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HomeMy WebLinkAboutDAQ-2024-004461 DAQE-AN119950004-24 {{$d1 }} Troy Allen Allen Gravel LLC 1139 East 12700 North Cove, UT 84320 allenrockproducts@gmail.com Dear Mr. Allen: Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN119950003-23 to Include Stack Testing on the Diesel-Fueled Generator Engine Project Number: N119950004 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on September 11, 2023. Allen Gravel LLC must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Mr. Tim DeJulis, who can be contacted at (385) 306-6523 or tdejulis@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:TD:jg cc: Bear River Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director January 8, 2024 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN119950004-24 Administrative Amendment to Approval Order DAQE-AN119950003-23 to Include Stack Testing on the Diesel-Fueled Generator Engine Prepared By Mr. Tim DeJulis, Engineer (385) 306-6523 tdejulis@utah.gov Issued to Allen Gravel LLC - Cove Aggregate Processing Plant Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality January 8, 2024 TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 4 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 6 PERMIT HISTORY ................................................................................................................... 10 ACRONYMS ............................................................................................................................... 11 DAQE-AN119950004-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Allen Gravel LLC Allen Gravel LLC - Cove Aggregate Processing Plant Mailing Address Physical Address 1139 East 12700 North 1015 East 12600 North Cove, UT 84320 Cove, UT 84320 Source Contact UTM Coordinates Name Troy Allen 434,000 m Easting Phone (435) 770-1230 4,645,000 m Northing Email allenrockproducts@gmail.com Datum NAD83 UTM Zone 12 SIC code 1442 (Construction Sand & Gravel) SOURCE INFORMATION General Description Allen Gravel LLC (AG) operates an aggregate pit in Cove, Cache County. Aggregate is harvested by bulldozers or front-end loaders from the pit. Front-end loaders collect and take the aggregate to the crushing/screening area of the pit. Crushers, dry screens, and wash (wet) screens process the aggregate. The sized aggregate is stored on site. Sized aggregate and unprocessed aggregate are loaded into trucks and taken to customers off-site. The plant will produce up to 600,000 tons of sized aggregate and 200,000 tons of unprocessed aggregate per year. NSR Classification Administrative Amendment Source Classification Located in Logan UT-ID PM2.5 NAA Cache County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Title V (Part 70) Area Source DAQE-AN119950004-24 Page 4 Project Description This administrative amendment will incorporate testing requirements for the 750-kW diesel-fired generator engine. 40 CFR 63 Subpart ZZZZ requires this generator engine, manufactured before 2006, to have a stack test every 8,760 hours of operation or three (3) years, whichever is first, from the date of the previous stack test. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 1167.00 Carbon Monoxide 0 6.58 Nitrogen Oxides 0 17.86 Particulate Matter - PM10 0 10.32 Particulate Matter - PM2.5 0 10.32 Sulfur Dioxide 0 3.23 Volatile Organic Compounds 0 0.07 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 520 Change (TPY) Total (TPY) Total HAPs 0 0.26 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] DAQE-AN119950004-24 Page 5 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] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Cove Aggregate Processing Plant II.A.2 One (1) Cone Crusher Capacity: 150 tons per hour NSPS Subpart OOO II.A.3 One (1) Triple Deck Screen Capacity: 350 tons per hour Size: 6 x 20 II.A.4 One (1) Double Deck Screen Capacity: 100 tons per hour Size: 3 x 8 II.A.5 Two (2) Wash Screens Includes: chip washer, rock washer, triple-deck screen, four-deck screen, sand screws, and various conveyors and stackers For informational purposes only. II.A.6 Various Aggregate Processing Equipment Conveyors, Feeders, and Stackers II.A.7 One (1) Generator Engine Rating: 750 kW Fuel: Diesel Emissions Control: Catalytic Converter Manufactured in 2003 Refurbished in 2022 MACT Subpart ZZZZ II.A.8 Various Mobile Equipment Front-end Loaders, Bulldozers, & Excavators DAQE-AN119950004-24 Page 