HomeMy WebLinkAboutDAQ-2024-0051431
DAQC-1072-23
Site ID 12058 (B1)
MEMORANDUM
TO: FILE – HARPER CONTRACTING, INC. – Pit #16, Parley's Canyon Aggregate
Facility
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Irene Tucker, Environmental Scientist
DATE: February 29, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County
INSPECTION DATE: August 16, 2023
SOURCE LOCATION: 1.25 miles east of mouth of Parley's Canyon
Salt Lake City, UT
Take I-80 exit 131.
SOURCE CONTACTS: Tyler Hodson, Environmental Compliance Coordinator,
385-228-3653, Tyler.hodson@kilgorecompanies.com
Lee Ware, Environmental Director
801-250-0132, 801-831-7402, lee.ware@kilgorecompanies.com
OPERATING STATUS: Operating normally at time of inspection.
PROCESS DESCRIPTION: Sand and gravel processing pit. All equipment is now connected
to electrical power and no longer requires the use of diesel
powered generators. The material for the crushing/screening
circuit is provided by dozer push offs of material generated
through blasting and drilling on the far-east side of the site from
the mountain face. Once the material has been processed it is
trucked off-site.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN0120580008-10, dated June 9,
2010
NSPS (Part 60), OOO: Standards of Performance for
Nonmetallic Mineral Processing Plants
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Harper Contracting, Inc.- Pit #16, Parley's Canyon Aggregate Facility
8201 West 5400 South 1.25 miles east of mouth of
PO Box 18549 Salt Lake City, UT 84118 Parley’s Canyon
Salt Lake City, UT
SIC Code: 1442 (Construction Sand & Gravel)
/ :
2
Section I: GENERAL PROVISIONS
I.1
Status:
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]
This is not a compliance issue.
I.2
Status:
The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
In compliance. Kilgore did not exceed any limits set forth in this AO.
I.3
Status:
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]
In compliance. Kilgore has not made any modifications to the equipment or processes
approved by this AO.
I.4
Status:
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 Executive Secretary or Executive Secretary'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 five (5) years. [R307-401-8]
In compliance. Kilgore plans to keep records for a minimum of five years.
I.5
Status:
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]
In compliance. Kilgore maintains records of maintenance activities performed on
equipment authorized by this AO.
I.6
Status:
The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
In compliance. Kilgore has not experienced any breakdowns that resulted in an emissions
event.
I.7
Status:
The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]
In compliance. According to the 2022 Emissions Inventory Report, the emissions indicate
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 Pit #16
II.A.2 Three (3) Jaw Crushers
Rating: 250 tph each
3
II.A.3 Four (4) Cone Crushers/Impactors
Rating: 250 tph each
II.A.4 Five (5) Triple Deck Screens
Rating: 250 tph each
II.A.5 One (1) Screen Plant
Rating: 250 tph each
II.A.6 Generator Sets and/or Screen Plant Engines
Any combination of diesel-fired generator sets and/or screen plant engines with total power
capacity not to exceed 600 kW.
II.A.7 Associated Stackers, Conveyors, etc.
The total number of transfer points shall not exceed 50.
II.A.8
Status:
Associated Loaders, Dozers, Scrapers, etc.
In compliance. There was no new or unapproved equipment observed onsite. AO Condition
II.A.6 is no longer onsite. Kilgore uses line power now with the generators no longer onsite.
II.B Requirements and Limitations
II.B.1 Pit #16 - Parley's Canyon Aggregate Facility shall be subject to the following:
II.B.1.a The following production limits shall not be exceeded:
A. 2,500,000 tons of processed aggregate material per rolling 12-month period.
B. 3,744 hours of operation for all diesel-fired generators combined per rolling 12-month
period. [R307-401-8]
II.B.1.a.1
Status:
To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the 25th 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 truck scale records or vendor receipts. The records of production shall be kept on
a daily basis. Hours of operation shall be determined by monitoring and maintaining of an
operations log. [R307-401-8]
In compliance. The 12-month rolling total for processed aggregate from July 2022 to June
2023, indicated 407,453 tons. See the attachment for additional information. The
diesel-fired generators in AO Condition II.A.6 is no longer onsite. Kilgore uses line power
now with the generators no longer onsite.
II.B.1.b Visible emissions from the following emission points shall not exceed the following values:
A. All crushers - 15% opacity
B. All screens - 10% opacity
C. All conveyor transfer points - 10% opacity
D. All conveyor drop points - 20% opacity
E. All diesel-fired engines - 20% opacity
F. All other points - 20% opacity. [R307-401-8]
4
II.B.1.b.1
Status:
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9.
