DAQ-2024-004609

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DAQC-CI109780001-23
Site ID 10978 (B1)

MEMORANDUM

TO: FILE – WEST SIDE GRADING INCORPORATED – Standard Pugmill Asphalt
Batch Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: November 14, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Millard County

INSPECTION DATE: July 12, 2023

SOURCE LOCATION: 1530 East Main Street
Delta, UT 84624
DIRECTIONS: East side of town, on the south side of Main Street.

SOURCE CONTACTS: Pam Smith, Owner
[e-mail]

Merlin Enis, Plant Manager

OPERATING STATUS: The asphalt plant is temporarily shut down, and had not operated
in over a year. The source was operating an unapproved concrete
batch plant.

PROCESS DESCRIPTION: West Side Grading owns and operates a standard pugmill asphalt
batch plant. The plant consists of a drum aggregate dryer, fueled
by No. 2 burner oil, and a pugmill for mixing the hot aggregate
with asphaltic cement. Exhaust gases and dust from the pugmill
and dryer pas through a dry dust collector. Fines collected are
routed back to the dryer. Exhaust gases then pass through a
multiple stage wet collector before being emitted to the
atmosphere.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN109780002-22, dated August 4,
2022
SOURCE EVALUATION:

Name of Permittee: Permitted Location:

West Side Grading Incorporated - Standard
Pugmill Asphalt Batch Plant

P.O. Box 549 1530 East Main Street
Delta, UT 84624 Delta, UT 84624

SIC Code: 2951: (Asphalt Paving Mixtures & Blocks)

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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]

Status: Out of Compliance. The source had unapproved equipment on site. See condition
II.A. Records were not current. No limits appear to have been exceeded. No reportable
breakdowns have occurred. The source is not required to submit an emission inventory at
this time.

Section II: SPECIAL PROVISIONS

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

II.A.1 Standard Pugmill Asphalt Plant

II.A.2 One (1) Pugmill Asphalt Plant
Capacity: 125 tons/hr
Control: Multi-stage Wet Scrubber
Manufactured prior to 1969

II.A.3 One (1) Engine Generator
Electrical Output: 500 kW
Fuel: #2 Fuel Oil
Manufactured prior to 1969

II.A.4 Miscellaneous Equipment
Various Front-end Loaders, Haul Trucks

Status: Out of Compliance. The source had an unapproved concrete batch plant in
operation and a second concrete batch plant which had not yet been installed.
The source is run solely on line power, the generator is no longer in use.

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II.B Requirements and Limitations

II.B.1.a The owner/operator shall keep a copy of this AO shall be posted on site. The AO shall be
available to the employees who operate the air emission producing equipment. These employees
shall receive proper instruction as to their responsibilities in operating the equipment according
to all of the relevant conditions listed below. [R307-401-8]

Status: Not Observed. This was not asked for at the time of inspection. However, the owner
does have a copy of the AO in their possession which they referenced in conversation with
the inspector.

II.B.1.b The owner/operator shall not exceed the following opacity limits for the indicated emission units.

A. All crushers - 15% opacity

B. All screens - 10% opacity

C. All conveyor transfer points - 10% opacity

D. All diesel engines - 20% opacity

E. Conveyor drop points - 20% opacity

F: Haul road traffic - 20% opacity

G. All other points - 20% opacity. [R307-401-8]

II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b.2 Opacity observations of emissions from mobile sources and intermittent sources shall use
procedures similar to Method 9, but the requirement for observations to be made at 15-second
intervals over a six- minute period shall not apply. Any time interval with no visible emissions
shall not be included. [R307-401-8]

II.B.1.b.3 Opacity observations of emissions for traffic sources shall use procedures similar to Method 9,
but the requirement for observations to be made at 15-second intervals over a six-minute period
shall not apply. Six points, distributed along the length of the haul road, shall be chosen by the
Director or Director's representative. An opacity reading shall be made at each point when a
vehicle passes the selected points. Opacity readings shall be made not less than one-half the
vehicle length behind the vehicle. The accumulated six readings shall be averaged for the
compliance value. [R307-401-8]

Status: In Compliance. All opacity observations during the inspection were within the
allowed limits.

II.B.1.c The owner/operator shall not produce more than the following:

A. 30,000 tons of asphaltic concrete per rolling 12-month period

B. 125 tons of asphaltic concrete per hour. [R307-401-8]

II.B.1.c.1 The owner/operator shall:

A. Determine production by plant weigh scale records

B. Record production on a daily basis

C. Use the production data to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months

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D. Keep the production records for all periods the plant is in operation. [R307-401-8]

Status: Not Observed. The asphalt plant had not operated in the last 12-months, so there
were no production records.

II.B.1.d The owner/operator shall not produce asphaltic concrete for more than 10 hours per day.
[R307-401-8]

II.B.1.d.1 Hours of operation shall be determined by supervisor monitoring and maintaining an operations
log or an operations totalizer meter. [R307-401-8]

Status: Not Applicable. The asphalt plant had not operated in the last 12-months.

