ordinance to include a fence line standard. 
Summary of Comments from Outreach Efforts on the 

Draft Non-metallic Mineral Mining Ordinance 

Rock Solid Meeting (Craig Tanner GM) 

+ 1.0 Applicability (Per DEQ) After section 1.0 add Prohibitions (e.g., no cutback 

asphaltic materials, No off specification fuels) 

+ 2.15 Elaborate on definition of "Fugitive emission" 

+ 3.1 A. 5 Add "Any other operation or source" after or crusher 

+ 3.1 C Add Rock Solids control system (e.g., Sprinklers on stock piles) 

+ 3.1 C Add "Except for wet products with sufficient moisture control to prevent dust" 

+ 3.2 A. Applicability - Mineral filler should be changed to read "add mixture or Lime 

and flyash" 

+ 3.2 A Delete "rule" in the applicability section 

+ 3.4 A Last sentence add "or NSPS" after Rule E Section 1.0 

+ 4.0 Rock Solid personnel asked if an O&M plan was required for the small 

baghouses on their fly ash and cement silos. GRIC personnel respondes "yes" 

+ 4.1 A End of Paragraph per DEQ change language to read "or required by an air 

pollution control permit" 

+ 5.1 Change 10 years to 5 years 

+ 5.1 B 1, d) Change to state "Volume and mass of raw materials used to make final and 

intermediate products produced per day, deliveredlday, volume of mixes (asphalt) 

+ 5.1 B 1. h) Delete "For dry mix concrete plants:" 

+ 5.2 Add "in accordance with the provisions of 40 CFR, Part 60, Appendix A" 
Gila River Sand and Gravel (Tony Enos, Llyn Fulmer, GM and Board members) 

+ Met with the Gila River Sand and Gravel Board to discuss the proposed ordinance on 

March 17,2003. 

+ Can we provide a list of consultants for due diligence when they take over additional 

facilities (e.g. United Metro and future plant on the west side) -possible-will check. 

+ board requested a copy of the Compliance and Enforcement policy and the Med Waste 

ordinance for the purpose of reviewing the administrative procedures. 

+ The board indicated that there may be additional tenants in the future not just United 

metro. 

+ How will GRIC DEQ handle permitting with two different operators but one 

landownerllease? GRIC answered that each operator must acquire their own permits and 

be responsible for their respective operations (e.g. stockpiles, vehicle traffic). 

+ How will GRIC DEQ handle portable hot plants? Recommended that GRIC DEQ add 

language for hot plants. 

+ Do GRIC Sand and Gravel personnel have to get opacity training? Responded "Yes". 

Can GRIC S&G get a reduced rate and a training at GRIC? 

+ Recommended that the record retention time frame of 10 years be changed to 5 years 

(same as permit). 

+ Llyn Fulmer asked GRIC DEQ to ensure that they are kept informed on all aspects of 

compliance and enforcement. Please don't surprise them. If they are informed of any 

problems they will correct the problem if given a chance. GRIC DEQ informed them 

that the DEQ is committed to worlung with them through compliance assistance. 

+ GRIC S&G asked that we separate their operations from those of United Metro so that 

they are not responsible for any violations that may occur from operation of United 

Metro's facilities. 

+ GRIC DEQ personnel requested a tour of the facility. Conducted the tour on 7/29/03. 
Thermo Rock (Robin Torro Mgr) 

+ Robin indicated that they were in the process of painting the duct work per a requirement 

of the Lone Butte Industrial Park. 

+ Robin indicated that they did install a new baghouse. 

+ Robin indicated that she had not reviewed the ordinance thoroughly but did have some 

comments. 

+ Robin questioned the requirement to document pressure drop readings every hour. She 

indicated that this would be very burdomsome and recommended changing the 

requirement to once per shft. I indicated that we were reviewing this requirement. 

+ Robin asked how often they would be required to test the baghouses. I indicated that we 

were looking into inserting the frequency for testing in the ordinance (e.g., every 5 yrs). 

