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HomeMy WebLinkAboutDAQ-2024-0048351 DAQC-CI128940001-24 Site ID 12894 (B1) MEMORANDUM TO: FILE – NIELSON CONSTRUCTION COMPANY – Huntington Asphalt and Aggregate Pit THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jordan Garahana, Environmental Scientist DATE: January 24, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Emery County INSPECTION DATE: September 7, 2023 SOURCE LOCATION: About 2 miles north and west of Huntington on Hwy 31 Emery County, Utah SOURCE CONTACTS: Christian Boudreau, Environmental Specialist 801-871-6704 christian.boudreau@stakerparson.com OPERATING STATUS: Not operating at the time of inspection. PROCESS DESCRIPTION: Nielson operates an asphalt production plant. Aggregate materials are trucked in from other pits and are stockpiled for use in the asphalt plant. Asphalt is produced in a Gencor drum mix asphalt plant with baghouse and associated equipment. Rotomilled asphalt is stored near the entry to the pit. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN128940010-19, dated March 14, 2019 NSPS (Part 60) -OOO : Standards of Performance for Nonmetallic Mineral Processing Plants, NSPS (Part 60) - IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60) - A: General Provisions, MACT (Part 63) -A : General Provisions, MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: Name of Permittee: Permitted Location: Nielson Construction Company Huntington Asphalt and Aggregate Pit 825 North Loop Road PO Box 620 About 2 miles north and west of Huntington on Hwy 31 Huntington, UT 84528 Emery County, UT 2 SIC Code: 1442: (Construction Sand & Gravel) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 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] Status: In Compliance. No breakdowns have occurred since the previous inspection. The 2020 Emission Inventory was submitted on time. Source was reminded of the submission date of the 2023 Emission Inventory. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Huntington Pit II.A.2 One (1) Gencor Drum Mix Asphalt Plant Rated Capacity: 400 tph Control Device: Baghouse NSPS Applicability: Subpart I II.A.3 One (1) Gencor Baghouse Type: Reverse Air Maximum Flow Rate: 89,217 ACFM Average Flow Rate: 49,133 ACFM NSPS Applicability: Subpart I 3 II.A.4 Two (2) Asphalt Storage Silos Capacity: 150 Tons Each II.A.5 Liquid Asphalt Storage Tanks* One (1) Tank Capacity: 30,000 Gallons One (1) Split tank Capacity: 10,000 and 20,000 Gallons NSPS Applicability: Subpart I II.A.6 Hot Oil Heater Rating: 1.4 MMBtu/hr Fuel: Waste Oil NSPS Applicability: Subpart I II.A.7 One (1) 4-Bin Feeder* Capacity: 400 TPH NSPS Applicability: Subpart OOO II.A.8 One (1) 2-Bin Feeder* Capacity: 400 TPH NSPS Applicability: Subpart OOO II.A.9 One (1) Lime Silo* Capacity: 45 Tons Control: Bin Vent NSPS Applicability: Subpart I II.A.10 2-Bin RAP Feeder* Capacity: 400 TPH NSPS Applicability: Subpart OOO II.A.11 Fly Ash Silo* Capacity: 150 Tons Control: Bin Vent NSPS Applicability: Subpart I II.A.12 One (1) Jaw Crusher* Capacity: 500 TPH NSPS Applicability: Subpart OOO II.A.13 Three (3) Cone Crushers* Capacity: 400 TPH NSPS Applicability: Subpart OOO II.A.14 Five (5) Triple Deck Screens* Size: 8' X 20' Each NSPS Applicability: Subpart OOO II.A.15 One (1) Scalper Screen* Size: 5' x 12' Each NSPS Applicability: Subpart OOO II.A.16 One (1) Hopper* Capacity: 400 TPH NSPS Applicability: Subpart OOO II.A.17 Two (2) Impact Crushers* Capacity 400 TPH NSPS Applicability: Subpart OOO 4 II.A.18 Associated Equipment Both aggregate and asphalt production equipment include: conveyors, drag elevator, weigh conveyors, stackers, loaders, and dozer, haul and water trucks. II.A.19 One (1) Emergency Generator Rating: 800 kW Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ *Indicates new equipment Status: In Compliance. No unapproved equipment was observed at the time of inspection. All equipment associated with aggregate production has been removed from the site. II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any installation of this AO to exceed 20% opacity. [R307-201-3] II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. No visible emissions were observed at the time of inspection. See the attachments section for additional information. II.B.2 HMA Plant Requirements II.B.2.a The owner/operator shall not produce more than 728,000 tons of asphalt per rolling 12-month period, and 5,600 tons of asphalt per day. [R307-401-8] II.B.2.a.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of production shall be kept for all periods when the plant is in operation. Production shall be determined by scale-house records or vendor receipts. The records of production shall be kept on a daily basis. [R307-401-8] II.B.2.a.2 The owner/operator shall weigh and account for all hot mix asphalt prior to the hot mix asphalt leaving the site. [R307-401-8] Status: In Compliance. The rolling 12-month total from September 2022 to August 2023, for the amount of asphalt produced is as follows: 43,404.1 tons of asphalt produced The daily total for asphalt produced for any day during the rolling 12-month period was under 1,500 tons of asphalt produced. No asphalt production exceeded 5,600 tons on any single day of operations. That total was obtained over the phone on November 30, 2023, from Christian Boudreau. Weight is determined by scale house and weighed before leaving the property. See the attachments section for additional information. II.B.2.b The owner/operator shall only operate the asphalt plant for 16 hours per day from March through November. The owner/operator shall not operate the asphalt plant from December through February. [R307-401-8] 5 II.B.2.b.1 Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. The records of operation shall be kept on a daily basis and shall include the time the asphalt plant starts operation, the time the asphalt plant ceases operation, and the total hours of operation for the day. [R307-401-8] Status: In Compliance. The hot mix asphalt plant did not operate for more than 16 hours per day within the last rolling 12-month period, according to daily runtime logs. See the attachments section for additional information. II.B.2.c The owner/operator shall use a baghouse to control particulate emissions from the hot mix asphalt plant. All exhaust air from the drum mixer shall be routed through the baghouse before being vented to the atmosphere. [R307-401-8] II.B.2.c.1 The owner/operator shall maintain the static pressure differential across the baghouse between 2.0 to 5.0 inches of water column on the pressure gauge. [R307-401-8] II.B.2.c.2 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The pressure gauge shall measure the pressure drop in one (1)-inch water column increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. [R307-401-8] Status: In Compliance. The baghouse gauge read at 0 inches of water column at the time of inspection, as the plant was not in operation. The baghouse gauge did not operate outside the permitted ranges within the last rolling 12-month period. The gauge was last calibrated on March 31, 2023. See the attachments section for additional information. II.B.2.d The owner/operator shall not allow visible emissions from the baghouse on site to exceed 10 percent opacity. [R307-401-8] Status: In Compliance. No visible emissions were observed from the baghouse at the time of inspection. See the attachments section for additional information. II.B.2.e Emissions to the atmosphere from the indicated emission point shall not exceed the following rates and concentrations: Source: Gencor 400 tph Hot Mix Asphalt Plant Baghouse Exhaust Stack Pollutant lb/hr grain/dscf (68 degrees F, 29.92 in Hg) TSP (virgin & RAP) 10.07 0.020 PM10 (virgin & RAP) 8.05 0.016 [R307-401-8] Status: Out of Compliance. The source operated the hot mix asphalt plant without conducting a stack test outside of the 5 years’ timeframe for stack testing. A Compliance Advisory (DAQC-1100-23) was issued. Nielson Construction sent a response letter stating the hot mix asphalt plant hasn't met enough production to meet the conditions for stack testing and requested a variance for stack testing. Upon reviewing that information, a Warning Letter (DAQC-1222-23) was issued stating that the request for variance was accepted and that if Nielson Construction has enough production in the hot mix asphalt plant to meet the stack testing parameters that they must stack test and notify the DAQ as soon as a testing date is known. If the source cannot stack test by October 25, 2024, they must notify the DAQ an update to the request for variance letter stating why they are unable to stack test the hot mix asphalt plant. No further action is currently recommended. 