Revised PM10 State Implementation Plan for the Salt River Area Technical Support Document AIR QUALITY DIVISION ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY June 2005 TABLE OF CONTENTS CHAPTER 1: CHAPTER 2: CHAPTER 3: CHAPTER 4: INTRODUCTION 1.1 Overview 1-1 1.2 The General Nature of Particulate Matter 1-2 1.3 Particulate Matter Concentrations in Metropolitan Phoenix 1-4 1.4 PM10 Trends in the Salt River Study Area: 1994-2002 1-6 AMBIENT AIR QUALITY DATA 2.1 Ambient Air Quality in 2002 2-1 2.2 Intensive Air Pollution Monitoring: Instruments and Sites 2-1 2.3 Study Period and Annual Statistics 2-3 2.4 Hourly Variation of PM10 by Site 2-4 2.5 Seasonal Variation of PM10 2-8 2.6 Conclusions 2-10 REPLACEMENT OF SALT RIVER MONITOR 3.1 Characteristics of the Salt River Site 3-1 3.2 rd Characteristics of the new West 43 Avenue Site 3-5 3.3 rd 3-8 Comparison of West 43 Avenue and Salt River PM10 SALT RIVER PM10 EMISSIONS INVENTORY 4.1 Introduction 4-1 4.2 Overview of Methodology 4-2 4.2.1 Satellite Image Analysis 4-3 4.2.2 Fugitive Dust Study 4-4 4.3 Development of 24-Hour Emissions Inventory 4-8 4.3.1 Paved Roads 4-8 4.3.1.1 Interstate 17 4-8 4.3.1.2 Primary Paved Roads 4-9 4.3.1.3. Secondary Paved Roads 4-12 4.3.2 Unpaved Shoulders 4-12 4.3.3 Trackout Onto Paved roads 4-13 4.3.4 Unpaved Roads and Unpaved Parking Lots 4-15 4.3.4.1 Unpaved Roads 4-15 4.3.4.2 Unpaved Parking Lots 4-15 4.3.5 Wind Erosion of Disturbed Areas 4-17 4.3.6 Agricultural Tilling 4-20 4.3.7 Agricultural Harvesting 4-22 4.3.8 Construction Activity 4-22 4.3.8.1 Road Construction 4-22 4.3.8.2 Residential and Industrial Construction 4-22 ii CHAPTER 5: 4.3.9 Lawn Care 4-24 4.3.10 Restaurant Charbroilers 4-25 4.3.11 Industrial Sources 4-26 4.4 Summary of 2002 PM10 Emissions Inventory 4-28 4.5 Projected Year 2006 Base Case Emissions 4-42 4.6 Conclusions 4-52 4.7 References 4-53 AIR QUALITY MODELING 5.1 Introduction 5-1 5.1.1 5-3 5.2 Design Day Selection 5-6 5.3 Emissions Inventory 5-6 5.4 Meteorological Data 5-8 5.5 Modeling Method 5-8 5.5.1 5.6 CHAPTER 6: Summary of Results and Modeling Methods Model Performance 5-10 Boundary Concentrations and Urban Background 5-19 5.6.1 PM10 Measurements at the Boundaries 5-19 5.6.2 Calculation of Boundary Values 5-19 5.6.3 Summary of Background Calculations 5-24 2006 PREDICTED CONCENTRATIONS AND CONTROLS 6.1 Emission Changes Between 2002 and 2006 and Their Air Quality Consequences 6-1 6.2 Emission Reduction to Meet the Standard and Background 6-2 6.2.1 Necessary Emission Reductions to Meet the Standard 6-2 6.2.2 Urban Background – The Irreducible Portion 6-4 6.2.3 Future Background Concentrations 6-8 6.3 Significant Sources of PM10 6.4 Emission Reduction for Attainment 6-12 6.4.1 Summary 6-12 6.4.2 Additional Controls 6-12 6.5 6-9 Demonstration of Attainment 6-25 rd 6.5.1 West 43 Avenue on April 15 and April 26, 2002 6.5.2 Other High Wind Exceedances: Durango Complex and Salt River on April 15 and April 26, 2002 6.6 CHAPTER 7: 6-25 6-28 6.5.3 Low Wind Exceedances on January 8 and December 16, 2002 6-34 6.5.4 Summary of Predicted Concentrations 6-36 6.5.5 Attaining The PM10 Standard - Conclusions 6-40 References 6-39 SALT RIVER PM10 ANALYSIS – CONCLUSIONS iii 7-1 A-1 APPENDICES: Appendix A – MAPS A-1 Appendix B - GLOSSARY OF TERMS B-1 Appendix C - AVERAGE DAILY TRAFFIC C-1 Appendix D - TRACKOUT STUDY D-1 Appendix E - ALLUVIAL CHANNEL STUDY E-1 Appendix F - AGRICULTURAL HARVEST AND TILLAGE F-1 Appendix G - INDUSTRIAL POINT AND AREA SOURCES G-1 Appendix H - SITE VISITS H-1 Appendix I - MCESD RULE EFFECTIVENESS STUDY I-1 Appendix J - MARICOPA COUNTY PM10 MONITORS J-1 Appendix K - METHODOLOGY FOR WEIGHTING TRACKOUT EMISSIONS K-1 Appendix L - STREET SWEEPING REDUCTIONS L-1 Appendix M - EMISSION DENSITY MAPS OF BACKGROUND M-1 Appendix N - WIND ROSES N-1 Appendix O - MODEL MEASUREMENT COMPARISON O-1 Appendix P - MAPPING WEIGHTED TRACKOUT EMISSIONS INTO PREDICTED CONCENTRATIONS P-1 Appendix Q - PROJECTED CONSTRUCTION ACTIVITY Q-1 Appendix R - VACANT LOT SURVEY R-1 Appendix S - INDUSTRIAL AREA EMISSIONS S-1 Appendix T - POTENTIAL CONTROL MEASURES FOR AREA SOURCES FOR SALT RIVER PM10 SIP T-1 Appendix U – UNPAVED ROAD SHOULDER EMISSIONS U-1 iv LIST OF TABLES Table 1-1 PM10 Concentrations in Metropolitan Phoenix for 2002 1-5 Table 1-2 Number of 24-Hour Exceedances per Year 1-7 Table 2-1 Intensive Study Monitoring Sites 2-1 Table 2-2 Intensive Study: Instruments and Operating Frequency 2-2 Table 2-3 Study-period PM10 Statistics 2-3 Table 2-4 Peak Hourly PM10 Values 2-7 Table 3-1 Salt River Site PM10 (1994-2002) Hi-volt Data 3-1 Table 4-1 Freeway Emission Factors for Durango Curve 4-9 Table 4-2 Trackout and Emission Factors 4-13 Table 4-3 Salt River PM10 Emissions Inventory – Year 2002; Land Use Totals 4-29 Table 4-4 Salt River PM10 Emissions Inventory – Year 2002; Emission Factors and Rule Effectiveness 4-31 Table 4-5 Salt River PM10 Emissions Inventory – Year 2002; Emission Totals 4-35 Table 4-6 Change in Emissions Between Year 2002 and 2006 (Base Case) Percent 4-44 Table 4-7 Salt River PM10 Emissions Inventory – Base Case 2006 4-45 Table 5-1 PM10 Exceedances in the Maricopa PM10 Nonattainment Area for 2002 th 5-7 Table 5-2 Meteorological Data File used for January 8 Modeling 5-8 Table 5-3 Source Categories Contributing Emissions for the Four Design Days 5-9 Table 5-4 Wind Data for December 16, 2002 5-13 rd Table 5-5 Wind Data for April 15, 2002 (from West 43 Avenue) 5-14 Table 5-6 Predicted Concentrations for Monitoring Sites 5-17 Table 5-7 Model Performance: Average Predicted PM10 Concentrations 5-18 Table 5-8 Boundary Wind Directions 5-20 rd Table 5-9 Boundary PM10 Concentrations Ratioed with West 43 Avenue PM10 Concentrations 5-23 Table 5-10 PM10 Background Concentrations 5-24 Table 6-1 Salt River PM10 Study Area Background Reductions from Area Wide Controls 6-3 Table 6-2 Background PM10 Concentrations on Exceedance Days in 2002 6-5 Table 6-3 Salt River PM10 Attainment Demonstration with Background Concentrations that have no Credit for Area-Wide Emission Reductions 6-6 Table 6-4 Salt River PM10 Attainment Demonstration with Background Concentrations that have Credit for Area-wide Emission Reductions which Accounts for the Rural Background (or Irreducible) Portion of the Metropolitan PM10 Loading 6-7 Table 6-5 Salt River PM10 Attainment Demonstration with Background Concentrations that have full Credit for Area-Wide Emission Reductions, with no Accounting for the Irreducible Portion of the Metropolitan Background Salt River PM10 Study Area Background PM10 Concentrations and their Response to Anticipated Urban-wide Emission Reductions by 2006 (Units are µg/m3, 24-hour Averages) Table 6-6 Table 6-7 Reductions of Emissions Necessary to Meet the Standard for Eight Salt River PM10 Exceedances v 6-7 6-8 6-9 Table 6-8 Predicted Significance Concentrations in µg/m3 from Emission Source Categories to the Eight exceedances of PM10 in the Salt River Study Area in 2002 (µg/m3) 6-11 Table 6-9 Salt River PM10 Study Area Exceedances and Attainment Status in 2006 6-12 Table 6-10 PM10 Percentage Emission Changes in the Salt River Study Area from 2002 to 2006 for the Base and Attainment Cases (A Negative Sign Means a Reduction; Positive Means an Increase) 6-13 Table 6-11 PM10 Emissions from Unpaved Road Shoulders 6-19 Table 6-12 Salt River PM10 Emissions Inventory – Year 2006 Attainment Case (Metric Tons / Day) 6-23 Table 6-13 3 Base Case - Predicted Concentrations in µg/m from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 6-37 Table 6-14 Attainment Case - Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 6-38 Table D-1 Silt Loading D-6 Table D-2 Trackout and Emission Factors D-8 Table F-1 Year 2002 Crop Calendar for Salt River PM10 Study Area F-4 Table F-2 Agriculture Tilling Days in Salt River PM10 Study Area F-6 Table F-3 Conversion of Agricultural Land to Residential and Commercial Uses Table G-1 Durango PM10 Monitor G-2 Table G-2 Salt River PM10 Monitor G-3 Table G-3 South Phoenix PM10 Monitor G-4 rd F-13 Table G-4 West 43 Avenue PM10 Monitor G-4 Table G-5 Maricopa County Industrial Sites in Salt River PM10 Study Area - Year 2001 PM10 Emissions Industrial Sources which will be Treated as Point Sources in Modeling G-6 Table G-6 Maricopa County Industrial Sites in Salt River PM10 Study Area - Year 2001 PM10 Emissions Industrial Sources which will be Treated as Area Sources in Modeling G-9 Table J-1 1994 PM10 Monitoring Data Summary (µ/m3) J-1 Table J-2 Table J-3 3 J-2 3 J-3 3 1995 PM10 Monitoring Data Summary (µ/m ) 1996 PM10 Monitoring Data Summary (µ/m ) Table J-4 1997 PM10 Monitoring Data Summary (µ/m ) J-4 Table J-5 1998 PM10 Monitoring Data Summary (µ/m3) J-5 Table J-6 3 J-6 3 1999 PM10 Monitoring Data Summary (µ/m ) Table J-7 2000 PM10 Monitoring Data Summary (µ/m ) J-7 Table J-8 2001 PM10 Monitoring Data Summary (µ/m3) J-8 Table J-9 3 2002 PM10 Monitoring Data Summary (µ/m ) J-9 vi Table K-1 Trackout Survey Summary K-1 Table K-2 Trackout Survey of May – June 2004: Salt River PM10 Study Area K-2 Table K-3 Silt Loading Values by Source Category K-6 Table K-4 Silt Loading Measurements in the Salt River PM10 Area from 2003 K-6 Table K-5 Silt Loading Measurements in Tucson and Phoenix from the Mid 1980s K-7 Table K-6 Reentrained Emission Rates for Six Trackout Source Categories K-8 Table K-7 Reentrained Emission Rates K-9 Table K-8 Trackout from Six Source Categories Weighted by Length and Severity K-9 Table K-9 Total Length of Trackout by Source Category Table L-1 Reentrained Road Emissions with Sweeping Once Every Two Weeks L-2 Table L-2 Reentrained Road Emissions with Sweeping Once a Week L-3 Table L-3 Reentrained Road Emissions with Sweeping Three Times a Month L-4 Table L-4 Salt River PM10 Study Area Roads Subject to Additional Sweeping L-5 Table L-5 Calculation of Reentrained Emissions for the Salt River PM10 Study Area L-8 Table M-1 Urban-wide PM10 Emissions M-2 Table M-2 Number of Grid Cells with a Specified Emission Range by Zone M-9 Table M-3 Calculation Table for Emissions by Zone, Percent, and Weighted Percent: Urban Background Adjustment Table N-1 Salt River PM10 Study Area Sites with Meteorological Data Table O-1 Regression Statistics O-13 Table O-2 Background Concentrations for April 15, 2002 O-15 Table P-1 Trackout from Six Source Categories Weighted by Length and Severity P-1 Table P-2 Industrial Source Complex Predicted Concentrations of PM10 from Six Types of Trackout for the Eight Exceedances in 2002 in the Salt River Study Area (µg/m3) P-2 Table P-3 Industrial Source Complex Predicted Concentrations of PM10 from Six Types of Trackout for the Eight Exceedances in 2002 in the Salt River Study Area – Weighted by Length and Severity (µg/m3) P-2 Table R-1 Dust Potential R-1 2 K-10 M-10 N-1 Table R-2 Size of Vacant Lot (Grid Cell = 400 x 400 m ) R-1 Table R-3 Vacant Lot Field Survey R-2 Table R-4 Number of Vacant Lots and Misc. Disturbed Areas Less Than 1/10 Acre R-6 Table S-1 Salt River Study Area Throughput for Large Stationary Sources in 2002 S-2 vii Table S-2 Salt River PM10 Area Throughput for the 12 Largest Facilities: 2002 - 2004 S-3 Table S-3 Base Case Industrial Area Emissions of PM10 in 2002 S-6 Table S-4 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Two Low-wind Exceedances of PM10 in the Salt River Study Area in 2002 with Base Case Industrial Area Emissions S-7 Table S-5 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Two Low-wind Exceedances of PM10 in the Salt River Study Area in 2002 with Industrial Area Emissions Increased 23% S-7 Table S-6 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Two Low-wind Exceedances of PM10 in the Salt River Study Area in 2002 with Industrial Area Emissions Increased 45% S-8 Table S-7 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Two Low-wind Exceedances of PM10 in the Salt River Study Area in 2002 with Industrial Area Emissions Increased 68% S-8 Table S-8 Summary of Industrial Area Source Concentrations and Percentages of the Total Concentration for the Base Case Emissions and Increases of 23, 45, and 68% on Two LowWind Days in Salt River Study Area in 2002 S-9 Table S-9 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 -- Attainment case, Corrected on November 22, 2004 S-15 Table S-10 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 -- Attainment Case corrected on November 22, 2004, with 23% increase in Large Industrial Area Emissions S-16 Table S-11 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 -- Attainment case Corrected on November 22, 2004, with a 45% increase in Industrial Area Emissions S-17 Table S-12 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 -- Attainment Case Corrected on November 22, 2004, with a 68% Increase in Industrial Area Emissions S-18 Table S-13 Predicted PM10 Concentrations for the 2006 Attainment Case, with Three Increases in the 2002 Industrial Area Emissions S-19 Table U-1 Unpaved Road Shoulder Emissions (Metric Tons PM10 / Day) U-1 Table U-2 Comparison of Predicted Ambient PM10 Levels (µg/m3) Before and After Including Additional Emissions from Unpaved Road Shoulders on Low-Wind Days U-2 Table U-3 Comparison of Predicted Ambient PM10 Levels (µg/m3) Before and After Including Additional Emissions from Unpaved Road Shoulders on High-Wind Days U-2 viii LIST OF FIGURES Figure 1-1 Salt River – 24 Hour Maximum 1-6 Figure 1-2 24-Hour Maximums at Durango and Salt River Monitors 1-7 Figure 1-3 Histogram of PM10 at Salt River Monitor (1994 – 2002) 1-8 Figure 1-4 24-Hour Average PM10 Trends 1994-2002 at Salt River Site 1-8 Figure 2-1 Diurnal Variation of PM10 at Salt River Monitor April-December 2002 2-5 Figure 2-2 Diurnal Variation of PM10 at Durango Complex Monitor May-December 2002 2-4 Figure 2-3 Diurnal Variation of PM10 at South Phoenix Monitor April-December 2002 2-5 rd Figure 2-4 Diurnal Variation of PM10 at West 43 Avenue Monitor April-December 2002 2-6 Figure 2-5 Diurnal Variation Comparison of 4 Sites 2-6 Figure 2-6 Monthly Average PM10 Values for Salt River Monitor by Time of Day 2-8 Figure 2-7 Monthly Variation of PM10 Values for Durango Monitor by Time of Day 2-8 rd Figure 2-8 Monthly Variation of PM10 for West 43 Avenue Monitor by Time of Day 2-9 Figure 2-9 Monthly Variation of PM10 values at South Phoenix Monitor by Time of Day 2-9 Figure 3-1 Hourly PM10 at Salt River Site, April – December 2002 (TEOM) 3-2 Figure 3-2 IKONOS Satellite Photograph of the Area Showing the Locations of the Salt River Monitor 3-4 Figure 3-3 rd Diurnal Variation of PM10 at West 43 Avenue Monitor, April – December 2002 3-6 rd Figure 3-4 IKONOS Satellite Photograph of the Area showing the location of the W. 43 Avenue Monitor Figure 3-5 Diurnal Variation of PM10 at Salt river and West 43rd Avenue Monitors 3-9 Figure 4-1 Salt River Fugitive PM10 Observations (June 1-December 31, 2002) 4-6 Figure 4-2 Salt River Fugitive PM10 Observations – Material Handling 4-6 Figure 4-3 Salt River Fugitive PM10Observations – Trackout 4-7 Figure 4-4 Salt River Fugitive Dust Observations – Unpaved Hauling 4-7 rd 3-7 Figure 4-5 Trackout on 43 Avenue, Looking South and North, Respectively 4-14 Figure 4-6 Salt River PM10 Emissions Low Wind Day – December 16, 2002 4-38 Figure 4-7 Salt River PM10 Emissions Low Wind Day – January 8, 2002 4-39 Figure 4-8 Salt River PM10 Emissions High Wind Day – April 15, 2002 4-40 Figure 4-9 Salt River PM10 Emissions High Wind Day – April 26, 2002 4-41 Figure 4-10 Salt River PM10 Emissions Low Wind Day – January 8, 2006 Base Case 4-48 Figure 4-11 Salt River PM10 Emissions Low Wind Day – December 16, 2006 Base Case 4-49 Figure 4-12 Salt River PM10 Emissions High Wind Day – April 15, 2006 Base Case 4-50 Figure 4-13 Salt River PM10 Emissions High Wind Day – April 26, 2006 Base Case 4-51 ix Figure 5-1 Modeled Source Contributions for High Wind Exceedances – 2002 5-4 Figure 5-2 Modeled Source Contributions for Low-Moderate Wind Exceedances - 2002 5-4 Figure 5-3 Salt River PM10 Model Predictions vs. Observations, with Monitoring Sites (WF, West 43rd Ave; SP, South Phoenix; SR, Salt River Site; and DC, Durango Complex 5-11 Figure 5-4 Salt River PM10 Model Predictions vs. Measurements, with High Wind (High) and Low Wind (Low) Conditions Indicated 5-12 Figure 5-5 Domain-wide PM10 Concentrations from the ISC Model for December 16, 2002 5-15 Figure 5-6 Domain-wide PM10 Concentrations from the ISC Model for April 15 5-16 Figure 5-7 Model Performance: Predicted vs. Observed PM10 Concentrations 5-17 Figure 5-8 Moving Averages for West Boundary/West 43rd Avenue Ratio 5-21 Figure 5-9 PM10 Concentration Ratios for East, West and North Boundaries Relative to PM10 Concentration at West 43rd Avenue Monitor 5-22 Figure 6-1a Source Contributions of All Sources to West 43rd Avenue Monitor on 4/15/02 6-26 rd Figure 6-1b Source Contributions of Windblown Sources to West 43 Avenue Monitor on 4/15/02 6-26 Figure 6-2a Source Contributions of All Sources to 43rd Avenue Monitor on 4/26/02 6-27 rd Figure 6-2b Source Contributions of Windblown Sources to West 43 Avenue on 4/26/02 6-27 Figure 6-3a Source Contributions of All Sources to Durango Monitor on 4/15/02 6-29 Figure 6-3b Source Contributions of Windblown Sources to Durango Monitor on 4/15/02 6-29 Figure 6-4a Source Contributions of All Sources to Durango Monitor on 4/26/02 6-30 Figure 6-4b Source Contributions of Windblown Sources to Durango Monitor on 4/26/02 6-30 Figure 6-5a Source Contributions of All Sources to Salt River Monitor on 4/15/02 6-32 Figure 6-5b Source Contributions of Windblown Sources to Salt River Monitor on 4/15/02 6-32 Figure 6-6a Source Contributions of All Sources to Salt River Monitor on 4/26/02 6-33 Figure 6-6b Source Contributions of Windblown Sources to Salt River Monitor on 4/26/02 6-33 Figure 6-7a Source Contributions to Salt River Monitor on 1/8/02 Low-Wind Exceedance 6-35 rd Figure 6-7b Source Contributions to West 43 Avenue Monitor on 12/16/02 Low-Wind Exceedance Figure A-1 Gridded Satellite Image with Locations of the Four Air Quality Monitors A-3 Figure A-2 Land Use Map A-4 Figure A-3 Fugitive Dust Study Map A-5 Figure A-4 Map of Locations of the 81 Industrial Sources A-6 Figure A-5 Map of Approximate Boundaries of Industrial Sources, such as Rock Products, Near the Salt River A-7 Figure A-6 Map of Soil Stability in Salt River Alluvial Channel with Property Ownership A-8 Figure A-7 Map of Modeling Grid A-9 Figure A-8 Map of Modeling Grid with Satellite Image A-10 Figure A-9 Emissions Density Map of 24-Hour PM10 Emissions - Primary Roads A-11 x 6-35 Figure A-10 Emissions Density Map of 24-Hour PM10 Emissions - Secondary Roads A-12 Figure A-11 Emissions Density Map of 24-Hour PM10 Emissions - Alluvial (Windblown) A-13 Figure A-12 Emissions Density Map of 24-Hour PM10 Emissions - Construction A-14 Figure A-13 Emissions Density Map of 24-Hour PM10 Emissions - Construction (Windblown) A-15 Figure A-14 Emissions Density Map of 24-Hour PM10 Emissions - Cleared Area (Windblown) A-16 Figure A-15 Emissions Density Map of 24-Hour PM10 Emissions - Miscellaneous Disturbed (Windblown) A-17 Figure A-16 Emissions Density Map of 24-Hour PM10 Emissions - Agriculture (Windblown) A-18 Figure A-17 Emissions Density Map of 24-Hour PM10 Emissions - Trackout A-19 Figure A-18 Emissions Density Map of 24-Hour PM10 Emissions - Unpaved Shoulders A-20 Figure A-19 Emissions Density Map of 24-Hour PM10 Emissions - Vacant Lots (Windblown) A-21 Figure A-20 Emissions Density Map of 24-Hour Total PM10 Emissions - Low Wind Day A-22 Figure A-21 Emissions Density Map of 24-Hour Total PM10 Emissions - High Wind Day A-23 Figure D-1 Sample #1 taken on northbound lane of 43rd Avenue at Elwood Street, 445 feet north of origin (area dimensions = 3 feet by 18 feet). Photo is looking west. D-2 Figure D-2 Sample #2 Taken on southbound lane of 43rd Avenue at Elwood Street, 445 feet north of the origin (area dimensions = 6 feet by 18 feet). Photo is looking south. D-2 Figure D-3 Sample #3 taken on the northbound lane of 43rd Avenue, 910 feet north of origin (area dimensions = 2 feet by 18 feet). Sample #4 taken directly across (west) from Sample #3 on the southbound lane, just north of exit road from the dirt storage pile (Area dimensions = 6 feet by 18 feet). Photo is looking northwest. D-3 Figure D-4 Figure D-5 Sample #5 was taken on the south bound lane, 2003 feet north of the origin (area dimensions = 6 feet by 17 feet). Sample #6 was taken directly across (east) from Sample #5 on the north bound lane (Area dimensions = 3 feet by 18 feet). Photo is looking east. D-3 Sample #7 (above photo) was taken just south of Lower Buckeye Rd (note traffic light) on the northbound lane of 43rd Avenue, 2,840 feet north of the origin (area dimensions = 3 feet by 26 feet). Sample #8 was taken across (west from Sample #7 on the southbound lane (area dimensions = 6’ by 18’). Photo is looking east. D-4 Figure D-6 Example of trackout on exit road onto 43rd Avenue & Elwood Road, that is used by the Glenn Weinberger Company. Photo is looking east D-4 Figure D-7 Silt Percentage From Trackout on 43rd Avenue D-7 Figure D-8 Silt Loading From Trackout on 43rd Avenue D-7 Figure E-1 Map of Soil Stability in Salt River Alluvial Channel With Property Ownership E-2 Figure F-1 Map of Agricultural Crops in Salt River PM10 Study Area F-2 xi Figure M-1 Onroad Mobile PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence M-4 Figure M-2 Point source PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence M-5 Figure M-3 Area source PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence M-6 Figure M-4 Nonroad Mobile PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence M-7 Figure M-5 Windblown PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence M-8 Figure N-1 Elevations in South-central Arizona (top), in Metropolitan Phoenix (bottom), with the Salt River PM10 Study Area Shown in the Lower Figure N-2 Figure N-2 Salt River Meteorological Sites N-3 Figure N-3 South Phoenix Wind Rose: Annual N-7 Figure N-4 South Phoenix Wind Rose: Seasonal N-8 Figure N-5 South Phoenix Wind Rose: Winter, Six-Hour Blocks N-9 Figure N-6 South Phoenix Wind Rose: Spring in Six-Hour Blocks N-10 Figure N-7 South Phoenix Wind Rose: Summer in Six-Hour Blocks N-11 Figure N-8 South Phoenix Wind Rose: Fall, Six-Hour Blocks N-12 Figure N-9 Durango Wind Rose: Winter, Six-Hour Blocks N-13 Figure N-10 Comparison of Three Sites: West 43rd Avenue, South Phoenix, and Durango for October through December N-14 Figure O-1 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- High Wind Day of April 15, 2002 at South Phoenix O-2 Figure O-2 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- High Wind Day of April 15, 2002 at West 43rd Avenue O-3 Figure O-3 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- High Wind Day of April 15, 2002 at Salt River Site O-3 Figure O-4 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- High Wind Day of April 15, 2002 at Durango O-4 Figure O-5 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- Low Wind Day of December 16, 2002 at South Phoenix O-4 Figure O-6 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- Low Wind Day of December 16, 2002 at West 43rd Avenue O-5 Figure O-7 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- Low Wind Day of December 16, 2002 at the Salt River Site O-5 Figure O-8 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- Low Wind Day of December 16, 2002 at Durango O-6 Figure O-9 Model + Background vs. Measured (TEOM): High Wind Day of April 15, 2002: Four Sites, Hourly O-7 xii Figure O-10 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- Four Sites, December 16, 2002 O-8 Figure O-11 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- Four Sites, High Wind, April 15, 2002, Ranked by TEOM Reading O-9 Figure O-12 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- Four Sites, Low Wind, December 16, 2002, Ranked by TEOM Reading O-10 Figure O-13 Salt River PM10 -- Model + Background vs. Measured (TEOM) -- Four High-Wind Hours of April 15, 2002, All Sites O-11 Figure O-14 Salt River PM10 Model + Background vs. Measured (TEOM) – All Low-Wind Hours, All Sites, April 15 and December 16, 2002 O-12 Figure O-15 Salt River PM10 – ISC Model-Predicted Concentrations (No Background) – April 15, 2002 O-17 Figure O-16 Salt River PM10 – ISC Model Predictions and Background for April 15, 2002 O-18 Figure O-17 Salt River PM10 – ISC Model Predicted Average, Measured Average, and Background -April 15, 2002 O-18 Figure O-18 Salt River PM10 – ISC Model-Predicted Concentrations (No Background) December 16, 2002 O-19 Figure O-19 Salt River PM10 – ISC Model Predictions and Background -- December 16, 2002 O-20 Figure O-20 Salt River PM10 – ISC Model Predicted Average of Four Sites, Measured Average, and Background – December 16, 2002 O-21 Figure P-1 Unweighted Relative Trackout Contributions to PM10 at the Salt River Site on January 8, 2002 P-3 Figure P-2 Weighted Relative Trackout Contributions to PM10 at the Salt River Site on January 8, 2002 P-3 Figure P-3 Unweighted Relative Trackout Contributions to PM10 at West 43rd Avenue on December 16, 2002 P-4 Figure P-4 Weighted Relative Trackout Contributions to PM10 at West 43rd Avenue on December 16, 2002 P-4 Figure P-5 Unweighted Relative Trackout Contributions to PM10 for Six High-Wind Exceedances P-5 Figure P-6 Weighted Relative Trackout Contributions to PM10 for Six High-Wind Exceedances P-5 Figure Q-1 Salt River PM10 Study Area Construction Acreage Q-1 Figure Q-2 Salt River Area Construction by Land Type Q-2 Figure Q-3 Available Agricultural Land in the Salt River Study Area and Construction Acreage Q-3 Figure S-1 Salt River PM10 Study Area Throughput for Facilities with Industrial Area Emissions: 2002 – 2004 from Survey Data, Linearly Extrapolated to 2006 S-3 Figure S-2 PM10 Concentrations (24-Hour Averages) at West 43rd Avenue in 2002: 189 TEOM Observations S-5 Figure S-3 PM10 Concentrations (24-Hour Averages) at the Salt River Site in 2002: 50 High-Volume Observations S-5 Figure S-4 Salt River PM10 Concentrations by Source Contribution: January 8, 2002, Salt River Site – Large Industrial Area Emissions at Base Case Levels xiii S-10 Figure S-5 Salt River PM10 Concentrations by Source Contribution: December 16, 2002, West 43rd Avenue – Large Industrial Area Emissions at Base Case Levels S-10 Figure S-6 Salt River PM10 Concentrations by Source Contribution: January 8, 2002, Salt River Site – Large Industrial Area Emissions Increased 23% S-11 Figure S-7 Salt River PM10 Concentrations by Source Contribution: December 16, 2002, West 43rd Avenue – Large Industrial Area Emissions Increased 23% S-11 Figure S-8 Salt River PM10 Concentrations by Source Contribution: January 8, 2002, Salt River Site – Large Industrial Area Emissions Increased 45% S-12 Figure S-9 Salt River PM10 Concentrations by Source Contribution: December 16, 2002, West 43rd Avenue – Large Industrial Area Emissions Increased 45% S-12 Figure S-10 Salt River PM10 Concentrations by Source Contribution: January 8, 2002, Salt River Site – Large Industrial Area Emissions Increased 68% S-13 Figure S-11 Salt River PM10 Concentrations by Source Contribution: December 16, 2002, West 43rd Avenue – Large Industrial Area Emissions Increased 68% S-13 xiv 1.0 CHAPTER 1 - SALT RIVER PM10 ANALYSIS – INTRODUCTION 1.1 OVERVIEW Through the Clean Air Act, the U. S. Environmental Protection Agency (EPA) has established health standards for airborne particulate matter. These standards are for particles with an aerodynamic diameter of 10 microns and smaller, otherwise know as PM10. The two averaging periods for these PM10 standards are 24 hours and annual. Their numerical values, expressed in mass of particles per volume of air: specifically, as micrograms per cubic meter (µg/m3), are 150 µg/m3 for 24 hours and 50 µg/m3 for annual. Metropolitan Phoenix, which has not attained the annual standard for PM10 at all monitoring sites, is under a State Implementation Plan to achieve this standard by 2006 (MAG 1999). A separate plan revision, submitted in 1997, included a technical analysis of the elevated 24-hour PM10 concentrations recorded in the Salt River PM10 Study area in southwest Phoenix. Since monitoring began with the Salt River PM10 monitoring site near 19th Avenue and Lower Buckeye Road in 1994, this monitor has recorded violations of the 24-hour PM10 standard every year. The site was supposed to attain the standard by 1999, as detailed in the above mentioned technical analysis. That it did not achieve the standard has led the EPA to require the state to develop a State Implementation Plan (SIP) demonstrating that the 24-hour PM10 standard can be attained by the end of 2006. This entire report constitutes the technical documentation supporting that demonstration. An additional issue concerns the historical Salt River monitoring site, which had been located on City of Phoenix property, was relocated to another section of the property in January 2002, and was discontinued altogether at the end of year. Removal of the equipment had been requested by the City due to substantial construction on and near the property. Actions to find a suitable replacement site with comparable PM10 concentrations and industrial emissions were taken by the Maricopa County Environmental Services Department (MCESD) and staff from the Assessment Section of the Air Quality Division of ADEQ. Such a site was identified and established, with the name of “West 43rd Avenue.” MCESD has agreed to long-term PM10 data collection at this site as a component of the SIP. As part of this SIP demonstration, the Assessment Section has shown that the PM10 concentrations and source contributions between this new site and the Salt River site are equivalent. Chapter 1 – Salt River PM10 Analysis - Introduction 1-1 In carrying out this overall demonstration of improved PM10 levels with additional controls, three projects were completed: 1. An intensive air quality monitoring study was conducted April – December 2002. 2. A complete inventory of PM10 emissions was constructed, and it was made ready for use in a numerical air quality model. 3. Air quality modeling was then conducted; potential controls to reduce PM10 emissions were translated into numerical reductions; and future (2006) air quality was evaluated. This work is fully described in chapters 2 – 7. The remainder of this introductory chapter begins with a general discussion of particulate matter. A brief description of PM10 concentrations throughout the metropolitan area follows to put the Salt River PM10 levels into a larger context. The chapter concludes with a historical view of PM10 monitoring in the Salt River PM10 Study area. 1.2 THE GENERAL NATURE OF PARTICULATE MATTER Particulate matter is a collective term describing very small solid or liquid particles that vary considerably in size, geometry, chemical composition and physical properties. Produced by both natural processes (pollen and wind erosion) and human activity (soot, fly ash, and dust from paved and unpaved roads), particulates contribute to visibility reduction, pose a threat to public health and cause economic damage through soil disturbance. PM10 is particulate matter 10 microns and smaller, and can be divided into two size fractions, coarse and fine. Some fine particulates (2.5 microns and smaller, or “PM2.5”) are formed by the condensation of vapors or by their subsequent growth through coagulation or agglomeration. Others are emitted directly from the sources, either by combustion or from mechanical grinding of soils. Coarse particulates (2.5 to 10 microns) are formed through mechanical processes such as the grinding of matter and the atomization of liquids. Fine particulates can also be classified as primary – produced within and emitted from a source with little subsequent change – or secondary – formed in the atmosphere from gaseous emissions. Secondary particulate nitrates and sulfates, for example, form in the atmosphere from the oxidation of sulfur dioxide and nitric oxide, which are two gases. In contrast, most atmospheric carbon is primary, having been emitted directly from combustion sources, although some of the organic carbon in the aerosol is secondary, having been formed by the complex photochemistry of gaseous volatile organic compounds. The size, shape and chemical composition of particulates determine their health effects. Particles larger than 10 microns are deposited in the upper respiratory tract. Particles from 2.5 to 10 microns are inhalable and are deposited in the upper parts of the Chapter 1 – Salt River PM10 Analysis - Introduction 1-2 respiratory system. Particles smaller than 2.5 microns are respirable and are deposited in the pulmonary tissues. Particles in the size range of 0.1 to 2.5 microns are most efficiently deposited in the alveoli, where their effective toxicity is greater than larger particles because of the higher relative content of toxic heavy metals, sulfates and nitrates. Epidemiological studies have shown causal relationships between particulates and excess mortality, aggravation of bronchitis, and, in children, small, reversible changes in pulmonary function. Acidic aerosols have been linked to the inability of the upper respiratory tract and pulmonary system to remove harmful particles. The Arizona Comparative Environmental Risk Project – a multi-disciplinary investigation into human exposure to all environmental risks completed in 1995 – ranked outdoor air quality in general and particulate matter in particular as the highest environmental risk in the State. In this study, annual premature deaths from exposure to PM10 concentrations in Arizona were estimated at 963, which included 667 in Maricopa County and 88 in Tucson. Increased percentages of hospital admissions for respiratory disease (1 to 4 percent, depending on the city), of asthma episodes (5 to 14 percent), of lower respiratory symptoms (5 to 15 percent) and of coughs (2 to 6 percent) were attributed to the prevailing annual PM10 concentrations in 1991. Chronically high particulate concentrations in the ambient air continue to pose a serious health threat to many Arizonans. Coarse particulate emissions are mostly geological and are dominated by dusts from three activities: re-entraining dust from paved roads, driving on unpaved roads and earthmoving associated with construction. Soil dust from these sources and others contribute more than 70 percent of the coarse particulates in Phoenix. On days with winds in excess of 15 miles per hour, wind erosion of soil contributes to this loading. PM10 concentrations are not evenly distributed throughout the Phoenix metropolitan area, because each monitoring site is strongly influenced by the degree of localized emissions of coarse particulates. Background concentrations of PM10 are about 20 percent of the urban maxima (10 µg/m3 for an annual average background versus about 50 µg/m3 for the urban maximum). Concentrations of particulates tend to be higher in the late fall and winter, when atmospheric dispersion is at a seasonal low. PM10 maximum concentrations can occur in any season, provided nearby sources of coarse particulates are present or when strong and gusty winds suspend soil disturbed by human activities. Hourly concentrations of particulates tend to peak during the hours of the worst dispersion, which is from sunset to mid-morning. Controls to reduce particulates have been in place for decades, beginning with an ordinance that required watering to reduce dust from construction in Pima County in the 1960s. Maricopa County’s umbrella dust abatement rule, Rule 310, has been revised many times through the years and now regulates construction dust, track-out dust from construction sites, and dust from unpaved parking and vacant lots. Efforts to reduce dust resuspended from paved roads have concentrated on eliminating track-out from construction sites, curbing and stabilizing road shoulders, and using more efficient street sweepers. Secondary fine particulates have been reduced by vehicular emission Chapter 1 – Salt River PM10 Analysis - Introduction 1-3 controls, which have reduced the gaseous emissions from which they are formed. Reducing gaseous hydrocarbon emissions has led to a significant reduction in the primary carbon emitted in motor vehicle exhaust. In Maricopa County, the Governor’s Agricultural Best Management Practices Committee developed a rule containing best management practices for agricultural activities intended to reduce particulate emissions from tilling and harvesting activities, cropland and non-cropland. In a recent PM10 SIP, the Maricopa Association of Governments obtained commitments from local and state governments to implement 77 new measures, including enhanced enforcement of the county dust rules, implementation of agricultural best management practices, use of PM10 efficient street sweepers and requirements for cleaner burning fireplaces. 1.3 PARTICULATE MATTER CONCENTRATIONS IN METROPOLITAN PHOENIX Metropolitan Phoenix PM10 concentrations are measured at fixed monitoring stations operated by three government agencies: the Maricopa County Environmental Services Department, the Arizona Department of Environmental Quality, and the Pinal County Air Quality Control District. In the filter-based methods, particulates are monitored by pulling ambient air through a filter, generally for 24 hours every sixth day, weighing the filter before and after, and measuring the volume of air sampled. Common particulates instruments include the high-volume sampler (Hi-Vol) and the dichotomous sampler (dichot), the latter of which measures both fine and coarse particulates. Particulates are also monitored continuously with a tapered element oscillating microbalance (TEOM) instrument. The PM10 concentrations presented in Table 1-1, based only on the Hi-Vol and Dichot networks, shows three sites exceeded the 24-hour standard of 150 µg/m3; and that most sites are well within the standards. In the remainder of this report, ambient concentrations from the filter-based samplers (Hi-Vol and Dichot) and continuous samplers (TEOM) will be presented. The last line of the table gives the PM10 concentrations at Organ Pipe National Monument, considered to be Sonoran Desert background. For PM10 a rule of thumb to understand annual concentrations is: Desert or plateau background Urban fringe General urban Urban with elevated concentrations Urban with serious problems µg/m3 10 20 – 30 30 – 45 45 – 55 60 – 80 Chapter 1 – Salt River PM10 Analysis - Introduction 1-4 TABLE 1-1 PM10 Concentrations in Metropolitan Phoenix for 2002 (µg/m3) 24-Hour Average Site or City Method Max Value 2nd High Phoenix – Salt River * Phoenix – Durango Complex* Phoenix - West 43rd Avenue* Higley South Phoenix* Chandler Phoenix – Greenwood West Phoenix Maryvale Central Phoenix Glendale West Chandler North Phoenix South Scottsdale Mesa Tempe – Community Center Phoenix – JLG Supersite Surprise Estrella Palo Verde Apache Junction Organ Pipe Cactus National Monument Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Hi-Vol Dichot Dichot Hi-Vol Dichot Dichot Hi-Vol Dichot 249 232 172 138 137 128 116 122 142 81 88 80 80 64 102 65 72 81 92 100 62 27 174 158 135 134 123 117 102 98 90 76 85 77 72 62 86 60 52 67 68 78 49 26 * Salt River PM10 Study area site Bold means an exceedance of the standard (150 µg/m3 for 24 hours) Note that the 24-hour standard was exceeded only within the Salt River area. While the air pollution levels in this area, as measured by PM10, unique to the Phoenix metropolitan area, they at least border on it. magnitude of the recorded concentrations –greater than 200 µg/m3 for the 24-hour averages – tends to set this area apart. PM10 Study may not be The sheer worst of the The above discussion about the spatial distribution of PM10 concerned a single year, 2002, the same year of the intensive monitoring study in the Salt River PM10 Study area. It is worthwhile to consider the historical levels of air pollution within the Salt River PM10 Study area. The longer-term considerations speak to the duration of the elevated PM10 concentrations in the area. Chapter 1 – Salt River PM10 Analysis - Introduction 1-5 1.4 PM10 TRENDS IN THE SALT RIVER PM10 STUDY AREA: 1994 – 2002 Data from three PM10 monitoring sites in the Salt River area were analyzed over an eight year period (1994 to 2002), to determine if the PM10 concentrations have decreased significantly. Analysis of the data indicates that the PM10 concentrations in the Salt River area have decreased from 1997 to 2002. The 24-hour Maximums for the Salt River site are displayed in Figures 1-1. Figure 1-1 Salt River – 24 Hour Maximum 600 24 hr Max PM10 (ug/m3) 500 400 300 200 100 0 1994 1995 1996 1997 1998 1999 2000 2001 2002 The 24-hour maximums are high in 1997 and 1998 (400 µg/m3 and higher), but they are significantly lower from 1999 through 2002. However, all of the 24-hour maximums exceed the 150 µg/m3 requirement. When compared with other sites in this area (Durango and South Phoenix), as in Table 1-2 the Salt River area has a much higher number of exceedances. Chapter 1 – Salt River PM10 Analysis - Introduction 1-6 TABLE 1- 2 Number of 24-Hour Exceedances per Year Year Salt South Durango Complex River Phoenix 1994 12 0 1995 14 0 1996 11 0 1997 14 0 1998 4 1 1999 9 0 0 2000 7 0 2 2001 5 1 1 2002 2 0 2 Comparison of the data for Salt River and Durango Complex from 1999 to 2002 indicates that the Salt River PM10 concentration decreases in 2002, while the Durango Complex concentration increases. The two locations are within one mile of each other, so the concentration variation should be in the same direction. Since it is not, one can conclude that the lower PM10 in 2002 for the Salt River site is due to the higher elevation of the monitor (starting in January 2002). Figure 1-2 displays the data. PM10 (ug/m3) 24 hr Max Figure 1-2 24-Hour Maximums at Durango and Salt River Monitors (DC = Durango Complex, SLT = Salt River) 350 300 250 200 150 100 50 0 DC 24 hr Max SLT 24 hr Max 1999 2000 2001 2002 A histogram of all the Salt River site PM10 data is displayed in Figure 1-3. It is a normal distribution, with a mean of 89.1 µg/m3. There are a few outliers that are greater than 225 µg/m3. Even the data points that exceed the PM10 limit (150 µg/m3 for a 24-hour average) are within the distribution. Chapter 1 – Salt River PM10 Analysis - Introduction 1-7 Figure 1-3 Histogram of PM10 at Salt River Monitor (1994 to 2002) Histogram: VAR2 538 * 50 * normal (x, 89.11115, 54.7603) 240 200 No of obs 160 120 80 40 0 -50 0 50 100 150 200 250 300 350 400 450 500 550 VAR2 Figure 1-4 24 hour average PM10 trends 1994-2002 at Salt River Site VAR2 Plot of variable: VAR2 600 600 500 500 400 400 300 300 200 200 100 100 0 0 -100 34354.0 34432.0 34506.0 34624.0 35470.0 35866.0 36508.0 36916.0 37288.0 -100 Dates (from variable: VAR1 ) In the day to day data no pattern is seen. One would expect seasonal variation, but that is seen in the hourly data, as described in the next section. This analysis shows the lack of seasonality, or any other fixed pattern and suggests that localized emissions in a random fashion dominate over the importance of other factors such as wind speed or direction. Chapter 1 – Salt River PM10 Analysis - Introduction 1-8 2.0 CHAPTER 2 – AMBIENT AIR QUALITY DATA 2.1 AMBIENT AIR QUALITY IN 2002 In the introduction, the PM10 concentrations in the Salt River PM10 Study area were briefly discussed. A short comparative analysis with other monitoring sites in metropolitan Phoenix in 2002 was presented, as well as an historical trends analysis. In this chapter, these PM10 concentrations in the Salt River study area will be thoroughly examined, based on the intensive monitoring performed in 2002. First, the monitoring network, its instruments, and sampling frequencies will be laid out. Second, the important regulatory statistics for the entire calendar year of 2002, including the 8-month intensive study, will be discussed. Third, those days when any Salt River area monitor exceeded the 24-hour average standard for PM10 of 50 µg/m3 will be examined in some detail, especially the underlying meteorological conditions contributing to the elevated concentrations. Fourth, the hourly variation of PM10 at the four sites will be presented and interpreted. Fifth, the seasonal variation of PM10 will be explained. Sixth, and last, the authors will give some concluding remarks on the ambient PM10 concentrations in the Salt River PM10 Study area. 2.2 INTENSIVE AIR POLLUTION MONITORING: INSTRUMENTS AND SITES Three monitoring sites have been operated by Maricopa County Environmental Services Department (MCESD) in the Salt River PM10 Study area for a number of years. These three sites operated throughout 2002, but were supplemented by additional instruments in the April – December intensive study. In addition, a fourth site was established in the spring of 2002 for the intensive study. These sites, listed in Table 21, provide adequate monitoring coverage for the 4x8 mile study area. TABLE 2-1 Intensive Study Monitoring Sites (All are in Phoenix) Site Name Abbreviation Address Salt River SR 3045 S. 22nd Ave South Phoenix SP 33 W. Tamarisk Durango Complex DC 2702 AC Esterbrook Blvd. rd West 43 Ave WF 3940 W. Broadway Remarks SIP site of 1997 work Long-term Began 1999 New as of April 2002 Of these sites, the South Phoenix site is the only one classified as population oriented; the other three are all designed to capture maximum concentrations. The major cross streets for the sites are Salt River, 22nd Avenue and Lower Buckeye Road; South Phoenix, Central and Broadway; Durango Complex, 27th Ave and Durango; and West 43rd Avenue, Broadway east of 43rd Avenue. Chapter 2 – Ambient Air Quality 2-1 During 2002, the three longer-term sites ran the entire year, while West 43rd began in April. The instrumentation at the various sites, described below, was directed towards the measurement of either meteorological variables or PM10. Three types of PM10 monitors were employed. The first two types are termed “filter-based samplers”, and operate by pulling air through a pre-weighed filter. After running for 24 hours, the filter and its collected particulates are weighed, thus giving the mass of particulates, which, divided by the volume of air, gives the concentrations of PM10. The first is called the high-volume sampler, or “hi-vol”, which is a filter-based sampler that employs a large (about 8x10 inch) filter and a high volume of air. The second type is called a dichotomous sampler, or “dichot”. It pulls a much lower volume of air than the hi-vol, uses a much smaller filter (47 mm in diameter, or about two inches), and separates the incoming air into two ports, each with its own filter. One side measures PM2.5; the other, PM10; with the difference called PM coarse. Both of these samplers are run for 24 hours, midnight to midnight, on a fixed schedule. Yet a third type of PM10 monitor is called a “TEOM”, which stands for tapered element oscillating microbalance. Unlike the filter-based instruments, this unit monitors particulates continuously, with concentrations typically stored in either five or 60 minute averages. In addition to the particulate measurements, wind speed and wind direction were monitored with standard meteorological equipment at a height of 10 meters. In conclusion, Table 2-2 shows which sites at what monitors were operating at what frequency. TABLE 2-2 Intensive Study: Instruments and Operating Frequency (April – December 2002) Wind Frequency Speed & PM10 by PM10 Filter of Filter1 1 2 Site Name Abbreviation Direction TEOM Based Based PM10 Salt River SR None Yes Hi-vol, 1 in 3; dichot 1 in 6 South Phoenix SP Yes Yes Hi-vol 1 in 3 Durango DC Yes Yes Hi-vol 1 in 3 Complex West 43rd WF Yes Yes Hi-vol, 1 in 3; Avenue dichot 1 in 6 See Appendix N for wind roses of the wind speed and direction data collected during the Salt River PM10 Study. 1 2 Continuous measurements, averaged hourly Filter-based measurements, averaged for 24 hours Chapter 2 – Ambient Air Quality 2-2 2.3 STUDY PERIOD AND ANNUAL STATISTICS The intensive study period began in April 2002, with the deployment of the instruments described above. By the middle of the month, most of the equipment was in place, and by the end of the month, all of it was. Therefore, the intensive study can best be described as an eight-month study, May – December 2002, with some of the specialized measurements beginning as early as mid-April. Regulatory concerns, however, dictate that elevated concentrations of PM10 – especially those that exceed the 24-hour standard of 150 µg/m3 – be examined throughout the year. As matters developed, potential design dates, a subset of those days with elevated PM10 concentrations slated for air quality modeling, included a January date, two in April, and one in December. Recall that three of the four sites have measurements throughout the year, while West 43rd Avenue measurements began in mid-April. Study-period and annual statistics are readily available, although the continuous collection of PM10 by TEOM and the every-third day collection by high-volume sampler provide different data sets. A clear picture of the overall air pollution at the four study sites would include long-term averages and the maximum values. In this case, “longterm” means nine months, April through December. These data, presented in Table 23, show that Salt River site has the highest long-term average, followed closely by West 43rd Avenue and Durango, and that South Phoenix is the cleanest of the four. The data also show that all sites except South Phoenix have 24-hour average maxima above the standard of 150 ug/m3. Because these concentrations come from both the filter-based and continuous samplers, these statistics differ slightly from the data presented in Table 1-1, which come only from the filter-based network. TABLE 2-3 Study Period PM10 Statistics South Statistic Salt River West 43rd Durango Phoenix 9-Month Average 75.4 68.2 66.0 59.0 High 24-Hr 249 243* 232 137 nd 2 184* 181* 198* 123 3rd 175 174* 158 102 4th 174 118 133 101 5th 147 113 132 94 Bold values exceed the standard of 150 ug/m3. *TEOM concentration, which was not recorded by the Maricopa County Department of Environmental Services high-volume sampler network. Chapter 2 – Ambient Air Quality 2-3 2.4 HOURLY VARIATION OF PM10 BY SITE For each site, an average was calculated for each hour, using the data from April (or May) through December, 2002. The hourly PM10 values were plotted to see the variation in a 24-hour period. The results are displayed in Figures 2-1 through 2-4. Figure 2-5 compares the diurnal pattern at the four sites, for the intensive study period. For all the months and sites, the data shows a pattern. PM10 values tend to be highest during the four hours after sunrise and during four hours after sunset. PM10 (ug/m3) Figure 2-1 Diurnal Variation of PM10 at Salt River Monitor April-December 2002 180 160 140 120 100 80 60 40 20 00:0003:0006:0009:0012:0015:0018:0021:00 Time of day April May June July Sept Oct Nov Dec Chapter 2 – Ambient Air Quality Aug 2-4 Figure 2-2 Diurnal Variation of PM10 at Durango Complex Monitor May-December 2002 PM10 (ug/m3) 140 120 100 80 60 40 20 00:00 04:00 08:00 12:00 16:00 20:00 Time of Day May June July Aug Sept Oct Nov Dec PM10 (ug/m3) Figure 2-3 Diurnal Variation of PM10 at South Phoenix Monitor April-December 2002 200 180 160 140 120 100 80 60 40 20 00:00 04:00 08:00 12:00 16:00 20:00 Time of Day April May June July Sept Oct Nov Dec Chapter 2 – Ambient Air Quality August 2-5 Figure 2-4 Diurnal Variation of PM10 at West 43rd Avenue Monitor April-December 2002 PM10 (ug/m3) 300 250 200 150 100 50 0 00:0003:0006:0009:0012:0015:0018:0021:00 Time of Day April May June July Sept Oct Nov Dec Aug Figure 2-5 Diurnal Variation Comparison of 4 Sites 180 PM10 (ug/m3) 160 140 120 100 80 60 40 20 00:00 04:00 08:00 12:00 16:00 20:00 Time of Day DC PM10 SR PM10 Chapter 2 – Ambient Air Quality SP PM10 W F PM10 2-6 For West 43rd, Durango Complex, and Salt River the higher peak occurs at 8 am, but for South Phoenix it occurs at 8 p.m. Table 2-4 lists the peak values and times of day at Salt River Study area sites during the study period. Time 8 a.m. Noon 8 p.m. 11 p.m. TABLE 2-4 Peak Hourly PM10 Values (μg/m3) West 43rd Salt River South Phoenix Durango Complex 180 120 105 80 50 50 50 35 100 100 140 75 85 85 85 55 Chapter 2 – Ambient Air Quality 2-7 2.5 SEASONAL VARIATION OF PM10 The average PM10 for each month during the intensive study was plotted for each site, at the same six times, in order to see the monthly variation, which can translate into seasonal variation. The summer months (June, July, August) are expected to display a substantially different behavior from the cooler months (October, November, December). Data for January through March were not available for comparison. The monthly variation of PM10 for each site is displayed in Figures 2-6 through 8. Figure 2-6 Monthly Average PM10 Values for Salt River Monitor by Time of Day PM10 (ug/m3) 200 150 100 50 0 April June Aug Sept Nov 00:00 06:00 08:00 12:00 17:00 20:00 Figure 2-7 Monthly Variation of PM10 Values for Durango Monitor by Time of Day PM10 (ug/m3) 140 120 100 80 60 40 20 May June Jul y Aug Sept Oct Nov Dec 00:00 06:00 08:00 12:00 17:00 20:00 Chapter 2 – Ambient Air Quality 2-8 Figure 2-8 Monthly Variation of PM10 for West 43rd Avenue Monitor by Time of Day 300 PM10 (ug/m3) 250 200 150 100 50 0 00:00 April May June July Aug Sept Oct Nov Dec 06:00 08:00 12:00 17:00 20:00 Figure 2-9 Monthly Variation of PM10 Values at South Phoenix Monitor by Time of Day PM10 (ug/m3) Monthly Variation of PM10 at S.Phoenix 180 160 140 120 100 80 60 40 20 June August 00:00 12:00 Chapter 2 – Ambient Air Quality Oct 06:00 17:00 Dec 08:00 20:00 2-9 2.6 CONCLUSIONS PM10 concentrations in the Salt River PM10 Study Area are the highest in metropolitan Phoenix. Based on intensive monitoring at four sites in 2002 within the study area, the highest long-term (nine-month) concentrations are, in decreasing order, at the Salt River, West 43rd Avenue, Durango, and South Phoenix sites. All except South Phoenix recorded violations of the 24-hour standard, with the highest three concentrations in the 230 – 250 ug/m3 range. The four sites exhibit similar diurnal patterns averaged for the study period, although the magnitude of the concentrations is different. This pattern is characterized by a rather sharp morning peak, a low, even plateau in the mid-day, another peak about 8:00 p.m., and another, but gently sloping plateau from 10:00 p.m. through 4:00 a.m. Each site exhibits a complex set of monthly diurnal patterns. Monthly variation from April through December varies by hour of the day, though the variation isn’t pronounced, and the patterns are not consistent from site to site. Chapter 2 – Ambient Air Quality 2-10 3.0 CHAPTER 3 – REPLACEMENT OF SALT RIVER MONITOR Although not a part of the official call for a State Implementation Plan (SIP) revision, the matter of a specific air pollution monitoring site for the Salt River PM10 Study Area was brought up by the U. S. Environmental Protection Agency in 2002. The precise monitoring location established in 1994 on the City of Phoenix Southwest Service Center property was scheduled for construction and therefore had to be moved. The City agreed to have the monitor relocated to the roof of their office building on the property, but would allow it to operate only until the end of 2002. In the meantime, County and State staffs were planning the intensive air monitoring study that forms the backbone of this technical analysis for the SIP. As part of this study, State and County officials agreed to establish a new monitoring site in the Salt River area. This new site would be for monitoring PM10, would replace the discontinued site at the City service center, and would have PM10 concentrations equivalent to those measured at the former site. Various details of the monitoring sites are presented in this chapter, with a concluding argument that the West 43rd Avenue site is an adequate replacement for the old “Salt River” site. 3.1 CHARACTERISTICS OF THE SALT RIVER SITE PM10 concentrations measured at the Salt River site were discussed in the previous chapter. What follows here are a table of the maximum 24-hour averages through the years and a figure that shows the diurnal variation of PM10 by month. Table 3-1 lists the number of 24-hour PM10 exceedances that were recorded at the Salt River site in the study area during the years 1994 through 2002. TABLE 3-1 Salt River Site PM10 (1994-2002) Hi-Vol Data Year Number of Exceedances 24 hr Max (µg/m3) 1994 12 371 1995 14 191 1996 11 250 1997 14 480 1998 4 403 1999 9 256 2000 7 244 2001 5 281 2002 2 249 Chapter 3 – Replacement of Salt River Monitor 3-1 Figure 3-1 Hourly PM10 at Salt River Site, April – December 2002 (TEOM) 1-Hr Avg. PM10 Conc. (ug/m3) 200 150 100 50 0 April 00:00 02:00 May 04:00 06:00 June Chapter 3 – Replacement of Salt River Monitor 08:00 July 10:00 12:00 14:00 Time of Day Aug Time 16:00 18:00 Sept 20:00 Oct 22:00 Nov 3-2 PM10 concentrations of this magnitude, with peak period hourly averages of 160 ug/m3, and with maximum 24-hour concentrations above 200 ug/m3, are a consequence of nearby emissions that elevate the levels high above the urban background concentration. As discussed in Chapter 5, background concentrations comprise about half of the PM10 measured in the Salt River PM10 Study Area. What is of concern here are the characteristics and activities on the land surface near the Salt River monitor. Figure 3-2 is an enlargement of the satellite image of March 2002 that was used in the construction of the emissions inventory. Both the long-term and 2002 locations of the monitor are shown. While comparisons between these two monitoring sites would be helpful in analyzing the 1994 – 2002 trends, the purpose of this chapter is to compare the “Salt River” site with the “West 43rd Avenue” site, both their PM10 concentrations and their site characteristics. The air quality comparison is limited to the eight months of 2002 when data were collected at both the West 43rd Avenue and the Salt River sites. During this time the monitoring instruments at the Salt River site were on the roof of the office building of the City of Phoenix Southwest Service Center, shown in the upper left of the image. Therefore, it is more instructive to analyze the roof top site and omit the original location. This site is surrounded by activities and land surfaces with considerable potential for PM10 emissions. To the southwest and south is a sand and gravel operation, a portion of which is visible in the lower left corner. A concrete beam fabrication company lies to the south and east. Unpaved roadways of this facility show up as a dark brown. Nineteenth Avenue lies to the east and carries 22,000 vehicles per day. North of the site extending to Lower Buckeye Road, are the City of Phoenix bus storage and maintenance yards. West of the site (not shown in the image) is a wide expanse of mostly bare land, that also contains the 23rd Avenue Wastewater Treatment Plant’s dry sludge ponds. The immediate area around the office building is paved. Vehicle parking lots, clearly visible in the image, virtually surround the site. In summary, the vehicular traffic on roads, entrance roads, and parking lots; the sand and gravel and industrial activity; and the bare land all have considerable potential for PM10 emissions. Chapter 3 – Replacement of Salt River Monitor 3-3 Figure 3-2 IKONOS Satellite Photograph of the Area Showing the Locations of the Salt River Monitor Chapter 3 – Replacement of Salt River Monitor 3-4 3.2 CHARACTERISTICS OF THE NEW WEST 43rd AVENUE SITE PM10 concentrations at the West 43rd Avenue site have been thoroughly examined for the April – December 2002 period. Already discussed in Chapter 2, these concentrations proved to be similar to the Salt River site. Figure 3-3 presents the diurnal variation at the site, by month, and shows that the morning peak concentrations are on the order of 200 ug/m3, depending on the month. Figure 3-4 is a satellite photograph showing the location of this monitor. Chapter 3 – Replacement of Salt River Monitor 3-5 Figure 3-3 Diurnal Variation of PM10 at West 43rd Avenue Monitor, April – Dec 2002 1-Hr Avg. PM10 Conc. (ug/m3) 300 250 200 150 100 50 0 00:00 02:00 04:00 06:00 08:00 10:00 12:00 14:00 16:00 18:00 20:00 22:00 Time of Day April May June July Aug Sept Oct Nov Chapter 3 – Replacement of Salt River Monitor Time 3-6 Figure 3-4 IKONOS Satellite Photograph of the Area Showing the Location of the W. 43rd Avenue Monitor Chapter 3 – Replacement of Salt River Monitor 3-7 Similar to Figure 3-2, Figure 3-3 shows the land use around the West 43rd Avenue site. Broadway Road with an average daily traffic count of 4,500 vehicles per day, curves across the lower part of the image. Residential housing is in the lower right; bare land that extends north to the bed of the Salt River lies north of the monitor; storage and light industrial activities can be seen to the southwest and south of the monitor. The nearest major industrial activity, a sand and gravel operation, lies about ¾ mile to the west southwest. This site is not subject to the same degree of close-in emissions as the Salt River site 3.3 COMPARISON OF WEST 43rd AVENUE AND SALT RIVER PM10 Despite the contrast between the two sites in their nearby emission sources, the PM10 concentrations are nearly equivalent. This equivalency can be seen in any number of statistics: only a few will be presented here. Figure 3-5 shows that diurnal patterns are similar, with West 43rd Avenue having a higher morning peak than the Salt River site. These patterns are based on eight months of data in 2002. The higher afternoon plateau at the Salt River site reflects its greater nearby vehicular and industrial activity. The nearly identical late evening and early morning concentrations suggest that the PM10 concentrations throughout the Salt River PM10 Study Area are uniform for these hours. This uniformity is consistent with the lack of localized emissions near the monitors through the night. A statistical analysis using the Student’s t-test for the two sets of the all the diurnal values indicates that they are statistically different. However, when the data from 6am to 8am are deleted, they are statistically same. Since the PM10 concentrations at the West 43rd Avenue site are higher than the Salt River site, the former is an adequate replacement for the latter. This equivalence is also born out by a cursory look at the regulatory important extreme values. In 2002, the Salt River PM10 maximum concentrations were 249, 184, and 174 ug/m3, with the first two under high wind conditions. At West 43rd Avenue, the highest PM10 concentrations were about the same: 243, 174, and 181 ug/m3, with the first two under high wind conditions. Under both low-wind and high-wind conditions, the two sites recorded equivalent maximum 24hour average PM10 concentrations. Chapter 3 – Replacement of Salt River Monitor 3-8 Figure 3-5 Diurnal Variation of PM10 at Salt River and West 43rd Avenue Monitors 200 180 1-Hr Avg. PM10 Conc. (ug/m3) 160 140 120 100 80 60 40 20 0 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Time of Day West 43rd Chapter 3 – Replacement of Salt River Monitor Salt River 3-9 4.0 CHAPTER 4 - SALT RIVER PM10 EMISSIONS INVENTORY 4.1 INTRODUCTION This chapter presents the methodology, assumptions and data used to build a gridded PM10 emissions inventory for modeling 24-hour PM10 levels in the Salt River PM10 Study Area. The boundaries of the study area are approximately, Van Buren Street on the north, Baseline Road on the south, 59th Avenue on the west and 10th Street on the east. This area is approximately 101 square kilometers (39 square miles). See Appendix A for a satellite image of the study area with the locations of the four air quality monitors and grid overlay (Map A-1). A base year emissions inventory was constructed for 2002 and a base case emissions inventory was constructed for 2006. Gridded hourly emissions were calculated for the four design days: January 8, 2002, April 15, 2002, April 26, 2002, and December 16, 2002. The design days have two different meteorological regimes – two days with low wind speeds and a thermal inversion and two days with wind speeds over 15 miles per hour. Thus the design days will have a different mix of emission sources. The design days with low wind speeds were January 8, 2002 and December 16, 2002, and the design days with wind speeds over 15 miles per hour were April 15, 2002 and April 26, 2002. The four major anthropogenic PM10 emission categories that were investigated are listed below: • Point Sources - major stationary sources, defined as all facilities emitting greater than five tons per year (TPY) PM10, Point source emissions include emissions from combustion, process operations, material transfers, storage pile wind erosion, and paved and unpaved roads within facility grounds. • Area Sources - smaller stationary sources (both anthropogenic and nonanthropogenic) not included in the point source inventory. These include small industrial facilities, agricultural tillage and harvesting, construction activity, and wind erosion of areas with disturbed topsoil. • On-Road Mobile Sources - vehicles certified for highway use – cars, trucks, and motorcycles. Road dust from paved and unpaved roads is also included. • Off-Road Mobile Sources - a wide variety of gasoline and diesel equipment that either move under their own power or can be moved from site to site. Off-road mobile sources are defined as equipment not licensed or certified as highway vehicles and will move or be moved at least once during a 12-month period. Offroad mobile sources include equipment used in agriculture, construction, mining, commercial and industrial operations, lawn and garden maintenance, aircraft, airport ground support, locomotives, railroad, recreational, and water craft. See Appendix B for a glossary of terms used in this technical support document (TSD). Chapter 4 – Salt River PM10 Emissions Inventory 4-1 A major category of non-anthropogenic PM10 emissions in the Salt River PM10 Study Area is the alluvial channel of the Salt River west of the 43rd Avenue monitor. The gridded land use and PM10 emissions source files for the Salt River PM10 Study Area were constructed from: 1) Inspection of satellite images of the Salt River PM10 Study Area. (IKONOS, March 2002), 2) Maricopa County Environmental Services Department (MCESD) permits records for industrial sources and earthmoving operations, 3) Site visits of monitoring sites and surrounding areas, and 4) Interviews with MCESD staff, other government staff and industrial sources. 4.2 OVERVIEW OF METHODOLOGY Wind direction and PM10 concentrations recorded by the four air quality monitors and meteorological stations located in the Salt River PM10 Study Area during the May through June 2002 Salt River Monitoring Study were reviewed for elevated ambient PM10 levels. Site visits and satellite image interpretation in conjunction with wind direction analysis were used to determine an appropriate study area for the Salt River area. In addition, all significant permitted industries within the study area were identified from MCESD permit records and site visits, and then located on satellite images of the Salt River PM10 Study Area. The resulting study area consisted of 630 grid cells, 400 meters by 400 meters with the southwest corner of the grid set at 59th Avenue and Baseline Road. A Cartesian coordinate system was used to specify the gridding of the study area. ADEQ estimated the point source and area source PM10 emissions for the Salt River PM10 Study Area based on MCESD’s earthmoving and industrial sources files and through satellite image analysis of land use, road networks, and field trips to verify land use and to collect activity data. An hourly PM10 source emissions profile file was also built for the various PM10 sources in the Salt River PM10 Study Area whose emissions can vary by hour of the day. These sources included vehicular traffic and various types of construction and industrial activity. After the gridded land use and hourly emissions profile files were built, the files were input to GRIDTEST. GRIDTEST is an emissions model, written by ADEQ Air Evaluation staff, which converts land use and traffic data to hourly emission rates and hourly emission scalars for each of the 630 grid cells in the Salt River PM10 Study Area. The output of GRIDTEST, PM10 emissions (g/s/m2) for each cell in the study area was combined with a file of PM10 emissions from industrial point sources in the study area to produce the PM10 emissions file that was input to EPA’s ISCST3 model for estimating ambient PM10 levels (ISCST3 modeling will be discussed in Chapter 5 of this TSD). The GRIDTEST program was also Chapter 4 – Salt River PM10 Emissions Inventory 4-2 used to generate individual categories of PM10 emissions to model in ISCST3 to perform area source sensitivity tests. The following sections will describe in detail the methodology used to build the PM10 emissions inventory for the Salt River PM10 Study Area. 4.2.1 Satellite Image Analysis Land use of the areas in the Salt River Study Area was characterized from a 1-meter satellite image (IKONOS, March 2002). This image was a pan sharpened composite of 1-meter black and white image and a 4-meter color with infrared band. The satellite image was used to identify and quantify area and linear sources of PM10. The linear sources included freeway, paved primary, paved secondary and unpaved roads. The area sources included paved and unpaved parking lots, surface mining, areas with disturbed topsoil, and earth moving activities. GIS and satellite image processing software were used to process and analyze satellite images of the Salt River PM10 Study Area to estimate emissions from land use, roads, and industrial sources. Following are the steps used to identify and quantify land use that contributed to PM10 emissions in the Salt River PM10 Study Area: 1) Overlay grid pattern on satellite image (630 grid cells, 400 x 400 meters) 2) Print enlargements of satellite image - blocks of 4 grid cells (approx. 158 blocks for reference during field trips) and selected individual grid cells that have complex land use. 3) In the office, make preliminary land use identification and annotate the land use on the satellite image printouts (e.g., location and extent of agricultural fields, paved roads). 4) In the field, verify land use, and if necessary, revise the annotated satellite image printouts. 5) In the office, use ArcGIS Editor (ESRI) to digitize the land use into the categories listed below. 6) Using ArcGIS, sum the area or length of each land use category by grid cell (e.g., 800 square meters of agricultural land and 1,000 meters of primary paved roads in grid cell #145) and export to a spreadsheet. 7) QA / QC the land use totals and produce a gridded land use file for input to the GRIDTEST emissions model for calculating gridded hourly emissions. Chapter 4 – Salt River PM10 Emissions Inventory 4-3 Based on satellite image analysis and field trips, the following categories were identified and assigned to the Salt River PM10 Study Area for input into the GRIDTEST program and are discussed in detail in the following sections: • Agricultural Land • Alluvial Channels • Construction Areas • Misc. Disturbed Areas (a.k.a. open areas) • Paved Primary Roads • Paved Secondary Roads • Paved Parking Lots • Unpaved Roads • Unpaved Road Shoulders • Unpaved Parking Lots • Surface Mining • Vacant Lots See Appendix A for a map showing a satellite image of the study area with an overlay of the above land uses (Map A-2). 4.2.2 Fugitive Dust Study MCESD and ADEQ conducted a field study between June 1 and December 31, 2002 to identify the locations of activities in the Salt River PM10 Study Area that produce fugitive dust. Every three days during the study (except for weekends and holidays), two teams would drive through the study area looking for fugitive dust being produced (e.g., see dust in the air). One team would do a survey in the morning and the other team would do a survey in the afternoon. While in the field, the teams would record the locations and types of fugitive dust producing activities on printouts of a satellite image of the study area. These observations were not a comprehensive survey of land use in the study area, nor a complete time line of when fugitive dust was produced in the study area. Rather, the observations were “snapshots” of when the teams saw fugitive dust being produced (i.e., emissions could not be directly quantified from the observations). The observations were used to identify those areas in the study area that had possible fugitive dust problems for further follow up in developing an emissions inventory for the study area. Chapter 4 – Salt River PM10 Emissions Inventory 4-4 In the office, the teams reviewed the observations and grouped the observations into the following twelve categories: • Agriculture – General activity associated with agricultural practices (e.g., plowing, harvesting). • Earthmoving – General activities associated with construction (e.g., scraping, grading, trenching). • Trackout – Soil or bulk material on a paved street surface • Material Handling – Vehicle traffic on dirt or gravel roads at construction, industrial, or commercial sites (e.g., front-end loaders, bulldozers, loading bulk material into haul trucks or processing equipment) • Diesel Exhaust – Exhaust from internal combustion engines that use diesel as fuel (e.g., haul trucks, front-end loaders, industrial equipment) • Wind Event – Dust that becomes airborne due to wind movement (e.g., material being picked up by wind gusts, dust devils) • Unpaved Hauling – Vehicle traffic on dirt or gravel roads at construction, industrial, or commercial sites (e.g., haul trucks on roads and forklifts in work areas) • Process Equipment – Mechanical equipment used to produce a product or perform a specific function that produces particulates (e.g., crushers, screens, conveyor belts, abrasive blasting) and associated control equipment to reduce emissions (e.g., cyclones, baghouses) • Unpaved Parking – Vehicle traffic on unpaved parking areas (e.g., unpaved parking areas at a business or commercial enterprise) • Burning – Open burning (e.g., cooking fires, fire fighting training) • Street Work – Activity associated with street maintenance (e.g., street sweeping, general road construction, disturbance of road surface to access underground utilities) • Other – General hazy or dusty conditions in an area that can not be attributed to a specific fugitive dust source and other miscellaneous emission sources, such as landscaping equipment See Appendix A for a map depicting the locations and types of fugitive dust producing activities that were observed during the study (Map A-3). Figure 4-1 contains a pie graph showing the relative percentages of the different types of fugitive dust sources observed during the Fugitive Dust Study. Chapter 4 – Salt River PM10 Emissions Inventory 4-5 Figure 4-2 shows the percentage of material handling observations attributed to vehicle traffic on dirt or gravel roads at construction and industrial sites. Figure 4-3 shows the percentage of trackout observations that were attributed to construction, industrial, and private sources and Figure 4-4 shows the percentage of unpaved hauling observations that were attributed to industrial and commercial sources. Figure 4-1 Salt River Fugitive PM10 Observations (June 1 - December 31, 2002) Burning 2.9% Unpaved Parking 3.2% Process Equipment 5.4% Other 2.8% Earthmoving 5.3% Agriculture 5.4% Street Work 1.8% Trackout 15.7% Wind 6.2% Material Handling 11.9% Dirt Shoulder 18.6% Unpaved Hauling 16.0% Figure 4-2 Diesel 4.8% Salt River Fugitive PM10 Observations Material Handling: Vehicle traffic on dirt or gravel roads at construction, industrial, or commercial sites (76/90 traced to specific source category) Construction 17% Industriall 83% Chapter 4 – Salt River PM10 Emissions Inventory 4-6 Figure 4-3 Salt River Fugitive PM10 Observations Trackout: Any evidence of bulk material on paved street surface (50/113 traced to specific source) Private 18% Construction 40% Industrial 42% Figure 4-4 Salt River Fugitive PM10 Observations Unpaved Hauling:Vehicle traffic on dirt or gravel roads at construction, industrial, or commercial sites (84/121 traced to specific source category) Construction 29% Industrial 71% Chapter 4 – Salt River PM10 Emissions Inventory 4-7 4.3 DEVELOPMENT OF 24-HOUR EMISSIONS INVENTORY The following sections describe the data sources, assumptions and equations used for calculating PM10 emissions from sources in the Salt River PM10 Study Area. 4.3.1 Paved Roads 4.3.1.1 Interstate 17 EPA’s MOBILE6.2 model was used to develop PM10 emission factors for the Durango Curve section of Interstate 17, which is the portion of Interstate 17 that is in the Salt River PM10 Study Area. The Durango Curve is an eight-lane freeway with an average daily traffic volume of about 120,000 vehicles per day. Traffic count data provided by the Arizona Department of Transportation (ADOT) were processed and formatted for input to the MOBILE6.2. The PM10 monitoring sites nearest the Durango Curve are the Salt River and Durango monitors, located 0.7 and 0.65 miles respectively from the freeway. The MOBILE6.2 model (released by EPA in 2002) was used to calculate PM10 emissions factors for exhaust, brake wear and tire wear emissions from mobile sources on the Durango Curve using hourly and day of week traffic count data as inputs. The reentrained road dust emission factor was calculated using EPA’s AP-42 guidance. In addition, the above emission factors were separated into two vehicle class categories: heavy duty vehicles (HD) and light duty vehicles (LD) that reflected the vehicle mix on the Durango Curve. ADOT, in their traffic count data, defines HD vehicles as vehicles that are more than thirty feet in length and LD vehicles as vehicles thirty feet or less in length. Table 4-1 lists the emission factors used to estimate PM10 emissions from mobile sources on the Durango Curve. The weighted average PM10 emission factor (HD traffic count vs. LD traffic count) of LD and HD vehicles was 0.124 g/mi, while the HD vehicle emission factor was 0.438 g/mi and the LD vehicle emission factor was 0.089 g/mi. It is important to note that the overall HD vehicle emission factor (brakes, tire, exhaust and reentrained road dust) is approximately five times higher than the LD vehicle emission factor, and that the HD vehicle emission factor for brakes, tires, and exhaust is over twelve times higher than the LD vehicle emission factor for this category. These differences in emission rates between HD and LD vehicles points to the necessity to segregate traffic count data into HD and LD vehicles before calculating freeway emissions. Chapter 4 – Salt River PM10 Emissions Inventory 4-8 TABLE 4-1 Freeway Emission Factors for Durango Curve PM10 Emission Factor Category Emission Factor g / VMT Combined Emissions - Weighted (brakes, tires, exhaust, reentrained road dust from LD and HD vehicles) 0.124 Combined Emissions - HD Vehicles (brakes, tires, exhaust, reentrained road dust) 0.438 Combined Emissions - LD Vehicles (brakes, tires, exhaust, reentrained road dust) 0.089 Reentrained Road Dust – Weighted Brakes, Tires, Exhaust - Weighted Brakes, Tires, Exhaust – HD Vehicles Brakes, Tires, Exhaust – LD Vehicles Ratio of HD Emissions to LD Emissions 5 0.059* 1 0.060 0.379 0.030 13 * EPA AP-42 guidance recommends that the average weight of all vehicles be used to calculate an emission factor for reentrainment and that a separate emission factor not be calculated for individual vehicle classes. (Bill Kuykendal, with EPA at 919-541-5372, also confirmed that an average vehicle weight should be used when calculating the reentrainment emission factor.) 