6 SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Plantwide 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% opacity. [R307-401-8] 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] II.B.2 Aggregate Production Plant: II.B.2.a The owner/operator shall not produce more than the following: A. 600,000 tons of sized aggregate per rolling 12-month period B. 200,000 tons of aggregate removed from bank run and sold without processing per rolling 12-month period. [R307-401-8] II.B.2.a.1 The owner/operator shall: A. Determine aggregate production by weighing haul trucks when both empty and full B. Account for all aggregate materials produced prior to the aggregate materials leaving the site C. Record production on a daily basis D. 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 E. Keep production records for all periods when the plant is in operation. [R307-401-8] II.B.2.b The owner/operator shall not allow visible emissions from any crusher on site to exceed 12% opacity. [40 CFR 60 Subpart OOO, R307-312-4, R307-401-8] II.B.2.c The owner/operator shall not allow visible emissions from any screen on site to exceed 7% opacity. [40 CFR 60 Subpart OOO, R307-312-4, R307-401-8] II.B.2.d The owner/operator shall not allow visible emissions from any conveyor transfer point on site to exceed 7% opacity. [40 CFR 60 Subpart OOO, R307-312-4, R307-401-8] II.B.2.e The owner/operator shall not allow visible emissions from any conveyor drop point on site to exceed 20% opacity. [R307-401-8] DAQE-AN119950004-24 Page 7 II.B.2.f The owner/operator shall install water sprays at the following points to control fugitive emissions: A. All crushers B. All screens C. All conveyor transfer points. [R307-401-8] II.B.3 Crushers, Screens, and Conveyors subject to NSPS Subpart OOO: II.B.3.a The owner/operator shall install water sprays on each crusher, screen, conveyor transfer point, and conveyor drop point 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] II.B.3.a.1 The owner/operator shall conduct monthly inspections of each crusher, screen, and conveyor manufactured after April 22, 2008, to check that water is flowing to discharge spray nozzles in the wet suppression system. [40 CFR 60 Subpart OOO] II.B.3.a.2 The owner/operator shall maintain records of wet suppression system inspections according to 40 CFR 60 Subpart OOO. [40 CFR 60 Subpart OOO] II.B.3.b The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving the maximum production rate but not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO] II.B.3.b.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] II.B.3.b.2 The owner/operator shall keep and maintain records of the initial performance test for each crusher, screen, and conveyor for the life of the equipment. [40 CFR 60 Subpart OOO, R307-401-8] II.B.4 Generator Engines: II.B.4.a The owner/operator shall not allow visible emissions from the generator engine to exceed 20% opacity. [R307-401-8] II.B.4.b The owner/operator shall not operate the 750-kW generator engine for more than 2,500 hours per rolling 12-month period. [R307-401-8] II.B.4.b.1 The owner/operator shall: A. Determine hours of operation with a supervisor monitoring and maintaining an operations log B. Record hours of operation each day C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8] DAQE-AN119950004-24 Page 8 II.B.4.c The owner/operator shall install a generator engine with a catalytic converter controlling the emission that is certified to meet the following emission rates: Pollutant g/hp-hr NOx 2.62 g/hp-hr CO 2.38 g/hp-hr [R307-401-8] II.B.4.c.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] II.B.4.c.2 The owner/operator shall operate the catalytic converter in accordance with manufacturer specifications and recommendations. [R307-401-8] II.B.4.c.3 The owner/operator shall test and replace the catalytic converter catalyst in accordance with manufacturer recommendations. Records of catalytic converter inspections and catalyst replacements shall be kept for the life of the equipment. [R307-401-8] II.B.4.d The owner/operator shall either: A. Limit concentration of CO in the generator engine exhaust to 23 ppmvd or less at 15 percent O2; or B. Reduce CO emissions by 70 percent or more from the generator engine. [40 CFR 63 Subpart ZZZZ] II.B.4.d.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 and in 40 CFR 63 Subpart ZZZZ. [R307-401-8] II.B.4.d.