6 II.B.2.e.1 Stack testing to show compliance with the emission limitations stated in the above condition shall be performed as specified below: Emission Point: Hot Mix Asphalt Plant Baghouse Exhaust Stack TSP (virgin & RAP): Initial Test Completed: 9/21/2011 PM10 (virgin & RAP): Test every five years or sooner if directed by the Director. Tests may be required if the source is suspected to be in violation with other conditions of this AO. Compliance testing shall not be required for both virgin and recycled materials during the same testing period. Testing shall be performed for the product being produced during the time of testing. [R307-165] Status: Out of Compliance. The source operated the hot mix asphalt plant without conducting a stack test outside of the 5 years’ timeframe for stack testing. A Compliance Advisory (DAQC-1100-23) was issued. Nielson Construction sent a response letter stating the hot mix asphalt plant hasn't met enough production to meet the conditions for stack testing and requested a variance for stack testing. Upon reviewing that information, a Warning Letter (DAQC-1222-23) was issued stating that the request for variance was accepted and that if Nielson Construction has enough production in the hot mix asphalt plant to meet the stack testing parameters that they must stack test and notify the DAQ as soon as a testing date is known. If the source cannot stack test by October 25, 2024, they must notify the DAQ an update to the request for variance letter stating why they are unable to stack test the hot mix asphalt plant. No further action is currently recommended. II.B.2.e.2 Notification: At least 30 days prior to conducting any emission testing required under any part of UAC, R307, the owner or operator shall notify the Director of the date, time and place of such testing and, if determined necessary by the Director, the owner or operator shall attend a pretest conference. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. The pretest conference shall include representation from the owner/operator, the tester, and the Director. [R307-165] II.B.2.e.3 Sample Location: The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-401-8] II.B.2.e.4 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director. [R307-401-8] II.B.2.e.5 PM10: For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201 or 201a. The back half condensables shall also be tested using the method specified by the Director. All particulate captured shall be considered PM10. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The back half condensables shall also be tested using the method specified by the Director. The portion of the front half of the catch considered PM10 shall be based on information in Appendix B of the fifth addition of AP-42 or other data acceptable to the Director. 7 The back half condensables shall not be used for compliance demonstration but shall be used for inventory purposes. [R307-401-8] II.B.2.e.6 Calculations: To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-401-8] II.B.2.e.7 Existing Source Operation: For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. In all cases, when testing for PM10 emissions during manufacture of recycled asphalt, recycled asphalt shall be introduced into the plant at a rate no less than 15% of the plant production (i.e. if the plant is producing 300 tons per hour of finished product, then asphalt to be recycled shall be introduced into the plant at a rate no less than 45 tons per hour). [R307-401-8] II.B.3 Aggregate Pit Requirements II.B.3.a The owner/operator shall not produce more than 624,000 tons of processed aggregate material and processed rotomill material combined per rolling 12-month period. [R307-401-8] II.B.3.a.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of production shall be kept for all periods when the plant is in operation. Production shall be determined by scale-house records or vendor receipts. The records of production shall be kept on a daily basis. [R307-401-8] II.B.3.a.2 The owner/operator shall weigh and account for all aggregate material prior to the aggregate material leaving the site. [R307-401-8] Status: Not Applicable. No aggregate has been produced at the site within the last 12-month period. See the attachments section for additional information. II.B.3.b The owner/operator shall not operate the Aggregate Plant (including haul road use and storage pile loading or unloading) more than the allotted times for the following months: A. March through October: 16 hours per day B. November: 12 hours per day C. December through February: 8 hours per day. [R307-401-8] II.B.3.b.1 Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. The records of operation shall be kept on a daily basis and shall include the time the aggregate processing plant starts operation, the time the aggregate processing plant ceases operation, and the total hours of operation for the day. [R307-401-8] Status: Not Applicable. No aggregate has been produced at the site within the last 12-month period. See the attachments section for additional information. II.B.3.c The owner/operator shall not allow visible emissions to exceed the following: A. Crushers- 12% B. Screens - 7% C. Conveyors - 7%. [40 CFR 60 Subpart OOO, R307-401-8] Status: Not Applicable. No visible emissions were observed at the time of inspection. No aggregate has been produced at the site within the last 12-month period. See the attachments section for additional information. 8 II.B.3.d The owner/operator shall install water sprays on all crushers, all screens, all conveyor transfer points, and all conveyor drop points at each location to control emissions. Sprays shall operate as required to ensure the opacity limits in this AO are not exceeded. [R307-401-8] Status: Not Applicable. No aggregate has been produced at the site within the last 12-month period. All equipment associated with aggregate crushing has been removed from the site. See the attachments section for additional information. II.B.3.e The owner/operator shall perform monthly periodic inspections to check that water is flowing to discharge spray nozzles associated with each crusher, screen, and conveyor. If the owner/operator finds that water is not flowing properly during an inspection of the water spray nozzles, the owner/operator shall initiate corrective action within 24 hours and complete corrective action as expediently as practical. [R307-401-8] II.B.3.e.1 Records of the water sprays inspections shall be kept and maintained in a logbook for all periods when the plant is in operation. The records shall include the following items: A. Date the inspections were made B. Any corrective actions taken C. Control mechanism used if sprays are not operating. [40 CFR 60 Subpart OOO, R307-401-8] Status: Not Applicable. No aggregate has been produced at the site within the last 12-month period. All equipment associated with aggregate crushing has been removed from the site. See the attachments section for additional information. II.B.3.f 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. Records of initial performance tests shall be kept and maintained on site for the life of the equipment. [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.f.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, R307-401-8] II.B.3.f.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: Not Applicable. No aggregate has been produced at the site within the last 12-month period. All equipment associated with aggregate crushing has been removed from the site. See the attachments section for additional information. II.B.4 Emergency Generator Engine Requirements II.B.4.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] 9 II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter on the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. The rolling 12-month total for generator hours is as follows: 6 hours of operation A non-resettable meter is installed on the generator. A log is kept for when the generator is run and how many hours it was used. See the attachments section for additional information. II.B.5 All Haul Roads and Fugitive Dust Sources Requirements II.B.5.