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HomeMy WebLinkAboutDAQ-2024-0077551 DAQC-411-24 Site ID 12905 (B1) MEMORANDUM TO: FILE – GRANITE CONSTRUCTION COMPANY – Wells and Wells South Aggregate Facilities THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: March 21, 2024 SUBJECT: FULL COMPLIANCE INSPECTION, Minor, Box Elder County INSPECTION DATE: July 19, 2023 SOURCE LOCATION: 750 North 300 East Willard, UT 84302 DIRECTIONS: From Salt Lake City, travel north on I-15 to Exit 357. Turn right and continue east on 750 North for about 1.5 miles. The pit is at the end of the road past US-89. SOURCE CONTACTS: Quin Bingham, Environmental Manager 435-770-4319, quin.bingham@gcinc.com OPERATING STATUS: Operating. PROCESS DESCRIPTION: The Granite Construction Company is an aggregate processing facility with crushers and screens. Material is processed by the jaw and cone crushers, screened, washed, and transferred by conveyor belts to storage piles. The pit has a water well, pump, and a water storage tank located near the entrance of the pit. The water truck also has pile spraying capability. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN129050010-21, dated June 30, 2021 NSPS (Part 60) -OOO: Standards of Performance for Nonmetallic Mineral Processing Plants [40 CFR 60 Subpart OOO], NSPS (Part 60) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines [40 CFR 60 Subpart ZZZZ]. / : 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Granite Construction Company Wells and Wells South Aggregate Facilities 1000 North Warm Springs Road 750 North State Route 89 Salt Lake City, UT 84116 Willard, UT 84302 SIC Code: 1442: (Construction Sand & Gravel) 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. Granite Construction Company 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. Granite Construction Company has made no 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 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] In Compliance. Granite Construction Company plans to keep the records for a minimum of two 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. Granite Construction Company maintains records of maintenance activities performed on equipment authorized by this AO. 3 I.6 Status: The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] In Compliance. Granite Construction Company did not experience any breakdowns resulting 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 2020 Emissions Inventory Report, the emissions indicated compliance with the PTEs of this AO. I.8 Status: The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] Not Applicable. This AO was approved to increase production and material handling with no associated construction activities. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Wells and Wells South Aggregate Facilities II.A.2 Jaw Crusher Manufacturer: Nordberg Rating: 600 tons per hour (TPH) Manufacture Date: 1985 NSPS Applicability: OOO II.A.3 Jaw Crusher Manufacturer: Pioneer Rating: 225 TPH Manufacture Date: 1969 II.A.4 Cone Crusher Manufacturer: Cedar Rapids Rating: 200 TPH Manufacture Date: 1984 NSPS applicability: OOO II.A.5 Cone Crusher Manufacturer: El Jay Rating: 200 TPH Manufacture Date: 1991 Size: 54 inches NSPS Applicability: OOO DAQE-AN129050010-21 Page 6 4 II.A.6 Cone Crusher Manufacturer: Sandvik H4800 HYD Rating: 300 TPH Manufacture Date: 2006 NSPS Applicability: OOO II.A.7 Cone Crusher Manufacturer: Kodiak Rating: 200 TPH Manufacture Date: 2018 NSPS Applicability: OOO II.A.8 Vibrating Screen Manufacturer: Cedar Rapids Rating: 200 TPH Manufacture Date: 1999 NSPS Applicability: OOO II.A.9 Screen Manufacturer: JCI Rating: 200 TPH Manufacture Date: 2006 NSPS Applicability: OOO II.A.10 Vibrating Screen Manufacturer: KPI-JCI Rated Capacity: 400 TPH Manufacture Date: 2017 NSPS Applicability: OOO II.A.11 Wet Screen Dimensions: 6' X 20' Listed for information purposes only II.A.12 Screen Manufacturer: Eljay Size: 6' x 20' Rating: 300 TPH Manufacture Date: 1987 NSPS Applicability: OOO II.A.13 Triple Deck Screen Manufacturer: JCI Size: 7' x 20' Rating: 200 TPH Manufacture Date: 2006 NSPS Applicability: OOO II.A.14 Generator Engine Rating: 1,186 hp Fuel: Diesel MACT Applicability: ZZZZ 5 II.A.15 Support Equipment Includes: Conveyors (NSPS Applicability: OOO), Loaders, Stockpiles, Bins, Sand Screws, Water Pumps, Water Trucks, etc. II.A.16 Wash Plant Support Equipment Includes: Wet material transfer conveyors and trap feeder conveyor Listed for information purposes only Status: In Compliance. There were no new or unapproved equipment observed onsite. The Generator Engine in AO II.A.14 is no longer onsite. II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not exceed the following production limits: A. 800,000 tons of aggregates (bank-run and processed combined) total per rolling 12-month period for the Wells site. B. 300,000 tons of aggregates (bank-run and processed combined) total per rolling 12-month period for the Wells South site. [R307-401-8] II.B.1.a.1 The owner/operator shall: A. Determine production using sales receipts. 