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-401-8] II.B.4.d.3 Test Frequency After the date of the most recent stack test of the emission unit, the owner/operator shall conduct a stack test on the emission unit every 8,760 hours of operation or within three (3) years, whichever comes first. 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.5 Stack Testing Requirements II.B.5.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.5.a.1 Notification At least 30 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. [R307-165-3, R307-401-8] II.B.5.a.2 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. [R307-165-4, R307-401-8] DAQE-AN119950004-24 Page 9 II.B.5.a.3 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. [R307-401-8] II.B.5.a.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.5.a.5 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. [R307-401-8] II.B.5.a.6 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.5.a.7 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. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.5.a.8 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.5.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the engine. [R307-401-8] II.B.5.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. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5.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. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.6 Haul Roads and Fugitive Dust Sources II.B.6.a The owner/operator shall comply with a FDCP for control of all fugitive dust sources associated with the aggregate process facility. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. [R307-401-8] II.B.6.b The owner/operator shall comply with all applicable requirements of R307-309-5 for Fugitive Emission and Fugitive Dust sources on site. [R307-309-5] II.B.6.c The owner/operator shall not allow visible emissions from paved haul roads to exceed 10% opacity. The owner/operator shall not allow visible emissions from the unpaved haul roads and fugitive dust sources to exceed 20% opacity on site and 10% opacity at the property boundary. [R307-309-5, R307-401-8] DAQE-AN119950004-24 Page 10 II.B.6.c.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] II.B.6.d The total paved haul road shall be no less than 0.30 miles in length. [R307-401-8] II.B.6.d.1 Compliance shall be determined through Global Positioning System (GPS) measurements or aerial photographs. [R307-401-8] II.B.6.e The owner/ operator shall sweep and spray clean the paved in-plant haul road as necessary to maintain the listed opacity limits in this AO. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN119950003-23 dated June 8, 2023 Is Derived From NOI dated September 11, 2023 DAQE-AN119950004-24 Page 11 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds DAQE- RN119950004 December 19, 2023 Troy Allen Allen Gravel LLC 1139 East 12700 North Cove, UT 84320 allenrockproducts@gmail.com Dear Troy Allen, Re: Engineer Review - Administrative Amendment: Administrative Amendment to Approval Order DAQE-AN119950003-23 to Include Stack Testing on the Diesel-Fueled Generator Engine. Project Number: N119950004 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. Allen Gravel LLC should complete this review within 10 business days of receipt. Allen Gravel LLC should contact Mr. Tim DeJulis at (385) 306-6523 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Tim DeJulis at tdejulis@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If Allen Gravel LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Allen Gravel LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N119950004 Owner Name Allen Gravel LLC Mailing Address 1139 East 12700 North Cove, UT, 84320 Source Name Allen Gravel LLC- Cove Aggregate Processing Plant Source Location 1015 East 12600 North Cove, UT 84320 UTM Projection 434,000 m Easting, 4,645,000 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1442 (Construction Sand & Gravel) Source Contact Troy Allen Phone Number (435) 770-1230 Email allenrockproducts@gmail.com Billing Contact Troy Allen Phone Number (435) 770-1230 Email allenrockproducts@gmail.com Project Engineer Mr. Tim DeJulis, Engineer Phone Number (385) 306-6523 Email tdejulis@utah.gov Notice of Intent (NOI) Submitted September 11, 2023 Date of Accepted Application September 12, 2023 Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 2 SOURCE DESCRIPTION General Description Allen Gravel LLC (AG) operates