II.B.2 Asphalt Plant Exhaust Stack Requirements

II.B.2.a Emissions to the atmosphere from the asphalt plant shall not exceed the following rates and
concentrations:

Pollutant lb/hr grain/dscf
PM10 3.17 0.03

[R307-401-8]

II.B.2.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-401-8]

II.B.2.a.2 Test Frequency
The owner/operator shall conduct a stack test on the emission unit within five (5) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-401-8]

II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.2.b.1 Notification
At least 45 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in R307-165-
3. If directed by the Director, the owner/operator shall attend a pretest conference.

Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4.

Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.

Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6.

New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the production rate listed in this AO.

Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall be
no less than 90% of the maximum production achieved in the previous three (3) years.
[R307-401-8]
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II.B.2.c Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.2.c.1 Standard Conditions
A. Temperature - 68 degrees Fahrenheit (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)
C. Averaging Time - As specified in the applicable test method

PM10
For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 60,
Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-
approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops should be
explored. If no reasonable method to eliminate the drops exists, then the following methods shall
be used: 40 CFR 51, Appendix M, Method 202; 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5e;
or other EPA-approved testing method as acceptable to the Director.

The back half condensibles shall also be tested using the method specified by the Director or
Director's representative.

All particulate captured shall be considered PM10. The back half condensibles shall not be used
for compliance demonstration but shall be used for inventory purposes.

Sample Location
40 CFR 60. Appendix A, Method 1

Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2

Calculations
To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director to give the results in the specified units of the
emission limitation. [R307-401-8]

Status: Out of Compliance. The source was unable to supply any stack test documentation.

II.B.3 Scrubber Requirements

II.B.3.a The owner/operator shall maintain the following operating parameters within the indicated
ranges for the scrubber system:

A. The pressure drop shall not be less than 15 inches of water gauge (minimum) for more
than five minutes in any 60-minute period.

B. The water pump pressure shall be no less than 50 psig for more than five minutes in
any 60-minute period at any time during the aggregate dryer operation.

Items A and B of this section shall be monitored with equipment located such that an
inspector/operator can safely read the output anytime. The readings shall be accurate to within
the following ranges:

A. Venturi throat pressure drop: plus or minus 1 inch of water column

B. Water pump pressure: plus or minus 1 psi

The venturi throat pressure drop and water pump pressure shall be recorded once each day that
the plant is in operation. [R307-401-8]
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II.B.3.a.1 The owner/operator shall install, calibrate, maintain, and operate each monitoring device certified
by the manufacturer for the continuous measurement of the scrubbing liquid flow rate to the
venturi scrubber. The monitoring device must be certified by the manufacturer to be accurate
within plus or minus 5% of the design scrubbing liquid flow rate and must be calibrated on an
annual basis in accordance with manufacturer's instructions. The scrubbing liquid flow rate to the
scrubber shall be recorded at the time of the compliance stack test and shall be maintained as the
minimum flow rate during asphalt production. [R307-401-8]

II.B.3.a.2 The owner/operator shall install, calibrate, maintain, and operate each monitoring device certified
by the manufacturer for the continuous measurement of the change in pressure of the gas stream
through the venturi scrubber. The monitoring device must be certified by the manufacturer to be
accurate within plus or minus one (1) inch of water gauge pressure and must be calibrated on an
annual basis in accordance with manufacturer's instructions. The pressure drop across the venturi
shall be recorded at the time of the compliance stack test and shall be maintained as the
minimum pressure during asphalt production. [R307-401-8]

Status: Out of compliance. The asphalt plant has not operated in the last 12-months due to
disrepair. Therefore, the scrubber has not been in operation.

II.B.4 Roads and Fugitive Dust Requirement

II.B.4.a The owner/operator shall use water application and/or chemical suppressants for all unpaved haul
roads and wheeled-vehicle operational areas to maintain opacity limits listed in this AO. If
chemical treatment is to be used, the plan must be approved by the Director. [R307-401-8]

II.B.4.a.1 Records of chemical suppressant and 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, and the approximate amount. [R307-401-8]

Status: Out of compliance. No records were provided at the time of inspection. The source
had a water truck on site and opacity readings were within the allowed limit.

II.B.4.b The owner/operator shall install water sprays or chemical dust suppression sprays on all
conveyor transfer points on site to control emissions. Water sprays shall operate as necessary to
prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8]

Status: Not Observed. The asphalt plant had not operated in the last 12-months.

II.B.4.c The owner/operator shall not exceed 0.3 miles of haul road. The owner/operator shall not exceed
a speed limit of 20 miles per hour. [R307-401-8]

Status: In Compliance. The haul road appeared to be within the set parameters and the
speed was posted.

II.B.4.d The owner/operator shall water all storage piles on site to prevent visible emissions from
exceeding the opacity limits listed in this AO, as dry conditions warrant. [R307-401-8]

Status: Not Observed. Opacity limits were within set limits.