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. [R307-401-8] Status: In Compliance. The rolling 12-month production from August 2022 to July 2023 indicated the following: A. 550,432 tons of aggregates (bank-run and processed combined) total per rolling 12-month period for the Wells site B. 0.0 tons of aggregates (bank-run and processed combined) total per rolling 12-month period for the Wells South site Granite Construction Company determines production daily from sales receipts. II.B.1.b The owner/operator shall not exceed the following bulldozing operating hour limits: A. 4500 hours of total operating time per rolling 12-month period for the Wells site B. 1500 hours of total operating time per rolling 12-month period for the Wells South site. [R307-401-8] 6 II.B.1.b.1 The owner/operator shall: A. Determine hours of operation by 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 the data from the previous 12 months. D. The operations log shall show the start and end times of any operation day. [R307-401-8] Status: In Compliance. The rolling 12-month bulldozing hours of operation from August 2022 to July 2023 indicated the following: A. 954 hours of total operating time per rolling 12-month period for the Wells site. B. 0.0 hours of total operating time per rolling 12-month period for the Wells South site. Granite Construction Company determines the hours of operation by maintaining the hours of operations in a log. II.B.1.c The owner/operator shall not operate before 6 am or after 10 pm each day. [R307-401-8] II.B.1.c.1 The owner/operator shall keep and maintain the following records of operation: A. Time operations begin each day. B. Time operations end each day. [R307-401-8] Status: In Compliance. Granite Construction Company operates during the approved hours of operation, and records the daily operation start and end times. II.B.1.d 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 except after the wet sand screw. [R307-309] Status: In Compliance. The crushers, screens, and conveyor transfer points are equipped with water sprays to control fugitive emissions. II.B.1.e The owner/operator shall not allow visible emissions to exceed the following limits: A. Crushers - 12% opacity B. Screens - 7% opacity C. All Conveyor Transfer Points - 7% opacity 7 D. All Diesel Engines - 20% opacity E. All Conveyor Drop Points - 20% opacity F. All Other Points - 20% opacity [R307-309, R307-312, R307-401-8] II.B.1.e.1 Unless otherwise specified in this AO, opacity observations of emission from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3] Status: In Compliance. There were no visible emissions observed during this inspection. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. See the attachment for additional information. II.B.2 Generator Engine Requirements. [R307-415-6a] II.B.2.a The owner/operator shall not operate the generator engine more than 2,500 hours per rolling 12-month period. [R307-401-8] II.B.2.a.1 The owner/operator shall: A. Determine hours of operation by 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 the data from the previous 12 months. [R307-401-8] II.B.2.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the generator engine. [R307-401-8] Status: Not Applicable. The Generator Engine is no longer onsite. II.B.2.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] Status: In Compliance. According to an Invoice from RelaDyne, the sulfur content of the diesel is characterized as Ultra Low Sulfur diesel. See the attachment for additional information. II.B.2.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-203] Status: In Compliance. According to an Invoice from RelaDyne, the sulfur content of the diesel is characterized as Ultra Low Sulfur diesel. See the attachment for additional information. 8 II.B.3 Haul Road and Fugitive Dust Requirements. [R307-415-6a] II.B.3.a The owner/operator shall comply with a FDCP acceptable to the Director for control of all dust sources associated with the facility. [R307-309-6] Status: In Compliance. The most current Fugitive Dust Control Plan (FDCP) is dated June 23, 2022. II.B.3.b The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% at the property boundary. [R307-309-5] Status: In Compliance. There were no visible emissions observed from haul roads during this inspection. See the attachment for additional information. II.B.3.b.1 Visible determinations for fugitive dust emissions from haul-road traffic and mobile equipment 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. [R307-309-5] Status: In Compliance. There were no fugitive dust emissions observed from haul-road traffic and mobile equipment during this inspection. II.B.3.c The haul roads and loader operation areas shall not exceed the following lengths: A. Unpaved haul roads - 1.82 miles B. Total (paved and unpaved) haul roads - 1.94 miles C. Loader operation areas - 0.20 miles. [R307-401-8] II.B.3.c.1 Compliance shall be determined through GPS measurements or aerial photographs. [R307-401-8] Status: In Compliance. According to Granite Construction Company, the areas and distances were calculated using Propeller (Trimble Software) imagery on June 30, 2023. A. Unpaved haul roads – 0.44 miles B. Total (paved and unpaved) haul roads – 0.66 miles C. Loader operation areas -0.18 miles See the attachment for additional information. II.B.3.d The owner/operator shall use water sprays on all unpaved haul road and loader operation areas. The owner/operator shall also use road base to cover the haul road and loader operation areas to control fugitive dust emissions. The owner/operator shall vacuum sweep and flush with water all the paved haul roads. The water sprays and flushing shall be of sufficient frequency and quantity to maintain the opacity limit specified in the AO, or unless it is below freezing. [R307-401-8] 9 II.B.3.d.1 Records of vacuum sweeping 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 D. Records of temperature, if the temperature was below freezing. [R307-401-8] Status: In Compliance. Granite