HomeMy WebLinkAboutDAQ-2024-0047331
DAQC-065-24
Site ID 10885 (B1)
MEMORANDUM
TO: FILE – STAKER PARSON MATERIALS & CONSTRUCTION – Heber Binggeli
Pit
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Irene Tucker, Environmental Scientist
DATE: January 8, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Wasatch County
INSPECTION DATE: November 30, 2023
SOURCE LOCATION: Three miles south of Heber City, Charleston
SOURCE CONTACT: Christian Boudreau, Environmental Specialist, West Division,
801-871-6704, 385-318-6938,
Christian.boudreau@stakerparson.com
OPERATING STATUS: In operation
PROCESS DESCRIPTION: This is an aggregate and concrete plant. Nonmetallic minerals
are mined, crushed, screened, and transported offsite or into the
concrete plant. Trucks, conveyors, and stackers move the
crushed aggregate (rocks, sand, and gravel) into storage piles or
off site for sale. Materials that pass through the on-site wash
plant are sent to the concrete plant. A concrete mixer combines
aggregate, cement, and water to create a cement mix that is
trucked offsite.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-A108850010-19 dated December
10, 2019
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Staker Parson Materials & Construction - Heber
Binggeli Pit
89 West 13490 South, Suite 100 Three miles south of Heber City
Draper, UT 84020 Charleston, UT
SIC Code: 1442: (Construction Sand & Gravel)
/ :
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Section I: GENERAL PROVISIONS
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]
Status: In Compliance. According to Staker & Parson, there has been no modifications to
the equipment or processes as approved by this AO and no breakdowns resulting in an
emissions event. Staker & Parson maintains records for at least two years. According to the
2020 Emissions Inventory Report, the emissions indicated compliance with the PTEs of this
AO.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Staker Parson Materials & Construction
II.A.2 Aggregate Plant
II.A.3 One (1) Jaw Crusher
Max capacity: 600 tons per hour (TPH)
NSPS applicability: Subpart OOO
II.A.4 Three (3) Cone Crushers
Max capacity: 600 TPH Each
NSPS applicability: Subpart OOO
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II.A.5 One (1) Vertical Shaft Impact Crusher
Max capacity: 600 TPH
NSPS applicability: Subpart OOO
II.A.6 Five (5) Triple Deck Screens**
Max capacity: 600 TPH Each
NSPS applicability: Subpart OOO
**Two (2) new screens
II.A.7 Two (2) Feeders*
Max capacity: 600 TPH Each
NSPS applicability: Subpart OOO
II.A.8 One (1) Grizzly Bar Feeder
II.A.9 One (1) Wash Plant
II.A.10 Associated Conveyors, Stackers, etc.
II.A.11 Concrete Plant
II.A.12 Central Mix Concrete Plant
Max capacity: 220 cubic yards/hour
Includes: Weigh hopper, central mix drum, and silos
II.A.13 One (1) Boiler*
Max rating: 9.9 MMBtu/hr
Fuel: Natural Gas
II.A.14 One (1) Dust Collector
Controls emissions from Central Mix Concrete Plant
II.A.15 One (1) Emergency Generator Engine
Max Rating: 320 kW
Fuel: Diesel
MACT applicability: Subpart ZZZZ
* Indicated new equipment
Status: In Compliance. There was a generator at the aggregate plant approved via temporary
relocate (DAQC-316-23). The generator operation hours from March 2023 to date, indicated
1,363 hours.
II.B Requirements and Limitations
II.B.1 Site-wide Requirement
II.B.1.a The owner/operator shall not produce more than the following:
A. 1,925,000 tons of processed aggregate per rolling 12-month period
B. 280,000 cubic yards of ready-mix concrete per rolling 12-month period. [R307-401-8]
Status: In Compliance. The rolling 12-month aggregate production from December 2022 to
November 2023, indicated 204,673 tons. The rolling 12-month ready-mix concrete
production from December 2022 to November 2023, indicated 77,921 cubic yards.
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months.
