HomeMy WebLinkAboutDAQ-2024-0051421
DAQC-162-24
Site ID 14245 (B1)
MEMORANDUM
TO: FILE – STAKER & PARSON COMPANY – Beef Hollow Pit (Formerly Tru
Crushing, Inc. – Point West Aggregate Pit)
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Irene Tucker, Environmental Scientist
DATE: February 1, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County
INSPECTION DATE: July 25, 2023
SOURCE LOCATION: 15750 South Redwood Road
Herriman, Utah County, UT
From Redwood Road go west on Porter Rockwell Boulevard
through the intersection for Mountainview Corridor.
SOURCE CONTACT: Christian Boudreau, Environmental Specialist, West Division,
801-871-6704, 385-318-6938,
Christian.boudreau@stakerparson.com
OPERATING STATUS: Operating normally at time of inspection.
PROCESS DESCRIPTION: Bank run aggregate is processed through a jaw crusher, conveyed
to a vibrating screen, and processed through a cone crusher prior
to stacking on storage piles by size. Numerous pieces of aggregate
processing equipment have been permitted to allow the company
to operate in different configurations depending on the type of
product needed. Unprocessed bank run is also sold, usually as
landscape rock. Generators are used to power the aggregate
equipment as well as providing power to the scale house.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN0142450001-10, dated March
10, 2010
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
MACT 63, Subpart ZZZZ—National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines
/ :
2
SOURCE EVALUATION:
Name of Permittee:
Tru Crushing, Inc. – Point West Aggregate Pit
71 East Wadsworth Park Drive
Draper, UT 84020
Permitted Location:
15750 South Redwood Road
Herriman, Utah County, UT
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. Staker & Parson 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. Staker & Parson has made no modification 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. Staker & Parson plans to keep 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. Staker & Parson maintain records of maintenance activities performed
on equipment authorized by this AO. See the attachment for additional information.
3
I.6
Status:
The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring.
[R307-150]
Non-compliance. According to the 2020 Emissions Inventory Report, the emissions for all
the pollutants exceed the PTEs of this AO. Staker & Parson to be referred to Emissions
Inventory to resolve this issue. No further action required at this time.
I.7
Status:
The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
In compliance. Staker & Parson has not experienced any breakdowns resulting in an
emissions event.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Point West Operations
Aggregate processing plant
II.A.2 Jaw Crushers
Two (2) jaw crushers, one rated at 200 tons/hr (tph) and manufactured in 1999, the other rated
capacity unknown and manufactured in 2000
II.A.3 Jaw Crushers
Two (2) jaw crushers, both rated at 500 tph each and manufactured in 2008*
II.A.4 Impact Crusher
One (1) impact crusher, capacity rating unknown and manufactured in 2004
II.A.5 Cone Crushers
Three (3) cone crushers, each rated at 200 tph and manufactured in 1978, 1980 and 1982
II.A.6 Cone Crushers
Two (2) cone crushers, each rated at 500 tph and manufactured in 2008*
II.A.7 Cone Crushers
Two (2) cone crushers, each rated at 500 tph and manufactured in 2003 and 2007
II.A.8 Vibrating Screens
Three (3) vibrating screens, each rated at 400 tph and manufactured in 2003, 2005 and 2006
II.A.9 Vibrating Screens
Four (4) vibrating screens, each rated at 500 tph and manufactured in 2008*
II.A.10 Diesel Powered Generator
One (1) diesel powered generator rated at 545 kW and manufactured in 2000
II.A.11 Diesel Powered Generators
Two (2) diesel powered generators each rated at 900 kW and manufactured date unknown
4
II.A.12 Diesel Powered Generators
Two (2) diesel powered generators each rated at 750 kW and manufactured in 2007
II.A.13 Transfers and Storages
Misc. transfer conveyor/stackers and storage bins
II.A.14 Aggregate Handling Equipment
Misc. aggregate handling equipment including grizzlies, feeders, splitters and traps
II.A.15 Mobile Equipment
Misc. off-highway mobile equipment including loaders, dozers and water trucks
II.A.16
Status:
Diesel Storage Tanks
Misc. diesel storage tanks
*Equipment considered to have been manufactured after April 22, 2008
Compliance undetermined. Staker & Parson was in the process of an Approval Order
modification at the time of this inspection. The new AO was approved on December 11,
2023.
