Study of collocated sources of air pollution and the potential for circumventing regulatory major source permitting requirements near Sun City, Arizona

The following research is a regulatory and emissions analysis of collocated sources of air pollution as they relate to the definition of "major, stationary, sources", if their emissions were amalgamated. The emitting sources chosen for this study are seven facilities located in a single, aggregate mining pit, along the Aqua Fria riverbed in Sun City, Arizona. The sources in question consist of Rock Crushing and Screening plants, Hot Mix Asphalt plants, and Concrete Batch plants. Generally, individual facilities with emissions of a criteria air pollutant over 100 tons per year or 70 tons per year for PM10 in the Maricopa County non-attainment area would be required to operate under a different permitting regime than those with emissions less than stated above. In addition, facility's that emit over 25 tons per year or 150 pounds per hour of NOx would trigger Maricopa County Best Available Control Technology (BACT) and would be required to install more stringent pollution controls. However, in order to circumvent the more stringent permitting requirements, some facilities have "collocated" in order to escape having their emissions calculated as single source, while operating as a single, production entity. The results of this study indicate that the sources analyzed do not collectively emit major source levels of emissions; however, they do trigger year and daily BACT for NOx. It was also discovered that lack of grid power contributes to the use of generators, which is the main source of emissions. Therefore, if grid electricity was introduced in outlying areas of Maricopa County, facilities could significantly reduce the use of generator power; thereby, reducing pollutants associated with generator use.