Records of production shall be kept for all periods when the plant is in operation. Production
shall be determined by belt scale records, scale house records, or bucket scale records. The
records of production shall be kept on a daily basis. [R307-401-8]
Status: In Compliance. Daily production records are determined from the scale house
records.
II.B.1.b Unless otherwise noted in this AO, the owner/operator shall not allow visible emissions to
exceed 20% opacity. [R307-401-8]
II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources
shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-205]
Status: In Compliance. There were no visible emissions observed during this inspection.
The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9.
See the attachment for additional information.
II.B.1.c The owner/operator shall not operate before 6:00 AM or after 6:00 PM during the months of
November, December, January, and February. The owner/operator may operate 24 hours per day
for all other months. [R307-401-8]
II.B.1.c.1 Hours of operation shall be determined by supervisor monitoring and maintaining of an
operations log. The hours of operation shall be kept on a daily basis and shall include the time
the aggregate processing plant starts operation and the time the aggregate processing plant ceases
operation during the months of November, December, January, and February. [R307-401-8]
Status: In Compliance. Staker & Parson is in compliance with this requirement. The log
book was reviewed onsite. The hours of operation are kept in a daily log to include the time
the plant starts operation and the time the aggregate plant ceases operation.
II.B.1.d The owner/operator shall not operate on-site dozers for more than 3,650 combined hours per
rolling-12 month period. [R307-401-8]
II.B.1.d.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months.
Records documents the use of each dozer shall be kept in a log and include the date and duration
each dozer was used. [R307-401-8]
Status: In Compliance. The rolling 12-month dozer hours from December 2022 to
November 2023, indicated 944 hours. A log was maintained to document the date and
duration of dozer operations.
II.B.2 Aggregate Processing Equipment
II.B.2.a The owner/operator shall ensure visible emissions for all crushers, screens, and conveyor transfer
points listed as new in this AO do not exceed the following:
A. Crushers - 12% opacity
B. Screens - 7% opacity
C. All Conveyor Transfer Points and Drops - 7% opacity.
[40 CFR 60 Subpart OOO, R307-401-8]
Status: In Compliance. The aggregate plant was in operation during this inspection. There
were no visible emissions observed from the crushers, screens, or conveyor transfer points
and drop points during this inspection. See the attachment for additional information.
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II.B.2.b The owner/operator shall install water sprays on all crushers, all screens, all conveyor transfer
points, and all conveyor drop points to control emissions. Sprays shall operate as required to
maintain the opacity limits listed in this AO when the temperature is above freezing. [40 CFR 60
Subpart OOO, R307-401-8]
Status: In Compliance. The crushers, screens, and conveyor transfer points and drop
points, were all equipped with spray bars to control emissions.
II.B.2.b.1 The owner/operator shall perform monthly periodic inspections to check that water is flowing
to discharge spray nozzles associated with each crusher, screen, and conveyor. If the
owner/operator finds that water is not flowing properly during an inspection of the water spray
nozzles, the owner/operator shall initiate corrective action within 24 hours and complete
corrective action as expediently as practical. [40 CFR 60 Subpart OOO, R307-401-8]
Status: In Compliance. Monthly inspections were conducted of the spray nozzles associated
with each crusher, screen, and conveyor to ensure the smooth flow of water to the
discharge spray nozzles. See the Dust Control Check sheets in the attachment for
additional information.
II.B.2.b.2 Records of the water sprays inspections shall be kept and maintained in a logbook for all periods
when the plant is in operation. The records shall include the following items:
A. Date the inspections were made
B. Any corrective actions taken
C. Control mechanism used if sprays are not operating. [40 CFR 60 Subpart OOO, R307-401-8]
Status: In Compliance. Monthly inspections were conducted of the spray nozzles associated
with each crusher, screen, and conveyor to ensure the smooth flow of water to the
discharge spray nozzles and maintained in a log book. See the Dust Control Check sheets in
the attachment for additional information.
II.B.2.c The owner/operator shall conduct an initial performance test for all crushers, screens, and
conveyor transfer points listed as new in this AO and subject to 40 CFR 60 Subpart OOO within
60 days after achieving the maximum production rate but not later than 180 days after initial
start-up. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO.
