DAQ-2024-004557

1
DAQC-CI106170001-23
Site ID 10617 (B1)
MEMORANDUM

TO: FILE – HOLLIDAY CONSTRUCTION INCORPORATED – Bluff Pit

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: October 31, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, San Juan County

INSPECTION DATE: June 5, 2023

SOURCE LOCATION/ 4 miles west of Bluff at the intersection of U.S. Routes 163 and
DIRECTIONS: 191, San Juan County, Utah

SOURCE CONTACTS: Jason Holliday, Owner
435-979-5351 [e-mail]

Clara H, Secretary
435-678-2028 [e-mail]

OPERATING STATUS: Not operating at the time of inspection. Work is done at this site
infrequently.

PROCESS DESCRIPTION: Holliday Construction owns an aggregate processing pit near
Bluff. Raw aggregate material mined from the walls of the
quarry is fed into the crusher/screening circuit where it is
separated according to size class. Material that is too large to
pass through the screen is crushed in a crusher and re-routed
through the screens. Separated aggregate is conveyed to various
storage piles by stacking conveyors. A water truck is used to
control dust in the yard and operational areas, and water sprays
are used to control dust in the crusher/screening circuit. The
aggregate operation is powered by a 400 kW diesel generator
with an Oxy Catalyst. A wash plant is also present onsite. The
wash plant and water pump were powered by a 180 kW diesel
generator, which is no longer operational.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN106170002-15, dated
November 5, 2015
NSPS (Part 60) IIII : Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
NSPS (Part 60) -OOO : Standards of Performance for Nonmetallic
Mineral Processing Plants,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Holliday Construction Incorporated
Bluff Pit
PO Box 713
Monticello, UT 84535

4 miles west of Bluff at the intersection of U.S.
Routes 163 and 191
San Juan County, Utah
SIC Code: 1442: (Construction Sand & Gravel)

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]

Status: Out of Compliance. Unpermitted equipment was present on-site at the time of
inspection. See Section II for more details. No breakdowns that would have affected
emissions have occurred since the last inspection. An emissions inventory for 2020 has been
submitted.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Bluff Pit

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II.A.2 One (1) Feeder/Jaw Crusher
Capacity: 400 tph
Manufacture Date: 2001

II.A.3 Two (2) Cone Crushers
Size: 54" and 45"

II.A.4 One (1) Triple-Deck Screen
Size: 6' x 20'
Manufacture Date: 1994

II.A.5 One (1) Triple-Deck Screen
Size: 4' x 14'

II.A.6 Various Conveyors

II.A.7 One (1) 400 kW Generator
Fuel: Diesel Fuel

II.A.8 One (1) Wash Plant Generator
Rating: 270 hp
Fuel: Diesel
Manufacture Date: 1974

II.A.9 Wash Plant
*Listed for Informational Purposes Only*

Status: Out of Compliance. A mobile concrete batch plant and associated 400 hp generator
were on site. A Compliance Advisory was issued on June 22, 2023 (see DAQC-626-23). An
initial response was received on August 21, 2023. The source decided to remove the
unpermitted equipment, and notification of that removal was received on September 28, 2023.
A warning letter was issued on October 27, 2023 (see DAQC-1153-23). No further action is
recommended at this time. The 270 hp wash plant generator in II.A.8 is no longer operational,
and the source intends to replace it. They were advised to submit an NOI prior to installing a
new generator.

II.B Requirements and Limitations

II.B.1 Site Wide Requirements

II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any source on site to exceed 20 percent opacity. [R307-201-3]

II.B.1.a.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. [R307-201-3]

Status: In Compliance. The equipment was not operating during the inspection; however,
no opacity was observed during the inspection from haul roads or other fugitive dust
sources.
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II.B.2 Aggregate Processing Requirements

II.B.2.a The owner/operator shall not produce more than 100,000 tons of aggregate material, including
bank-run material, per rolling 12-month period. [R307-401-8]

II.B.2.a.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 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]

II.B.2.a.2 The owner/operator shall weigh and account for all aggregate material prior to the aggregate
material leaving the site or being used in another process on site. [R307-401-8]

Status: In Compliance. For the rolling 12-month period from May 2022 - April 2023, a
total of 27,608.38 tons of aggregate material was produced.

II.B.2.b The owner/operator shall not allow visible emissions from any crusher on site to exceed 15
percent opacity. [40 CFR 60 Subpart OOO]

Status: Not Observed. The crusher was not operating during the inspection.

II.B.2.c The owner/operator shall not allow visible emissions from any screen on site to exceed 10
percent opacity. [40 CFR 60 Subpart OOO]

Status: Not Observed. No screens were operating during the inspection.

II.B.2.d The owner/operator shall not allow visible emissions from any conveyor transfer point on site to
exceed 10 percent opacity. [40 CFR 60 Subpart OOO]

Status: Not Observed. No conveyors were operating during the inspection.

II.B.2.e The owner/operator shall not allow visible emissions from any conveyor drop point on site to
exceed 20 percent opacity. [R307-205-4]

Status: Not Observed. No conveyors were operating during the inspection.