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources on site to exceed 20 percent opacity at all times. [R307-205-4] II.B.5.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-205-4] Status: In Compliance. No visible emissions from the haul road were observed at the time of inspection. See the attachments section for additional information. II.B.5.b The owner/operator shall comply with the following to maintain the opacities listed in this AO: A. Paved Haul Roads: Sweep and flush with water B. Unpaved Haul Roads and Operational Areas: Apply water applications and cover with road-base material The owner/operator may stop applying water to haul roads and operational areas when the temperature is below freezing and may stop sweeping the paved haul roads when the haul roads are covered with snow or ice. [R307-401-8] II.B.5.b.1 Records of sweeping and water application to all roads shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature is below freezing E. Records shall note if the paved haul roads are covered with snow or ice. [R307-401-8] Status: In Compliance. Records of water usage or sweeping for fugitive dust control mitigation are maintained. See the attachments section for additional information. II.B.5.c The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive Emission and Fugitive Dust sources on site. [R307-205] Status: In Compliance. The source maintains an FDCP and follows all rules in R307-205. See the attachments section for additional information. 10 II.B.6 Fuel Requirements II.B.6.a The owner/operator shall use natural gas, propane, fuel oil, on-specification used oil as defined in R315-15, or any combination thereof as fuel in the hot mix asphalt plants. [R307-401-8] Status: In Compliance. According to a fuel invoice from Pilot Thomas, the fuel utilized onsite is ULSD #2 diesel fuel. See the attachments section for additional information. II.B.6.b The sulfur content of any used fuel oil, fuel oil or diesel burned in the asphalt plant shall not exceed 0.5 percent by weight. The sulfur content of any diesel fuel consumed in any stationary engine on site shall not exceed 15 ppm. [R307-401-8] and [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.6.b.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved equivalent. Certification of used oil or diesel fuel shall be either by the owner/operator's own testing or by test reports from the diesel fuel marketer. [R307-401-8] Status: In Compliance. According to a fuel invoice from Pilot Thomas, the fuel utilized onsite is ULSD #2 diesel fuel. See the attachments section 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 Status: Not Applicable. All equipment associated with aggregate operations has been removed from the site and the site has not produced any aggregate within the last 12-month period. See the attachments section for additional information. NSPS (Part 60)- IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. The generator was manufactured post-2006, making this subpart applicable. The generator is operated according to the manufacturer’s specifications and has a non-resettable meter. The generator is operated using diesel fuel that is categorized and ULSD, and only operated for 6 hours within the rolling 12-month period. NSPS (Part 60) - A: General Provisions Status: Not Applicable. Compliance is not applicable with all corresponding subparts. MACT (Part 63) -A: General Provisions Status: In Compliance. Compliance with Subpart A is determined by compliance with applicable subparts. In compliance with Subpart ZZZZ. 11 MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. A non-resettable meter is installed on the generator and is operated according to the manufacturer’s specifications. The running 12-month total for hours the generator ran was 6 hours. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. According to the fuel invoice from Pilot Thomas fuels, the fuel utilized onsite is characterized as ULSD. See the attachments section for additional information. Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205] Status: In Compliance. Source maintains an FDCP and there were no visible emissions from fugitive dust during the time of inspection. See the attachments section for additional information. Standards of Performance for New Stationary Sources [R307-210] Status: In Compliance. Compliance with R307-210 is determined by compliance with applicable federal subparts. In Compliance with Subpart IIII. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. Compliance with R307-214 is determined by compliance with applicable federal subparts. In Compliance with Subpart ZZZZ. EMISSION INVENTORY: Listed below are the Actual Emissions Inventory provided by Nielson Construction Company - Huntington Asphalt and Aggregate Pit. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN128940010-19, dated March 14, 2019, is provided. PTE are supplied for supplemental purposes only. The 2020 Emission Inventory is listed below and can be found in the attachments section. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 13303.76 Carbon Monoxide 48.85 Nitrogen Oxides 20.47 Particulate Matter - PM10 27.93 Particulate Matter - PM2.5 10.85 Sulfur Dioxide 21.12 Volatile Organic Compounds 18.07 12 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr 2-Methynapthalene (CAS #91576) 196 Acetaldehyde (CAS #75070) 946 Benzene (Including Benzene From Gasoline) (CAS #71432) 288 Ethyl Benzene (CAS #100414) 1866 Formaldehyde (CAS #50000) 2360 Generic HAPs (CAS #GHAPS) 376 Hexane (CAS #110543) 684 Naphthalene (CAS #91203) 512 Propionaldehyde (CAS #123386) 104 Quinone (CAS #106514) 116 Toluene (CAS #108883) 2120 Xylenes (Isomers And Mixture) (CAS #1330207) 294 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN128940010-19, dated March 14, 2019: Out of compliance with AO Condition II.B.2.e.1. A Compliance Advisory (DAQC-1100-23) was issued for operating the hot mix asphalt plant without conducting a stack test. The source responded to the CA by applying for another variance for conducting the stack test, as they noted that there was not enough production at any time during the operation of the hot plant to conduct a stack test. The variance was granted and a Warning Letter (DAQC-1222-23) was issued, stating the source needs to notify the DAQ annual updates on the variance if stack testing cannot be conducted on the hot plant, or if there is enough production in the hot mix plant that stack testing must be conducted and that the DAQ must be notified as soon as the testing date is known. No further action is currently recommended at this time. In compliance with the rest of the conditions listed in this AO. Records were made available upon request. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect after October 25, 2024, to see if they have filed for another variance for the hot mix plant or if they have been able to conduct the stack test. Contact Christian Boudreau before conducting the inspection to see what days and times the plant is running. ATTACHMENTS: Applicable Supporting Documentation Included 2020 Emissions Inventory Report Emissions Summary for Nielson Construction Company- Huntington Asphalt and Aggregate Pit (12894) CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS Pollutant Code/CAS #Pollutant Name Emissions (tons, excluding tailpipe) Tailpipe Emissions (tons) Total Emissions (tons)* PM10-PRI PM10 Primary (Filt + Cond)3.41798 0.04561 3.46359 PM10-FIL PM10 Filterable 2.37208 <.00001 2.37208 PM25-PRI PM2.5 Primary (Filt + Cond)1.09464 0.04424 1.13888 PM25-FIL PM2.5 Filterable 0.44254 <.00001 0.44254 SO2 Sulfur Dioxide 0.00966 0.00119 0.01086 NOX Nitrogen Oxides 2.06312 0.79233 2.85545 VOC Volatile Organic Compounds 0.60888 0.06151 0.67039 CO Carbon Monoxide 0.53437 0.3247 0.85907 7439921 Lead 0.01609 <.00001 0.01609 HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions (tons)* 50000 Formaldehyde (HAP)VOC 0.09238 540841 2,2,4-Trimethylpentane (HAP)VOC 0.00119 N590 Polycyclic aromatic compounds (includes 25 specific compounds) (HAP)- 0.02622 *Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated. 1/2 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r2657837400523145…1/13 