Records of initial performance tests shall be kept and maintained with the equipment for the life
of the equipment. [40 CFR 60 Subpart OOO]
II.B.2.c.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner/operator may use methods and procedures specified in 40 CFR
60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR
60.675(c). [40 CFR 60 Subpart OOO]
II.B.2.c.2 The owner/operator shall submit written reports to the Director of the results of all performance
tests conducted to demonstrate compliance with the standards set forth in 40 CFR 60.672. [40
CFR 60 Subpart OOO]
Status: In Compliance. According to DAQC-643-21, “In compliance. Binggeli performed
initial Subpart OOO visible emission observations on July 3, 2000 and in 2006, additional
NSPS reading were performed by JBR Environmental on November 10, and November 30,
2009, for various pieces of equipment. Staker Parson purchased the equipment from
Binggeli in October 2010.”
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II.B.3 Concrete Batch Plant
II.B.3.a The owner/operator shall not allow visible emissions from the concrete batch plant and the
associated equipment to exceed 10% opacity. [R307-401-8]
Status: In Compliance. The concrete batch plant was in operation during this inspection.
There were no visible emissions observed from the concrete batch plant and the associated
equipment to exceed 10 % opacity during this inspection
II.B.3.b The owner/operator shall control particulate emissions from all storage silos associated with the
concrete batch plant with a fabric filter, a baghouse, a bin vent, or a dust collector. [R307-401-8]
Status: In Compliance. The particulate emissions from all storage silos associated with the
concrete batch plant are controlled with a dust collector.
II.B.4 Emergency Generator Engine Requirements
II.B.4.a The owner/operator shall not operate the emergency generator engine on site for more than 100
hours per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ]
Status: Not Applicable. Although the 1991 400 hp Caterpillar Emergency Generator is still
onsite, it has not been operated now for a couple of years. Staker & Parson operates on line
power.
II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of the emergency engine shall be kept in a log and shall include the
following:
A. The date the emergency engine was used
B. The duration of operation in hours
C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]
Status: Not Applicable. Although the 1991 400 hp Caterpillar Emergency Generator is still
onsite, it has not been operated now for a couple of years. Staker & Parson operates on line
power. Therefore, the hours of operation in a rolling 12-month period is zero.
II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter on the emergency generator engine. [R307-401-8]
Status: In compliance. This 1991 400 hp Caterpillar Emergency Generator is still onsite,
and equipped with a non-resettable hour meter. This equipment has not been operated now
for a couple of years.
II.B.4.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the emergency engine. [R307-401-8]
Status: In Compliance. According to Pilot Thomas Logistics delivery document, the diesel
fuel is certified to be 15 parts per million. See the attachment for additional information.
II.B.4.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
Status: In Compliance. According to Pilot Thomas Logistics delivery document, the diesel
fuel is certified to be 15 parts per million. See the attachment for additional information.
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II.B.4.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]
Status: In Compliance. According to Pilot Thomas Logistics delivery document, the diesel
fuel is certified to be 15 parts per million. See the attachment for additional information.
II.B.5 Haul Roads and Fugitive Dust Emissions Requirements
II.B.5.a The owner/operator shall not exceed the following:
A. 3,700 feet of unpaved haul roads
B. 12.00 acres of storage piles
C. 22.00 acres of exposed area. [R307-401-8]
Status: In Compliance.
A. 2,845 feet of unpaved haul roads
B. 5.00 acres of storage piles
C. 20.2 acres of exposed area
II.B.5.a.1 Compliance shall be determined through Global Positioning System (GPS) measurements or
aerial photographs. Reclaimed areas such as those with emerged vegetation or hydro-seeded
do not contribute to the acreage totals. [R307-401-8]
Status: In Compliance. See the GPS measurements in the attachment for additional
information.
II.B.5.b The owner/operator shall not allow visible emissions from all fugitive dust sources, including
haul roads, to exceed 20% opacity. [R307-309-5]
Status: In Compliance. There were no visible emissions observed from the haul roads
during this inspection. See pictures of the haul roads in the attachment.