4.3.1.2 Primary Paved Roads Primary paved roads within the Salt Site Study Area included the roads running east to west - Van Buren, Buckeye, Lower Buckeye Road, Broadway Road, Southern Avenue, and Baseline, and north to south – 59th Avenue (northbound only), 51st Avenue, 43rd Avenue, 35th Avenue, 27th Avenue, 19th Avenue, 7th Avenue, Central Avenue and 7th Street. Average Daily Traffic (ADT) for each primary road in the study area was obtained from the City of Phoenix Traffic Volume Map, 1999. This map can be found on the web at http://www.ci.phoenix.az.us/STREETS/counts.html. All sections of primary roads occurring in an individual cell of the study area were assigned ADT from this map. See Appendix C for a listing of ADT for Primary and Secondary Paved Roads for each grid cell in the Salt River PM10 Study Area. Following is an example of the ADT assignment: Given, Primary Road #1 in Cell #10 • ADT1 = 1,000 vehicles per day • L1 = Length of Primary Road #1 in Cell #10 = 350 meters Chapter 4 – Salt River PM10 Emissions Inventory 4-9 Primary Road #2 in Cell #10 • ADT2 = 6,000 vehicles per day on Primary Road #2 • L2 = Length of Primary Road #2 in Cell #10 = 200 meters Then, Average ADT in Cell #10 = [(ADT1 x L1) + (ADT2 x L2)] / (L1 + L2) Average ADT = [(1000 x 350) + (6000 x 200)] / (350 + 200) = 2,818 vehicles / day in Cell #10 The total length of primary paved roads in the Salt River PM10 Study Area was approximately 144 kilometers. Vehicle miles traveled (VMT) were calculated for each grid cell by multiplying the average daily traffic (ADT) by the length of primary paved roads in a grid cell. ADEQ collected road dust samples from paved roads at 5 locations in the Salt River PM10 Study Area. The road dust samples were collected using a vacuum cleaner while the roads were temporarily blocked by City of Phoenix Road Department staff using a sign truck. The following road locations were sampled: • Sample 1 - 19th Avenue south of Lower Buckeye Road November 7, 2002, road dust was collected from the two southbound lanes. Area = 24 ft wide by 12 ft long (288 square feet). • Sample 2 - 19th Avenue between Salt River Bridge and Broadway Road On November 7, 2002, road dust was collected from the two northbound lanes. Area = 24 feet wide by 15 feet long (360 square feet). • Sample 3 - West Broadway Rd just east of 38th Drive On October 22, 2002, road dust was collected from the two eastbound lanes. Area = 24 feet wide by 12 feet long (288 square feet). • Sample 4 - 51st Ave just south of Salt River Bridge. On October 22, 2002, road dust was collected from the northbound lane. Area = 14 feet wide by 18 feet long (252 square feet). • Sample 5 – Lower Buckeye Rd just west of 35th Avenue On October 22, 2002, road dust was collected from the two eastbound lanes. Area = 30 feet wide by 12 foot long (360 square feet). These samples were sent to an engineering laboratory, Kleinfelder and Associates, to determine their silt content and mass. An average silt loading value of 0.30 g/m2 was determined based on the laboratory’s sieve analyses. (Engineering Science,1988). Following are the calculations and PM10 emission factors that were used to calculate the PM10 emissions from primary paved roads. Chapter 4 – Salt River PM10 Emissions Inventory 4-10 Paved Road Emission Factor - EFpaved road The paved road emission factor (EFpaved road) includes reentrained road dust along with contributions from vehicle exhaust, brake wear and tire wear. The emission factor for paved roads was calculated using the following equation from Section 13.2.1 of AP – 42 (EPA, 2001c): EFpaved road = 7.3 * (sL / 2)0.65 * (W/3)1.5 in units of g/VMT where: EFpaved road = Paved road emission factor grams/vehicle miles traveled (g/VMT). sL = road surface silt loading (g/m2). W = average vehicle weight (tons). Using an average silt loading of value of 0.30 g/m2, and an average vehicle weight of 3 tons (national average), the PM10 emission factor for paved roads is 2.13 g/VMT. Brake, Tire, Exhaust Emission Factors The MOBILE6 model was used to derive the emission factors for brake, tire, and exhaust for traffic activity on primary paved roads in the Salt River PM10 Study Area: • Exhaust Emission Factor (Evehicle exhaust) = 0.065 g/VMT • Brake Wear Emission Factor (Ebrake wear) = 0.013 g/VMT • Tire Wear Emission Factor (Etire wear) = 0.009 g/VMT The above emission factors were reported in Pechan’s report, “1999 and 2013 Emission Estimates for the Yuma Arizona PM10 Nonattainment Area Maintenance Plan, Final Report” (Pechan, 2002). Primary Paved Roads Emissions Calculation Epaved roads = EFpaved road x (L / 1,600 m/mi) x Veh/day where: Epaved roads = PM10 emissions from paved roads (grams) EFpaved roads = Paved road emission factor in g/VMT = 2.13 g/VMT L Length of paved road (meters) = Veh/day = Vehicles per day Chapter 4 – Salt River PM10 Emissions Inventory 4-11 Note: The paved road emission factor (2.13 g / VMT) incorporates the emission factors for reentrained road dust (2.043 g/VMT), vehicle exhaust (0.065 g/VMT), brake wear (0.013 g/VMT), and tire wear (0.009 g/VMT). The reentrained road dust emission factor was derived by subtracting the emission factors for vehicle exhaust, brake wear and tire wear from the paved road emission factor (2.13 g/VMT). The emissions for reentrained road dust, vehicle exhaust, brake wear, and tire wear were calculated separately using the above paved roads emissions equation with the appropriate emission factor (e.g., use the vehicle exhaust emission factor of 0.065 g/VMT to calculate vehicle exhaust emissions). 4.3.1.3 Secondary Paved Roads Daily traffic counts were not available for secondary paved roads. ADEQ assumed that the daily traffic counts on secondary paved roads are 10% of the daily traffic counts on primary paved roads. This assumption was based on previous work in the 1997 Maricopa County PM10 SIP (ADEQ, 1997). The total length of secondary paved roads in the study area was approximately 402 kilometers. The calculation of PM10 emissions from secondary paved roads was treated in a similar fashion to the calculations of PM10 emissions from primary paved roads. 4.3.2 Unpaved Shoulders Unpaved shoulders of paved roads produce PM10 emissions when high profile vehicles (e.g., buses, large vans, delivery trucks, semi trucks, dump trucks) reentrain dust from the unpaved shoulders as these vehicles travel down the road. This is due to the wake effect of these large vehicles, which is much larger than the wake effect from automobiles or other small vehicles. To better evaluate the contribution of unpaved shoulders to PM10 emissions in the study area, ADEQ conducted a field survey to determine the amount of high profile vehicle traffic. This survey was patterned after a study reported in the Journal of Air & Waste Management Association (Moosmuller et al, 1998), in which a PM10 emission factor for unpaved shoulders along paved roads was developed. Three sites were selected in the study area for surveying high profile vehicle traffic: a) Southern Avenue and Hidalgo, b) 35th Avenue, one block north of Baseline, and c) Baseline between 43rd and 51st Avenues. The survey was conducted in the late morning (11 am), early afternoon (1 pm) and mid afternoon (4 pm) for 15 minutes at a time. The vehicles that were counted during each 15-minute observation were: a) low profile vehicles, which included cars and pickup trucks, and b) high profile vehicles which included buses, large delivery vans, semi trucks, dump trucks, vans whose length to height ratio was two or greater, and vans with roofs that an average person could barely touch from the ground. ADEQ’s survey indicates that approximately 10% of vehicle traffic in the study area is high profile vehicles. The Moosmuller (1998) study reported that high profile vehicles, traveling at 50 – 60 mph, had a PM10 emission factor of 12.88 ± 6.44 gm/VMT (8 ± 4 gm/VKT). The emission factor previously calculated for primary roads in the Salt River Study Area is Chapter 4 – Salt River PM10 Emissions Inventory 4-12 2.13 gm/VMT. Thus, a high profile vehicle may have an emission rate 10.75 g/VMT greater than a low profile vehicle. Since high profile vehicles represent ten percent of the average daily traffic in the study area, the additional emissions from overall vehicle traffic in the study area would be calculated using an emission rate of 1.08 gm/VMT. The emissions from unpaved shoulders were estimated using a similar equation to that used for paved road emissions: Eroad shoulder = EFroad shoulder x (L / 1,600 m/mi) x Veh/day where: Eroad shoulder = EFroad shoulder = L = Veh/day = PM10 emissions from unpaved shoulder in grid cell (grams) 1.08 g/VMT Total length of unpaved shoulders (meters). Total number of vehicles per day (both low profile and high profile) 4.3.3 Trackout Onto Paved Roads Trackout onto paved roads can be transitory, especially after a rain event or a material spill on a road. Prompt cleanup and street sweeping will greatly reduce the emissions in these instances. However, there appeared to be long term trackout on 43rd Avenue south of Lower Buckeye Road due to facilities along that road. This was reported to ADEQ by City of Phoenix Road Department staff and was also observed by ADEQ staff during site visits (See Figure 4-5 for two photographs of trackout). See Appendix D for a detailed description of a trackout field study done by ADEQ to assess trackout conditions on 43rd Avenue. Trackout was grouped into four classes of loading on unpaved roads with associated silt loading and emission factors based on ADEQ’s trackout study. Table 4-2 lists these values for trackout classifications, silt loadings and emission factors. See Appendix K for a discussion of the methodology used for weighting trackout emissions. TABLE 4-2 Trackout and Emission Factors Trackout Classification Class 1 Extreme Class 2 Average Class 3 Minimum Class 4 No Trackout Description Equivalent to heavy trackout found on 43rd Avenue south of Lower Buckeye Road Equivalent to the trackout values recommended by ADOT. Emission factor is approximately 6X larger than the average primary road emission factor (Class 4 in this table) per ADOT guidance. Equivalent to silt loading halfway between Class 2 value (3 g/m2) and Class 4 value (0.3 g/m2). Emission factor is also halfway between Class 2 value (12 g/VMT) and Class 4 value (2 g/VMT). No trackout associated with this class. The silt loading and emission factor are equivalent to average values for primary roads in study area. Chapter 4 – Salt River PM10 Emissions Inventory Silt Loading (g/m2) 8 – 11 Avg. = 9 3 Emission Factor (g/VMT) 29 1.65 7 0.3 2 12 4-13 Figure 4-5 – Trackout on 43rd Avenue, looking south and north respectively. Photos taken September 22, 2003 Chapter 4 – Salt River PM10 Emissions Inventory 4-14 4.3.4 Unpaved Roads and Unpaved Parking Lots The location and extent of unpaved roads and unpaved parking areas were determined from satellite image analysis and site visits by ADEQ and MCESD staff. 4.3.4.1 Unpaved Roads Emissions from unpaved roads in the Salt River PM10 Study Area are considered negligible (data on unpaved haul roads are included in MCESD’s permit records for industrial sources). After analysis of the satellite image of the Salt River PM10 Study Area, field trips by ADEQ staff, and meetings with MCESD inspectors, only two unpaved roads were located in the study area. ADEQ staff, in a subsequent field trip to investigate the two unpaved roads, determined that the two roads were private industrial access roads and had minimal VMT. One road is located south of Lower Buckeye Road off of 35th Avenue and extends about 200 meters west. The other road is located west of 35th Avenue off of Lower Buckeye Road and follows a railroad spur south about 400 meters. 4.3.4.2 Unpaved Parking Lots The majority of small unpaved parking lots in the Salt River PM10 Study Area are located along Broadway Road between 19th Avenue and 35th Avenue. The Manzanita Speedway located at Broadway Road and 35th Avenue has unpaved parking for spectators on the north side of the speedway and dirt parking for contestants on the south side of the racetrack. The Manzanita Speedway’s parking lot has entrance gates which are typically locked except for the Friday and Saturday night races. The Maricopa County Jail on Durango Road also has large unpaved parking areas for staff and visitors. PM10 emissions from unpaved parking lots were calculated using the same type of formulas with the same emission factors as those used for unpaved roads (EPA ,1988 and Engineering Science, 1988). Following is the PM10 emission factor and the calculations that were used to estimate the PM10 emissions from unpaved parking lots. Unpaved Parking Lot Emission Factor - EFup (Note: the same emission factor is used in calculating PM10 emissions from both unpaved parking lots and unpaved roads.) EFup = 5.9K x (s/12) x (S/30) x (W/3)0.7 x (w/4)0.5 x ((365-p)/365) Where: EFup s S W w p K VMT = = = = = = = = Unpaved road PM10 emission factor (lb/VMT) Silt content - fraction of particles 75 µm diameter or less Average vehicle speed in miles per hour (mi/hr) Vehicle weight in tons or megagrams (Mg) Number of wheels per vehicle Number of days per year with greater than 0.01 inches precipitation Aerodynamic particle size multiplier Vehicle miles traveled Chapter 4 – Salt River PM10 Emissions Inventory 4-15 For PM10 K = 0.36 Default values used to calculate EFup: s = 10 percent S = 15 mi/hr W = 2 tons w = 4 wheels per vehicle p = 30 days The result is an unpaved road emission factor of EFup = 0.55 lb/VMT or 250 g/VMT. (To convert from lb/VMT to g/VMT multiply by 454 g/lb.) Unpaved Parking Lot PM10 Emissions Calculations Average hourly traffic (AHT) on unpaved parking lots is needed to estimate the contribution of unpaved parking lots to PM10 emissions in the study area. Following are the assumptions, ADEQ used to estimate AHT on unpaved parking lots: • • Average time a car is parked in an unpaved parking lot is 30 minutes = 20% turnover of parked cars per hour Average distance driven in an unpaved parking lot = length + width of the parking lot The following equation was used to estimate PM10 emissions from unpaved parking lots: Eunpaved parking lot = EFup * (L + W) * 0.2 * N Where: Eunpaved parking lot = PM10 emissions from unpaved parking lot (grams) EFup = Unpaved road emission factor = 250 g / VMT L = length of unpaved parking lot W = width of unpaved parking lot 0.2 = 20% turnover of parked cars (e.g., 20% entering / leaving parking lot) N = number of parked vehicles ADEQ estimated the length and width of unpaved parking lots from satellite image analysis and field trips, and estimated the number of parked vehicles in a parking lot through field trips. The uncontrolled emissions calculated in the preceding equation were reduced by 55% to account for the control measures in MCESD’s Rule 310.01. Parking lots with a gravel surface are estimated to have 60% less emissions than dirt parking lots. Chapter 4 – Salt River PM10 Emissions Inventory 4-16 4.3.5 Wind Erosion of Disturbed Areas PM10 emissions were estimated from areas with disturbed topsoil that are vulnerable to wind erosion in the Salt River PM10 Study Area. Following are the categories of disturbed areas that were investigated: • Wind Erosion – Agricultural • Wind Erosion – Alluvial Channels • Wind Erosion – Construction • Wind Erosion – Miscellaneous Disturbed Areas • Wind Erosion – Vacant Lots • Wind Erosion – Unpaved Parking Lots PM10 emissions from wind erosion of unpaved road shoulders were considered negligible since the surface area of unpaved road shoulders was 0.2% of the total surface area of all disturbed areas ((68,889 m2 / 30,256,222 m2 = 0.00227 or 0.2%). See Appendix E for a detailed description of a field study conducted by ADEQ to identify and quantify areas in the Salt River alluvial channel that had different soil stabilities and thus different wind erosion PM10 emissions. PM10 emissions resulting from wind erosion were estimated for the two design days with hourly wind speeds greater than 15 mph – April 15 and April 26, 2002. April 15, 2002 had four hours with wind speeds greater than 15 mph: 14:00, 15:00, 16:00, and 17:00. April 26, 2002 also had four hours with wind speeds greater than 15 mph: 14:00, 15:00, 17:00, and 18:00 (18:00 is 6:00 PM). The emission factor used in estimating PM10 emissions from wind erosion was based on studies by Nickling and Gillies (1986) and Engineering Science (1988). These studies used a portable wind tunnel and silt sampling at various locations in Arizona to determine an emission factor for wind erosion of Arizona soils. The wind erosion emission factor equation appears below. Wind Erosion Emission Factor ( EFwind erosion ) EFwind erosion = F * FC where: EFwind erosion = PM10 emission rate for wind erosion (g / cm2 / sec) F = flux rate of 1.71 * 10-21 * U 4.355 ( g / cm2 sec ) U = wind speed at 10 meter height (cm / sec) FC = Fetch correction = 1/3 (log (3.281* d)) for d < 300 meters d = fetch length (meters) The wind erosion emission factor equation is from the Nickling and Gillies report, “Evaluation of Aerosol Production Potential of Type Surfaces in Arizona”, 1986. The threshold wind speed for wind erosion is an important factor in estimating emissions for a windblown dust episode. As previously discussed, portable wind tunnel studies conducted in Arizona have reported threshold wind speeds ranging from 12 mph to 25 mph depending on location. Threshold wind speed can vary due to local soil moisture, local silt content, type of soil, amount of crusting, and amount of wind shadowing. Chapter 4 – Salt River PM10 Emissions Inventory 4-17 In the Phoenix PM10 Microscale Study, conducted by ADEQ and MCESD in 1995 (ADEQ, 1997) wind speed, wind direction and ambient PM10 measurements were made every 30 minutes (PM10 measurements made using a TEOM or tapered element oscillating microbalance). After ADEQ reviewed the meteorological and PM10 data for the April 9, 1995 24-hour PM10 exceedance, it was apparent that the PM10 levels began to increase dramatically after the wind speed reached 15 mph. A threshold wind speed of 15 mph was also reported in a DRI study of wind erosion and PM10 levels in Las Vegas, Nevada (DRI, 2000). Thus, ADEQ used 15 mph as the threshold wind speed for wind erosion. Wind Erosion Emission Calculation ( Ewind erosion ) Ewind erosion = EFwind erosion * (A * (104 cm2 / m2 )) * (T * 3600 sec/hr) * (metric ton / 106 g) Where: Ewind erosion = PM10 emissions due to wind erosion (metric tons) EFwind erosion = PM10 emission rate for wind erosion (g / cm2 / sec) A = Area of disturbed areas (m2) from agriculture, alluvial channels, construction activity, misc. disturbed, vacant lots, and unpaved parking lots (each emission category calculated separately for wind erosion) T = Number of hours with wind speed greater than 15 mph Example for 50 meter x 10 meter Field: EF = 6.22 * 10-8 gm / (cm2 – sec) A = 50 meters * 100 meters = 5 * 103 m2 = 5 * 107 cm2 T = 4 hours wind duration greater than 15 mph E = (6.22 * 10-8 gm/cm2-sec) * (5 * 107 cm2) * (4 hrs * 3600 sec/hr) * (1 metric ton / 106 g ) = 0.045 metric tons per day Example for Construction Windblown Dust in Study Area (converting total area in m2 to metric tons per day): The emission factor per m2 is given by: EF = 6.22 * 10-8 * 104 m2 * 4 * 3600 / 106 = 8.9568 * 10-6 metric tons per day per meter2 A = 5,661,710 meters2 of areas under construction in Salt River PM10 Study Area E = 8.9568 * 10-6 metric tons per m2 per day * 5,661,710 m2 of construction = 18.76 metric tons / day (See Table 4-5 which lists 18.76 metric tons per day for construction windblown dust) Chapter 4 – Salt River PM10 Emissions Inventory 4-18 Wind Erosion Control Measures – Vacant Lots, Misc. Disturbed Areas, Construction Sites MCESD conducted a rule effectiveness study in 2003 (MCESD, 2003). Based on this study, MCESD revised the control effectiveness of control measures for the following sources for the Year 2002: • Wind Erosion - Vacant lots and misc. disturbed areas = 55% • Wind Erosion – Construction = 63% Following are MCESD’s calculations for Year 2002 control measure effectiveness Wind Erosion - Vacant Lots: • Year 2002 control effectiveness = 90% control efficiency * 62% compliance rate = 55% overall control effectiveness in Year 20021 Wind Erosion – Construction: • Year 2002 control effectiveness = 90% control efficiency * 70% compliance rate = 63% overall control effectiveness in Year 20021 Wind Erosion Control Measure – Agricultural Fields Agricultural fields are considered to be vulnerable to wind erosion when the topsoil has been disturbed (e.g., by tilling). ADEQ assumed that the corn and cotton fields in the study area had not been planted before the two high wind design days (planting time of corn and cotton varies depending on weather conditions and the availability of irrigation allotments which may be reduced due to drought conditions). According to the Maricopa County Farm Bureau and the University of Arizona Cooperative Extension Service, planting of corn and cotton is associated with twice-a-month irrigation and the development of a soil crust which greatly reduces wind erosion. The fields for some crops are tilled after harvest, while other crops are not tilled until shortly before planting. See Appendix F for a detailed description of how ADEQ estimated which agricultural crops were being grown in the study area and when the different crop fields may have experienced wind erosion in Year 2002. These data were provided by the Maricopa County Farm Bureau and the University of Arizona Cooperative Extension Service and spatially allocated using satellite image analysis and field trips. The Agricultural PM10 General Permit (URS and ERG, 2001) for agricultural best management practices includes a control measure for wind erosion of agricultural land [The Arizona Administrative Register (A.A.R), Title 18, Chapter 2, §609-611 contains the rulemaking for the "Agricultural PM10 General Permit."]. This control measure is listed in the general permit as “Limited Activity During High Wind Events”. The URS report (URS and ERG, 2001), which evaluated the agricultural best management practices, gives this measure a midpoint control efficiency of 9.3%. However, this 1 MCESD conducted a rule effectiveness study in 2002 and 2003 (Appendix G), to review the compliance rate of Maricopa County Rules 301, 310.01, and Rule 316 in the Salt River PM10 Study Area. The compliance rate for Rule 310 was determined to be 80%, however, wind erosion was not a factor in the observations, therefore, MCESD adjusted the compliance rate for wind erosion – construction to 70%, as a conservative estimate. Chapter 4 – Salt River PM10 Emissions Inventory 4-19 measure takes effect when wind speeds are over 25 miles per hour. The wind speed on the two high wind design days did not exceed 15 mph. Thus, the emission reductions from this control measure were not applied to ADEQ’s estimate of emissions from wind erosion of agricultural land. 4.3.6 Agricultural Tilling Crop types, acreage of crops grown, and a crop calendar (which months agricultural operations occur) in the Salt River PM10 Study Area were obtained from satellite image analysis of the study area to locate agricultural fields and from the Maricopa County Farm Bureau and University of Arizona Cooperative Extension Service. Land preparation data for specific crops were obtained from the Technical Support Document for Quantification of Agricultural Best Management Practices report (URS and ERG, 2001). Agricultural Tillage Emission Factor The agricultural tillage emission factor was calculated as follows: EF = k (4.8) s0.6 where: EF k s = agricultural emission tillage factor (lbs PM10 / acre-pass) = particle size multiplier (value of 0.15 for PM10) = silt content of soil (percent). Setting s to 35.2% (URS and ERG, 2001), then EF = 0.15 × 4.8 × (35.2)0.6 = 6.10 lbs PM10 / acre-pass Agricultural Tillage Emission Calculation The months that the four design days occurred were compared with the crop calendar (see Appendix F) to determine which design days had agricultural tillage activity. Of the four design days, only January 8, 2002 appears to have agricultural tillage activity. PM10 emissions from agricultural tillage were calculated for the January 8, 2002 design day using the following equation (ARB, 1997): TillageCrop = EF × APCrop × ACrop × x AFcrop where: TillageCrop EF APCrop ACrop AFCrop = = = = = tillage emissions for a specific crop type (lbs PM10) tillage emission factor (lbs PM10/acre-pass) number of tillage passes per crop (passes) surface area of tilled land for a specific crop type (acres) fraction of annual tillage activity occurring on design day Chapter 4 – Salt River PM10 Emissions Inventory 4-20 Example: Assume: EF APCrop = = ACrop AFCrop = = 6.10 lbs PM10 / acre-pass 7 tillage passes for a cotton crop (e.g., laser level, rip, disk, landplane, incorporate herbicide/disk, list, mulch) 10 acres of cotton fields per grid cell of study area 0.01 (for January 8, 2002 design day) TillageCotton = = 6.10 lbs PM10 / acre-pass × 7 passes × 10 acres x 0.01 4.27 lbs PM10 Then: These PM10 emissions calculations do not take into account the emissions reductions from the recent implementation of the general permit for agricultural best management practices (BMPs), which includes control measures for agricultural tillage [Arizona Administrative Code (A.A.C), Title 18, Chapter 2, §610-611]. The URS and ERG report (2001) quantified the emission reductions for three agricultural best management practices listed in the Agricultural PM10 General Permit for tillage • Combining tractor operations – midpoint control efficiency of 7.9% • Limited activity during high wind events – midpoint control efficiency of 9.3% • Multi-year crops – midpoint control efficiency of 15.8% The “Combining Tractor Operations” best management practice was selected for the January 8, 2002 design day because this design day was not considered a high wind event because fields with multi-year crops had already been identified for the time period of the monitoring study. Following is the calculation of PM10 emissions from agricultural tillage after accounting for the potential emission reductions from Maricopa County farmers implementing Ag BMPs (URS and ERG, 2001). E Controlled = E × (100% − BMP) where: EControlled E BMP = Controlled PM10 emissions from agricultural tillage after agricultural BMPs = Uncontrolled PM10 emissions from agricultural tillage = Percent emissions reduction from the BMPs Chapter 4 – Salt River PM10 Emissions Inventory 4-21 Example: E BMP = 10 tons PM10 from cotton = 7.9% Then: EControlled = 10 tons PM10 × (100% − 7.9%) = 9.21 tons PM10 The total amount of cotton and corn in the Salt River PM10 Study Area that was tilled on the January 8, 2002 design day was 1,769,600 m2 of cotton and 856,000 m2 of corn (haylage). 4.3.7 Agricultural Harvesting The months that the four design days occurred were compared with the crop calendar (see Appendix F) to determine which design days may have had agricultural harvesting activity. None of the four design days (January 8, April 15, April 26, December 16) appear to have agricultural harvesting activity. Thus, no emissions were calculated for this source category. See Appendix F for additional details on the development of crop types, crop calendar, and estimated number of acres of crops in the Salt River PM10 Study Area. 4.3.8 Construction Activity 4.3.8.1 Road Construction ADEQ planned on using the road construction emission factor listed in MRI’s 1996 report, “Improvement of Specific Emission Factors”, for estimating emissions from road construction (0.11 tons/acre/month or 0.0338 gm/m2/hour). However, review of MCESD’s earth moving permit records and conversations with MCESD staff indicate that there was no road construction in the Salt River PM10 Study Area in Year 2002. Thus, no road construction emissions were estimated for the study area. 4.3.8.2 Residential and Industrial Construction Areas with residential and construction activity in the Salt River PM10 Study Area were identified through satellite image analysis, MCESD records, site visits, and quarterly aerial photograph books that show current and planned construction (Rupp Aerial Photo 2001 and 2002) . Construction Emission Factors ( EFwind erosion ) EPA developed a new set of emission factors for residential construction that is an improvement on the AP-42 emission factors. The factors are based on based on a 1996 study by Midwest Research Institute (MRI, 1996). The new factors are as follows: Chapter 4 – Salt River PM10 Emissions Inventory 4-22 Single Home Construction Emission Factor (EFConst - New Home) • EFConst - Single Home = 0.032 tons/acre/month = 0.0098 g / m2 / hour Apartment Construction Emission Factor (EFConst - Apartment) • EFConst - Apartment = 0.11 tons/acre/month = 0.0338 g / m2 / hour The apartment construction emission factor also applies to construction of housing developments and industrial construction that do not involve substantial earth moving. The MRI report included an emission factor for a worst-case construction emissions scenario. This emission factor is appropriate for large-scale construction projects that involve substantial earthmoving operations. Large Scale Construction Emission Factor (EFConst – Large Scale) • EFConst – Large Scale = 0.42 tons/acre/month = 0.129 g / m2 / hour MRI's report points out that the emission factor for large scale construction is approximately 71% lower than the previous emission factor listed in EPA’s AP-42, Fourth Edition. South Coast Air Quality Management District (SCAQMD) uses the large-scale construction emission factor for estimating PM10 emissions from construction projects that involve substantial earthmoving operations. The remainder of California, which does not have as detailed construction information as SCAQMD, uses the construction emission factor of 0.11 tons/acre/month (0.0338 g / m2 / hour). Clark County, Nevada also uses the construction emission factor of 0.11 tons/acre/month (0.0338 g / m2 / hour) for estimating emissions from construction projects. Finally, the same values for emission rates for single home construction (0.032 tons/acre/month) and apartment construction (0.11 tons/acre/month) were used by Pechan and Associates for developing a PM10 emission inventory for Yuma, Arizona (Pechan, 2002). Chapter 4 – Salt River PM10 Emissions Inventory 4-23 Construction Emission Calculations ( Econstruction) Econstruction = EFconstruction * A where: Econstruction = PM10 emissions due to construction (g) EFconstruction = PM10 emission rate for construction (g / m2 / hour) • 0.0098 g / m2 / hour for single home construction • 0.0338 g / m2 / hour for housing developments, apartments, industrial construction • 0.129 g / m2 / hour for large-scale construction projects that involve substantial earthmoving operations A = Area under construction (m2) During 2002, construction in the Salt River PM10 Study area consisted of apartment complexes (multi-dwelling) and tract homes. ADEQ used a construction emission factor of 0.0338 g / m2 / hour (0.11 tons/acre/month) for these construction projects and applied MCESD’s control measure effectiveness of 56% for construction activity (MCESD Rule 310). MCESD estimated the overall control effectiveness for construction activity for Year 2002 to be 56% based on a 90% control efficiency and a 80% compliance rate and an adjustment to reflect future test method improvements [90% x 80% = 72%; 72% - 16% = 56%]. This will be discussed in the Emissions Summary section of this report. 4.3.9 Lawn Care Exhaust emissions from gasoline powered equipment used for professional lawn care in the Salt River PM10 study area were estimated using satellite image analysis and U.S. Census data. Using a gridded satellite image, the number of housing units in each grid cell (400 x 400 meters) in the study area that contained residential housing with lawns were counted (lawns show up as false color red on infrared band of satellite image). The number of housing units per cell was then multiplied by three to obtain an estimate of the number of people per grid cell. According to the U.S. Census Bureau, (http://factfinder.census.gov/), the average size household in Arizona is approximately three people (census map shows a household range from 2.67 to 2.80 people). Lawn Care Equipment Emission Factor: The Maricopa Association of Governments, in their 1999 particulate plan (MAG, 2000), reported that 0.65 metric tons of PM10 per day originated from lawn and garden equipment exhaust. This value was based on a 1994 population of 2,355,900. Thus, the lawn care equipment emission factor is calculated as follows: Chapter 4 – Salt River PM10 Emissions Inventory 4-24 EFlawn care = (0.65 metric tons PM10 / 2,355,900 people) x 1,000,000 grams / metric ton = 0.276 grams per person per day. Lawn Care Emission Calculations ( Elawn care): Elawn care = EFlawn care * N Where: Elawn care EFlawn care N = PM10 emissions due to lawn care emissions (g) = PM10 emission rate for lawn care emissions (g / person / day) = Number of people Example: EFlawn care N = 0.276 grams per person per day. = 100 people Then: Elawn care = 0.276 g / person / day × 100 people = 2.76 g PM10 Due to the very small amount of emissions from this source (2.43 x 10-6 metric tons / day), ADEQ classified its emissions as negligible. 4.3.10 Restaurant Charbroilers Through discussions with MCESD food inspectors and field trips, four restaurants were located in the Salt River PM10 Study Area that had charbroilers. Charbroiler Emission Factor: The Maricopa Association of Governments, in their 1999 particulate plan (MAG, 2000), reported that 23.97 metric tons of PM10 per year originated from restaurant charbroilers in the Maricopa County PM10 Nonattainment Area. This value is based on a total of 84 restaurants which charbroil meat, a control measure effectiveness of 83% and an assumption that 80% of the restaurants had the control measure in place. Thus, the charbroiler emission factor is calculated as follows: EFcharbroiler = (23.97 metric tons / year PM10 ) / 84 restaurants x 1,000,000 grams / metric ton x year / 365 days = 0.000756 grams PM10 per restaurant per day. Chapter 4 – Salt River PM10 Emissions Inventory 4-25 Charbroiler Emission Calculations ( Echarbroiler) Echarbroiler = EFcharbroiler * N Where: Echarbroiler = PM10 emissions from restaurant charbroilers (g) EFcharbroiler = PM10 emission rate for restaurant charbroiler (g / restaurant / day) Example: EFcharbroiler = 0.000756 grams PM10 per restaurant per day. N = 4 restaurants Then: Echarbroiler = 0.000756 g / restaurant / day × 4 restaurants = 0.003024 g PM10 / day Due to the very small amount of emissions from this source, ADEQ classified its emissions as negligible. 4.3.11 Industrial Sources Industrial sources in the Salt River PM10 Study Area were identified through MCESD permits records for industrial sources and GIS analysis to determine if a source was located in the study area. 81 industrial sources were identified as operating in the study area during 2002. See Appendix A for a satellite image showing the locations of the 81 industrial sources (Map A-4) and a satellite image of the approximate property boundaries of industrial sources along the Salt River (Map A-5). MCESD provided emissions data for the 81 sources and these data were used in either assigning PM10 emissions from industrial sources to each applicable grid cell within the study area (i.e., treated as an industrial area source) or to a particular coordinate within the study area (i.e., treated as an industrial point source). The following information was provided by MCESD from their permit records database: 1) 2) 3) 4) 5) 6) 7) 8) PM10 emission rates for area sources (g/sec/m2), PM10 emission rates for point sources (g/sec), Stack height (m), Stack diameter (m), Stack exit velocity (m/sec), Stack temperature (Kelvin) Operating hours by day of week Street address Chapter 4 – Salt River PM10 Emissions Inventory 4-26 ADEQ ranked the 81 industrial sources according to their total annual emissions and their distance from the four air quality monitors in the Salt River PM10 Study Area. Based on this ranking, 36 sources were selected to be modeled separately in the ISCST3 model (see Chapter 5 for modeling discussion) and the remaining 45 sources had their emissions added to the grid cell where the source was located. See Appendix G for a detailed discussion of the methodology used to segregate the industrial sources for modeling purposes and for a listing of annual, daily, and hourly emission totals for each source. Following are the 36 sources that were input to the ISCST3 model as point sources: • APS WEST PHX POWER PLANT • UNITED METRO PLANT #11 • PHOENIX BRICK YARD • METAL MANAGEMENT ARIZONA INC • VULCAN MATERIALS CO-WESTERN • THE PROCTER & GAMBLE MFG CO • TRENDWOOD INC • WOODSTUFF MANUFACTURING • HANSON AGGREGATES OF ARIZONA • VAW OF AMERICA INC • WESTERN ORGANICS INC • TPAC A DIVISION OF KIEWIT WESTERN CO • SOUTH MOUNTAIN GIN • CORESLAB STRUCTURES (ARIZ) INC • AMERON INTL-WATER TRANSMISSION GROUP • OLSON PRECAST OF ARIZONA INC • AJAX SAND & ROCK • PHOENIX CEMENT TERMINAL • SANDVICK EQUIPMENT & SUPPLY CO • CITY OF PHOENIX 27TH AVE LANDFILL • SCHUFF STEEL CO • QUALITY BLOCK INC • MARLAM INDUSTRIES INC • MONIER LIFETILE LLC • ROAD MACHINERY CO INC • CHEVRON USA ASPHALT DIVISION • ATC PHOENIX • CITY OF PHOENIX WASTE WATER TREATMENT PLANT • UNIVERSAL ENTECH • U.S. GREEN FIBER • SOUTHWEST FOREST PRODUCTS • SMITH PRECAST • WESTERN BLOCK COMPANY • ROCKLAND MATERIALS • MCP INDUSTRIES, INC. • WEINBERGER TOPSOIL Chapter 4 – Salt River PM10 Emissions Inventory 4-27 MCESD Year 2001 emissions data for industrial sources were used to select which industrial sources in the Salt River PM10 Study Area would be modeled separately based on their total annual emissions and their proximity to a monitor. This selection was done prior to building the emissions inventory when complete Year 2001 emissions data was available from MCESD. At that time, Year 2002 MCESD emissions inventory was in the process of being reviewed for quality control by MCESD. However, MCESD did accelerate their quality control process to provide ADEQ with Year 2002 emissions data for the 36 industrial sources that ADEQ had selected for separate modeling. Thus, ADEQ used Year 2002 emissions data for the 36 sources and Year 2001 emissions data for the remaining small sources in their modeling. Emissions from the 36 sources (Year 2002 data) are approximately 98% of the emissions in the study area, and emissions from the remaining 45 small sources (Year 2001 data) make up approximately 2% of the emissions in the study area. The industrial windblown emissions were calculated by first determining the area for each of the major facilities from which windblown dust could originate. This area was generally the area of the facility, less buildings, paved roads, paved parking lots, or other surfaces (e.g. water) without dust potential. This area was then multiplied by the emission factor of 20.0 lbs/acre/hour (0.000622 grams/meter/second), which comes from W. G. Nickling and J. A. Gillies, “Evaluation of aerosol production potential of type surfaces in Arizona”, submitted to Engineering-Science, Arcadia, California, for EPA Contract No. 68-02-388, 1986. Windblown emissions from stockpiles were determined by examining the satellite images to estimate the area of the stockpiles. Then, following a method from Section 4.1.2 of Control of Open Fugitive Dust Sources, EPA-450/3-88-008, September 1988, emission factors were calculated based on the values of the peak wind gusts. In this method, the four hour high-wind events that occurred on both April 15 and 26, 2002, were treated as one windblown event per day. The emission factor depends on the magnitude of the peak wind gust, which on April 15, 2002 was 28 meters per second, and on April 26, 2002 was 37 meters per second. The corresponding emission factors for the two dates were 90 lbs PM10 / acre / event for April 15, 2002 and 197 lbs PM10 / acre / event for April 26, 2002 (assuming sand in the stockpiles). Emission factors for stockpiles with aggregate are about 30% lower than stockpiles with sand. The area of the stockpiles was multiplied by the above emission factors to give the windblown emissions from the stockpiles for the two high wind design days. 4.4 SUMMARY OF 2002 PM10 EMISSIONS INVENTORY A summary of the PM10 emissions in the Salt River PM10 Study Area for the Year 2002 follows. The emissions and land use data calculated for each of the 630 grid cells (400 x 400 meter) in the study area were summed to produce the emission and land use totals listed in the following tables and pie graphs. See Appendix A for 24-hour PM10 emissions density maps for 11 emission source categories, total PM10 emissions for a low-wind design day, and total PM10 emissions for a high-wind day (Map A-9 through Map A-21). Chapter 4 – Salt River PM10 Emissions Inventory 4-28 Table 4-3 lists the land use totals for emission sources that are not industrial sources. TABLE 4-3 Salt River PM10 Emissions Inventory - YEAR 2002 Land Use Totals (meters or meters2) 1. AREA SOURCES Ag Tilling (Land Preparation) 1/8/02 4/15/02 4/26/02 12/16/02 Low Wind High Wind High Wind Low Wind Tuesday Monday Friday Monday 2,625,600 m2 30,256,222 m2 30,256,222 m2 14,305,920 m2 14,305,920 m2 5,661,760 m2 5,661,760 m2 5,274,164 m2 5,274,164 m2 4,396,542 m2 4,396,542 m2 617,836 m2 617,836 m2 5,661,760 m2 5,661,760 m2 5,661,760 m2 5,661,760 m2 5,661,760 m2 5,661,760 m2 2,625,600 m2 Wind Erosion – Agricultural Wind Erosion – Construction Wind Erosion - Cleared Areas $ vacant lots $ misc. disturbed areas Wind Erosion – Alluvial Channels 3. NONROAD MOBILE SOURCES 8,287,360 m2 Agricultural Equipment Exhaust 2,625,600 m2 Construction Activity 5,661,760 m2 Chapter 4 – Salt River PM10 Emissions Inventory 4-29 TABLE 4-3 Salt River PM10 Emissions Inventory - YEAR 2002 Land Use Totals (meters or meters2) 1/8/02 4/15/02 4/26/02 12/16/02 Low Wind High Wind High Wind Low Wind Tuesday Monday Friday Monday 4. ONROAD MOBILE SOURCES Paved Roads 552,588 m 552,588 m 552,588 m 552,588 m 7,200 m 7,200 m 7,200 m 7,200 m 143,606 m 143,606 m 143,606 m 143,606 m 401,782 m 401,782 m 401,782 m 401,782 m 259,439 m2 259,439 m2 259,439 m2 259,439 m2 22,963 m (68,889 m2)* 22,963 m (68,889 m2)* 22,963 m (68,889 m2)* 22,963 m (68,889 m2)* Unpaved Parking Lots reentrained dust 190,550 m2 190,550 m2 * Based on an unpaved road shoulder width of 3 meters 190,550 m2 190,550 m2 Freeway (Interstate 17, Durango Curve) Primary Roads Secondary Roads Unpaved Sources Unpaved Road Shoulders Chapter 4 – Salt River PM10 Emissions Inventory 4-30 Table 4-4 lists the emission factors and rule effectiveness for applicable emission source categories. See Appendix I for MCESD’s Rule Effectiveness Study. TABLE 4-4 Salt River PM10 Emissions Inventory - Year 2002 Emission Factors and Rule Effectiveness Emission Category Percent Rule Effectiveness Emission Factor Applicable ADEQ, City of Phoenix or MCESD Rule 1. AREA SOURCES Agricultural PM10 General Permit for tillage (Ag BMPs): General: Ag Tilling (Land Preparation) 6.10 lbs PM10 / acrepass Combining Tractor Operations midpoint control efficiency Crop Specific: 0.427 lbs PM10 / acre of cotton 7.9% 0.305 lbs PM10 / acre of corn (haylage) Wind Erosion – Agricultural 6.22 * 10-8 gm / (cm2 – sec) Wind Erosion – Construction 6.22 * 10-8 gm / (cm2 – sec) This control measure takes effect when 10meter height wind speed exceeds 25 mph. The maximum wind speed for the high wind design days was 21 mph. Thus, the 9.3% rule effectiveness was not applied. 63% Agricultural PM10 General Permit for wind erosion (Ag BMPs): Limited Activity During High Wind Events - midpoint control efficiency MCESD Rule 310 Wind Erosion – Cleared Areas: $ vacant lots $ misc. disturbed areas Wind Erosion – Alluvial Channels 6.22 * 10-8 gm / (cm2 – sec) 6.22 * 10-8 gm / (cm2 – sec) Max 37.32*10-8 Avg.6.22 * 10-8 Min 3.11*10-8 gm / (cm2 – sec) Chapter 4 – Salt River PM10 Emissions Inventory 55% 55% MCESD Rule 310.01 MCESD Rule 310.01 None None 4-31 TABLE 4-4 Salt River PM10 Emissions Inventory - Year 2002 Emission Factors and Rule Effectiveness Percent Applicable ADEQ, City Emission Category Emission Rule of Phoenix or MCESD Factor Effectiveness Rule 2. INDUSTRIAL SOURCES Varies by source 88% Stack Emissions Non-Stack Emissions (e.g., crushing, screening, Equivalent Control = Varies by source earthmoving, mining, MCESD Rule 310 62% MCESD Rule 316 hauling, cement and asphalt formulation, and stockpiles) Wind-speed Windblown Industrial 0% dependent Sources 3. NONROAD MOBILE SOURCES Agricultural Equipment Exhaust Construction Activity 0.4 g / hp-hr None None Single Home = 0.032 tons/acre/month Apartment = 0.11 tons/acre/month MCESD Rule 310 56% Large Scale = 0.42 tons/acre/month Chapter 4 – Salt River PM10 Emissions Inventory 4-32 TABLE 4-4 Salt River PM10 Emissions Inventory - Year 2002 Emission Factors and Rule Effectiveness Percent Applicable ADEQ, City Emission Category Emission Rule of Phoenix or MCESD Factor Effectiveness Rule 4. ONROAD MOBILE SOURCES Paved Roads Freeway - Interstate 17 Durango Curve 0.124 g / VMT (specific to vehicle mix on Durango Curve) Reentrained Road Dust = 2.043 g/VMT None None None Exhaust Emission Factor = 0.065 g/VMT Primary Roads Brake Wear Emission Factor = 0.013 g/VMT None Tire Wear Emission Factor = 0.009 g/VMT Secondary Roads Trackout Unpaved Road Shoulders Unpaved Parking Lots reentrained dust Same as Primary Road Emission Factors Extreme = 29g/VMT None None MCESD Rule 316 MCESD Rule 310 MCESD Rule 310.01 Medium = 12g/VMT Minimal Low = 7g/VMT No Trackout = 2g/VMT 1.08 gm/VMT 250 g/VMT Chapter 4 – Salt River PM10 Emissions Inventory None 55% for unpaved parking lots > 0.10 acre None MCESD Rule 310.01 4-33 The Equivalent Control Percentage of 62% listed for Non-Stack Emission sources in the Industrial Source category of Table 4-4 was based on the following: EQ = equivalent control = CE * RE * RP Where: CE = control efficiency (how well a control device works) RE = rule effectiveness (how a control device’s efficiency is reduced by failure and/or uncertainty of performance) RP = rule penetration (percentage of sources covered by the regulation) In 2003, MCESD and ADEQ staff determined the effectiveness of Rules 310 and 316 in their application to the Salt River study area sources (see Appendix I, “Rule Effectiveness Study for Salt River PM10 Study Revised Final”, December 18, 2003). For Rule 316, 11 sources (sand and gravel, topsoil, concrete blocks, etc) had an average rule effectiveness of 88%. For Rule 310, 10 Salt River area facilities (precast concrete, sand and gravel, aggregate, block manufacture) had an average rule effectiveness of 77%. Facilities were graded on stack and fugitive emission opacity, recordkeeping, unpaved haul and access roads, trackout control devices, observations of trackout, and water availability. Given these survey results, the Year 2002 industrial emissions can be characterized with the following percentages: Rule Effectiveness = 82% (average of the 310 and 316 sources) Control Efficiency = 75% (overall estimate, higher for process emissions; lower for fugitives such as haul road emissions) Rule penetration = 100% (small geographical area with limited number of sources) EQ equivalent control = 62% Note that Industrial Source emissions for the Year 2002 and for the Year 2006 Base Case are the same. Only in the Year 2006 Attainment Case are additional emission reductions invoked for this category. Chapter 4 – Salt River PM10 Emissions Inventory 4-34 Table 4-5 lists the major PM10 source categories in the Salt River PM10 Study Area for the four design days. Figures 4-6, 4-7, 4-8 and 4-9 depict these PM10 source categories by percent. As can be seen from Table 4-5 and the pie graphs in Figures 4-6 through 4-9, the major source categories on the low wind design days are Primary Roads, Secondary Roads, Construction Activity, and Industrial Sources; and on the high wind design days are Wind Erosion – Agricultural, Wind Erosion - Cleared Areas (vacant lots and misc. disturbed areas), Wind Erosion – Construction, and Wind Erosion – Alluvial Channels. TABLE 4-5 Salt River PM10 Emissions Inventory - Year 2002 (Metric Tons / Day) 1/8/02 4/15/02 4/26/02 Low Wind High Wind High Wind Tuesday 1. AREA SOURCES Friday 114.34 114.34 Wind Erosion – Agricultural 46.76 46.76 Wind Erosion – Construction 18.76 18.76 Wind Erosion - Cleared Areas 39.01 39.01 Ag Tilling (Land Preparation) 0.11 Monday Low Wind Monday 0.11 $ vacant lots 21.27 21.27 $ misc. disturbed areas 17.74 17.74 Wind Erosion - Alluvial Channels 9.81 9.81 48.61 56.05 MCESD Permitted Sources – Windblown Stockpiles 4.94 12.38 MCESD Permitted Sources – Windblown Cleared Areas 42.92 42.92 2. INDUSTRIAL SOURCES 12/16/02 0.75 0.75 MCESD Permitted Sources - Stacks 0.27 0.27 0.27 0.27 MCESD Permitted Sources – Process 0.45 0.45 0.45 0.45 MCESD Permitted Sources – Small 0.03 0.03 0.03 0.03 Chapter 4 – Salt River PM10 Emissions Inventory 4-35 TABLE 4-5 Salt River PM10 Emissions Inventory - Year 2002 (Metric Tons / Day) 1/8/02 4/15/02 4/26/02 12/16/02 Low Wind High Wind High Wind Low Wind 3. NONROAD MOBILE SOURCES Tuesday Monday Friday Monday 0.85 0.84 0.84 0.84 Agricultural Equipment Exhaust 0.005 Construction Activity 0.84 0.84 0.84 0.84 4.33 4.33 4.33 4.33 Freeway – (subtotal) 0.06 Brakes, Tires, Exhaust, Reentrainment 0.06 0.06 0.06 4. ONROAD MOBILE SOURCES Paved Road Primary Roads $ reentrained road dust 2.95 2.95 2.95 2.95 $ exhaust 0.09 0.09 0.09 0.09 $ brakes 0.02 0.02 0.02 0.02 $ tires 0.01 0.01 0.01 0.01 3.07 3.07 3.07 3.07 $ reentrained road dust 0.59 0.59 0.59 0.59 $ exhaust 0.02 0.02 0.02 0.02 $ brakes 0.004 0.004 0.004 0.004 $ tires 0.003 0.003 0.003 0.003 Secondary roads emissions subtotal 0.62 0.62 0.62 0.62 Paved Road Total Emissions 3.69 3.69 3.69 3.69 Primary roads emissions subtotal Secondary roads Chapter 4 – Salt River PM10 Emissions Inventory 4-36 TABLE 4-5 Salt River PM10 Emissions Inventory - Year 2002 (Metric Tons / Day) 1/8/02 4/15/02 4/26/02 Low Wind High Wind High Wind Tuesday Monday Friday 12/16/02 Low Wind Monday 5. Trackout 0.66 0.66 0.66 0.66 6. Unpaved Shoulders & Parking Lots 0.133 0.133 0.133 0.133 Unpaved Road Shoulders 0.13 0.13 0.13 0.13 Unpaved Parking Lots reentrained dust 0.003 0.003 0.003 0.003 6.25 168.43 175.87 6.14 PM10 EMISSIONS - GRAND TOTAL Chapter 4 – Salt River PM10 Emissions Inventory 4-37 Figure 4-6 Salt River PM10 Emissions Low Wind Day - December 16, 2002 Trackout (10.76%) Unpaved Parking Lots (0.05%) Unpaved Road Shoulders (2.09%) Secondary Roads (10.11%) Industrial Sources (12.23%) Construction Activity (13.70%) Freeway (1.01%) Primary Roads (50.05%) Chapter 4 – Salt River PM10 Emissions Inventory 4-38 Figure 4-7 Salt River PM10 Emissions Low Wind Day - January 8, 2002 Trackout (10.57%) Unpaved Parking Lots (0.05%) Unpaved Road Shoulders (2.05%) Industrial Sources (12.01%) Agricultural Tilling (1.76%) Secondary Roads (9.93%) Construction Activity (13.45%) Freeway (0.99%) Primary Roads (49.17%) Chapter 4 – Salt River PM10 Emissions Inventory 4-39 Figure 4-8 Salt River PM10 Emissions High Wind Day - April 15, 2002 ON-ROAD MOBILE INCLUDES: On-road Mobile (2.66%) Construction Activity (0.50%) Windblown Alluvial Channels (5.83%) Primary Roads Secondary Roads Freeways Unpaved Parking Lots Unpaved Road Shoulders Trackout Windblown Agricultural (27.79%) Windblown Industrial (25.51%) Windblown Stockpiles (2.94%) Industrial Sources (0.45%) Windblown Cleared Areas (23.18%) Windblown Construction (11.15%) Chapter 4 – Salt River PM10 Emissions Inventory 4-40 Figure 4-9 Salt River PM10 Emissions High Wind Day - April 26, 2002 ON-ROAD MOBILE INCLUDES: Primary Roads On-road Mobile (2.55%) Construction Activity (0.48%) Windblown Alluvial Channels (5.58%) Secondary Roads Freeways Unpaved Parking Lots Unpaved Road Shoulders Trackout Windblown Agricultural (26.61%) Windblown Industrial (24.43%) Windblown Stockpiles (7.05%) Windblown Cleared Areas (22.20% Industrial Sources (0.43%) Windblown Construction (10.68%) Chapter 4 – Salt River PM10 Emissions Inventory 4-41 4.5 PROJECTED YEAR 2006 BASE CASE EMISSIONS The following emission source categories in the Salt River PM10 Study Area are projected to show a change in their total emissions between Year 2002 and Year 2006 (Base Case): These projected emissions reflect a base case approach, and do not include additional emission reductions resulting from new control measures or enhancements to existing control measures that are discussed in Chapter 6. • Agricultural Tillage. The amount of agricultural land, and emissions from agricultural tillage, are projected to decrease 80% due to conversion of agricultural land to residential and commercial uses (Maricopa County Farm Bureau, 2003 and ADEQ analysis – see Appendix F). • Construction Activity. Emissions from construction activity are projected to decrease due to MCESD’s enhanced enforcement of Rule 310 to increase the rule effectiveness for this category from 56% to 72%. (See Appendix Q for discussion of projected construction activity.) • Roads – Freeway, Primary, and Secondary. Traffic is projected to increase by 6% between 2002 and 2006 based on the growth in traffic volumes in the Salt River Area which occurred between 1998 and 2002. Since there are no plans for road building projects in the Salt River PM10 Study Area, this estimate of VMT growth (1.47% per year), based on a MAG analysis of City of Phoenix traffic counts, is consistent with the central location and older neighborhoods characteristic of the study area. • Unpaved Parking Lots. Emissions from unpaved parking lots greater than 0.10 acres are projected to decrease due to MCESD’s strengthening and enhancing enforcement of Rule 310.01 to increase the rule effectiveness for this category from 55% to 71%. • Unpaved Road Shoulders. The amount of unpaved road shoulders in the Salt River PM10 Study Area has decreased by 10% since the Year 2002 due to shoulder stabilization projects that have been completed since the Year 2002. Thus, the amount of PM10 emissions from unpaved road shoulders in the study area will also decrease by 10%. • Wind Erosion – Agricultural. The amount of agricultural land, and emissions from wind erosion of agricultural land, are projected to decrease 80% due to conversion of agricultural land to residential and commercial uses (Maricopa County Farm Bureau, 2003 and ADEQ analysis – see Appendix F). • Wind Erosion – Alluvial. Application of MCESD Rule 310.01 to those parcels with windblown dust potential will result in a reduction of emissions of 57% • Wind Erosion – Construction. Emissions from wind erosion of disturbed areas due to construction are projected to decrease due to MCESD’s enhanced enforcement of Rule 310 to increase the rule effectiveness for this category from 63% to 70%. (See Appendix Q for discussion of projected construction activity.) Chapter 4 – Salt River PM10 Emissions Inventory 4-42 • Wind Erosion – Vacant Lots and Miscellaneous Disturbed Areas. The amount of vacant lots is projected to decrease by 39%, based on an ADEQ field survey of vacant lots converted to residential and commercial uses between Years 2002 and 2004 (See Appendix R). The survey included 171 vacant lots, 14 of which had been converted over a 10-month period, resulting in an 8.2% conversion rate. This ten-month conversion rate is equivalent to an annual conversion rate of 9.8% and a four-year conversion rate of 39.3%. Miscellaneous disturbed areas are projected to decrease 13.6% due to conversion to residential and commercial uses. ADEQ estimated the decrease in miscellaneous disturbed areas would parallel the conversion of agricultural land to residential and commercial uses (URS and ERG, 2001). ADEQ’s field survey did not have sufficient miscellaneous disturbed areas converted to residential and commercial use over the 10-month period to provide a statistically valid estimate (Appendix R). In addition, MCESD is strengthening and enhancing enforcement of Rule 310.01 to increase the rule effectiveness for this category from 55% to 71%. An example of the calculations used to quantify the percent change in emissions from Year 2002 to 2006 for those sources subject to the MCESD’s Rule 310.01 wind erosion control measure appears below. Example of Percent Reduction Emission Calculation: MCESD strengthened Rule 310.01 to increase the rule effectiveness (RE) for vacant lots from 55% to 71% between Year 2002 and 2006. This results in a 36% in emissions from this category from Year 2002 to 2006: E2002 (controlled emissions) = E2002 (uncontrolled emissions) * (1 – Year 2002 RE) E2002 (controlled emissions) = E2002 (uncontrolled emissions) * (1 – 0.55) E2006 (controlled emissions) = E2002 (uncontrolled emissions) * (1 – Year 2006 RE) E2006 (controlled emissions) = E2002 (uncontrolled emissions ) * (1 – 0.71) Percentage emissions change from Year 2002 to Year 2006 = [E2002 (controlled) - E2006 (controlled)] E2002 (controlled) = [E2002 (uncontrolled) (1 – 0.55) - E2002 (uncontrolled) (1 – 0.71)] E2002 (uncontrolled) (1 – 0.55) = ((1 - 0.55) – (1- 0.71)) / (1 – 0.55) = 0.16 / 0.45 = 0.36 or 36% Table 4-6 lists those emission categories that showed a change in emissions between Year 2002 and Year 2006 Base Case (no new additional control measures). Chapter 4 – Salt River PM10 Emissions Inventory 4-43 TABLE 4-6 Percent Change in Emissions Between Year 2002 and Year 2006 Base Case Emission Category Percent Change in Emissions Reason For Change AREA SOURCES Ag Tilling (Land Preparation) -80% Wind Erosion – Agricultural -80% Wind Erosion – Construction -19% Wind Erosion – Alluvial Channels -57% Agricultural land projected to decrease 80% due to conversion of agricultural land to residential and commercial uses (Maricopa County Farm Bureau, 2003) Agricultural land projected to decrease 80% due to conversion of agricultural land to residential and commercial uses (Maricopa County Farm Bureau, 2003) MCESD’s enhanced enforcement of Rule 310 to increase the rule effectiveness for this category from 63% to 70%. MCESD applying Rule 310.01 to control this category by 57% Wind Erosion – Cleared Areas: $ vacant lots $ misc. disturbed areas -36% MCESD strengthening and enhancing enforcement of Rule 310.01 to increase the rule effectiveness for this category from 55% to 71%. -39% Projected building of residential and commercial areas, based on ADEQ field survey of conversion of vacant lots. -61% -36% Overall reduction of 61%. MCESD strengthening and enhancing enforcement of Rule 310.01 to increase the rule effectiveness for this category from 55% to 71%. -13.6% Projected building of residential and commercial areas -45% Overall reduction of 45%. -36% MCESD’s enhanced enforcement of Rule 310 to increase the rule effectiveness for this category from 56% to 72%. NONROAD MOBILE SOURCES Construction Activity ONROAD MOBILE SOURCES Paved Roads Freeway - Interstate 17, Durango +6% Primary Roads +6% Secondary Roads +6% Traffic is projected to increase 6% based on MAG’s estimate of traffic increasing 1.5% per year Traffic is projected to increase 6% based on the MAG’s estimate of traffic increasing 1.5% per year Traffic is projected to increase 6% based on the MAG’s estimate of traffic increasing 1.5% per year Unpaved Road Shoulders and Unpaved Parking Lots Unpaved Road Shoulders -10% Unpaved Parking Lots reentrained dust -36% Decrease based on recent shoulder stabilization projects that have been completed since the Year 2002. MCESD strengthening and enhancing enforcement of Rule 310.01 to increase the rule effectiveness for this category from 55% to 71%. Chapter 4 – Salt River PM10 Emissions Inventory 4-44 Table 4-7 lists the major PM10 source categories in the Salt River PM10 Study Area for the four design days for the 2006 base case. Figures 4-9 and 4-11 depict these PM10 source categories by percent. As can be seen from Table 4-7 and the pie graphs in Figures 4-10 through 4-13, the major source categories on the low wind design days are Primary Roads, Industrial Sources, Secondary Roads, Trackout and Construction Activity.; and on the high wind design days are Wind Erosion – Industrial, Wind Erosion – Cleared Areas, Wind Erosion – Construction, and Wind Erosion – Agricultural. TABLE 4-7 Salt River PM10 Emissions Inventory – Base Case 2006 (Metric Tons / Day) 1/8/06* 4/15/06* 4/26/06* Low Wind High Wind High Wind Tuesday* 1. AREA SOURCES Friday* 50.34 50.34 Wind Erosion – Agricultural 9.35 9.35 Wind Erosion – Construction 15.20 15.20 Wind Erosion - Cleared Areas 21.57 21.57 Ag Tilling (Land Preparation) $ vacant lots $ misc. disturbed areas 0.02 Monday* 12/16/06* Low Wind Monday* 0.02 Wind Erosion - Alluvial Channels 0.75 2. INDUSTRIAL SOURCES MCESD Permitted Sources – Windblown Stockpiles MCESD Permitted Sources – Windblown Cleared Areas 11.76 11.76 9.81 9.81 4.22 4.22 48.61 56.05 4.94 12.38 42.92 42.92 0.75 MCESD Permitted Sources – Stacks 0.27 0.27 0.27 0.27 MCESD Permitted Sources – Process 0.45 0.45 0.45 0.45 MCESD Permitted Sources – Small 0.03 0.03 0.03 0.03 Chapter 4 – Salt River PM10 Emissions Inventory 4-45 TABLE 4-7 Salt River PM10 Emissions Inventory – Base Case 2006 (Metric Tons / Day) 1/8/06* 4/15/06* 4/26/06* Low Wind High Wind High Wind 3. NONROAD MOBILE SOURCES Tuesday* 0.54 12/16/06* Low Wind Monday* 0.54 Friday* 0.54 Monday* 0.54 Agricultural Equipment Exhaust 0.004 Construction Activity 0.54 0.54 0.54 0.54 4.19 4.19 4.19 4.19 Freeway – 0.07 Brakes, Tires, Exhaust, Reentrainment 0.07 0.07 0.07 4. ONROAD MOBILE SOURCES Paved Road Primary Roads $ reentrained road dust 3.19 3.19 3.19 3.19 $ exhaust 0.10 0.10 0.10 0.10 $ brakes 0.02 0.02 0.02 0.02 $ tires 0.01 0.01 0.01 0.01 3.32 3.32 3.32 3.32 $ reentrained road dust 0.64 0.64 0.64 0.64 $ exhaust 0.02 0.02 0.02 0.02 $ brakes 0.004 0.004 0.004 0.004 $ tires 0.003 0.003 0.003 0.003 Secondary roads subtotal 0.67 0.67 0.67 0.67 Paved Road Total Emissions 4.06 4.06 4.06 4.06 Primary roads subtotal Secondary roads Chapter 4 – Salt River PM10 Emissions Inventory 4-46 TABLE 4-7 Salt River PM10 Emissions Inventory – Year 2006 Base Case (Metric Tons / Day) 1/8/06* 4/15/06* 4/26/06* Low Wind High Wind High Wind Tuesday* Monday* Friday* 12/16/06* Low Wind Monday* 5. Trackout 0.66 0.66 0.66 0.66 6. Unpaved Shoulders & Parking Lots 0.133 0.133 0.133 0.133 0.13 0.13 0.13 0.13 0.003 0.003 0.003 104.47 111.91 6.14 Unpaved Road Shoulders Unpaved Parking Lots - reentrained dust 0.003 PM10 EMISSIONS - GRAND TOTAL 6.16 * Theoretical design days in Year 2006 that have same meteorological conditions, time of year, and day of week to the four design days in Year 2002 Emissions Inventory and Modeling. Chapter 4 – Salt River PM10 Emissions Inventory 4-47 Figure 4-10 Year 2006 Base Case Salt River PM10 Emissions Low Wind Day - January 8, 2006 Trackout (10.71%) Unpaved Parking Lots (0.05%) Unpaved Road Shoulders (2.08%) Secondary Roads (10.87%) Industrial Sources (12.17%) Agricultural Tilling (0.32%) Construction Activity (8.76%) Freeway (1.14%) Primary Roads (53.88%) Chapter 4 – Salt River PM10 Emissions Inventory 4-48 Figure 4-11 Year 2006 Base Case Salt River PM10 Emissions Low Wind Day - December 16, 2006 Trackout (10.75%) Unpaved Parking Lots (0.05%) Unpaved Road Shoulders (2.09%) Secondary Roads (10.91%) Industrial Sources (12.21%) Construction Activity (8.79%) Freeway (1.14%) Primary Roads (54.06%) Chapter 4 – Salt River PM10 Emissions Inventory 4-49 Figure 4-12 Year 2006 Base Case Salt River PM10 Emissions High Wind Day - April 15, 2006 ON-ROAD MOBILE INCLUDES: Primary Roads On-road Mobile (4.58%) Construction Activity (0.52%) Windblown Alluvial Channels (4.05%) Secondary Roads Freeways Unpaved Parking Lots Unpaved Road Shoulders Trackout Windblown Agricultural (8.97%) Windblown Cleared Areas (20.69%) Windblown Industrial (41.16%) Windblown Construction (14.58%) Industrial Sources (0.72%) Windblown Stockpiles (4.74%) Chapter 4 – Salt River PM10 Emissions Inventory 4-50 Figure 4-13 Year 2006 Base Case Salt River PM10 Emissions High Wind Day - April 26, 2006 ON-ROAD MOBILE INCLUDES: Primary Roads On-road Mobile (4.28%) Construction Activity (0.48%) Windblown Alluvial Channels (3.78%) Secondary Roads Freeways Unpaved Parking Lots Unpaved Road Shoulders Trackout Windblown Agricultural (8.37%) Windblown Cleared Areas (19.31%) Windblown Industrial (38.42%) Windblown Construction (13.61%) Industrial Sources (0.67%) Windblown Stockpiles (11.08%) Chapter 4 – Salt River PM10 Emissions Inventory 4-51 4.6 CONCLUSIONS As previously discussed, there are two quite different meteorological regimes for the four design days. Two design days had low wind speeds with a thermal inversion: January 8, 2002 and December 16, 2002; and two design days had wind speeds over 15 miles per hour: April 15, 2002 and April 26, 2002. The design days with low wind speeds will have a different mix of emission sources than the design days with high wind speeds, because the design days with high wind speeds have additional emission sources related to wind erosion of disturbed soil (e.g., wind erosion of agricultural land and wind erosion of alluvial channels). The major emission source categories projected for the Year 2006 Base Case on the low wind design days were Primary Roads (54%), Industrial Sources (12%), Secondary Roads (11%), Trackout (11%) and Construction Activity (9%) with total daily PM10 emissions in the range of 6 tons. The major emission source categories on the high wind design days were Wind Erosion – Industrial (40%), Wind Erosion – Cleared Areas (20%), Wind Erosion – Construction (14%), and Wind Erosion – Agricultural (9%) with total daily PM10 emissions in the range of 108 tons, which is more than eighteen times greater than the total PM10 emissions on the low wind design days. Thus, different control measures will be needed to reduce emissions on the two types of design days. The gridded hourly PM10 emission files and meteorological conditions for the four design days were used as inputs to EPA’s ISCST3 model. The next chapter will discuss the numerical modeling that was conducted to evaluate the relative contribution of the different emission sources to ambient PM10 levels. Please note that the relative importance of the emission sources listed in this chapter will not be the same as those emission sources identified in numerical modeling. This is because the ISCT3 model takes into account the transport of particulates throughout the study area (e.g., horizontal wind and vertical mixing) and accounts for the temporal and spatial differences in emission sources to estimate ambient PM10 concentrations at specified points in the study area. The emissions listed in the previous summary tables in this chapter are total emissions that do not reflect the spatial and temporal components, (location of sources and time of day and day of week of emissions). However, the spatial and temporal components of the Salt River PM10 Study Area emissions were reflected in the emission files that were input to the ISCST3 dispersion model since these files contained hourly profiles of emissions and the location where the emissions originated, either as a discrete point or spread through one of the 630 grid cells (400 x 400 meter) in the study area. Chapter 4 – Salt River PM10 Emissions Inventory 4-52 4.7 REFERENCES ADEQ (1997) – “Final Plan for Attainment of the 24-hour PM10 Standard – Maricopa Nonattainment Area”, Arizona Department of Environmental Quality and Maricopa Environmental Services Department, May 1997. ARB (1997) – “Methods for Assessing Area Source Emissions”, California Environmental Protection Agency, Air Resources Board, October 1997. AASS (2001) – “2001 Arizona Agricultural Statistics Bulletin”, Arizona Agricultural Statistics Service, July 2002. (http://www.nass.usda.gov/az/) DRI (2000) – “Reconciling Urban Fugitive Dust Emissions Inventory and Ambient Source Contribution Estimates: Summary of Current Knowledge and Needed Research”, by J.G. Watson and J.C. Chow, DRI Document No. 6110.4F, May 2000. EPA (1988) - “Control of Open Fugitive Dust Sources - Final Report”, by C. Cowheard, G.E. Muleski and J.S. Kinsey, EPA - 450/3-88-008, September 1988 EPA (1988A) - “Gap Filling PM10 Emission Factors for Selected Open Area Dust Sources” EPA Contract No. 68-02-4395 Assignment No. 6, March 1, 1988. EPA (1995) – “AP42 – Compilation of Air Pollution Emission Factors”, U.S. Environmental Protection Agency, January 1995. Engineering Science (1988) - “Final Report for Refinement of PM10 Emissions Inventory Data for the Maricopa Planning Area”, by Engineering Science, February, 1988. Fish and Clay (2003) - “Meeting with Jeannette Fish, Maricopa County Farm Bureau, and Patrick Clay, University of Arizona Cooperative Extension, with Randy Sedlacek, Phil DeNee, Darlene Jenkins, ADEQ”, May 21, 2003. Landiscor (2003) - “Phoenix 3rd Quarter Real Estate Photo Book”, Landiscor Aerial Photo Books, 1710 East Indian School Road, Suite201, Phoenix, Arizona 85016 MAG (2000) - “MAG 1999 Serious Area Particulate Plan for PM-10 For The Maricopa County Nonattainment Area”, Maricopa Association of Governments, February 2000. Maricopa County Farm Bureau (2003) – Salt River PM10 Stakeholders Meeting at South Mountain Community College on December 10, 2003. Jeannette Fish, Maricopa County Farm Bureau, and Patrick Clay, University of Arizona Cooperative Extension Service (meeting after stakeholders’ meeting). MCESD (2003) - October 9, 2003 email communication from MCESD staff. Chapter 4 – Salt River PM10 Emissions Inventory 4-53 Moosmuller et al. (1998) - "Particle Emission Rates for Unpaved Road Shoulders along a Paved Road", by H. Moosmuller, J. A. Gillies, C. F. Rogers, D. W. DuBois, J. C. Chow and J. G. Watson DRI and R. Langston San Joaquin Valley Air Pollution Control District, Fresno, California, J. Air & Waste Management Association, 48: 398-407. MRI (1996) - "Improvement of Specific Emission Factors (BACM Project No.1)", Final Report, Midwest Research Institute, March 29, 1996. Nickling (1986) – “Evaluation of aerosol production potential of type surfaces in Arizona”, by Nickling, W. G., and Gillies, J. A., Submitted to Engineering-Science, Arcadia, California, for EPA Contract No. 68-02-388, 1986. Pechan (2002) – “1999 and 2013 Emission Estimates for the Yuma Arizona PM10 Nonattainment Area Maintenance Plan, Final Report”, by Pechan and Associates, 2002. Rupp (2001 & 2002) – “The Aerial Photo Book, The Real Estate Atlas – Phoenix”, by Rupp Aerial Photography, Inc., issued quarterly, 2001 and 2002. URS (2001) – “Technical Support Document for Quantification of Agricultural Best Management Practices, Revised Final Draft”, ADEQ Contract No. 98-0159-BF, by URS Corporation and Eastern Research Group, Inc., June 8, 2001. Chapter 4 – Salt River PM10 Emissions Inventory 4-54 5.0 CHAPTER 5 -- AIR QUALITY MODELING 5.1 INTRODUCTION The elevated PM10 concentrations in the Salt River Industrial Area were simulated using the Industrial Source Complex Short Term (Version-3) – ISCST-3. This numerical model is a steady-state Gaussian dispersion model that has been approved by the U.S. Environmental Protection Agency and that has a long history of applications in both the industrial and urban settings. The Salt River Industrial Area was modeled using the urban parameter for ISCST-3 with flat terrain and the regulatory default modeling option. The U.S. Environmental Protection Agency (EPA) maintains the guideline on air quality models which provides the agency’s guidance on regulatory applicability of air quality dispersion models in the review and preparation of new source permits and State Implementation Plan (SIP) revisions (EPA, 1995). The regulatory default option selected in this modeling work conforms to the EPA guideline for SIP modeling - 40 CFR part 51, while the urban and flat terrain settings best reflect the conditions seen in the Salt River Industrial Area. Contributions to overall PM10 in the domain were predicted using separate, day specific, source category area emissions files. When these separate category files are used, the predicted concentration of that category will reflect the net contribution of that category to the overall PM10 concentration in the domain. The overall predicted concentration in the domain can be calculated by summing the source category contributions and the background estimations into a total predicted PM10 concentration for the domain. This modeling approach provides a means to calculate the relative net contributions from each category in a domain while also providing the total predicted PM10 concentration at each receptor. The modeling domain consisted of an array of 400x400 meter grids, 30 in the east-west (EW) direction and 21 in the north-south (NS) direction, for a total of 630 grids (Figures A-7 and A-8 in Appendix A). Dimensions of the array were 7.5 miles (12 kilometers) EW and 5.2 miles (8.4 km) NS. The domain size of 8 x 5 miles with its longitudinal center line along the Salt River was a logical choice that: 1. Included all four monitors in the Salt River Study Area; 2. Included most of the major industrial concerns in the area; 3. Took in an expansive area of active agricultural land; and 4. Included some extremely active residential construction sites (in its southwest corner). Chapter 5 – Air Quality Modeling 5-1 Extending the domain to both the east and the west could have been done, but this would have only added to the emissions inventory field work without bringing in emissions that would have significantly influenced the four monitors. A southward extension would have ended one mile south of Baseline Road at the South Mountain Park, not an important source of emissions. A northward extension would have brought in more vehicular and light industrial emissions. Almost all the air quality modeling relied on a four-point grid of receptors, one at each of the four monitoring sites. Some experimental receptor grids were employed to gauge the effect of windblown agricultural dust on the Durango monitor. Also, a similar grid was employed to investigate the spatial distribution of windblown alluvial dust on the West 43rd Avenue monitor. The model was rerun with a dense grid of receptors so that the spatial distribution of the predicted PM10 concentrations could be shown for the entire modeling domain. With a few exceptions, nearly all the emission sources were treated as area sources and their emissions were distributed evenly throughout the grid. This treatment was applied to roadways -- both reentrained emissions from average silt loading, as well as trackout emissions, to windblown dust of all types, to construction activity, and to all other source categories except industrial. Given the small size of each grid, with 630 grids in the domain, this arrangement worked satisfactorily. Industrial emissions were treated differently. First, those emissions from stacks, as stated on the Maricopa County emission survey forms, were modeled as stack emission sources with all the usual stack parameters within Industrial Source Complex (ISC). Second, all other industrial emissions were modeled as area sources. This area source modeling was done in two ways. For 45 of the 81 permitted sources in the study area -those with minimal particulate emissions -- their emissions were merely distributed evenly throughout the grid. For the 36 larger facilities, the “non-stack” emissions were taken from the county field survey; the potential emission area boundaries and its area were estimated from enlarged satellite images, and the emission rate determined, based on the stated hours of operation. These 36 process areas were islands of emissions anchored to their geographic location, rather than being spread throughout a grid. These emissions consisted of trucks on unpaved haul roads, crushing, grinding, and screening, material conveyance, and emissions from stacks too small to require an individual permit. Windblown industrial emissions and windblown stockpile emissions were given special consideration. “Windblown industrial” refers to that windblown dust that comes from the various disturbed and unstabilized areas of the facility (excluding stockpiles). These emissions were estimated by scrutinizing the enlarged satellite images and determining which portions of the ground surface would be subject to windblown dust. Buildings, paved roads and lots, and other surfaces that could not generate dust were excluded. These windblown industrial areas were fixed on the modeling grid, and their emissions came from the designated areas only, rather than being spread throughout the grid. Chapter 5 – Air Quality Modeling 5-2 The standard emission factor approach was taken, in which a certain mass flux was assigned to each hour with wind above the resuspension speed. The spatial treatment of windblown stockpiles was done in similar fashion. The difference was in the emission factor application. Rather than being dependent on a threshold wind speed, the emissions factors were based on the speed and frequency of wind gusts. To summarize, large industrial stacks, industrial non-stack emissions for the 36 larger facilities, and windblown emissions from stockpiles and industrial surfaces were treated with specific coordinates and stack and process area parameters. All other categories had their emissions spread throughout the grid and were treated as area sources within ISC. 5.1.1 Summary of Results and Modeling Methods Results from this modeling demonstrate a different source mix for two types of exceedance events: low-moderate wind and high wind conditions. Dispersion modeling results show that on the high wind days, windblown dust contributes 76% of the total concentration of PM10; while on the low–moderate wind days there is no one dominant source, with roadways contributing 56%, industrial processes 26%, and trackout 12%, to the total predicted PM10 for those days. Figures 5-1 and 5-2 are pie charts summarizing the source contributions under these two conditions. The relative importance of the emission sources to the ambient PM10 concentrations in these charts is an average of eight model predictions: four monitors for two days. Chapter 5 – Air Quality Modeling 5-3 Figure 5-1 Modeled Source Contributions for High Wind Exceedances - 2002 Construction Tilling 1% Track Out 0% 3% Roads 12% Industrial 8% Wind Blown Dust 76% Figure 5-2 Modeled Source Contributions for Low-Moderate Wind Exceedances -2002 Wind Blown Dust 0% Track Out 12% Construction 6% Tilling 0% Industrial 26% Roads 56% Chapter 5 – Air Quality Modeling 5-4 The remainder of this chapter is devoted to how days were selected for modeling and how the modeling techniques were used. Since this material is necessarily technical, it will be explained here in simpler terms. First, the goal of air quality modeling is to be able to understand the emission sources that contribute to high air pollution levels. This means to identify those sources and to quantify just how much each one contributes to the problem. There are four steps to achieve this goal: 1. In a particular area for a specific time, make intensive measurements of air pollution and winds at a number of sites. 