Jordan Garahana <jordangarahana@utah.gov> Records Request for Nielson Construction Huntington Asphalt Plant 20 messages Jordan Garahana <jordangarahana@utah.gov>Mon, Sep 11, 2023 at 11:51 AM To: "Scovill, Nakeasha (Staker Parson)" <nakeasha.scovill@stakerparson.com> Hello Nakeasha, I conducted an inspection of the Nielson Construction Asphalt Plant in Huntington on Thursday, September 7th, and as part of that inspection I am looking for some records to help complete my inspection. These are the records I am looking for: II.B.2.a - The owner/operator shall not produce more than 728,000 tons of asphalt per rolling 12-month period, and 5,600 tons of asphalt per day. I need a rolling 12-month total of asphalt produced through the plant II.B.2.b- The owner/operator shall only operate the asphalt plant for 16 hours per day from March through November. The owner/operator shall not operate the asphalt plant from December through February. I need a log that shows the hours of operation and that the asphalt plant isn't operated from December through February of 2022-2023 II.B.2.c.2- The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The pressure gauge shall measure the pressure drop in one (1)-inch water column increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. I need a record that shows the baghouse pressure gauge is calibrated or replaced every 12 months. II.B.3.a- The owner/operator shall not produce more than 624,000 tons of processed aggregate material and processed rotomill material combined per rolling 12-month period. I need a rolling 12-motnh total of aggregate processed at the Huntington Asphalt site. II.B.3.b- The owner/operator shall not operate the Aggregate Plant (including haul road use and storage pile loading or unloading) more than the allotted times for the following months: A. March through October: 16 hours per day B. November: 12 hours per day C. December through February: 8 hours per day I need a record that shows the hours of operation for the aggregate plant that shows the hours of operation for these specific timeframes II.B.3.e.1- Records of the water sprays inspections shall be kept and maintained in a logbook for all periods when the plant is in operation. The records shall include the following items: A. Date the inspections were made B. Any corrective actions taken C. Control mechanism used if sprays are not operating I need a record that shows the spray nozzles on the crushers, screens, and conveyor transfer and drop points are checked monthly and a log that shows if any of the equipment was failing what corrective actions were taken to fix the sprays or what control mechanism was used if the sprays were not operating II.B.3.f- 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 start-up. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO. Records of initial performance tests shall be kept and maintained on site for the life of the equipment. I need a record of the initial VEO tests for the equipment onsite II.B.4.a- The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. I need the rolling 12-month total for emergency generator hours onsite. II.B.5.b- The owner/operator shall comply with the following to maintain the opacities listed in this AO: A. Paved Haul Roads: Sweep and flush with water. 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r2657837400523145…2/13 B. Unpaved Haul Roads and Operational Areas: Apply water applications and cover with road-base material. The owner/operator may stop applying water to haul roads and operational areas when the temperature is below freezing and may stop sweeping the paved haul roads when the haul roads are covered with snow or ice. I need a copy of the log of times water application was used on paved and unpaved haul roads to help mitigate fugitive dust. II.B.5.c- The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive Emission and Fugitive Dust sources on site. I need a copy of the FDCP for the site. II.B.6.b- The sulfur content of any used fuel oil, fuel oil or diesel burned in the asphalt plant shall not exceed 0.5 percent by weight. The sulfur content of any diesel fuel consumed in any stationary engine on site shall not exceed 15 ppm. I need a certificate or bill of sale that demonstrates the sulfur content of the diesel fuel or fuel oil used on site does not exceed 0.5 percent by weight for the asphalt plant and the sulfur content does not exceed 15 ppm for the diesel fuel used by the stationary engines onsite. Those are all the records I am requesting, but I do have one question in regards to the asphalt operations onsite. Has the hot plant onsite run at any time since August of 2022? Is there any update on the status of the plants operations? Thanks for answering my question as well as sending me the records I have requested. I have attached my VEO form from my inspection for your records as well. Please have those records sent to me by Monday, September 18. Please let me know if you have any questions about the records or information I am asking for. Thanks, Jordan Garahana -- Jordan Garahana Environmental Scientist | Minor Source Compliance M: (385) 271-2871 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Nielson Asphalt VEO 2023.pdf 1298K Scovill, Nakeasha (Staker Parson) <nakeasha.scovill@stakerparson.com>Tue, Sep 12, 2023 at 12:11 PM To: Jordan Garahana <jordangarahana@utah.gov> Cc: "Boudreau, Christian (Staker & Parson)" <christian.boudreau@stakerparson.com> Hello Jordan, We will start working to put all these records together. Thank you, 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r2657837400523145…3/13 Nakeasha Scovill Environmental Specialist West Division Staker Parson Materials and Construction A CRH COMPANY 89 West 13490 South Draper, Utah 84020 O +1 (801) 871-6704 M +1 (385) 266-2060 E nakeasha.scovill@stakerparson.com From: Jordan Garahana <jordangarahana@utah.gov> Sent: Monday, September 11, 2023 11:51 AM To: Scovill, Nakeasha (Staker Parson) <nakeasha.scovill@stakerparson.com> Subject: [EXT] Records Request for Nielson Construction Huntington Asphalt Plant CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you are expecting this email and know the contents are safe. If you believe this email may be phishing or malicious, please use the Report Phish button. [Quoted text hidden] ATTENTION: Ce courriel vient de l'exterieur de l'entreprise. Ne cliquez pas sur les liens, et n'ouvrez pas les pièces jointes, à moins que vous ne connaissiez l'expéditeur du courriel et savez que le contenu est sécuritaire. Si vous pensez qu’il s’agit d’un courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentative d’hameçonnage. Jordan Garahana <jordangarahana@utah.gov>Thu, Sep 21, 2023 at 11:58 AM To: "Scovill, Nakeasha (Staker Parson)" <nakeasha.scovill@stakerparson.com> Cc: "Boudreau, Christian (Staker & Parson)" <christian.boudreau@stakerparson.com> Hello Nakeasha, I am emailing you to ask if there is any update on the records I requested for the Nielson Construction Asphalt Plant in Huntington? Please let me know as soon as you can. Thanks, 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r2657837400523145…4/13 Jordan [Quoted text hidden] Scovill, Nakeasha (Staker Parson) <nakeasha.scovill@stakerparson.com>Thu, Sep 21, 2023 at 3:37 PM To: Jordan Garahana <jordangarahana@utah.gov> Cc: "Boudreau, Christian (Staker & Parson)" <christian.boudreau@stakerparson.com> Hey Jordan, We should have this to you by tomorrow. I apologize for the delay. [Quoted text hidden] Scovill, Nakeasha (Staker Parson) <nakeasha.scovill@stakerparson.com>Fri, Sep 22, 2023 at 2:44 PM To: Jordan Garahana <jordangarahana@utah.gov> Cc: "Boudreau, Christian (Staker & Parson)" <christian.boudreau@stakerparson.com> Jordan, Sorry again for the delay. Is there any chance you can give us until next Friday to get all these records to you? [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Mon, Sep 25, 2023 at 9:48 AM To: "Scovill, Nakeasha (Staker Parson)" <nakeasha.scovill@stakerparson.com> Cc: "Boudreau, Christian (Staker & Parson)" <christian.boudreau@stakerparson.com> Nakeasha, I will allow you to send me the records by this Friday. Please have them to me by then. Thanks, Jordan [Quoted text hidden] Boudreau, Christian (Staker & Parson) <christian.boudreau@stakerparson.com>Thu, Sep 28, 2023 at 2:19 PM To: "jordangarahana@utah.gov" <jordangarahana@utah.gov> Jordan, Sorry