Construction Company maintains Watering Logs and Sweeping records as required by this AO Condition. Watering Logs and Sweeping records were reviewed onsite from April 12, 2023, to July 19, 2023. II.B.3.e The owner/operator shall not exceed 62 acres of all disturbed areas combined. [R307-401-8] II.B.3.e.1 To determine compliance with the total disturbed areas, the owner/operator shall measure the total disturbed area at least once every 12 months and shall maintain a record of the total disturbed acres. To determine the disturbed acres on site, the owner/operator shall use aerial drone survey, or equivalent, of each disturbed area on site to calculate each disturbed area on site. Records of the total disturbed areas shall contain the following: A. Date of measurements B. Size of each disturbed area on site C. Total acres of all disturbed areas combined. [R307-401-8] Status: Not In Compliance with the acres of all disturbed areas combined. According to Granite Construction Company, the disturbed area acreage is 62.9 acres. See the attachment for additional information. The new AO Modification for Granite Construction Company was approved on March 15, 2024. See the new AO Condition II.B.3.e for additional information. No further action is required at this time. II.B.3.f The owner/operator shall water the storage piles on site to minimize generation of fugitive dusts. The water treatment shall be of sufficient frequency and quantity to maintain the opacity limit specified in this AO. Records of water treatment shall be kept for all periods when the plant is in operation. [R307-309] Status: In Compliance. Granite Construction Company waters storage piles to minimize fugitive dust. Watering Logs were reviewed onsite from April 12, 2023, to July 19, 2023. II.B.4 Crushers, Screens, and Conveyors subject to NSPS Subpart OOO: [R307-415-6a] II.B.4.a 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 10 limitations specified in Table 3 to Subpart OOO. Records of initial performance tests shall be kept and maintained on site for the life of the equipment. [40 CFR 60 Subpart OOO] II.B.4.a.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.4.a.2 The owner/operator shall submit written reports to the Director of the results of all performance tests conducted to demonstrate compliance with the standards set forth in 40 CFR 60.672. [40 CFR 60 Subpart OOO, R307-401-8] Status: In Compliance. Initial performance tests for all crushers, screens, and conveyors transfer points were conducted on June 12, 2019. 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 [40 CFR 60 Subpart OOO] In Compliance. Initial performance tests for all crushers, screens, and conveyors transfer points were conducted on June 12, 2019. See the attachment for additional information. NSPS (Part 60) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines [40 CFR 60 Subpart ZZZZ] Not Applicable. The Generator Engine is no longer onsite. AREA SOURCE RULES EVALUATION The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] In Compliance. According to an Invoice from RelaDyne, the sulfur content of the diesel is characterized as Ultra Low Sulfur diesel. See the attachment for additional information. R307-305 Nonattainment and Maintenance Areas for PM10: Emission Standards. In Compliance. There were no emissions observed during this inspection. See the attachment for additional information. 11 R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust. In Compliance. The most current Fugitive Dust Control Plan (FDCP) is dated June 23, 2022. There were no fugitive emissions observed from paved haul roads, unpaved haul roads, and vehicular traffic during this inspection. Granite Construction Company maintained Sweeping Logs and Watering Logs which were reviewed onsite. See the attachment for additional information. Aggregate Processing Operations for PM2.5 Nonattainment Areas In Compliance. There were no visible emissions observed from the crushers, screens, or conveyors during this inspection. The crushers, screens, or conveyors were equipped with Water Sprays to control fugitive dust. See the attachment for additional information. EMISSION INVENTORY: Listed before are the Actual Emissions Inventory provided from Granite Construction Company – Wells and Wells South Aggregate Facilities. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN129050010-21, dated June 30, 2021 is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 1719.00 N/A Carbon Monoxide 2.19 2.13 Nitrogen Oxides 19.45 5.52 Particulate Matter - PM10 28.64 6.34 Particulate Matter - PM2.5 2.68 1.25 Sulfur Dioxide 0.02 0.003 Volatile Organic Compounds 0.42 0.41 Acetaldehyde (CAS #75070) 260 (lbs) N/A Generic HAPs (CAS #GHAPS) 740 (lbs) N/A PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Granite Construction Company is not in compliance with AO Conditions II.B.3.e of Approval Order (AO) DAQE-AN129050010-21, dated June 30, 2021. The new AO Modification for Granite Construction Company was approved on March 15, 2024. No further action is required at this time. See the email attachment for additional information. 12 HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: The new AO Modification for Granite Construction Company was approved on March 15, 2024. Verify the acreage of the total disturbed area for compliance. Required PPE includes hard hat, safety glasses, reflective glasses, and steel-toe boots. RECOMMENDATION FOR NSR: None at this time. ATTACHMENTS: Visible Emissions Observation Form, GPS measurements, Fuel Certification, Email, Initial VEOs