2. Construct an inventory of emissions, and arrange these emissions in a fashion suitable for input into an air quality model. 3. Through measurements and calculations, determine what fraction of the studyarea air pollution originates elsewhere. This fraction is called “background.” 4. Put the meteorological and emissions information from specific days into an air quality model. Such a model is nothing more than a numerical tool which estimates pollutant concentrations based on the strength and timing of the emissions, on the wind speed and direction, and on how well the air at the ground surface mixes vertically. These predicted concentrations that come out of the model result from the emissions from the study area only. Background concentrations (step 3) are those pollutant levels that would be present with zero emissions in the study area. Adding the background to the model-predicted concentrations gives the final estimates of air quality that can then be compared with the measurements. The technically inclined reader is encouraged to look into the details of these four steps as explained in the rest of the chapter. But any reader who understands the concepts behind these steps can skip to the discussions about source contributions, emission controls, and attainment (Chapter 6) without any disadvantages. Chapter 5 – Air Quality Modeling 5-5 5.2 DESIGN DAY SELECTION In 2002, in the Salt River area, 21 exceedances of the PM10 standard were recorded on 14 different days. Of these days, four were selected for modeling: January 8, April 15, April 26, and December 16. Two of these days, January 8 and December 16, had lowmoderate wind meteorology, with exceedances measured at one site for each day, and were among the highest concentrations measured under these conditions within the Salt River PM10 Study Area. The two April days were very similar in that dry cold fronts were passing through Arizona, bringing sustained winds in excess of 15 miles per hour. On those days, multiple monitoring sites throughout the nonattainment area measured exceedances, and within the Salt River PM10 Study Area, three of the four sites exceeded the NAAQS. These were also the two exceedance events with the highest measured concentrations for the year under these meteorological conditions within the Study Area. The other advantage of these two high wind events is that the winds were sustained through most of the day and wind direction was relatively stable. Both of these characteristics simplify the modeling exercise. Table 5-1 provides a summary of PM10 exceedances in the Salt River PM10 study area. The shaded exceedances were selected for modeling. 5.3 EMISSIONS INVENTORY Chapter 4 of this document describes the development of the emissions inventory and the inventory itself. The inventory was delivered as separate day and category dependent files. Each emissions category was modeled separately, and all were later summed to depict total emissions. This separate approach provided a clear and easy way to carry out modeling a large domain with a large number of area sources. Chapter 5 – Air Quality Modeling 5-6 TABLE 5-1 PM10 Exceedances in the Salt River PM10 Study Area for 2002 Wind Condition Category High ModerateLow Day of Week M Durango Complex South Phoenix West 43rd Ave. Salt River Date TEOM TEOM TEOM TEOM 4/15/2002 198 HiVol HiVol 128 HiVol 243 184 F 4/26/2002 144 232 128 123 174 172 M 5/20/2002 97 99 129 84 167 119 SU 6/9/2002 91 TU 7/9/2002 120 M 7/22/2002 203 TU 1/8/2002 158 49 164 106 102 119 173 249 67 130 153 90 HiVol 120 128 94 148 174 W 7/3/2002 90 117 152 M 8/26/2002 70 96 165 121 SU 10/13/2002 87 131 154 116 TU 10/15/2002 87 116 175 138 W 11/6/2002 107 105 183 152 F 11/22/2002 100 133 136 101 159 118 160 35 M 12/16/2002 111 132 105 82 181 135 126 23 Chapter 5 – Air Quality Modeling 5-7 5.4 METEOROLOGICAL DATA Meteorological data for each design day were based on the wind, temperature and humidity measurements collected at the West 43rd Avenue monitoring site. For a thorough analysis of winds in the Salt River PM10 Study Area, see Appendix N. Mixing height was calculated using soundings from the Tucson Airport taken at 5 a.m. and 5 p.m. on those days. These data included data for wind speed, wind direction, stability class, temperature and mixing height. Table 5-2 illustrates a sample meteorological file used for this modeling. TABLE 5–2 Meteorological Data File Used for January 8 Modeling DATE/HOUR* WIND DIRECTION (Degrees) WIND SPEED (m/sec) TEMPERATURE (K) STABILITY CLASS MIXING HEIGHT (m) 2010801 115 1.4 296.4 6 178 2010802 118 0.8 296.2 6 178 2010803 103 2.1 296.2 7 178 2010804 200 1.5 295.5 7 178 2010805 216 1 294.3 6 178 2010806 195 1.1 293.7 6 178 2010807 328 1 293.2 6 178 2010808 358 0.8 297 5 248.2 2010809 50 0.447 300.5 4 434.7 2010810 319 0.8 301.8 3 624.1 2010811 359 1.7881 302.1 2 807.6 2010812 27 1.2 303.4 3 994.1 2010813 48 1.3411 304.3 3 1180.5 2010814 70 1.6 304.8 4 1367 2010815 78 1.3 303.9 4 1367 2010816 74 1.2 302.3 4 1367 2010817 70 0.8 301.5 4 1367 2010818 75 0.6 300.9 5 1279.8 2010819 69 0.1 299 6 1097.7 2010820 78 0.1 297 7 915.5 2010821 85 1.4 295.3 7 733.4 2010822 81 1 293.5 7 551.3 2010823 44 1.5 292.5 7 369.1 2010824 58 0.8 291.8 6 187 *Format includes one digit for year and two each for month, day and hour – YMMDDhh. 5.5 MODELING METHOD The ISCST-3 model was used to predict PM10 concentrations in the Salt River PM10 Study Area for January 8, April 15, April 26 and December 16, 2002. April 15 and April 26 were modeled as ‘high-wind’ days, as the observed wind speeds exceeded the threshold of dust re-suspension of 15 miles per hour. Each of the Chapter 5 – Air Quality Modeling 5-8 four modeling days included emissions for construction, lawn care, roadways and industrial sources; with agricultural tilling included in the January 8th inventory and windblown emissions included in the April 15 and April 26 inventories. Table 5-3 shows the day and inventory assignment. TABLE 5-3 Source Categories Contributing Emissions for the Four Design Days Source Category/ Day Jan 8 April 15 April 26 Dec 16 CONSTRUCTION X X X X CORN TILLAGE X COTTON TILLAGE X LAWN CARE X X X X FREEWAY X X X X PRIMARY ROADS X X X X SECONDARY ROADS X X X X UNPAVED PARKING LOTS X X X X UNPAVED SHOULDERS X X X X SMALL INDUSTRIAL SOURCES X X X X LARGE INDUSTRIAL AREA SOURCES X X X X INDUSTRIAL POINT SOURCES X X X X WINDBLOWN AGRICULTURE X X WINDBLOWN ALUVIAL X X WINDBLOWN VACANT LOTS X X WINDBLOWN MISC. DISTURBED X X WINDBLOWN CONSTRUCTION X X WINDBLOWN STOCK PILES X X WINDBLOWN INDUSTRIAL X X The data in each inventory file was added to the category and day specific input run streams and was used in conjunction with the relative meteorological data file, the ISCST-3 program and a batch file to run the process. This allowed each scenario to be run independently and provided a simple means to adjust independent categories, when adjustments were needed. The ISCST-3 model was initiated by activating the batch file, which in turn ran the model and instructed the program to read in the appropriate input and meteorological data file. This, in turn, produced an ASCII output file, with the computed values for PM10 in the domain. The output option used produced a PM10 plot file with 24-hour average values for each of four receptors and their relative predicted concentrations. The receptor locations were the actual monitoring sites in the domain, so, the predicted Chapter 5 – Air Quality Modeling 5-9 concentrations can be directly compared to the measured value at each site for each day. Data from these plot files were copied to a spread sheet that had been set up by source category, site and day and summed into a receptor (monitoring site) and day specific total. These data were used to test the model performance, by comparing the predicted and measured values at each site. 5.5.1 Model Performance Model performance data presented here are for the January 8, April 15, April 26, and December 16, 2002 exceedance days. All four sites are included. Figures 5-3 and 5-4 show the relationship between observed and predicted PM10 values in the Salt River PM10 Study Area. Here these 24-hour average predictions and concentrations are shown with site and wind-condition labels. Chapter 5 – Air Quality Modeling 5-10 Figure 5-3. Salt River PM10 Model Predictions vs. Observations, with Monitoring Sites (WF, West 43rd Ave; SP, South Phoenix; SR, Salt River Site; and DC, Durango Complex Chapter 5 – Air Quality Modeling 5-11 Figure 5-4. Salt River PM10 Model Predictions vs. Measurements, with High Wind (High) and Low Wind (Low) Conditions Indicated Chapter 5 – Air Quality Modeling 5-12 Figure 5-5 presents PM10 concentrations domain-wide for December 16. The pattern is generally consistent with emissions and wind directions. The exceedance occurred at West 43rd Avenue and was 181 µg/m3. Winds were light, averaging 1.4 miles per hour, and, during the daylight hours were mostly out of the west, southwest, or northwest (Table 5-4). The pattern of moderately elevated concentrations is coincidental with the network of primary roads. Areas of the most elevated concentrations are close to either primary roads, large industrial sources, or both. Hour 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 AVG TABLE 5-4 Wind Data for December 16, 2002 Wind Direction Compass Degrees Cardinal Direction 248 W 194 S 114 SE 100 E 59 NE 285 W 255 W 286 W 279 W 209 SW 100 E 161 S 233 SW 225 SW 276 W 25 NE 334 NW 48 NE 219 SW 214 SW 96 E 297 NW 168 S ND ND Chapter 5 – Air Quality Modeling Wind Speed (mph) 1.4 0.5 1.9 2.8 0.6 2.7 1.3 2.7 1.6 0.5 2.1 1 2.1 1.2 0.8 0.8 2 1.3 1.6 1.1 0.7 1.4 0.5 ND 1.42 5-13 On the high-wind day of April 15, 2002, the model once again produced areas of elevated PM10 concentrations consistent with the location of nearby emissions (Figure 5-6). Four hours had wind speeds in excess of the dust resuspension threshold of 15 miles per hour (Table 5-5). Hour 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 AVG TABLE 5-5 Wind Data for April 15, 2002 (from West 43rd Avenue) Wind Direction Compass Degrees Cardinal Direction 295 NW 298 NW 283 W 20 N 36 NE 15 N 148 SE 178 S 230 SW 139 SE 179 S 207 SW 228 SW 250 W 258 W 254 W 250 W 255 W 249 W 258 W 265 W 261 W 224 SW 238 SW Chapter 5 – Air Quality Modeling Wind Speed (mph) 2 6 2.7 5.9 3.4 2.7 1.1 0.8 1.6 3.2 12.8 11.3 8.3 13 16.3 16.6 15.3 16.1 12.3 10.1 13.3 5.5 3.7 5.1 7.88 5-14 Figure 5-5. Domain-wide PM10 Concentrations from the ISC Model for December 16, 2002 Chapter 5 – Air Quality Modeling 5-15 Figure 5-6. Domain-wide PM10 Concentrations from the ISC Model for April 15, Chapter 5 – Air Quality Modeling 5-16 Table 5–6, illustrates the total predicted concentration, in µg/m³ at each receptor (monitoring site) in the Salt River PM10 Study Area domain, excluding background. Figure 5-7 illustrates the ISCST-3 model performance for the Salt River PM10 Study Area. Background values have been added to these results. TABLE 5-6 Predicted Concentrations for Monitoring Sites Total Predicted PM10 Concentration (µg/m³) 8-Jan 15-Apr 26-Apr SOUTH PHOENIX 20.4 39.0 47.3 DURANGO 25.7 21.6 25.0 SALT RIVER 21.9 31.4 40.7 WEST 43 9.7 19.1 26.1 16-Dec 22.3 20.7 26.3 12.9 Figure 5-7 Model Performance: Predicted vs. Observed PM10 Concentrations 300 Predicted PM10 (ug/m3) 250 200 150 100 50 0 0 50 100 150 200 250 300 Measured PM10 (ug/m3) Chapter 5 – Air Quality Modeling 5-17 The model performance shows that the predicted values are below the 1:1 line, meaning that the model has consistently under predicted the measurements. Of the 15 measurements, three predictions are within 10% of the measurements, one is within 30%, four are within 40%, three are within 50%, and four are within 60%. Table 5-7 illustrates the average ISCST-3 results for the Salt River PM10 Study Area. TABLE 5-7 Model Performance: Average Predicted PM10 Concentrations (µg/m³) Low Wind High Wind Predicted 20.0 31.4 Background 67.5 80.0 Total (Pred + Back) 87.5 111.4 Measured 138.6 192.0 % From Measured -36.9 -42.0 Appendix O presents model performance data on an hourly basis. This model performance, when put into the context of general dispersion model performance, is more than adequate. The rule of thumb in the modeling community is that any ISCST prediction within a factor of two of the measurements is acceptable. This “rule” has evolved through over three decades of application of the model to large industrial smokestack emissions. These emissions are much better characterized than the fugitive PM10 emissions from roads, windblown dust, and industrial sources such as sand and gravel. Within the Salt River PM10 Study Area, virtually all of the emissions are of a fugitive nature. This makes it especially difficult to have perfect site and day specific predictions of PM10 concentrations. While the precise cause of the under predictions is unknown, its effects on the overall technical analysis and the determination of the contributing emission sources are minimal. First, the model, as explained in Chapter 6, is used in a relative sense. The absolute prediction does not determine attainment. Second, the emissions inventory represents the state of the art in land use analysis, was fortified by ample local measurements and observations, and relied on the latest EPA-approved emission factors. There is no reason to suppose that one source category was under estimated or over estimated to a much greater degree than another source category. The primary emission sources are roads, industrial sources, and earthmoving from construction, and with windblown dust on the high-wind days. The rigorous methods of emission inventory construction provide confidence that the relative amounts of emissions from the different source categories are close to the real-world mark. Chapter 5 – Air Quality Modeling 5-18 5.6 BOUNDARY CONCENTRATIONS AND URBAN BACKGROUND 5.6.1 PM10 Measurements at the Boundaries Monitors were set up at Mule Stables (67thAvenue, just north of the Salt River), Battery Shop (16th Street, just south of the Salt River) and West 43rd Avenue to measure PM10, from January 2003 through March 10, 2003. Data for West 43rd Avenue were available from January 23, 2003. Wind directions and wind speeds were measured at these sites. Hourly averages were calculated from the data. The Battery Shop location is six streets east of the east boundary of the Salt River area. The west boundary is at 57th Avenue, which was close to the Mule Stables at 67th Avenue. Hence it was assumed that the boundary concentrations were represented by the readings at these two locations. Other sites in the region had monitors and wind direction/speed readings. Data from Durango and Supersite were used to estimate boundary concentrations where direct measurements were not available, as described in the next section. 5.6.2 Calculation of Boundary Values Since simultaneous PM10 readings were available at West 43rd Avenue and at the east and west boundary sites, the fractions at the east and west boundaries with respect to West 43rd Avenue were calculated from these measurements. North boundary concentrations could not be determined directly from measurements at or near the boundary. They were estimated using 80% of the readings at Supersite, which is north of the north boundary, and 20% of the readings at Durango, which is south of the north boundary. The Durango site, which is in the Salt River area, has considerably higher PM10 readings than the Supersite. However, due to the effect of wind, not all of PM10 at Durango is likely to contribute to the North boundary concentrations. It was assumed that 80% of the contribution to the North boundary came from Supersite. For the South boundary, no measurements were available. For potential PM10 emission areas, there are 8 square miles south of Baseline Road (south boundary) and 60 square miles north of Van Buren Street. The south boundary concentrations were estimated as 8/60 of the north boundary concentrations for each hour. Again, the wind directions were used to select south boundary concentrations, and fractions with respect to West 43rd Avenue were calculated. Before calculating the boundary concentrations as fractions of West 43rd Avenue PM10, the PM10 data were narrowed down to directions that are more likely to contribute to the concentrations at the boundaries. These wind directions are listed in Table 5-8. Chapter 5 – Air Quality Modeling 5-19 Boundary East West North South TABLE 5-8 Boundary Wind Directions Wind Direction Between 20 and 160 Between 200 and 340 Less than 70 and greater than 290 Between 110 and 250 The measured wind directions at the particular sites were used whenever available. When they were not available, the data for the site nearest to it were used, as in the case of West 43rd Avenue. For January, and up to February 5, 2003, the wind directions for West 43rd Avenue were available. For the remainder of February and March, wind data at Mule Stables were used. In the calculations of the west boundary fraction with respect to the West 43rd Avenue PM10 concentrations, diurnal distributions were calculated using the data from January 2003-March 2003, and the selected wind directions. The fraction at 2 p.m. was very high (1.2) compared to those around it. It was due to a very high reading (725.7 µg/m³) at Mule Stables, and only a moderately high (334.6 µg/m³) reading at West 43rd Avenue, on February 2, 2003. The concentrations before and after 2 p.m. were significantly lower, by an order of magnitude. Examination of meteorological data indicated that there was a cold front with gusting winds (35 mph) and blowing dust in the afternoon of that day. The winds decreased in the evening. It is possible that the winds were strong as they entered the Mule Stables area, creating very high PM10 concentrations, but decreasing as they entered West 43rd Avenue site. By 3 p.m. the gusting winds may have left these sites, although not the Phoenix area. The examination of the hourly fractions west boundary PM10 divided by West 43rd Avenue PM10 over a 24 hour period indicated that the effect of selective data based on wind direction was minimal in the morning. The fractions with all the wind directions versus. selected wind directions were within 0.1 of each other. In the afternoon, the difference was much greater, as more winds from the west brought in more PM10. This was particularly evident for the data point at 2 p.m. (hour 14). A value of 1.2 indicated that the west boundary concentration was 20% higher than the West 43rd Avenue concentration. In order to counteract the effect of a single data point raising the mean and standard deviation, it was decided to use a moving average of 3 points (See Figures 5-8 and 59) for this data point. For all the other points, the standard deviation was close to the mean in magnitude. Had all the wind data been used, instead of selecting the directions, the mean would have been considerably lower, but it would not have represented the real situation. Hence the very high data point was included, as a moving average, rather than the measured concentration. This gave a west boundary Chapter 5 – Air Quality Modeling 5-20 PM10 divided by West 43rd Avenue fraction equal to 1.0, which was more in line with the fractions at other points that afternoon. Ratios of boundary concentrations with West 43rd Avenue concentrations are displayed in Figure 5-9. They are calculated as fractions of the West 43rd Avenue monitor concentrations, which are known from measurements taken as 24 hour averages from the high volume sampler. Table 5-9 presents these data and the ratio calculations. Figure 5-8 Moving Averages for West Boundary/West 43rd Avenue Ratio West Bdy/West 43rd Meas. PM10 PM10 1.4 1.2 1 0.8 0.6 0.4 0.2 0 0 5 10 15 20 25 Hour WB/WF-windAdj Chapter 5 – Air Quality Modeling 3 per. Mov. Avg. (WB/WF-windAdj) 5-21 Figure 5-9 PM10 Concentration Ratios for East, West and North Boundaries Relative to PM10 Concentration at W. 43rd Avenue Monitor 1.4 Boundary/W. 43rd Ave. Meas. Conc. 1.2 1 0.8 0.6 0.4 0.2 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Hour N. Bdy Ratio Chapter 5 – Air Quality Modeling E. Bdy Ratio W. Bdy Ratio 5-22 TABLE 5-9 Boundary PM10 Concentrations Ratioed with West 43rd Avenue PM10 Concentrations rd Hour 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 W. 43 PM10 conc. 99 87 83 92 107 147 232 219 133 120 70 66 51 46 54 52 54 74 92 90 136 103 112 119 Ratio with W. 43rd Avenue PM10 Concentration N. Bdry PM10 conc. 43 38 38 37.2 35.4 36.6 49 55 45.2 43 30.2 26.6 30.2 26.2 26.4 29.8 30.2 34.2 37.6 41.8 54.2 49 51.6 50.4 Chapter 5 – Air Quality Modeling S. Bdry PM10 conc. 5.73 5.07 5.07 4.96 4.72 4.88 6.53 7.33 6.03 5.73 4.03 3.55 4.03 3.49 3.52 3.97 4.03 4.56 5.01 5.57 7.23 6.53 6.88 6.72 N. Bdry 0.43 0.44 0.46 0.40 0.33 0.25 0.21 0.25 0.34 0.36 0.43 0.40 0.59 0.57 0.49 0.57 0.56 0.46 0.41 0.46 0.40 0.48 0.46 0.42 E. Bdry 1.19 0.92 1.02 1.21 0.92 0.59 0.42 0.45 0.48 0.56 0.78 0.68 0.73 0.68 0.80 0.95 0.37 0.40 0.53 0.85 1.29 1.06 1.29 1.31 W. Bdry 1.01 0.99 0.74 1.05 0.67 0.52 0.44 0.46 0.40 0.71 0.72 0.81 0.88 0.90 1.00 0.98 0.94 1.03 0.87 0.54 0.66 0.65 0.81 1.33 S. Bdry 0.06 0.06 0.06 0.05 0.04 0.03 0.03 0.03 0.05 0.05 0.06 0.05 0.08 0.08 0.07 0.08 0.07 0.06 0.05 0.06 0.05 0.06 0.06 0.06 5-23 5.6.3 Summary of Background Calculations The calculations described above provide a day-specific relationship between PM10 concentrations entering the Salt River Area with the measured concentration at West 43rd Avenue monitor. In Table 5-10, this link between boundary and West 43rd Avenue monitor concentrations is given as a “boundary percentage” and is about 50%. This means that for the four exceedance dates, the PM10 concentrations at the boundaries of the Salt River Area are about one half of those measured by the West 43rd Avenue monitor. This percentage is applied to the average PM10 concentrations from the four monitoring sites (“4-site avg” in the table) to give the background concentration. These background concentrations are added to the prediction from the dispersion model to yield a total estimated concentration at a monitoring site. Date TABLE 5-10 PM10 Background Concentrations West 43rd 4-Site Boundary Background Avenue Average Percentage Concentration ( µg/m³) (µg/m³) (%) (µg/m³) 8-Jan-02 181* 137 49.8 68 15-Apr-02 243 188 46.9 88 26-Apr-02 174 153 47.2 72 16-Dec-02 181 131 50.8 67 rd * Salt River site was used; West 43 Avenue site was not set up until April 2002. Chapter 5 – Air Quality Modeling 5-24 6.0 CHAPTER 6 – 2006 PREDICTED CONCENTRATIONS AND CONTROLS Chapter 4 includes an in-depth accounting of the emissions predicted for 2006. To predict future air quality, these base case 2006 emissions could be put into the Industrial Source Complex model, with the same meteorology as the 2002 design dates. These model predictions would reflect the best estimates of future PM10 concentrations in the Salt River PM10 Study Area without additional controls. Of particular interest is whether the predicted air pollution concentrations are within the health standards. As the reader will see, given the controls described in Section 6.4, attainment can be achieved for the eight exceedances in 2002 that have been studied in this analysis. 6.1 EMISSION CHANGES BETWEEN 2002 AND 2006 AND THEIR AIR QUALITY CONSEQUENCES Chapter 4 describes the predicted base case 2006 PM10 emissions in considerable detail. In this chapter, only the additional controls necessary to meet the standard will be discussed. Emission reductions will be forthcoming from enhanced controls to be placed on five kinds of dust-producing activities: 1. Earthmoving and related activities associated with residential and commercial construction; 2. Industrial activity that is chiefly materials handling and transport, with haul roads, pile forming and material transfer being the principal sources; 3. Vehicular traffic on paved roads, principally the reentrained dust that vehicles generate, which can be reduced through increased street sweeping; 4. Trackout onto paved roads from a variety of sources, which adds to the reentrained dust from the nominally clean roads; and 5. Windblown dust from areas such as alluvial surfaces, vacant lots, miscellaneous disturbed areas, industrial stockpiles, and industrial sites. In addition to emission reductions from these activities, reductions in windblown emissions will also be forthcoming from changes in land use, e.g. the conversion of agricultural land, vacant lots, and miscellaneous disturbed areas to residential and commercial uses. Each of these activities contributes PM10 to the atmosphere throughout the metropolitan area, and within the Salt River PM10 Study Area. Each has some effect on the four monitors within the study area, and the emissions inventory and air quality model have quantified their “source category contributions.” In Section 6.5, each of the eight exceedances is examined in light of the base case and future emissions. Chapter 6 – 2006 Predicted Concentrations and Controls 6-1 6.2 EMISSION REDUCTIONS TO MEET THE STANDARD AND BACKGROUND 6.2.1 Necessary Emission Reductions to Meet the Standard Eight exceedances that occurred in the Salt River PM10 Study Area in 2002 were examined in detail. Each exceedance can be compared with the standard and its percentage above the standard calculated. This percentage above the standard (% above standard) has been calculated by dividing the difference between the [PM10]max, or maximum PM10 concentration, and the value of the standard, 150 µg/m3, by the standard, 150 µg/m3,, and multiplying by 100. % above std = { { [PM10]max – 150 } / 150 } * 100% If there were a one-to-one correspondence between emissions and concentrations, then the percentage above the standard would equal the emission reduction percentage needed to meet it. In the case of most air pollutants studied on most geographical scales, this correspondence is altered by the background value. Discussed in section 5.6, this background concentration makes it more difficult to achieve a standard, because it either does not respond at all to emission reductions that may occur in the study area, or it responds very little. A reasonable example is given by the air pollutant ozone, whose eight-hour natural background concentration is 60 parts per billion (ppb). The air quality standard is 84 ppb. If the exceedance was 100 ppb, the 16 ppb reduction would need to come out of the 40 ppb (100 minus background), not the full 94 ppb; a 40% instead of a 16% reduction. Since the background is present with or without metropolitan emissions or their reductions, the controls have to “work about twice as hard” because they affect about half as much. In the case of the Salt River PM10 concentrations, background values are one half of the elevated concentrations measured within the Study Area. The Study Area is a small fraction of the metropolitan total, as are its emissions (3 to 4%). “Background” in this sense can be regarded as that PM10 concentration that would prevail throughout the Salt River PM10 Study Area if all study-area emissions were to cease. This background concentration results from the emissions of the rest of the metropolitan area, and their resultant transport into the Study Area. To arithmetically account for background, the following equation applies, which, except for the addition of a background term in the denominator, denoted as “[PM10] back”, is identical to the previously discussed formula to calculate the percentage above the standard. % red = {{ [PM10]max – 150 } / { [PM10]max – [PM10]back}} * 100% Before presenting the emission reductions necessary to meet the standard that can be calculated with this equation, another complication has to be explained. The background concentration for some future year will differ from a base year if emission reductions are achieved throughout a metropolitan area. The calculation of emission Chapter 6 – 2006 Predicted Concentrations and Controls 6-2 reductions necessary to meet the standard in 2006 in the Salt River Study Area has to be done with a future background concentration. This is explained below. Because emission reductions will take place throughout the Maricopa County PM10 Nonattainment Area, the background concentration for the Salt River PM10 Study Area will be reduced as well. These background reductions, calculated below, affect the percentage reductions of emissions necessary to meet the standard. The effects are small. Because of the size of metropolitan Phoenix, the distribution of these PM10 emissions throughout this area, and their diminishing effects with increasing distance, the background values change very little. The urban-wide control effect on the Salt River PM10 Study Area background concentration was calculated as explained above. For each source category of emissions, its percentage of the total metropolitan PM10 emissions is calculated (Maricopa Association of Governments emissions inventory [MAG 2000], Quantification of Agricultural Best Management Practices [URS & ERG, 2001]). Next, the spatial distribution of the source-category PM10 emissions from the MAG PM10 technical analysis was obtained. The spatial distribution, sometimes called “emission density maps”, is critical because PM10 emissions more distant from the Salt River Area have less effect than those close to it. (See Appendix M for emission density maps for background concentrations.) For example, emission reductions 20 miles from South Phoenix matter much less than those immediately across the Study Area boundary. The percentage of the source category emissions in each of six zones progressively farther from the Salt River area is then multiplied by a transport weighting factor. This factor is an inverse-squared relationship using distance from the source (r); i.e., 1/r2. This effectively assigns a scalar value of one to the nearest zone and of 0.05 to the most distant. Each zone’s influence for each source category is added to yield an overall background reduction percentage. These percentages are given in the far right column of Table 6-1. TABLE 6-1 Salt River PM10 Study Area Background Reductions From Area Wide Controls Background Reduction PM10 Emissions (MetricTons/Day) % Total Percent Source Category Construction Activity Fugitive Dust 22.85 15.86% 4.53% Entrainment from Construction Trackout 6.10 4.23% 1.21% Industrial Processes 2.63 1.83% 0.59% Process Fugitives 0.42 0.29% 0.09% Paved Road Dust 56.40 39.14% 11.31% Agricultural Tillage 5.58 3.87% 1.11% Windblown 3860 NA 25.27% Chapter 6 – 2006 Predicted Concentrations and Controls 6-3 These percentages in Table 6-1 mean, for example, that if construction activity fugitive dust is reduced 10% urban wide, the background concentration at the Salt River PM10 Study Area would decrease by 4.53% of this, or 0.5%, because of the average distance between the Salt River Study Area and all of the construction activity in the nonattainment area. If windblown dust were reduced by 50% urban-wide, then the Salt River PM10 Study Area background concentrations would go down by about 12%. The Maricopa Association of Governments is carrying out a metropolitan-wide program to purchase PM10 efficient street sweepers. Their staff estimates that between 2002 and 2006, this program will lead to a 7% reduction of reentrained dust from paved roads. The Salt River PM10 Study Area background concentration reduction from this enhanced sweeper program, then, is 11.31% (fifth line of the table, far right) times 7%, or 0.8%. The response of the Salt River PM10 Study Area background concentrations to nonattainment-wide emission reductions did not account for that portion of the background that cannot be reduced. As the following discussion will show, this error turns out to be immaterial in the demonstration of attainment. Nonetheless, the following text discusses how these calculations should have proceeded. 6.2.2 Urban Background – The Irreducible Portion Background concentrations of air pollutants are those concentrations that would be present without any emissions in the domain of interest. For the Salt River PM10 Study Area, these background concentrations represent the degree of PM10 concentrations that would prevail within the Study Area if all activity within it were to cease. The background concentrations occur because of emissions in the rest of the metropolitan area being transported into the Salt River Study Area. The same concept applies to the Phoenix metropolitan area as a whole. Since area-wide emission reductions by 2006 would apply to the nonattainment area only, then that portion of the PM10 loading that comes from outside the metropolitan area would be unaffected. If one were able to zero out all emissions within the metropolitan area and set up air pollution monitors, they would not produce zero readings. Emissions both natural and anthropogenic from outside the area will be transported in and will comprise the background levels for the area. Background concentrations of PM10 are available for three of the four days on which the eight exceedances occurred. One day, April 15, 2002, was not a network run day, so the only PM10 data are the continuous TEOM instruments, none of which is in a background area. Because the meteorology of this date was so similar to its April 26 counterpart, however, that data adequately represents April 15. Table 6-2 presents the background concentrations. Organ Pipe National Monument is a close-to-pristine Sonoran Desert environment whose particulate levels have been among the lowest measured anywhere in the state. Its long-term average of PM10 is about 10 µg/m3. It lies 98 miles south-southwest of downtown Phoenix. Palo Verde is 45 miles west of downtown Phoenix and is subject to considerably more vehicular, construction, and agricultural activity than is Organ Pipe. Chapter 6 – 2006 Predicted Concentrations and Controls 6-4 Its long-term average of PM10 is about 25 µg/m3, although it has been increasing in recent years. Estrella Park is a Maricopa County Park that has large rugged mountainous area with some developed parklands next to the Gila River. On the western fringe of the Phoenix urban area, it lies 17 miles west-southwest of downtown Phoenix. Its long-term PM10 concentration is 30 µg/m3. In 2002 all three sites were equipped with Andersen dichotomous samplers. An EPA equivalent method for PM10, these instruments measure fine particles (about 2.5 microns and smaller) and coarse particles (about 2.5 to 10 microns) separately. TABLE 6-2 Background PM10 Concentrations on Exceedance Days in 2002 (µg/m3) Date Organ Pipe Palo Verde Fine Coarse PM10 Fine Coarse PM10 1/8/2002 3.0 4.6 7.6 6.7 28.2 35.0 4/15/2002 4/26/2002 5.8 16.4 22.2 11.6 64.5 76.1 12/16/2002 6.6 9.8 16.4 41.3 8.7 50.0 Supersite Estrella Park TEOM Fine Coarse PM10 PM10 49.9 107.5 6.6 59.6 66.3 89.2 11.7 36.3 48 50.9 Salt River AVG* BackAVG/BK ground 68.0 21.3 0.31 88.0 72.0 54.9 0.76 67.0 38.1 0.57 1/8/2002 4/15/2002 4/26/2002 12/16/2002 *AVG: • Average Value for January 8, 2002 based on Organ Pipe and Palo Verde PM10 monitors • Average Value for April 26 and December 16, 2002 based on Organ Pipe, Palo Verde, and Estrella PM10 monitors Note that the Phoenix Supersite TEOM concentrations have been shown for reference; and that the 2002 calculated background concentrations for the Salt River study area are also shown. Dividing the average of the two or three measured rural background concentrations by the Salt background gives the fractions in the lower right of the table. These fractions suggest that of the metropolitan Phoenix PM10 concentrations outside of the Salt River PM10 Study Area, the exceedance-day percentages that can be considered a rural background are: 31% on January 8, 76% on April 15 and 26, and 57% on December 16. Chapter 6 – 2006 Predicted Concentrations and Controls 6-5 The Salt River PM10 Study Area background concentrations for 2006 will now be shown in three ways: as they would appear with no credit taken for area-wide emission reductions (Table 6-3), as they would appear with the above background corrections made to the area-wide background reduction (Table 6-4), and as they appear in the TSD with full credit taken for area-wide emission reductions, (Table 6-5). Each of the tables has the measured concentration of the exceedance, the percentage above the standard, the background concentration, the necessary emission reduction to meet the standard (“Needed”), and that reduction obtained from the optimal set of air pollution controls (“Obtain”). TABLE 6-3 Salt River PM10 Attainment Demonstration with Background Concentrations that have No Credit for Area-Wide Emission Reductions % BackMeasured Is the Reduction % PM10 Above ground Standard Date Site Winds Std (µg/m3) (µg/m3) Obtain Attained? Needed 26-Apr-02 SR High 249 40 72 55.9 58 YES High 15-Apr-02 WF 243 38 88 60.0 63 YES High 26-Apr-02 DC 232 35 72 51.3 58 YES High 15-Apr-02 DC 198 24 88 43.6 44 YES High 15-Apr-02 SR 184 18 88 35.4 54 YES High 26-Apr-02 WF 174 14 72 23.5 74 YES 16-Dec-02 WF Low 181 17 67 27.2 36 YES 8-Jan-02 SR Low 174 14 68 22.6 41 YES Chapter 6 – 2006 Predicted Concentrations and Controls 6-6 TABLE 6-4 Salt River PM10 Attainment Demonstration with Background Concentrations that have Credit for Area-Wide Emission Reductions which Accounts for the Rural Background (or Irreducible) Portion of the Metropolitan PM10 Loading Date 26-Apr-02 15-Apr-02 26-Apr-02 15-Apr-02 15-Apr-02 26-Apr-02 16-Dec-02 8-Jan-02 Site SR WF DC DC SR WF WF SR Winds High High High High High High Low Low Measured % PM10 (µg/m3) 249 243 232 198 184 174 181 174 Above Std 40 38 35 24 18 14 17 14 Background (µg/m3) 70.8 86.6 70.8 86.6 86.6 70.8 66.6 67.3 Reduction % Needed Obtain 55.6 59.4 50.9 43.1 34.9 23.3 27.1 22.5 58 63 58 44 54 74 36 41 Is the Standard Attained? YES YES YES YES YES YES YES YES TABLE 6-5 Salt River PM10 Attainment Demonstration with Background Concentrations that have Full Credit for Area-Wide Emission Reductions, with No Accounting for the Irreducible Portion of the Metropolitan Background Date 26-Apr-02 15-Apr-02 26-Apr-02 15-Apr-02 15-Apr-02 26-Apr-02 16-Dec-02 8-Jan-02 Site SR WF DC DC SR WF WF SR Winds High High High High High High Low Low Measured % PM10 (µg/m3) 249 243 232 198 184 174 181 174 Above Std 40 38 35 24 18 14 17 14 Background (µg/m3) 67 82 67 82 82 67 66 67 Reduction % Needed Obtain 54.4 57.8 49.7 41.4 33.3 22.4 27.0 22.4 58 63 58 44 54 74 36 41 Is the Standard Attained? YES YES YES YES YES YES YES YES As these tables demonstrate, attainment is shown regardless of the degree to which the area-wide emission reductions are constrained by the irreducible background portion. Air Quality Division staff agree that the benefits from area-wide controls, as expressed in the Salt River PM10 Study Area background concentrations, should have accounted for that portion of the urban background that cannot be reduced by more stringent control measures. Chapter 6 – 2006 Predicted Concentrations and Controls 6-7 6.2.3 Future Background Concentrations Overall background reduction percentages are obtained by applying these percentages to the appropriate portion of the 2002 and 2006 inventories, and calculating the change as a percentage between the two years. This percentage is then applied to the 2002 background concentration to give the 2006 background value. Both sets of background concentrations are given in Table 6-6. TABLE 6-6 Salt River PM10 Study Area Background PM10 Concentrations and their Response to Anticipated Urban-wide Emission Reductions by 2006 (Units are µg/m3, 24-hour Averages) Exceedance Date Winds 2002 2006 % Change High 88 15-Apr-02 82 6.8 High 72 26-Apr-02 67 6.9 Low/Mod 67 16-Dec-02 66 1.5 Low/Mod 68 8-Jan-02 67 1.5 The background on the high-wind days is more responsive to area-wide reductions than on low-wind days because the windblown background reduction percentage of 25 is so much greater than the other emission types (See Table 6-1). This completes the discussion of future background concentrations. With these background values the equation presented on page 6-3 can be applied to the ambient measurements and the future background values to reveal how much emissions have to be reduced to achieve the standard. The necessary percentage reductions are quite high, ranging from about 20 to 60%, depending on the exceedance (Table 6-7). The percentages to meet the standard are considerably higher than their percentage above it. The net result is that the standard is roughly twice as difficult to achieve as it would be without a background. For April 15 at West 43rd Avenue, occupying the second line of the table, the exceedance is 38% above the standard, but the necessary emission reduction to meet the standard is 58% -- 1.6 times the percentage above the standard. Chapter 6 – 2006 Predicted Concentrations and Controls 6-8 TABLE 6-7 Reductions of Emissions Necessary to Meet the Standard for Eight Salt River PM10 Exceedances Measured % 2006 % Reduction PM10 Above Background to Meet the Date Site Winds (µg/m3) Std (µg/m3)* Standard 26-Apr-02 SR High 249 40 67 54 High 15-Apr-02 WF 243 38 82 58 High 26-Apr-02 DC 232 35 67 50 High 15-Apr-02 DC 198 24 82 41 High 15-Apr-02 SR 184 18 82 33 High 26-Apr-02 WF 174 14 67 22 16-Dec-02 WF Low/Mod 181 17 66 27 8-Jan-02 SR Low/Mod 174 14 67 22 6.3 SIGNIFICANT SOURCES OF PM10 Before discussing the particular mix of sources that lead to the PM10 exceedances, and the degree of additional controls necessary to meet the standard, it is first instructive to explain which sources are “significant.” In any area, some PM10 emission sources are more important than others. Significant sources are defined by EPA as those which contribute more than 5 µg/m3 to any exceedance of the PM10 standard, which itself is 150 µg/m3 averaged for 24 hours. (EPA, 2001). The “significance” concentrations were calculated in the following manner. Because the predicted concentrations, even including the background, were lower than the measurements, these values could not be used directly. Instead, the percentage contribution of each source to ambient PM10 was determined from the model output. This percentage does not include any background contribution. Next the measured concentration has the background subtracted from it. This difference represents the portion of the measured concentration that comes from the Salt River Area sources. Finally, this difference is multiplied by the percentage contribution from each source to give a significance concentration. An example to clarify this method is as follows. The measured PM10 concentration on January 8, 2002, was 174 µg/m3 at the Salt River site. Considering just a single source type, primary roads contributed 24.72% of the locally generated PM10 concentration at this site. This figure comes from the air quality modeling. The background concentration on that day was calculated to be 68 µg/m3. Subtracting this background from the measurement gives 106 µg/m3 – the measured concentration of PM10 from the Salt River Area. This difference is multiplied by the percentage to give the significance concentration of 26.21 µg/m3. Chapter 6 – 2006 Predicted Concentrations and Controls 6-9 Of all the source categories in the Salt River PM10 Inventory, only a few proved to be insignificant: • • • • Agricultural tillage Lawn and garden equipment Vehicular emissions from the Durango curve portion of I-17 Unpaved parking lots For the other source categories, all of which were significant for at least one of the eight exceedances, EPA guidance requires either that Best Available Control Measures be applied to reduce emissions or that compelling reasons be given to show why and how the measures would be unsuitable or ineffective. Table 6-8 shows the significance concentrations for each source category for each exceedance. The tillage and lawn equipment emission categories were left off for clarity, since all their values except two were zero. Chapter 6 – 2006 Predicted Concentrations and Controls 6-10 TABLE 6-8 Predicted Significance Concentrations in µg/m3 from Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2002 816Source Category – Number of 15-Apr 26-Apr Jan Dec Exceedances for which it was Significant SR DC SR WF DC SR WF WF Windblown Agricultural --- 4 24.81 Windblown Alluvial -- 4 4.41 5.63 84.90 41.12 3.49 16.73 59.67 0.47 Large Industrial Area -- 6 54.85 11.71 18.12 7.02 Primary Roads -- 7 26.21 33.30 10.12 8.33 16.47 3.19 6.29 79.52 2.62 28.84 4.17 27.25 7.72 2.10 44.81 Windblown Vacant Lots -- 3 5.77 0.00 3.90 39.60 0.08 Windblown Industrial -- 4 5.90 13.24 33.56 2.62 28.84 4.17 Windblown Disturbed -- 4 8.42 5.53 2.03 25.93 12.01 3.75 6.38 1.54 3.89 7.53 3.46 1.63 Windblown Construction -- 1 0.56 1.87 14.02 0.06 0.39 1.25 Windblown Stockpiles -- 4 1.77 12.58 10.48 8.98 6.52 1.28 Trackout -- 4 6.73 5.99 21.15 Unpaved Shoulders -- 1 2.92 0.70 0.39 1.70 0.00 0.00 0.00 7.23 Secondary Roads -- 1 2.69 1.54 1.20 1.24 1.20 0.66 0.27 6.92 Construction -- 1 6.04 1.17 0.86 4.38 0.45 0.52 0.47 3.44 Industrial Point Sources -- 1 5.33 2.68 3.02 2.93 3.03 0.61 0.04 1.47 Unpaved Parking Lots -- 0* 0.27 1.39 0.07 0.04 1.38 0.08 0.01 0.78 Freeway – 0 Notes: 0.44 0.24 0.27 0.08 0.37 0.29 0.07 0.70 Shaded concentrations exceed 5 µg/m3 and are, by definition, “significant.” SR = Salt River monitoring site DC = Durango Complex site WF = West 43rd Avenue site The importance of the 5 µg/m3 significance test is to determine which sources must be considered for Best Available Control Measures (EPA, 1994). Therefore, in this Technical Support Document, each of the source categories that are shaded in Table 68 will be evaluated with additional control measures since these source categories meet the 5 µg/m3 criterion. Chapter 6 – 2006 Predicted Concentrations and Controls 6-11 6.4 EMISSION REDUCTIONS FOR ATTAINMENT 6.4.1 Summary Table 6-9 assesses the achievement of attainment for eight exceedances in Salt River Study Area for 2002. For each of the eight exceedances, the measured concentration is followed by the percentage reduction necessary to achieve the standard. This is followed by the percentage reduction obtained through the additional controls. This percentage includes the adjustment to background concentrations to reflect metropolitan-wide controls. Attainment is shown for all eight, although several exceedances are in attainment by a narrow margin. Table 6-9 Salt River PM10 Study Area Exceedances and Attainment Status in 2006 Reduction % PM10 Is the Standard 3 Date Site Winds (µg/m ) Needed Obtained Attained? 26-Apr-02 Salt River 249 54 58 YES rd 15-Apr-02 West 43 243 58 63 YES 26-Apr-02 Durango 232 50 58 YES High 15-Apr-02 Durango 198 41 44 YES 15-Apr-02 Salt River 184 33 54 YES rd 26-Apr-02 West 43 174 22 74 YES rd 16-Dec-02 West 43 181 27 36 YES Low/Mod 8-Jan-02 Salt River 174 22 41 YES In the discussion of the individual exceedances to follow, two concepts apply: 1. The 2006 predicted PM10 concentrations are a consequence of emission reductions from a number of sectors. It is these predicted future concentrations that are being compared with the standard, not those from the 2006 base case. 2. The model is being applied to the Salt River PM10 Study Area concentrations in a relative, not an absolute, sense. The sum of the background concentration and the model-predicted concentration equals the “total prediction”. For 2006, the background concentration is lowered to account for the application of all controls urban wide. The model is then run for 2006 with the predicted Salt River area emissions with the additional controls. To show attainment, the percentage difference between the 2002 model predictions and the 2006 model predictions must equal or exceed the necessary reductions calculated from the measured PM10 concentration and the background. 6.4.2 Additional Controls The emission changes from 2002 to 2006 are shown in Table 6-10. Two sets of emission reductions are given. The first set is explained in Section 4.5 of the TSD and is considered to be the “2006 base case” emission reductions. These reductions reflect controls already in place in 2002. As will be shown in the present chapter, attainment cannot be achieved with these base case controls. The second set of emission Chapter 6 – 2006 Predicted Concentrations and Controls 6-12 reductions is called the “2006 attainment case” and is sufficient to show attainment. Each of the controls is explained below the table. TABLE 6-10 PM10 Percentage Emission Changes in the Salt River Study Area from 2002 to 2006 for the Base and Attainment Cases (A Negative Sign Means a Reduction; Positive Means an Increase) 2006 2006 Base Attainment Emission Category Case Case Wind Erosion – Agricultural -80 -80 Wind Erosion – Alluvial -57 -72 Wind Erosion – Construction -19 -19 Wind Erosion -- Vacant Lots -61 -61 Wind Erosion --Misc. Disturbed Areas -45 -45 Wind Erosion – Industrial Stockpiles NA -55 Wind Erosion – Industrial Surface NA -75 Agricultural Tillage (Land Preparation) -80 -80 Construction Activity -36 -36 Freeway - Interstate 17 Durango +6 +6 Primary Roads +6 -7 Secondary Roads +6 -1 Trackout NA - 80 Unpaved Road Shoulders -10 -10 Unpaved Parking Lots – Re-entrained Dust -36 -36 Industrial Area Sources NA -60 Industrial Point Sources NA -17 Chapter 6 – 2006 Predicted Concentrations and Controls 6-13 Following is a discussion of the percent change in emissions between Year 2002 and 2006: • Wind Erosion – Agricultural: Conversion of 80% of the farm land to other uses. • Wind Erosion – Alluvial: The control effectiveness for wind erosion – alluvial emissions is 72% (RP x RE x CE = 72%). This reduction is based on an assumed rule penetration (RP) of 100%, a rule effectiveness of 90% (RE), and an assumed control efficiency (CE) of 80%. The 100% penetration arises from the small number of landowners with dust-producing alluvial properties. Most of the alluvial property is locally owned and much of it is owned by governments. The control efficiency of 80% is consistent with an effective program to keep trespassers out and to stabilize the alluvial surfaces with either vegetation or rock/gravel/concrete. (A control efficiency of 80% was assumed for alluvial soil instead of the 90% control efficiency for vacant lots, because alluvial soil is assumed to be an infinite source of PM10 under windy conditions. In contrast, vacant lots will typically produce PM10 emissions at the start of a wind event and then taper off to minimal levels as the reentrainable PM10 on its surface becomes depleted by wind erosion.) An emissions reduction of this size is possible because the windblown dust from the alluvial areas of the Salt River was considered to be uncontrolled in 2002. This lack of control was evident in numerous field inspections conducted in February – May 2004 by ADEQ staff. For those portions of the river bottom area classified as moderate or severe in their windblown dust potential, the investigators noted ample evidence of vehicular traffic, extremely friable soil surfaces (sometimes ankle deep), and scant evidence of any attempts to stabilize the surface. The base case 2006 reduction percentage of 57% (Table 4-6 in Chapter 4) reflects the impact of Maricopa County Rule 310.01 on this area. As explained above, the 72% reduction of the 2006 attainment case comes from a concerted effort on the part of the County (and State) to get the property owners to both effectively bar access and to stabilize the ground surfaces wherever needed. • Wind Erosion – Construction: The 19% reduction results from an increase in overall control efficiency of 63% in 2002 to 70% in 2006. The emission reduction is not equal to the difference of the two efficiencies (this would be 7%). If the uncontrolled emissions were 100 tons, then, 63% control means that the actual emissions are 37 tons. In 2006, with a 70% control efficiency, the actual emissions are 30 tons. The emission reduction percentage, then, is (37-30)/37 times 100% = 19%. • Wind Erosion – Vacant Lots: The 61% figure is a combination of the 36% emission decrease from enhanced enforcement through Rule 310.01 and the 39.0% decrease in area from conversion to residential or commercial buildings. Vacant lots in the Salt River Area were surveyed in May 2004 by ADEQ staff, Chapter 6 – 2006 Predicted Concentrations and Controls 6-14 and 39% was the prorated percentage of vacant lot development for 2002 – 2006 (See Appendix R). There were not enough miscellaneous disturbed areas to yield any new information, so the 13.6% was retained for this category. For vacant lots, 39% of the emissions are first removed and the 36% enhancement is applied to the remaining. • Wind Erosion -- Disturbed Areas: The 45% figure is a combination of the 36% emission decrease from enhanced enforcement through Rule 310.01 and the 13.6% decrease in area from conversion to residential or commercial buildings (URS & ERG, 2001). 13.6% of the emissions are first removed and the 36% enhancement is applied to the remaining • Agricultural Tillage: 80% conversion of farm land to other uses. • Construction Activity: The 36% reduction comes from enhanced enforcement of Rule 310. This reduction comes from an increase in overall control efficiency of 56% in 2002 to 72% in 2006. • Freeway - Interstate 17 Durango: The Maricopa Association of Governments has estimated that traffic volumes in the Salt River Area will increase by 6% from 2002 to 2006. This increase is based on the actual growth rate of traffic counts taken on roads in the Salt River Area between 1998 and 2002. • Primary Roads: Reentrained dust and exhaust emissions from primary and secondary roads increase because of the 6% traffic increase and decrease because of increased sweeping. Primary roads have a net decrease of 7%. This figure is the combination of the 6% VMT increase and a 13% emission decrease from increased sweeping. The dirty portions of the streets, swept once every two weeks in 2002, were assumed to be swept once a week by 2006. In the Salt River Area “dirty streets” were assumed to be those primary streets adjacent to or within one quarter mile of an industrial, construction, or agricultural property (See Appendix L). In 2002, these streets with PM10 trackout and deposition potential amounted to 63% of the total length of primary roads. • Secondary Roads: In the Salt River Area emissions inventory, secondary roads are defined as all roads except the one-mile primary streets. The inventory emission total for secondary roads, therefore, includes emissions from collectors and residential streets. As increased sweeping applies only to the mile and halfmile streets, the calculations have taken this limitation into account. There are no projected emission changes or sweeping practices for residential or collector streets. Secondary roads have a net emissions decrease of 1%, a combination of the 6% VMT increase and a 7% decrease in emissions from an assumed doubling of the frequency of sweeping from once every two weeks to once a week on the targeted half-mile streets. Approximately 66% of the half-mile streets would have been subject to increased sweeping in 2002 (See Appendix L). Chapter 6 – 2006 Predicted Concentrations and Controls 6-15 • Trackout: Trackout onto paved streets comes from a variety of sources: industrial, construction, agricultural, commercial, private, and road shoulders. An ADEQ survey in May 2004 divided trackout into these six categories, and subdivided each one into three levels: light, medium, and heavy. Weighting these trackout contributions to ambient PM10 concentrations by the typical length and severity of the trackout showed that the industrial category accounted for about 85% of the total trackout contribution (See Appendix K). Construction contributed 7%, road shoulders 3%, and agricultural 2%. Trackout emissions were assumed to be reduced 80% by a combination of more frequent sweeping targeted at the problem streets and of reduced trackout from all the categories, but especially the industrial category. This was assumed to be the result of the more stringent Maricopa County Rule 316, and from better enforcement of all three County dust rules, 310, 310.01, and 316. Although ADEQ understands that unpaved road shoulders contribute to trackout, and that street sweeping is less efficient the greater the trackout, staff are confident in their relative weighting of this source’s six types. What the survey data show is that the shoulder trackout is more frequent but less severe than trackout from construction and industrial sources. It stands to reason that unpaved road shoulder trackout is shorter than that from industrial and construction sources. While PM10 concentrations would most certainly be reduced if all shoulders were stabilized, and if all streets were installed with curbs and gutters, the cost-effectiveness of these improvements is in question. The derivation of the 80% emissions reduction credit for trackout is explained below.. Average weighted contribution: Industrial - 85% Construction - 7% Road shoulders - 3% Agricultural - 2% Other - 3% Assume reductions are all taken from a 0% control baseline because the trackout emissions assessed in the 2002 base year in the Salt River plan are based on actual dirt trackout measurements, and the enhanced measures are aimed at reducing that trackout. Example of a hypothetical trackout reduction using a value of 100 tons reduced 80% to 20 tons for simplicity: Chapter 6 – 2006 Predicted Concentrations and Controls 6-16 Construction trackout = 7 tons • Credit a 72% reduction (90% RE and 80% CE) • 7 * 0.72 = 5.04 reduction • 7 - 5.04 = 2 tons remaining Road shoulders, agricultural, other = 8 tons • Credit a 10% reduction to enhanced primary/secondary road street sweeping (this is an average of the 13% and 7% reduction credited to the primary roads and secondary roads, respectively, within the separate paved road re-entrained dust category) • 8 * 0.10 = 0.8 reduction • 8 - 0.8 = 7 tons remaining Industrial trackout = 85 tons • Credit an 87% reduction (90% RE and 97% CE), with the higher CE supported by more stringent Rule 316 trackout control measures plus street sweeping • 85 * 0.87 = 73.95 reduction • 85 - 73.95 = 11 tons remaining 11 + 7 + 2 = 20 tons, or an overall 80% reduction • Unpaved Road Shoulders: Emissions from unpaved shoulders consist of five types: 1. Wake effects from high profile vehicles, 2. Vehicles driving on the shoulders, 3. Vehicles tracking out dirt onto the pavement, 4. Vehicles parking on the shoulders, and 5. Windblown dust from the shoulders themselves. Chapter 6 – 2006 Predicted Concentrations and Controls 6-17 The wake-induced emissions were assumed to be reduced 10% through shoulder stabilization work. The trackout emissions from unpaved shoulders are treated as part of the road sweeping and general trackout reductions. The Salt River PM10 emissions inventory quantified two of these, the wake effects and the trackout. All five types of emissions are examined below, with the net result that these five activities combined comprise a small percentage of the total emissions. Expressed in dollars per ton of PM10 reduced, curb and gutter and stabilizing would be $5.1 million per ton for low-wind days and $2.3 million per ton for low-wind days. These figures are far from being cost-effective. The five components of unpaved shoulder dust emissions are discussed below. 1. Unpaved shoulder emissions from wake effects were quantified in the emissions inventory. 2. Without any hard data on how many cars drive on the shoulders and for what distances, the figures of 1000 vehicles per day driving on the shoulders for a distance of 100 meters are employed. Applying the unpaved parking lot emission factor to this mileage provides at least an estimate of this activity. 3. Trackout was determined in the inventory, and, using the weighted trackout method, the shoulder contribution to these emissions is easy to calculate (See Appendices K and P). 4. Lacking information on how many vehicles park on the shoulders, an order of magnitude estimate is in the inventory: namely, the emissions from unpaved parking lots. 5. Windblown emissions were calculated as the product of the surface area of the unpaved shoulders and the emission factor. These components of unpaved road shoulder emissions are summarized in Table 6-11. Chapter 6 – 2006 Predicted Concentrations and Controls 6-18 TABLE 6-11 PM10 Emissions from Unpaved Road Shoulders Sources Metric Tons per Day Wake effects 0.13 Parking 0.003 Driving 0.016 Windblown 0.28 Trackout 0.04 Unpaved Road Shoulders - Low Wind Total All sources - Low Wind Total % Unpaved Road Shoulders 0.19 Unpaved Road Shoulders - High Wind Total All sources-High Wind Total % Unpaved Road Shoulders 0.47 6.20 3.0 171.0 0.3 Examination of Table 6-11 shows that Unpaved Road Shoulder emissions comprise three percent of the total PM10 emissions in the Salt River PM10 Study Area on low-wind days, and, on high-wind days, the percentage is 0.3. Furthermore, the cost-effectiveness of installing curb and gutter on the fourteen miles of streets with unpaved shoulders, and including stabilizing the shoulders themselves, does not appear to be favorable. If the cost of one mile of curb and gutter is $68,000 and the cost of shoulder stabilizing is $8,000, then the cost of reducing a ton of unpaved shoulder PM10 is $5.1 million for the low-wind conditions and $2.3 million for the high-wind conditions. Limiting the remediation to stabilizing only, and invoking a 75% control efficiency for the stabilized shoulder surfaces, produces less costly reductions: $0.8m per ton for low-wind and $0.3m per ton for high-wind conditions. Compared with the more capital-intensive combination of curb and gutter and stabilizing, stabilizing alone is much more cost effective in reducing PM10 emissions. Unpaved road shoulders in their five emissions manifestations do contribute to ambient PM10 concentrations. Municipalities in the metropolitan Phoenix area would do well to install curb and gutters along most major streets. Such capital improvements would effectively eliminate four types of the shoulder emissions, leaving only windblown dust and, perhaps, but to a lesser extent, the wake effects. These improvements would also facilitate better drainage and improve roadway safety. Given the cost-effectiveness figures in the Chapter 6 – 2006 Predicted Concentrations and Controls 6-19 millions of dollars per ton; however, an accelerated program of curb and gutter work and shoulder stabilization as an air pollution control measure would be difficult to justify. (See Appendix U for additional information on the contribution of parking and driving on unpaved road shoulders, and wind erosion of unpaved shoulders to total PM10 emissions and predicted PM10 concentrations) • Unpaved Parking Lots – Re-entrained Dust: PM10 emissions from vehicles driving on unpaved parking lots were assumed to be reduced by 36%, through an assumed increase in the overall control efficiency of 56% in 2002 to 72% in 2006. These reductions were based on better enforcement of Rule 310. • Industrial Area Sources: For the 2006 base case, the throughput of materials and their emissions were assumed to be the same as in 2002. This assumption has been borne out by throughput statistics presented in Appendix S. The 60% reduction in PM10 emissions from this collection of sources was assumed to be obtained through a strengthened Rule 316. Industrial Area Sources are defined as all sources of emissions from the industrial facilities in the Salt River Area, except registered stacks (or “points”) and windblown dust. This category includes such activities as driving on haul roads (56% of the emissions total), material transfer (20%), pile forming and loading (8%), crushing and screening (6%), and a variety of other activities that contribute the remaining 10%. Emission reductions from 65 to 70% for the first four of these activities would result in the overall 60% reduction. This matter is discussed more fully in Appendix S, which gives additional rationale for the reductions and a sensitivity analysis of the predicted concentrations based on varying control levels in 2002. • Industrial Activity - Material Transfer: The 65% reduction results from the assumed imposition of a fenceline opacity requirement of 0%, except on high wind days when reasonable precautions have been employed. In order for sources to achieve compliance with this requirement it is assumed that material transfer points will be controlled through the application of additional water control systems, increased material moisture content, and voluntarily applied enclosures. • Industrial Activity - Pile Forming/Loading: The 70% reduction results from an assumed imposition of a fenceline opacity requirement of 0%, except on high wind days when reasonable precautions have been employed. In order for sources to achieve compliance with this requirement it is assumed that stockpiles will be controlled through the application of additional water control systems, increased material moisture content, or the application of storage pile covers and partial enclosures. Additionally, loaders and all other ancillary equipment will be required to operate on controlled surface areas. Chapter 6 – 2006 Predicted Concentrations and Controls 6-20 • Industrial Activity - Crushing and Screening: The 70% reduction results from an assumed imposition of a fenceline opacity requirement of 0%, except on high wind days when reasonable precautions have been employed. In order for sources to achieve compliance with this requirement, sources were assumed to be required to install and operate permanently mounted watering systems on the inlet and outlet of all crushers, shaker screens, and on material transfer points. In addition, sources were assumed to be required to control screening emissions through the application of watering systems at the base of the screen; and loaders and all other ancillary equipment were assumed to be required to operate on controlled surface areas. Additional reductions are also expected from Concrete Batch Plants assumed to be applying baghouses designed to meet 0.01 gr/dscf emission standard, pneumatic pressure controls that shut off the silo loading process if excessive pressure is used when loading the silo, and audible or visible overfill warning systems. Additional reductions are also expected from Hot Mix Asphalt Plants from an assumed imposition of a 5% opacity requirement, overfill warning systems for silo, and baghouse controls for all drum dryers. • Windblown Emissions - Stockpiles: The 55% reduction results from an assumed fenceline opacity requirement of 0%, except on high wind days when reasonable precautions have been employed. It was assumed that sources would apply additional watering controls, and potentially stockpile covers and enclosures in order to meet this opacity requirement. • Windblown Industrial Emissions: Those particulates from the disturbed ground surface of industrial facilities are an important contributor to elevated PM10 levels and are easily reduced. Their contribution to elevated PM10 concentrations for the six high-wind exceedances varies from 1.6 to 21.9%, with an average of 10.4%. On average there are fewer than 12 days a year when the wind speeds exceed the resuspension threshold for dust. Managers of industrial properties can take the appropriate actions of watering, tarping, and cessation of activities on the few occasions when winds approach and exceed the dust suspension threshold. With better enforcement of the two County rules, managers of these properties should take the requisite precautions to reduce windblown dust. The 75% emissions reduction for this source category would entail implementation of such control measures as wetting the surface areas prone to erosion when high winds are forecast. The implementation of the above control measures for windblown industrial emissions results in an equivalent control percentage of about 75%, based on the following three components: Chapter 6 – 2006 Predicted Concentrations and Controls 6-21 1. Rule effectiveness: 85%, which accounts for failures and uncertainties that affect the actual performance of a control; 2. Rule penetration: 100%, which is the percentage of a source category covered by a regulation; and 3. Control efficiency: 90%, which is the efficiency of a control device or process change. Multiplying these percentages gives an equivalent control percentage of 76.5%. At issue here are 36 industrial facilities in a 32 square mile area no more (at its closest point) than a five minute drive from the MCESD offices. The rule effectiveness of 85% means that the MCESD and the regulated community would have 31 of 36 facilities actively taking the necessary precautions to reduce windblown dust about 12 times a year. Given the small number of facilities, given their proximity to the MCESD offices, and given the fact that they are already equipped with the means to suppress dust, it’s not unreasonable to assert that windblown industrial emissions can in fact be reduced by 75% by 2006. The assumption of 0% equivalent control for Year 2002 for these sources is based on the fact that no citations for windblown industrial emissions were issued in 2002 in the Salt River area; no evidence would suggest that precautions were being taken; and concentrations ranging from 174 to 249 µg/m3 of PM10, averaged for 24 hours, were recorded at three monitoring sites close to these industrial sources. ADEQ’s analysis of emissions and air quality data from these three sites has demonstrated that their elevated PM10 concentrations are in part (average 10%) attributable to windblown industrial emissions. All of these facts lead to the conclusion that control over this source category in Year 2002 was minimal, if not zero. • Industrial Point Sources: These emissions are from those stacks registered with the MCESD as having more than 5 tons per year of PM10 emissions. The small percentage reduction reflects the fact that they are already well controlled. An overall reduction of 17% will be forthcoming from assuming the application of the Maximum Achievable Control Technology to one brick manufacturer. In the discussions of future air quality to follow, these percentage emission reductions by source category are applied to the 2002 predicted concentrations to produce 2006 air quality concentrations. Table 6-12 lists the projected Year 2006 Attainment Case emissions by category. Chapter 6 – 2006 Predicted Concentrations and Controls 6-22 TABLE 6-12 Salt River PM10 Emissions Inventory – Year 2006 Attainment Case (Metric Tons / Day) 1/8/06* 1. AREA SOURCES 4/15/06* 4/26/06* Low Wind High Wind High Wind Low Wind Tuesday* Monday* 0.02 Monday* Friday* 45.36 45.36 Wind Erosion – Agricultural 9.35 9.35 Wind Erosion – Construction 15.20 15.20 Wind Erosion - Cleared Areas 18.06 18.06 Ag Tilling (Land Preparation) 12/16/06* 0.02 • vacant lots 8.30 8.30 • misc. disturbed areas 9.76 9.76 Wind Erosion - Alluvial Channels 2. INDUSTRIAL SOURCES 0.41 MCESD Permitted Sources – Windblown Stockpiles MCESD Permitted Sources – Windblown Cleared Areas 2.75 2.75 13.36 16.71 2.22 5.57 10.73 10.73 0.41 MCESD Permitted Sources – Stacks 0.22 0.22 0.22 0.22 MCESD Permitted Sources – Process 0.18 0.18 0.18 0.18 MCESD Permitted Sources – Small 0.01 0.01 0.01 0.01 3. NONROAD MOBILE SOURCES 0.54 0.54 0.54 0.54 0.54 0.54 0.54 Agricultural Equipment Exhaust 0.00 Construction Activity 0.54 Chapter 6 – 2006 Predicted Concentrations and Controls 6-23 TABLE 6-12 Salt River PM10 Emissions Inventory – Year 2006 Attainment Case (Metric Tons / Day) 1/8/06* 4. ONROAD MOBILE SOURCES 4/15/06* 4/26/06* 12/16/06* Low Wind High Wind High Wind Low Wind Tuesday* Monday* Monday* Friday* 3.52 3.52 3.52 3.52 0.06 0.06 0.06 0.06 Paved Road Freeway – Brakes, Tires, Exhaust, Reentrainment Primary Roads • reentrained road dust 2.74 2.74 2.74 2.74 • exhaust 0.08 0.08 0.08 0.08 • brakes 0.02 0.02 0.02 0.02 • tires 0.01 0.01 0.01 0.01 2.85 2.85 2.85 2.85 Primary roads subtotal Secondary roads • reentrained road dust 0.58 0.58 0.58 0.58 • exhaust 0.02 0.02 0.02 0.02 • brakes 0.004 0.004 0.004 0.004 • tires 0.003 0.003 0.003 0.003 Secondary roads subtotal 0.61 0.61 0.61 0.61 Paved Road Total Emissions 3.46 3.46 3.46 3.46 5. Trackout 0.13 0.13 0.13 0.13 6. Unpaved Shoulders & Parking Lots 0.122 0.122 0.122 0.122 0.12 0.12 0.12 0.12 0.002 0.002 0.002 Unpaved Road Shoulders Unpaved Parking Lots - reentrained dust 0.002 * Theoretical design days in Year 2006 that have same meteorological conditions, time of year, day of week to the 4 design days in Year 2002 Emissions Inventory and Modeling. Chapter 6 – 2006 Predicted Concentrations and Controls 6-24 6.5 DEMONSTRATION OF ATTAINMENT Each of the eight 2002 exceedances is analyzed in the next three subsections. 