for the delay, responses noted below, and documentation attached. Let me know if you have any further questions. Thank you, Christian Boudreau Environmental Specialist 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r2657837400523145…5/13 West Division Staker Parson A CRH COMPANY 89 West 13490 South Draper, Utah 84020 O +1 (801) 871 6704 C +1 (385) 318 6938 E christian.boudreau@stakerparson.com From: Jordan Garahana <jordangarahana@utah.gov> Sent: Monday, September 11, 2023 11:51 AM To: Scovill, Nakeasha (Staker Parson) <nakeasha.scovill@stakerparson.com> Subject: [EXT] Records Request for Nielson Construction Huntington Asphalt Plant CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you are expecting this email and know the contents are safe. If you believe this email may be phishing or malicious, please use the Report Phish button. Hello Nakeasha, I conducted an inspection of the Nielson Construction Asphalt Plant in Huntington on Thursday, September 7th, and as part of that inspection I am looking for some records to help complete my inspection. These are the records I am looking for: II.B.2.a - The owner/operator shall not produce more than 728,000 tons of asphalt per rolling 12-month period, and 5,600 tons of asphalt per day. I need a rolling 12-month total of asphalt produced through the plant. 43,404.1 tons. II.B.2.b- The owner/operator shall only operate the asphalt plant for 16 hours per day from March through November. The owner/operator shall not operate the asphalt plant from December through February. I need a log that shows the hours of operation and that the asphalt plant isn't operated from December through February of 2022-2023. Operating hours spreadsheet attached. II.B.2.c.2- The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The pressure gauge shall measure the pressure drop in one (1)-inch water column increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. I need a record that shows the baghouse pressure gauge is calibrated or replaced every 12 months. Pressure gauge last calibrated 03/31/2023. II.B.3.a- The owner/operator shall not produce more than 624,000 tons of processed aggregate material and processed rotomill material combined per rolling 12-month period. I need a rolling 12-motnh total of aggregate processed at the Huntington Asphalt site. Not applicable, no aggregates being processed on site. 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r2657837400523145…6/13 II.B.3.b- The owner/operator shall not operate the Aggregate Plant (including haul road use and storage pile loading or unloading) more than the allotted times for the following months: A. March through October: 16 hours per day B. November: 12 hours per day C. December through February: 8 hours per day I need a record that shows the hours of operation for the aggregate plant that shows the hours of operation for these specific timeframes. Not applicable, no aggregate plant operating on site. II.B.3.e.1- Records of the water sprays inspections shall be kept and maintained in a logbook for all periods when the plant is in operation. The records shall include the following items: A. Date the inspections were made B. Any corrective actions taken C. Control mechanism used if sprays are not operating I need a record that shows the spray nozzles on the crushers, screens, and conveyor transfer and drop points are checked monthly and a log that shows if any of the equipment was failing what corrective actions were taken to fix the sprays or what control mechanism was used if the sprays were not operating. Not applicable, no aggregate plant operating on site. II.B.3.f- 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 start- up. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO. Records of initial performance tests shall be kept and maintained on site for the life of the equipment. I need a record of the initial VEO tests for the equipment onsite. Not applicable, no aggregate plant operating on site. II.B.4.a- The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12- month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. I need the rolling 12-month total for emergency generator hours onsite. 6 hours. II.B.5.b- The owner/operator shall comply with the following to maintain the opacities listed in this AO: A. Paved Haul Roads: Sweep and flush with water. B. Unpaved Haul Roads and Operational Areas: Apply water applications and cover with road-base material. The owner/operator may stop applying water to haul roads and operational areas when the temperature is below freezing and may stop sweeping the paved haul roads when the haul roads are covered with snow or ice. I need a copy of the log of times water application was used on paved and unpaved haul roads to help mitigate fugitive dust. Attached. II.B.5.c- The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive Emission and Fugitive Dust sources on site. I need a copy of the FDCP for the site. FDCP attached. II.B.6.b- The sulfur content of any used fuel oil, fuel oil or diesel burned in the asphalt plant shall not exceed 0.5 percent by weight. The sulfur content of any diesel fuel consumed in any stationary engine on site shall not exceed 15 ppm. I need a certificate or bill of sale that demonstrates the sulfur content of the diesel fuel or fuel oil used on site does not exceed 0.5 percent by weight for the asphalt plant and the sulfur content does not exceed 15 ppm for the diesel fuel used by the stationary engines onsite. Fuel receipts attached. Those are all the records I am requesting, but I do have one question in regards to the asphalt operations onsite. Has the hot plant onsite run at any time since August of 2022? Is there any update on the status of the plants operations? 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r2657837400523145…7/13 Yes, the plant has run since August 2022. No update on operations. Thanks for answering my question as well as sending me the records I have requested. I have attached my VEO form from my inspection for your records as well. Please have those records sent to me by Monday, September 18. Please let me know if you have any questions about the records or information I am asking for. Thanks, Jordan Garahana -- Jordan Garahana Environmental Scientist | Minor Source Compliance M: (385) 271-2871 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. ATTENTION: Ce courriel vient de l'exterieur de l'entreprise. Ne cliquez pas sur les liens, et n'ouvrez pas les pièces jointes, à moins que vous ne connaissiez l'expéditeur du courriel et savez que le contenu est sécuritaire. Si vous pensez qu’il s’agit d’un courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentative d’hameçonnage. -- Jordan Garahana Environmental Scientist | Minor Source Compliance M: (385) 271-2871 airquality.utah.gov 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r2657837400523145…8/13 Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 4 attachments 785299.pdf 175K FDCP - Huntington HMA.pdf 226K 20230922 Huntington HMA - Operating Hours.xls 44K 2023-09-26_132558.pdf 3572K Jordan Garahana <jordangarahana@utah.gov>Mon, Oct 2, 2023 at 12:26 PM To: Chad Gilgen <cgilgen@utah.gov> Hey Chad, Here is the information I received from Nielson Construction for the Huntington Asphalt operations. Thanks, Jordan [Quoted text hidden] 4 attachments 785299.pdf 175K FDCP - Huntington HMA.pdf 226K 20230922 Huntington HMA - Operating Hours.xls 44K 2023-09-26_132558.pdf 3572K Jordan Garahana <jordangarahana@utah.gov>Wed, Oct 4, 2023 at 2:54 PM To: "Boudreau, Christian (Staker & Parson)" <christian.boudreau@stakerparson.com> Cc: "Scovill, Nakeasha (Staker Parson)" <nakeasha.scovill@stakerparson.com> Hey Christian, Thank you for the information you provided me for my inspection. I wanted to let you know that I will be sending a Compliance Advisory here in the next couple of days due to Nielson Construction operating the hot mix asphalt plant without conducting a stack test within 5 years of the previous stack test. What is a good address to send the compliance advisory to? Please let me know if you have any questions about the compliance advisory or if you have any questions about the process. Thanks, Jordan [Quoted text hidden] 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r2657837400523145…9/13 Boudreau, Christian (Staker & Parson) <christian.boudreau@stakerparson.com>Thu, Oct 