DAQ-2024-008264

DAQE-AN162000001-24

{{$d1 }}

Keith Gilbert
Southwest Grading and Paving, LLC
871 East Fiddler Canyon Road
Cedar City, UT 87421
[e-mail]

Dear Mr. Gilbert:

Re: Approval Order: New Portable Source (Aggregate, Hot Mix Asphalt, Concrete, and Stationary
Diesel-Fired Engines)
Project Number: N162000001

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on February
26, 2024. Southwest Grading and Paving, LLC must comply with the requirements of this AO, all
applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Dungan Adams, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well
as the DAQE number shown on the upper right-hand corner of this letter. Public comments were received
and considered on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DA:jg

cc: Salt Lake County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
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

May 28, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
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APPROVAL ORDER
DAQE-AN162000001-24
New Portable Source (Aggregate, Hot Mix Asphalt, Concrete, and
Stationary Diesel-Fired Engines)

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
Southwest Grading and Paving, LLC - Portable Aggregate Source

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

May 28, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 4
Source Classification .............................................................................................................. 4
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 14
ACRONYMS ............................................................................................................................... 15

DAQE-AN162000001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Southwest Grading and Paving, LLC Southwest Grading and Paving, LLC - Portable
Aggregate Source

Mailing Address Physical Address
871 East Fiddler Canyon Road Not Permanently based at a Site
Cedar City, UT 87421 Portable Source, UT

Source Contact
Name: Keith Gilbert
Phone: [phone]
Email: [e-mail]

SIC code 2951 (Asphalt Paving Mixtures & Blocks)

SOURCE INFORMATION
General Description
Southwest Grading and Paving, LLC, has requested an AO for a portable source. This AO is issued to
Southwest Grading and Paving, LLC, for the purpose of operating a portable source that belongs to the
nonmetallic mineral processing industry, including aggregate, concrete, and hot mix asphalt plants. The
plants subject to this AO shall be temporarily operated for a period of not more than 180 working days at
any location. A relocation shall not exceed 365 consecutive days at any location in the State of Utah.

Prior to the commencement of operation at a location, the owner/operator shall submit a Notice of
Temporary Relocation to the Director and obtain a Temporary Relocation Approval Letter. If the
owner/operator operates at a location in compliance with the AO, the Notice of Temporary Relocation,
and the Temporary Relocation Approval Letter, dispersion modeling results have determined that there
will be no adverse impacts on air quality at the nearest residence or commercial establishment.

Compliance with the opacity limits and operating practices contained in the conditions of the AO shall be
considered an application of BACT. The emission control measures required in the conditions of this AO
shall apply to all of the locations at which the source approved by this AO operates. The source may be
required to adopt additional measures for controlling emissions to address location-specific concerns.

This AO limits the source to emissions that are below the major source threshold, making it a "Synthetic
Minor" source.

DAQE-AN162000001-24
Page 4

NSR Classification
New Minor Source

Source Classification
Located in
Portable Source County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), I: Standards of Performance for Hot Mix Asphalt Facilities
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 (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Description
The owner/operator has requested an AO for a portable source. The portable source belongs to the
nonmetallic mineral processing industry, including aggregate processing plants, concrete batch plants, hot
mix asphalt plants, and stationary diesel-fired engines.

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

DAQE-AN162000001-24
Page 5

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Portable Source
Including: Aggregate Processing Equipment, Concrete Batching Equipment, Hot Mix Asphalt
Equipment, and Diesel-Fired Engines.

II.A.2 Aggregate Processing Equipment
These plants may be subject to NSPS Subpart OOO Requirements.
These plants include:

A. Crushers.

B. Screens.

C. Wash Plants.

D. Conveyors, Feeders, Hoppers, and Stackers.

DAQE-AN162000001-24
Page 6

II.A.3 Concrete Batch Plants
These plants include:

A. Central-Mix Concrete Batch Plants.

B. Truck-Mix Concrete Batch Plants.

C. Baghouses, Bin Vents, Dust Collectors, and Fabric Filters.

D. Storage Silos - Contents include:
i. Cement
ii. Fly Ash
iii. Lime
iv. Concrete Additives.

E. Boilers & Water Heaters
i. Fuel: Natural Gas/Propane
ii. Rating: less than 10 MMBtu/hr each.

F. Conveyors, Feeders, Hoppers, Pugmills, and Stackers.

II.A.4 Hot Mix Asphalt Plants
These plants may be subject to NSPS Subpart I Requirements
These plants include:

A. Drum-Mix Hot Mix Asphalt Plants.

B. Baghouses, Bin Vents, Dust Collectors and Fabric Filters.

C. Storage Silos - Contents include:
i. Lime
ii. Hot Mix Asphalt
iii. RAP
iv. Hot Mix Asphalt Additives.

D. Conveyors, Feeders, Hoppers, Mixers, Pugmills, and Stackers.

II.A.5 Stationary Diesel-Fired Engines
These stationary engines produce mechanical or electrical power to operate the plants in this AO.
These stationary engines are subject to MACT Subpart ZZZZ Requirements
These stationary engines may be subject to NSPS Subpart IIII Requirements

II.A.6 Storage Tanks
Contents include:

A. Asphalt Cement.

B. Diesel Fuel.

C. On-Specification Used Oil.

D. Gasoline.

E. Propane.

DAQE-AN162000001-24
Page 7

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Notice of Temporary Relocation:
II.B.1.a The owner/operator shall submit a Notice of Temporary Relocation and obtain a Temporary
Relocation Approval Letter prior to operating a portable source at any location. [R307-401-8]

II.B.1.a.1 Notices of Temporary Relocation shall include the following information (Form 15a is available
from the DAQ):

A. The address and driving directions of the proposed location.

B. A list of the equipment to be operated at the proposed location, including:
1. The type of equipment
2. The rated capacity of the equipment
3. The date of manufacture of the equipment.

C. A site diagram showing the general equipment location on site (to scale), and the
distance to the nearest houses, barns, or commercial operations (to scale if the
plant boundary is located within one (1) mile of these buildings.)

D. The expected startup and completion dates for operating at the proposed
location.

E. The expected hours of operation, including start and stop times.

F. The emission control measures that the owner/operator proposes to adopt for
each emission point at each location, including a FDCP specific to the proposed
location.

G. A reference to this AO.

[R307-401-8]

II.B.2 Temporary Relocation Approval Letter:
II.B.2.a The owner/operator shall operate and conduct its operations of the aggregate processing plants,
the concrete batch plants, the hot mix asphalt plants, and the diesel-fired engines in accordance
with the terms and conditions of this AO and the terms and conditions of the Temporary
Relocation Approval Letter issued by the Director for each relocation. In the case of any
discrepancy between the conditions of this AO and the Temporary Relocation Approval Letter,
the owner/operator shall comply with the site-specific requirements in the Temporary Relocation
Approval Letter. [R307-401-8]

II.B.2.a.1 Portable sources that plan to relocate to a stationary source listed in the Utah PM10 or PM2.5 State
Implementation Plan (SIP) shall comply with the standards and adopt the control strategies listed
in the PM10 or PM2.5 SIP for the stationary source in addition to the requirements of this AO and
the Temporary Relocation Approval Letter. [R307-401-8]

II.B.3 Operations at Temporary Locations:
II.B.3.a The owner/operator may temporarily relocate this portable source to any temporary location.
The temporary relocation shall not exceed 180 working days and shall not exceed 365
consecutive days. If a temporary relocation is expected to exceed 180 working days, the
owner/operator shall submit an NOI in accordance with R307-401 for a permanent source and
obtain a valid AO prior to the end of the 180 working days. [R307-401-17]

DAQE-AN162000001-24
Page 8

II.B.3.a.1 The owner/operator shall keep and maintain the following records on site:

A. The initial relocation date at each location.

B. Working days at each location.

C. Consecutive days at each location.

[R307-401-17]

II.B.3.a.2 The owner/operator shall submit records of the working days at each site and the consecutive
days at each site to the Director at the end of each 180 calendar days. [R307-401-17]

II.B.3.b The owner/operator shall not exceed the daily production limit specified in the Temporary
Relocation Approval Letter. [R307-401-8]

II.B.3.b.1 The daily production shall be determined by belt scale records, scale house records, vendor
receipts or by any other method as acceptable to the Director or the Director's representative.
[R307-401-8]