6.5.1 West 43rd Avenue on April 15 and April 26, 2002 In spite of the very high measured concentrations, controls can be implemented to bring these two exceedances within the standard in 2006. Values this high require large emission reductions to meet the standard. Two emission source categories dominate the high concentrations at West 43rd Avenue on these two days: windblown alluvial and windblown industrial emissions on April 15, and windblown alluvial alone on April 26. This monitoring site, with each day having four afternoon hours of high west winds capable of re-suspending dust, is downwind of a large expanse of the Salt River alluvial channel and major sand and gravel operations. As the figures below (Figure 6-1 a,b and Figure 6-2a,b) show, windblown dust in general dominates the PM10 concentrations on these dates, and alluvial is the larger contributor within the windblown category. Control strategies envisioned for alluvial dust (72% reduction) and industrial windblown emissions (75% reduction) prove sufficiently strong to meet the standard. For the April 15 exceedance, a reduction in model-predicted air quality of 58% is needed to show attainment; 63% is obtained from the predicted controls. For the April 26 exceedance, a reduction in model-predicted air quality of 22% is needed to show attainment; 74% is obtained from the predicted controls. This may seem an excessive level of control, but all of these reductions are necessary to achieve attainment for all exceedances. Chapter 6 – 2006 Predicted Concentrations and Controls 6-25 4/15/02 West 43rd Avenue INDUSTRIAL 6% UNPAVED ROAD SHOULDERS 1% TRACKOUT 3% UNPAVED PARKING LOTS 0% ROADS 6% WINDBLOWN 81% CONSTRUCTION ACTIVITY 3% 4/15/02 West 43rd Avenue AGRICULTURAL 4% INDUSTRIAL 27% ALLUVIAL CHANNELS 48% STOCKPILES 8% CONSTRUCTION 11% VACANT LOTS 0% MISC DISTURBED 2% Figures 6-1a (top) and b. Source Contributions to PM10 at West 43rd Avenue on April 15, 2002, for all sources (a) and for windblown sources (b). These figures show that the exceedance (243 µg/m3) was caused by windblown dust (top) and that of the windblown contributors, alluvial channels and industrial dominated. Chapter 6 – 2006 Predicted Concentrations and Controls 6-26 4/26/02 West 43rd Avenue INDUSTRIAL 4% TRACKOUT 7% UNPAVED ROAD SHOULDERS 1% WINDBLOWN 86% UNPAVED PARKING LOTS 0% CONSTRUCTION ACTIVITY 0% ROADS 2% 4/26/02 West 43rd Avenue INDUSTRIAL 4% STOCKPILES 1% AGRICULTURAL 3% CONSTRUCTION 1% MISC DISTURBED 4% VACANT LOTS 0% ALLUVIAL CHANNELS 86% Figures 6-2a (top) and b. Source contributions to PM10 at West 43rd Avenue on April 26, 2002, for all sources (a) and for windblown sources (b). These figures show that the exceedance (174 µg/m3) was caused by windblown dust (a) and that of the windblown contributors, alluvial channels dominated. Chapter 6 – 2006 Predicted Concentrations and Controls 6-27 6.5.2 Other High Wind Exceedances: Durango Complex and Salt River on April 15 and April 26, 2002 At these sites, as with West 43rd Avenue, attainment has been demonstrated because the controls applied to the emission source categories sufficiently lower the predicted concentrations to meet the standard. Durango Complex Site Considering the Durango Complex site exceedances first, the April 15 PM10 concentration of 198 µg/m3 can be attributed to an equal mix of windblown and anthropogenic sources (Figures 6-3 a,b). Roads, industrial, and trackout emissions are all major contributors from the anthropogenic emissions, while agricultural emissions dominate the windblown emissions. The agricultural contribution came from a complex of fields about two miles west of the monitoring site. For attainment in 2006, an emissions reduction of 41% is necessary. Envisioned controls will just exceed this figure at 44%. Of greater concern is the exceedance of April 26 at Durango, with a PM10 concentration of 232 µg/m3. A reduction of 50% in emissions is necessary to meet the standard on this date. This exceedance, whose sources are shown in Figure 6-4a and Figure 6-4b, was caused by a somewhat different mix of sources than the April 15 exceedance. The windblown contribution has increased from 46% to 78%, and the agricultural contribution to the windblown part has increased from 49% to 68%. While roads contributed 32% of the total PM10 concentration on April 15, their contribution on April 26 was down to 11%. The projected controls account for a 58% reduction in emissions, sufficient to meet the standard. Much of this reduction comes from the removal of 80% of the agricultural land. Additional outreach to farmers will be made through the Agricultural Best Management Practices program to encourage them to use practices that will minimize the potential for windblown dust during April, when fields are most at risk for generating dust. Chapter 6 – 2006 Predicted Concentrations and Controls 6-28 4/15/02 Durango TRACKOUT 6% WINDBLOWN 46% INDUSTRIAL 13% UNPAVED ROAD SHOULDERS 1% UNPAVED PARKING LOTS 1% ROADS 32% CONSTRUCTION ACTIVITY 1% 4/15/02 Durango STOCKPILES 3% INDUSTRIAL 12% CONSTRUCTION 1% MISC DISTURBED 17% VACANT LOTS 11% ALLUVIAL CHANNELS 7% AGRICULTURAL 49% Figure 6-3a (top) and b. Source contributions to PM10 at Durango on April 15, 2002, for all sources (a) and for windblown sources (b). These figures show that only about half the exceedance (198 µg/m3) was caused by windblown dust (a) and that of the windblown contributors, agricultural dominated. Chapter 6 – 2006 Predicted Concentrations and Controls 6-29 4/26/02 Durango UNPAVED ROAD SHOULDERS 1% INDUSTRIAL 4% TRACKOUT 5% UNPAVED PARKING LOTS 1% ROADS 11% CONSTRUCTION ACTIVITY 0% WINDBLOWN 78% 4/26/02 Durango INDUSTRIAL 2% STOCKPILES 7% AGRICULTURAL 68% CONSTRUCTION 0% MISC DISTURBED 20% VACANT LOTS 3% ALLUVIAL CHANNELS 0% Figure 6-4a (top) and b. Source contributions to PM10 at Durango on April 26, 2002, for all sources (a) and for windblown sources (b). These figures show that about three quarters of the exceedance (232 µg/m3) was caused by windblown dust (a) and that of the windblown contributors, agricultural dominated. Chapter 6 – 2006 Predicted Concentrations and Controls 6-30 Salt River Site The two high-wind exceedances at the Salt River site were also on April 15 and April 26, 2002, with 24-hour average PM10 concentrations of 184 and 249 µg/m3, respectively. Emission reductions needed to meet the standard are 33% and 54%, respectively, with credit taken for the urban-wide application of control strategies. Wind speeds high enough to resuspend dust occurred for four afternoon hours of each date. Given this site’s proximity to Durango (one mile to the southeast), a similar source distribution might be expected. As Figure 6-5a and Figure 6-5b illustrate, this source mixture is quite different than that at Durango, and is quite receptive to emission reductions. In comparison with the high-wind exceedances already discussed, the April 15 Salt River site exceedance has a similar windblown contribution (63%). Its anthropogenic source contributions are dominated by industrial emissions (22%) and by reentrained dust from paved roads (12%). The critical difference between this exceedance and the previous ones is that the windblown contribution is more or less equally divided among all of the windblown dust categories. Windblown emissions at West 43rd Avenue and Durango were dominated by a single category: alluvial channels at the former and agricultural at the latter. At the Salt River site the categories of ”industrial windblown stockpile” and “industrial surface area” emissions come into play for the first time. The Salt River monitor is the closest of the four to major industrial activity, with facilities on the east, the south, and the west. With the exception of alluvial emissions, all of these categories will be reduced by 2006; consequently, attainment is relatively easy to demonstrate. The necessary emission reduction of 33% is significantly surpassed with the 54% predicted reduction. Demonstrating attainment for the last of the six high-wind exceedances – that at the Salt River on April 26, 2002 – would seem to be more difficult than demonstrating it for the April 15 exceedance. The measured PM10 concentration was the highest recorded in 2002, at 249 µg/m3. Windblown emissions contribute more on the April 26 date, 76% versus 63% on April 15. The necessary emission reduction to meet the standard on April 26 is 54%, almost twice that of the April 15 reduction of 33%. The influence of industrial windblown emissions – from the stockpiles and ground surfaces combined -decreases from 43% to 26% from the first to the second April high-wind exceedance. These stockpile and surface area emission reductions from 2002 to 2006 are quite high (55% and 75%, respectively) and are instrumental in achieving attainment. The main difference on this latter April date can be found in the agricultural windblown category, which on April 15 was 7% of the total PM10 concentration, but which rises to 31% on April 26 (Figure 6-6). As was seen in the Durango exceedances, because of the 80% elimination of agricultural land, having a high agricultural contribution in 2002 means that it’s easier to attain the standard in 2006 than with a smaller agricultural component. For the Salt River exceedance of April 26, 2002, a 54% emission reduction is necessary to attain the standard. With stringent industrial controls, enhanced Rule 310, increased street sweeping, and the retirement of agricultural land, the predicted concentration is reduced by 58% in 2006 – enough to meet the standard. Chapter 6 – 2006 Predicted Concentrations and Controls 6-31 4/15/02 Salt River UNPAVED ROAD SHOULDERS 0% UNPAVED PARKING LOTS 0% INDUSTRIAL 22% TRACKOUT 2% ROADS 12% CONSTRUCTION ACTIVITY 1% WINDBLOWN 63% 4/15/02 Salt River ALLUVIAL CHANNELS 28% AGRICULTURAL 7% INDUSTRIAL 22% VACANT LOTS 10% STOCKPILES 21% CONSTRUCTION 3% MISC DISTURBED 9% Figure 6-5a (top) and b. Source contributions to PM10 at Salt River on April 15, 2002, for all sources (a) and for windblown sources (b). These figures show that two thirds of the exceedance (184 µg/m3) was caused by windblown dust (a) and that the windblown contributors were more equally divided among several sources than was the case for exceedances at West 43rd Avenue and Durango. Chapter 6 – 2006 Predicted Concentrations and Controls 6-32 4/26/02 Salt River INDUSTRIAL 17% UNPAVED ROAD SHOULDERS 0% TRACKOUT 2% UNPAVED PARKING LOTS 0% ROADS 5% WINDBLOWN 76% CONSTRUCTION ACTIVITY 0% 4/26/02 Salt River ALLUVIAL CHANNELS 5% AGRICULTURAL 31% VACANT LOTS 29% MISC DISTURBED 9% INDUSTRIAL 21% STOCKPILES 5% CONSTRUCTION 0% Figure 6-6a (top) and b. Source contributions to PM10 at Salt River on April 26, 2002, for all sources (a) and for windblown sources (b). These figures show that 85% of the exceedance (249 µg/m3) was caused by windblown dust (a) and that the windblown contributors were equally divided among several sources as in the Salt River exceedance of April 15. Chapter 6 – 2006 Predicted Concentrations and Controls 6-33 6.5.3 Low Wind Exceedances on January 8 and December 16, 2002 Two exceedances were recorded during low wind conditions: January 8, 2002, at Salt River, and December 16, 2002, at West 43rd Avenue with PM10 concentrations of 174 µg/m3; and 181 µg/m3, respectively. For these exceedances the seven categories of windblown dust are gone, leaving the ten anthropogenic categories. Of these categories, the combined “roads” category and combined “industrial” category prove to be the most influential. Salt River Site On January 8, 2002, at the Salt River site, the source contributions to the predicted PM10 concentration are led by industrial, roads, and trackout, which together account for 91% of the total, with roughly twice as much from the industrial as from the roads (Figure 6-7a). Attainment is shown for the January 8, 2002 exceedance at the Salt River monitor with a needed reduction of 22%, against a predicted reduction in ambient concentrations of 41%, about twice the needed amount. West 43rd Avenue Site On December 16, 2002, at the West 43rd Avenue site, the three sources still comprise 90% of the total. In this case, however, the roads have twice the impact as the industrial, and the trackout contribution has tripled from 6% to 19%. In both cases, the remaining 10% is construction dust and unpaved road shoulders (Figure 6-7b). Attainment is shown for the December 16, 2002 exceedance at the West 43rd Avenue site with a needed reduction of 27%, against a predicted reduction in ambient concentrations of 36%. Attainment for the low wind exceedances at the Salt River Site and the West 43rd Avenue Site is fairly easy because the emissions at these sites are dominated by road, trackout, and industrial sources, which decrease by roughly 7%, 80%, and 60%, respectively, from 2002 to 2006. Chapter 6 – 2006 Predicted Concentrations and Controls 6-34 1/8/02 Salt River AGRICULTURAL TILLAGE 0% TRACKOUT 6% CONSTRUCTION ACTIVITY 6% ROADS 28% INDUSTRIAL 57% UNPAVED ROAD SHOULDERS 3% UNPAVED PARKING LOTS 0% 12/16/02 West 43rd Avenue TRACKOUT 19% CONSTRUCTION ACTIVITY 3% INDUSTRIAL 25% UNPAVED ROAD SHOULDERS 6% ROADS 46% UNPAVED PARKING LOTS 1% Figures 6-7a (top) and b. Source contributions to PM10 for the two low-wind exceedances: the Salt River site exceedance of January 8, 2002 (174 µg/m3) and the West 43rd Avenue exceedance of December 16, 2002 (181 µg/m3). These figures show that reentrained dust from paved roads (“roads”) and industrial emissions comprise about 90% of the total (although their respective shares differ. The contribution from roads is twice that of industrial for the December exceedance but half of industrial for the January exceedance. Chapter 6 – 2006 Predicted Concentrations and Controls 6-35 6.5.4 Summary of Predicted Concentrations In the discussion of significant sources of PM10 in Section 6.3, the predicted concentrations for the 2002 base case were presented. In the preceding discussions of the eight exceedances events, the 2002 source contributions were presented. Attainment was expressed by comparing the overall emission reductions necessary to meet the 24-hour PM10 standard with percentage reductions by emission source category forthcoming from more stringent control measures. This set of controls and its accompanying concentrations can be termed the “2006 attainment case.” The 2006 attainment case is a projection of concentrations, divided into their emission source contributions, that would result from a combination of additional emission controls sufficient to show attainment. The emissions inventory discussion of Section 4.5 of Chapter 4 describes a “2006 base case.” This 2006 base case is an estimate of emissions in 2006 with neither no new control measures nor any strengthening of existing control measures, and taking into account projected land use changes and other emission source changes between 2002 and 2006. In Tables 6-13 and 6-14, the predicted concentrations for the 2006 base and attainment cases are presented. The following considerations should be kept in mind in understanding these tables. • Only unpaved parking lots and freeway emissions in these tables are insignificant. Other insignificant sources, omitted for clarity, are agricultural tillage, agricultural exhaust, and lawn and garden equipment emissions. • The predicted concentrations decrease from the 2002 to the 2006 base case, and from the 2006 base case to the 2006 attainment case for those emission source categories with anticipated reductions. • Background concentrations are lower in 2006 than in 2002. • The bottom line of the tables is the total predicted concentration for each event that resulted in exceedances in 2002. (SeeTable 6-8 for 2002 measured concentrations by source categories. • Note that in the 2006 base case, two of the 2002 exceedances are alleviated; in the 2006 attainment case, all eight are. • The number of source categories that meet the 5 µg/m3 significant threshold decreases from 45 to 35 to 25, for the 2002 base, the 2006 base, and the 2006 attainment cases, respectively. • In Table 6-14 the background is shown in two ways (See Section 6.2.2): with and without corrections for the irreducible portion. Normal background is uncorrected. Chapter 6 – 2006 Predicted Concentrations and Controls 6-36 TABLE 6-13 BASE CASE - Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 Source category 8-Jan 15-Apr 26-Apr 16-Dec SR DC SR WF DC SR WF WF Windblown Agricultural Windblown Alluvial Large Industrial Area Primary Roads Windblown Vacant Lots Windblown Industrial Windblown Disturbed Trackout Windblown Construction Windblown Stockpiles Unpaved Shoulders Secondary Roads Construction Industrial Point Sources Unpaved Parking Lots Freeway Sum of Contributions Background (2006) Background + Sum 5.23 1.58 12.35 37.22 3.58 0.94 7.65 19.25 11.40 3.75 1.17 26.65 7.29 9.17 0.00 17.51 0.21 2.70 18.00 2.37 8.46 2.78 29.65 8.42 23.99 0.67 35.87 4.37 2.34 0.05 6.22 5.23 6.73 0.48 14.06 3.46 1.64 1.61 34.86 1.24 4.04 11.80 2.70 15.76 7.76 0.05 29.65 7.27 3.56 0.33 4.37 2.31 1.71 1.06 2.65 2.88 4.35 5.38 1.87 0.67 1.72 0.88 2.82 13.36 0.37 1.35 0.65 3.21 10.88 1.59 1.37 3.25 3.04 9.27 0.00 1.31 0.33 3.12 6.70 0.00 0.72 0.38 0.62 1.35 0.00 0.30 0.35 0.05 6.56 7.40 2.48 1.49 0.19 0.47 106 67 173 1.05 0.27 88 82 170 0.05 0.30 83 82 165 0.03 0.09 116 82 198 1.02 0.40 83 67 150 0.06 0.31 123 67 190 0.00 0.08 55 67 122 0.56 0.75 116 66 182 55.37 28.04 6.79 Notes: This table is for the 2006 base case (i.e. no additional regulations or enforcement) Shaded concentrations exceed 5 µg/m3 and are, by definition, “significant.” Shaded concentrations in the bottom row exceed the 24-hour standard of 150 µg/m3. SR = Salt River Monitoring Site DC = Durango Complex Site WF = West 43rd Avenue Site Chapter 6 – 2006 Predicted Concentrations and Controls 6-37 27.49 47.92 21.33 TABLE 6-14 ATTAINMENT CASE - Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 Source category 8-Jan 15-Apr 26-Apr 16-Dec SR DC SR WF DC SR WF WF Windblown Agricultural Windblown Alluvial Large Industrial Area Primary Roads Windblown Vacant Lots Windblown Industrial Windblown Disturbed Trackout Windblown Construction Windblown Stockpiles Unpaved Shoulders Secondary Roads Construction Industrial Point Sources Unpaved Parking Lots Freeway Sum of Contributions Background Background + Sum Normal Background Irreducible Background Difference Difference + (Background + Sum) 5.23 1.03 4.94 32.80 2.37 0.94 4.98 7.70 10.04 2.48 1.17 17.36 2.92 8.08 0.00 17.51 0.14 1.08 15.86 1.57 8.46 1.81 11.86 7.42 15.88 0.67 23.36 1.75 2.06 0.03 1.55 4.88 1.35 0.48 3.52 3.23 0.33 1.61 8.71 1.16 0.81 11.80 0.67 14.71 1.55 0.05 7.41 6.79 0.71 0.33 1.09 2.16 0.34 1.06 2.65 2.68 3.90 4.46 0.84 0.67 1.60 0.79 2.34 6.01 0.37 1.26 0.58 2.66 4.90 1.59 1.27 2.91 2.53 4.17 0.00 1.22 0.30 2.59 3.02 0.00 0.67 0.34 0.52 0.61 0.00 0.28 0.31 0.04 6.56 6.89 2.22 1.23 0.17 0.47 63 67 130 0.94 0.27 62 82 144 0.05 0.30 46 82 128 0.03 0.09 65 82 147 0.91 0.40 63 67 130 0.05 0.31 66 67 133 0.00 0.08 34 67 101 0.50 0.75 76 66 142 67 67.3 0.3 82 86.6 4.6 82 86.6 4.6 82 86.6 4.6 67 70.8 3.8 67 70.8 3.8 67 70.8 3.8 66 66.6 0.6 130 149 133 152 134 136 105 142 22.15 24.71 1.36 Notes: This table is for the 2006 attainment case (i.e. additional regulations, controls, and enforcement). Shaded concentrations exceed 5 µg/m3 and are, by definition, “significant.” Shaded concentrations in the bottom row exceed the 24-hour standard of 150 µg/m3. SR = Salt River monitoring site DC = Durango Complex site WF = West 43rd Avenue site Chapter 6 – 2006 Predicted Concentrations and Controls 6-38 11.00 42.23 4.27 6.5.5 Attaining The PM10 Standard - Conclusions The PM10 monitoring record in the Salt River PM10 Study Area, which began in 1994, as well as the intensive monitoring work conducted in April – December 2002, clearly demonstrates that this portion of the Salt River airshed does not meet the 24-hour National Ambient Air Quality Standard for PM10. The construction of a complete emissions inventory, the development of a background concentration method, and the application of the most well used, Environmental Protection Agency dispersion model, Industrial Source Complex, have produced the results discussed in Section 6.5. These results have been presented in the form of realized versus necessary reductions to meet the standard, for each of the eight exceedances recorded during the 2002 intensive study period and thoroughly examined in the analyses. The results have also been presented as predicted concentrations in the preceding two tables. The realized reductions -- the predicted 2006 percentage reductions of the model-predicted PM10 concentrations from their 2002 concentrations – themselves depend on substantial emission reductions by 2006. These emission reductions include: • Earthmoving and related activities; • Industrial activities, principally materials handling and haul roads; • Additional street sweeping to reduce reentrained road dust; • Reduction of trackout by both sweeping and better regulatory efforts aimed chiefly at the industrial and construction facilities, • Continued retirement of agricultural land in the Salt River area (80% by 2006). Explained in detail in Chapter 4 and supplemented in Table 6-11, these emission reductions are essential to demonstrate attainment for all eight exceedances by 2006. Commitments will have to be obtained from Maricopa County and the cities and towns within the PM10 nonattainment area to amend rules, enforcement efforts, and work practices in such a way as to realize all of these potential emission reductions. With assertive efforts by these entities and the regulated communities, the emission reductions can be achieved by 2006. Considerable technical work has gone into a better understanding of the relationship between emissions and concentrations of PM10 in the Salt River PM10 Study Area. All of this work strongly suggests that if these emission reductions are forthcoming, the 24-hour PM10 standard will be achieved for both future low-wind and high-wind conditions in the Salt River PM10 Study Area. Chapter 6 – 2006 Predicted Concentrations and Controls 6-39 6.6 REFERENCES EPA, 1994: Federal Register Vol. 59, No. 157, 40 CFR Part 52 [FRL-5052-2] “State Implementation Plans for Serious PM-10 Nonattainment Areas, and Attainment Date Waivers for PM-10 Nonattainment Areas Generally; Addendum to the General Preamble for the Implementation of Title I of the Clean Air Act”, page 27, August 16, 1994 EPA, 2001: Federal Register Vol. 66, No. 191, 40CFR Part 52, [AZ0-92-002; FRL-70675], “Approval and Promulgation of Implementation Plans; Arizona -- Maricopa County PM-10 Nonattainment Area; Serious Area Plan for Attainment of the 24hour PM-10 Standard and Contingency Measures”, page 61, October 2, 2001 MAG, 2000: “Revised Technical Support Document for Regional PM10 Modeling in Support of the Revised MAG 1999 Serious Area Particulate Plan for PM10 for the Maricopa County Nonattainment Area”, February, 2000. URS & ERG, 2001: “Technical Support Document for Quantification of Agricultural Best Management Practices, Revised Final Draft”, page 4-1, Prepared for Arizona Department of Environmental Quality, ADEQ Contract No. 98-0159-BF, Task Assignment No. 00-0210-01. Chapter 6 – 2006 Predicted Concentrations and Controls 6-40 7.0 CHAPTER 7 - SALT RIVER PM10 ANALYSIS - CONCLUSIONS Following is a summary of ADEQ’s findings from the Salt River PM10 Monitoring, Emission Inventory, and Modeling Analyses: • PM10 concentrations in the Salt River Study Area have exceeded the 24hour average standard since monitoring began in 1994, with annual maxima ranging from 200 to 500 µg/m3, well above the standard of 150 µg/m3. • In response to a call for a revision to the State Implementation Plan, Arizona Department of Environmental Quality and Maricopa County Department of Environmental Services staff planned and carried out an extensive technical analysis of PM10 emissions, concentrations, and controls in a 4x8 mile area along the Salt River: from 10th Street on the east to 55th Avenue on the west, and from Baseline Road on the south to Van Buren Street on the north. • Intensive PM10 monitoring in 2002, with both continuous and filter-based instruments at four sites, revealed the following aspects of Salt River Study Area PM10 concentrations: • a. The diurnal variation is dominated by morning and evening peaks, with the former being greater than the latter except at the South Phoenix monitoring site. b. Monthly variation (May through December) varied by hour of the day, but for most hours and most sites, it was slight. c. Of the four sites, the Salt River site had the highest overall PM10 concentrations, followed closely by the West 43rd Avenue site and the Durango site, with South Phoenix a distant fourth. d. Eight exceedances of the 150 µg/m3 standard in 2002 were analyzed intensively, one in January, before the intensive study, and seven during the study. The highest recorded concentrations were in the 175 to 250 µg/m3 range. Background concentrations were determined based on continuous PM10 monitoring near the east and west boundaries of the Study Area, and were confirmed by an independent method based on the chemical composition of particulates. These background concentrations were about half of the measured concentrations within the Salt River PM10 Study Area. Chapter 7 – Salt River PM10 Analysis - Conclusions 7-1 • A thorough inventory of all emission sources within the Study Area was developed. Emissions were put into grids 400x400 meters, and were allocated to hours of the day consistent with the temporal variation of the activity. This inventory also included an in-depth accounting of all land surface types susceptible to erosion during high winds. Relying on satellite images, advanced digitizing techniques, and ground-truthing surveys, this land-surface characterization was exhaustive, thorough, and accurate as the technology allows. • A U. S. Environmental Protection Agency dispersion model called the “Industrial Source Complex” model was employed to simulate the measured PM10 concentrations for each of the exceedances. The model under predicted the measurements by 10 to 60%, but its results were still useful because they were used in a relative, not an absolute, sense. • Attainment of the standard in 2006 was evaluated for each exceedance. First, the necessary reduction to meet the standard was calculated from the value of the elevated PM10 concentration and the background. Second, the source-category emission decreases (or increases) from a set of control strategies were applied to the 2002 predicted concentrations. This step gave the 2006 predicted concentrations that reflected the various controls and land use changes. Third, the PM10 concentration in 2006 was compared with the 2002 concentration, the percentage decrease from the earlier to the later year was calculated, and this percentage was compared with the necessary percentage to meet the standard. Background concentrations were employed in this exercise, and 2006 background concentrations reflected the benefit of area-wide controls. • All eight exceedances could be shown to meet the standard in 2006, with a recommended set of control strategies. These strategies were increased street sweeping, more stringent controls on industrial sources, a variety of dust-reducing measures through a strengthened County dust rule (Rule 310), and expected land use changes such as the retirement of agricultural land. Regulatory commitments for this general type of controls will be sought, adopted and implemented by February 2005. . Chapter 7 – Salt River PM10 Analysis - Conclusions 7-2 APPENDIX A - MAPS Following are maps / satellite imagery that are referenced in the Salt River PM10 TSD: Map A-1 • Gridded satellite image with locations of the four air quality monitors Map A-2 • Land use map Map A-3 • Fugitive dust study Map A-4 • Locations of the 81 industrial sources (locations marked with a triangle) Map A-5 • Approximate boundaries of industrial sources, such as rock products, near the Salt River Map A-6 • Soil Stability in Salt River Alluvial Channel with Property Ownership Map A-7 • Modeling Grid Map A-8 • Modeling Grid with Satellite Image Map A-9 • 24-Hour PM10 Emissions - Primary Roads Map A-10 • 24-Hour PM10 Emissions – Secondary Roads Map A-11 • 24-Hour PM10 Emissions – Alluvial (Windblown) Appendix A - Maps A-1 Map A-12 • 24-Hour PM10 Emissions – Construction Map A-13 • 24-Hour PM10 Emissions – Construction (Windblown) Map A-14 • 24-Hour PM10 Emissions – Cleared Area (Windblown) Map A-15 • 24-Hour PM10 Emissions – Miscellaneous Disturbed (Windblown) Map A-16 • 24-Hour PM10 Emissions – Agriculture (Windblown) Map A-17 • 24-Hour PM10 Emissions – Trackout Map A-18 • 24-Hour PM10 Emissions – Unpaved Shoulders Map A-19 • 24-Hour PM10 Emissions – Vacant Lots (Windblown) Map A-20 • 24-Hour Total PM10 Emissions – Low Wind Day Map A-21 • 24-Hour Total PM10 Emissions – High Wind Day These maps are on the following pages. Appendix A - Maps A-2 Map A-1 Gridded satellite image with locations of air quality monitors Appendix A - Maps A-3 Map A-2 Land Use / Area Sources Appendix A - Maps A-4 Map A-3 Fugitive Dust Appendix A - Maps A-5 Map A-4 Locations of industrial sources Appendix A - Maps A-6 Map A-5 Approximate boundaries of industrial sources near Salt River Appendix A - Maps A-7 Map A-6 Soil Stability in Salt River Alluvial Channel with Property Ownership Appendix A - Maps A-8 Map A-7 Modeling Grid Appendix A - Maps A-9 Map A-8 Modeling Grid and Satellite Image Appendix A - Maps A-10 Map A-9 24-Hour PM10 Emissions – Primary Roads Appendix A - Maps A-11 Map A-10 24-Hour PM10 Emissions – Secondary Roads Appendix A - Maps A-12 Map A-11 24-Hour PM10 Emissions – Alluvial (Windblown) Appendix A - Maps A-13 Map A-12 24-Hour PM10 Emissions - Construction Appendix A - Maps A-14 Map A-13 24-Hour PM10 Emissions – Construction (Windblown) Appendix A - Maps A-15 Map A-14 24-Hour PM10 Emissions – Cleared Area (Windblown) Appendix A - Maps A-16 Map A-15 24-Hour PM10 Emissions – Miscellaneous Disturbed (Windblown) Appendix A - Maps A-17 Map A-16 24-Hour PM10 Emissions – Agriculture (Windblown) Appendix A - Maps A-18 Map A-17 24-Hour PM10 Emissions - Trackout Appendix A - Maps A-19 Map A-18 24-Hour PM10 Emissions – Unpaved Shoulders Appendix A - Maps A-20 Map A-19 24-Hour PM10 Emissions – Vacant Lots (Windblown) Appendix A - Maps A-21 Map A-20 24-Hour Total PM10 Emissions – Low Wind Day Appendix A - Maps A-22 Map A-21 24-Hour Total PM10 Emissions – High Wind Day Appendix A - Maps A-23 APPENDIX B - GLOSSARY OF TERMS Following are definitions of terms used in the Salt River PM10 TSD. Agricultural Tillage Agricultural tillage is defined as emissions from agricultural operations. The emissions in this category originate from agricultural tilling (land preparation, planting, weed control), and agricultural equipment exhaust. Construction Activity Construction activity is defined as construction of residential housing, businesses, and industrial buildings. The emissions in this category originate from earthmoving and to a lesser degree, construction equipment exhaust. Freeway Freeway emissions are defined as those emissions from vehicle traffic on the Durango Curve on Interstate 17. The emissions in this category originate from brake wear, tire wear, exhaust, and road dust reentrainment Industrial Sources Industrial sources are defined as facilities such as factories, power plants, and rock product operations that are permitted by the county or by the state. The emissions in this category originate from fuel burning, industrial processes, materials processing, construction equipment exhaust, and vehicle traffic over disturbed surfaces. Emissions from these sources are typically separated into four categories: 1) stack emissions, which are emissions that exit through stacks from combustion and materials processing and are specifically described in MCESD’s permit and/or emission survey for industrial sources (greater than 10 tons PM10 per year), 2) industrial area emissions, which are all other emissions from the facility, other than windblown, and includes material handling, crushing, screening, traffic on the facility, and the smaller stacks not listed in MCESD’s permits or survey forms, 3) windblown emissions from stockpiles, and 4) windblown emissions from the land surface of the facility. Industrial areas emissions have been further divided in to subcategories based on which MCESD rule applies to their operation, and into subcategories based on their nature (e.g., crushing and screening, haul road traffic, combustion, and so forth). Primary Roads Primary roads are defined as the major urban paved roads that are located at one-mile intervals. The emissions in this category originate from brake wear, tire wear, exhaust, and road dust reentrainment (road dust “kicked back” into the air from vehicles driving over it). Secondary Roads Secondary roads are defined as the minor urban paved roads that are located at halfmile intervals. The emissions in this category are the same as those in the primary roads category. Appendix B – Glossary of Terms B-1 Unpaved Parking Lots Unpaved parking lots are defined as parking lots, which have a gravel surface. The emissions in this category originate from reentrained dust from vehicle traffic in the unpaved parking lot. Unpaved Road Shoulders Unpaved road shoulders are defined as those road shoulders along paved roads that are not paved or stabilized. The emissions in this category originate from dust from the unpaved road shoulders being reentrained by the wake effect of large vehicles, such as large trucks and buses, traveling on the roadway. Wind Erosion Wind erosion is defined as the transport of disturbed / unconsolidated soil due to the movement of wind. Wind Erosion – Agricultural Agricultural land is defined as agricultural fields for growing crops. The emissions in this category originate from wind erosion of disturbed topsoil from agricultural fields in the time period between harvesting and when a crop is tall enough to act as a windbreak. Wind Erosion – Alluvial Channels Alluvial channels are defined as geological features such as dry streambeds, arroyos, and gullies, that are dry most of the year and contain loose soil, especially silt, due to water and wind erosion. The emissions in this category originate from wind erosion of material in the alluvial channel. Wind Erosion – Cleared Areas Cleared areas consist of vacant lots and miscellaneous disturbed areas. Vacant lots are defined as undeveloped land with disturbed topsoil that are in residential or business areas, and miscellaneous disturbed areas are defined as areas with disturbed topsoil that do not fall into the previously mentioned emission categories. The emissions in this category originate from wind erosion of disturbed topsoil. Wind Erosion – Construction Construction is defined as those areas that have disturbed topsoil due to construction activity (e.g., earthmoving). The emissions in this category originate from wind erosion of disturbed topsoil on construction sites. Appendix B – Glossary of Terms B-2 APPENDIX C - ADT BY GRID CELL The following table lists the average daily traffic counts and lengths of primary and secondary roads for each of the 630 grid cells in the Salt River PM10 Study Area. Source of data: City of Phoenix, Year 2001 Traffic Map and the lengths of the roads were from GIS analysis of a satellite image and a GIS road cover of the study area. Grid Cell Average Primary Secondary Grid Cell Average Primary Secondary Number Daily Roads Roads Number Daily Roads Roads Traffic (meters) (meters) Traffic (meters) (meters) 1 2767 200 70 1200 1299 2 4300 200 71 500 165 3 4300 200 72 4500 103 4 8500 600 73 4500 296 5 5300 200 77 1000 400 6 5300 200 79 500 768 7 5300 200 80 500 777 8 2767 600 81 10000 399 422 9 6100 200 82 500 34 10 6100 200 83 0 554 11 6100 200 84 1330 61 400 12 37687 599 303 85 13300 400 1992 13 7500 200 86 4500 2182 14 7500 200 87 20000 400 1942 15 7500 200 88 500 603 16 3167 200 89 16500 400 1098 17 8500 600 90 1200 1111 18 8500 200 91 2667 400 19 8500 200 92 3000 400 20 9500 200 93 3000 400 21 12800 600 378 94 3840 449 22 12800 200 454 95 7500 750 23 12800 200 104 96 4800 400 10 24 13133 600 737 97 5200 400 12 25 17500 200 1862 98 5200 573 13 26 17500 200 808 99 5100 626 902 27 23133 600 631 100 5100 400 1444 28 29400 200 101 5600 400 269 29 27300 600 844 102 5600 400 30 27300 200 1042 103 5500 799 31 2000 200 104 6400 400 34 10500 400 105 6400 400 38 1500 399 106 6400 400 42 4500 400 107 3850 800 47 1000 400 108 6700 400 49 8000 399 109 6700 400 400 50 1000 429 110 6700 400 72 51 10000 400 2074 111 12000 800 1284 52 6000 2241 112 13900 400 89 53 1000 598 113 13900 400 581 54 1000 153 736 114 13900 400 444 55 13300 247 1899 115 15050 800 1444 56 3000 1433 116 16800 400 1556 57 20000 400 1201 117 20800 800 650 58 600 1200 118 21600 400 205 59 16500 400 1665 119 19600 800 705 60 3600 1476 120 22700 400 1198 61 2000 200 121 3000 400 64 10500 399 124 13800 56 68 1500 400 10 125 13800 351 259 69 1200 984 126 0 352 Appendix C – Average Daily Traffic Table C-1 Grid Cell Average Number Daily Traffic 127 600 128 600 129 5100 130 6000 131 6000 132 1800 133 9500 137 3700 139 6000 140 2400 141 12500 142 600 143 3000 144 600 145 2000 146 1000 147 21600 148 1000 149 22700 150 3000 154 13800 155 0 156 0 157 159 2000 161 3600 162 4200 163 9500 167 4000 169 4200 170 6000 171 12500 172 300 173 6000 174 600 175 6000 176 10000 177 22600 178 600 179 19700 180 1000 184 13800 185 0 186 0 189 3000 190 0 191 3000 192 6000 193 9500 197 3700 200 3000 Primary Roads (meters) 406 405 404 403 402 402 401 400 400 400 400 400 400 400 401 400 373 400 400 Secondary Roads (meters) 368 332 2194 1200 2063 732 1848 1546 1618 418 1576 762 463 700 1161 2132 861 890 194 709 412 21 1751 2234 84 1895 2162 1292 800 2021 899 1251 2429 956 1087 811 1210 18 400 382 372 400 1349 1978 166 1439 Appendix C – Average Daily Traffic Table Grid Cell Average Number Daily Traffic 201 12500 202 6000 203 600 204 600 205 16400 206 1000 207 22600 208 600 209 19400 210 3000 214 13800 221 2400 222 3200 223 9500 224 10000 225 10000 226 10000 227 14700 228 14700 229 14700 230 14700 231 14500 232 16600 233 16600 234 16600 235 18300 236 18300 237 19700 238 19700 239 20000 240 20000 241 2000 242 1000 243 1000 244 13800 252 19100 253 19100 257 1000 261 19400 262 500 263 500 264 3600 265 20400 266 4800 267 19700 268 1000 269 21200 270 1800 271 2000 274 13800 282 19100 Primary Roads (meters) 400 400 400 400 401 128 400 800 400 400 400 800 400 400 400 800 400 400 400 800 401 800 400 800 400 600 401 411 766 71 330 152 400 400 400 400 200 400 400 Secondary Roads (meters) 1138 1600 1602 1621 2125 574 1099 1543 1391 1714 861 2122 271 276 770 1200 1389 1299 853 1111 1239 1342 958 794 187 400 1092 1266 1748 1258 1374 320 943 C-2 Grid Cell Average Number Daily Traffic 291 19400 293 0 294 600 295 20400 296 1000 297 24400 298 1000 299 21200 300 600 301 2000 304 13800 308 1000 312 19100 321 19400 323 0 325 20400 326 1000 327 24400 328 1000 329 21200 330 100 331 2000 334 13800 335 13800 338 5900 341 2000 342 10600 347 10800 351 19400 353 0 355 20400 357 24400 359 21200 361 4300 362 5100 363 5100 364 14400 365 7700 366 7700 367 7700 368 8300 369 11200 370 11200 371 11200 372 15400 373 10600 374 10600 375 10600 376 10600 377 83500 378 10800 Primary Roads (meters) 400 400 400 400 200 401 149 401 400 400 400 400 200 400 400 399 394 400 400 400 400 600 400 400 800 400 400 400 800 400 400 400 800 400 400 400 400 801 400 Secondary Roads (meters) 52 1027 1363 1719 1631 1627 413 1063 96 920 796 892 43 90 823 544 400 42 518 367 238 315 151 Appendix C – Average Daily Traffic Table Grid Cell Average Number Daily Traffic 379 92500 380 15000 381 25100 382 100 383 1000 384 1000 385 20400 387 24400 388 500 389 21200 390 1000 391 2000 394 19300 395 0 396 1000 397 0 398 12000 399 0 400 0 402 20000 403 1000 404 1000 405 1000 407 5900 409 7700 410 1000 411 25100 412 1000 413 1000 414 1000 415 19700 416 1000 417 24900 418 1000 419 28200 420 1000 421 3900 422 1000 424 19300 428 12000 430 1000 432 20000 433 7300 434 7300 435 7300 436 7300 437 7750 438 9600 439 1000 440 2000 441 20600 Primary Roads (meters) 199 400 418 604 400 400 200 400 400 400 400 603 400 501 1346 574 738 913 200 400 400 400 400 876 402 1318 Secondary Roads (meters) 327 302 800 668 1001 136 507 874 482 29 877 1172 67 21 385 400 323 738 410 591 754 137 588 1216 857 1294 1498 692 1100 525 300 166 138 747 22 683 1340 540 1285 400 925 1570 1451 1820 C-3 Grid Cell Average Number Daily Traffic 442 3000 443 3000 444 2000 445 19700 446 6000 447 24900 448 4200 449 28200 450 6000 451 3900 452 1000 453 1000 454 19300 458 12000 460 1000 462 20000 463 1000 464 3000 465 3000 466 3000 467 5900 468 4500 470 4500 471 20600 472 1200 473 1200 474 1200 475 19700 476 3000 477 24900 478 1000 479 28200 480 1800 481 16167 482 22300 483 22300 484 23800 485 21100 486 21100 487 21100 488 19100 489 27600 490 27600 491 27600 492 27300 493 29000 494 31000 495 31000 496 31000 497 22500 498 31600 Primary Roads (meters) 403 1140 1210 937 464 576 1105 307 200 400 400 400 400 803 400 400 401 400 600 400 401 800 400 400 400 800 400 400 401 400 800 400 400 399 800 400 Secondary Roads (meters) 2079 1731 1900 2952 1939 1689 2101 1724 2300 456 400 243 800 4 627 1163 1469 2129 2346 1572 1526 1142 2294 2449 1953 800 2298 1109 1163 754 1515 596 205 1669 293 266 1333 304 1274 1200 13 1742 Appendix C – Average Daily Traffic Table Grid Cell Average Number Daily Traffic 499 22500 500 22500 501 19000 502 16700 503 15000 504 15000 505 19100 506 16400 507 19100 508 17000 509 17000 510 17000 511 15100 512 1000 513 1000 514 1000 515 25200 519 18100 520 5400 521 3000 522 4500 523 26900 524 1000 525 1000 526 1000 527 13300 528 1000 529 1200 530 1200 531 21300 532 1200 533 1200 534 1200 535 21800 536 1000 537 21500 538 1000 539 28800 540 1000 541 15100 542 1000 543 1000 544 1000 545 25200 548 1000 549 18100 550 1000 551 1000 552 1000 553 26900 554 3000 Primary Roads (meters) 1200 401 911 399 400 400 801 400 803 400 801 400 200 188 213 400 400 400 800 400 404 401 401 200 401 400 400 Secondary Roads (meters) 1459 1375 1228 1862 1829 1806 1814 2786 1476 1609 1093 1604 1029 800 684 1952 1892 2379 1316 1031 1221 1097 18 1779 2298 2064 2001 2337 1973 2126 2246 2601 1675 2467 1451 1149 488 427 154 147 152 498 467 182 715 1635 C-4 Grid Cell Average Number Daily Traffic 555 1200 557 13300 558 1000 559 1000 560 1000 561 21300 562 1000 563 1000 564 1000 565 21800 566 1000 567 28800 568 28800 569 28800 570 28800 571 15100 572 1000 573 1000 574 1000 575 25200 576 1000 577 1000 578 1000 579 18100 580 1000 581 1000 582 1000 583 26900 584 3600 585 6000 586 6000 587 18000 588 12000 589 12000 590 12000 591 20000 592 21800 593 3000 594 1200 595 29100 596 20000 597 21500 598 20000 599 29200 600 20000 601 15500 602 15700 603 15700 604 15700 605 31000 606 20500 Primary Roads (meters) 399 800 400 400 400 400 200 401 400 400 400 800 400 401 401 400 600 400 400 400 800 400 Secondary Roads (meters) 426 866 642 1645 1603 1599 1389 1737 2153 1723 2286 1675 2766 1131 1279 1286 77 800 699 724 471 359 733 779 838 214 52 928 2297 2379 Grid Cell Average Number Daily Traffic 607 20500 608 20500 609 23000 610 27800 611 27800 612 27800 613 31000 614 28400 615 28400 616 28400 617 26000 618 26000 619 25200 620 25200 621 22550 622 20700 623 20700 624 20700 625 25000 626 21900 627 18800 628 23900 629 32900 630 29300 Primary Roads (meters) 400 400 800 400 400 400 800 400 400 400 800 400 1576 400 800 400 400 401 800 400 800 400 800 400 Secondary Roads (meters) 510 728 1056 837 1002 1405 517 1834 1309 1807 1081 945 1059 1488 1670 1811 1902 1893 1742 1600 1860 1568 841 1522 1558 2025 2378 2000 1417 1742 3042 2567 2400 2229 1750 2272 3124 2280 613 201 723 240 666 Appendix C – Average Daily Traffic Table C-5 APPENDIX D – TRACKOUT STUDY A study of trackout onto paved roads was conducted by ADEQ staff to determine silt loading and silt percentage from areas of a paved road with varying amounts of trackout. The study area was a section of 43rd Avenue that extended on the south from the start of paving on 43rd Avenue to the Lower Buckeye Road on the north. The dates of the study were September 29 and 30, 2003. This section of 43rd Avenue (south of Lower Buckeye Road) was selected for silt sampling due to it having the largest amount of trackout observed in the Salt River PM10 Study Area. Methodology The section of street to be sampled for trackout would first be blocked to traffic by a City of Phoenix sign truck. Following EPA silt sampling methodology, ADEQ staff marked the boundaries of the paved road that would be sampled. A clean, pre-weighed vacuum bag was installed in an electric vacuum cleaner (electricity from a portable generator). The road was sampled by vacuuming within the pre-defined sampling area from the edge of the road to the center of the road and then back to the edge of the road until all of the sampling site area been vacuumed. The vacuum bag would be removed and marked with a sample number. The other lane of the road would be sampled in a similar manner, giving two samples per sampling site. Then the sign truck and sampling equipment would be moved to the next sampling site and the sampling process would be repeated. The trackout samples were sent to an engineering laboratory for analysis of silt content. Sampling Sites Following is a description of the four sites that were used for collecting samples of trackout on 43rd Avenue. One pair of trackout samples were collected at each site – one sample from the northbound lane and one sample from the southbound lane of 43rd Avenue. The starting point (origin) for the sampling was the south end of 43rd Avenue (transition on 43rd Avenue from unpaved to paved road). Site #1 - This sampling site was located just north of GTI Capitol Holdings, LLC (a ready mix concrete and rock products company) on 43rd Avenue. A moderate amount of trackout was present on the northbound lane (Sample #1) and appeared to originate from GTI Capitol Holdings, LLC. A small amount of trackout was apparent on the southbound lane (Sample #2). See Figure D-1 and D-2 for photographs of the sampling site (approximately 455 feet north of the starting point). Site #2 - This sampling site was located north of the exit roadway from the Glenn Weinberger Company (a top soil and landfill company) on 43rd Avenue. An extreme amount of trackout was present on the northbound lane, Sample #3 (trackout was so heavy that the vacuum cleaner became overloaded and stopped working during the first sampling attempt at this site). Very little trackout was apparent on the southbound lane (Sample #4). See Figure D-3 for photograph of this sampling site (approximately 910 feet north of the starting point). Site #3 - This sampling site was located approximately 2,003 feet north of the starting point. A moderate amount of trackout was present on the northbound lane (Sample #5). Very little trackout was apparent on the southbound lane (Sample #6). See Figure D-4 for photograph of this sampling site. Site #4 – This sampling site was located approximately 2,840 feet north of the starting point. A moderate amount of trackout was present on the northbound lane (Sample #7). Very little trackout was apparent on the southbound lane (Sample #8). See Figure D-5 for photograph of the sampling site. Appendix D – Trackout Study D- 1 Figure D- 1. Sample #1 taken on northbound lane of 43rd Avenue at Elwood Street, 445 feet north of origin (area dimensions = 3 feet by 18 feet). Photo is looking west. Figure D-2. Sample #2 taken on south bound lane of 43rd Avenue at Elwood Street, 445 feet north of the origin (area dimensions = 6 feet by 18 feet). Photo is looking southwest. Appendix D – Trackout Study D- 2 Figure D-3. Sample #3 (above photo) taken on the northbound lane of 43rd Avenue, 910 feet north of origin (area dimensions = 2 feet by 18 feet). Sample #4 taken directly across (west) from Sample #3 on the southbound lane, just north of exit road from the dirt storage pile (area dimensions = 6 feet by 18 feet). Photo is looking northwest. Figure D-4. Sample #5 (above photo) was taken on the south bound lane, 2003 feet north of the origin (Area dimensions = 6 feet by 17 feet). Sample #6 was taken directly across (east) from Sample #5 on the north bound lane (Area dimensions = 3 feet by 18 feet). Photo is looking east. Appendix D – Trackout Study D- 3 Figure D-5. Sample #7 (above photo) was taken just south of Lower Buckeye Rd (note traffic light) on the northbound lane of 43rd Avenue, 2,840 feet north of the origin (area dimensions = 3 feet by 26 feet). Sample #8 was taken across (west) from sample #7 on the southbound lane (area dimensions = 6’ by 18’). Photo is looking east. Figure D-6. Example of trackout on exit road onto 43rd Avenue & Elwood Road, that is used by the Glenn Weinberger Company. Photo is looking east. Appendix D – Trackout Study D- 4 Results of Silt Analysis The eight trackout samples were sent to an engineering laboratory, Kleinfelder, for silt analysis. This analysis consisted of weighing a sample for total weight and then weighing the resulting fine material or silt that passed through a #200 mesh screen. See Figure D-7 for a copy of the silt analysis results from Kleinfelder. The silt loading value from sample #3 (northbound lane of Site #2) is much higher than any of the other samples due to the large buildup of trackout at this location which was quite deep and thus resulted in a large value of silt per unit area. However, not all of the silt at Site #2 may have been available for reentrainment, since only the top layer of the deep trackout was probably reentrained by vehicles driving over the trackout. Figure D-7. Sieve analysis results from eight trackout samples. Appendix D – Trackout Study D- 5 Table D-1 lists the percent silt and silt loading values for the eight trackout samples collected on 43rd Avenue south of Lower Buckeye Road. Sample # 1 2 3 4 6 5 7 8 Distance from Origin (feet) 455 455 910 910 2,003 2,003 2,840 2,840 Table D-1 – Silt Loading Percent Silt Silt Loading (g/m2) 12.0 11.2 7.8 3.3 7.1 54.3 14.1 1.3 11.8 8.8 8.8 0.4 10.6 7.9 9.8 0.5 Traffic Lane Northbound Southbound Northbound Southbound Northbound Southbound Northbound Southbound A comparison of the silt loading values in Table D-1 shows that Sample #3 has an extremely high silt loading of 54.3 grams/meter2. It was assumed that this value was an outlier due to the deep trackout that was present at the area of 43rd Avenue where Sample #3 was collected. Thus, the silt loading value for Sample #3 was not used. Based on the other values in Table D-1, the upper and lower limits of silt loading for trackout was set to 12 grams/meter2 as a maximum and 0.4 grams/meter2 as a minimum. Please note that the silt loading values listed for the southbound lane in Table D-1 most likely represent trackout that has migrated from the adjacent northbound lane that has heavier trackout loadings. Figure D-7 shows the relationship between percent silt in the trackout samples (northbound and southbound lanes) with increasing distance from the origin of the sampling on 43rd Avenue (southern end of 43rd Avenue where paving begins). Figure D-8 shows the relationship between silt loading in the trackout samples (northbound and southbound lanes) with increasing distance from the origin of the sampling on 43rd Avenue. Appendix D – Trackout Study D- 6 43rd Avenue Silt Percentage 16.0 14.0 12.0 Silt (%) 10.0 Northbound Southbound 8.0 6.0 4.0 2.0 0.0 0 500 1000 1500 2000 2500 3000 Distance (feet) . Figure D-7. Silt Percentage From Trackout on 43rd Avenue 43rd Avenue Silt Loading 60.0 Silt loading (grams/meter squared) 50.0 40.0 Northbound Southbound 30.0 20.0 10.0 0.0 0 500 1000 1500 2000 2500 3000 Distance (feet) Figure D-8. Silt Loading From Trackout on 43rd Avenue Appendix D – Trackout Study D- 7 Table D-2 lists the criteria used to derive the four classes of trackout and their associated silt loadings and emission factors. TABLE D-2 Trackout and Emission Factors Trackout Description Classification Class 1 Extreme Equivalent to heavy trackout found on 43rd Avenue south of Lower Buckeye Road Class 2 Equivalent to the trackout values Average recommended by ADOT. Emission factor is approximately 6X larger than the average primary road emission factor (Class 4 in this table) per ADOT guidance. Class 3 Equivalent to silt loading halfway between Minimum Class 2 value (3 g/m2) and Class 4 value (0.3 g/m2). Emission factor is also halfway between Class 2 value (12 g/VMT) and Class 4 value (2 g/VMT). Class 4 No trackout associated with this class. The No Trackout silt loading and emission factor are equivalent to average values for primary roads in study area. Silt Loading (g/m2) 8 – 11 Avg. = 9 3 Emission Factor (g/VMT) 29 1.65 7 0.3 2 12 Summary Based on the results of the ADEQ Trackout study, it appears that silt loading from areas with different amounts of trackout can range from a high of 11.2 grams/meter2 to a low of 0.4 grams/meter2, which results in emission factors that range from a high of 29 g/VMT to a low of 2 g/VMT. Appendix D – Trackout Study D- 8 APPENDIX E – ALLUVIAL CHANNEL STUDY ADEQ staff did a field survey of the portion of the Salt River Alluvial Channel between 35th Avenue and 51st Avenue in the Salt River PM10 Study Area during March 2004. The purpose of the study was to identify and quantify areas of the alluvial channel that have different soil stabilities and thus different wind erosion potential. Methodology ADEQ staff did a number of field surveys of the Salt River Alluvial Channel and identified the location and extent of three categories of areas with wind erosion potential. These categories were: (1) Maximum PM10 Emissions, (2) Moderate PM10 Emissions, and (3) Minimum PM10 Emissions based the soil stability and silt content of the areas. The locations of these areas were annotated on a printout of a satellite image (IKONOS, March 2002). Representative soil samples from the Maximum, Moderate, and Minimum PM10 Emissions areas were also collected and sent to an engineering laboratory for silt analysis. In the office, ADEQ GIS staff digitized the annotated satellite image printout and produced a new map showing the location and extent of the three wind erosion potential categories. Using the new map, ADEQ staff did an additional survey of the alluvial channel to verify that the categories had been correctly assigned. ADEQ GIS staff then calculated the surface area of the three wind erosion potential categories for each of the modeling grid cells that coincided with the Salt River Alluvial Channel. See Figure E-1 for map that shows the location of the areas with wind erosion potential with an overlay of the property ownership in that section of the Salt River Alluvial Channel. ADEQ staff assigned emission factors to the three wind erosion potential categories based on the surveys and results of the silt analysis of the Salt River alluvial channel. Following are the three categories and their emission factors: • Moderate (Average) PM10 Emissions – These areas were assigned the same AP-42 emission factor as that used for vacant lots and misc. disturbed areas (6.22 * 10-8 g / cm2 – sec). • Minimum PM10 Emissions - These areas were assigned an emission factor which was 1/2 the emission factor used for vacant lots and misc. disturbed areas (3.11 * 10-8 g / cm2 – sec). • Maximum PM10 Emissions – These areas were assigned an emission factor which was six times larger than the emission factor used for vacant lots and misc. disturbed areas. The rationale for the using a multiplier factor of six is that alluvial soils act as almost an infinite source of particulates for wind erosion, whereas other soil types typically stop producing PM10 emissions after about one hour of wind erosion. In addition, alluvial soils have a larger silt content and a lower wind speed threshold for wind erosion which leads to higher production of PM10 emissions (37.32 * 10-8 g / cm2 – sec) Summary The Salt River Alluvial Channel Study identified three types of areas in the Salt River Alluvial Channel that have wind erosion potential ranging from maximum PM10 emissions to minimum PM10 emissions. The areas that had a potential for high PM10 emissions from wind erosion generally had a high silt content and very loose soil (little plant cover or rocks). The areas that had a potential for low PM10 emissions generally had a lower silt content and the surface was partially stabilized by plants, rocks, or gravel. Appendix E – Alluvial Channel Study E-1 Figure E- 1 Soil Stability in Salt River Alluvial Channel With Property Ownership Appendix E – Alluvial Channel Study E-2 APPENDIX F - AGRICULTURAL HARVEST AND TILLAGE Estimation of PM10 Emissions from Agricultural Tillage and Harvest in Salt River PM10 Study Area Following is a description of the methods and data used to estimate PM10 emissions from agricultural tillage (land preparation) and harvest activities, and wind erosion of agricultural land in the Salt River PM10 Study Area. Identification of Crops The types of crops and the locations of the fields in the Salt River PM10 Study area were identified through a number of steps: 1. Field surveys – ADEQ staff located agricultural fields and identified some of the crop types using printouts of a gridded satellite image (IKONOS, Date: March, 2002) of the Salt River PM10 Study Area. 2. May 21, 2003 Meeting - Maricopa County Farm Bureau and University of Arizona Cooperative Extension Service staff provided ADEQ with detailed information on the crops that were present in the study area during ADEQ’s =Year 2002 PM10 intensive monitoring study. 3. Digitizing – ADEQ staff digitized the following crop areas on the gridded satellite image of the Salt River PM10 Study Area based on the field surveys done by ADEQ staff (see Figure F-1): $ Corn (Haylage) $ Corn / Developing / Developed $ Cotton $ Oats (Haylage) $ Pasture / Corn / Milo $ Pasture / Alfalfa $ Alfalfa / Oats $ Vegetables $ Alfalfa $ Bermuda Grass $ Nursery / Greenhouse $ Pasture Crop types such as APasture / Corn / Milo@ denote a transition in crops. For example, the fields started as out as pasture, then was planted in corn, and then milo during the study period. GIS was used to calculate the area (square meters) of each of the above crop types in each grid cell of the Salt River PM10 Study Area. Appendix F – Agricultural Tillage and Harvest F-1 Figure F-1 Agricultural Crops in Salt River PM10 Study Area Appendix F – Agricultural Tillage and Harvest F-2 Crop Calendar A crop calendar (see Table F-1) was developed to show the time period that agricultural tillage and harvesting occurred in the Salt River PM10 Study Area. The calendar was based: $ May 21, 2003 meeting with Maricopa County Farm Bureau, and University of Arizona Cooperative Extension Service. $ July 1, 2003 phone call with Maricopa County Farm Bureau $ June 11, 24, 26 and July 1, 2003 phone calls with Patrick Clay $ ADEQ’s analysis of quarterly aerial photography books for Year 2002 (AThe Aerial Photo Book@, Rupp Aerial Photography, 4811 North 7th Street, Phoenix, AZ 85014, Phone: 602277-0439) to define the months when the land use transition occurred in the ACorn / Developing / Developed@ category. $ University of Arizona Cooperative Extension Service website on crop budgets (http://www.ag.arizona.edu/arec/ext/budgets/Maricopa-map.html) Agricultural Tillage and Harvest Days The design days selected by ADEQ for modeling ambient PM10 concentrations in the Salt River PM10 Study Area were compared to the previously mentioned crop calendar (Table F-1) to determine which design days may have had agricultural tillage and / or agricultural harvest activity. Following are the design days that were compared to the crop calendar: $ Primary Design Days $ January 8, 2002 $ April 15, 2002 (high wind day) $ April 26, 2002 (high wind day) $ December 16, 2002 $ Optional Design Days $ May 9, 2002 $ June 25, 2002 $ July 2, 2002 $ August 26, 2002 $ November 9, 2002 $ November 22, 2002 After reviewing the crop calendar, it was found that January 8, 2002 was the only design day that had a potential for agricultural tillage activity. The crops that may have had tillage activity for this design day were corn (haylage) and cotton. Also after reviewing the crop calendar, it was found that four design days had a potential for agricultural harvest activity: May 9, 2002, July 2, 2002, November 9, 2002 and November 22, 2002. The crops that may have been harvested on these four days were cotton, corn, oats, milo. Appendix F – Agricultural Tillage and Harvest F-3 Table F-1 Year 2002 Crop Calendar for Salt River PM10 Study Area Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Corn (Haylage) Corn / Developing/Developed Cotton Oats (Haylage) Pasture/Corn/Milo Pasture/Alfalfa Alfalfa/Oats Vegetables Alfalfa Bermuda Grass Nursery/Greenhouse Pasture Design Days (red = high wind day) 1/8/03 Tilling = 12/16/02 5/9/02 Design Days – Optional Legend: 4/15/02 4/26/02 6/25/02 7/2/02 8/26/02 11/9/02 11/22/02 Source of Data: o May 21, 2003 Meeting with Maricopa County Farm Bureau and U of A Cooperative Extension, July 1, 2003 call o June 11, 24, 26, July 1, and December 10, 2003 Phone Calls with U of A Cooperative Extension Note: Wind erosion during planting months is reduced due to irrigation keeping topsoil moist. Harvesting crop as haylage produces minimal emissions since crop is harvested green. May not landplane every year. Planting = Appendix F – Agricultural Tillage and Harvest Crop in Field = Harvest = F-4 Percent Tilling Activity on Design Day According to the University of Arizona Cooperative Extension Service, tilling for corn typically occurs from the months of January through February, while tilling for cotton typically occurs from January through March. The potential percent tilling activity for the January 8, 2002 design day was calculated following the methodology in the URS and ERG report (ATechnical Support Document for Quantification of Agricultural Best Management Practices@, Prepared for Arizona Department of Environmental Quality, ADEQ Contract No. 98-0159-BF, Task Assignment No. 00-0210-01, June 8, 2001. Prepared by URS Corporation, 10389 Old Placerville Road, Sacramento, CA 95827 and Eastern Research Group, Inc., 8950 Cal Center Drive, Suite 260, Sacramento, CA 95826-3259). Paula Fields= methodology assumes that the tilling activity over a given period (e.g., two months for corn and three months for cotton) follows a normal distribution with activity levels peaking towards the middle of the tilling period. A summary of the methodology: 1. The tilling period for each specific crop (in this case, corn and cotton) was divided into 5 segments following the normal distribution curve convention. 2. Each segment was then assigned the number of days in the tilling period according to its percentage of the normal curve. 3. The corresponding calendar days were assigned to each of the five segments for each crop type. 4. Percent tilling activity for each segment was assumed to be:: $ Segment 1 = 10% $ Segment 2 = 20% $ Segment 3 = 40% $ Segment 4 = 20% $ Segment 5 = 10% 5. Percent tilling activity per day was calculated by dividing the percent tilling activity per segment (step #4) by the number of tilling days per segment (step #2). 6. The percent tilling activity for a design day was found from the appropriate segment for the design day (e.g., segment #1 for corn is from January 1 - January 10. January 8 is thus in segment #1). Following the above methodology, the percent tilling activity for the January 8, 2002 design day was 1% for both corn (haylage) and cotton. Table F-2 lists the calculations used to determine the percent tilling activity per day for corn (haylage) and cotton. Appendix F – Agricultural Tillage and Harvest F-5 Table F-2 Agriculture Tilling Days in Salt River PM10 Study Area A CORN (Tilled from Jan - Feb): B C Tilling Activity Percent (Bell Curve)* Segment 1 2 3 4 5 D Tilling Jan - Feb Total Days 17% 11% 44% 11% 17% E Tilling Days Per Segment (B * C) 59 59 59 59 59 Tilling Calendar Days Per Segment 10 6 26 6 10 Jan 1 - Jan 10 Jan 11 - Jan 16 Jan 17 - Feb 12 Feb 13 - Feb 18 Feb 19 - Feb 28 F Tilling Activity Per Segment* Segment 1 2 3 4 5 Tilling Jan - Feb Total Days 17% 11% 44% 11% 17% Tilling Days Per Segment (B * C) 90 90 90 90 90 Tilling Calendar Days Per Segment 15 10 40 10 15 Jan 1 - Jan 15 Jan 16 - Jan 25 Jan 26 - Mar 6 Mar 7 - Mar 16 Mar 17 - Mar 31 H Percent Percent Tilling Activity Per Day (F / D) Tilling Activity On Jan. 8 Design Day 10% 20% 40% 20% 10% COTTON (Tilled from Jan - March): Tilling Activity Percent (Bell Curve)* G Tilling Activity Per Segment* 10% 20% 40% 20% 10% 1% 3% 2% 3% 1% 1% N/A N/A N/A N/A Percent Percent Tilling Activity Per Day (F / D) Tilling Activity On Jan. 8 Design Day 1% 2% 1% 2% 1% 1% N/A N/A N/A N/A Notes: * Distribution of Tilling Activity from U of A Cooperative Extension Service as listed in Agricultural BMP Technical Support Document, URS and ERG, under contract to ADEQ, June 8, 2001 Appendix F – Agricultural Tillage and Harvest F-6 Wind Erosion from Agriculture The three design days (total design days = 10) classified as high wind days were compared to the crop calendar (Table F-1) to determine which of these days have a potential for wind erosion of agricultural land and for which crops. The April 15, 2002 and April 26, 2002 design days have a potential for wind erosion of agricultural fields with corn (haylage), cotton, and vegetables. While, the November 9, 2002 design day has a potential for wind erosion of agricultural fields with oats. ADEQ input the gridded agricultural land subject to wind erosion to GRIDTEST (in-house emissions processor) to produce an input file for this category to the ISC model. Agricultural fields are considered to be vulnerable to wind erosion when the topsoil has been disturbed (e.g., by tilling) and before the crop is tall enough to shield the soil from wind. However, Irrigation and the development of a crust on the soil (in the Salt River PM10 Study Area) during the month a crop is planted will reduce wind erosion. The fields for some crops are tilled after harvest, while other crops are not tilled until shortly before planting. This is reflected in the crop calendar. University of Arizona Cooperative Extension Service provided the information on the typical months for wind erosion for the crops present in the Salt River PM10 Study Area. Design Day PM10 Emissions from Ag Tillage 1. Emission Factor: Tillage emissions for the January 8, 2002 design day were calculated using the tillage emission factor equation listed in Section 9.1 of U. S. EPA=s AP-42 report (U.S. EPA, 1995): EF = k (4.8) s0.6 Where: EF k s = = = agricultural emission tillage factor (lbs PM10 / acre-pass) particle size multiplier (value of 0.15 for PM10) silt content of soil (percent) Assume: s = 35.2% (URS, 2001) = 0.15 Then: EF x 4.8 x (35.2)0.6 Appendix F – Agricultural Tillage and Harvest = 6.10 lbs PM10 / acre-pass F-7 2. Design Day PM10 Emissions TillageCrop = EF x APCrop x ACrop Where: TillageCrop EF APCrop ACrop AFCrop = = = = = x AFCrop tillage emissions for a specific crop type (lbs PM10) tillage emission factor (lbs PM10 / acre-pass) number of tillage passes per crop (passes) surface area of tilled land for a specific crop type (acres) fraction of annual tillage activity occurring on design day Assume for Cotton: EF APCrop = = ACrop AFCrop = = 6.10 lbs PM10 / acre-pass 7 tillage passes (laser level, rip, disk, landplane, incorporate herbicide / disk, list, mulch from URS, 2001) acres of cotton fields per grid cell of modeling domain 0.01 (for January 8, 2002 design day) Then PM10 emissions for tillage of cotton for the January 8, 2002 Design Day for each grid cell in the Salt River PM10 Study Area would be calculated using the following equation: TillageCotton = = 6.10 lbs PM10 / acre-pass x 7 passes x ACrop x 0.01 0.427 lbs PM10 / acre of cotton Converting to metric : 0.427 lbs PM10 / acre x 453.6 grams / lb x 1 acre / 4047 sq. meter = 0.0479 g PM10 / sq. meter of cotton field Assume for Corn (haylage): EF APCrop = = ACrop AFCrop = = 6.10 lbs PM10 / acre-pass 5 tillage passes (laser level, rip, disk, landplane, incorporate herbicide / disk, from URS, 2001) acres of corn (haylage) fields per grid cell of modeling domain 0.01 (for January 8, 2002 design day) Then PM10 emissions for tillage of corn (haylage) for the January 8, 2002 Design Day for each grid cell in the Salt River PM10 Study Area would be calculated using the following equation: TillageCorn = 6.10 lbs PM10 / acre-pass x 5 passes x ACrop x 0.01 = 0.305 lbs PM10 / acre of corn (haylage) Converting to metric : 0.305 lbs PM10 / acre x 453.6 grams / lb x 1 acre / 4047 sq. meter = 0.0342 g PM10 / sq. meter of corn field Appendix F – Agricultural Tillage and Harvest F-8 Design Day PM10 Emissions from Ag Tillage with Ag BMPs The PM10 tillage emission factors calculated in the previous section for the January 8, 2002 design day do not take into account the emissions reductions from the recent implementation of the general permit for agricultural best management practices which includes control measures for agricultural tillage [The Arizona Administrative Register (A.A.R), Title 18, Chapter 2, '609-611 contains the rulemaking for the "Agricultural PM10 General Permit."]. Three agricultural best management practices are listed in the Agricultural PM10 General Permit for tillage with quantifiable PM10 emission reductions: C Combining Tractor Operations - midpoint control efficiency of 7.9% C Limited Activity During High Wind Events - midpoint control efficiency of 9.3% C Multi-Year Crops - midpoint control efficiency of 15.8% The ACombining Tractor Operations@ best management practice was selected for the January 8, 2002 design day because this design day was not considered a high wind event and for the time period of the monitoring study, fields with multi-year crops had already been identified Following are the design day tillage emission factors for cotton and corn (haylage) after accounting for the potential emission reductions from farmers selecting the Combining Tractor Operations best management practice (Ag BMP) for their cotton and corn fields. Cotton Tillage Emissions after using Combining Tractor Operations Ag BMP: TillageCotton & BMP = 0.0479 g PM10 / sq. meter of cotton field x (100% - 7.9%) = 0.0442 g PM10 / sq. meter of cotton field Corn (Haylage) Tillage Emissions after using Combining Tractor Operations Ag BMP: TillageCorn & BMP = 0.0342 g PM10 / sq. meter of corn field x (100% - 7.9%) = 0.0315 g PM10 / sq. meter of corn (haylage) field ADEQ used the above tillage emission factors for cotton and corn (haylage) that account for the emission reductions from the Combining Tractor Operations Ag BMP in GRIDTEST (in-house emissions processor) along with data on the spatial extent of cotton and corn fields by individual grid cells of the Salt River PM10 Study Area to produce an input file of gridded and temporally allocated agricultural tillage PM10 emissions for the ISC model. The total amount of cotton and corn in the Salt River PM10 Study Area that was tilled on the January 8, 2002 design day were 1,769,600 m2 of cotton and 856,000 m2 of corn (haylage). Appendix F – Agricultural Tillage and Harvest F-9 Design Day PM10 Emissions from Harvesting After reviewing the crop calendar, it was found that the four optional design days, May 9, 2002, July 2, 2002, November 9, 2002 and November 22, 2002, may have had harvest activity for cotton, corn (haylage), oats (haylage), and milo (haylage) in the Salt River PM10 Study Area. However, harvest emissions from crops grown for haylage (in this case, corn, milo, and oats) are considered negligible since these crops are harvested green for haylage (Fish and Clay, 2003) and thus will not be considered as a PM10 source. Following is discussion of the calculations used to estimate PM10 emissions from cotton harvesting. Cotton harvest emissions for the two design day were calculated using the harvest emission factor developed by the Air Resource Board (ARB, 1997), 1.12 lbs PM10 / acre. It should be noted that a recent ARB draft report lists the cotton harvest emission factor as 3.41 lbs PM10 / acre. Following is the equation used to calculate cotton harvest emissions for the two design days HarvestCrop = EF x ACrop x AFCrop Where: HarvestCrop EF ACrop AFCrop = = = = harvest emissions for a specific crop type (lbs PM10) harvest emission factor (lbs PM10 / acre-pass) surface area of harvested land for a specific crop type (acres) fraction of annual tillage activity occurring on design day Assume for Cotton: EF ACrop AFCrop = = = 1.12 lbs PM10 / acre acres of cotton fields per grid cell of modeling domain 0.010 (based on 99 harvest days per year for cotton. 1 design day / 99 days = 0.01) Then PM10 emissions for harvest of cotton for the November 9 and 22, 2002 Design Day for each grid cell in the Salt River PM10 Study Area would be calculated using the following equation: HarvestCotton = = 1.12 lbs PM10 / acre x ACrop x 0.01 0.0112 lbs PM10 / acre of cotton Converting to metric: 0.0112 lbs PM10 / acre x 453.6 grams / lb x 1 acre / 4047 sq. meter = 0.00126 g PM10 / sq. meter of cotton field Appendix F – Agricultural Tillage and Harvest F-10 Design Day PM10 Emissions from Ag Harvesting with Ag BMPs The PM10 cotton harvest emission factors calculated in the previous section for the November 9 and 22, 2002 design days do not take into account the emissions reductions from the recent implementation of the general permit for agricultural best management practices which includes control measures for agricultural harvest [The Arizona Administrative Register (A.A.R), Title 18, Chapter 2, '609-611 contains the rulemaking for the "Agricultural PM10 General Permit."]. Two agricultural best management practices are listed in the Agricultural PM10 General Permit for agricultural harvesting with quantifiable PM10 emission reductions (URS, 2001): C Combining Tractor Operations - midpoint control efficiency of 17% C Reduced Harvest Activity - midpoint control efficiency of 20% The ACombining Tractor Operations@ best management practice was selected for the November 9 and 22, 2002 design days to be consistent with the previous Ag BMP selected for the section on tilling emissions and that this BMP has a higher probability of being used by farmers than the reduced harvest activity BMP which entails a larger change to standard farming practices. Following is the design day emission factor for cotton harvesting that accounts for potential emission reductions from farmers selecting the Combining Tractor Operations best management practice for their cotton fields. Cotton Harvesting Emissions after using Combining Tractor Operations Ag BMP: HarvestCotton & BMP = 0.00126 g PM10 / sq. meter of cotton field x (100% - 17%) = 0.00105 g PM10 / sq. meter of cotton field ADEQ used the above emission factor for cotton harvesting that accounts for the emission reductions from the Combining Tractor Operations Ag BMP in GRIDTEST (in-house emissions processor) along with data on the spatial extent of cotton fields by individual grid cells of the Salt River PM10 Study Area to produce an input file of gridded and temporally allocated agricultural harvesting PM10 emissions for the ISC model. Reduction in Agricultural Land by Year 2006 The Maricopa County Farm Bureau estimates that about eighty percent of agricultural land in the Salt River PM10 Study area will be replaced by residential and commercial uses between Year 2002 and 2006. This figure was corroborated by ADEQ’s analysis of the amount of agricultural land that was converted between March 2002 and December 2002. See Table F-3 for details of this analysis which involved satellite image analysis of March 2002 agricultural land and a field trip on December 12, 2003 to determine conversion of agricultural land. Appendix F – Agricultural Tillage and Harvest F-11 Summary Of the ten design days selected by the Evaluation Unit, following are the design days that have either potential agricultural tillage or harvesting activity in the Salt River PM10 Study Area: $ January 8, 2002 - agricultural tillage activity $ November 9, 2002 - harvesting activity $ November 22, 2002 - harvesting activity The following PM10 emission equations were used in GRIDTEST, ADEQ=s in-house emissions processor, to produce a file of gridded temporally allocated PM10 emissions for agricultural tillage and harvest activity in the Salt River PM10 Study Area. It was assumed that these activities would be during daylight hours and average 8 hours per day (URS, 2001). 1. Cotton Tillage PM10 Emissions after using Combining Tractor Operations Ag BMP: TillageCotton & BMP = 0.0442 grams PM10 / square meter of cotton field 2. Corn (Haylage) Tillage PM10 Emissions after using Combining Tractor Operations Ag BMP: TillageCorn & BMP = 3. 