an aggregate pit in Cove, Cache County. Aggregate is harvested by bulldozers or front-end loaders from the pit. Front-end loaders collect and take the aggregate to the crushing/screening area of the pit. Crushers, dry screens, and wash (wet) screens process the aggregate. The sized aggregate is stored on site. Sized aggregate and unprocessed aggregate are loaded into trucks and taken to customers off-site. The plant will produce up to 600,000 tons of sized aggregate and 200,000 tons of unprocessed aggregate per year. NSR Classification: Administrative Amendment Source Classification Located in Logan UT-ID PM2.5 NAA Cache County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Title V (Part 70) Area Source Project Proposal Administrative Amendment to Approval Order DAQE-AN119950003-23 to Include Stack Testing on the Diesel-Fueled Generator Engine. Project Description This administrative amendment will incorporate testing requirements for the 750-kW diesel-fired generator engine. 40 CFR 63 Subpart ZZZZ requires this generator engine, manufactured before 2006, to have a stack test every 8,760 hours of operation or three (3) years, whichever is first, from the date of the previous stack test. EMISSION IMPACT ANALYSIS Emissions will remain unchanged as a result of the administrative amendment; therefore, modeling is not required at this time. [Last updated October 10, 2023] Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 3 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 1167.00 Carbon Monoxide 0 6.58 Nitrogen Oxides 0 17.86 Particulate Matter - PM10 0 10.32 Particulate Matter - PM2.5 0 10.32 Sulfur Dioxide 0 3.23 Volatile Organic Compounds 0 0.07 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 520 Change (TPY) Total (TPY) Total HAPs 0 0.26 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding Process Equipment This is an administrative amendment; therefore, a BACT analysis is not required. [Last updated October 10, 2023] SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): 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] Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 5 SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Cove Aggregate Processing Plant II.A.2 One (1) Cone Crusher Capacity: 150 tons per hour NSPS Subpart OOO II.A.3 One (1) Triple Deck Screen Capacity: 350 tons per hour Size: 6 x 20 II.A.4 One (1) Double Deck Screen Capacity: 100 tons per hour Size: 3 x 8 II.A.5 Two (2) Wash Screens Includes: chip washer, rock washer, triple-deck screen, four-deck screen, sand screws, and various conveyors and stackers For informational purposes only. II.A.6 Various Aggregate Processing Equipment Conveyors, Feeders, and Stackers II.A.7 One (1) Generator Engine Rating: 750 kW Fuel: Diesel Emissions Control: Catalytic Converter Manufactured in 2003 Refurbished in 2022 MACT Subpart ZZZZ II.A.8 Various Mobile Equipment Front-end Loaders, Bulldozers, & Excavators Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 6 SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Plantwide Requirements: II.B.1.a NEW Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20% opacity. [R307-401-8] 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] II.B.2 Aggregate Production Plant: II.B.2.a The owner/operator shall not produce more than the following: A. 600,000 tons of sized aggregate per rolling 12-month period B. 200,000 tons of aggregate removed from bank run and sold without processing per rolling 12-month period. [R307-401-8] II.B.2.a.1 The owner/operator shall: A. Determine aggregate production by weighing haul trucks when both empty and full. B. Account for all aggregate materials produced prior to the aggregate materials leaving the site. C. Record production on a daily basis. D. 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. E. Keep production records for all periods when the plant is in operation. [R307-401-8] II.B.2.b NEW The owner/operator shall not allow visible emissions from any crusher on site to exceed 12% opacity. [40 CFR 60 Subpart OOO, R307-312-4, R307-401-8] II.B.2.c NEW The owner/operator shall not allow visible emissions from any screen on site to exceed 7% opacity. [40 CFR 60 Subpart OOO, R307-312-4, R307-401-8] II.B.2.d NEW The owner/operator shall not allow visible emissions from any conveyor transfer point on site to exceed 7% opacity. [40 CFR 60 Subpart OOO, R307-312-4, R307-401-8] Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 