II.B Requirements and Limitations
II.B.1
II.B.1.a
Status:
Site-wide Requirements and Limitations
Tru Crushing shall notify the Executive Secretary in writing when the installation of the
equipment listed in Condition II.A has been completed and is operational. To ensure proper
credit when notifying the Executive Secretary, send your correspondence to the Executive
Secretary, Attn: Compliance Section.
If the construction and/or installation have not been completed within 18 months from the date of
this AO, the Executive Secretary shall be notified in writing on the status of the construction
and/or installation. At that time, the Executive Secretary shall require documentation of the
continuous construction and/or installation of the operation and may revoke the AO.
[R307-401-18]
Compliance undetermined. Tru Crushing owned and operated this facility using a
Temporary Relocation Permit. Staker & Parson Companies transferred the AO to their
name on March 9, 2011. Initial notification submitted by Tru Crushing may have been
archived.
II.B.1.b
The following production and consumption limits shall not be exceeded:
A. 1,500,000 tons of aggregate processed per rolling 12-month period
B. 500,000 tons of bank run aggregate processed per rolling 12-month period
C. 436,300 gallons of diesel fuel used per rolling 12-month period
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 consumption/production shall be kept for all periods when the plant is in operation.
Production shall be determined by the belt scale records near the initial feeder, or any other
5
Status:
methods approved by the Executive Secretary. Production/Consumption shall be maintained
using an operations log. The records of consumption/production shall be kept on a daily basis.
[R307-401-8]
In compliance. The 12-month rolling total production and consumption from July 2022 to
June 2023 indicated the following:
A. 1,028,113 tons of aggregate processed per rolling 12-month period
B. 0.0 tons of bank run aggregate processed per rolling 12-month period
C. 132,106 gallons of diesel fuel used per rolling 12-month period
II.B.2 Conditions on Fugitive Dust Emissions
II.B.2.a
Status:
Tru Crushing shall comply with a fugitive dust control plan acceptable to the Executive Secretary
for control of all dust sources associated with the Point West Operations. Tru Crushing shall
submit the fugitive dust control plan to the Executive Secretary, attention: Compliance Section,
for approval within 30 days of the date of this AO. [R307-309]
In compliance. The most updated Fugitive Dust Control Plan (FDCP) is dated December
23, 2020.
II.B.2.b
Status:
The following unpaved haul road lengths shall not exceed
A. 0.3 miles in length for unpaved haul road
B. 0.1 miles in length for loader operating area
The owner/operator shall use chemical suppressant and water to control fugitive dust emissions
from the above haul roads. Application frequencies for chemical treatment and water spray shall
follow the requirements in the fugitive dust control plan. [R307-401-8]
Out of compliance with the unpaved haul road. According to Staker & Parson, the length
of the unpaved haul roads, and the length for the loader path, indicated the following:
A. 1.65 miles in length for unpaved haul road (one-way)
B. 0.1 miles in length for loader operating area (round trip): 503.6 ft (approximately
0.10 miles.
Staker & Parson uses water application to control fugitive dust emissions. See the Water
Truck Reports in the attachment.
The new AO dated December 11, 2023, addresses the unpaved haul road. Therefore, no
further action is required at this time.
II.B.2.c
The owner/operator shall cover all unpaved haul roads and wheeled-vehicle operational areas
with road base material and shall use water and/or chemical suppressant applications to maintain
opacity limits listed in this AO. If the temperature is below freezing, the owner/operator may
stop applying water to the unpaved haul roads and wheeled-vehicle operational areas.
6
Status:
Records of 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 is below freezing. [R307-401-8]
In compliance. The unpaved haul roads are covered with gravel. See the Water Truck
Reports in the attachment. See photos of unpaved haul roads taken during this inspection
in the attachment.
II.B.2.d
Status:
Visible fugitive dust emissions from unpaved haul-road traffic and mobile equipment in unpaved
operational areas shall not exceed 20% opacity at any point. Visible emission determinations
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. [R307-401-8]
In compliance. Visible fugitive dust emissions were not observed from unpaved haul-road
traffic during this inspection. The unpaved haul roads are covered with gravel. See the
Water Truck Reports in the attachment. See photos of unpaved haul roads taken during
this inspection in the attachment.