0.0315 grams PM10 / square meter of corn (haylage) field Cotton Harvesting PM10 Emissions after using Combining Tractor Operations Ag BMP: HarvestCotton & BMP = 0.00105 grams PM10 / square meter of cotton field Appendix F – Agricultural Tillage and Harvest F-12 Table F-3 Conversion of Agricultural Land to Residential and Commercial Uses Year 2002 North of Salt River Ag Land (Square Meters) 5,161,678 Year 2002 South of Salt River Ag Land (Square Meters) 9,144,532 Year 2002 Total Year 2003 Total Salt River Total Ag Land (Square Meters) 14,306,210 Salt River Total Ag Land (Square Meters) 9,506,210 Year 2003 North of Salt River Ag Land (Square Meters) 4,734,478 Year 2003 South of Salt River Ag Land (Square Meters) 4,771,732 Year 2002 – 2003 Year 2002 – 2003 Change Change Salt River Land Change Salt River % Change Ag Land Ag Land (Square Meters) (% Annual Change) 4,800,000 0.335519 (33.6%) TREND IN CONVERSION OF AG LAND BETWEEN YEAR 2002 TO YEAR 2006: (Conversion of area north of Salt River is predominantly industrial and area south of Salt River is predominantly residential) Year 2002 Salt River Total Ag Land (Square Meters) 14,306,210 Year 2003 Salt River Total Ag Land (Square Meters) 9,506,210 Year 2004 Salt River Total Ag Land (Square Meters) 6,316,699 Year 2005 Salt River Total Ag Land (Square Meters) 4,197,329 Year 2006 Salt River Total Ag Land (Square Meters) 2,789,047 Total Percent Conversion of Ag Land to Residential / Commercial between Years 2002 and 2006 = -80.5% Sources of Data: • Year 2002 surface area of agricultural land from March 2002 IKONOS satellite image digitized by ADEQ • Year 2003 surface area of agricultural land from December 12, 2003 field trip by ADEQ Methodology for Calculating Agricultural Land Conversion: • The amount of agricultural land in the Salt River PM10 Study Area was determined for Years 2002 and 2003 through satellite image analysis, field surveys, and discussions with Maricopa County Farm Bureau and University of Arizona Cooperative Extension Service staff. • Based on the Year 2002 and 2003 data, it was calculated that the projected annual decrease in agricultural land was 33.6%. This decrease was due to conversion of agricultural land to residential and commercial uses. • The 33.6% decrease was applied to the amount of agricultural land in subsequent years (Years 2003, 2004 and 2005) to estimate the amount of agricultural land in Year 2006 (note, if a fixed acreage decrease of 4,800,000 square meters was subtracted per year, the acreage would become negative by 2005). • Example: Projected Year 2004 agricultural land = Year 2003 agricultural land x (1 – 0.335519) = 9,506,210 meter2 X 0.664481 = 6,316,699 meter2 Appendix F – Agricultural Tillage and Harvest F-13 References ARB, 1997. Methods for Assessing Area Source Emissions. California Environmental Protection Agency, Air Resources Board. October Arizona Agricultural Statistics Service, 2001. 2001 Arizona Agricultural Statistics Bulletin, July 2002. (http://www.nass.usda.gov/az/) Fish and Clay, 2003. Meeting with Jeannette Fish, Maricopa County Farm Bureau, and Patrick Clay, University of Arizona Cooperative Extension, with Randy Sedlacek, Phil DeNee, Darlene Jenkins, ADEQ. May 21, 2003. URS and ERG. Technical Support Document for Quantification of Agricultural Best Management Practices. June 18, 2001, 2001. Prepared for Arizona Department of Environmental Quality, ADEQ Contract No. 98-0159-BF, Task Assignment No. 00-0210-01. J:\AQD\ASSESS\Special Application Unit\Salt River PM10 study area\Ag Tillage & Harvest\Ag Tilling & Harvest Documentation.wpd Appendix F – Agricultural Tillage and Harvest F-14 APPENDIX G – INDUSTRIAL AREA AND POINT SOURCES OVERVIEW The industrial sources listed in MCESD=s Year 2001 database for the Salt River PM10 Study Area were separated into sources that would be modeled as industrial point sources and industrial area sources. Following are the Arules@ used to select whether an industrial source in the Salt River PM10 Study Area would be characterized as a point source or an area source: 1) Salt River industrial sources size-ranked from 1 - 31 will be treated as point sources (#1 having the largest PM10 emissions) except for sources #17, 20, 23, 26 which will be treated as area sources due to the large distance between these sources and the four PM10 monitors. 2) All sources within a 3 x 3 grid around each of the four air quality monitors in the Salt River PM10 Study Area will be treated as a point source (grid cell = 400 meters x 400 meters). 3) The remaining industrial sources not classified as a point source in above rules #1 and #2 will be treated as an area source and their emissions will be added to the grid cell that the source is located. Based on rules 1 - 3, the following thirty-one sources were initially selected to be modeled as industrial point sources: $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ APS WEST PHX POWER PLANT UNITED METRO PLANT #11 PHOENIX BRICK YARD METAL MANAGEMENT ARIZONA INC VULCAN MATERIALS CO-WESTERN THE PROCTER & GAMBLE MFG CO TRENDWOOD INC BUILDING PRODUCTS CO HANSON AGGREGATES OF ARIZONA VAW OF AMERICA INC GTI CAPITAL HOLDINGS LLC WESTERN ORGANICS INC TPAC A DIVISION OF KIEWIT WESTERN CO SOUTH MOUNTAIN GIN CORESLAB STRUCTURES (ARIZ) INC AMERON INTL-WATER TRANSMISSION GROUP OLSON PRECAST OF ARIZONA INC AJAX SAND & ROCK PHOENIX CEMENT TERMINAL SANDVICK EQUIPMENT & SUPPLY CO CITY OF PHOENIX 27TH AVE LANDFILL SCHUFF STEEL CO QUALITY BLOCK INC MARLAM INDUSTRIES INC MONIER LIFETILE LLC ROAD MACHINERY CO INC CHEVRON USA ASPHALT DIVISION Appendix G – Industrial Point and Area Sources G-1 ATC PHOENIX CITY OF PHOENIX WASTE WATER TREATMENT PLANT UNIVERSAL ENTECH U.S. GREEN FIBER $ $ $ $ 3 x 3 GRID ANALYSIS Following is a discussion of the methodology used to determine which industrial sources were located in a 3 x 3 grid (based on modeling grid developed for Salt River PM10 Study Area with each grid cell 400 meter x 400 meter in size). ADEQ did site visits and analysis of printouts of the satellite image of the Salt River PM10 Study Area to determine the industrial sources that are located within the area bounded by a 3 x 3 grid (400 x 400 meter grid cells) area around each of the four PM10 monitors. The following tables (Tables G-1 through G-4) list, by air quality monitor, the ID number of the grid cells included in the 3 x 3 grids and the industrial sources located within the 3 x 3 grid areas. TABLE G-1 Durango PM10 Monitor Grid Cell ID # Industrial Source Comments Include in Point Source Category? (Yes / No) 375 Phoenix 27th Avenue Landfill Already included as a point source based on 1 - 31 size ranking. MCESD lists it has having emissions, However, Dan notes that the landfill has been capped and should have negligible PM10 emissions. Yes 376 Phoenix 27th Avenue Landfill A Yes 377 Western Organics Street address is listed as being in grid cell 377. In reality, their operations are located within grid cell 316, 346 or 347 (outside the area of interest). 405 No industrial sources No 406 No industrial sources No 407 No industrial sources No 435 No industrial sources No 436 No industrial sources No 437 No industrial sources No Appendix G – Industrial Point and Area Sources @ No G-2 Table G-2 Salt River PM10 Monitor Grid Cell ID # Industrial Source Comments Include in Point Source Category? (Yes / No) 318 No industrial sources No 319 No industrial sources No 320 T-Pac Prestressed Concrete Manufacturing 348 No industrial sources No 349 No industrial sources No 350 Chevron USA Asphalt Division T-Pac Prestressed Concrete Manufacturing Yes Already included as a point source based on 1 - 31 size ranking Yes Yes Already included as a point source based on 1 - 31 size ranking 378 City of Phoenix Waste Water Treatment Plan Yes 379 ATC Phoenix Yes 380 T-Pac Prestressed Concrete Manufacturing Yes Already included as a point source based on 1 - 31 size ranking Appendix G – Industrial Point and Area Sources G-3 Table G-3 South Phoenix PM10 Monitor Grid Cell ID # Industrial Source Comments Include in Point Source Category? (Yes / No) 175 No industrial point sources This area consists mostly of housing and commercial property. There are some open/vacant land within this area. No industrial point sources appear to be close enough to impact this monitor. No 176 A @ A @ No 177 A @ A @ No 205 A @ A @ No 206 A @ A @ No 207 A @ A @ No 235 A @ A @ No 236 A @ A @ No 237 A @ A @ No Table G-4 West 43rd Avenue PM10 Monitor Grid Cell ID # Industrial Source Comments Include in Point Source Category? (Yes / No) 189 No industrial sources There is some commercial storage areas near the monitor but no industrial point sources within this area. 190 No industrial sources No 191 No industrial sources No 219 No industrial sources No 220 No industrial sources No 221 No industrial sources No 249 No industrial sources There could be a very significant impact on the monitor from off road vehicle (recreational use) usage. No 250 No industrial sources A @ No 251 No industrial sources A @ No Appendix G – Industrial Point and Area Sources No G-4 Results of 3 x 3 Grid Analysis Five industrial sources were found in the 3 x 3 modeling grid areas around the four PM10 monitors in the Salt River PM10 Study Area. Two of the sources had already been added to the Aindustrial point source@ list based on their size ranking (i.e., within the top 31 highest emitters). The following three additional sources were added to the industrial point source list based on their locations within the 3 x 3 grid modeling grid area: $ $ $ Chevron USA Asphalt Division City of Phoenix Waste Water Treatment Plant ATC Phoenix LISTING OF INDUSTRIAL POINT AND AREA SOURCES Based on the previously mentioned three rules, two lists were compiled of industrial point sources and industrial area sources present in the Salt River PM10 Study Area. Table G-5 contains information on the industrial sources that were considered as point sources in preliminary modeling of ambient PM10 concentrations in the Salt River PM10 Study Area and Table G-6 contains information on the industrial sources that were be considered as area sources. Appendix G – Industrial Point and Area Sources G-5 TABLE G-5 Maricopa County Industrial Sites in Salt River PM10 Study Area - Year 2001 PM10 Emissions Industrial Sources Which Will Be Treated as Point Sources in Modeling Data Source: Maricopa County Environmental Services Department Note: Hourly emissions are based on a daily operating schedule of 8 hours Modeling Grid Cell Size Ranking Business Name Street Address City Zip Code Annual Emissions (Pounds) Annual Emissions Daily Emissions (Tons) (Pounds) Hourly Emissions (Pounds) 517 1 APS WEST PHX 4606 W HADLEY ST POWER PLANT PHOENIX 85043 132107 66.05 361.94 45.24 291 2 UNITED METRO 3640 S 19TH AVE PLANT #11 PHOENIX 85009 56347 28.17 154.38 19.30 445 3 PHOENIX BRICK YARD PHOENIX 85007 55602 27.80 152.33 19.04 282 4 METAL 3640 S 35TH AVE MANAGEMENT ARIZONA INC PHOENIX 850096738 44996 22.50 123.28 15.41 219 5 VULCAN MATERIALS CO-WESTERN 4830 S 43RD AVE PHOENIX 85041 29635 14.82 81.19 10.15 433 6 THE PROCTER 2050 S 35TH AVE & GAMBLE MFG CO PHOENIX 85009 28932 14.47 79.27 9.91 413 7 TRENDWOOD INC PHOENIX 850074400 24301 12.15 66.58 8.32 486 8 BUILDING 4850 W BUCKEYE PRODUCTS CO RD PHOENIX 85043 24286 12.14 66.54 8.32 513 9 HANSON AGGREGATES OF ARIZONA 4002 S 51ST AVE PHOENIX 85043 23951 11.98 65.62 8.20 249 S 51ST AVE PHOENIX 85043 23681 11.84 64.88 8.11 PHOENIX 85009 23102 11.55 63.29 7.91 1814 S 7TH AVE 2402 S 15TH AVE 575 10 VAW OF AMERICA INC 309 11 GTI CAPITAL 3636 S 43RD AVE HOLDINGS LLC G-6 Appendix G – Industrial Point and Area Sources TABLE G-5 Maricopa County Industrial Sites in Salt River PM10 Study Area - Year 2001 PM10 Emissions Industrial Sources Which Will Be Treated as Point Sources in Modeling Data Source: Maricopa County Environmental Services Department Note: Hourly emissions are based on a daily operating schedule of 8 hours Modeling Grid Cell Size Ranking Business Name Street Address City Zip Code Annual Emissions (Pounds) Annual Emissions Daily Emissions (Tons) (Pounds) Hourly Emissions (Pounds) 377 12 WESTERN 2807 S 27TH AVE ORGANICS INC PHOENIX 85009 21438 10.72 58.73 7.34 351 13 TPAC A DIVISION OF KIEWIT WESTERN CO PHOENIX 850096926 18612 9.31 50.99 6.37 14 SOUTH 6411 S 51ST AVE MOUNTAIN GIN LAVEEN 85339 16721 8.36 45.81 5.73 189 15 CORESLAB STRUCTURES (ARIZ) INC PHOENIX 85041 13195 6.60 36.15 4.52 419 16 AMERON 2325 S 7TH ST INTL-WATER TRANSMISSION GROUP PHOENIX 85034 9609 4.80 26.33 3.29 343 18 OLSON PRECAST OF ARIZONA INC 3045 S 35TH AVE PHOENIX 85009 8378 4.19 22.95 2.87 185 19 AJAX SAND & ROCK 5026 S 51ST AVE LAVEEN 85339 7432 3.72 20.36 2.55 382 21 PHOENIX CEMENT TERMINAL 1802 W LOWER BUCKEYE RD PHOENIX 85007 6241 3.12 17.10 2.14 263 22 SANDVICK EQUIPMENT & SUPPLY CO 4020 S 15TH AVE PHOENIX 85041 5496 2.75 15.06 1.88 376 24 CITY OF 2800 S 27TH AVE PHOENIX 27TH AVE LANDFILL PHOENIX 85009 4684 2.34 12.83 1.60 378 25 CITY OF PHOENIX PHOENIX 85009 4528 2.26 12.41 1.55 65 3052 S 19TH AVE 5026 S 43RD AVE 2301 W DURANGO ST G-7 Appendix G – Industrial Point and Area Sources TABLE G-5 Maricopa County Industrial Sites in Salt River PM10 Study Area - Year 2001 PM10 Emissions Industrial Sources Which Will Be Treated as Point Sources in Modeling Data Source: Maricopa County Environmental Services Department Note: Hourly emissions are based on a daily operating schedule of 8 hours Modeling Grid Cell Size Ranking Business Name Street Address City 561 27 SCHUFF STEEL 420 S 19TH AVE CO PHOENIX 343 28 QUALITY BLOCK INC 3035 S 35TH AVE PHOENIX 29 MARLAM INDUSTRIES INC 834 E HAMMOND LN PHOENIX 30 MONIER LIFETILE LLC 1832 S 51ST AVE 31 ROAD MACHINERY CO INC 716 S 7TH ST 390 455 539 351 379 224 513 Zip Code 85009 Annual Annual Emissions Daily Emissions Hourly Emissions Emissions (Tons) (Pounds) (Pounds) (Pounds) 2317 1.16 6.35 0.79 2217 1.11 6.07 0.76 2075 1.04 5.68 0.71 1387 0.69 3.80 0.47 1215 0.61 3.33 0.42 571 0.29 1.56 0.20 185 0.09 0.51 0.06 4308 2.15 11.80 1.48 5414 2.71 14.83 1.85 85009 85034 PHOENIX 85043 PHOENIX 85034 37 CHEVRON USA 3050 S 19TH AVE ASPHALT DIVISION PHOENIX 45 ATC PHOENIX PHOENIX 2225 W LOWER BUCKEYE RD 85009 85009 26 UNIVERSAL ENTECH LLC 3330 W BROADWAY PHOENIX RD 23 U S Greenfiber 601 S 55TH AVE 85041 PHOENIX 85043 G-8 Appendix G – Industrial Point and Area Sources Table G-6 Maricopa County Industrial Sites in Salt River PM10 Study Area - Year 2001 PM10 Emissions Industrial Sources Which Will Be Treated as Area Sources in Modeling Modeling Grid Cell Size Ranking Business Name Street Address City Zip Code Annual Annual Daily Hourly Emissions Emissions Emissions Emissions (Pounds) (Tons) (Pounds) (Pounds) 2018 1.01 5.53 0.69 459 17 WOODSTUFF MANUFACTURING INC 1635 S 43RD AVE PHOENIX 850096026 325 20 UNITED METRO MATERIALS #101 2875 S 7TH AVE PHOENIX 85041 6550 3.28 17.95 2.24 229 32 SMITH PRECAST 2410 W BROADWAY RD PHOENIX 85041 971 0.49 2.66 0.33 605 33 REXAM BEVERAGE CAN COMPANY 211 N 51ST AVE PHOENIX 85043 798 0.40 2.19 0.27 343 35 BAKER COMMODITIES 3602 W ELWOOD ST PHOENIX 85009 669 0.33 1.83 0.23 376 38 CITY OF PHOENIX 19TH AVE LANDFILL 1701 W LOWER BUCKEYE RD PHOENIX 85041 445 0.22 1.22 0.15 529 39 HOLSUM BAKERY INC 2322 W LINCOLN ST PHOENIX 850095827 433 0.22 1.19 0.15 489 40 HYDRO CONDUIT CORP 1011 S 43RD AVE PHOENIX 85009 252 0.13 0.69 0.09 438 41 PHOENIX HEAT TREATING INC 2405 W MOHAVE RD PHOENIX 850096413 207 0.10 0.57 0.07 513 42 CRAFTSMEN IN WOOD MFG 5441 W HADLEY ST PHOENIX 85043 200 0.10 0.55 0.07 433 43 INSULFOAM 3401 W COCOPAH ST PHOENIX 85009 192 0.10 0.53 0.07 576 44 HIGHLAND PRODUCTS INC 43 N 48TH AVE PHOENIX 85043 186 0.09 0.51 0.06 501 46 AMERICAN LINEN SUPPLY CO 1875 W BUCKEYE RD PHOENIX 85007 174 0.09 0.48 0.06 411 47 SUN VALLEY OAK 2465 S 19TH AVE PHOENIX 85009 174 0.09 0.48 0.06 330 48 DEL RIO LANDFILL 1150 E ELWOOD ST PHOENIX 85040 173 0.09 0.47 0.06 295 49 DESERT FIRE INDUSTRIES INC 720 W ILLINI ST PHOENIX 850411108 168 0.08 0.46 0.06 576 50 MPP OF ARIZONA 230 S 49TH AVE PHOENIX 85043 149 0.07 0.41 0.05 528 51 PACIFIC DESIGNS 2425 W SHERMAN ST PHOENIX 85043 146 0.07 0.40 0.05 G-9 Appendix G – Industrial Point and Area Sources Table G-6 Maricopa County Industrial Sites in Salt River PM10 Study Area - Year 2001 PM10 Emissions Industrial Sources Which Will Be Treated as Area Sources in Modeling Modeling Grid Cell Size Ranking Business Name Street Address City Zip Code Annual Emissions (Pounds) Annual Daily Hourly Emissions Emissions Emissions (Tons) (Pounds) (Pounds) 606 52 MAIL-WELL ENVELOPE 221 N 48TH AVE PHOENIX 85043 139 0.07 0.38 0.05 328 53 GOODRICH AIRCRAFT INTERIOR PRODUCTS 3414 S 5TH ST PHOENIX 85040 119 0.06 0.33 0.04 325 54 ACE ASPHALT OF ARIZONA INC 895 W ELWOOD ST PHOENIX 85041 114 0.06 0.31 0.04 528 55 PAN-GLO WEST 2401 W SHERMAN ST PHOENIX 85009 109 0.05 0.30 0.04 413 56 NATIONAL COUNTERTOPS & 2317 S 15TH AVE CABINET PHOENIX 85007 106 0.05 0.29 0.04 578 57 PERMA-FINISH INC 74 PHOENIX 85043 105 0.05 0.29 0.04 604 58 SHELL OIL / PHOENIX TEMINAL 5325 W VAN BUREN ST PHOENIX 85043 104 0.05 0.28 0.04 475 59 PHOENIX MEMORIAL HOSPITAL 1201 S 7TH AVE PHOENIX 85007 101 0.05 0.28 0.03 607 60 TROY BIOSCIENCES INC 113 N 47TH AVE PHOENIX 85043 87 0.04 0.24 0.03 559 61 HENRY PRODUCTS INC 302 S 23RD AVE PHOENIX 85009 85 0.04 0.23 0.03 414 62 CHEM RESEARCH CO INC 1122 W HILTON AVE PHOENIX 85007 71 0.04 0.19 0.02 528 63 MEYER & LUNDAHL MANUFACTURING CO 2345 W LINCOLN ST PHOENIX 85009 51 0.03 0.14 0.02 611 64 SUB ZERO FREEZER CO INC 3865 W VAN BUREN ST PHOENIX 85009 48 0.02 0.13 0.02 570 65 UPPER CRUST BAKERY 220 S 9TH ST PHOENIX 85034 43 0.02 0.12 0.01 528 66 J & A OAK INC 2452 W SHERMAN ST PHOENIX 85009 35 0.02 0.10 0.01 327 67 GLENWOOD MFG INC 44 PHOENIX 85040 34 0.02 0.09 0.01 295 68 BRYANT INDUSTRIES INC 788 W ILLINI ST PHOENIX 85041 27 0.01 0.07 0.01 578 69 STOROPACK INC 77 PHOENIX 85043 23 0.01 0.06 0.01 G-10 Appendix G – Industrial Point and Area Sources N 45TH AVE E PIONEER ST N 45TH AVE Table G-6 Maricopa County Industrial Sites in Salt River PM10 Study Area - Year 2001 PM10 Emissions Industrial Sources Which Will Be Treated as Area Sources in Modeling Modeling Grid Cell Size Ranking Business Name Street Address City Zip Code Annual Emissions (Pounds) Annual Daily Hourly Emissions Emissions Emissions (Tons) (Pounds) (Pounds) 410 70 ADOT EQUIPMENT SERVICES 2225 S 22ND AVE PHOENIX 85009 21 0.01 0.06 0.01 438 71 CAVCO INDUSTRIES LLC/DURANGO PLANT 2502 W DURANGO ST PHOENIX 85009 21 0.01 0.06 0.01 403 72 CAVCO INDUSTRIES LLC 2602 S 35TH AVE PHOENIX 85009 16 0.01 0.04 0.01 553 73 PURCELLS WESTERN STATES TIRE 420 S 35TH AVE PHOENIX 85009 16 0.01 0.04 0.01 566 74 IMPERIAL LITHOGRAPH 210 S 4TH AVE PHOENIX 85003 15 0.01 0.04 0.01 549 75 TEAM TWO DESIGN ASSOC INC 310 S 43RD AVE PHOENIX 85009 14 0.01 0.04 0.00 574 76 UNITED MODULAR 5301 W MADISON ST PHOENIX 85043 13 0.01 0.04 0.00 438 77 EQUIPMENT MAINTENANCE SERVICE 2412 W DURANGO ST PHOENIX 85009 9 0.00 0.02 0.00 414 78 PRECISION INDUSTRIAL PAINTING 1139 W HILTON AVE PHOENIX 85007 8 0.00 0.02 0.00 369 79 ZIEMAN MANUFACTURING CO 4205 W LOWER BUCKEYE RD PHOENIX 85009 1 0.00 0.00 0.00 415 80 PHOENIX SPECIALTIES 1843 S 5TH AVE PHOENIX 85003 1 0.00 0.00 0.00 383 81 INNOVATIVE WASTE UTILIZATION LLC 2550 S 15TH AVE PHOENIX 85007 1 0.00 0.00 0.00 G-11 Appendix G – Industrial Point and Area Sources After additional inspection of the satellite images of the Salt River PM10 Study Area and field surveys, the original list of thirty-one industrial sources to be modeled as industrial point sources was revised to thirty-six sources. Following are the thirty-six sources that were input to the ISCST3 model as point sources: • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • APS WEST PHX POWER PLANT UNITED METRO PLANT #11 PHOENIX BRICK YARD METAL MANAGEMENT ARIZONA INC VULCAN MATERIALS CO-WESTERN THE PROCTER & GAMBLE MFG CO TRENDWOOD INC WOODSTUFF MANUFACTURING HANSON AGGREGATES OF ARIZONA VAW OF AMERICA INC WESTERN ORGANICS INC TPAC A DIVISION OF KIEWIT WESTERN CO SOUTH MOUNTAIN GIN CORESLAB STRUCTURES (ARIZ) INC AMERON INTL-WATER TRANSMISSION GROUP OLSON PRECAST OF ARIZONA INC AJAX SAND & ROCK PHOENIX CEMENT TERMINAL SANDVICK EQUIPMENT & SUPPLY CO CITY OF PHOENIX 27TH AVE LANDFILL SCHUFF STEEL CO QUALITY BLOCK INC MARLAM INDUSTRIES INC MONIER LIFETILE LLC ROAD MACHINERY CO INC CHEVRON USA ASPHALT DIVISION ATC PHOENIX CITY OF PHOENIX WASTE WATER TREATMENT PLANT UNIVERSAL ENTECH U.S. GREEN FIBER SOUTHWEST FOREST PRODUCTS SMITH PRECAST WESTERN BLOCK COMPANY ROCKLAND MATERIALS MCP INDUSTRIES, INC. WEINBERGER TOPSOIL G-12 Appendix G – Industrial Point and Area Sources APPENDIX H - SITE VISITS Following are field notes by ADEQ staff of their site visits to the Salt River PM10 Study Area. Unpaved Parking Lots Survey Aug 1, 2003 field trip was to determine which previously identified unpaved parking lots on the satellite image are actually unpaved, and to determine the number of vehicles (capacity of an unpaved parking lot and the frequency of vehicles entering and leaving unpaved parking lots. Land Use Around Monitoring Sites Survey West 43rd Avenue Monitoring Site From the satellite image there were two areas that we decided to look at in grid cell 220. One area south of the monitor is a vehicle junkyard on a dirt lot (picture # 5). The dirt lot is enclosed by a fence that blocks the view of the lot. The other area is just west of the monitor and is an industrial storage lot with logs, concrete blocks, vehicles, construction equipment, etc. in storage (pictures 6 & 7). Northeast of the monitor in grid cells 250 & 251 is an active illegal open dump area (pictures 2, 3, & 4). Durango Monitoring Site In grid cell 405 are some large gravel covered parking areas near the county jail complex. See pictures 8, 9, & 10. In parts of grid cells 437, 438, 407, and 408 is a large truck tractor storage area. Appears to be paved. See picture 13. In grid cell 436 are some fenced in dirt lots (see picture 11). In grid cell 435 there is a large area that appeared to be a dirt lot from the satellite image. This area is now paved and fenced off (see picture 12). South Phoenix Monitoring Site Northwest of the monitoring site in grid cell 206 and 236 is a dirt lot open to the public. I was in this area about 10 am on July 31 for about 15 minutes. This lot had two cars parked on it this whole time and no additional vehicles drove onto or off of the lot during this time. I estimate that there is enough room to park 40 vehicles on this lot . Salt River Monitoring Site West of 19th Avenue in grid cell 320 is a large dirt area used by United Metro (a.k.a. Rinker Materials) for their concrete trucks. The north end of this area is paved (see pictures 14, 15, & 16). The emissions from this area should be included in the emissions inventory for United Metro. North of United Metro is Phoenix Metal Recycling. Appendix H – Site Visits H-1 APPENDIX I - MCESD RULE EFFECTIVENESS STUDY Appendix I – MCESD Rule Effectiveness Study I-1 Rule Effectiveness Study for Salt River PM10 Study Revised Final Compiled by: Renee Schindler Maricopa County Environmental Services Department Air Quality Division: Planning and Analysis Section Final May 23, 2003 Revised December 18, 2003 Table of Contents 1.0 Executive Summary 2.0 Background 2.1 Study Purpose and Goals 2.2 Study Team 2.3 Rule Summaries 2.3.1 Rule 310 2.3.2 Rule 310.01 2.3.3 Rule 316 3.0 Field Inspection Phase 3.1 Results 3.2 Rule Effectiveness Calculation 3.3 Examples and Results 3.4 Quality Assurance 4.0 Office Investigation Phase 5.0 Recommendations 6.0 Policy/Procedure Improvements 7.0 Summary Appendices A-1 A-2 A-3 B Rule 310 Rule 310.01 Rule 316 EPA’s Standard Deviation Table 2 1.0 Executive Summary In May 1997, ADEQ submitted the Plan for Attainment of the 24-hour PM-10 Standard – Maricopa County PM-10 Nonattainment Area, as a SIP revision. This plan, known as the microscale plan, included attainment and reasonable further progress (RFP) demonstrations for the 24-hour PM-10 standard at the Salt River air quality monitoring site. The attainment demonstration for the Salt River site showed that, with additional controls adopted by Maricopa County Environmental Services Department (MCESD) (improved control of emissions from earthmoving operations and strengthening its inspection program) and the City of Phoenix’s commitment to work cooperatively with MCESD to reduce particulate pollution, attainment at the site would occur by May 1998. EPA approved the attainment and RFP demonstrations for the Salt River site and Maricopa County’s controls on August 4, 1997 (62 FR 41856). According to the approved attainment demonstration, the Salt River site should not have violated the 24-hour PM-10 standard after May 1998. The site however continues to violate the standard. Based on data recorded in EPA’s Aerometric Information Retrieval System (AIRS), the Salt River monitor had 51 expected exceedances in 1999, 43 expected exceedances in 2000, and 19 expected exceedances through 3 quarters in 2001 or an average of 37 expected exceedances per year over the past three years. 1 On July 2, 2002 (67 FR 44369), EPA found the state implementation plan (SIP) for the Metropolitan Phoenix area (Maricopa County), Arizona serious PM-10 nonattainment area to be inadequate to attain the 24-hour particulate (PM-10) air quality standard at the Salt River monitoring site. Under authority from the Clean Air Act, EPA has required a SIP revision to be submitted by the State of Arizona to correct the inadequacy. The State of Arizona has implemented dust control regulations to help achieve a timely attainment for PM-10. The following Maricopa County and State Air Pollution Control Regulations apply to PM-10 control and can be found in Appendix A: Maricopa County Maricopa County Rule 310 Rule 310.01 Maricopa County Rule 316 Arizona Administrative Code (AAC) R18-2-610 & 611 Fugitive Dust Sources Fugitive Dust From Open Areas, Vacant Lots, Unpaved Parking Lots, and Unpaved Roadways Nonmetallic Mineral Mining and Processing Agricultural PM10 General Permit Within Maricopa County, the Maricopa County Air Pollution Control Regulations are applied in lieu of the state of Arizona’s Administrative Code Article 6 rules (R18-2-604, 605, 606, and 607). The state of Arizona Air Quality Control General Permit for Crushing and Screening plants incorporates the requirements of Maricopa County Air Pollution Control Rule 310 for the dust control plan requirements and Rule 316 for the visible emission limitations for facilities that operate in Maricopa County. However, at the time of the study, there were no permitted portable sources in the Salt River study area. To determine the effectiveness of the rules regulating PM-10 emissions in the Salt River Study area, a study team consisting of representatives from Arizona Department of Environmental Quality’s Air Quality Division and Maricopa County’s Environmental Services Department’s Air Quality Division was established. The study team was tasked 1 The 24-hour PM-10 standard is violated when the expected number of exceedances averages more than 1 per year over a three year period 40 CFR 50.6(a). 3 with determining the effectiveness of State and County rules for PM10 source categories located in and near the Salt River SIP area and determining compliance effectiveness with existing rules. The study consisted of a field inspection phase and an office investigation phase. The purpose of the field inspection phase was to observe the application of County Regulations. The office investigation phase focused on determining the level of compliance with applicable County Regulations by reviewing and analyzing the rule content, regulatory enforceability, inspection procedures, source files, and training and agency resource management. An overall rule effectiveness (RE) was calculated using as a guideline EPA’s Rule Effectiveness Guidance: Integration of Inventory, Compliance and Assessment Applications.2 The RE correlates Maricopa County’s findings to rule effectiveness, compliance effectiveness and SIP effectiveness. Based on the results of the study, recommendations for improvements for dust control and/or rule effectiveness have been offered. As mentioned, field inspections were conducted as part of this rule effectiveness study. The field inspection types and results are listed below: Compliance inspectors visited sites that are subject to the Maricopa County PM regulations. The inspectors included in the report which rules applied, which specific parts of the rule applied to the site, the type of site (earthmoving, vacant lot, nonmetallic facility), the compliance status of the site and if any compliance notifications were issued. 2.0 Background On July 2, 2002, EPA found the state implementation plan (SIP) for the Metropolitan Phoenix area (Maricopa County), Arizona serious PM-10 nonattainment area to be inadequate to attain the 24-hour particulate (PM-10) air quality standard at the Salt River monitoring site. Under authority from the Clean Air Act, EPA has required a SIP revision to be submitted by the State of Arizona to correct the inadequacy. The State of Arizona has implemented dust control regulations to help achieve a timely attainment for PM-10. The following Maricopa County and State Air Pollution Control Regulations apply to PM-10 control: Maricopa County Maricopa County Rule 310 Rule 310.01 Maricopa County Rule 316 AAC R18-2-610 & 611 Fugitive Dust Sources Fugitive Dust From Open Areas, Vacant Lots, Unpaved Parking Lots and Unpaved Roadways Nonmetallic Mineral Mining and Processing Agricultural PM10 General Permit Within Maricopa County, the Maricopa County Air Pollution Control Regulations are applied in lieu of the state of Arizona’s Administrative Code Article 6 rules (R18-2-604, 605, 606, and 607) which address particulate matter emissions from open areas, dry washes, riverbeds, roadways, streets, material handling operations, and storage piles. The state of Arizona Air Quality Control General Permit for Crushing and Screening plants incorporates the requirements of Maricopa County Air Pollution Control Rule 310 for the dust control 2 U.S. EPA, Office of Air Quality Planning and Standards, Rule Effectiveness Guidance: Integration of Inventory, Compliance and Assessment Applications, EPA-452/4-94-001, January 1994. 4 plan requirements and Rule 316 for the visible emission limitations for facilities that operate in Maricopa County. The state’s agricultural PM10 General Permit was not included as part of this study because the amount of agricultural land are projected to decrease significantly due to conversion of agricultural land to residential and commercial uses. 2.1 Study Purpose and Goals This study was conducted to review implementation and enforcement of Maricopa County Rules 310, 310.01, and 316 in the Salt River Study area. The review of particulate control included an examination of inspection procedures, compliance determinations, source compliance histories, rule enforceability, and source files. This was accomplished by performing a field inspection in conjunction with an office investigation, if appropriate. The field inspections included visits to ten initial facilities for each rule in the Salt River Study area to determine the level of compliance with applicable County and State Regulations. The type of inspections that will be conducted will be consistent with what would be done presently within the department. The goals of this phase were: • • To determine whether MCESD and ADEQ inspection procedures are adequate to identify and reconcile compliance with rule requirements; and To determine the effect the rule has had on decreasing dust-causing pollution. The office investigation phase focused on rule content and the internal policies and procedures that affect how rules are implemented and enforced, such as rule content, regulatory enforceability, inspection procedures, and training and agency resource management. Inspections will occur consistent to current department schedules. The goals of this phase were: • • • 2.2 To determine whether the current MCESD and ADEQ rule program could ensure that emission reductions for dust control are achieved; To evaluate the functions of MCESD and ADEQ emission inventory, permitting and compliance programs as they relate to attainment planning and emission reductions; and To determine whether MCESD and ADEQ programs are adequate to 1) determine compliance and 2) deter, detect and correct any instances of noncompliance. Study Team A 16-person team conducted the rule effectiveness study. The team included personnel from MCESD and the Arizona Department of Environmental Services (ADEQ). The following MCESD - Air Quality sections participated: Compliance, Engineering Services (Permitting), Planning and Analysis, and MCESD Community Services (Small Business Assistance). 2.3 Rule Summaries The following includes a summary of all the Maricopa County rules this study is analyzing to determine their effectiveness in the Salt River area. Rule 310 5 Rule 310 applies to all dust generating operations including open areas, vacant lots, unpaved parking lots, and unpaved roadways which are located at sources that require a permit under Maricopa County Rules. Normal farm cultural practices as defined under Arizona Revised Statutes (ARS) §49-457 and ARS §49-504.4 are exempt from this rule. With a 20% opacity limit, fugitive dust sources have to keep dust stabilized and control measures implemented at all times. Measures include installing signs restricting trespassing, applying gravel or paving unpaved parking lots, applying water, gravel, or dust suppressant to haul roads, prewatering work sites, constructing wind barriers and establishing vegetative cover. Earthmoving operations shall have a dust control plan submitted if the project is equal to or greater than 0.1 acres. Specific work practices for different types of activities are described in the rule. Compliance shall be determined by conducting opacity observations, stabilization determinations, and recordkeeping. Rule 310.01 Rule 310.01 applies to open areas, vacant lots, unpaved parking lots and unpaved roadways which are not regulated by Rule 310. Any open area or vacant lot that is not defined as agricultural land and is not used for agricultural purposes according to ARS § 42-1251 and ARS § 42-1252, and normal farm cultural practices as defined under Arizona Revised Statutes (ARS) §49-457 and ARS §49-504.4, are exempt from this rule. The rule outlines control measures and stabilization limitations required for different dust source activities such as preventing vehicular access to open areas and vacant lots, establishing vegetative cover, uniformly applying and maintaining surface gravel, and application of dust suppressant. Stabilization observations and recordkeeping shall be maintained. Rule 316 Rule 316 regulates particulate matter emissions from nonmetallic mining operations and rock product processing plants. Opacity limitations are outlined for the different type of operations and stack and fugitive dust emissions. For those sources with air pollution control equipment and/or monitoring equipment, an Operation and Maintenance Plan is required. This rule requires recordkeeping of daily operations and control device data. The site must comply with Rule 310 where it applies. 3.0 Field Inspection Phase Two types of field inspections were conducted as part of this rule effectiveness study. The first involved team members conducting inspections within the study area at earthmoving sites and vacant lots. The second involved MCESD investigators inspecting stationary permitted sources. A quality assurance (QA) team was assembled for this study. The team consisted of two MCESD employees and one ADEQ employee, who had a strong comprehension of the rules in this study. The QA team followed one earthmoving inspector and one stationary source inspector one morning and took notes based on what was observed and what was recorded. They accompanied an inspector to two different sites, an earthmoving construction site and a stationary source concrete batch facility. After reviewing how each interpreted that days’ observations they then separated and each accompanied a compliance inspector to the remainder of the sites determined to be part of the QA. The QA team will assure consistency is occurring during the investigations. The forms will be reviewed to see 6 that they are being filled out completely and correctly. The team will also evaluate the consistency of what is being considered a violation during the investigations and inspections. According to EPA’s Guidelines for Estimating and Applying Rule Effectiveness for Ozone/ CO State Implementation Plan Base Year Inventories3 (EPA, 1992), sample size should be representative of the categories population as a whole and the standard deviation, degree of accuracy and degree of confidence must be considered. EPA recommends a 90 percent confidence interval and the suggested sample error is 5 percent, but should not exceed 10 percent to be used with Table D-1 in EPA’s guideline (see Appendix B). With a 90 percent confidence interval, a standard deviation of 10%, and a sample error around 5%, about 10 stationary sources should be inspected and 10 earthmoving sites. Since there are twenty-seven stationary sources in the study area, nine facilities were an acceptable initial sample size. Since there are over 300 earthmoving sites in the study area, 15 initial inspections were an acceptable sample size. 3.1 Results Stationary Sources Ten facilities in the Salt River Study area subject to Rule 316 were inspected during the months of November and December 2002 and two more were inspected in spring 2003. All the inspections were Level 2, which include a source file review, site inspection, record review and written report. There was a difference between facilities because some sources had a complete facility inspection while the others were just focused on the equipment/process applicable to Rule 316 and/or 310. The following table summarizes what was observed at each facility and if any corrective action taken, according to Rules 310 or 316. There are three corrective actions taken: Notice to Correct, Compliance Status Notification (CSN), and Notice of Violation (NOV), with the NOV as the most serious corrective action. Date Permit Site ID Table 3.1: List of Inspected Facilities Address 310/311/316 Violation Observed 11/19/02 960737 Smith Precast 2140 W Broadway 11/25/02 000169 Eagle Roofing 4602 W Products Elwood St NOV/CSN Issued Failure to Maintain Records for Dust CSN-310 Control Failure to Maintain Record of Dust CSN-316 Collector Operating Parameters (in O&M Plan) Failure to Maintain Visible Emission CSN-316 Inspection Records (in O&M plan) 11/25/02 20046 Jensen Patio 515 W Failure to Maintain Dust Control Plan CSN-310 Log Failure to Obtain a Permit CSN-310 None, but O&M not submitted None 3 U.S. EPA, Guidelines for Estimation and Applying Rule Effectiveness for Ozone/ CO State Implementation Plan Base Year Inventories, EPA-452/R-92-010, November 1992. 7 12/1/02 12/3/02 12/3/02 12/5/02 12/9/02 12/9/02 12/20/02 3/12/03 4/1/03 Brick 000066 Glen Weinberger Topsoil 010216 Precast Manufacturing 990641 Ajax Sand and Rock 980089 Quality Block Inc 990095 Ultra Kote Products Elwood St 3425 S 43rd Failure to Maintain Records of Water CSN-310 Ave Log 301 W Broadway 5026 S 51st Ave 3035 S 35th Ave 327 S 27th Ave 10182 Tpac 3052 S 19th Ave 10066 Western Block 4021 S 19th Company Ave 98026 Hansen 4002 S 51st Aggregate Ave 10089 Hansen Salome Aggregate of Road Arizona Failure to have certified emissions observer Failure to Submit Dust Plan CSN-316 None None Failure to Submit Dust Plan CSN-310 Failure to maintain inspection logs CSN-316 Failure to include sand blasting equipment Failure to Submit Dust Plan Failure to Submit O&M Plan Failure to Submit O&M Plan CSN- 200 None None CSN-310 CSN-310 CSN-316 CSN-316 Earthmoving Sites Fifteen earthmoving sites were observed during the month of December 2002. Seventeen additional earthmoving sites were observed during the spring of 2003. The following table outlines the compliance issues and actions at each site. Date Table 3.2: List of Inspected Earthmoving Sites Permit ID Site Address 310 Violation Observed NOV/CSN Issued 12/5/02 E20102415 Hurley Properties 2505 W Durango No No 12/5/02 E20103594 Lockewood 4620 W Hadley Unstable haul road causing Notice to Greene E&C Visible Emissions correct 12/5/02 E20102145 Capital Pacific 55th Ave and Baseline 12/5/02 E20104856 LGE Corp 43rd Ave and Mojave 12/5/02 E20103032 KB Homes 27th Ave and Broadway 12/5/02 E20104603 Standard Pacific 19th Ave and Southern Backhoe running, no water seen in use, but no visible emissions No water being used but no visible emissions seen, no project info sign posted Very little gravel (for use as trackout device) Pile at exit needs spreading No Notice to correct 3 Notices to correct Notice to correct None Table 3.2 Cont’d: List of Inspected Earthmoving Sites 8 Date Permit ID Site Address 310 Violation Observed NOV/CSN Issued 27th Ave and Southern 41st and Alta Vista Trackout device too small, needs refreshing Pads being driven on, no water used with backhoe, trackout device needs refreshing , no permit onsite Notice to correct 3 CSNs issued, 2 Notices to Correct 12/5/02 E20103705 Trend Homes No No 12/5/02 E20102217 No No Trackout along roadway <= 50 feet Refresh trackout device at main entrance No Notice to correct Notice to correct Trackout on paved public roadway >50 ft Trackout on paved public roadway >50 ft Trackout pads need refreshing, trackout on paved public roadway, dust control records not onsite No permits or dust control records onsite No permits or dust control records onsite Notice to correct Notice to correct 2 Notices to correct 12/5/02 E20104994 Mountain West Estates 12/5/02 E20103401 Trend Homes 12/3/02 E20103037 12/3/02 E20104077 12/3/02 E20104319 12/3/02 E20103095 12/3/02 E20105007 4/9/03 E20300312 43rd Ave and Baseline Richmond 43rd Ave and American Baseline Great Western 7th Ave and Homes Sunland LinsenMeyer 11th Ave and Partnership Magnolia Renaissance 101 N 1st Companies Avenue Artisan Homes 7th St and Washington Reliance 2nd St and Commercial Buchanan Tono Contracting 15th Ave and Baseline 4/9/03 E20300830 PARS Development 4/9/03 E20300251 Gen Spec A Division of Contractor Abatement 4/9/03 E20300294 Complete Decon Inc 4/8/03 E20105365 Gen Spec A Division of Contractor Abatement 4/8/03 E20300345 DL Withers 11th Ave and Carter 4427 & 4409 S Central Ave 4/8/03 E20300747 Chaparral Construction 1102 E Tonto St #2- Must have H2O available, #5- Clean up <=50 ft, no Dust Control records None None 512 E Van Buren No None 120 S 6th Ave No None 800 W Adams No None 2 Notices to correct Table 3.2 Cont’d: List of Inspected Earthmoving Sites 9 Date Permit ID Site 4/8/03 E20300252 Gen Spec A Division of Contractor Abatement 5/1/03 E20300867 ACE Asphalt Address 310 Violation Observed NOV/CSN Issued 12th Ave and Madison No permit or dust control records onsite None 27th Ave and Southern #1- NTC, needs stabilization #2 NOV-No water onsite #4- CSN no trackout device seen #6 and #8 - same NOV as #2 No permit or dust control plan onsite, no project sign #2,3,6 NOV- No water used No 3 Notices to correct 1 CSN 1 NOV 5/1/03 E20104498 Courtland Homes 5/1/03 E20105398 Hallcraft 35th Ave and Baseline 51st Ave and Southern 5/1/03 E20300386 Richmond 43rd Ave and American Baseline 5/1/03 E20104994 Mountain West 27th Ave and Southern 5/1/03 E20300104 Dietz-Crane 35th Ave and Southern 5/1/03 E20301143 Richmond 27th Ave and American Vineyard 5/1/03 E20301285 KB Homes 27th Ave and Broadway 5/1/03 E20301289 KB Homes 27th Ave and Broadway One NOV None #2,8 NTC- No water hose 1 NTC No None #4 NTC- trackout surface worn and small, refresh No 1 NTC None No None No None Vacant Lot Sites Fifteen vacant lots in the Salt River Study area subject to Rule 310.01 were inspected during the month of April 2003. A checklist was followed to determine the compliance status of each site. The following table contains the site, location and if any compliance issues were observed. Date Permit ID Table 3.3: List of Inspected Vacant Lot Sites Address 301.01 Violation Observed 4/9/03 Yee Holdings 4/9/03 Phyllis Rawlings 35th and Broadway None 39th and Alta Vista Non-uniform gravel, partial control implementation 4/9/03 Ken Altiman 4/9/03 Mt Baldy Limited 39th and Southern 43rd and Southern None 60% vegetative cover and non-uniform gravel, partial control measure implementation 10 Date Table 3.3 Cont’d: List of Inspected Vacant Lot Sites Permit ID Address 301.01 Violation Observed 4/9/03 Michael Rose 4/9/03 First New Life Baptist 4/9/03 Robert Pennington 4/9/03 AT&SF 4/9/03 Ray West Development 4/24/03 Aljasa Enterprises 4/23/03 Reid Mary Carolyn 4/24/03 Branham Chanel 19th and Southern 19th and Romlex None None 19th and Broadway None 19th and Washington 39th and Washington 15th and Roeser Central and Jesse Owens 17th and Sunland Trees and some non-uniform gravel, almost complete control implementation Shrubs/trees and some non-uniform gravel, almost complete control implementation Partial gravel, failed stabilization tests, out of compliance None Partial curbs and fences, almost complete control implementation 4/24/03 Sagarino Frank 10th St and Baseline No control measures, out of compliance et al 4/24/03 IDRA Central and Elwood None 4/24/03 Roosevelt 10th St and Baseline No control measures, out of compliance School District 3.2 Rule Effectiveness Calculation In order to quantify the rules’ effectiveness the MCESD staff weighted the requirements of Rule 316 and Rule 310 according to its significance in terms of creating emissions. For example, an opacity limit has a direct correlation to pollution being emitted, where recordkeeping requirements are a minor element in decreasing emissions. This is similar to the approach taken in EPA’s Rule Effectiveness Guidance: Integration of Inventory, Compliance and Assessment Applications 2 for the RE Improvements Matrix. Most RE calculations are determined using baseline emissions and actual emissions after control efficiency is applied to the allowable emissions of a facility. Since the sources of this study are mainly fugitive emissions either without emissions calculated (earthmoving sites), or calculated using lowlevel emission factors, and the control devices don’t have an efficiency (trackout device, watering), a different approach was required. Rule 316 was evaluated by compiling all the requirements and furnishing a certain amount of points to each requirement. Since there are different requirements for specific types of facilities, those were handled accordingly. For each facility, there are 100 points per rule possible. If a corrective action takes place, no points are given for that requirement. For example, maintaining an O & M Plan onsite is worth 10 points, if a Notice To Correct (NTC), Compliance Status Notification (CSN), or Notice of Violation (NOV) is issued for not maintaining an O & M Plan onsite, then no points would be given for that requirement. If the requirement is not applicable or not observed, then no points are awarded and the points for that requirement are subtracted from the total. The following table outlines the amount of points possible for each requirement. 11 Table 3.4: Rule 316 Rule Effectiveness Point System Nonmettallic Mineral Processing Plant Standards: • Limit stack emissions to 7% opacity/ 0.02 gr./dscf (50mg/ dscm) of PM • Limit fugitive dust to 7% opacity for conveying systems • Limit fugitive dust to 15% opacity from a crusher • Limit fugitive dust to 10% opacity from any affected operation or process source (excluding the following) • Limit fugitive dust to 20% opacity from truck dumping directly into screening operation, feed hopper or crusher. O&M Requirements: • Shall submit for approval to the control officer • Shall be maintained and available onsite-the plan • Shall comply with identified actions and schedules provided in each O&M plan Recordkeeping Requirements: • General Data- Hours of operation, throughput • Control and Monitoring Device Data- baghouse records, scrubber records, device failure and reasons Compliance Determination: Method 9 certified observer TOTAL Concrete Plants and Bagging Operations Standards: • Limit stack emissions to 7% opacity • Limit fugitive dust to 10% opacity from any affected operation or process source (excluding the following) • Limit fugitive dust to 20% opacity from truck dumping directly into screening operation, feed hopper or crusher. O&M Requirements: • Shall submit for approval to the control officer • Shall be maintained and available onsite • Shall comply with identified actions and schedules provided in each O&M plan Recordkeeping Requirements: • General Data- Hours of operation, throughput • Control and Monitoring Device Data- baghouse records, scrubber records, device failure and reasons Compliance Determination: Method 9 certified observer TOTAL POINTS 20 7.5 7.5 7.5 7.5 7.5 7.5 15 5 5 10 100 POINTS 25 15 10 10 10 10 5 5 10 100 For Rule 310, the Earthmoving Site Inspection Form (Appendix C-1) was used to assign points for different requirements. For each site, there are 83.75 points possible. If a corrective action takes place, then points are deducted from that requirement’s points. For issuance of a Notice to Correct, a Compliance Status Notification (CSN), or a Notice of Violation (NOV), no points are given. If the requirement is not applicable or not observed, then no points are awarded and the points for that requirement are subtracted from the total. 12 The last four requirements are either “yes” or “no”, so points are either totally awarded or zero. The following outlines the amount of points possible for each requirement. Table 3.5: Rule 310 Rule Effectiveness Point System Requirements: Unpaved haul/access roads Disturbed surface areas Trenching Operations Track-out Control Device Track-out along a Paved Public Roadway (≤ 50 ft, >50ft) Bulk Material Handling On-site w/in boundaries or work site Bulk Material Handling Offsite onto paved public roadways Water supply/ availability Permit On-site Dust Control Records On site Project Information Sign Posted Visible Emissions Evaluation Conducted TOTAL POINTS 10 10 10 10 10 10 10 10 1.25 1.25 1.25 0 83.75 For Rule 310.01, a different type point system was used. There were no CSN, NTC or NOV notices issued, therefore, that could not be used as a measure. Depending on the use of the lot, Rule 310.01 allows for different types of control measures and stabilization determinations, which are outlined on the inspector checklist (Appendix C-2). A stabilization test method must be completed according to the rule to determine if the measure was effectively implemented. One point was allocated for each stabilization test passed and no points were given if a stabilization test failed. 3.3 RE Examples and Results The point system outlined above was used on each facility that was inspected according to the applicable rule’s requirements, and the rule effectiveness calculated. Below is an example of how the rule effectiveness for a Rule 316 applicable facility was calculated. Rule 316 Example: Facility- Concrete Plant and Bagging Operation Standards: • Limit stack emissions to 7% opacity (25 points) • Limit fugitive dust to 10% opacity from any affected operation or process source (excluding the following) (15 points) • Limit fugitive dust to 20% opacity from truck dumping directly into screening operation, feed hopper or crusher. (10 points) O&M Requirements: • Shall submit for approval to the control officer (10 points) • Shall be maintained and available onsite (10 points) POINTS 25 15 10 10 7.5- records not onsite but were available during follow up visit 13 10 Shall comply with identified actions and schedules provided in each O&M plan (10 points) Recordkeeping Requirements: • General Data- Hours of operation, throughput (5 points) 5 5 • Control and Monitoring Device Data- baghouse records, scrubber records, device failure and reasons (5 points) • Compliance Determination: Method 9 certified observer (10 points) 2.5 TOTAL 90 points Out of 100 points for complying with Rule 316, this facility had 90 points and, therefore, was 90% compliant with the rule’s requirements. This calculation was done for each facility, and the conclusions are summarized below. Table 3.6: Rule 316 Rule Effectiveness Results Site RE Calculation Smith Precast 100% Eagle Roofing Products 80% Jensen Patio Brick 90% Glen Weinberger Topsoil NA Precast Manufacturing 85% Ajax Sand and Rock 100% Quality Block Inc 100% Ultra Kote Products 75% Tpac 76.3% Western Block Company 70% Hansen Aggregate 92.5% Hansen Aggregate of Arizona 100% Average 88.1% Standard Deviation 11.42% For Rule 310, a very similar calculation was completed for a rule effectiveness value to be determined. The total for each facility was calculated by applying the corrective action deductions where necessary and then dividing by the total possible points. An example of this follows: Rule 310 Example: Site- Linsenmeyer Partnership Requirements: Unpaved haul/access roads Disturbed surface areas Trenching Operations Track-out Control Device Track-out along a Paved Public Roadway (≤ 50 ft, >50ft) Bulk Material Handling On-site w/in boundaries or work site Bulk Material Handling Offsite onto paved public roadways Water supply/ availability Permit On-site POINTS 10 10 N/A 0 10 Not Observed Not Observed 10 1.25 14 Dust Control Records On site Project Information Sign Posted Visible Emissions Evaluation Conducted TOTAL Not Observed 1.25 0 42.50/52.50 Therefore, out of 52.50 total possible points for complying with Rule 310, this site had earned 42.50 points. 42.50 points/ 52.50 points * 100% = 81.0% This site was 81% compliant with the rule’s requirements. This calculation was done for each site and the conclusions are summarized below. Table 3.7a: Rule 310 Only Sites RE Results Site RE Calculation Hurley Properties 100% Lockewood Greene E&C 71% Capital Pacific 79% LGE Corp 54% KB Homes 71% Standard Pacific 98% Mountain West Estates 77% Trend Homes 31% Trend Homes 98% Richmond American 100% Great Western Homes 79% LinsenMeyer Partnership 81% Renaissance Companies 100% Artisan Homes 77% Reliance Commercial 74% Tono Contracting 63% PARS Development 92% Gen Spec A Division of 94% Complete Decon Inc 92% Gen Spec A Division of 92% DL Withers 100% Chaparral Construction 60% Gen Spec A Division of 94% ACE Asphalt 16% Courtland Homes 56% Hallcraft 94% Richmond American 51% Mountain West 95% Dietz-Crane 82% Richmond American 96% KB Homes 97% KB Homes 97% Average 80.1% Standard Deviation 21.1% Rule 310 was applicable at some of the stationary sources inspected. The following table summarizes the rule effectiveness calculated at these facilities. 15 Table 3.7b: Rule 310 stationary source RE Results Site RE Calculation Smith Precast 76.2% Eagle Roofing Products 24% Glen Weinberger Topsoil 97% Precast Manufacturing 96.2% Ajax Sand and Rock 61.5% Quality Block Inc 96% Ultra Kote Products 61.5% Western Block Company 61.5% Hansen Aggregate of Arizona 100% Hansen Aggregate 100% Average 77.3% Standard Deviation 25.33% Therefore, the average combined RE for sources subject to Rule 310 is 79.5%. As explained above, Rule 310.01, the rule effectiveness had to be determined with a different calculation. The following is an example of how the rule effectiveness was calculated. Ray West Development: • Subject to Rule 310.01 Section 302 • For control measures has shrubs and trees and sporadic gravel • Facility passed drop ball/steel ball test stabilization test (1 point) and failed flat vegetative cover test (0 points) Therefore, out of 2 total possible points for complying with Rule 310.01, this site had a total of 1 point. (1 + 0)/2 * 100% = 50% This site was 50% compliant with the rule’s requirements. This calculation was done for each site and the conclusions are summarized below. Table 3.8: Rule 310.01 Rule Effectiveness Results Site RE Calculation Yee Holdings 100% Phyllis Rawlings 33% Ken Altiman 50% Mt Baldy Limited 50% Michael Rose 100% First New Life Baptist 50% Robert Pennington 50% AT&SF 50% Ray West Development 50% Aljasa Enterprises 0% Reid Mary Carolyn 50% Branham Chanel 98% 16 Sagarino Frank etal 50% IDRA 100% Roosevelt School District 100% Average 62.1% Standard Deviation 30.37% Sample Size As referenced earlier in the report, the number of sources in the sample size should be determined based on the standard deviation of the initial inspections conducted. MCESD used EPA guidance to determine adequate sample sizes.4 With Rule 316, the standard deviation was 11.42%. Assuming a 90 percent confidence limit and a limit of error of 5.5 percent, the sample size required is equal to 11. Nine sources were initially inspected and two additional sources were inspected to meet the sample size requirement. With Rule 310, the standard deviation was 21.1%. Assuming the same 90 percent confidence limit and a limit of error of 6.5 percent, the sample size required is 29. Thirtytwo sites were inspected. With Rule 310.01, the standard deviation was 30.37%. Assuming the same 90 percent confidence limit and a limit of error of 10 percent, the sample size required is 25. Fifteen sites were inspected. MCESD will consider conducting additional inspections if time and resources permit. 3.4 Quality Assurance As mentioned above there was a quality assurance team assembled to follow the inspectors on their visits to the regulated sources. The following outlines their observations and the differences between how the QA team member would have conducted the inspection and how the actual inspector performed. For the stationary sources, both the QA team member and the inspector had almost identical observations at nine sites and the QA member would have issued the same type of compliance notices. At two facilities the RE difference was 10.0% and at another facility there was a 15% difference in RE calculation because the QA member would have issued an NOV for not maintaining or recording control equipment parameters and also noted opacity created by the cement hopper where control was absent. Overall, the average RE determined by the QA team was 84.5% which is 3.6% difference from the inspections’ average RE calculation. For the earthmoving sites, both the QA team member and the inspector had less than a 5% difference in observations at 23 sites and the QA member would have issued the same type of compliance notices. For the other sites, there were mainly small discrepancies, which created minor differences in RE calculations. Eight sites had greater than 10% difference; five of them were that the QA member and the inspector differed on the number of NTC, 4 Guidelines for Estimating and Applying Rule Effectiveness for Ozone/CO State Implementation Plan Base Year Inventories, U.S. EPA, EPA-452/R-92-010, November 1992. 17 CSN, or NOV issued. At one site, the QA member decided a notice was not required according to the rule since the site had until the end of the workday to fix it. At three sites, the QA member did not see a violation, but the inspector did. Overall, the average QA RE calculated is 81.3%, which is 1.3% greater than the inspection average RE calculation of 80.1%. For the vacant lots, both the QA team member and the inspector had the same observations at all fifteen sites. The higher percentage of identical observations is likely related to the simpler interpretation that is allowed with this rule. 4.0 Office Investigation Phase The information and observations collected from the field inspection phase were reviewed in conjunction with the rule content and internal policies to determine if emission reductions for particulate matter are being achieved and to review enforcement procedures. When considering the low percentage of particulate emitting sources that were issued Notices of Violations (4.6% of 43 sites), along with the rule effectiveness values, the conclusion could be drawn that the rules are being implemented and followed by the regulated community. Therefore, the MCESD rule program is ensuring both dust control and a reduction in emissions are occurring. In terms of Compliance Status Notifications, 12 of 43 sites were issued CSNs, nine of which were administrative notifications, for example failure to submit a dust plan or O&M plan. The differences between the inspector and QA member were minimal, however the compliance department did review the differences and determined where more continuity and parity could occur between inspectors. The area with the larger discrepancy was with the earthmoving inspections. Rules are administered to attain the state implementation plan goals of reducing pollution by requiring control measures to be implemented at applicable emission sources. MCESD’s permitting program contains all the requirements of the particulate matter rules, as applicable. When a facility receives its permit and implements the actions necessary to be in compliance with that permit, the facility is fulfilling its duty to assist in attaining emission reductions the county was anticipating when adopting the rule. In terms of emission inventory, all sources with a stationary source permit must be prepared to submit an annual emission report if Maricopa County requests a report submittal. The report is created from recordkeeping required in the permit, and is used to create the SIP inventory that is used for modeling to determine if the pollution levels are decreasing as required by the SIP. The compliance section ascertains whether the facility complies with its requirements and stays within its limits. As seen in this study, MCESD inspections are thorough and check sheets follow the permit requirements. Inspections occur on a scheduled basis for all dust sources, except vacant lots. Vacant lots are only inspected when a complaint is made, due to a limited number of County inspection employees. The inspectors review all aspects of the source’s responsibility including recordkeeping and visible emission observations. Based on this study, it can be stated that the programs for MCESD adequately determine compliance status for all sources subject to the particulate matter rules and are able to detect and pursue correction of noncompliance. 18 5.0 Recommendations While conducting the inspections for this study, a slight difference in inspection methods appeared. The main area of difference was which type of corrective notice should be issued to the facility. A guideline with different possible infractions of each requirement given as scenarios would be useful in creating a more equitable inspection process. This would be beneficial for both stationary sources and earthmoving sites. When inspecting stationary sources that have an earthmoving permit, an earthmoving inspection form should be filled out to ensure uniform inspections will occur at all regulated sites. Since this study took place during a high profile time period in the Salt River study area, sources were aware of the County and State’s presence, and were therefore, probably more conscientious at complying with their requirements. It would be a useful exercise to conduct another round of inspections in a couple months to see if compliance with the rules has decreased or has held steady. It would help determine the level of education necessary for a source’s full understanding of their responsibilities. 6.0 Policy/Procedure Improvements The rule effectiveness national protocol provides guidance to states and local agencies to conform to standards set by the Stationary Source Compliance Division (SSCD), now the Office of Enforcement and Compliance Assurance (OECA). The primary purposes for the SSCD studies are to “determine the effectiveness of rules for a specific source category in a specific nonattainment area” and to “identify specific implementation problems which need to be addressed by the State and EPA compliance and enforcement staff.” Within one year following a study, a follow-up audit is conducted to determine whether corrective actions were implemented. It is useful exercise to conduct another round of inspections in a couple months to see if compliance with the rules has decreased or has held steady. This would be a useful tool for the county to determine which education would better benefit the sources. 7.0 Summary In summary, the rule effectiveness calculations for Maricopa County’s particulate matter rules in the Salt River Study area is as follows: • • • Sites inspected in the Salt River Study area that were subject to Rule 316 had a calculated average rule effectiveness of 88.1%. Sites subject to only Rule 310 requirements in the Salt River Area had a calculated average rule effectiveness of 80.1%; All sites subject to Rule 310 requirements in the Salt River Area had a calculated average rule effectiveness of 79.5%. The Salt River Study area’s vacant lots had a calculated Rule 310.01 average rule effectiveness of 62.1%. 19 Appendix A-1 20 REGULATION III - CONTROL OF AIR CONTAMINANTS RULE 310 FUGITIVE DUST SOURCES INDEX SECTION 100 - GENERAL 101 PURPOSE 102 APPLICABILITY SECTION 200 - DEFINITIONS 201 BULK MATERIAL 202 BULK MATERIAL HANDLING, STORAGE, AND/OR TRANSPORTING OPERATION 203 CARRY-OUT/TRACKOUT 204 CONTROL MEASURE 205 DISTURBED SURFACE AREA 206 DUST CONTROL IMPLEMENT 207 DUST CONTROL PLAN 208 DUST GENERATING OPERATION 209 DUST SUPPRESSANT 210 EARTHMOVING OPERATION 211 FREEBOARD 212 FUGITIVE DUST 213 GRAVEL PAD 214 GRIZZLY 215 HAUL TRUCK 216 INTERMITTENT SOURCE 217 MOTOR VEHICLE 218 NORMAL FARM CULTURAL PRACTICE 219 OFF-ROAD VEHICLE 220 OPEN AREAS AND VACANT LOTS 221 OWNER AND/OR OPERATOR 222 PAVE 223 PUBLIC ROADWAYS 224 ROUTINE 225 SILT 226 TRACKOUT CONTROL DEVICE 227 UNPAVED HAUL/ACCESS ROAD 21 228 UNPAVED PARKING LOT 229 UNPAVED ROAD 230 URBAN OR SUBURBAN OPEN AREA 231 VACANT LOT 232 VACANT PARCEL 233 WIND-BLOWN DUST 234 WIND EVENT 235 WORK SITE SECTION 300 - STANDARDS 301 OPACITY LIMITATION FOR FUGITIVE DUST SOURCES 302 STABILIZATION REQUIREMENTS FOR FUGITIVE DUST SOURCES 303 DUST CONTROL PLAN REQUIRED 304 ELEMENTS OF A DUST CONTROL PLAN 305 DUST CONTROL PLAN REVISIONS 306 CONTROL MEASURES 307 PROJECT INFORMATION SIGN 308 WORK PRACTICES SECTION 400 - ADMINISTRATIVE REQUIREMENTS 401 DUST CONTROL PLAN POSTING 402 COMPLIANCE SCHEDULE SECTION 500 - MONITORING AND RECORDS 501 COMPLIANCE DETERMINATION 502 RECORDKEEPING 503 RECORDS RETENTION 504 TEST METHODS ADOPTED BY REFERENCE TABLE 1 TABLE 2 Revised 07/13/88 Revised 07/06/93 Revised 09/20/94 Revised 06/16/99 22 Revised 02/16/00 MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS REGULATION III - CONTROL OF AIR CONTAMINANTS RULE 310 FUGITIVE DUST SOURCES SECTION 100 - GENERAL 101 PURPOSE: To limit particulate matter emissions into the ambient air from any property, operation or activity that may serve as a fugitive dust source. The effect of this rule shall be to minimize the amount of PM10 entrained into the ambient air as a result of the impact of human activities by requiring measures to prevent, reduce, or mitigate particulate matter emissions. 102 APPLICABILITY: The provisions of this rule shall apply to all dust generating operations except: normal farm cultural practices under Arizona Revised Statutes (ARS) §49-457 and ARS §49-504.4 and open areas, vacant lots, unpaved parking lots, and unpaved roadways which are not located at sources that require any permit under these rules. SECTION 200 - DEFINITIONS: For the purpose of this rule, the following definitions shall apply. See Rule 100 (General Provisions And Definitions) of these rules for definitions of terms that are used but not specifically defined in this rule. 201 BULK MATERIAL - Any material, including but not limited to, earth, rock, silt, sediment, sand, gravel, soil, fill, aggregate less than 2 inches in length or diameter (i.e., aggregate base course (ABC)), dirt, mud, demolition debris, cotton, trash, cinders, pumice, saw dust, feeds, grains, fertilizers, and dry concrete, which are capable of producing fugitive dust at an industrial, institutional, commercial, governmental, construction, and/or demolition site. 202 BULK MATERIAL HANDLING, STORAGE, AND/OR TRANSPORTING OPERATION - The use of equipment, haul trucks, and/or motor vehicles, such as but not limited to, the loading, unloading, conveying, transporting, piling, stacking, screening, grading, or moving of bulk materials, which are capable of producing fugitive dust at an industrial, institutional, commercial, governmental, construction, and/or demolition site. 203 CARRY-OUT/TRACKOUT - Any and all bulk materials that adhere to and agglomerate on the exterior surfaces of motor vehicles, haul trucks, and/or equipment (including tires) and that have fallen onto a paved public roadway. 204 CONTROL MEASURE - A technique, practice, or procedure used to prevent or minimize the generation, emission, entrainment, suspension, and/or airborne transport of fugitive dust. Control measures include but are not limited to: 23 204.1 Curbing. 204.2 Paving. 204.3 Pre-wetting. 204.4 Applying dust suppressants. 204.5 Physically stabilizing with vegetation, gravel, recrushed/recycled asphalt or other forms of physical stabilization. 204.6 Limiting, restricting, phasing and/or rerouting motor vehicle access. 204.7 Reducing vehicle speeds and/or number of vehicle trips. 204.8 Limiting use of off-road vehicles on open areas and vacant lots. 204.9 Utilizing work practices and/or structural provisions to prevent wind and water erosion onto paved public roadways. 204.10 Appropriately using dust control implements. 204.11 Installing one or more grizzlies, gravel pads, and/or wash down pads adjacent to the entrance of a paved public roadway to control carryout and trackout. 204.12 Keeping open-bodied haul trucks in good repair, so that spillage may not occur from beds, sidewalls, and tailgates. 204.13 Covering the cargo beds of haul trucks to minimize windblown dust emissions and spillage. 205 DISTURBED SURFACE AREA - A portion of the earth's surface (or material placed thereupon) which has been physically moved, uncovered, destabilized, or otherwise modified from its undisturbed native condition, thereby increasing the potential for the emission of fugitive dust. For the purpose of this rule, an area is considered to be a disturbed surface area until the activity that caused the disturbance has been completed and the disturbed surface area meets the standards described in Section 301 and Section 302 of this rule. 206 DUST CONTROL IMPLEMENT - A tool, machine, equipment, accessory, structure, enclosure, cover, material or supply, including an adequate readily available supply of water and its associated distribution/delivery system, used to control fugitive dust emissions. 207 DUST CONTROL PLAN - A written plan describing all control measures. 208 DUST GENERATING OPERATION - Any activity capable of generating fugitive dust, including but not limited to, land clearing, earthmoving, weed abatement by discing or blading, excavating, construction, demolition, material handling, storage and/or transporting operations, vehicle use and movement, the operation of any outdoor equipment, or unpaved parking 24 lots. For the purpose of this rule, landscape maintenance and/or playing on a ballfield shall not be considered a dust generating operation. However, landscape maintenance shall not include grading, trenching, nor any other mechanized surface disturbing activities performed to establish initial landscapes or to redesign existing landscapes. 209 DUST SUPPRESSANT - Water, hygroscopic material, solution of water and chemical surfactant, foam, non-toxic chemical stabilizer or any other dust palliative, which is not prohibited for ground surface application by the U.S. Environmental Protection Agency (EPA) or the Arizona Department of Environmental Quality (ADEQ) or any applicable law, rule, or regulation, as a treatment material for reducing fugitive dust emissions. 210 EARTHMOVING OPERATION - The use of any equipment for an activity which may generate fugitive dust, such as but not limited to, cutting and filling, grading, leveling, excavating, trenching, loading or unloading of bulk materials, demolishing, blasting, drilling, adding to or removing bulk materials from open storage piles, back filling, soil mulching, landfill operations, or weed abatement by discing or blading. 211 FREEBOARD - The vertical distance between the top edge of a cargo container area and the highest point at which the bulk material contacts the sides, front, and back of a cargo container area. 212 FUGITIVE DUST - The particulate matter, which is not collected by a capture system, which is entrained in the ambient air, and which is caused from human and/or natural activities, such as but not limited to, movement of soil, vehicles, equipment, blasting, and wind. For the purpose of this rule, fugitive dust does not include particulate matter emitted directly from the exhaust of motor vehicles and other internal combustion engines, from portable brazing, soldering, or welding equipment, and from piledrivers, and does not include emissions from process and combustion sources that are subject to other rules in Regulation III (Control Of Air Contaminants) of these rules. 213 GRAVEL PAD - A layer of washed gravel, rock, or crushed rock which is at least one inch or larger in diameter, maintained at the point of intersection of a paved public roadway and a work site entrance to dislodge mud, dirt, and/or debris from the tires of motor vehicles and/or haul trucks, prior to leaving the work site. 214 GRIZZLY - A device (i.e., rails, pipes, or grates) used to dislodge mud, dirt, and/or debris from the tires and undercarriage of motor vehicles and/or haul trucks prior to leaving the work site. 215 HAUL TRUCK - Any fully or partially open-bodied self-propelled vehicle including any non-motorized attachments, such as but not limited to, trailers or other conveyances which are connected to or propelled by the actual motorized portion of the vehicle used for transporting bulk materials. 216 INTERMITTENT SOURCE - A fugitive dust generating operation and/or activity that lasts for a duration of less than six consecutive minutes. 25 217 MOTOR VEHICLE - A self-propelled vehicle for use on the public roads and highways of the State of Arizona and required to be registered under the Arizona State Uniform Motor Vehicle Act, including any non-motorized attachments, such as but not limited to, trailers or other conveyances which are connected to or propelled by the actual motorized portion of the vehicle. 218 NORMAL FARM CULTURAL PRACTICE - All activities by the owner, lessee, agent, independent contractor, and/or supplier conducted on any facility for the production of crops and/or nursery plants. Disturbances of the field surface caused by turning under stalks, tilling, leveling, planting, fertilizing, or harvesting are included in this definition. 219 OFF-ROAD VEHICLE - Any self-propelled conveyance specifically designed for off-road use, including but not limited to, off-road or all-terrain equipment, trucks, cars, motorcycles, motorbikes, or motorbuggies. 220 OPEN AREAS AND VACANT LOTS - Any of the following described in subsection 220.1 through subsection 220.4 of this rule. For the purpose of this rule, vacant portions of residential or commercial lots that are immediately adjacent and owned and/or operated by the same individual or entity are considered one vacant open area or vacant lot. 220.1 An unsubdivided or undeveloped tract of land adjoining a developed or a partially developed residential, industrial, institutional, governmental, or commercial area. 220.2 A subdivided residential, industrial, institutional, governmental, or commercial lot, which contains no approved or permitted buildings or structures of a temporary or permanent nature. 220.3 A partially developed residential, governmental, or commercial lot. industrial, institutional, 220.4 A tract of land, in the nonattainment area, adjoining agricultural property. 221 OWNER AND/OR OPERATOR - Any person who owns, leases, operates, controls, or supervises a dust generating operation subject to the requirements of this rule. 222 PAVE - To apply and maintain asphalt, concrete, or other similar material to a roadway surface (i.e., asphaltic concrete, concrete pavement, chip seal, or rubberized asphalt). 223 PUBLIC ROADWAYS - Any roadways that are open to public travel. 224 ROUTINE - Any dust generating operation which occurs more than 4 times per year or lasts 30 cumulative days or more per year. 225 SILT - Any aggregate material with a particle size less than 75 micrometers in diameter, which passes through a No. 200 Sieve. 26 226 TRACKOUT CONTROL DEVICE - A gravel pad, grizzly, wheel wash system, or a paved area, located at the point of intersection of an unpaved area and a paved roadway, that controls or prevents vehicular trackout. 227 UNPAVED HAUL/ACCESS ROAD - Any on-site unpaved road used by commercial, industrial, institutional, and/or governmental traffic. 228 UNPAVED PARKING LOT - Any area larger than 5,000 square feet that is not paved and that is used for parking, maneuvering, or storing motor vehicles. 229 UNPAVED ROAD - Any road or equipment path that is not paved. For the purpose of this rule, an unpaved road is not a horse trail, hiking path, bicycle path, or other similar path used exclusively for purposes other than travel by motor vehicles. 