5, 2023 at 9:08 AM To: Jordan Garahana <jordangarahana@utah.gov> 89 W 13490 S Draper, UT 84020 [Quoted text hidden] Boudreau, Christian (Staker & Parson) <christian.boudreau@stakerparson.com>Wed, Oct 25, 2023 at 10:23 AM To: Jordan Garahana <jordangarahana@utah.gov> Jordan, I’ve attached our response to the Compliance Advisory dated October 12, 2023. As you know, we have tried repeatedly to get the Huntington HMA plant tested over the past few years but have either not had the production or have run into other issues that have kept us from being able to test. If the attached letter should be addressed to someone else or needs to be mailed, please let me know. Feel free to call if you have any questions. Thank you, Christian Boudreau Environmental Specialist West Division Staker Parson A CRH COMPANY 89 West 13490 South Draper, Utah 84020 O +1 (801) 871 6704 C +1 (385) 318 6938 E christian.boudreau@stakerparson.com From: Jordan Garahana <jordangarahana@utah.gov> Sent: Wednesday, October 4, 2023 2:55 PM 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r265783740052314…10/13 [Quoted text hidden] [Quoted text hidden] Huntington-Request for Variance-Stack Testing-231025.pdf 133K Jordan Garahana <jordangarahana@utah.gov>Wed, Oct 25, 2023 at 10:33 AM To: Chad Gilgen <cgilgen@utah.gov> Here is the response from Staker Parson for the CA I issued for the Nielson Construction Huntington Asphalt Pit in regards to operating the hot plant without stack testing. They are requesting another variance for the stack test requirement in their AO. Thanks, Jordan [Quoted text hidden] Huntington-Request for Variance-Stack Testing-231025.pdf 133K Chad Gilgen <cgilgen@utah.gov>Mon, Oct 30, 2023 at 4:49 PM To: Jordan Garahana <jordangarahana@utah.gov> Hey Jordan, Sorry I haven't gotten back to you on this one yet. I'm going to discuss it with Jay tomorrow morning then I'll get a response to you after that. Thanks, 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] Chad Gilgen <cgilgen@utah.gov>Tue, Oct 31, 2023 at 9:32 AM To: Jordan Garahana <jordangarahana@utah.gov> Hello Jordan, Let's close this one out with a Warning Letter and add some additional language in stating they need to do the following: Stack test once they have the production required and notify the DAQ of the testing date as soon as it is known. Provide an annual update to the request for variance letter to the DAQ, starting no later than October 25, 2024, for each year they are unable to stack test. Thanks and let me know if you'd like any assistance on putting the letter together. Chad 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r265783740052314…11/13 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] Jordan Garahana <jordangarahana@utah.gov>Tue, Oct 31, 2023 at 9:49 AM To: Chad Gilgen <cgilgen@utah.gov> Hey Chad, Thanks for the feedback regarding this issue with Nielson Construction. I will get working on that warning letter soon and will send you draft once I have it completed. Thanks, Jordan [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Tue, Oct 31, 2023 at 10:21 AM To: Jordan Garahana <jordangarahana@utah.gov> Hi Jordan, Thanks, that sounds good. Please email Christian and let him know we have accepted their request for variance and will be closing out the Compliance Advisory with a Warning Letter. 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] Jordan Garahana <jordangarahana@utah.gov>Tue, Oct 31, 2023 at 11:31 AM To: "Boudreau, Christian (Staker & Parson)" <christian.boudreau@stakerparson.com> Hey Christian, Thank you for your response letter to the Compliance Advisory that was issued. We have accepted your request for a variance for stack testing the hot asphalt plant at the Huntington Asphalt Plant. I will be closing out the Compliance Advisory I issued with a Warning Letter, which you should receive once it's finalized. Please let me know if you have any questions about the compliance advisory or the warning letter. Thanks, 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r265783740052314…12/13 Jordan Garahana [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Thu, Nov 30, 2023 at 8:44 AM To: "Boudreau, Christian (Staker & Parson)" <christian.boudreau@stakerparson.com> Hey Christian, I have one more piece of information I need to complete my inspection. Can you confirm that the asphalt plant did not produce more than 5600 tons of asphalt in any one day from September 2022 to August 2023? Thanks, Jordan Garahana [Quoted text hidden] Boudreau, Christian (Staker & Parson) <christian.boudreau@stakerparson.com>Mon, Dec 4, 2023 at 9:11 AM To: Jordan Garahana <jordangarahana@utah.gov> Jordan, The Huntington plant never got near 5,600 tons of production from Sept 22 – Aug 23, their highest volume was <1,500 tons. Thanks, Christian Boudreau Environmental Specialist West Division Staker Parson A CRH COMPANY 89 West 13490 South Draper, Utah 84020 O +1 (801) 871 6704 C +1 (385) 318 6938 E christian.boudreau@stakerparson.com From: Jordan Garahana <jordangarahana@utah.gov> Sent: Thursday, November 30, 2023 8:45 AM 12/4/23, 9:32 AM State of Utah Mail - Records Request for Nielson Construction Huntington Asphalt Plant https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-8595948753224356&simpl=msg-a:r265783740052314…13/13 You don't often get email from jordangarahana@utah.gov. Learn why this is important To: Boudreau, Christian (Staker & Parson) <christian.boudreau@stakerparson.com> Subject: Re: FW: [EXT] Records Request for Nielson Construction Huntington Asphalt Plant [Quoted text hidden] Jordan Garahana <jordangarahana@utah.gov>Mon, Dec 4, 2023 at 9:18 AM To: "Boudreau, Christian (Staker & Parson)" <christian.boudreau@stakerparson.com> Christian, Thanks for sending that information over! I appreciate your help. Thanks, Jordan [Quoted text hidden] F ugitive Dust 9/22/2023 1:11:17 PM Introduction Please complete the following information in order to create a Fugitive D ust Application for your pro ject.  You will have a chance to review the plan prior to nal s ubmission. Introduction A Fu gitive Dust Con trol Plan is requ ired if you r project is 1/4 acre or larger an d located in Cache, Box Elder, Weber, Davis, Salt Lake, Tooele or Utah Cou nty. Other areas and con dition s are option al.  Please complete the form to assess your project. Project Location Projec t Loc ation A Fu gitive Dust Con trol Plan is requ ired if you r project is 1/4 acre or larger an d located in Cache, Box Elder, Weber, Davis, Salt Lake, Tooele or Utah Cou nty. Other areas and con dition s are option al. Select th e Coun ty where you r project will be located :Emer y Utah Administrative Code (UAC) 307-309-6 re quire s that any person owning or ope rating a source of fugitive dust within PM10 and PM2.5 non-attainment and maintenance plan are as on cle ared land grea te r than 1/4 acre in size m ust submit a completed Fugitive Dust Control Plan. The DAQ Tempora ry Relocation Form re quire s the submission of a Fugitive Dust Control Plan Permit Num ber for a ll temporary re location proje cts. Is th is project a temporary relocation project?: Yes No Atta inm ent Fug itive Dust Tutoria l Attainment Area This pr oject is lo cated in a por tion of Utah where air quality meets national air quality standards and is known as an attainment ar ea. Fugitive dust in an attainment area is regulated under Utah R307-205. This rule requires implementation of control measur es to minimize fugitive dust. While the r ule do es NOT r equir e that you le a formal fugitive dust contr ol plan with DEQ, we str ongly encourage you to us e this tool to develop your plan because you ar e subject to DEQ enforcement x inspections and this tool contains DEQ pre-appr oved and reco mmended control measures . W hat is Fugitive D ust? Fugitive dust is dust that is stirred up, creating an air quality pro blem. It is made up of ne particles called particulate matter . It is a health concern becaus e it irritates eyes and nasal tis s ue and s er ious ly impacts the respir ator y system. Fugitive dust may come from gravel o per ations, constr uctio n o r demolition activities, land clear ing and exposed surfaces, r oadways, and mining activities. Tracko ut fr om muddy work areas also create fugitive dust when the mud dries. Utah Fugitive Dust Ru le Atta in m e n t Area Du st R ule Applicant Inform ation Applican t