+ Robin asked if every baghouse needed to be tested and recommended that a size cutoff 

be established for testing. 

+ I explained to Robin that their permit would be based ontheir emissions and that she 

needed to keep good records of all the material brought into the facility, total sweeps 

shipped offsite as waste, and total product shipped. I indicated that her facility was close 

to the major source threshold and that it was in her best interest to accurately document 

throughput to document that they were not above the major source threshold. She also 

indicated that the operate 24 hrs per day. I informed her that fugitive emissions will be 

added when calculating their emissions. 

+ Robin requested copies of log sheets for documenting pressure drop on the baghouses 

and copies of O&M plan requirements. I indicated that we could supply the log sheets 

and would sent an application for submitting an O&M plan. 

+ We conducted a quick tour and observed that several baghouses either did not have 

magnehelic gauges or the gauges were inoperable. Emissions were observed from one of 

the baghouses. 

Superlite Block Company ( ) 

+ We met with Superlite Block personnel, I explained the ordinance and TIP and they 

indicated that they briefly reviewed the ordinance but would like to review it further and 

submit written comments. They did have some immediate comments. 

+ They had a question about documenting pressure drop every hour and indicated that they 

had no problem with documenting pressure drop every hour on the two big baghouses but 

didn't think this was necessary for the two passive baghouses on top of the silos. They 
recommended that we clarify this requirement in the ordinance. 

4 They recommended that we clarifjl which baghouses needed to be performance tested 

and the frequency of the testing. (e.g., annually or once per permit term.) 

4 They questioned whether a VE certified person needed to be onsite at all times and what 

the frequency for conducting VE's will be. I indicated that we would clarify both these 

issues in the ordinance. 

4 Superlite personnel also recommended that the record retention period be changed to 5 

years from 10 years. 

4 We conducted a tour and observed two separate operations (bagging and block 

manufacturing). The bagging operation is equipped with a rotary kiln (dryer) to dry 

aggregate before it is bagged as premix concrete and a large baghouse. The actual 

bagging operations also is equipped with a baghouse. The block process is located in the 

back of the facility with several silos being located on the west side of the property. 

United Metro (Archer Shelton) 

4 Archer recommended that the ordinance explain performance testing frequencies and 

indicated that the testing requirements should not apply to the passive baghouses on the 

cement and flyash silos. 

4 Define where the Method 9 readings are to be conducted (e.g., baghouse stack, silo, 

transfer points etc.) While in operation. 

4 Archer indicated that the state requires annual performance testing on hot plants with 

capacity of 100,000 tonslyr and once every three years for less than 100,000 tonslyr. 

4 No problem with documenting pressure drop every hour but consider allowing VE 

reading every hour in lieu of manometer readings every hour. Manometer read 

documentation requirement should not apply to passive baghouses (silos). 

4 Archer indicated that Maricopa County required performance testing every permit term 

(every 5 yrs). 

4 Mr. Shelton recommended revisions to section 6.1 A. 1. c. to read "Summary of 

throughput per month of basic raw materials" etc. 

4 Recommended revisions to section 6.1 A. 1. d. to read "Volume of concrete andlor 

weight of aggregate and asphalt products produced per day" 

4 Recommended revisions to section 6.1 A. 1. e. to read "Weight of aggregate" 
4 Recommended deleting "heating value data" not useful. 

4 Recommended revisions to section 6.1 A. 2. a. to include an exclusion of hourly 

manometer readings for passive baghouses (silo). Possibly revise the definitionof 

baghouse to exclude bin vent or silo baghouse. 

4 Recommended revisions to section 6.1 C. to read Syears rather than 10 years. 

4 Recommended adding an explanation of the frequency for conducting VEs to section 7.1 

- - 

4 Recommended adding an explanation of the frequency for conducting performance test 

to section 7.2. 

4 Mr. Shelton also made several recommendations to the TSD for NMMM.