II.B.5 Fuel Requirements

II.B.5.a The owner/operator shall use only #2 fuel oil as a primary fuel and natural gas as a backup fuel
in the asphalt batch plant aggregate dryer. [R307-401-8]

Status: Not Observed. The asphalt plant has not operated in the last 12-months.

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II.B.5.b The owner/operator shall only combust fuel oil or diesel that has a maximum sulfur content of
0.5 percent by weight. [R307-401-8]

II.B.5.b.1 The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
[R307-401-8]

Status: Not Observed. The asphalt plant has not operated in the last 12-months.

II.B.6 Construction Requirements

II.B.6.a The owner/operator shall construct and maintain the settling ponds for the scrubbing liquor
according to the following parameters:

A. The residence time for settling shall be no less than 4 hours. This means that for a
liquid flow rate of 150 gallons per minute (gpm), the pond should hold at least 36,000
gallons (approximately 200 cubic yards).

B. In order to prevent short circuiting of the water flow through the pond, the pond shall
be divided into three sections separated by two weirs. The third section can be the
return sump. Baffles may also need to be installed to trap any oil floating on the
surface of the pond which might foul the scrubber system.

C. As a rule of thumb, the primary section of the pond should be at least six feet deep.
The overall length of the pond should be at least two times the width. [R307-401-8]

Status: Not Observed. The asphalt plant has not operated in the last 12-months.
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.

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

Status: Not Applicable. The source operates on line power, the generator is no longer used.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

R307-205. Fugitive Emissions. Fugitive Dust.

Status: In compliance. Observed emissions were within set limits.

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EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from West Side Grading
Incorporated - Standard Pugmill Asphalt Batch Plant on the Approval Order (AO)
DAQE-AN109780002-22, dated August 4, 2022. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 8288.00
Carbon Monoxide 3.81
Nitrogen Oxides 13.34
Particulate Matter - PM10 3.17
Particulate Matter - PM2.5 3.17
Sulfur Dioxide 8.31
Volatile Organic Compounds 1.43

Hazardous Air Pollutant PTE lbs/yr
Generic HAPs (CAS #GHAPS) 1100

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN109780002-22,
dated August 4, 2022: Out of compliance with condition I.3 for
operating an unapproved concrete batch plant, condition
II.B.2.a.2 for failing to stack test the asphalt plant exhaust stack,
and II.B.4.a.1 for failing to maintain water records. This was the
initial compliance inspection for this source. The initial AO was
issued July 7, 1997 (DAQE-613-97). A Compliance Advisory
was issued August 2, 2023 (DAQC-730-23). A Warning was
issued October 27, 2023 (DAQC-1151-23).

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: The source was in the process of selling the operating concrete
batch plant and a second concrete batch plant that was on site but
not installed. Verify that this sale was finalized and that the
equipment is no longer on site. The source also needs to conduct
a stack test of the asphalt plant exhaust stack within 180 days of
startup when the asphalt plant comes back into repair. Verify that
watering records are being kept.

NSR RECOMMENDATIONS: Verify the equipment on site is consistent with the equipment
list.

ATTACHMENTS: Emails, CA Response.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-1151-23
Site ID 10978 (B1)

Sent Via Certified Mail No. 70190700000208346085

Pam Smith
West Side Grading Incorporated
P.O. Box 549
Delta, Utah 84624

Dear Ms. Smith:

Re: Warning Letter – West Side Grading Incorporated, Utah Administrative Code (UAC)
R307-401, Approval Order (AO) DAQE-AN109780002-22, Millard County

On July 12, 2023, the Utah Division of Air Quality (DAQ) conducted an inspection of West Side
Grading Incorporated, located at 1500 East 100 South, Delta, Utah. The DAQ believes that West
Side Grading Inc. was in violation of:

1. UAC R307-401-5. Notice of Intent and DAQE-AN109780002-22 condition I.3 for adding
emission producing equipment (Concrete Batch Plant) without prior approval and without
submitting a Notice of Intent.

2. DAQE-AN109780002-22 condition II.B.2.a.2 for failing to stack test the asphalt plant
exhaust stack.

Please be aware this letter is a warning and that future instances of noncompliance may be
considered violations of UAC R307-401 and AO DAQE-AN109780002-22 and West Side
Grading Inc. may be assessed penalties up to $10,000 per day if found to be in violation of Utah
Air Quality Rules. If the sale of the two concrete batch plants is not finalized, a Notice of Intent
must be submitted to the DAQ to add the equipment to West Side Gradings Inc.’s AO if they will
continue to be used on-site. When the asphalt plant is brought back online, a stack test must be
conducted within 180 days of start-up to be in compliance with condition II.B.2.a.2 of the AO.
The DAQ retains its authority to take subsequent enforcement action if during the next inspection
the DAQ finds the source is still not in compliance with R307-401-5.

1 , " / Û à Û Ù Û Ü
DAQC-1151-23
Page 2

A response to this letter is not required. If you have any questions regarding this letter, please
contact Chad Gilgen at 385-306-6500 or at [e-mail].

Sincerely,

Bryce C. Bird
Director

BCB:CG:rh

cc: Central Utah Public Health Department
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