Type::Facility/Project Manager Plan Certicate Number:149E8D 00AC Name:Huntington HMA Mailing Address Mailin g Address - Address Line 1:89 W 13490 S Mailin g Address - Address Line 2: Mailin g Address - City:Draper Mailin g Address - State:Utah Mailin g Address - Zip:84020 Email:chris tian.boudr eau@staker parson.com Ph one:(385) 318-6938 Project Informa tion Project Name:Huntington HMA Project End Date:Ongoing Pr oject L ocation Address Lin e 1:39.351597 -111.002979 Address Lin e 2: City:Huntington State:Utah Zip:84528 Site Direction s:Take UT-31W for 2.9 miles from Huntington, UT County:Emer y Acreage:290 Calcu lated Acreage:290.0 La titude/L ongitude Verication For Ma nu a l La titu d e a nd Lon gitu de in p u t:  Ma ke su r e to in clu de a t lea st 6 d igits a fter the d e cim al a n d it m u st fa ll w ith in the sta te of Uta h . E xa m p le 40.404976 or 40.404976232 Latitude (Decimals Only) :39.351597 Lon gitu de (Decimals Only) :-111.002979 Map Ver ic ation Copy the following URL into your br owser so you can verify on a map that the pr oject latitude and longitude you pr ovided ar e co rrect. Map Calcu lation :https://www.google.com/maps/place/39.351597,-111.002979 Latitu de/Lon gitu de verication : The above Latitude and Longitude have been veried. Point of Contact x Point of Contact for du st c ontrol matters and to wh om a COMPLIANCE ACTION sh ou ld be sen t if n ecessary. Name:Chr istian Boudreau Compan y:Staker P ar s on Addr ess Address Lin e 1:89 W 13490 S Address Lin e 2: City:Dr aper State:Utah Zip:84020 Ph one nu mber:(385) 318-6938 Cell n umber: Dust Suppressants Do you plan on using chemical dust su ppressing or stabilizin g agents?: Yes No Best Manag em ent Practices (BMP) Checklist Best Man agemen t Practices (BMP) Ch ecklist Instru ctions Place a check mark next to every activity th at will be con ducted on th is site.   For each checked activity, complete the corresponding control measures/best management practices (BMP) selection page.  When completed, we will email the entire plan to you.  Fu gitive Du st Plan Nu mber:88D029CC0A x Select all that apply: 01. Backlling area previously excavated or trenched. 02. Blasting so il and rock - drilling and blasting. 03. Clearing for site pr eparation and vacant land cleanup. 04. Clearing forms, foundations, slab clear ing and cleaning of for ms , foundations and slabs prior to pour ing concrete. 05. Crushing o f constr uctio n and demolition debr is, rock and soil. 06. Cut and ll soils for site gr ade pr eparation. 07. Demolitio n - Implosive demolition of a structure, using explosives. 08. Demolitio n - mechanical/manual demolitio n o f walls, stucco , concrete, freestanding str uctures, buildings and o ther str uctur es. 09. Disturbed so il throughout pr oject including between s tructures. THIS ACTIV ITY MUST BE SELECTED FOR ALL PROJECTS. 10. Disturbed land - long term stabilization and erosion contr ol of large tracts of distur bed land that will no t have continuing activity for mor e than 30 days. 11. Hauling mater ials. 12. P aving/subgr ade preparation fo r paving streets, par king lots, etc. 13. Sawing/cutting mater ial, concrete, asphalt, block or pipe. 14. Screening of rock, soil or cons truction debris. 15. Staging ar eas, equipment stor age, vehicle parking lo ts, and material stor age ar eas. 16. Stockpiles materials (storage), other soils, rock or debris, for future use or export. 17. Tailings piles, ponds and erosion contr ol. 18. Trackout, Pr evention and cleanup of mud, silt and soil tracked out onto paved roads. (THIS ACTIV ITY MUST BE SELECTED FOR ALL PROJECTS.) 19. Trac - unpaved r outes and par king, constr uctio n related trac on unpaved interior and/or access r oads and unpaved employee/wo rker parking ar eas. 20. Trenching with track or wheel mounted excavator, shovel, backhoe or trencher . 21. Truck loading with mater ials including constr uction and demolition debr is, rock and soil. BMP - 09 Disturbed soil throughout project including between structures. GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5 MAKE AT LEAST ONE SELECTION FROM EACH SECTION. Limit disturbance of soils where possible.: 09-01. Limit disturbance of s oils with the use o f fencing, bar r iers, barricades, and/or wind barrier s. 09-02. Limit vehicle mileage and reduce speed. x x x x x x x x x Stabilize and maintain stability of all disturbed soil throu ghou t con struction site.: 09-03. Apply water to stabiliz e disturbed so ils . Soil mo isture must be maintained such that soils can be wor ked without gener ating fugitive dust. 09-04. Apply and maintain a chemical stabilizer. 09-05. Use wind breaks. 09-06. Apply cover (natur al or synthetic). BMP - 10 Disturbed la nd - long term stabilization a nd erosion control ... for more than 30 da ys. GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5 MAKE AT LEAST ONE SELECTION FROM EACH SECTION. Prevent access to limit soil distu rbance.: 10-01. Prevent access by fencing, ditches, vegetation, ber ms or other suitable bar rier. Stabilize soil.: 10-02. Apply and maintain a chemical stabilizer on disturbed so ils . 10-03. Stabiliz e disturbed so il with vegetation. 10-04. Pave or apply sur face r ock. 10-05. Use wind breaks. 10-06. Apply water and maintain soil moisture sucient to avoid gener ating fugitive dust. BMP - 11 Ha uling ma terials. GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5 MAKE AT LEAST ONE SELECTION FROM EACH SECTION. Limit visible du st opacity from veh icu lar operations.: 11-01. Apply and maintain water/chemical suppr essant to operational areas and haul r outes. 11-02. Limit vehicle mileage and speed. Stabilize materials during transport on site.: 11-03. Use tarps or other suitable enclosures on haul trucks . 11-04. Apply water prior to trans port. x x x x x Clean wh eels an d u ndercarriage of h au l tru cks prior to leavin g con struction site.: 11-05. Clean wheels. 11-06. Sweep or water haul r oad. BMP - 15 Staging areas, equipment stora ge, vehicle pa rking lots, and ma teria l storage areas. GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5 MAKE AT LEAST ONE SELECTION FROM EACH SECTION. Limit visible du st opacity from veh icu lar operations.: 15-01. Limit vehicle mileage and speed limit. 15-02. Apply water on all vehicle trac ar eas in the staging ar eas and unpaved access r outes. Stabilize stagin g area soils du rin g u se.: 15-03. Pre-water and maintain surface soils in a stabiliz ed condition. 15-04. Apply and maintain a chemical stabilizer to surface s oils. Stabilize stagin g area soils at project completion .: 15-05. Apply a chemical stabilizer. 15-06. Apply scr eened or washed aggr egate. 15-07. Use wind breaks. 15-08. Pave. 15-09. Completed project will cover s taging area with buildings, paving, and/or landscaping. 15-10. Apply water to form adequate cr ust and pr event acces s . BMP - 16 Stockpiles materials (storage), other soils, rock or debris, for future use or export. GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5 MAKE AT LEAST ONE SELECTION FROM EACH SECTION. Stabilize su rface soils where support equipmen t an d veh icles will operate.: 16-01. Pre-water and maintain surface soils in a stabiliz ed condition. 16-02. Apply and maintain a chemical stabilizer on s ur face soils. 16-03. Pave area. x x x x x Stabilize stockpile materials du rin g h andling.: 16-04. Remove material from the downwind side of the stockpile, when safe to do so. 16-05. Reduce height. 16-06. Create wind scr een Stabilize stockpiles after h andling.: 16-07. Water stockpiles to for m a crust immediately. 16-08. Apply and maintain a chemical stabilizer to all outer sur faces of the stockpiles. 16-09. Pro vide and maintain wind barrier s on 3 sides of the pile. 16-10. Apply a cover (natural o r synthetic) 16-11. Wind s creen. 16-12. Avoid steep sides to pr event material slo ughing. 16-13. Reduce height. BMP - 18 Tra ckout, Prevention a nd clea nup of mud, silt a nd soil tra cked out onto pa ved roa ds. GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5 MAKE AT LEAST ONE SELECTION FROM EACH SECTION. Prevent dust from trackou t.: 18-01. Clean tr ackout at the end of the work shift fr om paved sur faces to maintain dust co ntrol 18-02. Maintain dust contr ol during wo rking hours and clean tracko ut fr om paved sur faces at the end of the wor k shift/day. 18-03. Install gravel pad(s), clean, well-gr aded gravel or cr ushed rock. Minimum dimensions must be 30 feet wide by 3 inches deep, and, at minimum, 50' o r the length of the longest haul tr uck, whichever is greater. Re-screen, wash or apply additional rock in gravel pad to maintain eectivenes s . 