II.B.2.e
Status:
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive dust emissions:
A. All crushers
B. All screens
C. All conveyor transfer points
The sprays shall operate to meet the opacity limits or as determined by the Executive Secretary.
[R307-401-8]
In compliance. There were no visible emissions observed from the crushers, screens, and
conveyor transfer points, as they were equipped with water sprays to reduce fugitive dust
emissions. Staker & Parson has a water tank that is periodically filled by the dedicated
on-site water truck.
II.B.2.f
Status:
The storage piles shall be watered to maintain opacity limit listed in this AO. Records of water
and/or chemical treatment shall be kept for all periods when the plant is in operation. Records of
water and/or chemical treatment shall be made available to the Executive Secretary or Executive
Secretary's representative upon request. [R307-401-8]
In compliance. The storage piles are watered regularly to reduce fugitive dust.
II.B.2.g
Visible emissions from the following emission points (except where indicated otherwise) shall
not exceed the following values:
A. All crushers - 15% opacity
B. All screens - 10% opacity
C. All conveyor transfer points - 10% opacity
7
Status:
D. Conveyor drop points - 20% opacity
E. All other NSPS Subpart OOO affected equipment - 10% opacity
F. All other points - 20% opacity
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9.
For equipment subject to NSPS, opacity shall be determined by conducting observations in
accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9.
Initial visible emission observations shall be conducted according to 40 CFR 60.11 and 40 CFR
60.675. A certified observer must be used for these observations. Emission points which are
subject to the initial observations are those as defined in 40 CFR60.670. [R307-401-8]
In compliance. There were no visible emissions observed during this inspection. Opacity
observations were conducted according to 40 CFR 60, Appendix A, Method 9. See the
attachment for additional information. Initial visible emission observations were conducted
on September 2, 2011, and for Screen #2 on May 29, 2019. See the attachment for
additional information.
II.B.3 NSPS Subpart OOO Affected Equipment That Commenced Construction, Modification, or
Reconstruction on or after April 22, 2008
II.B.3.a
Status:
Visible emissions from the following emission points shall not exceed the following values:
A. All affected crushers - 12% opacity
B. All other affected equipment - 7% opacity
Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. [40 CFR 60 Subpart OOO]
In compliance. There were no visible emissions observed during this inspection. Opacity
observations were conducted according to 40 CFR 60, Appendix A, Method 9. See the
attachment for additional information.
II.B.3.b
Status:
Initial visible emission observations shall be conducted according to 40 CFR 60.11 and 40 CFR
60.675. A certified observer must be used for these observations. Emission points which are
subject to the initial observations are those as defined in 40 CFR60.670.
[40 CFR 60 Subpart OOO]
In compliance. Initial visible emission observations were conducted on September 2, 2011
(see DAQC-1027-11), and for Screen #2 on May 29, 2019 (See the DAQ inspection memo
DAQC-139-20). See the attachment for additional information.
II.B.4 Diesel Powered Generators
II.B.4.a
Status:
The owner/operator shall use #1, #2 fuel oil or any combination of both as a fuel in all diesel
powered generators. [R307-401-8]
In compliance. Staker & Parson uses diesel as fuel for the Generators.
8
II.B.4.b
Status:
The sulfur content of any fuel oil or diesel burned shall not exceed 0.05 percent by weight. The
sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of the fuel oil shall be either by Tru Crushing's own testing or test reports from the
fuel marketer. The sulfur content certification or the test reports shall be available on-site for
each load delivered. [R307-401-8]
In compliance. According to a Bill of Lading from Chevron, the sulfur content of diesel is
characterized as Ultra Low Sulfur Diesel Fuel. See the attachment for additional
information.
II.B.4.c
Status:
Visible emissions from the diesel powered generators shall not exceed 20% opacity. Opacity
observations of emissions from stationary sources shall be conducted according to 40 CFR 60,
Appendix A, Method 9. [R307-401-8]
In compliance. There were no visible emissions observed from the generators during this
inspection.
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: In compliance. Initial visible emission observations were conducted on September 2, 2011 (see
DAQC-1027-11), and for Screen #2 on May 29, 2019 (See the DAQ inspection memo DAQC-139-20).
Staker & Parson conduct monthly Water Spray Inspections. See the attachment for additional
information.