II.B.3.b.2 The owner/operator shall keep and maintain the following production records on site for all
periods that the portable source is in operation at any location:

A. The date production occurs at each location.

B. The production for that date at each location.

C. The total production at each location.

[R307-401-8]

II.B.3.b.3 The owner/operator shall submit records of the actual production rate to the Director at the end of
each 180 calendar days. [R307-401-17]

II.B.3.c The owner/operator shall only operate between 6:00 a.m. and 10:00 p.m. each day. The hours of
operation may be altered upon approval of the Director; however, any request for a change in
these hours shall include modeling showing that all NAAQS are met.
[R307-401-10, R307-401-8]

II.B.3.c.1 The owner/operator shall keep and maintain the following records of operation for all periods
that the portable source is in operation at any location:

A. The time operations began each day at each location.

B. The time operations ended each day at each location.

[R307-401-8]

II.B.3.d Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any installation of this AO to exceed 20 percent opacity. [R307-201-3, R307-305-3]

II.B.3.d.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, R307-305-3]

DAQE-AN162000001-24
Page 9

II.B.4 Emission Estimates and Emissions Inventory:
II.B.4.a The owner/operator shall estimate the actual emissions that resulted from operating at each
location. These emissions shall be summarized for each piece of equipment, each source of
fugitive dust, and each source of fugitive emissions at the completion of operation at each
location. The Director may require a summary of emissions for each location at any time.
[R307-401-8, R307-150-1]

II.B.4.a.1 Records of actual emissions shall be kept for each location. Records of actual emissions shall
include the following:

A. The emission factors used to estimate emissions for each location.

B. All variables (production, hours of operation, haul road lengths, etc.) used in
the emission estimates for each location.

C. The actual emissions from each location, which includes emissions from each
emission unit, each source of fugitive dust, and each source of fugitive
emissions.

[R307-401-8, R307-150-1]

II.B.5 Haul Roads and Fugitive Dust Sources:
II.B.5.a The owner/operator shall comply with a FDCP consistent with R307-309-6 for each location.
The FDCP for a location shall address the control of all fugitive dust sources at that location.
[R307-401-8]

II.B.5.b The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to
exceed 20 percent opacity on site and 10 percent at the property boundary for each temporary
location. [R307-205-4, R307-309-5, R307-401-8]

II.B.5.b.1 Visible emission determinations for fugitive dust from haul roads and 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 one-half vehicle length
behind the vehicle and not less than one-half the height of the vehicle.
[R307-205-4, R307-309-5, R307-401-8]

II.B.5.c The owner/operator shall use water application or other control options contained in R307-309 to
minimize emissions from fugitive dust and fugitive emissions sources, including haul roads,
storage piles, and disturbed areas. Controls shall be applied to ensure the opacity limits in this
AO are not exceeded. [R307-309, R307-401-8]

II.B.6 Aggregate Processing Plants:
II.B.6.a The owner/operator shall not allow visible emissions from any crusher subject to this AO to
exceed 12 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.b The owner/operator shall not allow visible emissions from any screen subject to this AO to
exceed 7 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.c The owner/operator shall not allow visible emissions from any conveyor transfer point subject to
this AO to exceed 7 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.d The owner/operator shall not allow visible emissions from any conveyor drop point at each
temporary location to exceed 20 percent opacity. [R307-205-4, R307-309-5, R307-401-8]

DAQE-AN162000001-24
Page 10

II.B.6.e 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]

II.B.6.f 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. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.f.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]

II.B.7 Crushers, Screens, and Conveyors subject to NSPS Subpart OOO:
II.B.7.a The owner/operator shall conduct an initial performance test for all crushers, screens, and
conveyor transfer points subject to this AO that are subject to NSPS OOO. Performance tests
shall meet the limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO]

II.B.7.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner or operator may use methods and procedures specified in 40 CFR
60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c).
[40 CFR 60 Subpart OOO]

II.B.7.a.2 The owner/operator shall keep and maintain records of the initial performance test for each
crusher, screen, and conveyor for the life of the equipment. The record of the initial performance
test must be made available to the Director or the Director's representative upon request.
[40 CFR 60 Subpart OOO, R307-401-8]

II.B.8 Concrete Batch Plants:
II.B.8.a The owner/operator shall not allow visible emissions from any concrete batch plant and the
associated equipment subject to this AO to exceed 7 percent opacity. [R307-401-8]

II.B.8.b Each storage silo associated with a concrete batch plant subject to this AO shall be equipped with
a fabric filter, a baghouse, a bin vent, or a dust collector to control particulate emissions
generated during filling of the silos. [R307-401-8]

II.B.9 Hot Mix Asphalt Plants:
II.B.9.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 subject to this AO.
[R307-401-8]

II.B.9.b The sulfur content of any fuel oil burned in the hot mix asphalt plants subject to this AO shall not
exceed 15 ppm by weight. [R307-401-8]

II.B.9.b.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of fuel oil shall be either by the owner/operator's own testing or by test
reports from the fuel oil marketer. [R307-203-1, R307-401-8]

DAQE-AN162000001-24
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II.B.9.b.2 The owner/operator shall keep and maintain records of the test certification of sulfur content in
fuel oil. Records of the test certifications shall be kept for all periods when the plant is in
operation. [R307-203-1, R307-401-8]

II.B.9.c The owner/operator shall control particulate emissions from each hot mix asphalt plant dryer
subject to this AO with a baghouse. [R307-401-8]

II.B.9.d The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across each baghouse. [R307-401-8]

II.B.9.d.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.9.d.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]

II.B.9.d.3 During operation of the baghouse, the owner/operator shall maintain the static pressure drop
across the baghouse between 3.0 and 7.0 inches of water column. [R307-401-8]

II.B.9.d.4 The owner/operator shall record the pressure drop at least once per operating day while the
baghouse is operating. [R307-401-8]

II.B.9.d.5 The owner/operator shall maintain the following records of the pressure drop readings:

A. Unit identification;

B. Date of reading;

C. Daily static pressure drop readings.

[R307-401-8]

II.B.9.d.6 At least once every 12 months, the owner/operator shall calibrate the pressure gauges in
accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]

II.B.9.e Each storage silo associated with a hot mix asphalt plant subject to this AO shall be equipped
with a fabric filter, a baghouse, a bin vent, or a dust collector to control particulate emissions
generated during filling of the silos. [R307-401-8]

II.B.9.f The owner/operator shall not allow visible emissions from any baghouse, bin vent, dust collector
or fabric filter associated with a hot mix asphalt plant subject to this AO to exceed 10 percent
opacity. [R307-401-8]

II.B.10 Stack Testing Requirements
II.B.10.a The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.10.a.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.10.a.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

DAQE-AN162000001-24
Page 12

II.B.10.a.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.10.a.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.10.a.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.10.a.6 Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.10.b Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K).

B. Pressure - 29.92 in Hg (101.3 kPa).

C. Averaging Time - As specified in the applicable test method.

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.10.b.1 PM
40 CFR 60, Appendix A, Method 5 or other EPA-approved testing method as acceptable to the
Director. [R307-401-8]

II.B.10.b.2 PM10
Total PM10 = Filterable PM10 + Condensable PM

Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10.

Condensable PM
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to
the Director.

[R307-401-8]

DAQE-AN162000001-24
Page 13

II.B.10.b.3 PM2.5
Total PM2.5 = Filterable PM2.5 + Condensable PM

Filterable PM2.5
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other
EPA-approved testing method as acceptable to the Director. If other approved testing methods
are used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the
filterable particulate emissions shall be considered PM2.5.

Condensable PM
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to
the Director.

[R307-401-8]

II.B.11 Emission Unit Specific Conditions
II.B.11.a The owner/operator shall not emit more than the following rates and concentrations from each
asphalt drum mixer:

Pollutant grains/dscf
PM 0.030
PM10 0.024
PM2.5 0.024

[R307-401-8]

II.B.11.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO.

The owner/operator shall test for condensable PM; however, the condensable particulate
emissions shall not be used for compliance demonstration, but shall be used for inventory
purposes.