II.B.2.f The owner/operator shall install water sprays on all crushers, all screens, and all unenclosed
conveyor transfer points on site to control fugitive emissions. Sprays shall operate as required to
maintain the opacity limits listed in this AO. [R307-401-8]

Status: In Compliance. Water sprays have been installed as required.

II.B.2.g Within 60 days after achieving the maximum production rate but not later than 180 days after
initial startup, the owner/operator shall conduct an initial performance test for all crushers,
screens, and conveyor transfer points on site manufactured after August 31, 1983. Performance
tests shall meet the limitations specified in Table 3 to Subpart OOO. Records of initial
performance tests shall be kept and maintained on site for the life of the equipment. [40 CFR 60
Subpart OOO]

II.B.2.g.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner or 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]

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II.B.2.g.2 The owner/operator shall submit written reports to the Executive Secretary 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. Holliday Construction conducted the initial VEOs for the existing
associated wash plant equipment that included conveyors and the two screens on January
31, 2012. Copies of the observation were submitted to the DAQ on February 1, 2012, and
are present in the DAQ files (see DAQC-149-12).

II.B.3 Engine Requirements

II.B.3.a The 400 kW diesel generator shall not exceed 2,400 hours of operation per rolling 12-month
period. [R307-401-8]

Status: In Compliance. For the rolling 12-month period from May 2022 - April 2023, the
generator was used for a total of 110 hours.

II.B.3.a.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.
Hours of operation shall be determined by supervisor monitoring and maintaining of an
operations log. [R307-401-8]

Status: In Compliance. The 400 kW generator operated for 100 hours from March 2021 to
February 2022. See attached records.

II.B.3.b The wash plant diesel generator shall not exceed 500 hours of operation per rolling 12-month
period. [R307-401-8]

II.B.3.b.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.
Hours of operation shall be determined by supervisor monitoring and maintaining of an
operations log. [R307-401-8]

Status: In Compliance. The wash plant generator is not currently in operation, and was
used for 0 hours from May 2022 - April 2023.

II.B.3.c The owner/operator shall not allow visible emissions from any stationary diesel engine on site to
exceed 20 percent opacity. [R307-201-3]

Status: Not Observed. The source was not operating.

II.B.3.d The sulfur content of diesel fuel burned in the stationary diesel engines on site shall not exceed
15 ppm by weight. [40 CFR 63 Subpart ZZZZ]

II.B.3.d.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of diesel fuel shall be either by the owner/operator's own testing or by
test reports from the diesel fuel marketer. [R307-203-1]

Status: In Compliance. The source uses ultra-low sulfur diesel in the generator. A fuel
invoice was observed at the time of inspection.

II.B.4 Haul Road and Fugitive Dust Requirements

II.B.4.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources
on site to exceed 20 percent opacity at all times. [R307-205-4]

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II.B.4.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile
equipment in operational areas shall use procedures similar to Method 9. The normal
requirement for observations to be made at 15-second intervals over a six-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. [R307-205-4]

Status: In Compliance. No fugitive dust was observed during the inspection. The source
has a water truck on site and waters as needed to keep the dust maintained.

II.B.4.b The haul road shall be no greater than 2,640 feet in length. [R307-401-8]

Status: In Compliance. The source is located directly off highway 191. The haul road
appeared less than 2,640 feet.

II.B.4.c The owner/operator shall use water application on all haul roads, storage piles, and operational
areas to maintain opacity limits listed in this AO. The owner/operator may stop applying water
to the haul roads, storage piles, and operational areas when the temperature is below freezing.
[R307-401-8]

II.B.4.c.1 Records of water application shall be kept for all periods when the plant is in operation. The
records shall include the following items:

A. Date and time treatments were made
B. Number of treatments made and quantity of water applied
C. Rainfall amount received, if any
D. Records of temperature, if the temperature is below freezing.

[R307-401-8]

Status: In Compliance. The source maintains records of watering the operations and haul
road.

II.B.4.d All bulldozers on site shall not operate more than 40 hours combined per rolling 12-month
period. [R307-401-8]

II.B.4.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.
Hours of operation shall be determined by supervisor monitoring and maintaining of an
operations log. The records of operation shall be kept on a daily basis. [R307-401-8]

Status: In Compliance. For the rolling 12-month period from May 2022 - April 2023, the
bulldozer operated for 30 hours.

II.B.4.e The owner/operator shall control disturbed or stripped areas at all times (24 hours per day, every
day) for the duration of the project/operation until the area is reclaimed. Records of reclamation
shall be kept for all periods when the plant is in operation. [R307-401-8]

Status: In Compliance. No visible emissions were observed from the storage piles or pit
banks.

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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) IIII : Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: Not Applicable. The generators on the AO were installed prior to 2006. The generator that was
connected to the portable concrete batch plant is no longer operational and has been removed from the
facility.

