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Home My WebLink AboutDAQ-2024-007498 Small Source Registration DAQE-EN161850004-24 {{$d1 }} Brady Bradshaw Bradshaw Farms & Equipment PO Box 1484 Beaver, UT 84713 rbradybradshaw@yahoo.com Dear Mr. Bradshaw: Re: Request for Evaluation of Compliance with Rule R307-401-9, UAC: Small Source Exemption Project Fee Code: N161850004 On March 7, 2024, the Division of Air Quality (DAQ) received your request for a small source exemption for Bradshaw Farms & Equipment’s Irrigation Pond project. The source is located approximately 2.5 miles northeast of Beaver, Utah, at UTM (Universal Transverse Mercator) coordinates of 358,649 meters easting and 4,241,182 meters northing (Datum NAD 83, Zone 12) in Beaver County, Utah. DAQ has determined the small source exemption applies to the source, as long as the equipment and associated processes operate as specified in the registration request. The small source exemption does not exempt a source from complying with other applicable federal, state, and local regulations and the current Utah Administrative Code. Based on the DAQ estimated emissions for your site and project, Bradshaw Farms & Equipment is not required to obtain an approval order under R307-401 for the construction of the pond and crushing of the excavated rock for road base usage. If you change your operation such that there is an increase in emissions, we recommend that you notify us, as an approval order may be required. 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director / % Û à Û Ù Û Ý DAQE-EN161850004-24 Page 2 Thank you for registering your source with the DAQ. If you have any additional questions, please contact Katie Andersen at (385) 515-1748 or kandersen@utah.gov. Sincerely, Bryce C. Bird Director {{$s }} Alan D. Humpherys, Manager New Source Review Section BCB:ADH:KA:jg {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}} lbs/hr t/hr t/2weeks Tons emitted during operation PM10 12.92 0.006461 0.516887624 0.516888 PM2.5 2.25 0.001124 0.089897761 0.089898 Nox 12.40 0.0062 0.496 0.496 CO 2.67 0.001336 0.10688 0.10688 VOC 1.01 0.000503 0.0402256 0.040226 SO2 0.00 2.43E-06 0.00019416 0.000194 HAP 0.01 5.42E-06 0.00043385 0.000434 Total 1.250519 All less than 5 tons 20000 y^3, I doubled their expected excavation amount 40000 tons of material 500 tons of material/hour Assumptions: 8 hours a day, 5 days a week 1 y^3=2 tons of material Working in 1 acre Storage Piles are 0.5 acres 1 Crusher, 3 screens, and 5 tran lbs emitted during operation 1033.775 179.7955 992 213.76 80.4512 0.38832 0.8677 HAPS less than 500 lbs/year nsfer points Wind Erosion of Exposed Area Total Area of Disturbed Ground 1 acres Emission Factors & Distribution TSP Emission Factor 0.38PM10 Content 50% PM2.5 Content 7.5% Pollutant Emission Factor (tons/acre-year) Emission Rate (lbs/hr) Emission Total (tons/year)PM10 0.19 0.04 0.19 PM2.5 0.03 0.01 0.03 Disturbed Ground Reference AP-42 Table 11.9-4 AP-42 Section 13.2.5.3 Page 3 of Version 1.1 September 4, 2019 Equipment Details Rating 400 hp = (298.6 kw) Operational Hours 80 hours/year Sulfur Content 15 ppm or 0.0015% Criteria Pollutant Emission Standards (g/hp-hr) Emission Factor (lb/hp-hr) Emission Rate (lbs/hr) Emission Total (tons/year)Reference NOX 0.031 12.40 0.50 CO 6.68E-03 2.67 0.11 PM10 2.20E-03 0.88 0.04 PM2.5 2.20E-03 0.88 0.04 VOC 2.51E-03 1.01 0.04SO21.21E-05 0.00 0.00 AP-42 Table 3.4-1 HAP 0.01 0.00 See Below Green House Gas Pollutant Global Warming Potential Emission Factor (lb/hp-hr) Emission Rate (lbs/hr) Emission Total (tons/year)ReferenceCO2 (mass basis)1 1.15E+00 460 18 Methane (mass basis)25 0 0CO2e18 Hazardous Air Pollutant Emission Rate (lbs/hr) Emission Total (tons/year)Reference Benzene 9.33E-04 2.61E-03 1.04E-04 Toluene 4.09E-04 1.15E-03 4.58E-05 Xylenes 2.85E-04 7.98E-04 3.19E-05 1,3-Butadiene 3.91E-05 1.09E-04 4.38E-06 Formaldehyde 1.18E-03 3.30E-03 1.32E-04 Acetaldehyde 7.67E-04 2.15E-03 8.59E-05 Acrolein 9.25E-05 2.59E-04 1.04E-05 Naphthalene 8.48E-05 2.37E-04 9.50E-06 Acenaphthylene 5.06E-06 1.42E-05 