[R307-165-2, R307-401-8]

II.B.11.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]

II.B.11.a.3 Test Frequency
The owner/operator shall conduct a stack test on the emission unit every third calendar year after
the date of the most recent stack test, not exceeding 42 months between tests. The Director may
require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

DAQE-AN162000001-24
Page 14

II.B.12 Stationary Diesel-Fired Engines:
II.B.12.a The owner/operator shall comply with the applicable requirements in 40 CFR 63 Subpart ZZZZ
and 40 CFR 60 Subpart IIII for all stationary engines. An engine is considered a stationary
engine if the engine meets the definition of "stationary reciprocating internal combustion engine
(RICE)" in 40 CFR 63.6675 or "stationary internal combustion engine" in 40 CFR 60.4219. In
determining whether an engine is considered a stationary engine, the time the engine remains at a
location shall be considered. 40 CFR 1068.30 states that an engine is a stationary engine if:

A. The engine remains at a location for more than 12 consecutive months.

B. The engine remains at a seasonal source during the full annual operating period
of the seasonal source. A seasonal source is a stationary source that remains in a
single location on a permanent basis (i.e., at least two (2) years) and that
operates at that single location approximately three (3) months (or more) each
year.

[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.12.b The owner/operator shall not allow visible emissions from any stationary diesel-fired engine
subject to this AO to exceed 20 percent opacity. [R307-201-3, R307-305-3, R307-401-8]

II.B.12.c The sulfur content of any fuel oil or diesel fuel burned in a stationary diesel-fired engine subject
to this AO shall not exceed 15 ppm.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.12.c.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of diesel fuel shall be either by the owner/operator's own testing or by
test reports from the diesel fuel marketer. [R307-203-1, R307-401-8]

II.B.12.c.2 The owner/operator shall keep and maintain records of the test certification of sulfur content in
diesel fuel. Records of the test certification shall be kept for all periods when the plant is in
operation. [R307-203-1, R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Is Derived From NOI dated February 26, 2024

DAQE-AN162000001-24
Page 15

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN162000001-24

April 4, 2024

Keith Gilbert
Southwest Grading and Paving, LLC
871 East Fiddler Canyon Road
Cedar City, UT 87421
[e-mail]

Dear Mr. Gilbert:

Re: Intent to Approve: New Portable Source (Aggregate, Hot Mix Asphalt, Concrete, and Stationary
Diesel-Fired Engines)
Project Number: N162000001

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Dungan Adams, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Dungan Adams, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DA:jg

cc: Salt Lake County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
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

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN162000001-24
New Portable Source (Aggregate, Hot Mix Asphalt, Concrete, and
Stationary Diesel-Fired Engines)

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
Southwest Grading and Paving, LLC - Portable Aggregate Source

Issued On
April 4, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 4
Source Classification .............................................................................................................. 4
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 14
ACRONYMS ............................................................................................................................... 15

DAQE-IN162000001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Southwest Grading and Paving, LLC Southwest Grading and Paving, LLC - Portable
Aggregate Source

Mailing Address Physical Address
871 East Fiddler Canyon Road Not Permanently based at a Site
Cedar City, UT 87421 Portable Source, UT

Source Contact
Name: Keith Gilbert
Phone: [phone]
Email: [e-mail]

SIC code 2951 (Asphalt Paving Mixtures & Blocks)

SOURCE INFORMATION
General Description
Southwest Grading and Paving, LLC has requested an AO for a portable source. This AO is issued to
Southwest Grading and Paving, LLC for the purpose of operating a portable source that belongs to the
nonmetallic mineral processing industry, including aggregate, concrete, and hot mix asphalt plants. The
plants subject to this AO shall be temporarily operated for a period of not more than 180 working days at
any location. A relocation shall not exceed 365 consecutive days at any location in the State of Utah.

Prior to the commencement of operation at a location, the owner/operator shall submit a Notice of
Temporary Relocation to the Director and obtain a Temporary Relocation Approval Letter. If the
owner/operator operates at a location in compliance with the AO, the Notice of Temporary Relocation,
and the Temporary Relocation Approval Letter, dispersion modeling results have determined that there
will be no adverse impacts on air quality at the nearest residence or commercial establishment.

Compliance with the opacity limits and operating practices contained in the conditions of the AO shall be
considered an application of BACT. The emission control measures required under the conditions of this
AO shall apply to all of the locations at which the source approved by this AO operates. The source may
be required to adopt additional measures for controlling emissions to address location-specific concerns.

This AO limits the source to emissions that are below the major source threshold, making it a "Synthetic
Minor" source.

DAQE-IN162000001-24
Page 4

NSR Classification
New Minor Source

Source Classification
Located in Portable Source County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), I: Standards of Performance for Hot Mix Asphalt Facilities
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 (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Description
The owner/operator has requested an AO for a portable source. The portable source belongs to the
nonmetallic mineral processing industry, including aggregate processing plants, concrete batch plants, hot
mix asphalt plants, and stationary diesel-fired engines.

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Salt Lake Tribune and Deseret News on April 7, 2024. During
the public comment period the proposal and the evaluation of its impact on air quality will be available
for the public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as
practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.

DAQE-IN162000001-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

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]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.A THE APPROVED EQUIPMENT

II.A.1 Portable Source
Including: Aggregate Processing Equipment, Concrete Batching Equipment, Hot Mix Asphalt
Equipment, and Diesel-Fired Engines

DAQE-IN162000001-24
Page 6

II.A.2 Aggregate Processing Equipment
These plants may be subject to NSPS Subpart OOO requirements. These plants include:

A. Crushers

B. Screens

C. Wash Plants

D. Conveyors, Feeders, Hoppers, and Stackers

II.A.3 Concrete Batch Plants
These plants include:

A. Central-Mix Concrete Batch Plants

B. Truck-Mix Concrete Batch Plants

C. Baghouses, Bin Vents, Dust Collectors, and Fabric Filters

D. Storage Silos: Contents include:
i. Cement
ii. Fly Ash
iii. Lime
iv. Concrete Additives

E. Boilers & Water Heaters
i. Fuel: Natural Gas/Propane
ii. Rating: less than 10 MMBtu/hr each

F. Conveyors, Feeders, Hoppers, Pugmills, and Stackers

II.A.4 Hot Mix Asphalt Plants
These plants may be subject to NSPS Subpart I requirements. These plants include:

A. Drum-Mix Hot Mix Asphalt Plants

B. Baghouses, Bin Vents, Dust Collectors, and Fabric Filters

C. Storage Silos: Contents include:
i. Lime
ii. Hot Mix Asphalt
iii. RAP
iv. Hot Mix Asphalt Additives

D. Conveyors, Feeders, Hoppers, Mixers, Pugmills, and Stackers

II.A.5 Stationary Diesel-Fired Engines
These stationary engines produce mechanical or electrical power to operate the plants in this AO.
These stationary engines are subject to MACT Subpart ZZZZ Requirements.
These stationary engines may be subject to NSPS Subpart IIII Requirements.

DAQE-IN162000001-24
Page 7

II.A.6 Storage Tanks
Contents include:

A. Asphalt Cement

B. Diesel Fuel

C. On-Specification Used Oil

D. Gasoline

E. Propane

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Notice of Temporary Relocation:
II.B.1.a The owner/operator shall submit a Notice of Temporary Relocation and obtain a Temporary
Relocation Approval Letter prior to operating a portable source at any location. [R307-401-8]

II.B.1.a.1 Notices of Temporary Relocation shall include the following information (Form 15a is available
from the DAQ):

A. The address and driving directions of the proposed location.

B. A list of the equipment to be operated at the proposed location, including:
1. The type of equipment.
2. The rated capacity of the equipment.
3. The date of manufacture of the equipment.

C. A site diagram showing the general equipment location on site (to scale), and the
distance to the nearest houses, barns, or commercial operations (to scale if the
plant boundary is located within one (1) mile of these buildings).

D. The expected startup and completion dates for operating at the proposed
location.

E. The expected hours of operation, including start and stop times.

F. The emission control measures that the owner/operator proposes to adopt for
each emission point at each location, including a FDCP specific to the proposed
location.