II.B.5.b.1 Visible emission determinations for fugitive dust from haul roads and operational areas shall
use procedures similar to Method 9. The normal requirement for observations to be made at
15-second intervals over a six (6)-minute period, however, shall not apply. Visible emissions
shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle
length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5]
Status: In Compliance. There were no visible emissions observed from the haul roads and
operational areas during this inspection. See pictures of the haul roads in the attachment.
II.B.5.c The owner/operator shall sweep and apply water to the on-site paved roads as necessary to
maintain the listed opacity requirements. [R307-401-8]
Status: In Compliance. Staker & Parson maintain records of water application on the
paved roads to control dust and visible emissions. See the water application records in the
attachment.
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II.B.5.d The owner/operator shall use a chemical suppressant and water application on unpaved haul
roads to maintain the opacity limits listed in this AO. [R307-401-8]
Status: In Compliance. Staker & Parson maintain records of water application on unpaved
haul roads to control dust and visible emissions. See the water application records in the
attachment.
II.B.5.d.1 Records of treatments to haul roads shall include:
A. The date, time, and location of applications
B. The volume of chemical suppressant applied (as applicable)
C. The volume of water applied. [R307-401-8]
Status: In Compliance. The records of water treatments to the haul roads include the date,
time, location, and volume of water applied. See the attachment for additional information.
II.B.5.d.2 Records of haul road treatments shall be kept for all periods when the plant is in operation.
[R307-401-8]
Status: In Compliance. Staker & Parson maintains records of water treatments to the haul
roads including the date, time, location, and volume of water applied. See the attachment
for additional information.
Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
Status: In Compliance. According to DAQC-643-21, “In compliance. Binggeli performed initial
Subpart OOO visible emission observations on July 3, 2000 and in 2006, additional NSPS reading
were performed by JBR Environmental on November 10, and November 30, 2009, for various
pieces of equipment. Staker Parson purchased the equipment from Binggeli in October 2010.”
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Status: Not Applicable. Although the 1991 400 hp Caterpillar Emergency Generator is still onsite, it
has not been operated now for a couple of years.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
R307-203. Emission Standards: Sulfur Content of Fuels
In Compliance. According to Pilot Thomas Logistics delivery document, the diesel fuel is certified
to be 15 parts per million. See the attachment for additional information.
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UAC R307-305 Nonattainment and Maintenance Areas for PM10: Emission Standards
In Compliance. There were no visible emissions observed during this inspection. The opacity
observations were conducted according to 40 CFR 60, Appendix A, Method 9. See the attachment
for additional information
EMISSION INVENTORY:
Listed before are the Actual Emissions Inventory provided from Staker Parson Materials & Construction -
Heber Binggeli Pit. A comparison of the estimated total potential emissions (PTE) on Approval Order
(AO) DAQE-AN108850010-19 dated December 10, 2019 and the actual emissions according to the 2020
Emissions Inventory Report is indicated below: PTE are supplied for supplemental purposes only.
Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 5126.00 ----
Carbon Monoxide 3.71 0.892
Nitrogen Oxides 4.92 0.892
Particulate Matter - PM10 21.33 14.01
Particulate Matter - PM2.5 3.28 3.25
Sulfur Dioxide 0.07 0.003
Volatile Organic Compounds 0.29 0.036
Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Formaldehyde (CAS #50000) 7
Hexane (CAS #110543) 152
Status: In Compliance. According to the 2020 Emissions Inventory Report, the emissions indicated
compliance with the PTEs of this AO.
PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: Staker & Parson is in compliance with the conditions in the
Approval Order (AO) DAQE-AN108850010-19 dated December
10, 2019. Staker & Parsons demonstrated good housekeeping
practices.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Required PPE includes steel-toe boots, hard hat,
protective glasses, and reflective vest.
NSR RECOMMENDATIONS: None at this time.
ATTACHMENTS: Applicable Supporting Documentation Included