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines
Status: In compliance. According to a Bill of Lading from Chevron, the sulfur content of diesel is
characterized as Ultra Low Sulfur Diesel Fuel. See the attachment for additional information. Staker &
Parson maintain records of maintenance activities performed on the Generators. See the attachment for
additional information.
MACT 63, Subpart ZZZZ—National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Status: Out of compliance. Failure to perform stack testing on applicable diesel-fueled generator engines
may be in violation of 40 CFR Part 63 Subpart ZZZZ, Table 2d # 3. The new AO dated December 11,
2023, addresses the generator engines. Therefore, no further action is required at this time.
9
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
R307-203. Emission Standards: Sulfur Content of Fuels
In compliance. According to a Bill of Lading from Chevron, the sulfur content of diesel is
characterized as Ultra Low Sulfur Diesel Fuel. See the attachment for additional information.
R307-210. Stationary Sources
Status: This area source rule is applicable to NSPS Part 60, Subparts OOO and IIII. See Section
III for the compliance evaluation.
R307-214. National Emission Standards for Hazardous Air Pollutants
Status: This area source rule is applicable to 40 CFR Part 63 Subpart ZZZZ. See Section III for the
compliance evaluation.
R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards.
Status: In compliance. There were no visible emissions observed during this inspection. Opacity
observations were conducted according to 40 CFR 60, Appendix A, Method 9. See the attachment
for additional information.
R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive
Dust.
Status: In compliance. There were no visible emissions observed during this inspection from
unpaved haul roads and operational areas. The unpaved haul roads had a gravel base. The most
updated Fugitive Dust Control Plan (FDCP) is dated December 23, 2020. The unpaved haul roads
were watered. See the Water Truck Report in the attachment. There were no visible emissions
observed from the crushers, screens, and conveyor transfer points, as they were equipped with
water sprays to reduce fugitive dust. See photos of the haul roads and the haul road speed limit in
the attachment.
R307-312 Aggregate Processing Operations for PM2.5 Nonattainment Areas.
Status: In compliance. There were no visible emissions observed from the crushers, screens, and
conveyor transfer points, as they were equipped with water sprays to reduce fugitive dust
emissions. Staker & Parson has a water tank that is periodically filled by the dedicated on-site
water truck.
10
EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions from Tru Crushing, Inc. –
Point West Aggregate Pit on the Approval Order (AO) DAQE-AN0142450001-10, dated March 10,
2010. The following information was supplied for supplemental purposes only.
Criteria Pollutant PTE tons/yr 2020 Emissions
Actuals tons/yr
Carbon Monoxide 7.57 17.99
Nitrogen Oxides 15.48 64.65
Particulate Matter - PM10 8.65 35.99
Particulate Matter - PM2.5 --- 9.39
Sulfur Oxides 0.82 5.52
Volatile Organic Compounds 0.11 6.65
Emission Inventory:
Status: Non-compliance. According to the 2020 Emissions Inventory Report, all the Emissions for
all the pollutants exceed the PTEs of this AO. Staker & Parson to be referred to Emissions
Inventory to resolve this issue. Staker & Parson also indicated that the new AO will address any
increases in emissions. The new AO dated December 11, 2023, replaces the old generator engines.
Therefore, no further action required at this time.
PREVIOUS ENFORCEMENT
ACTIONS: A Compliance Advisory was issued to Staker & Parson on June
13, 2019 (DAQC-0755-19). An Early Settlement Letter was
issued on December 24, 2019 (DAQC-1698-19).
COMPLIANCE STATUS &
RECOMMENDATIONS: Staker & Parson is not in compliance with the conditions in AO
DAQE-AN0142450001-10 dated March 10, 2010, for exceeding
all the PTEs in the 2020 Emissions Inventory Report; for
exceeding the length of the unpaved roads; and for failure to
conduct performance tests on the generators. The new AO was
approved on December 11, 2023, and addresses these
deficiencies, therefore, no further action is required at this time.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Required PPE includes steel-toe boots, hard hat,
safety glasses, reflective vest. The new AO was approved on
December 11, 2023, after this inspection.
RECOMMENDATION FOR
NSR PERMITTING REVIEW: None at this time.
ATTACHMENTS: Visible Emissions Observation Form, Fuel Certification, Water
Truck Report, Maintenance Report, Initial Visible Emissions
Observation Forms, Site Photos