G. A reference to this AO.

[R307-401-8]

DAQE-IN162000001-24
Page 8

II.B.2 Temporary Relocation Approval Letter:
II.B.2.a The owner/operator shall operate and conduct its operations of the aggregate processing plants,
the concrete batch plants, the hot mix asphalt plants, and the diesel-fired engines in accordance
with the terms and conditions of this AO and the terms and conditions of the Temporary
Relocation Approval Letter issued by the Director for each relocation. In the case of any
discrepancy between the conditions of this AO and the Temporary Relocation Approval Letter,
the owner/operator shall comply with the site-specific requirements in the Temporary Relocation
Approval Letter. [R307-401-8]

II.B.2.a.1 Portable sources that plan to relocate to a stationary source listed in the Utah PM10 or PM2.5 State
Implementation Plan (SIP) shall comply with the standards and adopt the control strategies listed
in the PM10 or PM2.5 SIP for the stationary source in addition to the requirements of this AO and
the Temporary Relocation Approval Letter. [R307-401-8]

II.B.3 Operations at Temporary Locations:
II.B.3.a The owner/operator may temporarily relocate this portable source to any temporary location.
The temporary relocation shall not exceed 180 working days and shall not exceed 365
consecutive days. If a temporary relocation is expected to exceed 180 working days, the
owner/operator shall submit an NOI in accordance with R307-401 for a permanent source and
obtain a valid AO prior to the end of the 180 working days. [R307-401-17]

II.B.3.a.1 The owner/operator shall keep and maintain the following records on site:

A. The initial relocation date at each location.

B. Working days at each location.

C. Consecutive days at each location.

[R307-401-17]

II.B.3.a.2 The owner/operator shall submit records of the working days at each site and the consecutive
days at each site to the Director at the end of each 180 calendar days. [R307-401-17]

II.B.3.b The owner/operator shall not exceed the daily production limit specified in the Temporary
Relocation Approval Letter. [R307-401-8]

II.B.3.b.1 The daily production shall be determined by belt scale records, scale house records, vendor
receipts or by any other method as acceptable to the Director or the Director's representative.
[R307-401-8]

II.B.3.b.2 The owner/operator shall keep and maintain the following production records on site for all
periods that the portable source is in operation at any location:

A. The date production occurs at each location.

B. The production for that date at each location.

C. The total production at each location.

[R307-401-8]

II.B.3.b.3 The owner/operator shall submit records of the actual production rate to the Director at the end of
each 180 calendar days. [R307-401-17]

DAQE-IN162000001-24
Page 9

II.B.3.c The owner/operator shall only operate between 6:00 AM and 10:00 PM each day. The hours of
operation may be altered upon approval of the Director; however, any request for a change in
these hours shall include modeling showing that all NAAQS are met.
[R307-401-10, R307-401-8]

II.B.3.c.1 The owner/operator shall keep and maintain the following records of operation for all periods
that the portable source is in operation at any location:

A. The time operations began each day at each location.

B. The time operations ended each day at each location.

[R307-401-8]

II.B.3.d Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any installation of this AO to exceed 20 percent opacity. [R307-201-3, R307-305-3]

II.B.3.d.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, R307-305-3]

II.B.4 Emission Estimates and Emissions Inventory:
II.B.4.a The owner/operator shall estimate the actual emissions that resulted from operating at each
location. These emissions shall be summarized for each piece of equipment, each source of
fugitive dust, and each source of fugitive emissions at the completion of operation at each
location. The Director may require a summary of emissions for each location at any time.
[R307-401-8, R307-150-1]

II.B.4.a.1 Records of actual emissions shall be kept for each location. Records of actual emissions shall
include the following:

A. The emission factors used to estimate emissions for each location.

B. All variables (production, hours of operation, haul road lengths, etc.) used in
the emission estimates for each location.

C. The actual emissions from each location, which includes emissions from each
emission unit, each source of fugitive dust, and each source of fugitive
emissions.

[R307-401-8, R307-150-1]

II.B.5 Haul Roads and Fugitive Dust Sources:
II.B.5.a The owner/operator shall comply with a FDCP consistent with R307-309-6 for each location.
The FDCP for a location shall address the control of all fugitive dust sources at that location.
[R307-401-8]

II.B.5.b The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to
exceed 20 percent opacity on site and 10 percent at the property boundary for each temporary
location. [R307-205-4, R307-309-5, R307-401-8]

II.B.5.b.1 Visible emission determinations for fugitive dust from haul roads and 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 one-half vehicle length
behind the vehicle and not less than one-half the height of the vehicle.
[R307-205-4, R307-309-5, R307-401-8]

DAQE-IN162000001-24
Page 10

II.B.5.c The owner/operator shall use water application or other control options contained in R307-309 to
minimize emissions from fugitive dust and fugitive emissions sources, including haul roads,
storage piles, and disturbed areas. Controls shall be applied to ensure the opacity limits in this
AO are not exceeded. [R307-309, R307-401-8]

II.B.6 Aggregate Processing Plants:
II.B.6.a The owner/operator shall not allow visible emissions from any crusher subject to this AO to
exceed 12 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.b The owner/operator shall not allow visible emissions from any screen subject to this AO to
exceed 7 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.c The owner/operator shall not allow visible emissions from any conveyor transfer point subject to
this AO to exceed 7 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.d The owner/operator shall not allow visible emissions from any conveyor drop point at each
temporary location to exceed 20 percent opacity. [R307-205-4, R307-309-5, R307-401-8]

II.B.6.e 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]

II.B.6.f 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. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.f.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]

II.B.7 Crushers, Screens, and Conveyors subject to NSPS Subpart OOO:
II.B.7.a The owner/operator shall conduct an initial performance test for all crushers, screens, and
conveyor transfer points subject to this AO that are subject to NSPS OOO. Performance tests
shall meet the limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO]

II.B.7.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner or operator may use methods and procedures specified in 40 CFR
60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c).
[40 CFR 60 Subpart OOO]

II.B.7.a.2 The owner/operator shall keep and maintain records of the initial performance test for each
crusher, screen, and conveyor for the life of the equipment. The record of the initial performance
test must be made available to the Director or the Director's representative upon request.
[40 CFR 60 Subpart OOO, R307-401-8]

II.B.8 Concrete Batch Plants:
II.B.8.a The owner/operator shall not allow visible emissions from any concrete batch plant and the
associated equipment subject to this AO to exceed 7 percent opacity. [R307-401-8]

DAQE-IN162000001-24
Page 11

II.B.8.b Each storage silo associated with a concrete batch plant subject to this AO shall be equipped with
a fabric filter, a baghouse, a bin vent, or a dust collector to control particulate emissions
generated during filling of the silos. [R307-401-8]

II.B.9 Hot Mix Asphalt Plants:
II.B.9.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 subject to this AO.
[R307-401-8]

II.B.9.b The sulfur content of any fuel oil burned in the hot mix asphalt plants subject to this AO shall not
exceed 15 ppm by weight. [R307-401-8]

II.B.9.b.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of fuel oil shall be either by the owner/operator's own testing or by test
reports from the fuel oil marketer. [R307-203-1, R307-401-8]

II.B.9.b.2 The owner/operator shall keep and maintain records of the test certification of sulfur content in
fuel oil. Records of the test certifications shall be kept for all periods when the plant is in
operation. [R307-203-1, R307-401-8]

II.B.9.c The owner/operator shall control particulate emissions from each hot mix asphalt plant dryer
subject to this AO with a baghouse. [R307-401-8]

II.B.9.d The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across each baghouse. [R307-401-8]

II.B.9.d.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.9.d.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]

II.B.9.d.3 During operation of the baghouse, the owner/operator shall maintain the static pressure drop
across the baghouse between 3.0 and 7.0 inches of water column. [R307-401-8]

II.B.9.d.4 The owner/operator shall record the pressure drop at least once per operating day while the
baghouse is operating. [R307-401-8]

II.B.9.d.5 The owner/operator shall maintain the following records of the pressure drop readings:

A. Unit identification;

B. Date of reading;

C. Daily static pressure drop readings.

[R307-401-8]

II.B.9.d.6 At least once every 12 months, the owner/operator shall calibrate the pressure gauges in
accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]

II.B.9.e Each storage silo associated with a hot mix asphalt plant subject to this AO shall be equipped
with a fabric filter, a baghouse, a bin vent, or a dust collector to control particulate emissions
generated during filling of the silos. [R307-401-8]

DAQE-IN162000001-24
Page 12

II.B.9.f The owner/operator shall not allow visible emissions from any baghouse, bin vent, dust collector
or fabric filter associated with a hot mix asphalt plant subject to this AO to exceed 10 percent
opacity. [R307-401-8]

II.B.10 Stack Testing Requirements
II.B.10.a The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.10.a.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.10.a.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.10.a.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.10.a.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.10.a.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.10.a.6 Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.10.b Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K).

