## 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 EnvironmentalHealth ServicesOn 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 ofthe comments and responses are included below. Maricopa County suggested that GRIC revise the Table of Contents to ensure that the
name ofthe Part listed in the Table of Contents match the heading in each ofthe Parts throughout the document. The GRIC Air Program will review and revise headings and Table of Contentsas appropriate.

The format ofthe 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 revisingPart I, Section2.3 "Incorporated Materials" to include a revised date for referencing amended provisions of 40 Code ofFederal Regulations. The Air Program will revise this sectionfrom July 1,2001to May 13, 2005. In addition, the Air Program will include references to the new 40 CFR's promulgated up to May 13,2005in sections 7 and 8 ofPart 11. Maricopa County personnel suggested that GRIC change the adoption date in Part 11, Section7.1 (B) from November 1,2004to a more current date and include all the New SourcePerformance 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 federalregister notice that applies to medical waste incineratorsand not a federal rule. The GRIC Air Program will delete Part 11, Section 7.1 (B) (9). Maricopa County personnel suggestedthat GRIC change the adoption date in Part 11, Section 8.

### I (A) and (B) from November 1,2004to a more current date and include all the National Emissions Standardsfor 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 ofMay 13,2005and 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, Storageand Handling ordinance) and Section 3.0 (Degreasing and Solventmetal Cleaning ordinance), to include the recently revised EPA definition ofVolatile OrganicCompound (VOC). The GRIC Air Program will replace the definitionof 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 suggestedthat GRIC revise Part VI, Section 2.0 (VOC Usage, Storageand Handling ordinance),Section 3.0 (Degreasingand SolventMetal Cleaningordinance) and Part VII, Section 2.0 (Aerospace Manufacturingand Rework Operations), to include the revised definitionofNon-Precursor Organic Compound which includes exclusionspromulgated by EPA on November 29,2004. The GRIC Air Program will replace the definition ofNon-Precursor Organic Compound in the draft VOC Usage, Storage and Handling ordinance,the Degreasing and Solvent Metal Cleaningordinance and the Aerospace Manufacturing and Rework Operations ordinance with the updated EPA definition. Maricopa County suggests adding test method language to Subsection 5.0, ofPart VII, Section 2.0 for determiningVOC content in coatings. The GRIC Air Program will include the following language, "Coatings: The VOC content of coatings (lesswater and less nonprecursor organic compounds) as applied shall be determinedby manufacturer's supplieddata or Method 24 of40 CFR part 60, Appendix A. If there is a discrepancy between the manufacturer's formulationdata and the results ofthe 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 addedto the revised MaricopaCounty Rule 3 16 to meet the Salt River SIP requirementsbecause monitoring indicatesa direct contribution to violations ofthe NAAQS fromNon-Metallic Mineral Mining operations in the SaltRiver area. Since GRIC is a rural Communityvery different fromthe Maricopa County metropolitan area and monitoring does not indicate any impact on the NAAQS from particulatematter emissions generated by Non-metallic mineral mining operations at GRIC, the Community does not see any air pollution benefit from implementingthis 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 1.0add Prohibitions (e.g.,no cutback asphaltic materials, No off specification fuels) 

# + 2.15 Elaborate on definition of "Fugitive emission"



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

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

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

# + 3.2 A. Applicability

### - Mineral filler shouldbe changedtoread "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 ofmixes (asphalt) 

# + 5.1 

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

# + 5.2 Add "in accordance with the provisions of40 CFR, Part 60, AppendixA"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 consultantsfor 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 operatorsbut one landownerllease? GRIC answered that each operatormust acquiretheir 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 10years 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 separatetheir operations from those of United Metro so that they are not responsible for any violations that may occur from operation ofUnited Metro's facilities. 

# + GRIC DEQ personnel requested a tour ofthe facility. Conductedthe tour on 7/29/03.Thermo Rock (Robin Torro 

### Mgr) 

# + Robin indicated that they were in the process ofpainting 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 requirementto documentpressure drop readings every hour. She indicated that this would be very burdomsome and recommended changingthe requirementto onceper 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 explainedto Robinthat 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 facilitywas close to the major source threshold and that it was in her best interest to accurately document throughputto 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 supplythe log sheets and would sent an application for submittingan 

### 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 SuperliteBlock personnel, I explainedthe ordinance and TIP and they indicated that they briefly reviewed the ordinancebut would like to review it further and submit written comments. They did have some immediate comments. 

# + They had a question about documentingpressure drop every hour and indicatedthat 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 ofthe silos. Theyrecommended that we clarify this requirement in the ordinance.

4 They recommended that we clarifjl which baghouses needed to be performance tested and the frequencyofthe 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 Superlitepersonnel 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 equippedwith 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 ofthe facility with several silos being located on the west side of the property. United Metro (Archer Shelton)

4 Archer recommendedthat the ordinance explain performance testing frequencies and indicatedthat the testing requirements should not apply to the passive baghouseson 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 100,000tonslyr and once every three years for less than 100,000tonslyr.

4 No problem with documentingpressure drop every hour but consider allowingVE 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 everypermit term (every 5 yrs).

4 Mr. Shelton recommended revisionsto section 6.1A. 1.c. to read "Summary of throughputper month ofbasic raw materials" etc.

4 Recommended revisionsto section 6.1 A. 1. d. to read "Volume of concrete andlor weight of aggregate and asphalt products produced per day"

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

4 Recommended revisionsto section 6.1A. 2. a. to include an exclusion of hourly manometer readings for passive baghouses (silo). Possibly revise the definitionof baghouse to exclude bin vent or silobaghouse.

4 Recommended revisions to section 6.1 C.

### to read Syearsrather than 10years.

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

-- 4 Recommended adding an explanation ofthe frequency for conductingperformance test to section 7.2.

4 Mr. Shelton also made several recommendationsto the 

### TSD for

### NMMM.