230 URBAN OR SUBURBAN OPEN AREA - The definition of urban or suburban open area is included in Section 220 (Definition Of Open Areas And Vacant Lots) of this rule. 231 VACANT LOT - The definition of vacant lot is included in Section 220 (Definition Of Open Areas And Vacant Lots) of this rule. 232 VACANT PARCEL - The definition of vacant parcel is included in Section 220 (Definition Of Open Areas And Vacant Lots) of this rule. 233 WIND-BLOWN DUST - Visible emissions from any disturbed surface area, which are generated by wind action alone. 234 WIND EVENT – When the 60-minute average wind speed is greater than 25 miles per hour. 235 WORK SITE - Any property upon which any dust generating operations and/or earthmoving operations occur. 27 SECTION 300 - STANDARDS 301 OPACITY LIMITATION FOR FUGITIVE DUST SOURCES: The owner and/or operator of a source engaging in dust generating operations shall not allow visible fugitive dust emissions to exceed 20% opacity. 301.1 Wind Event: Exceedances of the opacity limit that occur due to a wind event shall constitute a violation of the opacity limit. However, it shall be an affirmative defense in an enforcement action if the owner and/or operator demonstrates all of the following conditions: a. All control measures required were followed and 1 or more of the control measures in Table 2 were applied and maintained; b. The 20% opacity exceedance could not have been prevented by better application, implementation, operation, or maintenance of control measures; c. The owner and/or operator compiled and retained records, in accordance with Section 502 (Recordkeeping) of this rule; and d. The occurrence of a wind event on the day(s) in question is documented by records. The occurrence of a wind event must be determined by the nearest Maricopa County Environmental Services Department Air Quality Division monitoring station, from any other certified meteorological station, or by a wind instrument that is calibrated according to manufacturer’s standards and that is located at the site being checked. 301.2 Emergency Maintenance Of Flood Control Channels and Water Retention Basins: No opacity limitation shall apply to emergency maintenance of flood control channels and water retention basins, provided that control measures are implemented. 301.3 Vehicle Test And Development Facilities And Operations: No opacity limitation shall apply to vehicle test and development facilities and operations when dust is required to test and validate design integrity, product quality, and/or commercial acceptance, if such testing is not feasible within enclosed facilities. 302 STABILIZATION REQUIREMENTS FOR FUGITIVE DUST SOURCES: 302.1 Unpaved Parking Lot: The owner and/or operator of any unpaved parking lot shall not allow visible fugitive dust emissions to exceed 20% opacity, and either: a. Shall not allow silt loading equal to or greater than 0.33 oz/ft2; or 28 b. Shall not allow the silt content to exceed 8%. 302.2 Unpaved Haul/Access Road: The owner and/or operator of any unpaved haul/access road (whether at a work site that is under construction or at a work site that is temporarily or permanently inactive): a. b. Shall not allow visible fugitive dust emissions to exceed 20% opacity, and either: (1) Shall not allow silt loading equal to or greater than 0.33 oz/ft2; or (2) Shall not allow the silt content to exceed 6%. Shall, as an alternative to meeting the stabilization requirements for an unpaved haul/access road, limit vehicle trips to no more than 20 per day and limit vehicle speeds to no more than 15 miles per hour. If complying with subsection 302.2(b) of this rule, must include, in a Dust Control Plan, the number of vehicles traveled on the unpaved haul/access roads (i.e., number of employee vehicles, earthmoving equipment, haul trucks, and water trucks). 302.3 Open Area And Vacant Lot Or Disturbed Surface Area: The owner and/or operator of an open area and vacant lot or any disturbed surface area on which no activity is occurring (whether at a work site that is under construction, at a work site that is temporarily or permanently inactive) shall meet at least 1 of the standards described in subsection 302.3(a) through subsection 302.3(g) below, as applicable. The owner and/or operator of such inactive disturbed surface area shall be considered in violation of this rule if such inactive disturbed surface area is not maintained in a manner that meets at least 1 of the standards described in subsection 302.3(a) through subsection 302.3(g) below, as applicable. a. Maintain a visible crust; or b. Maintain a threshold friction velocity (TFV) for disturbed surface areas corrected for non-erodible elements of 100 cm/second or higher; or c. Maintain a flat vegetative cover (i.e., attached (rooted) vegetation or unattached vegetative debris lying on the surface with a predominant horizontal orientation that is not subject to movement by wind) that is equal to at least 50%; or d. Maintain a standing vegetative cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is equal to or greater than 30%; or 29 e. Maintain a standing vegetative cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is equal to or greater than 10% and where the threshold friction velocity is equal to or greater than 43 cm/second when corrected for non-erodible elements; or f. Maintain a percent cover that is equal to or greater than 10% for non-erodible elements; or g. Comply with a standard of an alternative test method, upon obtaining the written approval from the Control Officer and the Administrator of the Environmental Protection Agency (EPA). 302.4 Vehicle Test And Development Facilities And Operations: No stabilization requirement shall apply to vehicle test and development facilities and operations when dust is required to test and validate design integrity, product quality, and/or commercial acceptance, if such testing is not feasible within enclosed facilities. 303 DUST CONTROL PLAN REQUIRED: The owner and/or operator of a source shall submit to the Control Officer a Dust Control Plan with any permit applications that involve earthmoving operations which would equal or exceed 0.10 acre. Compliance with this section does not effect a source’s responsibility to comply with the other standards of this rule. The Dust Control Plan shall describe all control measures to be implemented before, after, and while conducting any dust generating operation, including during weekends, after work hours, and on holidays. 303.1 A Dust Control Plan shall, at a minimum, contain all the information described in Section 304 of this rule. The Control Officer shall approve, disapprove, or conditionally approve the Dust Control Plan, in accordance with the criteria used to approve, disapprove or conditionally approve a permit. Failure to comply with the provisions of an approved Dust Control Plan is deemed to be a violation of this rule. Regardless of whether an approved Dust Control Plan is in place or not, the owner and/or operator of a source is still subject to all requirements of this rule at all times. In addition, the owner and/or operator of a source with an approved Dust Control Plan is still subject to all of the requirements of this rule, even if such owner and/or operator is complying with the approved Dust Control Plan. 303.2 At least one primary control measure and one contingency control measure must be identified in the Dust Control Plan for all fugitive dust sources. Should any primary control measure(s) prove ineffective, the owner and/or operator shall immediately implement the contingency control measure(s), which may obviate the requirement of submitting a revised Dust Control Plan. 303.3 The following subsections, subsection 303.3(a) and subsection 303.3(b) of this rule, describe the permit applications with which a Dust Control Plan must be submitted. 30 a. If a person is required to obtain an Earthmoving Permit under Regulation II (Permits And Fees) of these rules, then such person must first submit a Dust Control Plan and obtain the Control Officer’s approval of the Dust Control Plan before commencing any dust generating operation. b. If a person is required to obtain or has obtained a Title V Permit, a Non-Title V, or a General Permit under Regulation II (Permits And Fees) of these rules, then such person must first submit a Dust Control Plan and obtain the Control Officer’s approval of the Dust Control Plan before commencing any routine dust generating operation. 303.4 A Dust Control Plan shall not be required: 304 a. To play on a ballfield and/or for landscape maintenance. For the purpose of this rule, landscape maintenance does not include grading, trenching, nor any other mechanized surface disturbing activities. b. To establish initial landscapes or to redesign existing landscapes of legally-designated public parks and recreational areas, including national parks, national monuments, national forests, state parks, city parks, and county regional parks, hiking paths, horse trails, bicycle paths, ballfields, playgrounds at camp sites, and camp sites, which are used exclusively for purposes other than travel by motor vehicles. For the purpose of this rule, establishing initial landscapes or redesigning existing landscapes does not include grading, trenching, nor any other mechanized surface disturbing activities. ELEMENTS OF A DUST CONTROL PLAN: A Dust Control Plan shall contain, at a minimum, all of the following information: 304.1 Names, address(es), and phone numbers of person(s) responsible for the submittal and implementation of the Dust Control Plan and responsible for the dust generating operation. 304.2 A drawing, on at least 8½” x 11” paper, which shows: a. Entire project site boundaries; b. Acres to be disturbed with linear dimensions; c. Nearest public roads; d. North arrow; and e. Planned exit locations onto paved public roadways. 304.3 Control measures or combination thereof to be applied to all actual and potential fugitive dust sources, before, after, and while 31 conducting any dust generating operation, including during weekends, after work hours, and on holidays. a. At least one primary control measure and one contingency control measure must be identified, from Table 1 of this rule, for all fugitive dust sources. Should any primary control measure(s) prove ineffective, the owner and/or operator shall immediately implement the contingency control measure(s), which may obviate the requirement of submitting a revised Dust Control Plan. b. Alternatively, a control measure(s) that is not in Table 1 of this rule may be chosen, provided that such control measure(s) is implemented to comply with the standard(s) described in Section 301 and Section 302 of this rule, as determined by the corresponding test method(s), as applicable, and must meet other applicable standard(s) set forth in this rule. c. If complying with subsection 302.2(b) (Stabilization Requirements For Fugitive Dust Sources-Unpaved Haul/Access Roads) of this rule, must include the number of vehicles traveled on the unpaved haul/access roads (i.e., number of employee vehicles, earthmoving equipment, haul trucks, and water trucks). 304.4 Dust suppressants to be applied, including product specifications or label instructions for approved usage: a. Method, frequency, and intensity of application. b. Type, number, and capacity of application equipment. c. Information on environmental impacts and approvals or certifications related to appropriate and safe use for ground application. 304.5 Specific surface treatment(s) and/or control measures utilized to control material trackout and sedimentation where unpaved and/or access points join paved public roadways. 305 DUST CONTROL PLAN REVISIONS: If the Control Officer determines that an approved Dust Control Plan has been followed, yet fugitive dust emissions from any given fugitive dust source still exceed Section 301 and Section 302 of this rule, then the Control Officer shall issue a written notice to the owner and/or operator of such source explaining such determination. The owner and/or operator of such source shall make written revisions to the Dust Control Plan and shall submit such revised Dust Control Plan to the Control Officer within three working days of receipt of the Control Officer’s written notice, unless such time period is extended by the Control Officer, upon request, for good cause. During the time that such owner and/or operator is preparing revisions to the approved Dust Control Plan, 32 such owner and/or operator must still comply with all requirements of this rule. 306 CONTROL MEASURES: The owner and/or operator of a source shall implement control measures before, after, and while conducting any dust generating operation, including during weekends, after work hours, and on holidays. See subsection 304.3, Table 1, and Table 2 of this rule. For the purpose of this rule, any control measure that is implemented must meet the applicable standard(s) described in Section 301 and in Section 302 of this rule, as determined by the corresponding test method(s), as applicable, and must meet other applicable standard(s) set forth in this rule. Failure to comply with the provisions of Section 308 (Work Practices) of this rule, as applicable, and/or of an approved Dust Control Plan, is deemed a violation of this rule. Regardless of whether an approved Dust Control Plan is in place or not, the owner and/or operator of a dust generating operation is still subject to all requirements of this rule at all times. In addition, the owner and/or operator of a dust generating operation with an approved Dust Control Plan is still subject to all of the requirements of this rule, even if such owner and/or operator of a dust generating operation is complying with the approved Dust Control Plan. 307 PROJECT INFORMATION SIGN: The owner and/or operator of a source shall erect a project information sign at the main entrance, that is visible to the public, of all sites with an Earthmoving Permit that are five acres or larger. Such sign shall be a minimum of four feet long by four feet wide, have a white background, have black block lettering which is at least four inches high, and shall contain the following information: 307.1 Project name; and 307.2 Name and phone number of person(s) responsible for conducting the project; and 307.3 Text stating: “Complaints? Call Maricopa County Environmental Services Department (insert the current/accurate phone number for the complaint phone line).” 308 WORK PRACTICES: When engaged in the following specific activities, the owner and/or operator of a source shall comply with the following work practices in addition to implementing, as applicable, the control measures described in Table 1 of this rule. Such work practices shall be implemented to meet the standards described in Section 301 and Section 302 of this rule. 308.1 Bulk Material Hauling Off-Site Onto Paved Public Roadways: a. Load all haul trucks such that the freeboard is not less than three inches; and b. Prevent spillage or loss of bulk material from holes or other openings in the cargo compartment’s floor, sides, and/or tailgate(s); and 33 c. Cover all haul trucks with a tarp or other suitable closure; d. Before the empty haul truck leaves the site, clean the interior of the cargo compartment or cover the cargo compartment. and 308.2 Bulk Material Hauling On-Site Within The Boundaries Of The Work Site: When crossing a public roadway upon which the public is allowed to travel while construction is underway: a. Load all haul trucks such that the freeboard is not less than three inches; and b. Prevent spillage or loss of bulk material from holes or other openings in the cargo compartment’s floor, sides, and/or tailgate(s); and c. Install a suitable trackout control device that controls and prevents trackout and/or removes particulate matter from tires and the exterior surfaces of haul trucks and/or motor vehicles that traverse such work site. Examples of trackout control devices are described in Table 1 (Trackout-1J, 2J, 3J) of this rule. 308.3 Spillage, Carry-Out, Erosion, And/Or Trackout: a. b. Install a suitable trackout control device (Examples of trackout control devices are described in Table 1 (Trackout1J, 2J, 3J) of this rule) that controls and prevents trackout and/or removes particulate matter from tires and the exterior surfaces of haul trucks and/or motor vehicles that traverse such work site at all exits onto a paved public roadway: (1) From all work sites with a disturbed surface area of five acres or larger. (2) From all work sites where 100 cubic yards of bulk materials are hauled on-site and/or off-site per day. Cleanup spillage, carry-out, erosion, and/or trackout on the following time-schedule: (1) Immediately, when spillage, carry-out, and/or trackout extends a cumulative distance of 50 linear feet or more; or (2) At the end of the work day, when spillage, carry-out, erosion, and/or trackout are other than the spillage, carry-out, erosion, and/or trackout described above, in subsection 308.3(b)(1) of this rule. 308.4 Unpaved Haul/Access Roads: Implement 1 or more control measure(s) described in Table 1 (Unpaved Haul/Access Roads-1C 34 through 5C) of this rule, before engaging in the use of or in the maintenance of unpaved haul/access roads. 308.5 Easements, Rights-Of-Way, And Access Roads For Utilities (Electricity, Natural Gas, Oil, Water, And Gas Transmission) Associated With Sources That Have A Non-Title V Permit, A Title V Permit, And/Or A General Permit Under These Rules: a. Inside the PM10 nonattainment area, restrict vehicular speeds to 15 miles per hour and vehicular trips to no more than 20 per day; or b. Outside the PM10 nonattainment area, restrict vehicular trips to no more than 20 per day; or c. Implement control measures, as described in Table 1 (Unpaved Haul/Access Roads-1C through 5C) of this rule. 308.6 Open Storage Piles: For the purpose of this rule, an open storage pile is any accumulation of bulk material with a 5% or greater silt content which in any one point attains a height of three feet and covers a total surface area of 150 square feet or more. Silt content shall be assumed to be 5% or greater unless a person can show, by testing in accordance with ASTM Method C136-96A or other equivalent method approved in writing by the Control Officer and the Administrator of EPA, that the silt content is less than 5%. a. During stacking, loading, and unloading operations, apply water, as necessary, to maintain compliance with Section 301 of this rule; and b. When not conducting stacking, loading, and unloading operations, comply with one of the following work practices: (1) Cover open storage piles with tarps, plastic, or other material to prevent wind from removing the coverings; or (2) Apply water to maintain a soil moisture content at a minimum of 12%, as determined by ASTM Method D2216-98, or other equivalent as approved by the Control Officer and the Administrator of EPA. For areas which have an optimum moisture content for compaction of less than 12%, as determined by ASTM Method D1557-91(1998) or other equivalent approved by the Control Officer and the Administrator of EPA, maintain at least 70% of the optimum soil moisture content; or (3) Meet one of the stabilization requirements described in subsection 302.3 of this rule; or 35 (4) Construct and maintain wind barriers, storage silos, or a three-sided enclosure with walls, whose length is no less than equal to the length of the pile, whose distance from the pile is no more than twice the height of the pile, whose height is equal to the pile height, and whose porosity is no more than 50%. If implementing this subsection, subsection 308.6(b)(4), must also implement either subsection 308.6(b)(2) or subsection 308.6(b)(3) above. 308.7 Earthmoving Operations On Disturbed Surface Areas 1 Acre Or Larger: If water is the chosen control measure, operate water application system (e.g., water truck) while conducting earthmoving operations on disturbed surface areas 1 acre or larger. 308.8 Weed Abatement By Discing Or Blading: a. Apply water before weed abatement by discing or blading occurs; and b. Apply water while weed abatement by discing or blading is occurring; and c. Pave, apply gravel, apply water, or apply a suitable dust suppressant, in compliance with subsection 302.3 of this rule, after weed abatement by discing or blading occurs; or d. Establish vegetative ground cover in sufficient quantity, in compliance with subsection 302.3 of this rule, after weed abatement by discing or blading occurs. SECTION 400 - ADMINISTRATIVE REQUIREMENTS 401 DUST CONTROL PLAN POSTING: The owner and/or operator of a source shall post a copy of the approved Dust Control Plan in a conspicuous location at the work site, within on-site equipment, or in an on-site vehicle, or shall otherwise keep a copy of the approved Dust Control Plan available onsite at all times. The owner and/or operator of a source that has been issued a Block Permit shall not be required to keep a copy of the plot plan, an element of a Dust Control Plan, on-site. 402 COMPLIANCE SCHEDULE: The requirements of this rule supercede any conflicting requirements that may be found in existing Dust Control Plans. 402.1 For Earthmoving Permits: If any changes to a Dust Control Plan, associated with an Earthmoving Permit, are necessary as a result of the most recent revisions of this rule, such changes shall not be required until the Earthmoving Permit is required to be renewed. 402.2 For Non-Title V Permits And For Title V Permits: If any changes to a Dust Control Plan, associated with a Non-Title V Permit or with a Title V Permit, are necessary as a result of the most recent revisions of this rule, then the owner and/or operator shall submit a 36 revised Dust Control Plan to the Control Officer, according to the minor permit revision procedures described in Rule 220 and Rule 210 of these rules respectively, no later than 6 months after the effective date of the most recent revisions to this rule. SECTION 500 - MONITORING AND RECORDS 501 COMPLIANCE DETERMINATION: To determine compliance with this rule, the following test methods shall be conducted: 501.1 Opacity Observations: a. Dust Generating Operations: Opacity observations of a source engaging in dust generating operations shall be conducted in accordance with Appendix C, Section 3 (Visual Determination Of Opacity Of Emissions From Sources For Time-Averaged Regulations) of these rules, except opacity observations for intermittent sources shall require 12 rather than 24 consecutive readings at 15-second intervals for the averaging time. b. Unpaved Parking Lot: Opacity observations of any unpaved parking lot shall be conducted in accordance with Appendix C, Section 2.1 (Test Methods For Stabilization-For Unpaved Roads And Unpaved Parking Lots) of these rules. c. Unpaved Haul/Access Road: Opacity observations of any unpaved haul/access road (whether at a work site that is under construction or at a work site that is temporarily or permanently inactive) shall be conducted in accordance with Appendix C, Section 2.1 (Test Methods For Stabilization-For Unpaved Roads And Unpaved Parking Lots) of these rules. 501.2 Stabilization Observations: a. Unpaved Parking Lot: Stabilization observations for unpaved parking lots shall be conducted in accordance with Appendix C, Section 2.1 (Test Methods For Stabilization-For Unpaved Roads And Unpaved Parking Lots) of these rules. When more than 1 test method is permitted for a determination, an exceedance of the limits established in this rule determined by any of the applicable test methods constitutes a violation of this rule. b. Unpaved Haul/Access Road: Stabilization observations for unpaved haul/access roads (whether at a work site that is under construction or at a work site that is temporarily or permanently inactive) shall be conducted in accordance with Appendix C, Section 2.1 (Test Methods For Stabilization-For Unpaved Roads And Unpaved Parking Lots) of these rule. When more than 1 test method is permitted for a determination, an exceedance of the limits established in this 37 rule determined by any of the applicable test methods constitutes a violation of this rule. c. Open Area And Vacant Lot Or Disturbed Surface Area: Stabilization observations for an open area and vacant lot or any disturbed surface area on which no activity is occurring (whether at a work site that is under construction, at a work site that is temporarily or permanently inactive) shall be conducted in accordance with at least one of the techniques described in subsection 501.2(c)(1) through subsection 501.2(c)(7) below, as applicable. The owner and/or operator of such inactive disturbed surface area shall be considered in violation of this rule if such inactive disturbed surface area is not maintained in a manner that meets at least 1 of the standards described in subsection 302.3 of this rule, as applicable. (1) Appendix C, Section 2.3 (Test Methods For Stabilization-Visible Crust Determination) (The Drop Ball/Steel Ball Test) of these rules for a visible crust; or (2) Appendix C, Section 2.4 (Test Methods For Stabilization-Determination Of Threshold Friction Velocity (TFV)) (Sieving Field Procedure) of these rules for threshold friction velocity (TFV) corrected for non-erodible elements of 100 cm/second or higher; or (3) Appendix C, Section 2.5 (Test Methods For Stabilization-Determination Of Flat Vegetative Cover) of these rules for flat vegetation cover (i.e., attached (rooted) vegetation or unattached vegetative debris lying on the surface with a predominant horizontal orientation that is not subject to movement by wind) that is equal to at least 50%; or (4) Appendix C, Section 2.6 (Test Methods For Stabilization-Determination Of Standing Vegetative Cover) of these rules for standing vegetation cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is equal to or greater than 30%; or (5) Appendix C, Section 2.6 (Test Methods For Stabilization-Determination Of Standing Vegetative Cover) of these rules for standing vegetation cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is equal to or greater than 10% and where the threshold friction velocity is equal to or greater than 43 cm/second when corrected for non-erodible elements; or 38 (6) Appendix C, Section 2.7 (Test Methods For Stabilization-Rock Test Method) of these rules for a percent cover that is equal to or greater than 10%, for non-erodible elements; or (7) An alternative test method approved in writing by the Control Officer and the Administrator of the EPA. 502 RECORDKEEPING: Any person who conducts dust generating operations that require a Dust Control Plan shall keep a daily written log recording the actual application or implementation of the control measures delineated in the approved Dust Control Plan. Any person who conducts dust generating operations which do not require a Dust Control Plan shall compile and retain records that provide evidence of control measure application, by indicating the type of treatment or control measure, extent of coverage, and date applied. Upon verbal or written request by the Control Officer, the log or the records and supporting documentation shall be provided within 48 hours, excluding weekends. If the Control Officer is at the site where requested records are kept, records shall be provided without delay. 503 RECORDS RETENTION: Copies of approved Dust Control Plans, control measures implementation records, and all supporting documentation shall be retained for at least six months following the termination of the dust generating operation. Copies of approved Dust Control Plans, control measures implementation records, and all supporting documentation shall be retained for at least 1 year from the date such records were initiated. If a person has obtained a Title V Permit and is subject to the requirements of this rule, then such person shall retain records required by this rule for at least 5 years from the date such records are established. 504 TEST METHODS ADOPTED BY REFERENCE: The test methods listed in this section are adopted by reference. These adoptions by reference include no future editions or amendments. Copies of the test methods listed in this section are available for review at the Maricopa County Environmental Services Department, 1001 North Central Avenue, Phoenix, AZ, 850041942. 504.1 ASTM Method C136-96A (“Standard Test Method For Sieve Analysis Of Fine And Coarse Aggregates”), 1996 edition. 504.2 ASTM Method D2216-98 (“Standard Test Method For Laboratory Determination Of Water (Moisture) Content Of Soil And Rock By Mass”), 1998 edition. 504.3 ASTM Method 1557-91(1998) (“Test Method For Laboratory Compaction Characteristics Of Soil Using Modified Effort (56,000 ftlbf/ft3 (2,700 kN-m/m3)”), 1998 edition. 39 TABLE 1 SOURCE TYPE AND CONTROL MEASURES Vehicle Use In Open Areas And Vacant Lots: 1A Restrict trespass by installing signs. 2A Install physical barriers such as curbs, fences, gates, posts, signs, shrubs, and/or trees to prevent access to the area. Unpaved Parking Lots: 1B Pave. 2B Apply and maintain gravel, recycled asphalt, or other suitable material, in compliance with subsection 302.1 of this rule. 3B Apply a suitable dust suppressant, in compliance with subsection 302.1 of this rule. Unpaved Haul/Access Roads: (The control measures listed below (1C-5C) are required work practices, per subsection 308.4 of this rule.) 1C Limit vehicle speed to 15 miles per hour or less and limit vehicular trips to no more than 20 per day. 2C Apply water, so that the surface is visibly moist and subsection 302.2 of this rule is met. 3C Pave. 4C Apply and maintain gravel, recycled asphalt, or other suitable material, in compliance with subsection 302.2 of this rule. 5C Apply a suitable dust suppressant, in compliance with subsection 302.2 of this rule. Disturbed Surface Areas: Pre-Activity: 1D Pre-water site to the depth of cuts. 2D Phase work to reduce the amount of disturbed surface areas at any one time. During Dust Generating Operations: 3D Apply water or other suitable dust suppressant, in compliance with Section 301 of this rule. 4D Apply water as necessary to maintain a soil moisture content at a minimum of 12%, as determined by ASTM Method D2216-98 or other equivalent as approved by the Control Officer and the Administrator of EPA. For areas which have an optimum moisture content for compaction of less than 12%, as determined by ASTM Method D1557-91(1998) or other equivalent approved by the Control Officer and the Administrator of EPA, maintain at least 70% of the optimum soil moisture content. 5D Construct fences or 3 foot - 5 foot high wind barriers with 50% or less porosity adjacent to roadways or urban areas that reduce the amount of wind blown material leaving a site. If constructing fences or wind barriers, must also implement 3D or 4D above. Temporary Stabilization During Weekends, After Work Hours, And On Holidays: 6D Apply a suitable dust suppressant, in compliance with subsection 302.3 of this rule. 7D Establish vegetative ground cover in sufficient quantity, in compliance with subsection 302.3 of this rule. 8D Restrict vehicular access to the area, in addition to either of the control measures described in 6D and 7D above. Permanent Stabilization (Required Within 8 Months Of Ceasing Dust Generating Operations): 9D Restore area such that the vegetative ground cover and soil characteristics are similar to 40 adjacent or nearby undisturbed native conditions, in compliance with subsection 302.3 of this rule. 10D Pave, apply gravel, or apply a suitable dust suppressant, in compliance with subsection 302.3 of this rule. 11D Establish vegetative ground cover in sufficient quantity, in compliance with subsection 302.3 of this rule. Open Areas And Vacant Lots: 1E Restore area such that the vegetative ground cover and soil characteristics are similar to adjacent or nearby undisturbed native conditions. 2E Pave, apply gravel, or apply a suitable dust suppressant, in compliance with subsection 302.3 of this rule. 3E Establish vegetative ground cover in sufficient quantity, in compliance with subsection 302.3 of this rule. Control measures 1F – 1M below are required work practices and/or methods designed to meet the work practices, per Section 308 (Work Practices) of this rule. Bulk Material Handling Operations And Open Storage Piles: During Stacking, Loading, And Unloading Operations: 1F Apply water as necessary, to maintain compliance with Section 301 of this rule; and When Not Conducting Stacking, Loading, And Unloading Operations: 2F Cover open storage piles with tarps, plastic, or other material to prevent wind from removing the coverings; or 3F Apply water to maintain a soil moisture content at a minimum of 12%, as determined by ASTM Method D2216-98, or other equivalent as approved by the Control Officer and the Administrator of EPA. For areas which have an optimum moisture content for compaction of less than 12%, as determined by ASTM Method D1557-91(1998) or other equivalent approved by the Control Officer and the Administrator of EPA, maintain at least 70% of the optimum soil moisture content; or 4F Meet the stabilization requirements described in subsection 302.3 of this rule; or 5F Construct and maintain wind barriers, storage silos, or a three-sided enclosure with walls, whose length is no less than equal to the length of the pile, whose distance from the pile is no more than twice the height of the pile, whose height is equal to the pile height, and whose porosity is no more than 50%. If implementing 5F, must also implement 3F or 4F above. Bulk Material Hauling/Transporting: When On-Site Hauling/Transporting Within The Boundaries Of The Work Site When Crossing A Public Roadway Upon Which The Public Is Allowed To Travel While Construction Is Underway: 1G Load all haul trucks such that the freeboard is not less than 3 inches when crossing a public roadway upon which the public is allowed to travel while construction is underway; and 2G Prevent spillage or loss of bulk material from holes or other openings in the cargo compartment’s floor, sides, and/or tailgate(s); and 3G Install a suitable trackout control device that controls and prevents trackout and/or removes particulate matter from tires and the exterior surfaces of haul trucks and/or motor vehicles that traverse such work site. Examples of trackout control devices are described in Table 1 (Trackout 1J, 2J, 3J) of this rule; and 41 When On-Site Hauling/Transporting Within The Boundaries Of The Work Site But Not Crossing A Public Roadway Upon Which The Public Is Allowed To Travel While Construction Is Underway: 4G Limit vehicular speeds to 15 miles per hour or less while traveling on the work site; or 5G Apply water to the top of the load such that the 20% opacity standard, as described in Section 301 of this rule, is not exceeded, or cover haul trucks with a tarp or other suitable closure. Off-Site Hauling/Transporting Onto Paved Public Roadways: 6G Cover haul trucks with a tarp or other suitable closure; and 7G Load all haul trucks such that the freeboard is not less than 3 inches; and 8G Prevent spillage or loss of bulk material from holes or other openings in the cargo compartment’s floor, sides, and/or tailgate(s); and 9G Before the empty haul truck leaves the site, clean the interior of the cargo compartment or cover the cargo compartment. Cleanup Of Spillage, Carry Out, Erosion, And/Or Trackout: 1H Operate a street sweeper or wet broom with sufficient water, if applicable, at the speed recommended by the manufacturer and at the frequency(ies) described in subsection 308.3 of this rule; or 2H Manually sweep-up deposits. Trackout: 1J Install a grizzly or wheel wash system at all access points. 2J At all access points, install a gravel pad at least 30 feet wide, 50 feet long, and 6 inches deep. 3J Pave starting from the point of intersection with a paved public roadway and extending for a centerline distance of at least 100 feet and a width of at least 20 feet. Weed Abatement By Discing Or Blading: 1K Pre-water site and implement 3K or 4K below. 2K Apply water while weed abatement by discing or blading is occurring and implement 3K or 4K below. 3K Pave, apply gravel, apply water, or apply a suitable dust suppressant, in compliance with subsection 302.3 of this rule, after weed abatement by discing or blading occurs; or 4K Establish vegetative ground cover in sufficient quantity, in compliance with subsection 302.3 of this rule, after weed abatement by discing or blading occurs. Easements, Rights-Of-Way, And Access Roads For Utilities (Electricity, Natural Gas, Oil, Water, And Gas Transmission) Associated With Sources That Have A Non-Title V Permit, A Title V Permit, And/Or A General Permit Under These Rules: 1L Inside the PM10 nonattainment area, restrict vehicular speeds to 15 miles per hour and vehicular trips to no more than 20 per day; or 2L Outside the PM10 nonattainment area, restrict vehicular trips to no more than 20 per day; or 3L Implement control measures, as described in Table 1 (Unpaved Haul/Access Roads-1C through 5C) of this rule. Earthmoving Operations On Disturbed Surface Areas 1 Acre Or Larger: 1M If water is the chosen control measure, operate water application system (e.g., water truck), while conducting earthmoving operations on disturbed surface areas 1 acre or larger. 42 TABLE 2 Note: Control measures in [brackets] are to be applied only to sources outside the nonattainment area. SOURCE TYPE AND WIND EVENT CONTROL MEASURES Dust Generating Operations: 1A Cease dust generating operations for the duration of the condition/situation/event when the 60-minute average wind speed is greater than 25 miles per hour. If dust generating operations are ceased for the remainder of the work day, stabilization measures must be implemented; or 2A Apply water or other suitable dust suppressant twice [once] per hour, in compliance with Section 301 of this rule; or 3A Apply water as necessary to maintain a soil moisture content at a minimum of 12%, as determined by ASTM Method D2216-98 or other equivalent as approved by the Control Officer and the Administrator of EPA. For areas which have an optimum moisture content for compaction of less than 12%, as determined by ASTM Method D1557-91(1998) or other equivalent approved by the Control Officer and the Administrator of EPA, maintain at least 70% of the optimum soil moisture content; or 4A Construct fences or 3 foot - 5 foot high wind barriers with 50% or less porosity adjacent to roadways or urban areas that reduce the amount of wind-blown material leaving a site. If implementing 4A, must also implement 2A or 3A above. Temporary Disturbed Surface Areas (After Work Hours, Weekends, Holidays): 1B Uniformly apply and maintain surface gravel or dust suppressants, in compliance with subsection 302.3 of this rule; or 2B Apply water to all disturbed surface areas three times per day. If there is any evidence of wind-blown dust, increase watering frequency to a minimum of four times per day; or 3B Apply water on open storage piles twice [once] per hour, in compliance with subsection 302.3 of this rule; or 4B Cover open storage piles with tarps, plastic, or other material to prevent wind from removing the coverings; or 5B Utilize any combination of the control measures described in 1B, 2B, 3B, and 4B above, such that, in total, these control measures apply to all disturbed surface areas. 43 Appendix A-2 44 REGULATION III - CONTROL OF AIR CONTAMINANTS RULE 310.01 FUGITIVE DUST FROM OPEN AREAS, VACANT LOTS, UNPAVED PARKING LOTS, AND UNPAVED ROADWAYS INDEX SECTION 100 - GENERAL 101 PURPOSE 102 APPLICABILITY SECTION 200 - DEFINITIONS 201 BULK MATERIAL 202 CHEMICAL/ORGANIC STABILIZER 203 COMMERCIAL FEEDLOTS AND/OR COMMERCIAL LIVESTOCK AREAS 204 CONTROL MEASURE 205 DISTURBED SURFACE AREA 206 DUST SUPPRESSANT 207 FUGITIVE DUST 208 MOTOR VEHICLE 209 NORMAL FARM CULTURAL PRACTICE 210 OFF-ROAD VEHICLE 211 OPEN AREAS AND VACANT LOTS 212 OWNER AND/OR OPERATOR 213 PAVE 214 PUBLIC ROADWAYS 215 UNPAVED PARKING LOT 216 UNPAVED ROADWAY (INCLUDING ALLEYS) 217 VACANT LOT SECTION 300 - STANDARDS 301 VEHICLE USE IN OPEN AREAS AND VACANT LOTS 302 OPEN AREAS AND VACANT LOTS 303 UNPAVED PARKING LOTS 304 UNPAVED ROADWAYS (INCLUDING ALLEYS) 45 305 COMMERCIAL FEEDLOTS AND/OR COMMERCIAL LIVESTOCK AREAS 306 EROSION-CAUSED DEPOSITION OF BULK MATERIALS ONTO PAVED SURFACES 307 EASEMENTS, RIGHTS-OF-WAY, AND ACCESS ROADS FOR UTILITIES (ELECTRICITY, NATURAL GAS, OIL, WATER, AND GAS TRANSMISSION) SECTION 400 - ADMINISTRATIVE REQUIREMENTS (NOT APPLICABLE) SECTION 500 - MONITORING AND RECORDS 501 STABILIZATION OBSERVATIONS 502 RECORDKEEPING 503 RECORDS RETENTION 46 Adopted 06/16/99 Revised 02/16/00 MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS REGULATION III - CONTROL OF AIR CONTAMINANTS RULE 310.01 FUGITIVE DUST FROM OPEN AREAS, VACANT LOTS, UNPAVED PARKING LOTS, AND UNPAVED ROADWAYS SECTION 100 - GENERAL 101 PURPOSE: To limit the emission of particulate matter into the ambient air from open areas, vacant lots, unpaved parking lots, and unpaved roadways which are not regulated by Rule 310 (Fugitive Dust Sources) of these rules and which do not require a permit nor a Dust Control Plan. The effect of this rule shall be to minimize the amount of fine particulate matter (PM10) entrained into the ambient air as a result of the impact of human activities by requiring measures to prevent, reduce, or mitigate particulate matter emissions. 102 APPLICABILITY: The provisions of this rule shall apply to open areas, vacant lots, unpaved parking lots, and unpaved roadways which are not regulated by Rule 310 (Fugitive Dust Sources) of these rules and which do not require a permit nor a Dust Control Plan. In addition, the provisions of this rule shall apply to any open area or vacant lot that is not defined as agricultural land and is not used for agricultural purposes according to Arizona Revised Statutes (ARS) §42-12151 and ARS §42-12152. The provisions of this rule shall not apply to normal farm cultural practices according to ARS §49-457 and ARS §49-504.4. SECTION 200 - DEFINITIONS: For the purpose of this rule, the following definitions shall apply. See Rule 100 (General Provisions And Definitions) of these rules for definitions of terms that are used but not specifically defined in this rule. 201 BULK MATERIAL - Any material, including but not limited to, earth, rock, silt, sediment, sand, gravel, soil, fill, aggregate less than 2 inches in length or diameter (i.e., aggregate base course (ABC)), dirt, mud, demolition debris, cotton, trash, cinders, pumice, saw dust, feeds, grains, fertilizers, and dry concrete. 202 CHEMICAL/ORGANIC STABILIZER - Any non-toxic chemical or organic dust suppressant, other than water, which meets any specifications, criteria, or tests required by any Federal, State, or local water agency and is not prohibited for use by any applicable law, rule, or regulation. 203 COMMERCIAL FEEDLOTS AND/OR COMMERCIAL LIVESTOCK AREAS - Any operation directly related to feeding animals, displaying animals, racing animals, exercising animals, and/or for any other such activity, for the primary purpose of livelihood. 47 204 CONTROL MEASURE - A technique, practice, or procedure used to prevent or minimize the generation, emission, entrainment, suspension, and/or airborne transport of fugitive dust. 205 DISTURBED SURFACE AREA - A portion of the earth's surface (or material placed thereupon) which has been physically moved, uncovered, destabilized, or otherwise modified from its undisturbed native condition, thereby increasing the potential for the emission of fugitive dust. For the purpose of this rule, an area is considered to be a disturbed surface area until the activity that caused the disturbance has been completed and the disturbed surface area meets the standards described in Section 501 of this rule, as applicable. 206 DUST SUPPRESSANT - Water, hygroscopic material, solution of water and chemical surfactant, foam, non-toxic chemical stabilizer or any other dust palliative which is not prohibited for ground surface application by the Environmental Protection Agency (EPA) or the Arizona Department of Environmental Quality (ADEQ) or any applicable law, rule, or regulation, as a treatment material for reducing fugitive dust emissions. 207 FUGITIVE DUST - The particulate matter, which is not collected by a capture system, which is entrained in the ambient air and which is caused from human and/or natural activities, such as but not limited to, movement of soil, vehicles, equipment, blasting, and wind. For the purpose of this rule, fugitive dust does not include particulate matter emitted directly from the exhaust of motor vehicles and other internal combustion engines, from portable brazing, soldering, or welding equipment, and from piledrivers, and does not include emissions from process and combustion sources that are subject to other rules in Regulation III (Control Of Air Contaminants) of these rules. 208 MOTOR VEHICLE - A self-propelled vehicle for use on the public roads and highways of the State of Arizona and required to be registered under the Arizona State Uniform Motor Vehicle Act, including any non-motorized attachments, such as but not limited to, trailers or other conveyances which are connected to or propelled by the actual motorized portion of the vehicle. 209 NORMAL FARM CULTURAL PRACTICE - All activities by the owner, lessee, agent, independent contractor, and/or supplier conducted on any facility for the production of crops and/or nursery plants. Disturbances of the field surface caused by turning under stalks, tilling, leveling, planting, fertilizing, or harvesting are included in this definition. 210 OFF-ROAD VEHICLE - Any self-propelled conveyance specifically designed for off-road use, including but not limited to, off-road or all-terrain equipment, trucks, cars, motorcycles, motorbikes, or motorbuggies. 211 OPEN AREAS AND VACANT LOTS - Any of the following described in subsection 211.1 through subsection 211.4 of this rule. For the purpose of this rule, vacant portions of residential or commercial lots that are immediately adjacent and owned and/or operated by the same individual or entity are considered one vacant open area or vacant lot. 48 211.1 An unsubdivided or undeveloped tract of land adjoining a developed or a partially developed residential, industrial, institutional, governmental, or commercial area. 211.2 A subdivided residential, industrial, institutional, governmental, or commercial lot, which contains no approved or permitted buildings or structures of a temporary or permanent nature. 211.3 A partially developed residential, governmental, or commercial lot. industrial, institutional, 211.4 A tract of land, in the nonattainment area, adjoining agricultural property. 212 OWNER AND/OR OPERATOR - Any person who owns, leases, operates, controls, or supervises a fugitive dust source subject to the requirements of this rule. 213 PAVE - To apply and maintain asphalt, concrete, or other similar material to a roadway surface (i.e., asphaltic concrete, concrete pavement, chip seal, or rubberized asphalt). 214 PUBLIC ROADWAYS - Any roadways that are open to public travel. 215 UNPAVED PARKING LOT - Any area larger than 5,000 square feet that is not paved and that is used for parking, maneuvering, or storing motor vehicles. 216 UNPAVED ROADWAY (INCLUDING ALLEYS) - A road that is not paved and that is owned by Federal, State, county, municipal, or other governmental or quasi-governmental agencies. For the purpose of this rule, an unpaved roadway (including alleys) is not a horse trail, hiking path, bicycle path, or other similar path used exclusively for purposes other than travel by motor vehicles. 217 VACANT LOT - The definition of vacant lot is included in Section 211 (Definition Of Open Areas And Vacant Lots) of this rule. SECTION 300 - STANDARDS 301 VEHICLE USE IN OPEN AREAS AND VACANT LOTS: If open areas and vacant lots are 0.10 acre or larger and have a cumulative of 500 square feet or more that are driven over and/or used by motor vehicles and/or off-road vehicles, then the owner and/or operator of such open areas and vacant lots shall implement one of the control measures described in subsection 301.1 of this rule within 60 calendar days following the initial discovery of vehicle use on open areas and vacant lots. For the purpose of this rule, such control measures shall be considered effectively implemented when the open areas and vacant lots meet one of the stabilization limitations described in subsection 301.2 of this rule. Use of or parking on open areas and vacant lots by the owner and/or operator of such open areas and vacant lots and/or landscape 49 maintenance of such open areas and vacant lots shall not be considered vehicle use in open areas and vacant lots. For the purpose of this rule, landscape maintenance does not include grading, trenching, nor any other mechanized surface disturbing activities performed to establish initial landscapes or to redesign existing landscapes. 301.1 Control Measures: a. Prevent motor vehicle and/or off-road vehicle trespassing, parking, and/or access, by installing barriers, curbs, fences, gates, posts, signs, shrubs, trees, or other effective control measures. Once vehicular traffic has been restricted from an open area or a vacant lot, such open area or vacant lot is no longer subject to the requirements of Section 301 of this rule, but rather such open area and vacant lot is subject to the requirements of Section 302 (Open Areas And Vacant Lots) of this rule. b. Uniformly apply and maintain surface gravel or chemical/organic stabilizers to all areas disturbed by motor vehicles and/or off-road vehicles in compliance with one of the stabilization limitations described in subsection 301.2 of this rule. c. Apply and maintain an alternative control measure approved in writing by the Control Officer and the Administrator of the Environmental Protection Agency (EPA). 301.2 Stabilization Limitations: a. A visible crust shall be implemented, as determined by Appendix C, Section 2.3 (Test Methods For StabilizationVisible Crust Determination) (The Drop Ball/Steel Ball Test) of these rules; or b. A threshold friction velocity (TFV) corrected for nonerodible elements of 100 cm/second or higher shall be implemented, as determined by Appendix C, Section 2.4 (Test Methods For Stabilization-Determination Of Threshold Friction Velocity (TFV)) (Sieving Field Procedure) of these rules; or c. Flat vegetative cover (i.e., attached (rooted) vegetation or unattached vegetative debris lying on the surface with a predominant horizontal orientation that is not subject to movement by wind) that is equal to at least 50% shall be implemented, as determined by Appendix C, Section 2.5 (Test Methods For Stabilization-Determination Of Flat Vegetative Cover) of these rules; or d. Standing vegetative cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is 50 equal to or greater than 30% shall be implemented, as determined by Appendix C, Section 2.6 (Test Methods For Stabilization-Determination Of Standing Vegetative Cover) of these rules; or 302 e. Standing vegetative cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is equal to or greater than 10% and where the threshold friction velocity is equal to or greater than 43 cm/second when corrected for non-erodible elements shall be implemented, as determined by Appendix C, Section 2.6 (Test Methods For Stabilization-Determination Of Standing Vegetative Cover) of these rules; or f. A percent cover that is equal to or greater than 10% for non-erodible elements shall be implemented, as determined by Appendix C, Section 2.7 (Test Methods For Stabilization-Rock Test Method) of these rules; or g. An alternative test method approved in writing by the Control Officer and the Administrator of the Environmental Protection Agency (EPA) shall be implemented. OPEN AREAS AND VACANT LOTS: If open areas and vacant lots have 0.5 acre or more of disturbed surface area and remain unoccupied, unused, vacant, or undeveloped for more than 15 days, then the owner and/or operator of such open areas and vacant lots shall implement one of the control measures described in subsection 302.1 of this rule within 60 calendar days following the initial discovery of the disturbance on the open areas and vacant lots. For the purpose of this rule, such control measures shall be considered effectively implemented when the open areas and vacant lots meet one of the stabilization limitations described in subsection 302.2 of this rule. 302.1 Control Measures: a. Establish vegetative ground cover on all disturbed surface areas within 60 calendar days following the initial discovery of the disturbance. Such control measure(s) must be maintained and reapplied, if necessary, until the disturbed surface areas are stabilized, in compliance with one of the stabilization limitations described in subsection 302.2 of this rule. Stabilization shall be achieved, per this control measure, within eight months after the control measure has been implemented. b. Apply a dust suppressant to all disturbed surface areas, in compliance with one of the stabilization limitations described in subsection 302.2 of this rule. c. Restore all disturbed surface areas within 60 calendar days following the initial discovery of the disturbance, such that the vegetative ground cover and soil characteristics 51 are similar to adjacent or nearby undisturbed native conditions. Such control measure(s) must be maintained and reapplied, if necessary, until the disturbed surface areas are stabilized, in compliance with one of the stabilization limitations described in subsection 302.2 of this rule. Stabilization shall be achieved, per this control measure, within eight months after the control measure has been implemented. d. Uniformly apply and maintain surface gravel, in compliance with one of the stabilization limitations described in subsection 302.2 of this rule. e. Apply and maintain an alternative control measure approved in writing by the Control Officer and the Administrator of the Environmental Protection Agency (EPA). 302.2 Stabilization Limitations: a. A visible crust shall be implemented, as determined by Appendix C, Section 2.3 (Test Methods For StabilizationVisible Crust Determination) (The Drop Ball/Steel Ball Test) of these rules; or b. A threshold friction velocity (TFV), corrected for nonerodible elements of 100 cm/second or higher, shall be implemented, as determined by Appendix C, Section 2.4 (Test Methods For Stabilization-Determination Of Threshold Friction Velocity (TFV)) (Sieving Field Procedure) of these rules; or c. Flat vegetative cover (i.e., attached (rooted) vegetation or unattached vegetative debris lying on the surface with a predominant horizontal orientation that is not subject to movement by wind) that is equal to at least 50% shall be implemented, as determined by Appendix C, Section 2.5 (Test Methods For Stabilization-Determination Of Flat Vegetative Cover) of these rules; or d. Standing vegetative cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is equal to or greater than 30% shall be implemented, as determined by Appendix C, Section 2.6 (Test Methods For Stabilization-Determination Of Standing Vegetative Cover) of these rules; or e. Standing vegetative cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is equal to or greater than 10% and where the threshold friction velocity is equal to or greater than 43 cm/second when corrected for non-erodible elements shall be implemented, as determined by Appendix C, Section 2.6 (Test Methods 52 For Stabilization-Determination Of Standing Vegetative Cover) of these rules; or 303 f. A percent cover that is equal to or greater than 10% for non-erodible elements shall be implemented, as determined by Appendix C, Section 2.7 (Test Methods For Stabilization-Rock Test Method) of these rules; or g. An alternative test method approved in writing by the Control Officer and the Administrator of the EPA shall be implemented. UNPAVED PARKING LOTS: The owner and/or operator of an unpaved parking lot shall implement one of the control measures described in subsection 303.1 of this rule. For the purpose of this rule, the owner and/or operator of an unpaved parking lot on which vehicles are parked no more than 35 days per year, excluding days on which ten or fewer vehicles enter, shall implement either the control measure described in subsection 303.1(b) or subsection 303.1(c) below for the duration of time that over 100 vehicles enter and/or park on such unpaved parking lot. In addition, for the purpose of this rule, such control measures shall be considered effectively implemented when the unpaved parking lot meets the stabilization limitation described in subsection 303.2 of this rule. 303.1 Control Measures: a. Pave. b. Apply dust suppressants, in compliance with the stabilization limitation described in subsection 303.2 of this rule. c. Uniformly apply and maintain surface gravel, in compliance with the stabilization limitation described in subsection 303.2 of this rule. 303.2 Stabilization Limitation: For the purpose of this rule, control measures shall be considered effectively implemented when stabilization observations for fugitive dust emissions from unpaved parking lots do not exceed 20% opacity and do not equal or exceed 0.33 oz/ft2 silt loading, or do not exceed 8% silt content, as determined by Appendix C, Section 2.1 (Test Methods For Stabilization-For Unpaved Roads And Unpaved Parking Lots) of these rules. 304 UNPAVED ROADWAYS (INCLUDING ALLEYS): If a person allows 150 vehicles or more per day to use an unpaved roadway (including alleys) in the nonattainment area, then such person shall first implement one of the best available control measures described in subsection 304.1 of this rule. Existing unpaved roadways (including alleys) with vehicular traffic of 250 vehicles or more per day must be stabilized by one of the best available control measures described in subsection 304.1 of this rule by June 10, 2000. Existing unpaved roadways (including alleys) with vehicular traffic 53 of 150 vehicles or more per day must be stabilized by one of the best available control measures described in subsection 304.1 of this rule by June 10, 2004. For the purpose of this rule, the best available control measures shall be considered effectively implemented when the unpaved roadway (including alleys) complies with subsection 304.3 of this rule. 304.1 Best Available Control Measures: a. Pave. b. Apply dust suppressants, in compliance with the stabilization limitation described in subsection 304.3 of this rule. c. Uniformly apply and maintain surface gravel, in compliance with the stabilization limitation described in subsection 304.3 of this rule. 304.2 Implementation Of Best Available Control Measures: For the purpose of this rule, best available control measures shall be considered effectively implemented, under the following conditions: a. The unpaved roadway (including alleys) meets the stabilization limitation described in subsection 304.3 of this rule; and, where applicable, b. Existing unpaved roadways (including alleys) are stabilized according to the following schedule: (1) Roadways with vehicular traffic of 250 vehicles or more per day are stabilized by June 10, 2000. (2) Roadways with vehicular traffic of 150 vehicles or more per day are stabilized by June 10, 2004. 304.3 Stabilization Limitation: For the purpose of this rule, control measures shall be considered effectively implemented when stabilization observations for fugitive dust emissions from unpaved roadways (including alleys) do not exceed 20% opacity and do not equal or exceed 0.33 oz/ft2 silt loading, or do not exceed 6% silt content, as determined by Appendix C, Section 2.1 (Test Methods For Stabilization-For Unpaved Roads And Unpaved Parking Lots) of these rules. 305 COMMERCIAL FEEDLOTS AND/OR COMMERCIAL LIVESTOCK AREAS: The owner and/or operator of any commercial feedlot and/or commercial livestock area shall implement one of the control measures described in subsection 305.1 of this rule. 305.1 Control Measures: 54 a. Apply dust suppressants, in compliance with the stabilization limitation described in subsection 305.2 of this rule. b. Uniformly apply and maintain surface gravel, in compliance with the stabilization limitation described in subsection 305.2 of this rule. c. Install shrubs and/or trees within 50 feet to 100 feet of animal pens, in compliance with the stabilization limitation described in subsection 305.2 of this rule. 305.2 Stabilization Limitation: No fugitive dust plume emanating from commercial feedlots and/or commercial livestock areas shall exceed 20% opacity, as determined by Appendix C, Section 3 (Visual Determination Of Opacity Of Emissions From Sources For Time-Average Regulations) of these rules. 306 EROSION-CAUSED DEPOSITION OF BULK MATERIALS ONTO PAVED SURFACES: In the event that erosion-caused deposition of bulk materials or other materials occurs on any adjacent paved roadway or paved parking lot, the owner and/or operator of the property from which the deposition eroded shall implement both of the control measures described in subsection 306.1 of this rule. Such control measures shall be considered effectively implemented when the deposition meets the stabilization limitation described in subsection 306.2 of this rule. Exceedances of the opacity limit, due to erosion-caused deposition of bulk materials onto paved surfaces, shall constitute a violation of the opacity limit. 306.1 Control Measures: a. Remove any and all such deposits by utilizing the appropriate control measures within 24 hours of the deposits’ identification or prior to the resumption of traffic on pavement, where the pavement area has been closed to traffic; and b. Dispose of deposits in such a manner so as not to cause another source of fugitive dust. 306.2 Stabilization Limitation: For the purpose of this rule, control measures shall be considered effectively implemented when stabilization observations for fugitive dust emissions from erosioncaused deposition of bulk materials onto paved surfaces do not exceed 20% opacity, as described in Appendix C, Section 2.1 (Test Methods For Stabilization-For Unpaved Roads And Unpaved Parking Lots) of these rules. 307 EASEMENTS, RIGHTS-OF-WAY, AND ACCESS ROADS FOR UTILITIES (ELECTRICITY, NATURAL GAS, OIL, WATER, AND GAS TRANSMISSION): If a person allows 150 vehicles or more per day to use an easement, right-of-way, and access road for utilities (electricity, natural 55 gas, oil, water, and gas transmission) in the nonattainment area, then such person shall first implement one of the control measures described in subsection 307.1 of this rule. For the purpose of this rule, the control measures shall be considered effectively implemented, when the easement, right-of-way, and access road for utilities (electricity, natural gas, oil, water, and gas transmission) complies with subsection 307.2 of this rule. 307.1 Control Measures: a. Pave. b. Apply dust suppressants, in compliance with the stabilization limitation described in subsection 307.2 of this rule. c. Uniformly apply and maintain surface gravel, in compliance with the stabilization limitation described in subsection 307.2 of this rule. 307.2 Stabilization Limitation: For the purpose of this rule, control measures shall be considered effectively implemented when stabilization observations for fugitive dust emissions from easements, rights-of-way, and access roads for utilities (electricity, natural gas, oil, water, and gas transmission) do not exceed 20% opacity and do not equal or exceed 0.33 oz/ft2 silt loading, or do not exceed 6% silt content, as determined by Appendix C, Section 2.1 (Test Methods For Stabilization-For Unpaved Roads And Unpaved Parking Lots) of these rules. SECTION 400 - ADMINISTRATIVE REQUIREMENTS (NOT APPLICABLE) SECTION 500 - MONITORING AND RECORDS 501 STABILIZATION OBSERVATIONS: 501.1 Stabilization observations for unpaved parking lots and/or unpaved roadways (including alleys) shall be conducted in accordance with Appendix C, Section 2.1 (Test Methods For Stabilization-For Unpaved Roads And Unpaved Parking Lots) of these rules. 501.2 Stabilization observations for an open area and vacant lot shall be conducted in accordance with the following: a. Appendix C, Section 2.3 (Test Methods For StabilizationVisible Crust Determination) (The Drop Ball/Steel Ball Test) of these rules; or b. Appendix C, Section 2.4 (Test Methods For StabilizationDetermination Of Threshold Friction Velocity (TFV)) (Sieving Field Procedure) of these rules, where the threshold friction velocity (TFV) for disturbed surface areas corrected for nonerodible elements is 100 cm/second or higher; or 56 c. Appendix C, Section 2.5 (Test Methods For StabilizationDetermination Of Flat Vegetative Cover) of these rules, where flat vegetation cover (i.e., attached (rooted) vegetation or unattached vegetative debris lying on the surface with a predominant horizontal orientation that is not subject to movement by wind) is equal to at least 50%; or d. Appendix C, Section 2.6 (Test Methods For StabilizationDetermination Of Standing Vegetative Cover) of these rules, where standing vegetation cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) is equal to or greater than 30%; or e. Appendix C, Section 2.6 (Test Methods For StabilizationDetermination Of Standing Vegetative Cover) of these rules, where the standing vegetation cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) is equal to or greater than 10% and where the threshold friction velocity, corrected for non-erodible elements, is equal to or greater than 43 cm/second; or f. Appendix C, Section 2.7 (Test Methods For StabilizationRock Test Method) of these rules where a percent cover is equal to or greater than 10% for non-erodible elements. g. An alternative test method approved in writing by the Control Officer and the Administrator of the EPA. 502 RECORDKEEPING: Any person subject to the requirements of this rule shall compile and retain records that provide evidence of control measure application (i.e., receipts and/or purchase records). The records should describe the type of treatment or control measure, extent of coverage, and date applied. Upon verbal or written request by the Control Officer, the records and supporting documentation shall be provided within 48 hours, excluding weekends. If the Control Officer is at the site where requested records are kept, records shall be provided without delay. 503 RECORDS RETENTION: Copies of the records required by Section 502 (Recordkeeping) of this rule shall be retained for at least one year. 57 Appendix A-3 58 REGULATION III - CONTROL OF AIR CONTAMINANTS RULE 316 NONMETALLIC MINERAL MINING AND PROCESSING INDEX SECTION 100 - GENERAL 101 PURPOSE 102 APPLICABILITY SECTION 200 - DEFINITIONS 201 AFFECTED OPERATION 202 APPROVED EMISSION CONTROL SYSTEM 203 ASPHALTIC CONCRETE PLANT/ASPHALT PLANT 204 BAGGING OPERATION 205 BELT CONVEYOR 206 CONCRETE PLANT 207 CONVEYING SYSTEM 208 CRUSHER 209 DRY MIX CONCRETE PLANT 210 ENCLOSED TRUCK OR RAILCAR LOADING STATION 211 FUGITIVE DUST EMISSION 212 GRINDING MILL 213 NONMETALLIC MINERAL 214 NONMETALLIC MINERAL PROCESSING PLANT 215 PARTICULATE MATTER 216 PARTICULATE MATTER EMISSIONS 217 PROCESS 218 PROCESS SOURCE 219 SCREENING OPERATION 220 STACK EMISSIONS 221 STORAGE BIN 222 TRANSFER POINT 223 TRUCK DUMPING 224 VENT SECTION 300 - STANDARDS 59 301 LIMITATIONS - NONMETALLIC MINERAL PROCESSING PLANTS 302 LIMITATIONS - ASPHALTIC CONCRETE PLANTS 303 LIMITATIONS - CONCRETE PLANTS AND BAGGING OPERATIONS 304 LIMITATIONS - OTHER ASSOCIATED OPERATIONS 305 REQUIREMENT FOR AIR POLLUTION CONTROL EQUIPMENT AND EMISSION CONTROL SYSTEM (ECS) MONITORING EQUIPMENT SECTION 400 - ADMINISTRATIVE REQUIREMENTS 401 O&M PLAN COMPLIANCE SCHEDULE SECTION 500 - MONITORING AND RECORDS 501 RECORDKEEPING AND REPORTING 502 COMPLIANCE DETERMINATION 60 Adopted 07/06/93 Revised 04/21/99 MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS REGULATION III - CONTROL OF AIR CONTAMINANTS RULE 316 NONMETALLIC MINERAL MINING AND PROCESSING SECTION 100 - GENERAL 101 PURPOSE: To limit the emission of particulate matter into the ambient air from any nonmetallic mining operation or rock product processing plant. 102 APPLICABILITY: The provisions of this rule shall apply to any commercial and/or industrial nonmetallic mineral mining and/or rock product plant operation. Compliance with the provisions of this rule shall not relieve any person subject to the requirements of this rule from complying with any other federally enforceable New Source Performance Standards. In such case, the more stringent standard shall apply. SECTION 200 - DEFINITIONS: For the purpose of this rule, the following definitions shall apply: 201 AFFECTED OPERATION - An operation that processes nonmetallic minerals or that is related to such processing and process sources including, but not limited to, crushers, grinding mills, screening equipment, conveying systems, elevators, transfer points, bagging operations, storage bins, enclosed truck and railcar loading stations and truck dumping. 202 APPROVED EMISSION CONTROL SYSTEM - A system for reducing particulate emissions, consisting of collection and/or control devices which are approved in writing by the Control Officer and are designed and operated in accordance with good engineering practice. 203 ASPHALTIC CONCRETE PLANT/ASPHALT PLANT - Any facility used to manufacture asphaltic concrete by mixing graded aggregate and asphaltic cements. 204 BAGGING OPERATION - The mechanical process by which bags are filled with nonmetallic minerals. 205 BELT CONVEYOR - A conveying device that transports material from one location to another by means of an endless belt that is carried on a series of idlers and routed around a pulley at each end. 206 CONCRETE PLANT - Any facility used to manufacture concrete by mixing water, aggregate, and cement. 207 CONVEYING SYSTEM - A device for transporting materials from one piece of equipment or location to another location within a facility. Conveying systems 61 include, but are not limited to, feeders, belt conveyers, bucket elevators and pneumatic systems. 208 CRUSHER - A machine used to crush any nonmetallic minerals, including, but not limited to, the following types: jaw, gyratory, cone, roll, rod mill, hammermill, and impactor. 209 DRY MIX CONCRETE PLANT - Any facility used to manufacture a mixture of aggregate and cements without the addition of water. 210 ENCLOSED TRUCK OR RAILCAR LOADING STATION - That portion of a nonmetallic mineral processing plant where nonmetallic minerals are loaded by an enclosed conveying system into enclosed trucks or railcars. 211 FUGITIVE DUST EMISSION - Particulate matter that is not collected by a capture system and is released to and suspended in the ambient air. 212 GRINDING MILL - A machine used for the wet or dry fine crushing of any nonmetallic mineral. Grinding mills include, but are not limited to, the following types: hammer, roller, rod, pebble and ball, and fluid energy. The grinding mill includes the air conveying system, air separator, or air classifier, where such systems are used. 213 NONMETALLIC MINERAL - Any of the following minerals or any mixture of which the majority is any of the following minerals: 213.1 213.2 213.3 213.4 213.5 213.6 213.7 213.8 213.9 213.10 213.11 213.12 213.13 213.14 213.15 213.16 213.17 213.18 213.19 214 Crushed and broken stone, including limestone, dolomite, granite, rhyolite, traprock, sandstone, quartz, quartzite, marl, marble, slate, shale, oil shale, and shell. Sand and gravel. Clay including kaolin, fireclay, bentonite, fuller's earth, ball clay, and common clay. Rock salt. Gypsum. Sodium compounds, including sodium carbonate, sodium chloride, and sodium sulfate. Pumice. Gilsonite. Talc and pyrophyllite. Boron, including borax, kernite, and colemanite. Barite. Fluorspar. Feldspar. Diatomite. Perlite. Vermiculite. Mica. Kyanite, including andalusite, sillimanite, topaz, and dumortierite. Coal. NONMETALLIC MINERAL PROCESSING PLANT - Any facility utilizing any combination of equipment or machinery that is used to mine, excavate, separate, combine, crush, or grind any nonmetallic mineral, including, but not 62 limited to: lime plants, coal fired power plants, steel mills, asphalt plants, concrete plants, portland cement plants, and sand and gravel plants. Rock Product Processing Plants are included in this definition. 215 PARTICULATE MATTER - Any material, except uncombined water, which has a nominal aerodynamic diameter smaller than 100 microns (micrometers), and which exists in a finely divided form as a liquid or solid at actual conditions. 216 PARTICULATE MATTER EMISSIONS - Any and all finely divided solid or liquid materials other than uncombined water released to the ambient air as measured by the applicable state and federal test methods. 217 PROCESS - One or more operations including those using equipment and technology in the production of goods or services or the control of by-products or waste. 218 PROCESS SOURCE - The last operation of a process or a distinctly separate process which produces an air contaminant and which is not a pollution abatement operation. 219 SCREENING OPERATION - A device that separates material according to its size by passing undersize material through one or more mesh surfaces (screens) in series, and retaining oversize material on the mesh surfaces (screens). 220 STACK EMISSIONS - The particulate matter emissions that are released to the atmosphere from a capture system through a building vent, stack or other point source discharge. 221 STORAGE BIN - A facility enclosure, hopper, silo or surge bin for the storage of nonmetallic minerals prior to further processing or loading. 222 TRANSFER POINT - A point in a conveying operation where nonmetallic mineral is transferred from or to a belt conveyor except for transfer to a stockpile. 223 TRUCK DUMPING - The unloading of nonmetallic minerals from movable vehicles designed to transport nonmetallic minerals from one location to another. Movable vehicles include, but are not limited to, trucks, front end loaders, skip hoists, and railcars. 224 VENT - An opening through which there is mechanically or naturally induced air flow for the purpose of exhausting air carrying particulate matter. SECTION 300 - STANDARDS 301 LIMITATIONS - NONMETALLIC MINERAL PROCESSING PLANTS: No person shall discharge or cause or allow to be discharged into the ambient air: 63 302 303 301.1 Stack emissions exceeding 7% opacity and containing more than 0.02 gr/dscf (50 mg/dscm) of particulate matter. 301.2 Fugitive dust emissions from any “transfer point” on a conveying system exceeding 7% opacity. 301.3 Fugitive dust emissions exceeding 15% opacity from any crusher. 301.4 Fugitive dust emissions exceeding 10% opacity from any affected operation or process source, excluding truck dumping directly into any screening operation, feed hopper or crusher. 301.5 Fugitive dust emissions exceeding 20% opacity from truck dumping directly into any screening operation, feed hopper or crusher. LIMITATIONS - ASPHALTIC CONCRETE PLANTS: No person shall discharge or cause or allow to be discharged into the ambient air: 302.1 Stack emissions exceeding 20% opacity and containing more than 0.04 gr/dscf (90 mg/dscm) of particulate matter. 302.2 Fugitive dust emissions exceeding 20% opacity from any other affected operation or process source. LIMITATIONS - CONCRETE PLANTS AND BAGGING OPERATIONS: No person shall discharge or cause or allow to be discharged into the ambient air: 303.1 Stack emissions exceeding 7% opacity. 303.2 Fugitive dust emissions exceeding 10% opacity from any affected operation or process source, excluding truck dumping directly into any screening operation, feed hopper or crusher. 303.3 Fugitive dust emissions exceeding 20% opacity from truck dumping directly into any screening operation, feed hopper or crusher. 304 LIMITATIONS - OTHER ASSOCIATED OPERATIONS: All other activities not specifically listed in Sections 301, 302, or 303 of this rule associated with the mining and processing of nonmetallic minerals, shall, at a minimum, meet the provisions of Rule 310 of these rules. 305 REQUIREMENT FOR AIR POLLUTION CONTROL EQUIPMENT AND EMISSION CONTROL SYSTEM (ECS) MONITORING EQUIPMENT: For the purposes of this rule, an emission control system (ECS) is a system for reducing emissions of particulates, consisting of both collection and control devices, which are approved in writing by the Control Officer and are designed and operated in accordance with good engineering practices. 305.1 Operation And Maintenance (O&M) Plan Requirements For ECS: a. An owner or operator of a facility shall provide and maintain, readily available on-site at all times, (an) O&M Plan(s) for any ECS, any other emission processing equipment, and any ECS 64 monitoring devices that are used pursuant to this rule or to an air pollution control permit. b. The owner or operator of a facility shall submit to the Control Officer for approval the O&M Plans of each ECS and of each ECS monitoring device that is used pursuant to this rule. c. The owner or operator of a facility shall comply with all the identified actions and schedules provided in each O&M Plan. 305.2 Providing And Maintaining ECS Monitoring Devices: An owner or operator of a facility operating an ECS pursuant to this rule shall install, maintain, and calibrate monitoring devices described in the O&M Plan. The monitoring devices shall measure pressures, rates of flow, and/or other operating conditions necessary to determine if the control devices are functioning properly. 