B. Pressure - 29.92 in Hg (101.3 kPa).

C. Averaging Time - As specified in the applicable test method.

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.10.b.1 PM
40 CFR 60, Appendix A, Method 5 or other EPA-approved testing method as acceptable to the
Director. [R307-401-8]

DAQE-IN162000001-24
Page 13

II.B.10.b.2 PM10
Total PM10 = Filterable PM10 + Condensable PM

Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10.

Condensable PM
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to
the Director.

[R307-401-8]

II.B.10.b.3 PM2.5
Total PM2.5 = Filterable PM2.5 + Condensable PM

Filterable PM2.5
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-
approved testing method as acceptable to the Director. If other approved testing methods are
used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the
filterable particulate emissions shall be considered PM2.5.

Condensable PM
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to
the Director.

[R307-401-8]

II.B.11 Emission Unit Specific Conditions
II.B.11.a The owner/operator shall not emit more than the following rates and concentrations from each
asphalt drum mixer:

Pollutant grains/dscf
PM 0.030
PM10 0.024
PM2.5 0.024

[R307-401-8]

II.B.11.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO.

The owner/operator shall test for condensable PM; however, the condensable particulate
emissions shall not be used for compliance demonstration, but shall be used for inventory
purposes.

[R307-165-2, R307-401-8]

II.B.11.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]

DAQE-IN162000001-24
Page 14

II.B.11.a.3 Test Frequency
The owner/operator shall conduct a stack test on the emission unit every third calendar year after
the date of the most recent stack test, not exceeding 42 months between tests. The Director may
require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

II.B.12 Stationary Diesel-Fired Engines:
II.B.12.a The owner/operator shall comply with the applicable requirements in 40 CFR 63 Subpart ZZZZ
and 40 CFR 60 Subpart IIII for all stationary engines. An engine is considered a stationary
engine if the engine meets the definition of "stationary reciprocating internal combustion engine
(RICE)" in 40 CFR 63.6675 or "stationary internal combustion engine" in 40 CFR 60.4219. In
determining whether an engine is considered a stationary engine, the time the engine remains at a
location shall be considered. 40 CFR 1068.30 states that an engine is a stationary engine if:

A. The engine remains at a location for more than 12 consecutive months.

B. The engine remains at a seasonal source during the full annual operating period
of the seasonal source. A seasonal source is a stationary source that remains in a
single location on a permanent basis (i.e., at least two (2) years) and that
operates at that single location approximately three (3) months (or more) each
year.

[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.12.b The owner/operator shall not allow visible emissions from any stationary diesel-fired engine
subject to this AO to exceed 20 percent opacity. [R307-201-3, R307-305-3, R307-401-8]

II.B.12.c The sulfur content of any fuel oil or diesel fuel burned in a stationary diesel-fired engine subject
to this AO shall not exceed 15 ppm.
[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.12.c.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of diesel fuel shall be either by the owner/operator's own testing or by
test reports from the diesel fuel marketer. [R307-203-1, R307-401-8]

II.B.12.c.2 The owner/operator shall keep and maintain records of the test certification of sulfur content in
diesel fuel. Records of the test certification shall be kept for all periods when the plant is in
operation. [R307-203-1, R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Is Derived From NOI dated February 26, 2023

DAQE-IN162000001-24
Page 15

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-NN162000001-24

April 4, 2024

Salt Lake Tribune and Deseret News
Legal Advertising Dept.
P.O. Box 704055
West Valley City, UT 84170
Acct #9001399880

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on April 7, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Wasatch Front Regional Council

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
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

DAQE-NN162000001-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Southwest Grading and Paving, LLC
Location: Southwest Grading and Paving, LLC - Portable Aggregate Source – Not
Permanently based at a Site, Portable Source, UT
Project Description: Southwest Grading and Paving, LLC has requested an Approval Order for a
portable source. The portable source belongs to the nonmetallic mineral
processing industry, including aggregate, concrete, and hot mix asphalt plants.
The plants shall be temporarily operated for a period of not more than 180
working days at any location. A relocation shall not exceed 365 consecutive
days at any location in the State of Utah. Dispersion modeling results have
determined that there will be no adverse impacts on air quality at the nearest
residence or commercial establishment if the source operates at a location in
compliance with the AO, the Notice of Temporary Relocation, and the
Temporary Relocation Approval Letter. Compliance with the opacity limits and
operating practices contained in the conditions of the Approval Order shall be
considered as application of BACT. The emission control measures required
under the conditions of the Approval Order shall apply to all of the locations at
which the source operates. The source may be required to adopt additional
measures for controlling emissions to address location-specific concerns.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before May 7, 2024 will be considered in making the
final decision on the approval/disapproval of the proposed project. Email comments will also be accepted
at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication
of this notice, a hearing will be held in accordance with
R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: April 7, 2024

{{#s=Sig_es_:signer1:signature}}

4/8/24, 10:39 AM utahlegals.com/(S(c1ti1vab0bzswl2yqqiosqr2))/DetailsPrint.aspx?SID=c1ti1vab0bzswl2yqqiosqr2&ID=182275
https://www.utahlegals.com/(S(c1ti1vab0bzswl2yqqiosqr2))/DetailsPrint.aspx?SID=c1ti1vab0bzswl2yqqiosqr2&ID=182275 1/1
The Salt Lake Tribune
Publication Name:
The Salt Lake Tribune
Publication URL:
Publication City and State:
Salt Lake City, UT
Publication County:
Salt Lake
Notice Popular Keyword Category:
Notice Keywords:
southwest grading
Notice Authentication Number:
202404081139338918379
1761527914
Notice URL:
Back
Notice Publish Date:
Sunday, April 07, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Southwest Grading and Paving, LLC Location: Southwest Grading and Paving,
LLC - Portable Aggregate Source – Not Permanently based at a Site, Portable Source, UT Project Description: Southwest Grading and Paving,
LLC has requested an Approval Order for a portable source. The portable source belongs to the nonmetallic mineral processing industry,
including aggregate, concrete, and hot mix asphalt plants. The plants shall be temporarily operated for a period of not more than 180
working days at any location. A relocation shall not exceed 365 consecutive days at any location in the State of Utah. Dispersion modeling
results have determined that there will be no adverse impacts on air quality at the nearest residence or commercial establishment if the
source operates at a location in compliance with the AO, the Notice of Temporary Relocation, and the Temporary Relocation Approval Letter.
Compliance with the opacity limits and operating practices contained in the conditions of the Approval Order shall be considered as
application of BACT. The emission control measures required under the conditions of the Approval Order shall apply to all of the locations at
which the source operates. The source may be required to adopt additional measures for controlling emissions to address location-specific
concerns. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of
federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public
comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection
and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division
at this same address on or before May 7, 2024 will be considered in making the final decision on the approval/disapproval of the proposed
project. Email comments will also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to
challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment
period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance
of the issue. Date of Notice: April 7, 2024 SLT0026924
Back

DAQE-MN162000001-24

M E M O R A N D U M

TO: 16200: Southwest Grading and Paving, LLC- Portable Aggregate Source - (N162000001)
THROUGH: Alan Humpherys, Minor NSR Manager – Air Quality
FROM: Dungan Adams, Environmental Engineer – Air Quality
DATE: May 8, 2024
SUBJECT: Response to Public Comment for 16200: Southwest Grading and Paving, LLC- Portable
Aggregate Source
An Intent to Approve (ITA) for Southwest Grading and Paving, LLC - Portable Aggregate Source was
proposed with a public comment period from April 7, 2024, through May 7, 2024. One commenter made
several comments on the proposed Approval Order (AO) [DAQE- IN162000001-24]. The comments are
attached to this memo.

The Division of Air Quality (DAQ) considered the received comments as required by Utah
Administrative Code (UAC) Rule R307-401-7(3) and provided the following responses:

Comment #1
A comment was received requesting the permit be denied due to Southwest Grading and Paving
(Southwest) trespassing on the Utah Iron property that it does not own or lease.