5.67E-07 Acenaphthene 1.42E-06 3.98E-06 1.59E-07 Fluorene 2.92E-05 8.18E-05 3.27E-06 Phenanthrene 2.94E-05 8.23E-05 3.29E-06 Anthracene 1.87E-06 5.24E-06 2.09E-07 Fluoranthene 7.61E-06 2.13E-05 8.52E-07 Pyrene 4.78E-06 1.34E-05 5.35E-07 Benz(a)anthracene 1.68E-06 4.70E-06 1.88E-07 Chrysene 3.53E-07 9.88E-07 3.95E-08 Benzo(b)fluoranthene 9.91E-08 2.77E-07 1.11E-08 Benzo(k)fluoranthene 1.55E-07 4.34E-07 1.74E-08 Benzo(a)pyrene 1.88E-07 5.26E-07 2.11E-08 Indeno(1,2,3-cd)pyrene 3.75E-07 1.05E-06 4.20E-08 Dibenz(a,h)anthracene 5.83E-07 1.63E-06 6.53E-08 Benzo(g,h,l)perylene 4.89E-07 1.37E-06 5.48E-08 AP-42 Table 3.3-1 & Table 3.4-1 Emission Factor (lb/MMBtu) AP-42 Table 3.3-2, Table 3.4-3, & Table 3.4-4 (1,3-Butadiene will not popluate if the engine size is greater than 600 hp. AP-42 does not list 1,3- Butadiene for engines greater than 600 hp.) Diesel-Fired Engines Emergency Engines should equal 100 hours of operation per year Manufacturer Data, AP-42 Table 3.3-1, & Table 3.4-1 Page 4 of Version 1.1 February 21, 2019 Production Rates Hourly Rates 500 tons/hour Annual Production 40,000 tons/year Variables Number of Transfer Points 5 Mean Wind Speed 10 mph Moisture Content 4 % Pollutant Emission Factor (lb/ton) Emission Rate (lbs/hr) Emission Total (tons/year)Reference PM10 0.00104 2.61 0.10 PM2.5 0.00016 0.40 0.02 Material Handling AP-42 13.2.4.3 Equation #1 Page 5 of Version 1.0 November 29, 2018 Storage Pile Area Total Area of Storage Piles 1 acres Control Efficiency PM10 Control Efficiency 66% PM2.5 Control Efficiency 40% Pollutant Uncontrolled Emission Factor (lb/acre-day) Controlled Emission Factor (lb/acre-day) Emission Rate (lbs/hr) Emission Total (tons/year)ReferencePM106.30 2.14 0.04 0.20 AP-42 Fourth Edition Table 8.19.1-1PM2.5 1.85 1.11 0.02 0.10 AP-42 Appendix B.2 Table B.2-2 Storage Piles Reference AP-42 Appendix B.2 Tables B.2-2 & B.2-3 Page 6 of Version 1.0 November 29, 2018 Production Rates Hourly Rates 500 tons/hour Annual Production 40,000 tons/year Loader Information Empty Loader Weight 20 tons Weight of Load 10 tons Loaded Loader Weight 30 tons Loader Route\ Information Loader Route One-Way Length 500 feet Hourly Vehicle Miles Traveled 9.5 miles Annual Vehicle Miles Traveled 758 miles Type of Control Pollutant Uncontrolled Emission Factor (lb/VMT) Controlled Emission Factor (lb/VMT) Emission Rate (lbs/hr) Emission Total (tons/year)ReferencePM101.71 0.51 4.85 0.19 PM2.5 0.171 0.051 0.49 0.02 Loader Routes Basic Watering - (70% control) AP-42 13.2.2 & DAQ Haul Road Guidance Page 7 of Version 1.0 November 29, 2018 Production Rates Hourly Rates 500 tons/hour Annual Production 40,000 tons/year Truck Information Empty Truck Weight 20 tons Weight of Load 40 tons Loaded Truck Weight 60 tons Haul Road Information Haul Road One-Way Length 1,000 feet Hourly Vehicle Miles Traveled 4.7 miles Annual Vehicle Miles Traveled 379 miles Type of Control Pollutant Uncontrolled Emission Factor (lb/VMT) Controlled Emission Factor (lb/VMT) Emission Rate (lbs/hr) Emission Total (tons/year)ReferencePM102.11 0.63 3.00 0.12 PM2.5 0.211 0.063 0.30 0.01 Haul Roads Basic Watering - (70% control) AP-42 13.2.2 & DAQ Haul Road Guidance Page 8 of Version 1.0 November 29, 2018 Production Rates Hourly Rates 500 tons/hour Annual Production 40,000 tons/year Emission Unit Number of Emission Units PM10 Emission Factor (lb/ton) PM2.5 Emission Factor (lb/ton)Reference Crushers 1 0.00054 0.00010 Screens 3 0.00074 0.00005 Conveyor Transfer Points 5 4.6E-05 1.3E-05 Pollutant Emission Rate (lbs/hr) Emission Total (tons/year)PM10 1.50 0.06 PM2.5 0.16 0.01 Emission Unit PM10 Emission Rate (lbs/hr) PM10 Emission Total (tons/year) PM2.5 Emission Rate (lbs/hr) PM2.5 Emission Total (tons/year) Crushers 0.27 0.01 0.05 0.00 Screens 1.11 0.04 0.08 0.00 Conveyors 0.12 0.00 0.03 0.00 Aggregate Processing Equipment AP-42 Table 11.19.2-2 Page 9 of Version 1.0 November 29, 2018 3/8/24, 11:48 AM State of Utah Mail - Fwd: Bradshaw Farms filling fee https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1792977950252280913&simpl=msg-f:17929779502522809…1/2 