NSPS (Part 60) -OOO : Standards of Performance for Nonmetallic Mineral Processing Plants

Status: In Compliance. This subpart applies to the permitted crushers and screens. This source has
conducted initial observations (January 2011) in accordance with the 40 CFR Subpart OOO Method 9
for the crusher and screen. The facility was not operating and no opacity was observed during the
inspection.

MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: Out of Compliance. The source did not retest the 400 kW generator in 2020. This generator is
required to be retested every 8,760 hours or 3 years (Table 3), whichever comes first. It was last tested
in 2017. A Compliance Advisory was sent on April 20, 2022, addressing the unpermitted equipment.
See DAQC-485-22. A response was received on May 3, 2022, stating that they will stack test the 400 kW
generator in August. A pre-test protocol was received on April 11, 2023, to stack test the generator. See
DAQC-395-23. Stack testing is scheduled for November 13, 2023. The 270 hp generator is no longer
operational.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]

Status: In Compliance. Ultra-low sulfur fuel is utilized at this source. A fuel invoice was observed at
the time of inspection.

Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

Status: In Compliance. No fugitive emissions were observed at the time of inspection. The source
has a water truck on site and waters as needed to keep the dust maintained

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EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Holliday Construction Incorporated -
Bluff Pit. A comparison of the estimated total potential emissions (PTE) on AO DAQE-AN106170002-
15, dated November 5, 2015. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Carbon Monoxide 4.75 1.483
Nitrogen Oxides 22.07 0.562
Particulate Matter - PM10 5.64 3.95977
Particulate Matter - PM2.5 2.10 1.33838
Sulfur Dioxide 1.46 0.453
Volatile Organic Compounds 1.65 0.562

PREVIOUS ENFORCEMENT
ACTIONS: A Compliance Advisory was sent on April 20, 2022, addressing
the unpermitted equipment. See DAQC-485-22. A response
was received on May 3, 2022, stating that they will stack test the
400-kW generator in August, 2022. An ESA was signed on
September 28, 2022. See DAQC-1294-22. A pre-test protocol
was received on April 11, 2023, to stack test the generator. See
DAQC-395-23. Stack testing is scheduled for November 13,
2023.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN106170002-15,
dated November 5, 2015: The source was out of compliance with
condition I.3 for installing unpermitted equipment. A
Compliance Advisory was issued on June 22, 2023 (see DAQC-
626-23). An initial response was received on August 21, 2023.
The source decided to remove the unpermitted equipment, and
notification of that removal was received on September 28, 2023.
A warning letter was issued on October 27, 2023 (see DAQC-
1153-23). No further action is recommended at this time.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Verify that the 400-kW generator in condition II.A.7 has been
stack tested. Verify that no unpermitted generators are on site.
Verify that the concrete batch plant has been removed.

ATTACHMENTS: VEO form, email correspondence, response to CA
10/31/23, 11:23 AM State of Utah Mail - 400 kw hours of operation
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-9099361129803746260&simpl=msg-a:r-5880322410658…1/2
Daniel Riddle <[e-mail]>
400 kw hours of operation
2 messages
Daniel Riddle <[e-mail]>Tue, Oct 3, 2023 at 11:14 AM
To: Holliday Construction Inc <[e-mail]>
Clara,
How many hours was the 400 kW diesel generator operated between May 2022 and April 2023?
Thanks,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Holliday Construction Inc <[e-mail]>Wed, Oct 4, 2023 at 12:28 PM
To: Daniel Riddle <[e-mail]>
110 hours between those dates.

From: Daniel Riddle [mailto:[e-mail]]
Sent: Tuesday, October 3, 2023 11:15 AM
To: Holliday Construcon Inc <[e-mail]>
Subject: 400 kw hours of operaon

Clara,

How many hours was the 400 kW diesel generator operated between May 2022 and April 2023?

Thanks,
Daniel

--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: (385) 222-
1357
10/31/23, 11:23 AM State of Utah Mail - 400 kw hours of operation
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-9099361129803746260&simpl=msg-a:r-5880322410658…2/2
airquality.utah.gov

August 3O,2O23
RE: Compliance Advisory DAQC-879-23
Chad Gilgeh
TO WHOM IT MAY CONCERN:
Chad, l'm writing this letter to let you know about the stack testing on the 400 KW generator engine. We
have contacted Alliance to reschedule stack test, and the soonest availability is November L3,2023.|f
anything opens up before that date they will let us know as soon as possible. I will call Shamit and let
him know to give the 30 day protocol. The crusher broke down and we could not get anyone down to
see what the matter was to get it fixed, all mechanics were booked out finally got one to come they had
to get parts for it and could not get the parts and finally were able to find the part. So it looks like the
crusher is running and will be able to get that test down.
Please let me know if there is anything else I need to do.
Sincerely,
REVIH,WED
Inrtials: iG-'^"' 1 4 4^a)
)dgon Conrpliarice
Jason Holliday, President
HOLLIDAY CONSTRUCTION, I NC
P.O. BOX 502
BLANDING, UTAH 84511
r_t4I llett
UTAH DEPARTMENT OF
ENVIRONMENTAL OUALITY
sEP - 1 2023
DIVISION OF AIR QUALITY