DAQ Response
To operate at any location, a portable source must submit a notice of temporary relocation and obtain a
temporary relocation authorization or approval letter under UAC Rule R307-401-17. See also ITA,
Condition II.B.1.a. A notice of temporary relocation must contain the exact location of the temporary site
as well as the location of the closest businesses or properties. See id., Condition II.B.1.a.1. The temporary
relocation authorization is issued only after the source’s generic AO has been approved. Southwest’s
portable AO has not yet been approved, and the company cannot yet submit temporary relocation
authorization. The ITA for Southwest is for a generic portable AO which does not specify the location of
operation. Therefore, property ownership does not affect Southwest’s ability to obtain a generic portable
AO. DAQ does not have the authority to determine property rights. It is the responsibility of the source to
obtain the necessary authorizations to operate in a specific location, whether through a lease or other
permission to operate. The commenter did not provide the authority that DAQ has to deny a permit due to
property rights.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
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

DAQE-MN162000001-24
Page 2

No changes were made as a result of this comment.

Comment #2
A comment was received requesting the permit be denied due to Southwest operating beyond the scope of
its Bureau of Land Management (BLM) permit. The requester asked the DAQ to contact the Cedar City
BLM office to verify Southwest’s federal permit status.

DAQ Response
Southwest’s AO has not been approved, and therefore, they are not permitted to operate at any specific
location at this time. The ITA for Southwest is for a generic portable AO which does not specify the
location of operation. See also the DAQ Response to Comment #1. The conditions and requirements of
Southwest’s BLM permit do not affect the applicant's ability to obtain a generic portable AO. The BLM
and DAQ have separate and distinct authorities. The DAQ is responsible for determining the impact of
the proposed source’s emissions of air pollutants and approving or denying the source’s application for a
permit. The BLM is responsible for issuing permits to allow for mineral extraction on BLM-managed
lands. The DAQ cannot interfere with the BLM’s regulatory authority. The ITA is within DAQ’s
authority to issue because it meets all the requirements of the Clean Air Act and state law. The
commenter failed to explain how the BLM and DAQ share authority.

No changes were made as a result of this comment.

Comment #3
A comment was received requesting confirmation that Southwest’s project meets the qualification of a
portable source and stating that Southwest has commenced construction and poured concrete pads to
make the operation permanent.

DAQ Response
Under UAC Rule R307-401-17, once a source receives its temporary relocation authorization, it shall not
operate at the same location for more than 180 working days or 365 consecutive days. If a temporary
relocation is expected to exceed 180 working days, the source shall submit a Notice of Intent (NOI) for a
permanent source. Southwest currently meets the qualifications of a portable source under this definition.
Southwest has not been permitted to operate at any location as it has not yet received its AO and a
temporary relocation authorization. Sources may not commence construction until they have received an
AO. DAQ compliance will evaluate whether Southwest has commenced construction without prior
approval from the Director and begin an enforcement action with potential penalties for noncompliance if
warranted. However, early construction does not necessarily disqualify the source from receiving an AO.

No changes were made as a result of this comment.

Comment #4
A comment was received requesting the DAQ confirm Southwest is complying with a fugitive dust
control plan (FDCP) and conducting proper watering operations.

DAQ Response
Under UAC Rule R307-309-3, a FDCP is required for projects 1/4 acre or larger, and located in Cache,
Box Elder, Weber, Davis, Salt Lake, Tooele, or Utah County. In addition, Condition II.B.5.a of the ITA
requires a source to submit and comply with a FDCP for each temporary relocation. Southwest does not
need to comply with this requirement at this time because its generic portable AO has not yet been
DAQE-MN162000001-24
Page 3
approved and does not permit operation at a specific location. Once Southwest has submitted a temporary
relocation authorization, the DAQ will require Southwest to submit and comply with a FDCP. If
Southwest commences construction and operation without prior authorization from DAQ, this will be
investigated by DAQ compliance and appropriately addressed through DAQ compliance process.

No changes were made as a result of this comment.

Engineer Review N162000001: Southwest Grading and Paving, LLC- Portable Aggregate Source
February 29, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N162000001
Owner Name Southwest Grading and Paving, LLC
Mailing Address 871 East Fiddler Canyon Road
Cedar City, UT, 87421

Source Name Southwest Grading and Paving, LLC- Portable Aggregate Source
Source Location Not Permanently based at a Site
Portable Source, UT

SIC Code 2951 (Asphalt Paving Mixtures & Blocks)

Source Contact Keith Gilbert
Phone Number [phone]
Email [e-mail]

Billing Contact Keith Gilbert
Phone Number [phone]
Email [e-mail]

Project Engineer Dungan Adams, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted February 26, 2024
Date of Accepted Application March 1, 2024

Engineer Review N162000001: Southwest Grading and Paving, LLC- Portable Aggregate Source
February 29, 2024
Page 2
SOURCE DESCRIPTION

General Description
Bedrock Sand & Gravel LLC has requested an AO for a portable source. This AO is issued to
Bedrock Sand & Gravel LLC for the purpose of operating a portable source that belongs to the
nonmetallic mineral processing industry, including aggregate, concrete, and hot mix asphalt
plants. The plants subject to this AO shall be temporarily operated for a period of not more than
180 working days at any location. A relocation shall not exceed 365 consecutive days at any
location in the State of Utah.

Prior to commencement of operation at a location, the owner/operator shall submit a Notice of
Temporary Relocation to the Director and obtain a Temporary Relocation Approval Letter. If the
owner/operator operates at a location in compliance with the AO, the Notice of Temporary
Relocation, and the Temporary Relocation Approval Letter, dispersion modeling results have
determined that there will be no adverse impacts on air quality at the nearest residence or
commercial establishment.

Compliance with the opacity limits and operating practices contained in the conditions of the AO
shall be considered as application of BACT. The emission control measures required in the
conditions of this AO shall apply to all of the locations at which the source approved by this AO
operates. The source may be required to adopt additional measures for controlling emissions to
address location-specific concerns.

This AO limits the source to emissions that are below the major source threshold, making it a
"Synthetic Minor" source.

NSR Classification:
New Minor Source

Source Classification
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), I: Standards of Performance for Hot Mix Asphalt Facilities
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 (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Proposal
New Portable Source (Aggregate, Hot Mix Asphalt, Concrete, and Stationary Diesel-Fired
Engines)

Engineer Review N162000001: Southwest Grading and Paving, LLC- Portable Aggregate Source
February 29, 2024
Page 3
Project Description
The owner/operator has requested an AO for a portable source. The portable source belongs to the
nonmetallic mineral processing industry, including aggregate processing plants, concrete batch
plants, hot mix asphalt plants, and stationary diesel-fired engines.

EMISSION IMPACT ANALYSIS
DAQ modeled a generic aggregate site to determine the appropriate operating conditions for this AO. Ambient
air quality impacts are smaller in the daytime hours than in the nighttime hours. To minimize impacts, the
times of operation were limited. Sources will be allowed to operate from 6:00 am to 10:00 pm. A permit
condition is included in this AO to reflect the time restriction of operation. More stringent times of operation
may be included in different areas of the State. If a source wants to operate outside these times, the source
must submit modeling with the temporary relocation letter to demonstrate that the NAAQS are met. [Last
updated February 29, 2024]

Engineer Review N162000001: Southwest Grading and Paving, LLC- Portable Aggregate Source
February 29, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Process Equipment
The process equipment for this portable source may include the following:

A. Aggregate Equipment (Crushers, Screens, Conveyors)
B. Concrete Batch Plants
C. Hot Mix Asphalt Plants
D. Stationary Diesel-Fired Engines

A. Aggregate Equipment (Crushers, Screens, Conveyor Transfer Points)

The following opacity limitations shall not be exceeded for the following aggregate equipment:
Crushers - 12%
Screens - 7%
Conveyor Transfer Points - 7%
Feeders - 7%
Stackers - 7%
Water sprays will control the emissions from crushers, screens, conveyors, feeders, and stackers.
Sprays will operate as needed to comply with the above opacity limits.

B. Concrete Batch Plants

Fabric filters will control the emissions from concrete batch plants, the batching operations, and
associated silos. The fabric filters will reduce visible emissions to 7% opacity or less. Any
boiler/water heater used will use natural gas and/or propane as fuel. Any boiler/water heater shall
be limited to 10% opacity.