For equipment subject to NSPS, opacity shall be determined by conducting observations in
accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. [R307-401-8]
In compliance. There were no visible emissions observed during this inspection from the
crushers, screens, conveyor transfer points, conveyor drop points, and any other points.
The diesel-fired engines are no longer onsite. The opacity observations were conducted
according to 40 CFR 60, Appendix A, Method 9. See the attachment for additional
information.
II.B.2 All Haul Roads and Fugitive Dust Sources on site shall be subject to the following:
II.B.2.a Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas
shall not exceed 20% opacity. [R307-309-5]
II.B.2.a.1
Status:
Visible emission determinations for traffic sources 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. Six points, distributed along the length of the haul road or in the
operational area, shall be chosen by the Executive Secretary or the Executive Secretary's
representative. An opacity reading shall be made at each point when a vehicle passes the selected
points. Opacity readings shall be made at no less than one-half the vehicle length behind the
vehicle and at no less than approximately one-half the height of the vehicle. The accumulated six
readings shall be averaged for the compliance value. [R307-309-5]
In compliance. There were no visible emissions observed from haul road traffic and mobile
equipment. The water truck was in the process of watering the haul roads during this
inspection. See photographs in the attachment.
II.B.2.b
Status:
The owner/operator shall comply with a fugitive dust control plan acceptable to the Executive
Secretary for control of all dust sources associated with Pit #16. The owner/operator shall submit
a fugitive dust control plan to the Executive Secretary, attention: Compliance Section, for
approval within 30 days of the date of this AO. [R307-309-6]
In compliance. The most updated Fugitive Dust Control Plan for Kilgore is dated 2018.
II.B.2.c
Status:
All unpaved roads and other unpaved operational areas that are used by mobile equipment shall
be water sprayed and/or chemically treated to control fugitive dust. The application of water or
chemical treatment shall be used except when the ambient temperature is below freezing (32ºF).
Treatment shall be of sufficient frequency and quantity to maintain the surface material in a
damp/moist condition unless it is below freezing. The opacity shall not exceed 20% during all
times the areas are in use except when wind speeds exceed 25 mph, as measured by a hand-held
anemometer or equivalent device. If chemical treatment is to be used, the plan must be approved
by the Executive Secretary. [R307-401-8]
In compliance. All unpaved roads and other unpaved operational areas were watered to
control fugitive dust during this inspection. See the photographs in the attachment.
II.B.2.c.1
Records of water and/or chemical treatment shall be kept for all periods when the facility is in
operation. The records shall include the following items:
A. Date of application
B. Number of treatments made
C. Time of day treatments were made
D. Records of temperature if the temperature is below freezing
5
Status:
E. Records of wind speeds when wind speeds exceed 25 mph. This record is not required if
the owner/operator does not claim the wind speed exemption from the opacity limit on
fugitive dust. [R307-401-8]
In compliance. Kilgore maintains records of water treatment to include the date and
number of treatments on logs. See the Water Logs in the attachment.
II.B.2.d
Status:
The haul roads shall not exceed 0.4 miles in round trip length and the vehicle speed along the
haul road shall not exceed 15 miles per hour. The vehicle speed on the haul road shall be posted,
at a minimum, onsite at the beginning of the haul road so that it is clearly visible from the haul
road. [R307-401-8]
In compliance. The haul roads did not appear to exceed 0.4 miles. The posted haul road
speed is 10 miles per hour. See the attachment for additional information.
II.B.2.e
Status:
Control of disturbed or stripped areas is required at all times for the duration of the
project/operation. Records of treatment shall be kept for all periods when the plant is in
operation. [R307-401-8]
In compliance. Kilgore waters disturbed or stripped areas to control fugitive dust.
II.B.2.f
Status:
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:
A. All crushers
B. All screens
C. All conveyor transfer points
The sprays shall operate whenever dry conditions warrant and the ambient temperature is above
freezing, or as determined necessary by the Executive Secretary to meet the opacity limitations
listed in this AO. [R307-401-8]
In compliance. The crushers, screens, and conveyor transfer points are equipped with
water sprays to control fugitive dust. Kilgore also conduct monthly inspections of all water
sprays to ensure they are operating properly. See records of Water Spray Inspections in the
attachment.
II.B.2.g
Status:
The storage piles shall be watered to minimize generation of fugitive dust as dry conditions
warrant and the ambient temperature is above freezing, or as determined necessary by the
Executive Secretary to meet the opacity limitations listed in this AO. [R307-401-8]
In compliance. Kilgore waters the storage piles to minimize the generation of fugitive dust.