305.3 O&M Plan Responsibility: An owner or operator of a facility that is required to have an O&M Plan pursuant to subsection 305.1 of this rule must fully comply with all O&M Plans that the owner or operator has submitted for approval, even if such O&M Plans have not yet been approved, unless notified in writing by the Control Officer. SECTION 400 - ADMINISTRATIVE REQUIREMENTS 401 O&M PLAN COMPLIANCE SCHEDULE: Any owner or operator of a facility employing an ECS device as of April 21, 1999 to meet the requirements of this rule, shall file, by October 18, 1999, an O&M Plan with the Control Officer in accordance with subsection 501.3 of this rule. SECTION 500 - MONITORING AND RECORDS 501 RECORDKEEPING AND REPORTING: Any person subject to this rule shall comply with the following requirements. Records shall be retained for 5 years and shall be made available to the Control Officer upon request. 501.1 Operational information required by this rule shall be kept in a complete and consistent manner on site and be made available without delay to the Control Officer upon request. 501.2 Records of the following process and operational information, as applicable, are required: a. General Data: Daily records shall be kept for all days that a plant is actively operating. Records shall include the following: hours of operation; type of batch operation (wet, dry, central); throughput per day of basic raw materials including sand, aggregate, cement, (tons/day); volume of concrete and asphaltic concrete produced per day; volume of aggregate mined per day (cu. yds./day); composition of a cubic yard of concrete produced (percent cement, sand, aggregate, admixture, water, fly ash, etc.); composition of a cubic yard of asphaltic concrete produced (percent cement, sand, aggregate, gypsum, admixture, water, fly 65 ash, etc.); amount of each basic raw material including sand, aggregate, cement, fly ash delivered per day (tons/day). 501.3 502 b. Additional Data For Dry Mix Concrete Plants: The number of bags of dry mix produced per day; weight (size) of bags of dry mix produced per day; kind and amount of fuel consumed in dryer (cu. ft./day or gals./day); kind and amount of any back-up fuel (if any). c. Control And Monitoring Device Data: Baghouse records shall include dates of inspection, dates and designation of bag replacement, dates of service or maintenance, related activities, static pressure gauge (manometer) hourly readings. Scrubber records shall include dates of service or maintenance related activities; the scrubbing liquid flow rate; the pressure or head loss; and/or any other operating parameters which need to be monitored to assure that the scrubber is functioning properly and operating within design parameters. Records of time, date and cause of all control device failure and down time shall also be maintained. ECS O&M Plan Records: An owner or operator of a facility shall maintain a record of the periods of time than an approved ECS is used to comply with this rule. Key system parameters, such as flow rates, pressure drops, and other conditions necessary to determine if the control equipment is functioning properly, shall be recorded in accordance with the approved O&M Plan. The records shall account for any periods when the control system was not operating. The owner or operator of a facility shall also maintain results of the visual inspection and shall record any corrective action taken, if necessary. COMPLIANCE DETERMINATION: The test methods for those subparts of 40 Code Of Federal Regulations (CFR) Part 60, Appendix A, adopted as of July 1, 1998, as listed below, are adopted by reference as indicated. This adoption by reference includes no future editions or amendments. Copies of test methods referenced in Section 502 of this rule are available at the Maricopa County Environmental Services Department, 1001 North Central Avenue, Phoenix, Arizona, 85004-1942. When more than one test method is permitted for a compliance determination, then an exceedance of the limits established in this rule, determined by any of the applicable test methods, constitutes a violation of this rule. 502.1 Grain Loading: Particulate matter and associated moisture content shall be determined using the applicable EPA Reference Methods 1 through 5, 40 CFR Part 60, Appendix A. 502.2 Opacity Determination: Opacity observations to measure the opacity of visible emissions shall be conducted in accordance with the techniques specified in EPA Reference Method 9, 40 CFR Part 60, Appendix A, except the opacity observations for intermittent visible emissions shall require 12 (rather than 24) consecutive readings at 15-second intervals. 66 APPENDIX J – Maricopa County PM10 Monitors 24-Hour PM10 Ambient Air Quality Monitoring Network Data for Maricopa County and the Salt River PM10 Study Area Table J-1 1994 PM10 Monitoring Data Summary (µ/m3), from ADEQ Annual Air Quality Report for Arizona MARICOPA COUNTY PM10 MONITORS - (24-Hour National Ambient Air Quality Standard - 150 µ/m3) 24-Hour Average City Location Site Location Operator Method MAX 2nd Hi Chandler 1475 E. Pecos MCESD HI-VOL 127 114 Glendale 6000 W. Olive MCESD HI-VOL 76 54 Mesa Broadway/Brooks MCESD HI-VOL 73 51 South Phoenix 4732 S. Central MCESD HI-VOL 97 89 West Phoenix 3847 W. Earll MCESD HI-VOL 98 93 Central Phoenix 1845 E. Roosevelt MCESD HI-VOL 92 80 North Phoenix 601 E. Butler MCESD HI-VOL 73 66 South Scottsdale 2857 N. Miller MCESD HI-VOL 76 65 nd Phx-Salt River 3045 S. 22 Avenue MCESD HI-VOL 371 215 Appendix J – Maricopa County PM10 Monitors Number of Exceedances Number of Samples 0 0 0 0 0 0 0 0 12 56 51 43 56 53 54 51 50 55 J- 1 Table J-2. 1995 PM10 Monitoring Data Summary (µ/m3), from ADEQ Annual Air Quality Report for Arizona MARICOPA COUNTY PM10 MONITORS - (24-Hour National Ambient Air Quality Standard - 150 µ/m3) 24-Hour Average City Location Site Location Operator Method MAX 2nd Hi Chandler 1475 E. Pecos Road MCESD HI-VOL 252 160 1 Gilbert 15500 S. Higley ADEQ DICHOT 110 106 Glendale 6000 W. Olive MCESD HI-VOL 70 63 2 Goodyear 15099 W. Casey Abbott ADEQ DICHOT 86 65 Mesa Broadway & Brooks MCESD HI-VOL 89 70 South Phoenix 4732 S. Central MCESD HI-VOL 78 74 West Phoenix 3847 W. Earll MCESD HI-VOL 99 88 Central Phoenix 1845 E. Roosevelt MCESD HI-VOL 88 76 3 Phoenix 4701 W. Thunderbird ADEQ DICHOT 57 51 4 Phx-JLG Site 4530 N. 17th Ave. ADEQ HI-VOL 73 63 Phoenix 4530 N. 17th Ave. ADEQ DICHOT 71 59 North Phoenix 601 E. Butler MCESD HI-VOL 84 68 South Scottsdale 2857 N. Miller MCESD HI-VOL 75 69 5 Tempe 3340 S. Rural ADEQ DICHOT 63 62 Phx-Salt River 3045 S. 22nd Avenue MCESD HI-VOL 199 196 Appendix J – Maricopa County PM10 Monitors Number of Exceedances Number of Samples 2 0 0 0 0 0 0 0 0 0 0 0 0 0 15 146 55 53 44 57 50 61 55 51 2084 56 58 61 58 57 J- 2 Table J-3. 1996 PM10 Monitoring Data Summary (µ/m3), from ADEQ Annual Air Quality Report for Arizona, Appendix 1 MARICOPA COUNTY PM10 MONITORS - (24-Hour National Ambient Air Quality Standard - 150 µ/m3) 24-Hour Average City Location Site Location Operator Method MAX 2nd Hi Chandler 1475 E. Pecos Road MCESD HI-VOL 140 130 Gilbert 15500 S. Higley ADEQ DICHOT 179 114 Glendale 6000 W. Olive MCESD HI-VOL 67 60 Goodyear 15099 W. Casey Abbott ADEQ DICHOT 82 72 Mesa Broadway & Brooks MCESD HI-VOL 67 62 6 Mesa 6001 S. Power Road ADEQ DICHOT 53 50 South Phoenix 4732 S. Central MCESD HI-VOL 96 96 West Phoenix 3847 W. Earll MCESD HI-VOL 102 100 Central Phoenix 1845 E. Roosevelt MCESD HI-VOL 105 89 Phoenix 4701 W. Thunderbird ADEQ DICHOT 58 57 Phoenix 4530 N. 17th Ave. ADEQ HI-VOL 137 104 Phx-JLG Site 4530 N. 17th Ave. ADEQ DICHOT 83 68 North Phoenix 601 E. Butler MCESD HI-VOL 71 66 South Scottsdale 2857 N. Miller MCESD HI-VOL 80 64 Tempe 3340 S. Rural ADEQ DICHOT 193 185 Phx-Salt River 3045 S. 22nd Avenue MCESD HI-VOL 250 238 Appendix J – Maricopa County PM10 Monitors Number of Exceedances Number of Samples 0 1 0 0 0 0 0 0 0 0 0 0 0 0 3 11 59 55 57 55 54 30 75 55 59 55 8177 54 74 59 54 55 J- 3 Table J-4. 1997 PM10 Monitoring Data Summary (µ/m3), from ADEQ Annual Air Quality Report for Arizona, Appendix I MARICOPA COUNTY PM10 MONITORS - (24-Hour National Ambient Air Quality Standard - 150 µ/m3) 24-Hour Average City Location Site Location Operator Method MAX 2nd Hi Chandler 1475 E. Pecos Road MCESD HI-VOL 221 148 7 W. Chandler 163 S. Price Road MCESD HI-VOL 194 162 Gilbert 535 N. Lindsay Road MCESD HI-VOL 170 108 Glendale 6000 W. Olive MCESD HI-VOL 170 87 Goodyear 15099 W. Casey Abbott ADEQ DICHOT 179 146 8 Higley 15500 S. Higley ADEQ DICHOT 288 234 Maryvale9 6180 W. Encanto MCESD HI-VOL 345 161 10 Mesa Broadway & Brooks MCESD HI-VOL 129 119 11 Palo Verde 36248 W. Elliot Road ADEQ DICHOT 124 73 South Phoenix 4732 S. Central MCESD HI-VOL 160 114 West Phoenix Central Phoenix North Phoenix Phx-JLG Site Phx-JLG Site12 Phoenix13 Phoenix Phoenix Phoenix Phx-Salt River South Scottsdale Tempe Wickenburg 3847 W. Earll 1845 E. Roosevelt 601 E. Butler 4530 N. 17th Ave. 4530 N. 17th Ave. 27th Ave./I-10 27th Ave./I-10 27th Ave./I-10 4701 W. Thunderbird 3045 S. 22nd Avenue 2857 N. Miller 3340 S. Rural 155 North Tegner MCESD MCESD MCESD ADEQ ADEQ ADEQ ADEQ MCESD ADEQ MCESD MCESD ADEQ MCESD Appendix J – Maricopa County PM10 Monitors HI-VOL HI-VOL HI-VOL DICHOT HI-VOL DICHOT HI-VOL HI-VOL DICHOT HI-VOL HI-VOL DICHOT HI-VOL 224 108 152 131 147 148 161 220 164 480 154 90 125 137 96 81 82 143 103 113 125 92 301 84 74 65 Number of Exceedances Number of Samples 1 2 1 1 1 2 2 0 0 1 57 57 55 57 50 56 61 59 62 61 1 0 0 0 0 0 1 1 1 15 0 0 0 60 55 51 57 7328 53 7792 56 55 59 60 56 48 J- 4 Table J-5. 1998 PM10 Monitoring Data Summary (µ/m3), from ADEQ Annual Air Quality Report for Arizona, Appendix I MARICOPA COUNTY PM10 MONITORS - (24-Hour National Ambient Air Quality Standard - 150 µ/m3) 24-Hour Average City Location Site Location Operator Method MAX 2nd Hi 99th Pct Number of Exceedances Number of Samples Chandler W. Chandler Gilbert Glendale Goodyear / Estrella Higley Maryvale Mesa Palo Verde South Phoenix 1475 E. Pecos Road 163 S. Price Road 535 N. Lindsay Road 6000 W. Olive 15099 W. Casey Abbott 15500 S. Higley 6180 W. Encanto Broadway & Brooks 36248 W. Elliot Road 4732 S. Central MCESD MCESD MCESD MCESD ADEQ HI-VOL HI-VOL HI-VOL HI-VOL DICHOT 136 78 133 61 56 104 74 91 57 56 136 78 133 61 56 0 0 0 0 0 52 55 55 56 61 ADEQ MCESD MCESD ADEQ MCESD DICHOT HI-VOL HI-VOL DICHOT HI-VOL 135 92 64 47 77 116 83 61 46 67 135 92 64 47 77 0 0 0 0 0 61 59 61 55 25 West Phoenix Phx-Salt River14 Central Phoenix North Phoenix Phx-JLG Site Phx-Greenwood Phx-Greenwood Phx-ASU West South Scottsdale Tempe Wickenburg15 3847 W. Earll 3045 S. 22nd Avenue 1845 E. Roosevelt 601 E. Butler 4530 N. 17th Ave. 27th Ave./I-10 27th Ave./I-10 4701 W. Thunderbird 2857 N. Miller MCESD MCESD MCESD MCESD ADEQ ADEQ MCESD ADEQ MCESD HI-VOL HI-VOL HI-VOL HI-VOL DICHOT DICHOT HI-VOL DICHOT HI-VOL 107 NA 70 67 69 106 121 55 81 106 NA 62 62 67 95 115 53 66 107 NA 70 67 69 106 121 55 81 0 0 0 0 0 0 0 0 0 57 25 23 57 54 37 61 61 58 3340 S. Rural 155 North Tegner ADEQ MCESD DICHOT HI-VOL 70 55 68 42 70 55 0 0 61 17 Appendix J – Maricopa County PM10 Monitors J- 5 Table J-6. 1999 PM10 Monitoring Data Summary (µ/m3), from ADEQ Annual Air Quality Report for Arizona, Appendix I MARICOPA COUNTY PM10 MONITORS - (24-Hour National Ambient Air Quality Standard - 150 µ/m3) 24-Hour Average City Location Site Location Operator Method MAX 2nd Hi Number of Exceedances Number of Samples Chandler 1475 E. Pecos Road MCESD HI-VOL 110 100 0 59 W. Chandler 163 S. Price Road MCESD HI-VOL 104 92 0 59 Gilbert 535 N. Lindsay Road MCESD HI-VOL 90 88 0 55 Glendale 6000 W. Olive MCESD HI-VOL 77 63 0 58 Goodyear / Estrella Higley 15099 W. Casey Drive 15500 S. Higley ADEQ DICHOT 80 73 0 59 ADEQ DICHOT 208 110 1 58 Maryvale 6180 W. Encanto MCESD HI-VOL 104 96 0 60 Mesa Broadway & Brooks MCESD HI-VOL 80 71 0 60 Palo Verde 36248 W. Elliot Road ADEQ DICHOT 83 46 0 53 Phx-Durango16 2702 AC Esterbrook MCESD HI-VOL 148 143 0 29 South Phoenix 4732 S. Central MCESD HI-VOL 67 62 1 18 West Phoenix 3847 W. Earll MCESD HI-VOL 111 103 0 57 Abbott nd Phx-Salt River 3045 S. 22 Avenue MCESD HI-VOL 148 143 0 29 Central Phoenix 1845 E. Roosevelt MCESD HI-VOL 85 85 0 45 North Phoenix 601 E. Butler MCESD HI-VOL 70 63 0 57 Phx-JLG Site 4530 N. 17th Ave. ADEQ DICHOT 78 70 0 58 Phx-Greenwood 27th Ave./I-10 ADEQ DICHOT 111 111 0 55 Phx-Greenwood 27th Ave./I-10 MCESD HI-VOL 117 115 0 59 Phx-ASU West 4701 W. Thunderbird ADEQ DICHOT 55 53 0 59 South Scottsdale Tempe 2857 N. Miller MCESD HI-VOL 87 80 0 57 3340 S. Rural ADEQ DICHOT 82 78 0 55 Appendix J – Maricopa County PM10 Monitors J- 6 Table J-7. 2000 PM10 Monitoring Data Summary (µ/m3), from ADEQ Annual Air Quality Report for Arizona, Appendix I MARICOPA COUNTY PM10 MONITORS - (24-Hour National Ambient Air Quality Standard - 150 µ/m3) 24-Hour Average City Location Site Location Operator Method MAX 2nd Hi Number of Exceedances Number of Samples Chandler 1475 E. Pecos Road MCESD HI-VOL 202 145 0 59 W. Chandler 163 S. Price Road MCESD HI-VOL 135 95 0 51 Gilbert 535 N. Lindsay Road MCESD HI-VOL 128 109 0 60 Glendale 6000 W. Olive MCESD HI-VOL 122 100 0 58 Goodyear / Estrella Higley 15099 W. Casey Drive 15500 S. Higley ADEQ DICHOT 82 77 0 44 ADEQ DICHOT 136 129 0 53 17 Abbott Higley 15500 S. Higley MCESD HI-VOL 327 143 0 38 Maryvale 6180 W. Encanto MCESD HI-VOL 173 109 1 61 Mesa Broadway & Brooks MCESD HI-VOL 126 94 0 61 Palo Verde 36248 W. Elliot Road ADEQ DICHOT 75 43 0 57 Phx-Durango 2702 AC Esterbrook MCESD HI-VOL 300 173 2 61 South Phoenix 4732 S. Central MCESD HI-VOL 175 122 1 61 West Phoenix 3847 W. Earll MCESD HI-VOL 151 133 1 59 Phx-Salt River 3045 S. 22nd Avenue MCESD HI-VOL 244 232 6 54 Central Phoenix 1845 E. Roosevelt MCESD HI-VOL 135 105 0 59 North Phoenix 601 E. Butler MCESD HI-VOL 114 114 0 59 Phx-JLG Site 4530 N. 17th Ave. ADEQ DICHOT 84 84 0 61 Phx-Greenwood 27th Ave./I-10 ADEQ DICHOT 151 108 1 49 Phx-Greenwood 27th Ave./I-10 MCESD HI-VOL 164 159 2 60 Phx-ASU West 4701 W. Thunderbird ADEQ DICHOT 101 84 0 59 South Scottsdale Tempe 2857 N. Miller MCESD HI-VOL 100 98 0 61 3340 S. Rural ADEQ DICHOT 95 81 0 57 Appendix J – Maricopa County PM10 Monitors J- 7 Table J-8. 2001 PM10 Monitoring Data Summary (µ/m3), from ADEQ Annual Air Quality Report for Arizona, Appendix I MARICOPA COUNTY PM10 MONITORS - (24-Hour National Ambient Air Quality Standard - 150 µ/m3) 24-Hour Average City Location Site Location Operator Method MAX 2nd Hi Number of Exceedances Percent Data Recovery Chandler 1475 E. Pecos Road MCESD HI-VOL 146 99 0 100 W. Chandler 163 S. Price Road MCESD HI-VOL 134 58 0 100 Gilbert 535 N. Lindsay Road MCESD HI-VOL 121 119 0 100 Glendale 6000 W. Olive MCESD HI-VOL 110 63 0 97 Goodyear / Estrella ADEQ DICHOT 122 51 0 90 Higley19 15099 W. Casey Abbott Drive 15500 S. Higley ADEQ DICHOT NA NA NA NA Higley 15500 S. Higley MCESD HI-VOL 176 93 1 97 Maryvale 6180 W. Encanto MCESD HI-VOL 123 94 0 97 Mesa Broadway & Brooks MCESD HI-VOL 98 55 0 100 Palo Verde 36248 W. Elliot Road ADEQ DICHOT 71 54 0 85 Phx-Durango 2702 AC Esterbrook MCESD HI-VOL 189 142 1 100 South Phoenix 4732 S. Central MCESD HI-VOL 143 92 0 98 West Phoenix 3847 W. Earll MCESD HI-VOL 142 91 0 100 18 nd Phx-Salt River 3045 S. 22 Avenue MCESD HI-VOL 281 275 2 98 Central Phoenix 1845 E. Roosevelt MCESD HI-VOL 124 65 0 98 North Phoenix 601 E. Butler MCESD HI-VOL 99 55 0 100 4530 N. 17th Ave. ADEQ DICHOT 109 58 0 97 Phx-Greenwood 27th Ave./I-10 ADEQ DICHOT NA NA NA NA Phx-Greenwood 27th Ave./I-10 MCESD HI-VOL 145 99 0 97 Phx-ASU West 4701 W. Thunderbird ADEQ DICHOT 42 39 0 59 South Scottsdale 2857 N. Miller MCESD HI-VOL 110 53 0 100 Tempe 3340 S. Rural ADEQ DICHOT 109 55 0 95 18600 N. Reems MCESD HI-VOL 107 52 0 97 Phx-JLG Site 20 21 22 Surprise Appendix J – Maricopa County PM10 Monitors J- 8 Table J-9. 2002 PM10 Monitoring Data Summary (µ/m3), from ADEQ Annual Air Quality Report for Arizona, Appendix I MARICOPA COUNTY PM10 MONITORS - (24-Hour National Ambient Air Quality Standard - 150 µ/m3) 24-Hour Average City Location Site Location Operator Method MAX 2nd Hi Number of Exceedances Percent Data Recovery Chandler 1475 E. Pecos Road MCESD HI-VOL 128 117 0 100 W. Chandler 163 S. Price Road MCESD HI-VOL 80 77 0 100 Glendale 6000 W. Olive MCESD HI-VOL 88 85 0 98 Goodyear / Estrella Higley 15099 W. Casey Abbott Drive 15500 S. Higley ADEQ DICHOT 92 68 0 85 MCESD HI-VOL 138 134 0 95 Maryvale 6180 W. Encanto MCESD HI-VOL 142 90 0 92 Mesa Broadway & Brooks MCESD HI-VOL 102 86 0 100 Palo Verde 36248 W. Elliot Road ADEQ DICHOT 100 78 0 97 Phx-Durango 2702 AC Esterbrook MCESD HI-VOL 232 158 2 100 South Phoenix 4732 S. Central MCESD HI-VOL 137 123 0 100 W. 43 Ave. 3940 W. Broadway Road MCESD 172 135 1 100 West Phoenix 3847 W. Earll MCESD HI-VOL 122 98 0 100 rd 23 nd Phx-Salt River 3045 S. 22 Avenue MCESD HI-VOL 249 174 2 98 Central Phoenix 1845 E. Roosevelt MCESD HI-VOL 81 76 0 100 North Phoenix 601 E. Butler MCESD HI-VOL 80 72 0 98 Phx-JLG Site 4530 N. 17th Ave. ADEQ DICHOT 72 52 0 74 Phx-Greenwood 27th Ave./I-10 MCESD HI-VOL 116 102 0 100 South Scottsdale 2857 N. Miller MCESD HI-VOL 64 62 0 100 Tempe 3340 S. Rural ADEQ DICHOT 65 60 0 90 Surprise 18600 N. Reems MCESD HI-VOL 81 67 0 97 1 ADEQ added its Gilbert monitor site in 1995. 2 ADEQ added its Goodyear monitor in 1995. 3 ADEQ added a monitor at 4701 W. Thunderbird, in 1995. Appendix J – Maricopa County PM10 Monitors J- 9 4 ADEQ added two monitors at 4530 North 17th Avenue, in Phoenix, in 1995. 5 ADEQ added a monitor in Tempe, in 1995. 6 ADEQ added a monitor in Mesa, in 1996. 7 MCESD added a monitor in West Chandler, in 1997. 8 ADEQ added a Higley monitor in 1997. 9 MCESD added a Maryvale monitor in 1997. 10 ADEQ removed its Mesa monitor at 6001 South Power Road, in 1997. 11 ADEQ added the Palo Verde monitor in 1997. 12 ADEQ's monitor was closed in 1997 at the Phoenix-JLG Site. 13 Three monitors were added to sites at I-10 and 27th Avenue, just north of the current Salt River study area, in 1997. Two monitors were operated by ADEQ, and one by MCESD. 14 MCESD added its Phoenix-Salt River monitor in 1998. 15 MCESD removed its Wickenburg monitor in 1998. 16 MCESD added the Phoenix-Durango Complex monitor in 1999, adding to monitoring data for the Salt River study area. 17 MCESD added a monitor in Higley, in 2000. 18 The Gilbert monitor was closed on December 31, 2001. 19 ADEQ's Higley monitor was removed in 2001. 20 ADEQ's Phoenix – Greenwood monitor was removed in 2001. 21 The Phoenix – ASU West monitor was closed on August 6, 2001. 22 MCESD placed an SPM monitor in Surprise, Arizona, in 2001. 23 The West 43rd Avenue monitoring site was opened on April 1, 2002. Appendix J – Maricopa County PM10 Monitors J- 10 APPENDIX K – WEIGHTING TRACKOUT EMISSIONS This approach was applied to data from an April 2004 ADEQ trackout survey, in which the incidents of trackout were divided into six source categories and three levels of severity. Table K-1 shows that the heaviest trackout occurred infrequently (i.e. 5 to 16% of the time for three categories and completely absent in the other three). Average and minimum trackouts were far more prevalent. TABLE K-1 Trackout Survey Summary Trackout Category Agricultural Construction Industrial Private Commercial Unpaved shoulders Observations Number Percent 11 12.2 19 21.1 19 21.1 1 1.1 9 10.0 31 34.4 Severity (Percent) Max 9 5 16 0 0 0 Avg 18 48 68 0 44 66 Min 73 47 16 100 56 34 These survey data would suggest, at first glance, that unpaved shoulders are the principal trackout source, with 34% of all observations from this category. But when severity is factored in, a much different picture emerges. Recalling the discussion on the length of trackout , the unpaved shoulders trackout loses even more ground to the industrial, construction, and agricultural categories. The survey confirms the expected: that a car driving on an unpaved shoulder will track out some, but not much, dirt onto the roadway for a fairly short distance. In contrast to this lightweight trackout, the trucks leaving construction or industrial sites will track out considerably more dirt for longer distances. Unpaved shoulders are an important source of trackout – as are all the sources. But by comparison with the heavier hitters, they are minor contributors. The weighting method, as explained in this appendix, is both logical and driven by data. All of these survey data are presented in Table K-2. Appendix K – Methodology for Weighting Trackout Emissions K-1 TABLE K-2 Trackout Survey of May – June 2004: Salt River PM10 Study Area Cell # 125 159 185 189 197 219 223 227 282 291 308 312 334 335 338 368 372 383 413 11 12 43 Trackout Class 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2 2 2 ADT (5.2)/2 3.2 (13.8)/2 3.2 (10+3.7)/2 3.2 (10+19.5)/2 (10+3.7)/2 19.1 19.4 5.9 19.1 (13.8)x10% (13.8)x10% 5.9 5.9 19.1 2.2 2.2 (6.1)/2 (6.1)/2 (4.5)/2 Severity 2 2 3 2 2 2 2 2 2 2 1 2 2 2 1 1 2 3 3 1 3 2 68 77 98 2 2 2 (1.5)/2 (1)/2 (1.5)/2 2 2 2 Appendix K – Methodology for Weighting Trackout Emissions Notes West bound Southern 43rd Ave South of Broadway North bound 51st Ave 43rd Ave south of Broadway 27th Ave & Broadway 43rd Ave south of Broadway Broadway & 35th Ave. 27th Ave & Broadway 35th Ave south of Lower Buckeye 19th Ave south of freeway 43rd Ave south of Lower Buckeye 35th Ave south of Lower Buckeye Minor street off 51st Ave. Minor street off 51st Ave. 43rd Ave south of Lower Buckeye 43rd Ave south of Lower Buckeye 35th Ave south of Lower Buckeye 15th Ave south of freeway 15th Ave south of freeway West bound Baseline West bound Baseline North bound 35th Ave. South bound 43rd Ave 27th Ave south of Southern South bound 43rd K-2 102 111 112 175 175 235 357 373 378 415 419 433 435 89 8 107 108 125 133 364 367 368 2 2 2 2 2 2 2 2 2 2 2 2 2 3 4 4 4 4 4 4 4 4 376 4 377 411 223 269 4 4 5 5 TABLE K-2 Trackout Survey of May – June 2004: Salt River PM10 Study Area Ave (5.6)/2 2 East bound Southern 13.9 3 Southern Ave east of 19th Ave 13.9 3 Southern Ave east of 19th Ave (16.4)/2 3 7th Ave south of Roeser (16.4+.1x16.4)/2 3 7th Ave & Sunland (20.4+18.3)/2 2 7th Ave & Broadway 24.4 2 Central Ave south of river 10.6 3 Lower Buckeye between 35th Ave & 27th Ave (10.8)/2 3 Lower Buckeye east of 27th Ave. east bound lane 20.4 3 7th Ave south of freeway 21.2 3 7th Street south of freeway 7.3 2 Durango Rd. 7.3 2 Durango Rd. (16.5)/2 3 7th Street south of Alta Vista 1.5 2 6.7 3 Southern Ave east of 27th Ave 6.7 3 Southern Ave east of 27th Ave (5.2)/2 1 West bound Southern (6.4)/2 2 West bound Southern (5.1+19.3)/4 3 NW corner of 51st Ave & Lower Buckeye 7.7 3 Lower Buckeye between 51st & 43rd Ave 7.7 3 Lower Buckeye between 51st & 43rd Ave Lower Buckeye between 35th Ave & 27th Ave. west bound lane (10.6)/2 3 Lower Buckeye between 35th Ave & 27th Ave. west bound (10.8+5.9)/2 3 lane and north bound 27th Ave (26.1+.1x26.1)/2 3 19th Ave south of freeway (10 +19.5)/2 2 Broadway & 35th Ave. (21.2)/2 3 7th Street south of river Appendix K – Methodology for Weighting Trackout Emissions K-3 370 371 372 385 494 509 535 8 8 34 69 99 109 110 119 125 125 127 133 197 223 227 235 236 244 274 369 370 371 373 5 5 5 5 5 5 5 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 TABLE K-2 Trackout Survey of May – June 2004: Salt River PM10 Study Area 11.2 2 Lower Buckeye between 43rd & 35th Ave 11.2 2 Lower Buckeye between 43rd & 35th Ave 11.2 2 Lower Buckeye between 43rd & 35th Ave 20.4 3 7th Ave south of freeway 31 3 Buckeye Rd (17.2)/2 3 Buckeye Rd west bound lane east of 7th street (21.8+9)/2 3 Northwest corner of 7th Ave & Lincoln (6.1)/2 3 East bound Baseline (6.1)/2 3 West bound Baseline 10.6 3 (1.5)/2 2 North bound 43rd Ave (1.5)/2 2 North bound 43rd Ave 6.7 3 Southern Ave east of 27th Ave 6.7 3 Southern Ave east of 27th Ave (16.5+21.6)/2 3 7th Street & Southern (5.2)/2 2 West bound Southern (13.8)/2 2 North bound 51st Ave (5.2)/2 2 West bound Southern (6.4)/2 2 West bound Southern (3.7)/2 2 27th Ave south of Broadway (10+19.5)/2 2 Broadway &35th Ave. (3.7)/2 2 27th Ave south of Broadway (20.4+18.3)/2 3 7th Ave & Broadway (18.3)/2 3 Broadway west of Central Ave (13.8)/2 2 North bound 51st Ave (13.8)/2 2 North bound 51st Ave 11.2 2 Lower Buckeye between 43 rd & 35th Ave 11.2 2 Lower Buckeye between 43 rd & 35th Ave 11.2 2 Lower Buckeye between 43 rd & 35th Ave (10.6)/2 3 Lower Buckeye between 35th Ave & 27th Ave west bound Appendix K – Methodology for Weighting Trackout Emissions K-4 374 6 375 6 428 429 6 6 458 459 6 6 488 489 6 6 Trackout Class 1 = Industrial 2 = Construction 3 = Private 4 = Agriculture 5 = Commercial 6 = Unpaved Shoulders TABLE K-2 Trackout Survey of May – June 2004: Salt River PM10 Study Area lane Lower Buckeye between 35th Ave & 27th Ave. west bound (10.6)/2 3 lane Lower Buckeye between 35th Ave & 27th Ave. west bound (10.6)/2 3 lane South bound 43rd (12)/2 2 Ave (12)/2 2 North bound 43 rd Ave South bound 43rd (12)/2 2 Ave (12)/2 2 North bound 43 rd Ave South bound 43rd (18.1)2 2 Ave (18.1)/2 2 North bound 43 rd Ave ADT ADT = Average Daily Traffic Count Using 1999 Totals in Thousands Severity 1 = Maximum 2 = Moderate 3 = Minimum The next step in the weighting approach was to assign silt loading values to the maximum, average, and minimum trackout segments. In Table K-3, these silt loadings are given on the top row, with a weighted silt loading based on the percentage occurrence given in the far right column. Appendix K – Methodology for Weighting Trackout Emissions K-5 TABLE K-3 Silt Loading Values by Source Category Note: Bold figures are silt loading in g/m2; other figures are percentages from Table K-1 Trackout Category Silt loading (g/m2) Agricultural Construction Industrial Private Commercial Unpaved shoulders Maximum Average 12 1.5 9% 18% 5% 48% 16% 68% 0% 0% 0% 44% 0% 66% Combined Silt Minimum Loading (g/m2) 0.75 73% 1.90 47% 1.67 16% 3.06 100% 0.75 56% 1.08 34% 1.25 These source category silt loadings, weighted by the percentage occurrence of the minimum, average, and maximum observed trackout segments, result in an overall silt loading for each of the source categories. As this set of silt loadings depends critically on the assigned values, these are discussed below. The average value of 1.5 g/m2 is used in the inventory for trackout, and is six times the average value for “clean streets” of 0.3 g/m2, less 0.3. This value is consistent with local silt loading data, as evidenced in Tables K-4 and K-5. TABLE K-4 Silt Loading Measurements in the Salt River PM10 Area from 2003 Location Silt Loading (g/m2) 19th Ave S Lower Buckeye 0.38 19th Ave S river N Broadway 0.57 W. Broadway 38th Drive 0.24 51st Ave S of bridge 0.12 Lower Buckeye W 35th Ave 2.10 Appendix K – Methodology for Weighting Trackout Emissions K-6 TABLE K-5 Silt Loading Measurements in Tucson and Phoenix from the Mid 1980s Silt Type Site Loading 2 (g/m ) 6th Ave & 28th Street 1.269 arterial th Avalon & 25 0.523 local Speedway Blvd E. of Pantano 0.398 busy arterial Apache (9th/10th Streets) 0.279 busy arterial Orange Grove E. of C. dl Tierra 0.160 mod arterial Broadway/Central 0.126 busy arterial Ft. Lowell E. of Alvernon 0.112 mod arterial La Canada, N of Orange Grove 0.105 local 59th Ave & Peoria 0.098 busy arterial Mesa Drive 0.098 mod arterial South Central 0.084 mod arterial 3rd & Miller 0.070 local 43rd Ave & Vista 0.042 busy arterial Indian School/28th St 0.035 busy arterial 28th Street & Glenrosa 0.035 local 17th Ave and Highland 0.028 local 22nd St. E. of Camino Seco 0.028 busy arterial Ina Rd E. of La Cholla 0.021 busy arterial E. McKellips & Olive 0.014 busy arterial Anklam Rd, St Mary's Rd 0.014 mod arterial Oracle Rd S. of Kanmar 0.014 busy arterial The silt loading assigned to the average trackout of 1.5 g/m2 places it above the distribution of Table K-4 but lower than four of the five Salt River silt loading measurements in Table K-5. The maximum value of 12 g/m2 in Table K-3 is somewhat problematic, but numbers as high as 50 g/m2 were obtained on 43rd Avenue. Three 43rd Avenue values were around 10, and one was 55 g/m2, all in the heavily tracked out lane. The assigned value would appear to be approaching the mean of this heavily tracked out section of pavement. The minimum value of 0.75 g/m2 in Table K-3 is higher than the 0.3 g/m2 average. The average silt loading of 0.3 g/m2 was applied to all primary and secondary streets in the Salt River PM10 Study Area, and, therefore drove the vehicular emissions calculations for the inventory. The 0.3 g/m2 value is the average of the top four contemporary silt loading measurements in Table K-4. Since these measurements were taken on pavement with no visual trackout, assigning a value somewhat more than double the average for light trackout is reasonable. With the assigned silt loading values for the three degrees of trackout, and with the percentages by source category, the overall source category silt loading values have Appendix K – Methodology for Weighting Trackout Emissions K-7 been calculated (Table K-6). These silt loading values then enabled the calculation of emission rates. When these rates were combined with the estimated average length of the trackout by source category, the relative emission rate of the trackout type was obtained (Table K-6, far right column, “Norm to Industrial”). Table K-6 Reentrained Emission Rates for Six Trackout Source Categories Distance *Silt **E ***Distance ****Norm to Trackout Category (m) (g/m2) (g/mi) xE Industrial Agricultural 100 1.90 4.214 421 0.36 Construction 200 1.67 3.866 773 0.66 Industrial 200 3.06 5.826 1165 1.00 Private 50 0.75 2.209 110 0.09 Commercial 50 1.08 2.857 143 0.12 Unpaved Shoulders 50 1.25 3.154 158 0.14 * Silt = Silt loading in grams per meter squared **E = PM10 reentrained emission rate in grams per mile *** “Distance x E = Distance of the trackout segment times the emission rate in grams times meters per mile **** “Norm to Industrial = Normalized to the industrial category: i.e. all figures in the “Distance X E” column have been divided by the value for industrial, 1165. The distance values listed in Table K-6 are estimates from discussions with staff who conducted the survey. The silt loading values come from Table K-3. The emission rates in grams per mile come directly from the AP-42 equation below. E = k {sL/2}^.65 *(W/3)^1.5 – C where : sL = silt loading in g/m2 W = average vehicle weight C = constant that reflects the 1980 exhaust, brake, and tire wear emissions K = constant that reflects the particle size fraction, and E = reentrained emission rate in grams per mile. Appendix K – Methodology for Weighting Trackout Emissions K-8 Example: W = 2.2 tons C = .2119 g/mi k = 7.3 for PM10 E = 7.3*{sL/2)^.65 * (2.2/3)^1.5 - .2119 = 4.58*(sL/2)^.65 - .2119 Then plugging various values of silt loading (sL) into the above equation results in the reentrained emission rates listed in Table K-7. TABLE K-7 Reentrained Emission Rates Silt Loading Emission Rates 2 (sL g/m ) (g/mi) 3.00 5.749 0.30 1.123 1.50 3.587 0.75 2.209 This method provides a set of distance-weighted and silt-loading weighted emission rates that account for both the length and severity of the trackout. For example, if industrial trackout is set to an emission factor of 1.0, then the other categories have the weightings shown in Table K-8. TABLE K-8 Trackout from Six Source Categories Weighted by Length and Severity Relative Emission Category Rate Industrial 1.00 Construction 0.66 Agricultural 0.36 Unpaved shoulders 0.14 Commercial 0.12 Private 0.09 These relative weightings were applied to the predicted concentrations from the Industrial Source Complex model by source category (Appendix P). The weighted concentrations formed the basis of the predicted impacts of trackout on the ambient air at the four Salt River PM10 Study Area monitors. Appendix K – Methodology for Weighting Trackout Emissions K-9 Table K-9 lists the total lengths associated with the six trackout categories found in the Salt River PM10 Study Area. TABLE K-9 Total Length of Trackout By Source Category Average Number of Total Length of Track-Out Type Track-Out Distance Occurences Track-Out (meters) by Track-Out Type (meters) Agricultural 100 11 1,100 Construction 200 19 3,800 Industrial 200 19 3,800 Private 50 1 50 Commercial 50 9 450 Unpaved Shoulders 50 31 1,550 Appendix K – Methodology for Weighting Trackout Emissions K-10 APPENDIX L - HOW STREET SWEEPING REDUCTIONS WERE CALCULATED The basis of these calculations is a set of tables, produced by Sierra Research, Inc, that quantify the emission reductions from both conversion of conventional street sweepers to PM10 efficient sweepers as well as the reductions from an increase in sweeping frequency. These tables appear in a Maricopa Association of Governments document called “Methodologies for Evaluating Congestion Mitigation and Air Quality Improvement Projects”, December 9, 2003, pages 31 – 36. All sweepers in the Salt River PM10 Study Area were reported to be of the PM10 efficient kind in 2002, the base year of the study. Reductions in this study area, then, depend solely on an increase of frequency. Other aspects of reducing reentrained emissions from paved roads concern the silt loading and the portion of roads targeted for increased sweeping. For the calculation of basic reentrained emissions (and street sweeping benefits), the silt loading was held constant at 0.3 g/m2, the average value for the Study Area. Areas of heavy trackout with their elevated emissions were put into the inventory and were modeled explicitly. Their emission reduction of 80% was attributed to better enforcement of Maricopa County Rules 316, 310, and 310.01 and to the increased sweeping of targeted streets. This reduction, however, is independent of the general paved road reentrained emission reduction from increased sweeping. Because of insufficient information on trackout silt loading and trackout length, treating trackout silt loading and sweeping frequency explicitly was impossible. Therefore, the only calculated PM10 reentrained emission reductions come from increasing the frequency on targeted streets. Streets in the Salt River area were divided into three types: primary (one-mile), one-half mile, and all others, i.e. collector, local, residential. Targeted increased sweeping was limited to those one-mile and half-mile streets adjacent to industrial, construction, or agricultural properties. Tables L-1 through L-3 illustrate how reentrained road emissions vary with sweeping frequency. The “Conven” column refers to the conventional sweeper; the “PM10” refers to the PM10 efficient sweeper. The emission rates are expressed in units of grams per vehicle mile traveled. Appendix L – Street Sweeping Reductions L-1 TABLE L-1 Reentrained Road Emissions with Sweeping Once Every Two Weeks Day Sweep 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Sweep 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Sweep Every Two Weeks (2 Sweeps per month) Appendix L – Street Sweeping Reductions EF (g/VMT) Conven PM10 0.87 0.39 0.95 0.5 1.03 0.61 1.1 0.7 1.1 0.79 1.1 0.87 1.1 0.95 1.1 1.03 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 0.87 0.39 0.95 0.5 1.03 0.61 1.1 0.7 1.1 0.79 1.1 0.87 1.1 0.95 1.1 1.03 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.07 0.89 L-2 TABLE L-2 Reentrained Road Emissions with Sweeping Once a Week Day Sweep 1 2 3 4 5 6 Sweep 7 8 9 10 11 12 Sweep 13 14 15 16 17 18 Sweep 19 20 21 22 23 24 25 26 27 28 1 Sweep Once a Week (4 sweeps per month) Appendix L – Street Sweeping Reductions EF (g/VMT) Conven PM10 0.87 0.39 0.95 0.5 1.03 0.61 1.1 0.7 1.1 0.79 1.1 0.87 1.1 0.39 0.87 0.5 0.95 0.61 1.03 0.7 1.1 0.79 1.1 0.87 1.1 0.39 1.1 0.5 0.87 0.61 0.95 0.7 1.03 0.79 1.1 0.87 1.1 0.39 1.1 0.5 1.1 0.61 0.87 0.7 0.95 0.79 1.03 0.87 1.1 0.39 1.1 0.5 1.1 0.61 1.1 0.7 1.04 0.64 L-3 TABLE L-3 Reentrained Road Emissions with Sweeping Three Times a Month EF (g/VMT) Day Conven PM10 Sweep 1 0.87 0.39 2 0.95 0.5 3 1.03 0.61 4 1.1 0.7 5 1.1 0.79 6 1.1 0.87 7 1.1 0.95 8 1.1 1.03 Sweep 9 1.1 0.39 10 1.1 0.5 11 1.1 0.61 12 1.1 0.7 13 1.1 0.79 14 1.1 0.87 15 0.87 0.95 16 0.95 1.03 17 1.03 1.1 Sweep 18 1.1 0.39 19 1.1 0.5 20 1.1 0.61 21 1.1 0.7 22 1.1 0.79 23 1.1 0.87 24 1.1 0.95 25 1.1 1.03 26 1.1 1.1 27 1.1 1.1 28 1.1 1.1 3 Sweeps per Month 1.07 0.78 Appendix L – Street Sweeping Reductions L-4 Notice that the type of sweeper results in marked differences in emission rates. 1. The emission rates for the PM10 efficient sweepers are lower than for the conventional sweepers; and 2. Streets swept by conventional sweepers return to their pre-sweeping equilibrium value of 1.1 g/VMT on the fourth day but the streets swept with PM10 efficient machines don’t reach equilibrium until the ninth day (see Table L-1). Averaging the emissions for the 28 day period, with the PM10 efficient sweepers, gives a 0.89 g/VMT value for the once every two weeks schedule, and a 0.64 g/VMT value for the once a week schedule. Three sweeps in the 28-day period gives an emission rate of 0.74 g/VMT. Therefore, doubling the frequency of sweeping from once every two weeks to once a week reduces emissions by 28.1%. Applying these emission reductions to the Salt River PM10 Area becomes somewhat complicated, because not all the streets would be subject to increased sweeping. First, the half-mile streets need to be separated from the remainder of the “secondary roads.” This was done in consultation with MAG staff and amounted to the assumption that 80% of the vehicle miles traveled (VMT) on secondary roads occurs on the half-mile streets. Second, the fraction of mile and half-mile streets subject to frequent trackout had to be estimated. This was done by reviewing satellite images of the area and counting the primary and secondary (in this case, half-mile streets only) street lengths adjacent to and within one quarter a mile of industrial, construction, and agricultural land. The percentages of mile and half-mile roads subject to additional sweeping are given in Table L-4. Onemile Halfmile TABLE L-4 Salt River PM10 Study Area Roads Subject to Additional Sweeping Length Percentage of Streets with Potential Trackout of All Streets Industrial Miscellaneous* Agricultural Total (Miles) 89 14.1 20.3 28.9 63.3 50 6.2 22.1 37.7 66.0 *The miscellaneous category consists of construction sites, unpaved shoulders, and trackout from private (not industrial, construction, or agricultural) sources. Appendix L – Street Sweeping Reductions L-5 Combining the roads subject to trackout, and therefore, increased sweeping, with the emission reductions of Tables L-1 and L-2, results in the emission rates and estimated emission reduction shown in Table L-5. The following notes are provided to assist in understanding Table L-5. 1. Road Type: Primary is one-mile; secondary is half-mile streets 2. Trackout Type: “Misc” consists of construction, road shoulders, and private, or “miscellaneous.” 3. % Swp: % of roadways in Salt River Area subject to this type of sweeping 4. Base Freq: Sweeping frequency assumed for the base year. 5. SIP Freq: Projected 2006 sweeping frequency. For the rain and dust sweeping, the base frequency is once per two weeks, with 12 days added per year for sweeping after major rains and dust storms. 6. “% Visible”: All figures are 100%, reflecting that targeted sweeping would take place along the entire length of the street with trackout potential, not just the visibly dirty portion. 7. % Covered: The percentage of roadways that would be swept at a higher frequency. These percentages are equal to the “% swp” column except for agricultural trackout. Agricultural streets have been reduced by 80%, reflecting the 20% of the year that fields are being worked or tilled or recently planted. It is only under these conditions that agricultural trackout is likely. 8. Emission Rates: Based on PM10 efficient street sweepers only, for base and future years. The overall emission rate is the combination of the base rate and its street percentage with the control rate with its percentage. 9. % Reduc: The emission reduction percentages on the far right of the table come from increasing the sweeping frequency on that fraction of the streets affected by the five trackout types. These types are Industrial Miscellaneous (private, road shoulder, construction) Agricultural Heavy rain washout Heavy dust deposition. 10. The heavy rain washout and heavy dust deposition lines in the table require additional explanation. First, 10% and 5% of primary and secondary roads are assumed to be affected. The base frequency of one sweep per two weeks is supplemented with one additional sweeping day a month (12 days of Appendix L – Street Sweeping Reductions L-6 storms per year). Thus, the base emission rate of 0.89 g/VMT changes to the control rate of 0.78 g/VMT which comes from Table L-3. To further clarify the calculations, the following bullets explain the results shown in the first row, for primary roads near industrial sites. • First, 14.1% of the primary roads in the Salt River area either border or are within 1/4 mile of an industrial site. • Second, the base (2002) frequency of sweeping is once every two weeks, with PM10 efficient sweepers. • Third, the proposed industrial sweeping criterion is to "sweep weekly or whenever visible trackout is observed." The frequency could be anywhere from daily to weekly, depending on the prevalence of visible trackout. The table reflects an assumed frequency of once per week. • Fourth, the %visible figures have been set to 100%. This reflects the fact that the sweeper would sweep the entirety of the street near the industrial site, even if the trackout does not occur on the entire length of the street. • Fifth, "% covered", 14.1%, is the percentage that the primary roads near industrial sites comprises of all primary roads. • Sixth, base and control emission rates (0.89 g/VMT and 0.64 g/VMT) were taken from Tables L-1 and L-2. These emission rates reflect the base and proposed sweeping frequencies. • Seventh, the overall emission rate of 0.85 g/VMT is the rate for all primary roads. This overall emission rate accounts for the 14.1% of primary roads that border or are within ¼ mile of an industrial facility being swept once a week and the remaining primary roads being swept once every two weeks. • Eighth, the percentage reduction is that of the overall emission rate compared with the base emission rate. • Ninth, the "primary" percent reduction of 12.58% near the bottom right of the table is the sum of the four primary percentage reductions. • Tenth, the half-mile street reduction of 7.19% is merely the secondary street reduction of 8.99 multiplied by 80%. The figures of primary (one-mile) and half-mile reentrained emission reductions from increased sweeping appear on page 6-12 of the TSD. Appendix L – Street Sweeping Reductions L-7 TABLE L-5 Calculation of Reentrained Emissions for the Salt River PM10 Study Area Emission Rate Type % Swp Base Freq SIP Freq % Visible % Covered Base (g/VMT) Control Overall % Reduc Primary Indus 14.1 1 per 2 wks 1per wk 100 14.1 0.89 0.64 0.85 3.96 Second Indus 6.2 1 per 2 wks 1per wk 100 6.2 0.89 0.64 0.87 1.74 Primary Misc 20.5 1 per 2 wks 1per wk 100 20.5 0.89 0.64 0.84 5.76 Second Misc 22.1 1 per 2 wks 1per wk 100 22.1 0.89 0.64 0.83 6.21 Primary Agric 28.9 1 per 2 wks 1per wk 100 5.8 0.89 0.64 0.82 1.62 Second Agric 7.5 1 per 2 wks 100 1.5 0.89 0.64 0.87 0.42 Primary Rain/Dst 10.0 1 per 2 wks 100 10.0 0.89 0.78 0.88 1.24 Second Rain/Dst 5.0 1 per 2 wks 1per wk Base + Rain/Dust Base + Rain/Dust 100 5.0 0.89 0.78 0.88 0.62 Primary 63.5 % of roads covered 12.58 Secondary 35.8 % of roads covered 8.99 1/2 Mile Only (no Residential), with 1/2 Mile Streets having 80% of VMT Appendix L – Street Sweeping Reductions 7.19 L-8 APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND Changes to background concentrations from area-wide controls are calculated for specific emission types by: 1. Figuring the percentage that each emission type comprises of the total metropolitan PM10 inventory; 2. Dividing the spatial distribution of the category emissions into six zones of increasing distance from the Salt Industrial area; 3. Figuring the percentage of emissions occurring in each of the six zones; 4. Applying a 1/r2 weighting as the transport potential to the emission percentage by zone; 5. Adding these weighted percentages (This gives a transport percentage by emission type); and 6. Multiplying this transport percentage by the percentage of the emission type of the total inventory, giving an "urban background reduction percentage." This percentage would then be applied to any control-strategy based metropolitan wide reduction percentage to give the ultimate background reduction. The PM10 emissions for metropolitan Phoenix come from the Maricopa Association of Governments 1995 emission inventory. Only certain components of the inventory matched up with source categories from the Salt River inventory. These are given in Table M-1. APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-1 TABLE M-1 Urban-wide PM10 Emissions Tons/ % Emission Type Category Day Total Construction activity fugitive dust Nonroad 22.85 15.86 Entrainment from construction trackout Nonroad 6.10 4.23 Industrial processes Point 2.63 1.83 Stationary Process fugitives Area 0.42 0.29 Paved road dust Onroad 56.40 39.14 Ag tilling 5.58 3.87 Total of all sources* 144.05 Transport Percent 28.59 Reduction Percent 4.53 28.59 32.42 1.21 0.59 32.42 28.90 28.59 0.09 11.31 1.11 25.27 25.27 Windblown is treated separately, since it is its own category Windblown 3860 100 *The total of all sources means the total in the inventory. This figure is much higher than the total of the sources listed in the table, since many categories did not have a match in both the metropolitan and Salt River inventories. The spatial distribution of these emission sources throughout the metropolitan area is given in emission density plots built by MAG for their PM10 SIP inventory. These plots are shown below, along with the designated six zones of increasing distance from the Salt River study area. The emissions in each zone are tabulated in Table M-2. Table M-3 presents the emissions by category and by zone, with first the raw percentages and seconds the weighted percentages. The weighting is based on a 1/r2 decay, with the decimal weighting factors shown for convenience. Moving from zone 1, the closest to the Salt River study area, to zone 6, the farthest away, the decimal zone fractions decrease, and so must the weighted percentages. All of this is merely a numerical and tabular illustration that the influence of emissions diminishes with distance. When the weighted percentages from all six zones are summed, the result is an overall “transport percentage.” This figure can be considered the overall metropolitan potential for a particular emission category to reach the Salt River study area. These transport percentages, calculated in Table M-3, are also shown in Table M-1. When this transport percentage is multiplied by the percentage that the emission category comprises of the total emissions, the product is the “urban background reduction percentage.” To put this necessarily numeric argument into practice, consider the top line of Table M-1, concerning “construction activity fugitive dust.” This emission source at 22.85 tons/day comprises 15.86% of the metropolitan PM10 emissions. From Table M-2 and the APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-2 nonroad emission density map, with the 1/r2 for the distance weighting factor, the transport percentage of 28.59 is calculated. Multiplying this percentage by 15.86%, the share of the total inventory attributed to construction dust, gives the “urban background reduction percentage” of 4.53. This figure should be interpreted as follows: if construction dust throughout the metropolitan area were reduced by 50% (from about 23 tons to 11.5 tons), then the PM10 concentrations at the border of the Salt River study area would be reduced by 2.27% (50% of 4.53%). The response of Salt River background concentrations to metropolitanwide emission reductions depends on: 1. What reduction can be expected to a particular source category, and how important that source category is to the metropolitan emission total; and 2. How the emissions of that particular source category are distributed throughout the metropolitan area. APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-3 Figure M-1. Onroad Mobile PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-4 Figure M-2. Point source PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-5 Figure M-3. Area source PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-6 Figure M-4. Nonroad Mobile PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-7 Figure M-5. Windblown PM10 Emission Density Plot for Metropolitan Phoenix with Salt River Zones of Influence APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-8 TABLE M-2 Number of Grid Cells with a Specified Emission Range by Zone Point Sources Emissions (kg/day) Zone 1-25 25-50 50-100 >100 Average Emissions 12.5 37.5 75.0 150.0 1 15 1 1 0 2 14 1 0 0 3 19 0 1 1 4 8 2 2 0 5 4 1 0 0 6 1 1 0 1 Nonroad Emissions (kg/day) Zone 1-100 100-250 250-500 >500 Average Emissions 50.0 175.0 375.0 750.0 1 103 22 11 0 2 208 31 4 2 3 233 66 25 0 4 232 29 12 0 5 125 16 4 1 6 94 4 1 0 Onroad Emissions (kg/day) Zone 1-150 150-300 300-500 >500 Average Emissions 75.0 225.0 400.0 750.0 1 98 24 1 0 2 140 16 0 0 3 237 7 1 0 4 189 5 3 3 5 135 9 1 0 6 61 3 5 3 Windblown Emissions (kg/day) 10025005>10,000 Zone 2500 5000 10,000 Average Emissions 1300.0 3750.0 7500.0 15000.0 1 68 17 28 1 2 108 32 65 4 3 175 20 62 6 4 245 26 56 2 5 242 20 21 0 6 225 11 15 0 APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-9 TABLE M-3 Calculation Table for Emissions by Zone, Percent, and Weighted Percent: Urban Background Adjustment Point Sources Emissions (kg/day) Zone 1-25 25-50 50-100 >100 Average Zone Weighted Emissions 12.5 37.5 75.0 150.0 Total Percent Weight Percent 1 187.5 37.5 75.0 0.0 300.0 18.9 1.00 18.90 2 175.0 37.5 0.0 0.0 212.5 13.4 0.36 4.82 3 237.5 0.0 75.0 150.0 462.5 29.1 0.18 5.35 4 100.0 75.0 150.0 0.0 325.0 20.5 0.11 2.27 5 50.0 37.5 0.0 0.0 87.5 5.5 0.07 0.41 6 12.5 37.5 0.0 150.0 200.0 12.6 0.05 0.67 Total 1587.5 32.42 Nonroad Emissions (kg/day) 100250Zone 1-100 250 500 >500 Average Zone Weighted Emissions 50 175 375 750 Total Percent Weight Percent 1 5150 3850 4125 0 13125 12.8 1.00 12.77 2 10400 5425 1500 1500 18825 18.3 0.36 6.59 3 11650 11550 9375 0 32575 31.7 0.18 5.82 4 11600 5075 4500 0 21175 20.6 0.11 2.29 5 6250 2800 1500 750 11300 11.0 0.07 0.82 6 4700 700 375 0 5775 5.6 0.05 0.30 Total 102775 28.59 Onroad Emissions (kg/day) 150300Zone 1-150 300 500 >500 Average Zone Weighted Emissions 75 225 400 750 Total Percent Weight Percent 1 7350 5400 400 0 13150 15.0 1.00 14.98 2 10500 3600 0 0 14100 16.1 0.36 5.78 3 17775 1575 400 0 19750 22.5 0.18 4.13 4 14175 1125 1200 2250 18750 21.4 0.11 2.37 5 10125 2025 400 0 12550 14.3 0.07 1.06 6 4575 675 2000 2250 9500 10.8 0.05 0.58 Total 87800 28.90 APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-10 TABLE M-3 Calculation Table for Emissions by Zone, Percent, and Weighted Percent: Urban Background Adjustment Windblown Emissions (kg/day) 10025005Zone 2500 5000 10,000 >10,000 Average Zone Weighted Emissions 1300 3750 7500 15000 Total Percent Weight Percent 1 88400 63750 210000 15000 377150 9.7 1.00 9.67 2 140400 120000 487500 60000 807900 20.7 0.36 7.45 3 227500 75000 465000 90000 857500 22.0 0.18 4.04 4 318500 97500 420000 30000 866000 22.2 0.11 2.47 5 314600 75000 157500 0 547100 14.0 0.07 1.04 6 292500 41250 112500 0 446250 11.4 0.05 0.61 Total 3901900 25.27 APPENDIX M - EMISSION DENSITY MAPS OF BACKGROUND M-11 APPENDIX N - WIND ROSES Three of the four monitoring sites in the Salt River PM10 Study Area were equipped with meteorological instruments in 2002. These sites were South Phoenix, West 43rd Avenue, and Durango. The Salt River site had no meteorological equipment. The West 43rd Avenue site began operation in April; the other two, both long-term County sites, had full annual records. Because of the shortened record at West 43rd Avenue, seasonal and annual patterns of winds shown in the following figures are based on either South Phoenix or Durango. A three-site comparison will be limited to the last three months of 2002. Distances between the three sites are given in Table N-1. TABLE N-1 Salt River PM10 Study Area Sites with Meteorological Data Site A to Site B Direction Meters Miles rd West 43 Ave. to South Phoenix E 7133 4.43 West 43rd Ave to Durango NE 3667 2.28 Durango to South Phoenix SE 5267 3.27 South Phoenix and West 43rd Avenue lie near the south bank of the Salt River, at distances of 1.4 and 0.4 miles, respectively, from the center line of the channel. Durango is on the north bank of the river, at a distance of 1.2 miles. A complete discussion of how the topographical features influence wind patterns is beyond the scope of this response. Only a few of the basic features will be discussed. Figure N-1 shows the elevations of the terrain in south-central Arizona and in the Phoenix metropolitan area. First, the Salt River Valley of metropolitan Phoenix lies at the southwestern edge of some rapidly rising terrain. Second, to the west and southwest of the valley, desert elevations, punctuated by mountain ranges, predominate all the way to the Colorado River at Yuma. The meso-scale circulation is driven by valley-to-mountain flow in the daytime (winds from the west) and by mountain-to-valley downslope flow at night (winds from the east and northeast). Third, on a metropolitan scale, these three wind monitors would be expected to be influenced by Salt River channel flow and by nocturnal drainage off the slopes of the South Mountains and, perhaps, from downslope flow from the Estrella Mountains. Slope flow from the north would not be expected, as the southerly flowing Agua Fria River lies 10 miles to the west of the Study Area and the southerly flowing Verde River lies 18 miles to the eastnortheast. Figure N-=2 shows the location of the meteorological stations on a satellite image of the Salt River PM10 Study Area. APPENDIX N - WIND ROSES N-1 Phoenix area Yuma Salt River PM10 Study Area Figure N-1. Elevations in South-central Arizona (top), in Metropolitan Phoenix (bottom), with the Salt River PM10 Study Area Shown in the Lower Figure APPENDIX N - WIND ROSES N-2 Figure N-2. Salt River Meteorological Sites APPENDIX N - WIND ROSES N-3 A series of wind roses from these three monitors is shown below. In each rose, the length of the bar (and its designated numerical value) is the percentage of the time that the wind is coming from a particular direction. Each directional bar is divided into sub-lengths of wind speed. The speeds in meters per second can be converted to miles per hour by multiplying by 2.24. The first set of roses is from South Phoenix: annual, seasonal, and seasonal in blocks of six hours. Following this are a wind rose from Durango and then roses from all three sites. A few observations on this series, all from South Phoenix, except the last two figures, are: • The annual pattern (Figure N-3) is dominated by local down-valley and up-valley wind flow, resulting in the high and nearly equal frequencies of east and west winds. “Down and up valley’ refer to the Salt River Valley, aligned east and west. Given this dominance, the southerly and northerly components are minor. Southerly winds occur more often than northerly winds, reflecting the influence of down-slope drainage from the South Mountains. • In the seasonal variation, spring and summer (Figure N-4) have more westerlies than the other two seasons, about 25% in contrast to 15%. This may reflect the spring and early summer dry cold fronts that move into the Salt River Valley from the west. The higher wind speeds in these seasons can be attributed to the same phenomenon. In contrast, the fall and winter lower wind speeds are a consequence of high pressure patterns that suppress the passage of high-wind synoptic fronts. • The six-hour blocks by season (Figures N-5 through N-8) illustrate the daytime (hours 12 – 17) upslope flow from the west and the nighttime (hours 00 – 05) downslope flow from the east. • In the seasonal hourly block pattern, drainage flow from the South Mountains (Figure N-5) is evident in the winter and fall hours of 18 – 23, but is either absent or muted in the other seasons and hourly blocks. By the 00 – 05 hours, the wind direction has completed its transition from west to east. To further explain, the mesoscale flow reversal along the Salt River takes place from 1800 to 2300 hours. During this reversal west and east winds would be suppressed, perhaps allowing the southerly drainage flow to persist. By midnight the mesoscale easterly flow has been established, and has apparently grown strong enough to overwhelm the South Mountain nocturnal drainage flow. APPENDIX N - WIND ROSES N-4 • Also in the seasonal pattern of hourly blocks, the “local wind” pattern differs between spring and summer on the one hand and fall and winter, on the other. In spring and summer the westerly flow lasts longer into the night (block 18 – 23) and maintains higher speeds than in fall and winter. The reversal of the nocturnal wind flow is not completed until the early morning. This later upslope flow is consistent with the later sunset times and residual surface heat of the late spring and summer. • In comparing the patterns at Durango and South Phoenix, Figure N-9 ( Durango) should be contrasted with Figure N-5 (South Phoenix), Daytime hours (12 – 17) are nearly identical in directions with Durango having higher speeds. For the evening and nighttime hours (hours 18 – 23) the wind patterns at the two sites are quite different. Durango is dominated by westerlies, but South Phoenix has pronounced easterly and southerly components. This difference can be interpreted as the earlier transition from westerlies to easterlies at South Phoenix than at Durango, with the latter site once again having higher speeds. Midnight through 5:00 a.m. (hours 00 – 05) has a significant northerly component at Durango that’s completely absent from South Phoenix. Also during this time the South Phoenix winds are dominated by a strong easterly vector. At Durango, in contrast, the winds are more evenly distributed among the west, north, and east directions, indicating that on the north side of the Salt River the transition to nocturnal down-valley flow is slower to arrive than at South Phoenix. During the 6 – 11 hours, although the principal components of the easterly direction are nearly the same at the two sites, Durango has a much stronger southerly component than does South Mountain. All of this demonstrates that two sites 3.3 miles apart along the same major river can have significantly different wind patterns. Apparently the South Phoenix site’s being closer to the South Mountain ridgeline than Durango has a pronounced influence on the timing of the flow reversal, as well as on the overall directional patterns and lower speeds. Also of considerable importance for all hourly blocks is the difference in wind speeds: Durango is substantially higher than South Phoenix. This holds for all hourly blocks and virtually all directions. • The last Figure (number N-10) is a comparison of the three sites. With the data record at West 43rd Avenue being incomplete, and realizing that the instrument was operated only for April – December, 2002, it was not possible to present three annual wind roses. Instead, wind patterns for October through December are shown. Differences among the sites are that Durango has higher speeds than the other two; South Phoenix has a much higher frequency of east winds than APPENDIX N - WIND ROSES N-5 the other two; and both Durango and West 43rd Avenue have a small but perceptible northerly component absent from South Phoenix. Surprisingly South Phoenix fails to exhibit a stronger southerly component than the other two, in spite of its location closest to down slope from the South Mountains. APPENDIX N - WIND ROSES N-6 South Phoenix 2002 N 0.58 0.77 0.94 2.00 1.39 8.39 5.83 20.49 W 20.06 9.46 E 10.10 4.86 4.25 4.31 3.19 3.38 S 1 2 3 4 5 6 Calms excluded. No observations were missing. Wind Speed ( Meters Per Second) PERCENTOCCURRENCE: LOWER BOUND OF CATEGORY 1 2 3 4 5 DIR N 0.33 0.13 0.06 NNE 0.51 0.12 0.04 NE 0.63 0.31 0.19 ENE 1.59 1.22 1.07 E 4.78 4.62 3.67 ESE 4.20 2.09 SE 2.50 0.69 SSE 1.83 0.42 6 Figure N-3. South Phoenix Wind Rose: Annual APPENDIX N - WIND ROSES N-7 South Phoenix Winter (Jan, Feb and Dec) South Phoenix Spring (Mar,Apr and May) N N 0.65 0.39 1.57 0.98 1.51 0.85 0.85 0.79 2.79 0.67 10.74 7.01 5.83 15.32 W 23.58 7.33 4.72 5.63 3.73 2.88 3.34 E W 5.10 25.49 15.72 15.52 6.07 S 1 2 3 4 5 6 Wind Speed ( Meters Per Second) Calms excluded. No observations were missing. 1 2 3 4 5 6 Wind Speed ( Meters Per Second) N 0.72 0.60 0.66 1.79 1.55 0.86 0.48 0.81 2.31 1.78 17.38 E 15.16 W 24.11 8.11 5.76 4.53 5.43 4.83 3.82 3.82 4.20 3.01 4.41 2.74 3.77 2 3 4 5 6 Wind Speed ( Meters Per Second) E 13.66 S S 1 5.73 5.49 5.59 25.12 10.76 Calms excluded. No observations were missing. South Phoenix Fall (Sep, Oct and Nov) N W 3.16 4.19 3.34 2.55 S South Phoenix Summer (Jun,jul and Aug ) 11.03 E 6.37 11.35 1 Calms excluded. No observations were missing. 2 3 4 5 6 Wind Speed ( Meters Per Second) Calms excluded. No observations were missing. Figure N-4. South Phoenix Wind Rose: Seasonal APPENDIX N - WIND ROSES N-8 South Phoenix Winter(Jan, Feb and Dec) Hour 00-05 South Phoenix Winter(Jan, Feb and Dec) Hour 06-11 N N 0.00 0.93 0.62 0.31 0.93 1.05 0.00 0.52 1.57 2.36 1.85 5.25 W 11.26 2.36 4.32 32.41 E 12.04 W 6.79 36.13 4.45 23.15 4.01 9.26 2.78 2.47 4.94 3.40 2.36 1.57 1.57 1.05 S 1 2 3 4 5 6 Wind Speed ( Meters Per Second) W S Calms excluded. No observations were missing. 1 2 3 4 5 6 Wind Speed ( Meters Per Second) N N 1.07 0.43 2.78 1.50 1.92 0.28 0.28 1.98 0.28 0.57 8.12 30.13 12.39 1.70 E 2.55 9.35 W 7.69 16.71 15.86 7.93 9.63 S 3 4 5 6 Wind Speed ( Meters Per Second) E 6.80 3.85 1.92 1.71 0.43 1.07 2 Calms excluded. No observations were missing. South Phoenix Winter(Jan, Feb and Dec) Hour 18-23 10.47 1 18.32 South Phoenix Winter(Jan, Feb and Dec) Hour 12-17 14.53 E 7.93 7.37 10.76 S Calms excluded. No observations were missing. 1 2 3 4 5 6 Wind Speed ( Meters Per Second) Calms excluded. No observations were missing. Figure N-5. South Phoenix Wind Rose: Winter, Six-Hour Blocks APPENDIX N - WIND ROSES N-9 South Phoenix Spring((Mar, Apr and May) Hour 00-05 South Phoenix Spring((Mar, Apr and May) Hour 06-11 N N 0.83 1.11 0.28 2.49 1.98 0.83 9.42 2.49 7.48 W E 4.16 10.37 34.81 5.43 6.65 6.37 0.99 12.35 W 12.19 7.20 2.72 4.16 2 3 4 5 2.72 1.48 2.47 6 1 2 3 4 5 South Phoenix Spring((Mar, Apr and May) Hour 18-23 N N 0.42 0.63 0.49 0.42 20.38 46.43 0.00 1.26 0.49 9.11 E W 0.49 30.05 1.72 2.73 3.15 2.10 22.91 11.82 2.94 2.22 7.39 4.93 S 3 4 5 6 Wind Speed ( Meters Per Second) E 2.46 1.68 2.10 2 0.25 3.94 1.26 11.13 1 Calms excluded. Wind flow is FROM the directions shown. No observations were missing. 6 Wind Speed ( Meters Per Second) South Phoenix Spring((Mar, Apr and May) Hour 12-17 3.15 W 1.48 S Calms excluded. Wind flow is FROM the directions shown. No observations were missing. Wind Speed ( Meters Per Second) 0.21 E 9.38 S 1 1.98 8.40 29.09 5.26 1.98 1.48 1.72 S Calms excluded. Wind flow is FROM the directions shown. No observations were missing. 1 2 3 4 5 6 Wind Speed ( Meters Per Second) Calms excluded. Wind flow is FROM the directions shown. No observations were missing. Figure N-6. South Phoenix Wind Rose: Spring in Six-Hour Blocks APPENDIX N - WIND ROSES N-10 South Phoenix Summer (Jun, July and Aug) Hour 00-05 South Phoenix Summer (Jun, July and Aug) Hour 06-11 N N 1.26 0.50 1.00 2.26 0.87 3.52 11.31 4.77 8.54 W E 3.52 10.46 35.95 4.79 5.03 5.78 2.61 12.20 W 8.79 5.53 1.96 1.51 2 3 4 5 3.27 2.18 2.40 Calms excluded. Wind flow is FROM the directions shown. No observations were missing. 6 1 2 3 4 5 South Phoenix Summer (Jun, July and Aug) Hour 18-23 N N 0.19 0.38 3.02 0.64 0.19 46.04 0.42 2.08 1.27 6.57 E W 1.06 28.18 6.36 1.32 1.13 1.89 22.46 8.69 5.47 3.18 8.26 3.39 2.75 S 3 4 5 6 Wind Speed ( Meters Per Second) E 4.45 1.13 1.89 2 0.64 1.70 1.13 8.11 1 Calms excluded. Wind flow is FROM the directions shown. No observations were missing. 6 Wind Speed ( Meters Per Second) South Phoenix Summer (Jun, July and Aug) Hour 12-17 0.75 W 4.79 S Wind Speed ( Meters Per Second) 25.28 E 9.59 S 1 1.31 4.58 29.40 7.29 0.87 2.18 S Calms excluded. Wind flow is FROM the directions shown. No observations were missing. 1 2 3 4 5 6 Wind Speed ( Meters Per Second) Calms excluded. Wind flow is FROM the directions shown. No observations were missing. Figure N-7. South Phoenix Wind Rose: Summer in Six-Hour Blocks APPENDIX N - WIND ROSES N-11 South Phoenix Fall (Sep, Oct and Nov) Hour 00-05 South Phoenix Fall (Sep, Oct and Nov) Hour 06-11 N N 0.28 0.84 0.28 0.28 0.23 1.69 9.55 0.28 36.52 5.90 6.18 3.93 E 1.40 6.05 6.74 W 43.49 4.19 19.38 6.74 3.09 2 3 4 5 4.42 1.63 2.56 6 Calms excluded. No observations were missing. 1 2 3 4 5 6 Calms excluded. No observations were missing. Wind Speed ( Meters Per Second) South Phoenix Fall (Sep, Oct and Nov) Hour 12-17 South Phoenix Fall (Sep, Oct and Nov) Hour 18-23 N N 0.59 0.59 2.38 0.26 1.39 15.25 0.26 1.56 4.95 33.86 W 3.95 S Wind Speed ( Meters Per Second) 1.78 E 17.44 1.40 2.81 S 1 0.93 2.33 2.25 W 0.70 2.56 7.52 0.78 1.82 1.04 E 2.86 11.95 W 12.73 E 7.92 11.88 1.58 9.61 4.16 1.19 2.18 11.69 2.77 5.97 10.39 7.01 7.27 14.81 S 1 2 3 4 5 6 Wind Speed ( Meters Per Second) S Calms excluded. No observations were missing. 1 2 3 4 5 6 Wind Speed ( Meters Per Second) Calms excluded. No observations were missing. Figure N-8. South Phoenix Wind Rose: Fall, Six-Hour Blocks APPENDIX N - WIND ROSES N-12 Durango Complex Winter (Dec, Jan and Feb) Hours 18-23 Durango Complex Winter (Dec, Jan and Feb) Hours 12-17 N N 11.14 W 5.43 4.71 1.86 2.14 3.86 11.73 5.43 20.71 7.43 12.86 E W 5.14 24.28 7.82 5.86 6.14 1.23 0.82 1.03 2.47 2.06 13.17 2.57 2.57 3.57 3.71 4.94 4.32 1.65 2.26 7.61 S 1 2 3 4 5 S 6 Wind Speed ( Meters Per Second) Calms excluded. No observations were missing. 1 2 3 4 5 6 Wind Speed ( Meters Per Second) Durango Complex Winter (Dec, Jan and Feb) Hours 00-05 N N 5.06 9.66 E 3.57 5.04 4.83 5.88 5 6 Wind Speed ( Meters Per Second) 14.89 7.58 W 16.01 14.29 2.25 1.69 3.65 S 4 5.90 5.90 5.04 3 4.78 3.65 17.23 8.61 2 5.34 4.49 7.14 6.51 1 Calms excluded. No observations were missing. Durango complex Winter (Dec, Jan and Feb) Hours 06-11 2.94 1.89 1.68 3.36 2.31 W E 9.46 4.49 E 9.55 4.78 S Calms excluded. No observations were missing. 