18-04. Install wheel shaker s. Clean wheel shaker s o n a r egular basis to maintain eectiveness. 18-05. Install wheel washers. Maintain wheel was her s o n a r egular basis to maintain eectivenes s . 18-06. Motoriz ed vehicles will only operate on paved sur faces. 18-07. Install cattle guard before paved road entrance. All exiting trac mu st be rou ted over selected trackou t con trol device(s).: 18-08. Clearly establish and enforce tr ac patterns to route tr ac over selected tr ackout contr ol device(s). 18-09. Limit site accessibility to ro utes with trackout contro l devices in place by installing eective barr iers on unprotected routes. x x x x x x Best Manag em ent Practice Selections - 19 Tra c - unpa ved routes a nd pa rking , construction related trac ... pa rking areas. GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5 MAKE AT LEAST ONE SELECTION FROM EACH SECTION. Stabilize su rface soils where support equipmen t an d veh icles will operate.: 19-01. Limit vehicle mileage and speeds. 19-02. Apply and maintain water on surface so ils . 19-03. Apply and maintain chemical stabilizers on surface soils. 19-04. Apply and maintain gravel on surface soils. 19-05. Supplement chemical stabiliz er s, water or aggregate applications as necessary. 19-06. Apply r ecycled asphalt (RAP) to surface so ils . BMP - 21 Truck loa ding with materials including construction and demolition debris, rock a nd soil. GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5 MAKE AT LEAST ONE SELECTION FROM EACH SECTION. Apply and maintain a ch emical stabilizer on surface soils wh ere loaders, support equipmen t and vehicles will operate. : 21-01. Pre-water and maintain surface soils in a stabiliz ed condition wher e loader s , s uppo rt equipment and vehicles will operate. 21-02. Apply and maintain a chemical stabilizer on s ur face soils wher e loaders, support equipment and vehicles will operate. 21-03. Empty loader bucket slowly and keep loader bucket close to the truck to minimiz e the dro p height while dumping. Reviewing Your Pla n Please carefully review yo ur plan befo re submitting it. Once the plan has been submitted, it CANNOT be edited. BEFO RE you submit your plan, if you ne ed to m ake cha nges, navigate back to those sections via the left navigation or the Previous button to complete those cha nges. Whe n you are satisfied, submit your plan. x x x The plan will be available to download in the My Forms section, under the Done tab. By s ubmitting this plan I agree to the following terms : A. I am authorized, on be half of the individual or compa ny liste d in Se ction 1, as Applicant, to apply for a Fugitive Dust Control Plan and to com m it to a ll of the terms and conditions of the re que ste d pla n. B. Construction a ctivities will be limited to lands that the applicant e ithe r owns or is authorize d to use for construction activitie s. C. The applica nt a cce pts re sponsibility for assuring that all contractors, subcontractors, and all othe r pe rsons on the construction site covered by this plan, comply with the terms and conditions of the Fugitive Dust Control Plan. D. I unde rstand that any false m ate rial state m ent, re presentation or certification made in this application may invalidate the plan or ca use me to be subject to e nforcement action pursuant to Utah Code Ann. 19-2-115. E. Failure to comply with fugitive dust rules m ay result in compliance action and penalties up to $10,000 pe r violation/day. Conrmation of terms: My plan is r eady to be submitted. Fr equently As ked Questions Division of Air Quality Utah Depar tment of Environmental Quality Feedback Div isio n of Air Quality Address: 195 North 1950 West P.O. Box 144820 Salt Lake City, UT 84114-482 Contact Phone: 801-536-4000 Contact Fax: 801-536-4099 Frequently Asked Questions Fr equently As ked Questions Division of Air Quality Utah Depar tment of Environmental Quality x Feedback Div isio n of Air Quality Address: 195 North 1950 West P.O. Box 144820 Salt Lake City, UT 84114-482 Contact Phone: 801-536-4000 Contact Fax: 801-536-4099 Loss % Moist % Total Used Rec Sales End Inv Phy Inv Adj CommentsUsed/Prod 04560 Huntington Asphalt Inventory Date: 09/01/22 - 08/31/23 Company: 100 - Staker & Parson Companies Plant List: 04560 Material Category: Meter Summarize Option: By Day/Shift Include All? No Beg Inv 09/06/22 1st Shift Soft Close 2.14 Usage 09/08/22 1st Shift Soft Close 1.11 Meter Plant Meter Plant Meter 214.97 09/16/22 1st Shift Soft Close 2.20 09/07/22 1st Shift Soft Close 3.40 10/10/22 1st Shift Soft Close 2.12 09/14/22 1st Shift Soft Close 1.56 10/12/22 1st Shift Soft Close 2.28 09/21/22 1st Shift Soft Close 0.00 10/17/22 1st Shift Soft Close 1.38 10/11/22 1st Shift Soft Close 2.41 10/19/22 1st Shift Soft Close 3.13 10/13/22 1st Shift Soft Close 2.26 10/21/22 1st Shift Soft Close 0.00 10/18/22 1st Shift Soft Close 1.20 10/25/22 1st Shift Soft Close 4.10 10/20/22 1st Shift Soft Close 2.23 10/27/22 1st Shift Soft Close 0.00 10/24/22 1st Shift Soft Close 2.33 10/31/22 1st Shift Soft Close 5.58 10/26/22 1st Shift Soft Close 2.00 11/02/22 1st Shift Soft Close 0.00 10/28/22 1st Shift Soft Close 1.36 11/08/22 1st Shift Soft Close 4.37 11/01/22 1st Shift Soft Close 6.14 11/10/22 1st Shift Soft Close 4.55 11/07/22 1st Shift Soft Close 4.23 11/14/22 1st Shift Soft Close 4.55 11/09/22 1st Shift Soft Close 0.00 11/16/22 1st Shift Soft Close 3.60 11/11/22 1st Shift Soft Close 5.33 11/21/22 1st Shift Soft Close 0.00 11/15/22 1st Shift Soft Close 5.24 11/17/22 1st Shift Soft Close 0.28 11/22/22 1st Shift Soft Close 0.29 Inventory Date: 09/01/22 - 08/31/23 Company: 100 - Staker & Parson Companies Plant List: 04560 Material Category: Meter Summarize Option: By Day/Shift Include All? No 11/25/22 1st Shift Soft Close 0.50 11/29/22 1st Shift Soft Close 0.80 12/09/22 1st Shift Soft Close 4.29 11/28/22 1st Shift Soft Close 0.00 12/13/22 1st Shift Soft Close 4.45 12/08/22 1st Shift Soft Close 4.18 04/26/23 1st Shift Soft Close 2.42 12/10/22 1st Shift Soft Close 5.38 05/16/23 1st Shift Soft Close 0.55 12/14/22 1st Shift Soft Close 2.19 05/22/23 1st Shift Soft Close 4.20 04/27/23 1st Shift Soft Close 0.44 05/30/23 1st Shift Soft Close 0.00 05/20/23 1st Shift Soft Close 0.00 06/05/23 1st Shift Soft Close 1.51 05/23/23 1st Shift Soft Close 6.26 06/07/23 1st Shift Soft Close 0.21 06/01/23 1st Shift Soft Close 1.36 06/09/23 1st Shift Soft Close 1.70 06/06/23 1st Shift Soft Close 0.51 06/14/23 1st Shift Soft Close 5.53 06/08/23 1st Shift Soft Close 2.32 06/16/23 1st Shift Soft Close 6.53 06/13/23 1st Shift Soft Close 2.45 06/20/23 1st Shift Soft Close 6.43 06/15/23 1st Shift Soft Close 5.27 06/22/23 1st Shift Soft Close 1.17 06/19/23 1st Shift Soft Close 6.35 06/27/23 1st Shift Soft Close 2.29 06/21/23 1st Shift Soft Close 1.28 06/29/23 1st Shift Soft Close 2.18 06/26/23 1st Shift Soft Close 1.17 07/05/23 1st Shift Soft Close 1.48 06/28/23 1st Shift Soft Close 2.07 07/18/23 1st Shift Soft Close 1.50 06/30/23 1st Shift Soft Close 2.10 07/20/23 1st Shift Soft Close 3.43 07/17/23 1st Shift Soft Close 0.48 07/24/23 1st Shift Soft Close 0.00 07/19/23 1st Shift Soft Close 1.54 07/26/23 1st Shift Soft Close 3.25 07/21/23 1st Shift Soft Close 0.00 07/25/23 1st Shift Soft Close 0.39 Inventory Date: 09/01/22 - 08/31/23 Company: 100 - Staker & Parson Companies Plant List: 04560 Material Category: Meter Summarize Option: By Day/Shift Include All? No 07/28/23 1st Shift Soft Close 0.31 08/01/23 1st Shift Soft Close 3.20 07/27/23 1st Shift Soft Close 1.26 08/03/23 1st Shift Soft Close 0.20 07/31/23 1st Shift Soft Close 0.17 08/07/23 1st Shift Soft Close 1.21 08/02/23 1st Shift Soft Close 3.44 08/16/23 1st Shift Soft Close 3.44 08/04/23 1st Shift Soft Close 1.10 08/18/23 1st Shift Soft Close 0.34 08/15/23 1st Shift Soft Close 6.10 08/22/23 1st Shift Soft Close 0.34 08/17/23 1st Shift Soft Close 2.60 08/24/23 1st Shift Soft Close 1.00 08/21/23 1st Shift Soft Close 0.00 08/28/23 1st Shift Soft Close 1.02 08/23/23 1st Shift Soft Close 2.90 08/30/23 1st Shift Soft Close 2.28 08/25/23 1st Shift Soft Close 1.02 08/31/23 1st Shift Soft Close 0.00 08/29/23 1st Shift Soft Close 1.51