7 II.B.2.e NEW The owner/operator shall not allow visible emissions from any conveyor drop point on site to exceed 20% opacity. [R307-401-8] II.B.2.f The owner/operator shall install water sprays at the following points to control fugitive emissions: A. All crushers B. All screens C. All conveyor transfer points. [R307-401-8] II.B.3 Crushers, Screens, and Conveyors subject to NSPS Subpart OOO: II.B.3.a NEW The owner/operator shall install water sprays on each crusher, screen, conveyor transfer point, and conveyor drop point 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] II.B.3.a.1 NEW The owner/operator shall conduct monthly inspections of each crusher, screen, and conveyor manufactured after April 22, 2008 to check that water is flowing to discharge spray nozzles in the wet suppression system. [40 CFR 60 Subpart OOO] II.B.3.a.2 NEW The owner/operator shall maintain records of wet suppression system inspections according to 40 CFR 60 Subpart OOO. [40 CFR 60 Subpart OOO] II.B.3.b The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving the maximum production rate but not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO] II.B.3.b.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] II.B.3.b.2 The owner/operator shall keep and maintain records of the initial performance test for each crusher, screen, and conveyor for the life of the equipment. [40 CFR 60 Subpart OOO, R307- 401-8] II.B.4 Generator Engines: II.B.4.a The owner/operator shall not allow visible emissions from the generator engine to exceed 20% opacity. [R307-401-8] II.B.4.b The owner/operator shall not operate the 750-kW generator engine for more than 2,500 hours per rolling 12-month period. [R307-401-8] Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 8 II.B.4.b.1 NEW The owner/operator shall: A. Determine hours of operation with a supervisor monitoring and maintaining an operations log B. Record hours of operation each day C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8] II.B.4.c NEW The owner/operator shall install a generator engine with a catalytic converter controlling the emission that is certified to meet the following emission rates: Pollutant g/hp-hr NOx 2.62 CO 2.38 [R307-401-8] II.B.4.c.1 NEW To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] II.B.4.c.2 NEW The owner/operator shall operate the catalytic converter in accordance with manufacturer specifications and recommendations. [R307-401-8] II.B.4.c.3 NEW The owner/operator shall test and replace the catalytic converter catalyst in accordance with manufacturer recommendations. Records of catalytic converter inspections and catalyst replacements shall be kept for the life of the equipment. [R307-401-8] II.B.4.d NEW The owner/operator shall either: A. Limit concentration of CO in the generator engine exhaust to 23 ppmvd or less at 15 percent O2; or B. Reduce CO emissions by 70 percent or more from the generator engine The owner/operator shall either: A. Limit concentration of CO in the generator engine exhaust to 23 ppmvd or less at 15 percent O2; or B. Reduce CO emissions by 70 percent or more from the generator engine. [40 CFR 63 Subpart ZZZZ] Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 9 II.B.4.d.1 NEW 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 and in 40 CFR 63 Subpart ZZZZ. [R307-401-8] II.B.4.d.2 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-401-8] II.B.4.d.3 NEW Test Frequency After the date of the most recent stack test of the emission unit, the owner/operator shall conduct a stack test on the emission unit every 8,760 hours of operation or within three (3) years, whichever comes first. 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.5 NEW Stack Testing Requirements II.B.5.a NEW The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.5.a.1 NEW Notification At least 30 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. [R307- 165-3, R307-401-8] II.B.5.a.2 NEW 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. [R307-165-4, R307-401-8] II.B.5.a.3 NEW 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. [R307- 401-8] II.B.5.a.4 NEW Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.5.a.5 NEW 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. [R307-401-8] II.B.5.a.6 NEW 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] Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 10 II.B.5.a.7 NEW 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. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.5.a.8 NEW CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.5.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the engine. [R307-401-8] II.B.5.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. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5.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. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.6 Haul Roads and Fugitive Dust Sources II.B.6.a The owner/operator shall comply with a FDCP for control of all fugitive dust sources associated with the aggregate process facility. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. [R307-401-8] II.B.6.b The owner/operator shall comply with all applicable requirements of R307-309-5 for Fugitive Emission and Fugitive Dust sources on site. [R307-309-5] II.B.6.c The owner/operator shall not allow visible emissions from paved haul roads to exceed 10% opacity. The owner/operator shall not allow visible emissions from the unpaved haul roads and fugitive dust sources to exceed 20 percent opacity on site and 10% opacity at the property boundary. [R307-309-5, R307-401-8] II.B.6.c.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] II.B.6.d The total paved haul road shall be no less than 0.30 miles in length. [R307-401-8] Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 11 II.B.6.d.1 Compliance shall be determined through Global Positioning System (GPS) measurements or aerial photographs. [R307-401-8] II.B.6.e The owner/ operator shall sweep and spray clean the paved in-plant haul road as necessary to maintain the listed opacity limits in this AO. [R307-401-8] PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN119950003-23 dated June 8, 2023 REVIEWER COMMENTS 1. Comment regarding Emission Estimates: The emission estimates are calculated as follows: Emission estimates from the generator engine are from AP-42 Section 3.4 and from the manufacturer of the catalytic converter. The emission factors in AP-42 Section 3.4 are multiplied with the following catalytic converters efficiencies: NOx - 6.4%, CO - 72%, and VOC - 74.3% [Last updated October 11, 2023] 2. Comment regarding NSPS & MACT: 40 CFR 60 (NSPS) 40 CFR Part 60 Subpart OOO applies to select equipment at nonmetallic mineral processing plants that commenced construction, modification, or reconstruction after August 31, 1983. The screens, crushers, and transfer/drop points (conveyors, stackers, feed bins) at this facility are subject to 40 CFR Part 60 Subpart OOO. 40 CFR 60 Subpart IIII applies to owner and operators of CI ICE that commence construction, modification, or reconstruction after 07/11/2005. The CI ICE was manufactured in 2002 and refurbished in 2023 (see explanation under review comment 4). NSPS Subpart IIII will not apply to this plant. 40 CFR 63 (MACT) 40 CFR 63 Subpart ZZZZ applies to owners and operators of stationary RICE at a major or area source of HAP emissions. Since this source will have a stationary RICE at an area source of HAP emissions, MACT Subpart ZZZZ will apply to this plant. 40 CFR 63 Subpart CCCCCC applies to owners and operators of new or reconstructed gasoline storage tanks. No stationary gasoline storage tanks are at this site: therefore, Subpart CCCCCC does not apply to this facility. [Last updated November 9, 2023] Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 12 3. Comment regarding Title V Requirements: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is subject to 40 CFR 60 (NSPS) and 40 CFR 63 (MACT) regulations. The facility is not subject to 40 CFR 61 (NESHAP) regulations. Title V applies to this facility as an area source. There is no requirement for this source to apply for a Title V operating permit under current UDAQ and EPA rules. The source will be charged applicable Title V fees and Title V funds may be used for inventory and compliance inspections of this source. [Last updated November 9, 2023] 4. Comment regarding Stack Test Inclusion and Refurbishment of the 750-kW Generator Engine: The 750-kW diesel fueled generator engine was manufactured before 2006. 