C. Hot Mix Asphalt Plants

The hot mix asphalt plants may use propane, natural gas, fuel oil, on-specification used oil or any
combination of these fuels as fuel. A baghouse will control the emissions from the drum mixer.
The baghouse will reduce visible emissions to 10% opacity or less. In addition, the baghouse will
reduce the concentration of PM10 in the exhaust to 0.024 grains per dscf or less. To ensure the
baghouse is operating correctly, the baghouse pressure drop shall be between 3 and 7 inches of
water column. The pressure gauge shall measure the pressure drop in 1-inch water column
increments or less.

D. Stationary Diesel-Fired Engines

The NSR Section recommends the following as BACT for stationary diesel engines:
1. Proper engine tuning and maintenance
2. Visible emissions shall be 20% opacity or less
3. Sulfur content of fuel shall be 15 ppm or less
4. Compliance with the applicable federal standards contained in
a. 40 CFR 60, NSPS, Subpart IIII, and
b. 40 CFR 63, MACT, Subpart ZZZZ. [Last updated February 29, 2024]

2. BACT review regarding Fugitive Emissions and Fugitive Dust
To ensure fugitive emissions and fugitive dust will be controlled, the owner/operator will be
required to submit a FDCP for each location with the temporary relocation letter. Fugitive

Engineer Review N162000001: Southwest Grading and Paving, LLC- Portable Aggregate Source
February 29, 2024
Page 5
emissions and fugitive dust will be generated from the following:

A. Haul Roads
B. Storage Piles
C. Conveyor Drop Points
D. Material Handling Operations

A. Haul Roads

Wet suppression (or other chemical treatment) will control the emissions from haul roads. To
ensure the wet suppression is adequate, visible emissions from haul roads will not exceed 20%
opacity on site and 10% at the property boundary.

B. Storage Piles

Routine water application will control the emissions from storage piles. To ensure the water
application is of sufficient frequency, visible emissions from storage piles will not exceed 20%
opacity on site and 10% at the property boundary.

C. Conveyor Drop Points

Water sprays will control the emissions from conveyor drop points. Sprays will operate as needed
to reduce visible emissions to 20% opacity or less on site and 10% at the property boundary.

D. Material Handling Operations

Water application will control the emissions from material handling operations. To ensure the
water application is of sufficient frequency, visible emissions from material handling will not
exceed 20% opacity on site and 10% at the property boundary. [Last updated February 29, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

Engineer Review N162000001: Southwest Grading and Paving, LLC- Portable Aggregate Source
February 29, 2024
Page 6
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]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1
NEW
Portable Source
Including: Aggregate Processing Equipment, Concrete Batching Equipment, Hot Mix Asphalt
Equipment, and Diesel-Fired Engines

II.A.2
NEW
Aggregate Processing Equipment
These plants may be subject to NSPS Subpart OOO Requirements
These plants include:
A. Crushers
B. Screens
C. Wash Plants
D. Conveyors, Feeders, Hoppers, and Stackers

Engineer Review N162000001: Southwest Grading and Paving, LLC- Portable Aggregate Source
February 29, 2024
Page 7
II.A.3
NEW
Concrete Batch Plants
These plants include:
A. Central-Mix Concrete Batch Plants
B. Truck-Mix Concrete Batch Plants
C. Baghouses, Bin Vents, Dust Collectors and Fabric Filters
D. Storage Silos - Contents include:
i. Cement
ii. Fly Ash
iii. Lime
iv. Concrete Additives
E. Boilers & Water Heaters
i. Fuel: Natural Gas/Propane
ii. Rating: less than 10 MMBtu/hr each
F. Conveyors, Feeders, Hoppers, Pugmills, and Stackers

II.A.4
NEW
Hot Mix Asphalt Plants
These plants may be subject to NSPS Subpart I Requirements
These plants include:
A. Drum-Mix Hot Mix Asphalt Plants
B. Baghouses, Bin Vents, Dust Collectors and Fabric Filters
C. Storage Silos - Contents include:
i. Lime
ii. Hot Mix Asphalt
iii. RAP
iv. Hot Mix Asphalt Additives
D. Conveyors, Feeders, Hoppers, Mixers, Pugmills, and Stackers

II.A.5
NEW
Stationary Diesel-Fired Engines
These stationary engines produce mechanical or electrical power to operate the plants in this
AO.
These stationary engines are subject to MACT Subpart ZZZZ Requirements
These stationary engines may be subject to NSPS Subpart IIII Requirements

II.A.6
NEW
Storage Tanks
Contents include:
A. Asphalt Cement
B. Diesel Fuel
C. On-Specification Used Oil
D. Gasoline
E. Propane

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Page 8
SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1
NEW
Notice of Temporary Relocation:
II.B.1.a
NEW
The owner/operator shall submit a Notice of Temporary Relocation and obtain a Temporary
Relocation Approval Letter prior to operating a portable source at any location. [R307-401-8]

II.B.1.a.1
NEW
Notices of Temporary Relocation shall include the following information (Form 15a is
available from the DAQ):

A. The address and driving directions of the proposed location

B. A list of the equipment to be operated at the proposed location, including:
1. The type of equipment
2. The rated capacity of the equipment
3. The date of manufacture of the equipment

C. A site diagram showing the general equipment location on site (to scale), and the
distance to the nearest houses, barns or commercial operations (to scale if the plant
boundary is located within one mile of these buildings)

D. The expected startup and completion dates for operating at the proposed location.

E. The expected hours of operation, including start and stop times

F. The emission control measures that the owner/operator proposes to adopt for each
emission point at each location; including a FDCP specific to the proposed location

G. A reference to this AO

[R307-401-8]

II.B.2
NEW
Temporary Relocation Approval Letter:
II.B.2.a
NEW
The owner/operator shall operate and conduct its operations of the aggregate processing
plants, the concrete batch plants, the hot mix asphalt plants, and the diesel-fired engines in
accordance with the terms and conditions of this AO and the terms and conditions of the
Temporary Relocation Approval Letter issued by the Director for each relocation. In the case
of any discrepancy between the conditions of this AO and the Temporary Relocation
Approval Letter, the owner/operator shall comply with the site-specific requirements in the
Temporary Relocation Approval Letter. [R307-401-8]

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Page 9
II.B.2.a.1
NEW
Portable sources that plan to relocate to a stationary source listed in the Utah PM10 or PM2.5
State Implementation Plan (SIP) shall comply with the standards and adopt the control
strategies listed in the PM10 or PM2.5 SIP for the stationary source in addition to the
requirements of this AO and the Temporary Relocation Approval Letter. [R307-401-8]

II.B.3
NEW
Operations at Temporary Locations:
II.B.3.a
NEW
The owner/operator may temporarily relocate this portable source to any temporary location.
The temporary relocation shall not exceed 180 working days and shall not exceed 365
consecutive days. If a temporary relocation is expected to exceed 180 working days, the
owner/operator shall submit an NOI in accordance with R307-401 for a permanent source and
obtain a valid AO prior to the end of the 180 working days. [R307-401-17]

II.B.3.a.1
NEW
The owner/operator shall keep and maintain the following records on site:

A. The initial relocation date at each location

B. Working days at each location

C. Consecutive days at each location

[R307-401-17]

II.B.3.a.2
NEW
The owner/operator shall submit records of the working days at each site and the consecutive
days at each site to the Director at the end of each 180 calendar days. [R307-401-17]

II.B.3.b
NEW
The owner/operator shall not exceed the daily production limit specified in the Temporary
Relocation Approval Letter. [R307-401-8]

II.B.3.b.1
NEW
The daily production shall be determined by belt scale records, scale house records, vendor
receipts or by any other method as acceptable to the Director or the Director's representative.
[R307-401-8]

II.B.3.b.2
NEW
The owner/operator shall keep and maintain the following production records on site for all
periods that the portable source is in operation at any location:

A. The date production occurs at each location

B. The production for that date at each location

C. The total production at each location

[R307-401-8]

II.B.3.b.3
NEW
The owner/operator shall submit records of the actual production rate to the Director at the
end of each 180 calendar days. [R307-401-17]

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II.B.3.c
NEW
The owner/operator shall only operate between 6:00 AM and 10:00 PM each day. The hours
of operation may be altered upon approval of the Director; however, any request for a change
in these hours shall include modeling showing that all NAAQS are met. [R307-401-8, R307-
401-10]

II.B.3.c.1
NEW
The owner/operator shall keep and maintain the following records of operation for all periods
that the portable source is in operation at any location:

A. The time operations began each day at each location

B. The time operations ended each day at each location

[R307-401-8]