Katie Andersen <kandersen@utah.gov> Fwd: Bradshaw Farms filling fee 1 message Alan Humpherys <ahumpherys@utah.gov>Fri, Mar 8, 2024 at 9:56 AM To: Katie Andersen <kandersen@utah.gov> Katie, Can you please process this project? This will be a small source exemption and a permit revocation. The source submitted the wrong type of permit application and we issued a portable AO instead of a SSE. You will need to estimate the emissions yourself to confirm the source meeting the SSE thresholds. You can use the spreadsheets on our website to estimate emissions. We will also not bill the source for this work. Please update the letters to reflect this when you issue them. Site ID: 16185 Peer: EQ Please let me know if you have any questions. Thanks, Alan ---------- Forwarded message --------- From: Brady Bradshaw <rbradybradshaw@yahoo.com> Date: Thu, Mar 7, 2024 at 9:24 AM Subject: Bradshaw Farms filling fee To: ahumpherys@utah.gov <ahumpherys@utah.gov> Hello Alan, We are local farmers working on building a pond on our rural farm to settle sentiment out of the water before it goes into the irrigation pipes. When building the pond, we decided to crush the rock, that is dug out of the hole for the pond, to use as road base. The crushing is in a very remote area, away from residential houses, and would be a ONE time thing only lasting about 2 weeks. The amount of rock that will be crushed is around 10,000 yards. We completed the public comment period at the local zoning and planning meeting and received approval to do the project, upon receiving an air quality permit. Once again, this project is a one time thing only lasting a couple of weeks and is basically a process to "kill 2 birds with 1 stone" because we would be digging the rock up anyways, so we decided to crush it and use it for road base in the same area. This being our first time submitting for an air quality permit, I called the air quality permit division and talked with Eq, and was directed to fill out the application that I submitted. I was a bit surprised at the process, because this is a very small one time project, but I figured that was part of the process because I had called and was directed to fill out that certain application. The process took over 3 months and was more involved than expected. Being the first time applying for this type of permit, I assumed this must be the normal process even though it seemed much more involved than necessary. Once everything was finally completed and approved, I received a bill for almost $3,000! I was quite shocked! As mentioned earlier, this was my first time going thru this process and I had called and received direction that I followed. This cost a lot of unnecessary time and money. Because of the direction I received, from the air quality permit personnel, I feel that I was misled and lost time waiting for the completion of a permit that was not necessary when another type of permit would have been sufficient. I had no idea the cost would add up so quickly, and there was no quote given before the process was started, to notify us of the cost. Because of all these factors, this is what I am hoping we can accomplish: 1. I would like to know what the correct application is to fill out and find out what that cost would be. 2. I would like to know if it's an option to not to be charged for the first permit as it is much more than what is necessary for the project. We appreciate the help and work that has been done so far and would like to be get everything worked out and the right permit granted. Thank you for your time and I look forward to your response. Please reach out with any questions or for further clarification. 3/8/24, 11:48 AM State of Utah Mail - Fwd: Bradshaw Farms filling fee https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-f:1792977950252280913&simpl=msg-f:17929779502522809…2/2 Thanks again, Brady Bradshaw 435-310-0727 Bradshaw Farms & Equipment -- Alan Humpherys Manager | Minor NSR Section P: (385) 306-6520 F: (801) 536-4099 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.