40 CFR 63 Subpart ZZZZ has a requirement to regularly stack test the generator engine initially and thereafter, when operations have reached 8,760 hours or three (3) years since the previous test was performed. This administrative amendment incorporates testing requirements into the AO. The source refurbished the generator engine. The cost for the refurbishment was 12% of the fixed capital cost that would be required to construct a comparable entirely new generator engine. Therefore, this was not a reconstruction, and the NSPS Subpart IIII requirements do not apply to the refurbished generator engine. The generator engine, however, is still subject to MACT Subpart ZZZZ requirements. The testing conditions, including II.B.4.d and II.B.5, are incorporated into this ER to meet the MACT Subpart ZZZZ requirements. [Last updated December 19, 2023] Engineer Review N119950004: Allen Gravel LLC- Cove Aggregate Processing Plant December 19, 2023 Page 13 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISTON OF AIR QUALITY Bryce C. Bird Director RN119950004 December 22, 2023 Troy Allen Allen Gravel LLC 1015 East 12600 North Cove, UT 84320 allenrockproducts@gmail.com Dear Troy Allen, Re: Engineer Review - Administrative Amendment: Administrative Amendment to Approval Order DAQE-ANl 19950003-23 to Include Stack Testing on the Diesel-Fueled Generator Engine. Project Number: Nl 19950004 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. Allen Gravel LLC should complete this review within 10 business days of receipt. Allen Gravel LLC should contact Mr. Tim DeJulis at (385) 306-6523 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Tim DeJulis at tdejulis@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If Allen Gravel LLC does not respond to this letter vdthin 10 business days, the project will move forward without souixe concurrence. If Allen Gravel LLC has concerns that cannot be resolved and the project becomes stagnant, the DA(JJDirector rp^ issue^anprder prohibiting construction. Approval Signature 195 North 1950 West • Salt Lake City, UT Mailing Addi-ess: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536^000 • Fax (801) 5364099 • T.D.D. (801) 903-3978 WLH V. deq. utah.gov Printed on 100% recycled paper 11/14/23, 2:06 PM State of Utah Mail - Allen Gravels Stack Testing Status https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r3416998546666242729&simpl=msg-a:r341865102988292…1/2 Tim Dejulis <tdejulis@utah.gov> Allen Gravels Stack Testing Status 2 messages Tim Dejulis <tdejulis@utah.gov>Fri, Jul 7, 2023 at 9:11 AM To: Troy Allen <allenrockproducts@gmail.com> Cc: Chad Gilgen <cgilgen@utah.gov>, Alan Humpherys <ahumpherys@utah.gov> Hi Troy. We have an answer on whether the generator engine needs to have stack testing or not. Unfortunately, I had the incorrect information with respect to the stack testing, based on my review of MACT Subpart ZZZZ. Cost of Making Changes to the Permit The DAQ will make the changes to Allen Gravel's permit at no charge. We will fix this situation at no expense to Allen Gravel. Permit Changes The catalytic converter purchased and installed is a requirement, since the engine is older than 2006. Reading MACT Subpart ZZZZ, we will have Allen Gravel perform an initial stack test and then it would have to be repeated each 8,760 hrs or three years, whichever is sooner. Based on the hours of operation per year given to me, 2,500 hrs/yr, Allen Gravel wouldn't need to do another stack test for three years from the date of the first test. Changes to the Language The changes to language in the permit are as follows in the attached file. If you have any questions or concerns please let me know. I am prepared to move forward within this change in the next few months. Thank you. Timothy DeJulis, PE Environmental Engineer | Minor NSR Section P: (385) 306-6523 airquality.utah.gov Allen Gravel Stack Testing Conditions 2023.docx 14K Chad Gilgen <cgilgen@utah.gov>Fri, Jul 7, 2023 at 12:58 PM To: Tim Dejulis <tdejulis@utah.gov> Cc: Troy Allen <allenrockproducts@gmail.com>, Alan Humpherys <ahumpherys@utah.gov> Tim, Please see the attached document with the changes that need to be made to the proposed stack testing conditions. Item II.A.7 of the equipment list needs to include the horsepower rating of the engine as that is what Subpart ZZZZ uses to determine the stack testing CO emission limits. I also need to see a copy of the updated Approval Order before it is finalized. Thanks, 11/14/23, 2:06 PM State of Utah Mail - Allen Gravels Stack Testing Status https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r3416998546666242729&simpl=msg-a:r341865102988292…2/2 Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Allen Gravel Stack Testing Conditions 2023_cg.docx 21K