See photographs of the stockpiles in the attachment.
II.B.2.h The silt content of the haul road shall not exceed 4.8% by weight. [R307-401-8]
II.B.2.h.1
Status:
The silt content shall be determined if directed by the executive secretary using the appropriate
ASTM method. The silt content is defined as all material passing a #200 U.S. Standard Sieve.
[R307-401-8]
Not applicable. Kilgore has not been directed to test the silt content of the haul roads.
II.B.3 All fuels consumed on site shall be subject to the following:
II.B.3.a
Status:
The owner/operator shall use #2 fuel oil as fuel. [R307-401-8]
In compliance. Kilgore uses #2 fuel for the mobile equipment. There are no more
generators onsite.
6
II.B.3.b The sulfur content of any fuel oil shall not exceed 0.50 percent by weight. [R307-401-8]
II.B.3.b.1
Status:
The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
The sulfur content shall be tested if directed by the Executive Secretary. [R307-203-1]
In compliance. Parkland certifies that diesel fuel provided to Kilgore Companies from
Parkland and its affiliates is Ultra Low Sulfur Diesel 15ppm. The sulfur content does not
exceed 15%. 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
In compliance. According to DAQC-652-2014, the Initial Visible Emissions Observation Reports were
received by the DAQ on May 21, 2014. There were no visible emissions observed during this inspection
from the crushers, screens, conveyor transfer points, conveyor drop points, and any other points. The
crushers, screens, and conveyor transfer points are equipped with water sprays to control fugitive dust.
Kilgore also conduct monthly inspections of all water sprays to ensure they are operating properly.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
R307-203. Emission Standards: Sulfur Content of Fuels
In compliance. Parkland certifies that diesel fuel provided to Kilgore Companies from Parkland
and its affiliates is Ultra Low Sulfur Diesel 15ppm. The sulfur content does not exceed 15%. See the
attachment for additional information.
R307-210. Stationary Sources
In compliance. This area source rule is applicable to Subpart OOO. See the Status of Subpart OOO
in Section III for additional information.
R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards
In compliance. There were 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.
R307-309. Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive
Dust
In compliance. There were no visible emissions observed from the haul roads and the haul road
traffic during this inspection. The most updated Fugitive Dust Control Plan for Kilgore is dated
2018. The speed limit for the haul roads indicated 10 miles per hour (mph). The crushers, screens,
and conveyor transfer points are equipped with water sprays to control fugitive dust. Kilgore
maintains water logs and sweeping logs. See the attachment for additional information.
7
R307-312. Aggregate Processing Operations for PM2.5 Nonattainment Areas
In compliance with Table 1 of R307-312-4. There were no visible emissions observed during this
inspection from the crushers, screens, conveyor transfer points, conveyor drop points, and any
other points. The crushers, screens, and conveyor transfer points are equipped with water sprays to
control fugitive dust. Kilgore also conducts monthly inspections of all water sprays to ensure they
are operating properly.
EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions from Harper Contracting, Inc.
- Pit #16, Parley's Canyon Aggregate Facility on the Approval Order (AO) DAQE-AN0120580008-10,
dated June 9, 2010. The following information was supplied for supplemental purposes only.
Estimated Criteria Pollutant Potential Emissions
Estimated Hazardous Air Pollutant Potential Emissions
EMISSION INVENTORY can be collected from SLEIS Harper Contracting, Inc.- Pit #16, Parley's
Canyon Aggregate Facility Emissions Inventory data for the 2022 activity year are indicated below:
Pollutant Tons/yr
Carbon Monoxide <0.00
Nitrogen Oxides <0.00
Particulate Matter - PM10 9.08
Sulfur Dioxide <0.00
Volatile Organic Compounds 0.003
PREVIOUS ENFORCEMENT
ACTIONS: Prior violations include a Compliance Advisory
(DAQC-1036-18) and an Early Settlement Agreement
(DAQC-2161-18)
COMPLIANCE STATUS &
RECOMMENDATIONS: Kilgore is in compliance with the conditions of AO
DAQE-AN0120580008-10 dated June 9, 2010, at the time of
inspection. Kilgore maintains good housekeeping practices.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Required PPE includes safety glasses, steel-toe
boots, hard hat, and reflective vest.
RECOMMENDATION FOR
NSR PERMITTING REVIEW: None at this time.
ATTACHMENTS: Visible Emissions Observation Form, Rolling 12-month
Aggregate Production, Fuel Certification Letter, Sweeping Dates
for Parleys Canyon, Daily Watering Logs, Monthly Water Spray
Inspection, Site Photographs.