1 2 3 4 5 6 Wind Speed ( Meters Per Second) Calms excluded. No observations were missing. Figure N-9. Durango Wind Rose: Winter, Six-Hour Blocks APPENDIX N - WIND ROSES N-13 Durango Complex Nov, Oct and Dec South Phoenix Oct, Nov and Dec N N 3.10 1.35 2.28 2.75 0.88 3.74 4.50 W 0.51 1.14 4.80 14.74 16.26 E 6.20 3.22 26.60 8.53 4.49 5.15 2.81 6.06 14.72 W 8.48 10.35 4.86 4.93 5.38 3.22 S 1 2 3 4 5 0.51 1.26 9.71 E 13.77 3.73 S 6 Calms excluded. No observations were missing. Wind Speed ( Meters Per Second) 1 2 3 4 5 6 Wind Speed ( Meters Per Second) Calms excluded. No observations were missing. West 43rd Ave. Oct, Nov and Dec N 2.48 W 1.24 0.83 3.31 11.67 2.38 7.64 17.25 15.08 8.16 E 8.88 5.48 2.69 2.27 3.82 6.82 S 1 2 3 4 5 6 Wind Speed ( Meters Per Second) Calms excluded. No observations were missing. Figure N-10. Comparison of Three Sites: West 43rd Avenue, South Phoenix, and Durango for October through December APPENDIX N - WIND ROSES N-14 APPENDIX O - HOURLY MODEL MEASUREMENT COMPARISON Model performance data presented here are for the high-wind day of April 15, 2002, and the low-wind day of December 16, 2002. All four sites are included. APPENDIX O – MODEL MEASUREMENT COMPARISON O-1 Because the emissions inventory, air quality model, calculated background concentrations, and continuous PM10 measurements by TEOM are all done on an hourly basis, it’s reasonable to discuss model performance on this time scale. In all of the graphs and tables to follow, the “prediction” is the sum of the Industrial Source Complex Model concentration and the background concentration. Most of the graphs show the prediction as “model + background” or “model + B.” An hourly time series is an excellent way to gauge model performance. For each hour of the day along the x-axis, two lines progress through the 24 hours: one for the ‘model + background”, the other for the measurement. Eight such graphs now follow (Figures O-1 – O-8), for the four sites on the high-wind and low-wind days. Figure O-1. Salt River PM10 -- Model + Background vs. Measured (TEOM) -- High Wind Day of April 15, 2002 at South Phoenix 1000 PM10 (ug/m3) 800 Model + B TEOM 600 400 200 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour APPENDIX O – MODEL MEASUREMENT COMPARISON O-2 Figure O-2. Salt River PM10 -- Model + Background vs. Measured (TEOM) -High Wind Day of April 15, 2002 at West 43rd Avenue 1000 PM10 (ug/m3) 800 Model + B TEOM 600 400 200 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour Figure O-3. Salt River PM10 -- Model + Background vs. Measured (TEOM) -High Wind Day of April 15, 2002 at the Salt River Site 1000 900 800 PM10 (ug/m3) 700 600 Model + B TEOM 500 400 300 200 100 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour APPENDIX O – MODEL MEASUREMENT COMPARISON O-3 Figure O-4. Salt River PM10 -- Model + Background vs. Measured (TEOM) -High Wind Day of April 15, 2002 at Durango 1000 PM10 (ug/m3) 800 Model + B TEOM 600 400 200 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour Figure O-5. Salt River PM10 -- Model + Background vs. Measured (TEOM) -Low Wind Day of December 16, 2002 at South Phoenix 350 PM10 (TEOM) ug/m3 300 250 200 Model + B TEOM 150 100 50 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour APPENDIX O – MODEL MEASUREMENT COMPARISON O-4 Figure O-6. Salt River PM10 -- Model + Background vs. Measured (TEOM) -Low Wind Day of December 16, 2002 at West 43rd Avenue 450 400 PM10 (TEOM) ug/m3 350 300 250 Model + B TEOM 200 150 100 50 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour Figure O-7. Salt River PM10 -- Model + Background vs. Measured (TEOM) -Low Wind Day of December 16, 2002 at the Salt River Site 350 PM10 (TEOM) ug/m3 300 250 200 Model + B TEOM 150 100 50 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour APPENDIX O – MODEL MEASUREMENT COMPARISON O-5 Figure O-8. Salt River PM10 -- Model + Background vs. Measured (TEOM) -Low Wind Day of December 16, 2002 at Durango 350 PM10 (TEOM) ug/m3 300 250 200 Model + B TEOM 150 100 50 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour Model performance on April 15, 2002, must be viewed in the context of the high winds that occurred in hours 14 – 17. For these four afternoon hours, the average wind speed exceeded 15 miles per hour, the threshold for dust resuspension. In constructing the emissions inventory, only these hours had windblown dust emissions. Although the measurements reflect the dust storm, there are the usual ambiguities. For example, all four sites show an extremely elevated measured peak at hour 14 or 15: 480, 567, 860, and 887 µg/m3. But the peak does not last the entire four hours, as one might think it should. Furthermore, two of the sites, West 43rd Avenue and the Salt River site, have sharp peaks at hour 21 (465 and 800 µg/m3, respectively). The model, consisting of the Industrial Source Complex prediction added to the background concentration, did rather well on this day, simulating most of the peaks at most of the sites. The model failed to reproduce the hour 7-8 peak at the three sites where it occurred, predicted an hour 21 peak at two sites that lacked one, and over predicted the hour 14-15 wind gust peak at two sites. At West 43rd Avenue and Durango, however, the simulation of this afternoon high-wind peak was nearly perfect. What’s puzzling is that the shape of the model-predicted peak mimicked the measured peak, instead of being flat for four hours as the equal doses of windblown emissions would suggest. In contrast to its performance on a gusty April day, the model had trouble getting the shape, the duration, the timing, and the magnitude of the measured variations right on a stagnant December day. Measurements on December 16, APPENDIX O – MODEL MEASUREMENT COMPARISON O-6 2002, are dominated by a sharp, high morning peak and a lower, late evening plateau, separated by low, constant values in the afternoon. Magnitudes of the morning peaks varied from 194 to 258 µg/m3, while the evening plateaus ranged from 168 to 231 µg/m3. In the model simulations, false peaks and valleys appear throughout the time series. The model failed dismally in simulating the morning peaks, under predicting them at each site. For this low-wind day, the model didn’t work well. The next two figures present these data in a different fashion. Here, all sites are combined for each of the two days, with the model + background plotted against the measurement in traditional x-y scatter graphs. Figure O-9. Model + Background vs. Measured (TEOM): High Wind Day of April 15, 2002: Four Sites, Hourly 400 Model + Background (ug/m3) 350 300 250 (M + B) = 0.99*TEOM + 9.43, r2 = 0.58 200 150 100 50 0 0 50 100 150 200 250 300 350 400 Measured (TEOM, ug/m3) APPENDIX O – MODEL MEASUREMENT COMPARISON O-7 Figure O-10. Salt River PM10 -- Model + Background vs. Measured (TEOM) -Four Sites, December 16, 2002 400 Model + Background (ug/m3) 350 300 250 200 150 (M + B) = 0.17*TEOM + 93.79, r2 = 0.03 100 50 0 0 50 100 150 200 250 300 350 400 Measured (TEOM) ug/m3 In these two figures, each point represents a paired model prediction (model + background) and measurement, averaged for one hour. The scatter of the points, diverging in many cases far from the 1:1 line, indicates that the model is not simulating the measurements accurately, especially for the December 16 case. Another way to present these data is to plot the measurements from their highest to lowest value as a single line, and to plot the paired model prediction as a separate line. The index number of the x-axis is the rank of the hourly TEOM measurement: number 1 is the highest; number 91 (or 94) is the lowest. These two figures are given below. APPENDIX O – MODEL MEASUREMENT COMPARISON O-8 Figure O-11. Salt River PM10 -- Model + Background vs. Measured (TEOM) -Four Sites, High Wind, April 15, 2002, Ranked by TEOM Reading 1200 PM10 (ug/m3) 1000 800 Model + B TEOM 600 400 200 0 1 6 11 16 21 26 31 36 41 46 51 56 61 66 71 76 81 86 91 96 index APPENDIX O – MODEL MEASUREMENT COMPARISON O-9 Figure O-12. Salt River PM10 -- Model + Background vs. Measured (TEOM) -Four Sites, Low Wind, December 16, 2002, Ranked by TEOM Reading 450 400 PM10 (ug/m3) 350 300 250 Model + B TEOM 200 150 100 50 0 1 6 11 16 21 26 31 36 41 46 51 56 61 66 71 76 81 86 91 index These two figures suggest that on April 15, the model is faithfully reproducing the lower range of measured concentrations, but that from the mid-range to the highest concentrations, the model is diverging widely for most of the predictions. On December 16 the model is under predicting all but one of the highest 18 observations. As the concentrations decrease to their lowest value, the model under and over predicts equally until about the 65th value, after which a decided over prediction sets in. Since the model appears to be more reliable under high-wind conditions than low wind, it’s instructive to segregate the hours into high and low wind categories. Even though that leaves only 16 high-wind hours, the two figures below present the data with this division. APPENDIX O – MODEL MEASUREMENT COMPARISON O-10 Figure O-13. Salt River PM10 -- Model + Background vs. Measured (TEOM) -Four High-Wind Hours of April 15, 2002, All Sites Model + Background PM10 (ug/m3) 1200 1000 800 600 400 200 0 0 200 400 600 800 1000 1200 Measured PM10 (TEOM) ug/m3 APPENDIX O – MODEL MEASUREMENT COMPARISON O-11 Figure O-14. Salt River PM10 – Model + Background vs. Measured (TEOM) – All Low-Wind Hours, All Sites, April 15 and December 16, 2002 Model + Background PM10 (ug/m3) 600 500 400 300 200 100 0 0 100 200 300 400 500 600 Measured PM10 (TEOM) ug/m3 The high-wind concentrations are consistently over predicted, while the low-wind predictions show the wide scatter seen on many of the earlier figures. Table O-1 presents regression statistics for the various graphs. In all of these statistics, the model + background is being regressed against the measurement. Recall that an intercept near zero, a slope near 1.0, and a regression coefficient squared close to 1.0 mean that there’s a strong correlation with similar overall distributions. APPENDIX O – MODEL MEASUREMENT COMPARISON O-12 TABLE O-1 Regression Statistics Figure Description N R2 Slope Intercept South Phoenix, April 15 24 0.81 1.87 -31.46 Durango, April 15 24 0.66 0.83 24.57 Salt River, April 15 24 0.44 1.19 -21.31 rd West 43 Avenue, April 15 24 0.79 0.95 -44.05 All sites, April 15 96 0.58 0.99 9.43 South Phoenix, December 16 23 0.04 0.27 88.47 Durango, December 16 23 0.01 0.11 103.08 Salt River, December 16 23 0.00 -0.02 124.26 West 43rd Avenue, December 16 23 0.21 0.41 32.59 All sites, December 16 92 0.03 0.17 93.79 All sites, low wind hours, both days 171 0.27 0.49 45.50 All sites, high wind hours, April 15 16 0.33 0.54 397.13 As the graphs have already indicated, for only three individual cases does the model display much predictive ability: South Phoenix, Durango, and West 43rd Avenue for April 15, 2002. The intercepts for these three cases are actually close to zero, since the scale on the y-axis is 1000 µg/m3. In addition, for Durango and West 43rd Avenue, the slopes are close to 1.0. All sites on April 15, with its regression coefficient of 0.58, slope of 0.99, and low intercept might also be put into the acceptable category of model performance. To understand exactly why a modeling system doesn’t predict any better than this is difficult. This system consists of three parts: an emissions inventory, an air quality model that uses the emissions and measured meteorological variables, and a set of calculated background concentrations. Uncertainties are present in all three components. This discussion cannot cover all three in great detail, but will present some possibilities. Emissions need to be considered separately for low and high wind hours. For low wind hours, the dominant sources of PM10 in the Salt River Area are roads and trackout (70%), construction (14%), and industrial sources (12%). Construction and industrial sources are easy to place accurately in the modeling domain, but are almost impossible to specify the right day and hour. Emission estimates are based on annual or monthly activity levels. On a specific day it is unknown how much activity is taking place at construction or industrial sites. So one quarter of the emissions (26%) has an unknown time element. Roads and trackout have the advantage of excellent temporal accuracy, thanks to traffic counts and generally repeatable traffic patterns. But since roadway PM10 emissions are dominated by reentrained dust, and since its driving variable of silt loading is not measured frequently (five measurements during the 2002 study), APPENDIX O – MODEL MEASUREMENT COMPARISON O-13 large uncertainties crop in. Trackout is even more uncertain, as accurate measurements of its length, silt loading, and location are generally not available. Emissions on high-wind days, completely dominated by the high-wind hours, depend on getting the land surfaces right: that is, in the right place and categorized into an accurate depiction of soil surfaces of different erodible potential. This part of the inventory is generally done quite well; although, as the post-February 2004 reexamination of alluvial soils demonstrated, there’s always room for improvement. The tricky part in estimating windblown emissions comes from finding the right emission factor, that itself is coupled to the right threshold wind speed to resuspend dust. In this arena, the empirical data are sparse (there are some) and the variation of land surface within a category is substantial. The net result is an estimate with a high degree of uncertainty. The air quality model (Industrial Source Complex) has been tested many times in its 30 years of use with voluminous field measurements. The problem with these tests is that this field work concentrated on tall stack emissions of mostly gaseous pollutants. In the Salt River Area virtually all the emissions are surface emissions of the fugitive particulate type, whose mass is two thirds in the coarse particle size (2.5 to 10 microns). The model was used nearly exclusively in the “area” sense. This means that all emissions except for registered stacks and the 36 largest industrial process areas were homogenously distributed throughout each modeling grid (400x400 meters). This model’s performance under these conditions has really gone unchecked, except for studies such as this one. Another aspect of unknown model performance concerns high-wind emissions of mostly coarse particles. Although equipped with a deposition algorithm, this was not used because it has been shown to make little difference, increases the computational time by a factor of ten, and has never received EPA sanction. The over prediction of the high-wind concentrations, as shown in Figure O-13 , could very well be due to the model’s treatment of these mostly coarse particles as a gas. The last part of the system is background. On average the background concentrations are about four times the ISC model predictions. The model is contributing only 20% of the total prediction. This varies by hour and site, of course, but, on average, 20% is model and 80% is background. This suggests that given the degree of under and over predictions, the background uncertainty is going to swamp the model’s. As described in the TSD, the background values are based on two sets of paired measurements: TEOM PM10 at West 43rd Ave and at a site two miles west of the western boundary; and, separately, in different months, at West 43rd and at a site one mile east of the eastern boundary of the modeling domain. Relationships were calculated between the east and west boundary sites and West 43rd Avenue. Done on an hourly basis, those hours when the wind was blowing out of the Salt River Study Area towards the boundary monitors were discarded. Since the wind comes from all directions, South and North boundary concentrations had to be estimated and expressed as a fraction of the east and west values. This was done, based on TEOM data for APPENDIX O – MODEL MEASUREMENT COMPARISON O-14 Supersite and Durango for the North boundary, and on emission inventory considerations for the South boundary. Finally, for each hour of each design day a background concentration based primarily on the hourly TEOM concentration at West 43rd Avenue was calculated. With this concentration as an anchor, a north, south, east, or west boundary fraction consistent with the wind direction was applied. For example a northwest wind was given both a north and west boundary value. Averaging these provided the “background” concentration. This calculated value was applied uniformly throughout the modeling domain. An example is given in Table O-2. Hour 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00 TABLE O-2 Background Concentrations for April 15, 2002 Wind Boundary Direction Concentrations PM10WF Degrees Dir NB EB WB SB 41.5 295 NW 18.0 41.8 33.2 298 NW 14.5 32.8 40.5 283 W 30.1 62.0 20 N 25.1 43.7 36 NE 14.5 40.1 58.7 15 N 14.6 109.4 148 SE 45.7 3.1 280.1 178 S 9.4 276.7 230 SW 109.9 12.5 185.1 139 SE 104.0 8.8 86.1 179 S 5.0 407.0 207 SW 328.3 21.9 110.8 228 SW 97.6 8.7 113.3 250 W 102.4 490.0 258 W 590.1 884.9 254 W 864.0 416.5 250 W 392.3 220.1 255 W 226.0 400.2 249 W 346.6 236.6 258 W 127.1 195.5 265 W 129.7 799.7 261 W 523.3 234.8 224 SW 191.3 14.4 100.0 238 SW 133.3 5.6 Avg 29.9 23.6 30.1 25.1 27.3 14.6 24.4 9.4 61.2 56.4 5.0 175.1 53.2 102.4 590.1 864.0 392.3 226.0 346.6 127.1 129.7 523.3 102.9 69.5 What’s important to note here is that each direction boundary concentration, NB, EB, WB, and SB, is the result of applying a direction-specific fraction to the measured PM10 concentration on the far left. Each hour has its own set of boundary concentration fractions. APPENDIX O – MODEL MEASUREMENT COMPARISON O-15 Although this method would appear empirically sound, with ample measurements to form the basis of the hour-and-direction specific fractions, something isn’t working right. Implicit in this method is the assumption that the monitored concentrations at West 43rd Avenue are generally representative of the entire domain, or, at least those portions of the domain with the other three monitors. The other built-in assumption is that the PM10 concentrations monitored at the east and west boundary sites were representative of the PM10 concentrations prevailing in these areas outside the modeling domain. Neither site had evidence of strong localized PM10 emissions. Nonetheless, this method could be improved upon, most likely by using wind direction averages of five or 15 minutes, instead of hourly, and by using the boundary layer winds as measured by Sodar. As a final aspect of model performance, it’s worth taking a look at how the ISC model did in tracking the temporal variation of the measured concentrations at the four monitors. This last series of graphs, three for each day, consists of the ISC-predicted concentrations at each site, of the same concentrations with the background added, and of the model predictions and measurements averaged for the four sites along with the background. APPENDIX O – MODEL MEASUREMENT COMPARISON O-16 Figure O-15. Salt River PM10 – ISC Model-Predicted Concentrations (No Background) – April 15, 2002 300 PM10 (ug/m3) 250 200 S. Phoenix Durango Salt R. West 43rd 150 100 50 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour Recall that the high-wind hours are 14 – 17. The shape of the four peaks is nearly identical, but why South Phoenix should be so much higher than the other three is an open question. Note that the model has failed to find a morning peak at West 43rd Avenue. APPENDIX O – MODEL MEASUREMENT COMPARISON O-17 Figure O-16. Salt River PM10 – ISC Model Predictions and Background for April 15, 2002 500 450 400 PM10 (ug/m3) 350 S. Phoenix Durango Salt R. West 43rd background 300 250 200 150 100 50 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour Figure O-17. Salt River PM10 -- ISC Model Predicted Average, Measured Average, and Background -- April 15, 2002 800 700 PM10 (ug/m3) 600 500 background TEOM average Model average 400 300 200 100 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour APPENDIX O – MODEL MEASUREMENT COMPARISON O-18 In Figure O-17 the background value at hour 15 is 864 µg/m3, with the scale lowered to improve the clarity of the modeling results. What the background trace shows is a pattern coincident with the modeling prediction for the high wind hours, but which is radically different for many of the low wind hours. In Figure O-17 the background trace mirrors the four-site TEOM average quite well, as it ought to, since it’s based on the West 43rd Avenue measurements. At this scale the average modeling concentrations are at or near zero for all but the four highwind hours. In the next three figures, similar concentrations are shown for December 16, 2002. Unlike April 15, these figures show considerable unexplained patterns. First shown are the ISC model predictions (Figure O-18). Figure O-18. Salt River PM10 -- ISC Model-Predicted Concentrations (No Background) December 16, 2002 120 PM10 (ug/m3) 100 80 S.Phoenix West 43rd Durango Salt R. 60 40 20 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour Predictions at the four sites coincide for most low and most peaking hours, the exceptions being Salt River at hours 4 and 8, and Durango at hour 11. The coincidence of the four peaks at hour 17 is remarkable. APPENDIX O – MODEL MEASUREMENT COMPARISON O-19 Adding the background line to the graph (Figure O-19) demonstrates that the background concentrations do not vary in sync with the modeled concentrations (and, for the most part, they shouldn’t). Figure O-19. Salt River PM10 -- ISC Model Predictions and Background -December 16, 2002 300 PM10 (ug/m3) 250 200 S.Phoenix West 43rd Durango Salt R. BACK 150 100 50 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour In the last figure the model predictions and measurements are averaged for the four sites, with the background included. APPENDIX O – MODEL MEASUREMENT COMPARISON O-20 Figure O-20. Salt River PM10 -- ISC Model Predicted Average of Four Sites, Measured Average, and Background – December 16, 2002 300 PM10 (ug/m3) 250 200 Background Model Average TEOM Average 150 100 50 22 20 18 16 14 12 10 8 6 4 2 0 0 Hour This figure shows that the model is mostly unresponsive to the emissions, except for hour 17. The shape of its trace bears no resemblance to the measurement line. The zigzag presence of the background is inconsistent with the more gradual changes expected in this kind of regional concentration. All in all, this graph points out weaknesses in both the modeling and the background calculations. APPENDIX O – MODEL MEASUREMENT COMPARISON O-21 APPENDIX P – MAPPING WEIGHTED TRACKOUT EMISSIONS INTO PREDICTED CONCENTRATIONS Appendix K explained how the six categories of trackout emissions were weighted to account for their relative length and severity. In the Industrial Source Complex modeling, however, time constraints made it impossible to rebuild the trackout inventories and to perform the modeling again. Instead, the base-case, unweighted trackout emissions were used to produce predicted trackout concentrations. These concentrations were in turn modified to reflect the weighting results of Appendix K. How this was done is the subject of this appendix. First, the final table from Appendix K is presented below, which shows the relative weightings of the six trackout categories. TABLE P-1 Trackout from Six Source Categories Weighted by Length and Severity Relative Emission Category Rate Industrial 1.00 Construction 0.66 Agricultural 0.36 Unpaved shoulders 0.14 Commercial 0.12 Private 0.09 Appendix P – Mapping Weighted Trackout Emissions Into Predicted Concentrations P-1 Second, the predicted concentrations from ISC for the various trackout categories for the eight exceedances are taken from the model (Table P-2). These predictions are TABLE P-2 Industrial Source Complex Predicted Concentrations of PM10 from Six Types of Trackout for the Eight Exceedances in 2002 in the Salt River Study Area (µg/m3) 8-Jan 15-Apr 26-Apr 16-Dec SALT RIVER DURANGO SALT RIVER WEST 43 DURANGO SALT RIVER WEST 43rd WEST 43rd Agricultural 0.130 0.372 0.104 0.014 0.217 0.077 0.012 0.086 Construction 0.061 0.176 0.046 0.029 0.187 0.104 0.017 0.113 Industrial 0.831 0.238 0.192 0.280 0.229 0.263 0.218 1.401 Private 0.002 0.000 0.000 0.000 0.001 0.002 0.000 0.001 Commercial 0.067 0.131 0.035 0.052 0.168 0.122 0.021 0.262 Unpaved 0.303 0.334 0.127 0.106 0.376 0.228 0.148 0.533 Total 1.394 1.251 0.504 0.480 1.178 0.796 0.417 2.396 Third, these concentrations are multiplied by the weighting factors, given in Table P-1 and shown below as the first numeric row in Table P-3. TABLE P-3 Industrial Source Complex Predicted Concentrations of PM10 from Six Types of Trackout for the Eight Exceedances in 2002 in the Salt River Study Area – Weighted by Length and Severity (µg/m3) Weighting Factor/Site 8-Jan SALT RIVER DURANGO 15-Apr SALT RIVER WEST 43rd DURANGO 26-Apr SALT RIVER WEST 43rd 16-Dec WEST 43rd Agricultural 0.36 0.047 0.134 0.037 0.005 0.078 0.028 0.004 0.031 Construction 0.66 0.040 0.116 0.030 0.019 0.123 0.069 0.011 0.074 Industrial 1.00 0.831 0.238 0.192 0.280 0.229 0.263 0.218 1.401 Private 0.09 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Commercial 0.12 0.008 0.016 0.004 0.006 0.020 0.015 0.003 0.031 Unpaved 0.14 0.042 0.047 0.018 0.015 0.053 0.032 0.021 0.075 These weighted and unweighted concentrations are portrayed in the subsequent figures. Appendix P – Mapping Weighted Trackout Emissions Into Predicted Concentrations P-2 Total 0.968 0.551 0.281 0.325 0.504 0.406 0.257 1.613 Unpaved 22% Commercial 5% Private 0% Agricultural 9% Construction 4% Industrial 60% Figure P-1. Unweighted Relative Trackout Contributions to PM10 at the Salt River Site on January 8, 2002 Unpaved 22% Commercial 11% Private 0% Agricultural 4% Construction 5% Industrial 58% Figure P-2. Weighted Relative Trackout Contributions to PM10 at the Salt River Site on January 8, 2002 Appendix P – Mapping Weighted Trackout Emissions Into Predicted Concentrations P-3 Private 0% Unpaved 4% Agricultural 2% Commercial 2% Construction 5% Industrial 87% Figure P-3. Unweighted Relative Trackout Contributions to PM10 at West 43rd Avenue on December 16, 2002 Unpaved 4% Commercial 2% Private 0% Agricultural 2% Construction 5% Industrial 87% Figure P-4. Weighted Relative Trackout Contributions to PM10 at West 43rd Avenue on December 16, 2002 Appendix P – Mapping Weighted Trackout Emissions Into Predicted Concentrations P-4 Agricultural 17% Unpaved 29% Construction 12% Commercial 11% Industrial 31% Private 0% Figure P-5. Unweighted Relative Trackout Contributions to PM10 for Six High-Wind Exceedances Commercial 3% Private 0% Unpaved 7% Agricultural 11% Construction 14% Industrial 65% Figure P-6. Weighted Relative Trackout Contributions to PM10 for Six HighWind Exceedances Appendix P – Mapping Weighted Trackout Emissions Into Predicted Concentrations P-5 In interpreting these figures, the concept of an emission contribution to a predicted concentration must be kept in mind. The prediction is for one of four monitoring sites and depends on both the wind direction and the location of the trackout emissions with respect to both the wind and the monitoring site. The three pairs of pie charts have the unweighted contributions as the top figure and the weighted contributions below. The first pair, for the low-wind day of January 8, 2002, at the Salt River site (exceedance of 174 µg/m3), shows that the largest change is for unpaved shoulder emissions. This contribution is reduced to 4% from 22%, a five-fold decrease. Industrial shows a marked increase from 60% to 86%. A second low-wind exceedance, that of West 43rd Avenue on December 16, 2002 (exceedance of 181 µg/m3), is shown in Figures P-3 and P-4. The changes at this site from the weighted trackout emissions are nearly identical to those of the Salt River site in January. Trackout emissions and virtually all other “process”, as opposed to wind blown emissions, don’t make a large impact on high-wind days. It’s instructive to see whether the weighting produces compositional changes in the category contributions that are comparable to the low-wind days. The set of unweighted and weighted trackout emission contributions, as shown in Figures P-5 and P-6, reveals that the changes are just as pronounced: industrial trackout doubles and unpaved shoulders go down by a factor of four. Note that these last two figures, as opposed to the first four, are an average of three monitoring sites for the two high-wind April 2002 exceedance days. In summary, trackout emissions went through a developmental process in this State Implementation Plan. The first results did not even have trackout as a source category. The second results treated trackout rather simplistically. The third results assigned better locations and source category types (six in all) to trackout. Finally, the weighting method of Appendix K and its application to predicted concentrations of trackout, explained in this Appendix P, bring an added infusion of rigor into a difficult and important emissions problem. Appendix P – Mapping Weighted Trackout Emissions Into Predicted Concentrations P-6 APPENDIX Q - PROJECTED CONSTRUCTION ACTIVITY The following is a summary of how ADEQ projected construction activity in the Salt River PM10 Study Area for the Year 2006. If construction activity were to increase significantly between 2002 and 2006, then the 2006 emission figures for construction activity, windblown construction, and construction trackout should be increased accordingly. To answer this question, land under construction in the Salt River PM10 Study Area has been determined for years 2001, 2002, and 2003 by reviewing quarterly and annual aerial photograph books of the Phoenix metropolitan area focusing on the Salt River PM10 Study Area. These photographs have, among other land uses, active and planned construction. ADEQ determined the total number of active construction acres in the first quarter of 2001, 2002, and 2003 and projected a trend (Figure Q-1). Figure Q-1. Salt River PM10 Study Area Construction Acreage 10000 9000 8000 7000 Acres 6000 From Maps Extrapolated 5000 4000 3000 2000 1000 0 2001 2002 2003 2004 2005 2006 Year Examination of Figure Q-1 would suggest a drastic increase in construction in the four year period. However, the actual change in construction activity from 2002 to 2006 for the Salt River PM10 Study Area is quite different. The reason for this difference has to do with what kinds of land are going into construction and what their extent is. Almost all the construction in the Salt River PM10 Study Area has and will take place on retired agricultural land. Given the conversion rates of miscellaneous disturbed areas (13.6% in the four years) and vacant lots (39.6% in the four years), and given their respective 2002 acreages, only 15% of new construction in 2002 – 2006 could take place on these lands. The other 85% will occur on agricultural land. As there is only a finite amount of agricultural land in the Salt River PM10 Study Area, and as the four-year retirement rate is 80%, the actual change in land being affected by construction activity is more accurately shown in Figure Q-2. Appendix Q – Projected Construction Activity Q-1 Figure Q-2. Salt River Area Construction by Land Type 3,000 2,500 acres 2,000 on ag land on vac lot on misc dist total 1,500 1,000 500 2002 2003 2004 2005 2006 Examination of Figure Q-2 shows that conversion of vacant lots and miscellaneous disturbed areas contributes a small, but constant amount, to construction acreage. In contrast, the construction on agricultural land increases in the first year and decreases thereafter. This decrease comes about from the dwindling supply of agricultural land available in the Salt River PM10 Study Area as shown in Figure Q-3. Appendix Q – Projected Construction Activity Q-2 Figure Q-3. Available Agricultural Land in the Salt River Study Area and Construction Acreage 9,000 8,000 7,000 acres 6,000 5,000 avail ag construction 4,000 3,000 2,000 1,000 2000 2001 2002 2003 2004 2005 2006 Figure Q-3 shows that the conversion of agricultural land into commercial and residential uses by construction activity is limited by the land that’s available in the Salt River PM10 Study Area. The construction line in Figure Q-3 rides slightly above the available agricultural land line because of the 15% contribution to construction from vacant lots and miscellaneous disturbed areas. However, the exponential increase in construction activity between 2002 and 2006 inferred from Figure Q-1 cannot happen because there’s not that much land available to build on in the Salt River PM10 Study Area. Thus, instead of a projected increase in construction activity in this four-year period, there is a sizeable decrease -- from about 1,550 acres in 2002 to 850 acres in 2006, a net decrease of 45%. This decrease means that 2006 construction emissions stated in ADEQ’s “Revised PM10 State Implementation Plan for the Salt River Area, Technical Support Document, July 2004”, have been over estimated, not under estimated, as has been suggested. Appendix Q – Projected Construction Activity Q-3 APPENDIX R - VACANT LOT SURVEY Percentage of Vacant Lots Converted to Residential and Commercial Use A summary of the survey that ADEQ conducted to determine the percentage of vacant lots that had been converted to residential and commercial use for the time period between July 2003 and May 2004 in the Salt River PM10 Study Area appears below. ADEQ staff used two sets of identifiers, dust potential and size, to classify the vacant lots found during the field study. These are listed in Table R-1 and Table R-2. TABLE R-1 Dust Potential 1 = low dust potential 2 = low to medium dust potential 3 = medium dust potential 4 = medium to high dust potential 5 = high dust potential 6 = extreme dust potential TABLE R-2 Size of Vacant Lot (Grid Cell = 400 x 400 m2) 1 = less than 1/8 grid cell size 2 = 1/8 to 1/4 grid cell size 3 = 1/4 to 1/2 grid cell size 4 = occupies more than 1/2 of grid cell Table R-3 lists the dust potential, size, and comments for the 171 vacant lots that were surveyed in the ADEQ’s field study in 2004. Appendix R – Vacant Lot Survey R-1 TABLE R-3 Vacant Lot Field Survey Grid Cell ID # Dust Potential Rating Size Rating Comments 1 2 3 4 5 6 7 8 8 3 2 2 4 2 2 4 3 3 1 1 1 1 1 1 2 1 1 9 9 9 10 11 11 11 12 12 13 14 15 15 16 16 16 16 17 17 18 19 20 21 21 22 22 23 23 24 24 24 24 25 25 26 4 4 4 4 4 4 4 2 3 4 2 2 1 1 3 2 2 1 1 1 2 2 2 1 2 2 1 3 2 3 3 3 2 2 2 4 4 2 3 2 4 1 6 2 3 3 3 4 4 4 4 5 5 5 4 2 2 2 1 1 1 1 1 1 1 1 4 4 3 palm trees, gravel, weeds, glass/trash. sandy, grainy gravel, weeds, tires, car seat, trash dirt, weeds, trash, vehicle tracks half of 2 front lots paved, back lot dirt, weeds dirt, weeds, glass, trash dirt, weeds, glass dirt, weeds, some trash/glass " dirt mound across lot from E-W. some weeds & trash. New buildings on N-W corner & S-W corner. N-W corner is being constructed. " " sandy, grainy, some weeds. sand, weeds. " " West side of 43rd Avenue is under construction. East side of 43'rd Avenue has truck parking and trackout. Covered pretty well with weeds & gravel. ag field in back, industrial. all dirt, very little gravel, & weeds. Industrial area. " industrial area. Dirt & gravel lots mostly fenced. industrial area. Dirt & gravel lots mostly fenced. industrial area. Dirt & gravel lots mostly fenced. industrial area. Dirt & gravel lots mostly fenced. industrial area. Dirt and weeds " industrial area. Dirt and weeds industrial area. construction on SE portion industrial area. Dirt & dried weeds. industrial area. dried weeds. " walled area mostly gravel, fenced area covered with weeds. " area covered with weeds & rock. " " " adjacent to and/or part of Rio Salado project. " fenced field area under construction. Soil wet at time of visit. Appendix R – Vacant Lot Survey R-2 TABLE R-3 Vacant Lot Field Survey Grid Cell ID # 27 27 28 29 30 31 31 31 32 33 33 34 34 35 35 36 36 37 37 38 39 39 40 41 41 42 43 44 45 45 46 47 48 49 50 51 51 52 53 54 55 55 56 57 58 59 Dust Potential Rating 3 3 3 1 2 1 1 1 2 3 3 6 6 3 3 2 2 1 3 3 1 1 5 2 3 3 3 5 3 1 3 3 3 2 3 4 Size Rating Comments 1 1 1 1 1 3 1 1 1 1 1 2 1 3 3 1 1 1 1 2 1 1 2 1 3 1 1 1 1 1 2 1 3 4 1 1 1 1 1 1 1 1 1 2 2 2 field has been scraped. " weeds & rocks access difficult horse run area. Soil powder like. " new home construction new home construction in progress. new home construction. " fence removed. Weeds. Along canal. along canal field weeds field weeds north of CIGNA Health Clinic Commercial construction: Family Dollar Store both sides of canal east side of lot has newly constructed storage rental units. weeds, rocks, dirt. new home construction. open lot south part now bus station. North part still dirt lot. No fence, tire tracks, no weed cover " some weeds, wind break wind break, weeds some grass some tire tracks (few). Some fence. 3 separate lots(1 large, 2 small) some berm (big lot) & curbing (middle lot) new home construction. Appendix R – Vacant Lot Survey R-3 TABLE R-3 Vacant Lot Field Survey Grid Cell ID # 60 61 62 62 63 63 64 65 66 67 68 68 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 91 92 93 93 Dust Potential Rating 3 5 2 2 1 1 1 3 3 3 1 2 2 3 3 3 1 1 1 3 3 4 3 4 2 6 3 3 1 3 4 2 1 1 Size Rating 3 2 4 3 2 1 4 2 1 1 2 3 4 1 4 2 1 4 4 4 4 2 2 1 1 1 1 1 1 2 2 2 1 1 2 1 1 1 2 1 Comments tire tracks, some grass. part berm and part fence. Horse property. construction in progress on most of lot. New houses (?) " west end has commercial bldg. now. Some berm, some grass & weeds. under construction (row houses or multi family units?) berm (partial) fence & sign NT (misc. disturbed) " " radio tower area, grass berm not complete fence grass and a few trees fence poles (no fence) plenty of tire tracks. home construction on part. grass/veg. construction (retention basin?) much grass much grass some grass, tire tracks, parking, some gravel for parking. some gravel, tire tracks, some grass. clear lot some gravel/stone and dead grass on lot. dirt crusted, some grass, some tire tracks. semi truck trailers parked on lot. Saw truck-trailer combination drive across this lot causing much dust. parking lot with some gravel and oil coating along RR tracks. Some weeds & grass. No (?) vehicle access. weeds/grass cover some dead grass/weeds dirt piles, some dead grass/weeds. large warehouse type bldg. here now. dead grass & weeds. lots of weeds. " truck-trailer parking on south part of lot. Some dead grass, weeds, berm north part of lot. storage of large dumpsters and vehicle parking on south and east part of lot " 94 3 2 95 4 1 95 4 2 95 4 1 95 4 1 96 4 1 pipeline construction lot now. Appendix R – Vacant Lot Survey R-4 TABLE R-3 Vacant Lot Field Survey Grid Cell ID # 97 98 98 99 99 100 101 101 101 101 102 102 103 104 104 105 105 106 107 107 108 109 110 110 111 112 113 114 114 115 116 117 118 119 120 Dust Potential Rating 3 2 2 3 3 4 4 4 4 4 2 1 1 3 3 3 3 1 5 5 1 1 1 1 3 3 3 3 3 3 1 3 3 1 Size Rating Comments 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 some pipeline storage now dead grass & weeds. " some dead grass/weeds walled in industrial storage area. dirt road across, some dead grass & weeds. utility easement utility easement weeds & rocks new home construction fence poles but no fencing west side of lot has new Family Dollar Store middle of lot has one new home Total number of vacant lots in survey = 171 Total Number of Vacant Lots Converted 14 Total Number of Vacant Lots 171 Fraction Of Vacant Lots Converted 0.08187 0.09825 0.39298 In ten months: July 2003 to May 2004 Annual conversion rate Four year (2002 to 2006) conversion rate Appendix R – Vacant Lot Survey R-5 Number of Vacant Lots & Misc. Disturbed Areas Less Than 1/10 Acre ADEQ staff also did an analysis of the number of vacant lots and miscellaneous disturbed areas that were less than 1/10 of an acre in the Salt River PM10 Study Area. Following is a description of the analysis and results. 1. Obtain the original land use classification files that were developed using GIS digitizing of satellite images (IKONOS, March 2002) of the data from field surveys of the Salt River PM10 Study Area. 2. Import the data files from GIS analysis into an Excel spreadsheet. 3. Sort the land use files into two land use categories: a. Miscellaneous Disturbed (Category 540) b. Vacant Lots (Category 550) 4. Total the number and surface area of miscellaneous disturbed areas and vacant lots that are less than 1/10 acre. Table R-4 summarizes the results of the analysis and shows that the extent of miscellaneous disturbed areas and vacant lots less than 1/10 acre is minimal in the Salt River PM10 Study Area. Table R-4 Number of Vacant Lots and Misc. Disturbed Areas Less Than 1/10 Acre Land Use Total Total Total Total Surface Area Percent Less than Type Number Surface Number of Areas Less than 1/10 Acre Area Less than 1/10 Acre (Acres) 1/10 Acre (Acres) Misc. Disturbed Vacant Lots 220 1,627 13 0.7 0.04% 902 1,303 74 3.7 0.29% Appendix R – Vacant Lot Survey R-6 APPENDIX S - INDUSTRIAL AREA EMISSIONS Industrial area PM10 emissions in the Salt River PM10 Study Area are important, especially their reductions from 2002 to 2006 which, among several other source categories, are necessary to demonstrate attainment. Given this importance, this appendix provides justification for the use of the 2002 emissions for the 2006 base case. It also presents further rationale for the reductions and an analysis of the sensitivity of the predicted concentrations to three levels of 2002 emissions. I. Rationale for the 2006 Base Case Emissions Being Equal to the 2002 Emissions Throughput and emission statistics for each emission point for each Salt River Area facility provide enough information to infer emission trends from 2002 to 2006. This inference can be made by looking at only 12 of the 36 major facilities, as many others are quite small, and several do not have any industrial area emissions. In Table S-1 the 2002 throughput statistics are given for all the major facilities with industrial emissions. This table shows that 95% of the total throughput comes from the top 12 or 13 facilities. Appendix S – Industrial Area Emissions S-1 Table S-1 Salt River Study Area Throughput for Large Stationary Sources in 2002 Throughput Company (Tons/year) % Total Cum % PHX 23rd Ave Wastewater Treatment Plant NA Proctor & Gamble NA APS West Phoenix Power Plant NA Marlam Industries Inc NA Road Machinery Co Inc NA City of Phoenix 27th Ave Landfill NA Chevron NA United Metro Materials 2,221,057 39.1 39.1 Vulcan 1,046,351 18.4 57.5 Rockland Materials 754,279 13.3 70.7 Quality Block (35th Ave) 321,081 5.6 76.4 Metal Management (35th Ave) 202,418 3.6 80.0 Hanson Aggregates 51st Ave 198,852 3.5 83.4 TPAC 153,822 2.7 86.2 Western Block Co. 126,335 2.2 88.4 Western Organics 27th Ave 109,714 1.9 90.3 Coreslab Structures, Inc. 82,878 1.5 91.8 Western Organics 51th Ave 81,850 1.4 93.2 Ameron International 69,088 1.2 94.4 Weinberger Topsoil 65,410 1.2 95.6 Phoenix Brick Yard 58,108 1.0 96.6 MCP Industries Inc. 45,985 0.8 97.4 Olson Precast 42,328 0.7 98.1 Smith Precast 35,050 0.6 98.8 VAW Of America, Inc. 34,875 0.6 99.4 South Mountain Farmers' Gin 19,947 0.4 99.7 Universal Entech Llc 6,546 0.1 99.8 Ajax Sand & Rock 3,500 0.1 99.9 Trendwood, Inc. 2,274 0.0 99.9 Southwest Forest Products 1,300 0.0 100.0 Schuff Steel 1,012 0.0 100.0 Woodstuff Mfg 879 0.0 100.0 ATC Phoenix 48 0.0 100.0 NA: No industrial area emissions %Total: The percentage that each facility contributes to the total Cum%: The cumulative percentage that each set of facilities contributes to the total Appendix S – Industrial Area Emissions S-2 Throughput statistics from these largest twelve facilities have been collected from their annual emission reports for 2002, 2003, and 2004. Projected throughput levels for 2005 and 2006 have been extrapolated linearly. Shown in Table S-2 and Figure S-1, the overall throughput trend for those facilities with industrial area emissions is slightly down, justifying the use of 2002 emissions in the 2006 base case. Table S-2 Salt River PM10 Area Throughput for the 12 Largest Facilities: 2002 - 2004 Company Annual Throughput in Tons 2002 2003 2004 United Metro Materials (19th Ave) [Now Rinker] 2,268,745 1,458,549 1,296,184 Vulcan (43rd Ave) 1,046,351 1,381,919 1,456,110 Hanson Aggregates (51st Ave) 953,269 944,846 1,322,700 Rockland Materials (43rd) [Now Arizona Materials] 656,407 533,051 371,914 Metal Management (35th Ave) 202,418 270,182 270,182 Quality Block (35th Ave) 198,852 198,512 226,199 TPAC (19th Ave) 153,822 67,775 92,702 Western Block Co. (19th Ave) 126,335 126,335 126,335 Western Organics Inc (27th Ave) 109,714 78,080 80,531 Western Organics Inc (51st Ave) 81,850 50,311 47,050 Coreslab Structures, Inc. (43rd Ave) 81,041 90,170 107,183 Ameron International (7th St) 69,088 73,234 111,611 Totals: 5,947,892 5,272,964 5,508,701 Bold values: No data were available, so the value from the previous year was used. Figure S-1. Salt River PM10 Study Area Throughput for Facilities with Industrial Area Emissions: 2002 – 2004 from Survey Data, Linearly Extrapolated to 2006 7 Throughput (millions of tons) 6 5 4 3 2 1 0 2002 2003 Appendix S – Industrial Area Emissions 2004 2005 2006 S-3 II. Rationale for the 60% Reductions The primary question here is what level of control was being achieved in 2002. While the MCESD Rule Effectiveness Study (see Appendix I) claims an impressively high figure of 88% for Rule 316 facilities (industrial and/or earthmoving) and 80% for Rule 310 facilities (earthmoving only), a less sanguine view may be in order. The rule effectiveness survey did inspect a suitable number of facilities: Twelve of the Rule 316 type and thirty-two of the Rule 310 type. But this kind of survey may have overestimated rule effectiveness because it: 1) was conducted under normal inspection conditions and not during high winds; 2) estimated compliance based on a numerical point system and did not correlate observed noncompliance to PM10 emissions; and 3) for Rule 316 sources, focused on process equipment and activities and may not have always verified stabilization in other less active areas of the site. It would be prudent to consider these high effectiveness figures as upper bounds, with the actual effectiveness being considerably lower. How much lower, exactly, is unknown, but the ambient record would suggest that far less than 80% of PM10 emissions were being controlled. At the West 43rd Avenue site, for example, of 189 24-hour averages of PM10 by TEOM, 10% of the concentrations exceeded 150 µg/m3 and 43% exceeded 100 µg/m3. At the Salt River site with every sixth day sampling by high-volume samplers, 4% of the 24-hour averages exceeded 150 µg/m3 and 28% exceeded 100 µg/m3. Shown in Figures S-2 and S-3, these distributions of PM10, and their elevated concentrations in particular, suggest that industrial emissions and trackout, which comprise 22% of the total emissions on lowwind days, were not being effectively controlled. Appendix S – Industrial Area Emissions S-4 Figure S-2. PM10 Concentrations (24-Hour Averages) at West 43rd Avenue in 2002: 189 TEOM Observations 250 200 ug/m3 150 100 50 4 9 14 19 23 28 33 38 42 47 52 57 61 66 71 76 80 85 90 95 99 0 Percentile Figure S-3. PM10 Concentrations (24-Hour Averages) at the Salt River Site in 2002: 50 High-Volume Observations 300 250 ug/m3 200 150 100 50 2 8 14 20 26 32 38 44 50 56 62 68 74 80 86 92 98 0 Percentile Appendix S – Industrial Area Emissions S-5 III. Sensitivity Analysis The largest four categories in the industrial area source group comprise 90% of its total emissions (Table S-3). In the demonstration of attainment in the Salt River PM10 Technical Support Document, these emissions have been reduced between 65 and 70% from 2002 to 2006. These reductions were based on the engineering effectiveness of more stringent controls and on the assumption that actual 2002 controls were less than the rule effectiveness study showed. With considerable uncertainty about the degree of control in 2002, this paper calculates modeled concentrations on the two low-wind design days with four sets of industrial area emissions: base case, plus 23%, plus 45%, and plus 68%. These figures translate into increases of 25%, 50%, and 75% for the top four categories: haul roads, material transfer, pile forming/loading, and crushing/screening. TABLE S-3 Base Case Industrial Area Emissions of PM10 in 2002 Activity Lbs/year % Total 200,904 56.17 Material Transfer 72,890 20.38 Pile Forming/Loading 29,644 8.29 Crushing/Screening 21,718 6.07 Combustion 11,648 3.26 Cooling Towers 10,346 2.89 Sand Blasting 6,563 1.83 Other 2,288 0.64 Conveyor Transfer 1,683 0.47 357,684 100 Haul Roads Total In Tables S-4 through S-7, the predicted concentrations are presented for the base case and the three increases. Table S-8 summarizes the results of the four previous tables. Figures S-4 through S-11 present the same data in pie charts. The percentage contribution of industrial area sources increases from 52 to 65% for January 18, 2002, at the Salt River site; and from 24 to 36% on December 16, 2002, at West 43rd Avenue, as their base case values are increased by 68%. If the degree of control of these four industrial area source activities in 2002 was less than the 80% claimed in the rule effectiveness study, then this range of concentrations provides a plausible contribution from this source category that is consistent with the 65 – 70% reductions taken in the Salt River PM10 Technical Support Document. Appendix S – Industrial Area Emissions S-6 TABLE S-4 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Two Low-wind Exceedances of PM10 in the Salt River Study Area in 2002 with Base Case Industrial Area Emissions January 8 December 16 Source category Primary Roads 26.66 West 43rd Avenue 57.92 Large Industrial Area 55.81 35.22 Trackout Unpaved Shoulders 6.85 2.97 27.33 9.34 Secondary Roads 2.73 8.94 Construction 6.14 4.45 Industrial Point Sources 5.42 1.90 Unpaved Parking Lots 0.27 1.00 Salt River TABLE S-5 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Two Low-wind Exceedances of PM10 in the Salt River Study Area in 2002 with Industrial Area Emissions Increased 23% January 8 December 16 Source category Salt River West 43rd Avenue Primary Roads 26.66 57.92 Large Industrial Area 68.65 43.32 Trackout 6.85 27.33 Unpaved Shoulders 2.97 9.34 Secondary Roads 2.73 8.94 Construction 6.14 4.45 Industrial Point Sources 5.42 1.90 Unpaved Parking Lots 0.27 1.00 Appendix S – Industrial Area Emissions S-7 TABLE S-6 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Two Low-wind Exceedances of PM10 in the Salt River Study Area in 2002 with Industrial Area Emissions Increased 45% January 8 December 16 Source category Salt River West 43rd Avenue Primary Roads 26.66 57.92 Large Industrial Area 80.92 51.07 Trackout 6.85 27.33 Unpaved Shoulders 2.97 9.34 Secondary Roads 2.73 8.94 Construction 6.14 4.45 Industrial Point Sources 5.42 1.90 Unpaved Parking Lots 0.27 1.00 TABLE S-7 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Two Low-wind Exceedances of PM10 in the Salt River Study Area in 2002 with Industrial Area Emissions Increased 68% January 8 December 16 Source category Salt River West 43rd Avenue Primary Roads 26.66 57.92 Large Industrial Area 93.76 59.17 Trackout 6.85 27.33 Unpaved Shoulders 2.97 9.34 Secondary Roads 2.73 8.94 Construction 6.14 4.45 Industrial Point Sources 5.42 1.90 Unpaved Parking Lots 0.27 1.00 Appendix S – Industrial Area Emissions S-8 TABLE S-8 Summary of Industrial Area Source Concentrations and Percentages of the Total Concentration for the Base Case Emissions and Increases of 23, 45, and 68% on Two Low-Wind Days in Salt River Study Area in 2002 Concentrations (µg/m3) Percentages of Total Emissions January 8 December 16 January 8 December 16 Salt River West 43rd Ave Salt River West 43rd Ave Base Case 56 35 52% 24% Plus 23% 69 43 58% 28% Plus 45% 81 51 62% 31% Plus 68% 94 59 65% 36% Appendix S – Industrial Area Emissions S-9 Figure S-4. Salt River PM10 Concentrations by Source Contribution: January 8, 2002, Salt River Site – Large Industrial Area Emissions at Base Case Levels Construction 6% Secondary Roads 3% Unpaved Shoulders 3% Unpaved Parking Lots Industrial Point 0% Sources Primary Roads 5% 25% Trackout 6% Large Industrial Area 52% Figure S-5. Salt River PM10 Concentrations by Source Contribution: December 16, 2002, West 43rd Avenue – Large Industrial Area Emissions at Base Case Levels Construction 3% Secondary Roads 6% Unpaved Shoulders 6% Trackout 19% Unpaved Parking Lots Industrial Point 1% Sources 1% Primary Roads 40% Large Industrial Area 24% Appendix S – Industrial Area Emissions S-10 Figure S-6. Salt River PM10 Concentrations by Source Contribution: January 8, 2002, Salt River Site – Large Industrial Area Emissions Increased 23% Construction 5% Secondary Roads 2% Unpaved Shoulders 2% Trackout 6% Unpaved Parking Lots Industrial Point 0% Sources Primary Roads 5% 22% Large Industrial Area 58% Figure S-7. Salt River PM10 Concentrations by Source Contribution: December 16, 2002, West 43rd Avenue – Large Industrial Area Emissions Increased 23% Construction 3% Secondary Roads 6% Unpaved Shoulders 6% Industrial Point Sources Unpaved Parking 1% Lots 1% Primary Roads 37% Trackout 18% Large Industrial Area 28% Appendix S – Industrial Area Emissions S-11 Figure S-8. Salt River PM10 Concentrations by Source Contribution: January 8, 2002, Salt River Site – Large Industrial Area Emissions Increased 45% Construction 5% Secondary Roads 2% Unpaved Shoulders 2% Trackout 5% Industrial Point Sources 4% Unpaved Parking Lots 0% Primary Roads 20% Large Industrial Area 62% Figure S-9. Salt River PM10 Concentrations by Source Contribution: December 16, 2002, West 43rd Avenue – Large Industrial Area Emissions Increased 45% Secondary Roads 6% Construction 3% Unpaved Shoulders 6% Industrial Point Sources 1% Unpaved Parking Lots 1% Primary Roads 35% Trackout 17% Large Industrial Area 31% Appendix S – Industrial Area Emissions S-12 Figure S-10. Salt River PM10 Concentrations by Source Contribution: January 8, 2002, Salt River Site – Large Industrial Area Emissions Increased 68% Industrial Point Sources 4% Construction 4% Secondary Roads 2% Unpaved Shoulders 2% Trackout 5% Unpaved Parking Lots 0% Primary Roads 18% Large Industrial Area 65% Figure S-11. Salt River PM10 Concentrations by Source Contribution: December 16, 2002, West 43rd Avenue – Large Industrial Area Emissions Increased 68% Construction 3% Secondary Roads 5% Unpaved Shoulders 5% Industrial Point Sources 1% Unpaved Parking Lots 1% Primary Roads 34% Trackout 16% Large Industrial Area 35% Appendix S – Industrial Area Emissions S-13 The effect of increasing the 2002 industrial area emissions on the overall predicted air quality concentrations can be seen in the following set of tables, Tables S-9 through S12. The predicted concentrations from the industrial area sources increase, as the concentrations from the other sources decrease. This balancing increase and decrease arises from the fact that the ambient concentration and its background contribution remain constant, so increasing one source leads to decreases in the others. The chief contributor to the low-wind concentrations other than industrial area is primary roads. Because primary road emissions from 2002 to 2006 decrease seven percent with more frequent sweeping, but the industrial area source emissions decrease 60% with more stringent rules and better enforcement, the overall change is a net decrease in the total predicted concentrations on the low-wind days. In Table S-13 the four previous tables are summarized, with the total predicted PM10 concentrations decreasing from 130 to 124 µg/m3 for the January 8 exceedance and from 142 to 138 µg/m3 for the December 16 exceedance. This exercise demonstrates that increasing the industrial area source emissions in 2002 – on anecdotal and ambient air evidence that the overall control efficiencies were lower than the rule effectiveness study indicated – does not jeopardize the demonstration of attainment. Appendix S – Industrial Area Emissions S-14 TABLE S-9 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 -- Attainment case, Corrected on November 22, 2004 Dec. Jan. 8 April 15 April 26 16 Source Category West West West Durango Salt Salt Durango Salt 43rd 43rd 43rd River River River Avenue Avenue Avenue Windblown Agricultural 0.94 1.17 0.67 5.23 17.51 8.46 Windblown Alluvial 1.03 4.98 0.14 1.81 17.36 23.36 Large Industrial Area 4.94 2.92 1.08 1.75 22.15 7.70 11.86 11.00 Primary Roads 2.06 24.71 32.80 10.04 8.08 15.86 7.42 42.23 Windblown Vacant Lots 2.37 2.48 0.00 1.57 0.03 15.88 Windblown Industrial 1.55 3.52 0.67 1.09 8.71 7.41 Windblown Disturbed 3.23 1.16 2.16 4.88 14.71 6.79 Trackout 1.36 1.35 0.33 0.81 1.55 0.71 0.34 4.27 Windblown Construction 0.48 1.61 0.05 0.33 1.06 11.80 Windblown Stockpiles 0.84 4.90 4.17 3.02 0.61 6.01 Unpaved Shoulders 2.65 0.67 0.37 1.59 0.00 0.00 0.00 6.56 Secondary Roads 2.68 1.60 1.26 1.27 1.22 0.67 0.28 6.89 Construction 3.90 0.79 0.58 2.91 0.30 0.34 0.31 2.22 Industrial Point Sources 4.46 2.34 2.66 2.53 2.59 0.52 0.04 1.23 Unpaved Parking Lots 0.17 0.94 0.05 0.03 0.91 0.05 0.00 0.50 Freeway 0.47 0.27 0.30 0.09 0.40 0.31 0.08 0.75 Sum of Contributions 63 62 46 65 63 66 34 76 Background 67 82 82 82 67 67 67 66 Background + Sum 130 144 128 147 130 133 101 142 Shaded concentrations exceed 5 µg/m3, the threshold for significance for potential controls. Appendix S – Industrial Area Emissions S-15 TABLE S-10 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 -- Attainment Case corrected on November 22, 2004, with 23% increase in Large Industrial Area Emissions Jan. 8 April 15 April 26 Dec. 16 West West West Source Category Salt Durango Salt Durango Salt 43rd 43rd 43rd River River River Avenue Avenue Avenue Windblown Agricultural 0.90 1.16 0.66 5.11 17.45 8.15 Windblown Alluvial 1.01 4.77 0.14 1.75 17.18 23.14 Large Industrial Area 3.55 1.32 2.13 24.35 5.93 9.08 14.06 12.82 Primary Roads 2.04 22.08 32.02 9.63 8.00 15.80 7.15 40.03 Windblown Vacant 2.31 2.38 0.00 1.56 0.03 15.31 Lots Windblown Industrial 1.52 3.37 0.67 1.08 8.62 7.15 Windblown Disturbed 4.77 3.10 1.15 2.14 14.65 6.55 Trackout 1.21 1.31 0.31 0.80 1.55 0.69 0.34 4.04 Windblown 0.47 1.54 0.05 0.31 1.05 11.68 Construction Windblown Stockpiles 0.82 4.85 4.15 2.91 0.60 5.76 Unpaved Shoulders 2.37 0.65 0.36 1.57 0.00 0.00 0.00 6.22 Secondary Roads 2.40 1.56 1.21 1.26 1.22 0.64 0.28 6.54 Construction 3.49 0.77 0.56 2.88 0.29 0.33 0.31 2.11 Industrial Point 3.99 2.29 2.55 2.50 2.58 0.50 0.04 1.17 Sources Unpaved Parking Lots 0.15 0.92 0.04 0.03 0.91 0.05 0.00 0.48 Freeway 0.42 0.26 0.29 0.09 0.40 0.30 0.08 0.71 Sum of Contributions 60 62 46 65 63 66 34 74 Background 67 82 82 82 67 67 67 66 Background + Sum 127 144 128 147 130 133 101 140 Shaded concentrations exceed 5 µg/m3, the threshold for significance for potential controls. Appendix S – Industrial Area Emissions S-16 TABLE S-11 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 -- Attainment case Corrected on November 22, 2004, with a 45% increase in Industrial Area Emissions Jan. 8 April 15 April 26 Dec. 16 West West West Source Category Salt Durango Salt Durango Salt 43rd 43rd 43rd River River River Avenue Avenue Avenue Windblown Agricultural 4.99 0.86 1.15 0.66 17.38 7.88 Windblown Alluvial 0.98 4.59 0.14 1.69 17.01 22.94 Large Industrial Area 4.14 1.55 2.49 26.05 6.84 10.29 16.02 14.40 Primary Roads 2.02 20.05 31.30 9.26 7.92 15.75 6.91 38.13 Windblown Vacant 2.26 2.29 0.00 1.56 0.03 14.79 Lots Windblown Industrial 1.48 3.24 0.67 1.07 8.54 6.91 Windblown Disturbed 4.66 2.98 1.13 2.12 14.60 6.33 Trackout 1.10 1.28 0.30 0.79 1.54 0.66 0.34 3.85 Windblown 0.46 1.48 0.05 0.30 1.04 11.56 Construction Windblown Stockpiles 0.80 4.80 4.14 2.81 0.60 5.54 Unpaved Shoulders 2.15 0.63 0.34 1.56 0.00 0.00 0.00 5.93 Secondary Roads 2.17 1.53 1.16 1.25 1.21 0.62 0.28 6.22 Construction 3.16 0.76 0.54 2.85 0.29 0.32 0.31 2.01 Industrial Point 3.62 2.24 2.45 2.48 2.57 0.48 0.04 1.11 Sources Unpaved Parking Lots 0.14 0.90 0.04 0.03 0.90 0.05 0.00 0.45 Freeway 0.38 0.26 0.28 0.09 0.40 0.29 0.08 0.68 Sum of Contributions 59 61 46 65 63 66 34 73 Background 67 82 82 82 67 67 67 66 Background + Sum 126 143 128 147 130 133 101 139 Shaded concentrations exceed 5 µg/m3, the threshold for significance for potential controls. Appendix S – Industrial Area Emissions S-17 TABLE S-12 Predicted Concentrations in µg/m3 from All Emission Source Categories to the Eight Exceedances of PM10 in the Salt River Study Area in 2006 -- Attainment Case Corrected on November 22, 2004, with a 68% Increase in Industrial Area Emissions Jan. 8 April 15 April 26 Dec. 16 West West West Source Category Salt Durango Salt Durango Salt 43rd 43rd 43rd River River River Avenue Avenue Avenue Windblown Agricultural 4.88 0.83 1.14 0.65 17.32 7.61 Windblown Alluvial 0.96 4.41 0.13 1.63 16.84 22.73 Large Industrial Area 4.75 1.79 17.94 2.86 27.52 7.74 11.47 15.89 Primary Roads 2.01 18.28 30.59 8.90 7.84 15.69 6.68 36.33 Windblown Vacant 2.21 2.20 0.00 1.55 14.30 0.03 Lots Windblown Industrial 1.45 3.12 0.67 1.06 8.45 6.67 Windblown Disturbed 4.55 2.87 1.12 2.10 14.55 6.11 Trackout 1.01 1.26 0.29 0.78 1.54 0.64 0.33 3.67 Windblown 0.45 1.42 0.05 0.29 1.03 11.45 Construction Windblown Stockpiles 0.78 4.75 4.12 2.71 0.59 5.33 Unpaved Shoulders 1.96 0.62 0.33 1.54 0.00 0.00 0.00 5.65 Secondary Roads 1.98 1.49 1.12 1.24 1.21 0.60 0.27 5.93 Construction 2.88 0.74 0.52 2.82 0.29 0.31 0.31 1.91 Industrial Point 3.30 2.19 2.36 2.45 2.56 0.47 0.04 1.06 Sources Unpaved Parking Lots 0.13 0.87 0.04 0.03 0.90 0.05 0.00 0.43 Freeway 0.35 0.25 0.27 0.08 0.40 0.28 0.08 0.64 Sum of Contributions 57 61 45 65 63 66 34 72 Background 67 82 82 82 67 67 67 66 Background + Sum 124 143 127 147 130 133 101 138 Shaded concentrations exceed 5 µg/m3, the threshold for significance for potential controls. Appendix S – Industrial Area Emissions S-18 TABLE S-13 Predicted PM10 Concentrations for the 2006 Attainment Case, with Three Increases in the 2002 Industrial Area Emissions Percent Jan 8 April 15 April 26 Increase West in Source category Salt Durango Salt 43rd Durango Salt Emissions River River Ave. River Large Industrial Area 22.15 4.94 7.70 2.92 1.08 11.86 Sum of Base Contributions 63 62 46 65 63 66 +0% Background 67 82 82 82 67 67 Background + Sum 130 144 128 147 130 133 Industrial Area +23% Industrial Area +45% Industrial Area +68% Large Industrial Area Sum of Contributions Background Background + Sum Large Industrial Area Sum of Contributions Background Background + Sum Large Industrial Area Sum of Contributions Background Background + Sum West 43rd Ave. Dec16 West 43rd Ave. 1.75 11.00 34 67 76 66 101 142 24.35 5.93 9.08 3.55 1.32 14.06 2.13 12.82 60 67 62 82 46 82 65 82 63 67 66 67 34 67 74 66 127 144 128 147 130 133 101 140 26.05 6.84 10.29 4.14 1.55 16.02 2.49 14.40 59 67 61 82 46 82 65 82 63 67 66 67 34 67 73 66 126 143 128 147 130 133 101 139 27.52 7.74 11.47 4.75 1.79 17.94 2.86 15.89 57 67 61 82 45 82 65 82 63 67 66 67 34 67 72 66 124 143 127 147 130 133 101 138 Appendix S – Industrial Area Emissions S-19 APPENDIX T - POTENTIAL CONTROL MEASURES FOR AREA SOURCES FOR SALT RIVER PM10 SIP Maricopa Environmental Services Department - May 27, 2005 Potential Control Measures for Area Sources for Salt River SIP Source Category Comments 1. Open areas and vacant lots1 – stabilization standards Potential Enhancement Clarify Rule 310 and 310.01 subsection 302 stabilization standards by including text from Appendix C 2.2. Difficult to enforce stabilization requirements as currently written 2. Open areas and vacant lots – compliance and inspection program Unpaved parking lots – stabilization requirements2 Enhance vacant lot enforcement and compliance program by hiring inspection and enforcement staff dedicated to open areas and vacant lots. 3. 4. 5. Dust generating operation – requirement to have water application system on site Construction activities3 requirement for dust monitor at large construction sites 1 Revise 310.01 subsection 303 “For the purpose of this rule, the owner and/or operator of an unpaved parking lot on which vehicles are parked no more than 35 days per year, excluding days on which ten or fewer vehicles enter, shall implement … for the duration of time that over 100 vehicles enter and/or park on such unpaved parking lot” so that it is similar to Clark Co. AQR 92, “For unpaved parking lots that are utilized intermittently, for a period of 35 days or less during the calendar year, the owner and/or operator shall implement one of the control measures described in …during the period that the unpaved parking lot is utilized for vehicle parking” Rule 310 subsection 308.7 (Soil Moisture) lower the requirement to have a water application system on site during earthmoving operations from 1 acre to ½ acre. Require trained “dust control monitor” on site for construction projects with 10 acres or greater of active, disturbed area and all sand and gravel operations who would direct dust control activities to maintain compliance with a 20% opacity limit. Clark Co. AQR 90.4.1 Clark Co. has one inspector in each regional office dedicated to vacant lot inspections. Per Rodney Langston, Clark Co. More understandable and more enforceable. Clark Co. MSM analysis 6.3.2.1 Being proposed in new Rule 310 revisions. Clark Co. AQR 94.7.5 Clark Co. MSM analysis 6.3.3.2 1999 MAG Serious Area Plan (p. V-21) - MAG assumed that 76 percent of the disturbed vacant land in the nonattainment area is disturbed vacant lots. Assumptions related to the effectiveness of control measures (local govt and Rule 310 commitments) on the emissions from disturbed vacant lots were based on the effectiveness reported in the ADEQ microscale plan. It assumed that an equal number of vacant disturbed lots would be treated with mulch or vegetative cover, treated with gravel, and treated with chemical stabilizers. Emissions from vacant disturbed lots were assumed to be 71 percent controlled in 2006. Since vacant disturbed lots comprise 76 percent of disturbed vacant land, the 71 percent control level only applies to 76 percent of the disturbed vacant land emissions. A 100 percent rule penetration was assumed to be reasonable for Rule 310 application to vacant lots. 2 1999 MAG Serious Area Plan (p. V-17) assumed that an equal number of parking lots would be paved, treated with gravel, and treated with chemical stabilizers. Emissions from vehicular travel on unpaved parking lots were assumed to be 60 percent controlled in 2006. Windblown dust from unpaved parking lots was assumed to be 71 percent controlled in 2006. It was also assumed that unpaved parking lots comprise 24 percent of the disturbed vacant land and therefore the 71 percent level only applies to 24 percent of the disturbed vacant land emissions. A 100 percent rule penetration was assumed to be reasonable for Rule 310 application to unpaved parking lots. T-1 Appendix T – Potential Control Measures for Area Sources Source Category Potential Enhancement Comments 6. Revise Rule 310 requirement for the use of track out control devices from projects with > five acres of disturbed area to projects with > one acre of disturbed area (subsection 308.3 a.1). Clark Co. limit is 0.25 acres. Clark Co. MSM analysis 6.3.3.9 Dust generating operation – trackout prevention4 5 This change will require trackout controls on 98% of earthmoving acreage from 94% before the revision (based on 2002-2003 earth moving permits 1 acre or larger vs. earthmoving permits 5 acres or larger in 2002 – 2003). 4.3% increase in sites required to control trackout. 7. Dust generating operation – hauling and transporting Revise Rule 310 subsection 308.6(b) (Open Storage Piles) and Bulk Material Hauling/Transporting (Table 11) to include the following: Requirement to “empty loader bucket slowly and keep loader bucket close to the truck to minimize the drop height”. Being proposed in new Rule 310 revisions. Clark Co. has similar requirements for construction activity truck loading. Clark Co. MSM analysis 6.3.3.10 and dust control handbook BMP 23; SCAQMD Rule 403 Being proposed in new Rule 310 revisions. 3 1999 MAG Serious Area Plan (V-9) assumed PM10 emissions from construction activities are 72% (90% CE x 80% CE) controlled in 2006 (66 % reduction from base case emissions.). 4 1999 MAG Serious Area Plan (p.V-9) assumed that methods used to remove and/or control trackout from construction sites resulted in 72% control in 2006 (because the base case emissions were assumed to be 18 percent controlled, raising the control to 72 % for 2006 will provide 66 % reduction from base case emissions.). (DK1 assuming the 72% = 80% Control Efficiency * 90% Compliance Rate). The 1999 MAG Serious Area Plan also assumed a rule penetration of 100 percent for Rule 310 with regard to construction activities. 5 Final BACM Technological and Economic Feasibility Analysis, Sierra Research, March 21, 2003, p. 22: The pipe grid trackout control device was estimated to reduce trackout by 80%. This estimate is based on the data reported in the 2002 MRI report for gravel and paved interior road control devices, and an estimate provided by a construction inspector for the Maricopa County SBAP. p. 23 – The control efficiency of a gravel bed trackout control device has been shown in the 2001 MRI study to average 46%. P. 24 – The average control efficiency of interior paved roads in reducing trackout was 43% as reported in the 2001 MRI study. T-2 Appendix T – Potential Control Measures for Area Sources Source Category Potential Enhancement Comments 8. Revise Rule 310 to include “Limit vehicle speeds to 15 m.p.h. on the work site as a suggested additional control measure for contingency plans in Table 2 (unpaved parking lots), Table 6 (Disturbed Surface Areas – Work Practices During Operations), Table 13 (Bulk Material Hauling/Transporting – Within the Boundaries of the Work Site when Crossing a Paved Area Accessible to the Public While Construction is Underway), and Table 18 (Weed abatement by discing or blading). Because this is a contingency measure and stationary sources report average vehicle speeds of ≈ 7 – 10 mph, the reductions are difficult to quantify and possibly minimal. Fugitive dust sources (unpaved parking lots, disturbed surface areas, bulk material hauling/transporting, weed abatement) - limit vehicle speeds to 15 mph Clark Co. MSM analysis 6.3.3.11 and Dust Control Handbook BMP 13 Sierra Research estimated that use of a radar gun on unannounced inspection basis would produce 50% compliance with the proposed measure to limit on-site vehicle speeds to 15 mph San Joaquin Rule 8021 requires that vehicle travel over unpaved surfaces at construction sites not produce visible dust plumes with opacities greater than 20%. They also proposed vehicle speeds on unpaved surfaces would be limited to 15 mph to guarantee low emission rates. 9. Dust generating operations – visible emission limits Revise Rule 310 to include revisions to the fugitive dust test methods contained in Rule 310, Appendix C and other improvements including a 50% opacity limit at any given time as observed in a single opacity reading (Subsection 301). Being proposed in new Rule 310 revisions. In addition to the 20 % opacity limit based on 12 or 24 time-averaged readings, Clark Co. AQR Section 94 limits visible emissions from construction activities to a 50% opacity using the instantaneous method. Clark Co. MSM analysis 6.3.3.4; AQR 94.6.8(d); AQR 94.6.8(b) Being proposed in new Rule 310 revisions. 10. Unpaved haul road and trackout controls6 Strengthen and better enforcement of fugitive dust control rules at stationary sources. 6 The large majority of industrial sources reporting emissions from unpaved haul roads report control efficiency of 70% and control capture of 100%. The rule effectiveness study conducted in 2003, estimated the compliance rate for Rule 316 at 89.7% and for Rule 310 at 77.3%, Bob Downing will adjust the industrial source emission estimates for modeling purposes accordingly. Appendix T – Potential Control Measures for Area Sources T-3 Potential Reductions from MCESD Control Measures 1. WIND EROSION – CONSTRUCTION BACKGROUND INFORMATION: Per Phil Denee 10/6/03 no controls included in 10/1/03 Emissions Summary by Category. xls 1999 MAG Serious Area Plan (p. V-10) – Assumptions related to the control of windblown emissions from construction sites were revised to be consistent with the assumptions related to control of construction-activity generated fugitive dust. It was assumed that construction sites on the regional scale used the following control measures equally: wind fences, chemical stabilizers, gravel, and watering. It was assumed that windblown emissions from construction sites were 70 percent controlled in 2006. Because the base case emissions were assumed to be 20 percent controlled, raising the control to 70 percent for 2006 will provide 62.4 percent control of the base case emissions for 2006. The acreage of construction activity that was used to estimate total construction emissions in the MAG Serious Area Plan was based on the permitted acres of construction. Therefore, only emissions from permitted construction activities appear in the Serious Area Plan inventory and a rule penetration of 100 percent was used for Rule 310 with regard to construction activities. Evaluation for Compliance with the 24-hour PM10 Standard for the West Chandler and Gilbert Microscale Sites, ADEQ, June 1999, p.3-5 – Road and Housing Construction – Control measures for reducing PM10 emissions from disturbed areas that are a result of road and housing construction include: 1) chemical stabilizers, which have a control efficiency of 82 to 90%; 2) watering to maintain adequate soil moisture, with a control efficiency of 90%; and 3) watering to maintain a crust on the surface of the soil when and area is inactive, with a control efficiency of 90%. To be effective, the soil crust should be at least 0.6 cm thick and not easily crumble between the fingers. A control efficiency of 90% was used in modeling this type of measure. Salt River Inspection Results for earthmoving dated 10/2/03 – showed average rule effectiveness “compliance rate” of 80.0%. PROPOSED CONTROL MEASURE: • Change requirement for water application system on site from 1 acre to 0.50 acres. PROPOSED CONTROL EFFECTIVENESS: Proposed 2002 control effectiveness – 90% control efficiency * 70% = 63% overall control effectiveness 2006 control effectiveness - 90% control efficiency * 78% compliance rate = 70% overall control effectiveness Example: 2002 Wind Erosion Construction uncontrolled = 50.71 mtpd 2002 Wind Erosion Construction 63% controlled = 18.76 mtpd 2006 Wind Erosion Construction 70% controlled = 15.21 mtpd 2. WIND EROSION - VACANT LOTS BACKGROUND INFORMATION: Appendix T – Potential Control Measures for Area Sources T-4 Per Phil Denee 10/6/03 no controls included in 10/1/03 Emissions Summary by Category.xls 1999 MAG Serious Area Plan (p. V-21) – MAG assumed that 76 percent of the disturbed vacant land in the nonattainment area is disturbed vacant lots. Assumptions related to the effectiveness of control measures (local govt and Rule 310 commitments) on the emissions from disturbed vacant lots were based on the effectiveness reported in the ADEQ microscale plan. It assumed that an equal number of vacant disturbed lots would be treated with mulch or vegetative cover, treated with gravel, and treated with chemical stabilizers. Emissions from vacant disturbed lots were assumed to be 71 percent controlled in 2006. Since vacant disturbed lots comprise 76 percent of disturbed vacant land, the 71 percent control level only applies to 76 percent of the disturbed vacant land emissions. A 100 percent rule penetration was assumed to be reasonable for Rule 310 application to vacant lots. Clark Co. PM10 State Implementation Plan, June 2001, p. L-11 – Clark Co. has committed to hiring ten new enforcement department staff members to implement enforcement for wind erosions – vacant land, unpaved parking and race tracks. A 80% rule compliance will be in place by Jan. 1, 2002. Rule compliance will be “ramping up” during 2001 and a rule compliance of 40 percent was used as a default prior to 2002. For construction – activities, wind erosions and trackout, Clark Co. committed to a similar increase in enforcement staff. Currently, there are seven enforcement officers that inspect construction sites. Clark Co. AQD committed to hiring three additional enforcement officers to enforce the new Section 94 regulation. Due to the current 30 percent deficit in enforcement officers, the default rule effectiveness was reduced 24 percent (30 percent reduction of 80 percent) in 2001 to 56 percent due to lack of sufficient enforcement. Salt River Inspection Results for vacant lots dated 10/2/03 – showed average rule effectiveness “compliance rate” value of 62.1%. PROPOSED CONTROL MEASURES: • Clarify Rule 310 and 310.01 subsection 302 stabilization standards by including text from Appendix C 2.2. • Enhance vacant lot enforcement and compliance program by hiring inspection and enforcement staff dedicated to open areas and vacant lots. PROPOSED CONTROL EFFECTIVENESS: Proposed 2002 control effectiveness - 90% control efficiency * 62 % compliance rate = 55% overall control effectiveness • Adding 4 additional inspectors would allow inspection of 20% of the vacant lots. And focused inspections during wind events over 15 mph per national weather service bulletin. 2006 control effectiveness - 90% control efficiency * 79% compliance rate = 71% overall control effectiveness Example: 2002 Vacant Lots uncontrolled = 106.27 mtpd 2002 Vacant Lots 55% controlled = 47.82 mtpd 2006 Vacant Lots 71% controlled = 30.82 mtpd 3. CONSTRUCTION ACTIVITY TOTAL - RESIDENTIAL AND INDUSTRIAL CONSTRUCTION BACKGROUND INFORMATION: Salt River EI Methodology, Rough Draft – September 30, 2003, p. 11 Controlled PM10 = Uncontrolled PM10 emission x 90% x 90% Uncontrolled PM10 emission x 0.80 (round-off) Appendix T – Potential Control Measures for Area Sources T-5 1999 MAG Serious Area Plan (p. V-10) The effect of Rule 310 on general construction emissions, those resulting from active construction processes, is based on an assumed compliance rate of 80% and the effectiveness reported in the ADEQ microscale plan for earth moving (water to the depth of cut 90%). It was assumed that PM10 emissions resulting from construction activities are 72 percent controlled in 2006. Because the base case emissions were assumed to be 18 percent controlled, raising the control to 72 percent for 2006 will provide a 66 percent control of the base case emissions for 2006. Clark County estimated that the improved test methods we are in the process of implementing should improve their rule's effectiveness by 16% (20% X 80%). PROPOSED CONTROL MEASURES: • Lower the requirement to have a water application system on site from 1 acre to ½ acre (Rule 310 subsection 308.7). Being proposed in new Rule 310 revisions. • Require trained “dust control monitor” on site for construction projects with 10 acres or greater of active, disturbed area and all sand and gravel operations who would direct dust control activities to maintain compliance with a 20% opacity limit.7 • Revise Rule 310 requirement for the use of track out control devices from projects with > five acres of disturbed area to projects with > one acre of disturbed area (subsection 308.4 a.1). Being proposed in new Rule 310 revisions.8 • Revise Rule 310 bulk material hauling/transporting (Table 11) to include the following a requirement to “empty loader bucket slowly and keep loader bucket close to the truck to minimize the drop height”. Being proposed in new Rule 310 revisions. • Revise Rule 310 table 2, 6, 13, and 18 (during construction) to include as a contingency measure “limiting vehicle speeds to 15 mph on the work site” Being proposed in new Rule 310 revisions. • Revise Rule 310 to include revisions to test methods and other improvements including a 50% opacity limit using the instantaneous method or no single reading over 50% opacity. Being proposed in new Rule 310 revisions. PROPOSED CONTROL EFFECTIVENESS: Proposed 2002 control effectiveness = Reduce the 72% by 16% = 56% overall rule effectiveness 2006 control effectiveness = 90% control efficiency * 80% compliance rate = 72% overall rule effectiveness 7 Final BACM Technological and Economic Feasibility Analysis, Sierra Research, March 21, 2003, p. 41-43: San Joaquin Valley assumed that monitoring would demonstrate the need for additional dust control effectiveness, which would be satisfied by the operation of an additional water truck on a continuous basis to reduce emissions from all fugitive PM10 sources. days. The control efficiency of construction dust control measures implemented under an apporved dust control plan were estimated from data reported by the Bay Area power plan construction inspectors and data collected by MRI. Base on the data provided in the Bay Area construction reports, Sierra Research estimated that a 50-acre residential construction project would use two 4,000 gallon water trucks operating continuously to water 30% of the construction site (15 acres) that would be actively disturbed due to earthmoving operations on any one day. Operating continuously, these water trucks would cover the 15 acres every 3.2 hours. The MRI study indicates that the average control efficiency provided by watering actively disturbed areas on this frequency would be 60.6%. The use of one additional water truck would reduce the watering frequency to every 2.1 hours. At this frequency, the MRI report indicates that the average control efficiency would be 73.7%. The emission reduction that would occur on 5% of the days on which the monitoring system would record exceedances of the PM10 concentration increment would be 0.29 tons or 586 pounds of PM10. These latter values, then, represent the emission reduction benefits of conducting monitoring at a 50-acre residential construction sites. 8 1999 MAG Serious Area Plan (p.V-9) assumed that methods used to remove and/or control trackout from construction sites resulted in 72% control in 2006 (because the base case emissions were assumed to be 18 percent controlled, raising the control to 72 % for 2006 will provide 66 % reduction from base case emissions.). Appendix T – Potential Control Measures for Area Sources T-6 Example: 2002 Construction Activity Total – 80% controlled = 1.91 mtpd 2002 Construction Activity Total – uncontrolled = 9.55 mtpd Proposed 2002 control effectiveness – 56% controlled ([1-.56] * 9.55)= 4.20 2006 Construction Activity Total – 72 % controlled ([1-.28] * 9.55) = 2.67 4. INDUSTRIAL SOURCE EMISSIONS – AREA/POINT BACKGROUND INFORMATION: According to Bob Downing industrial source emissions inventory report 70% control efficiency and 100% capture efficiency. Revise capture efficiency to be consistent with rule effectiveness study. Rule effectiveness study results show 89.7% compliance rate for Rule 316 and 77.3% control efficiency for Rule 310. PROPOSED CONTROL MEASURES • Strengthen and better enforcement of fugitive dust control rules at stationary sources. PROPOSED CONTROL EFFECTIVENESS: Proposed 2002 control effectiveness for Rule 310 = 77% compliance rate * 70% control efficiency = 54% overall rule effectiveness 2006 control effectiveness = 70% control efficiency * 80% compliance rate = 56% overall rule effectiveness Proposed 2002 control effectiveness for Rule 316 = 80% compliance rate * 70% control efficiency = 56% overall rule effectiveness 2006 control effectiveness = ??? Appendix T – Potential Control Measures for Area Sources T-7 APPENDIX U – UNPAVED ROAD SHOULDER EMISSIONS The contribution of wake effects and trackout from unpaved road shoulders were accounted for in the Salt River PM10 Emissions Inventory. However, the contribution of parking and driving on unpaved road shoulders, and wind erosion of unpaved road shoulders were not included in the inventory due to their very small contribution. The predicted impacts on ambient PM10 levels if the emissions from parking and driving on unpaved road shoulders, and wind erosion of unpaved road shoulders had been included in the inventory is included below. I. Change in PM10 Emissions Table 1 lists the predicted emissions from unpaved road shoulders for the above five categories for high-wind and low-wind days. TABLE U-1 Unpaved Road Shoulder Emissions (Metric Tons PM10 / Day) High-Wind Low-Wind Category Day Day Included in Inventory: Wake Effects 0.13 0.13 Trackout 0.04 0.04 Total 0.17 0.17 Not Included in Inventory: Parking Driving Wind Erosion Total 0.003 0.016 0.280 0.299 0.003 0.016 -0.019 Thus, the emissions from unpaved road shoulders would increase by only 0.299 tons per day for high-wind days and 0.019 tons per day for low wind days if the emissions from parking and driving on unpaved road shoulders, and wind erosion had been included in the inventory. For comparison, the total PM10 emissions on the April 15, 2002 high-wind day were 168.43 metric tons /day and the total PM10 emissions on the January 8, 2002 lowwind day were 6.25 metric tons/day. This translates to a 0.18% increase in total PM10 emissions for high-wind days and a 0.30% increase in total PM10 emissions for low-wind days. Appendix U – Unpaved Road Shoulder Emissions U-1 II. Change in Predicted Ambient PM10 Levels Tables U-2 and U-3 show the change in predicted ambient PM10 levels for high-wind days and low-wind days for the Year 2006 out year when the PM10 emissions from parking and driving on unpaved road shoulders, and wind erosion of unpaved road shoulders are included. (Note: design days correspond to PM10 exceedance days recorded during Salt River monitoring study) TABLE U-2 Comparison of Predicted Ambient PM10 Levels (µg/m3) Before and After Including Additional Emissions from Unpaved Road Shoulders on Low-Wind Days Emissions Inventory January 8, December 2006 16, 2006 Low-Wind Low-Wind Design Day Design Day Salt River West 43rd Avenue Monitor Monitor 2006 PM10 Emissions Inventory – Original 129 138 2006 PM10 Emissions Inventory – Revised* 129.03 138.51 Increase in Ambient PM10 Levels 0.03 0.51 * Revised emissions inventory includes additional emissions from parking and driving on unpaved road shoulders, and wind erosion of unpaved road shoulders TABLE U-3 Comparison of Predicted Ambient PM10 Levels (µg/m3) Before and After Including Additional Emissions from Unpaved Road Shoulders on High-Wind Days Emissions April 15, 2006 April 26, 2006 Inventory High-Wind Design Day High-Wind Design Day Salt W. 43rd Durango Salt W. 43rd Durango Avenue Complex River Avenue Complex River Monitor Monitor Monitor Monitor Monitor Monitor 2006 PM10 Emissions Inventory – Original 144 128 141 130 140 94 2006 PM10 Emissions – Revised* 144.86 128.01 141.79 130.27 140 94 Increase in Ambient PM10 Levels 0.86 0.01 0.79 0.27 0 0 * Revised emissions inventory includes additional emissions from parking and driving on unpaved road shoulders, and wind erosion of unpaved road shoulders Appendix U – Unpaved Road Shoulder Emissions U-2 In conclusion, Appendix U demonstrates that the contribution of parking and driving on unpaved road shoulders, and wind erosion of unpaved road shoulders to ambient PM10 levels in the Salt River PM10 Study Area is negligible. Appendix U – Unpaved Road Shoulder Emissions U-3