II.B.3.d
NEW
Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions
from any installation of this AO to exceed 20 percent opacity. [R307-201-3, R307-305-3]

II.B.3.d.1
NEW
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,
R307-305-3]

II.B.4
NEW
Emission Estimates and Emissions Inventory:
II.B.4.a
NEW
The owner/operator shall estimate the actual emissions that resulted from operating at each
location. These emissions shall be summarized for each piece of equipment, each source of
fugitive dust, and each source of fugitive emissions at the completion of operation at each
location. The Director may require a summary of emissions for each location at any time.
[R307-401-8, R307-150-1]

II.B.4.a.1
NEW
Records of actual emissions shall be kept for each location. Records of actual emissions shall
include the following:

A. The emission factors used to estimate emissions for each location

B. All variables (production, hours of operation, haul road lengths, etc.) used in
the emission estimates for each location

C. The actual emissions from each location, which includes emissions from each
emission unit, each source of fugitive dust, and each source of fugitive emissions

[R307-401-8, R307-150-1]

II.B.5
NEW
Haul Roads and Fugitive Dust Sources:
II.B.5.a
NEW
The owner/operator shall comply with a FDCP consistent with R307-309-6 for each location.
The FDCP for a location shall address the control of all fugitive dust sources at that location.
[R307-401-8]

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Page 11
II.B.5.b
NEW
The owner/operator shall not allow visible emissions from haul roads and fugitive dust
sources to exceed 20 percent opacity on site and 10 percent at the property boundary for each
temporary location. [R307-205-4, R307-309-5, R307-401-8]

II.B.5.b.1
NEW
Visible emission determinations for fugitive dust from haul roads and 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 one-half vehicle
length behind the vehicle and not less than one-half the height of the vehicle. [R307-205-4,
R307-309-5, R307-401-8]

II.B.5.c
NEW
The owner/operator shall use water application or other control options contained in R307-309
to minimize emissions from fugitive dust and fugitive emissions sources, including haul roads,
storage piles, and disturbed areas. Controls shall be applied to ensure the opacity limits in this
AO are not exceeded. [R307-309, R307-401-8]

II.B.6
NEW
Aggregate Processing Plants:
II.B.6.a
NEW
The owner/operator shall not allow visible emissions from any crusher subject to this AO to
exceed 12 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.b
NEW
The owner/operator shall not allow visible emissions from any screen subject to this AO to
exceed 7 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.c
NEW
The owner/operator shall not allow visible emissions from any conveyor transfer point subject
to this AO to exceed 7 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.d
NEW
The owner/operator shall not allow visible emissions from any conveyor drop point at each
temporary location to exceed 20 percent opacity. [R307-205-4, R307-309-5, R307-401-8]

II.B.6.e
NEW
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]

II.B.6.f
NEW
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. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.6.f.1
NEW
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]

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Page 12
II.B.7
NEW
Crushers, Screens, and Conveyors subject to NSPS Subpart OOO:
II.B.7.a
NEW
The owner/operator shall conduct an initial performance test for all crushers, screens, and
conveyor transfer points subject to this AO that are subject to NSPS OOO. Performance tests
shall meet the limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO]

II.B.7.a.1
NEW
Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner or operator may use methods and procedures specified in 40 CFR
60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR
60.675(c). [40 CFR 60 Subpart OOO]

II.B.7.a.2
NEW
The owner/operator shall keep and maintain records of the initial performance test for each
crusher, screen, and conveyor for the life of the equipment. The record of the initial
performance test must be made available to the Director or the Director's representative upon
request. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.8
NEW
Concrete Batch Plants:
II.B.8.a
NEW
The owner/operator shall not allow visible emissions from any concrete batch plant and the
associated equipment subject to this AO to exceed 7 percent opacity. [R307-401-8]

II.B.8.b
NEW
Each storage silo associated with a concrete batch plant subject to this AO shall be equipped
with a fabric filter, a baghouse, a bin vent, or a dust collector to control particulate emissions
generated during filling of the silos. [R307-401-8]

II.B.9
NEW
Hot Mix Asphalt Plants:
II.B.9.a
NEW
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 subject to
this AO. [R307-401-8]

II.B.9.b
NEW
The sulfur content of any fuel oil burned in the hot mix asphalt plants subject to this AO shall
not exceed 15 ppm by weight. [R307-401-8]

II.B.9.b.1
NEW
The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of fuel oil shall be either by the owner/operator's own testing or by
test reports from the fuel oil marketer. [R307-203-1, R307-401-8]

II.B.9.b.2
NEW
The owner/operator shall keep and maintain records of the test certification of sulfur content
in fuel oil. Records of the test certifications shall be kept for all periods when the plant is in
operation. [R307-203-1, R307-401-8]

II.B.9.c
NEW
The owner/operator shall control particulate emissions from each hot mix asphalt plant dryer
subject to this AO with a baghouse. [R307-401-8]

II.B.9.d
NEW
The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
static pressure drop across each baghouse. [R307-401-8]

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Page 13
II.B.9.d.1
NEW
The pressure gauge shall be located such that an inspector/operator can safely read the
indicator at any time. [R307-401-8]

II.B.9.d.2
NEW
The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]

II.B.9.d.3
NEW
During operation of the baghouse, the owner/operator shall maintain the static pressure drop
across the baghouse between 3.0 and 7.0 inches of water column. [R307-401-8]

II.B.9.d.4
NEW
The owner/operator shall record the pressure drop at least once per operating day while the
baghouse is operating. [R307-401-8]

II.B.9.d.5
NEW
The owner/operator shall maintain the following records of the pressure drop readings:

A. Unit identification;

B. Date of reading;

C. Daily static pressure drop readings. [R307-401-8]

II.B.9.d.6
NEW
At least once every 12 months, the owner/operator shall calibrate the pressure gauges in
accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]

II.B.9.e
NEW
Each storage silo associated with a hot mix asphalt plant subject to this AO shall be equipped
with a fabric filter, a baghouse, a bin vent, or a dust collector to control particulate emissions
generated during filling of the silos. [R307-401-8]

II.B.9.f
NEW
The owner/operator shall not allow visible emissions from any baghouse, bin vent, dust
collector or fabric filter associated with a hot mix asphalt plant subject to this AO to exceed 10
percent opacity. [R307-401-8]

II.B.10
NEW
Stack Testing Requirements
II.B.10.a
NEW
The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.10.a.1
NEW
Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.10.a.2
NEW
Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

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Page 14
II.B.10.a.3
NEW
Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.10.a.4
NEW
Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.10.a.5
NEW
Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.10.a.6
NEW
Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved
test methods as acceptable to the Director. Acceptable test methods for pollutants are listed
below. [R307-401-8]

II.B.10.b
NEW
Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K)

B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.10.b.1
NEW
PM
40 CFR 60, Appendix A, Method 5 or other EPA-approved testing method as acceptable to
the Director. [R307-401-8]

II.B.10.b.2
NEW
PM10
Total PM10 = Filterable PM10 + Condensable PM

Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate
emissions, all of the filterable particulate emissions shall be considered PM10.

Condensable PM
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to
the Director. [R307-401-8]

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II.B.10.b.3
NEW
PM2.5
Total PM2.5 = Filterable PM2.5 + Condensable PM

Filterable PM2.5
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-
approved testing method as acceptable to the Director. If other approved testing methods are
used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the
filterable particulate emissions shall be considered PM2.5.

Condensable PM
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to
the Director. [R307-401-8]

II.B.11
NEW
Emission Unit Specific Conditions
II.B.11.a
NEW
The owner/operator shall not emit more than the following rates and concentrations from each
asphalt drum mixer:

Pollutant grains/dscf
PM 0.030
PM10 0.024
PM2.5 0.024.

[R307-401-8]

II.B.11.a.1
NEW
Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained
in this AO.

The owner/operator shall test for condensable PM; however, the condensable particulate
emissions shall not be used for compliance demonstration, but shall be used for inventory
purposes. [R307-165-2, R307-401-8]

II.B.11.a.2
NEW
Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days
after startup of the emission unit. [R307-165-2]

II.B.11.a.3
NEW
Test Frequency
The owner/operator shall conduct a stack test on the emission unit every third calendar year
after the date of the most recent stack test, not exceeding 42 months between tests. The
Director may require the owner/operator to perform a stack test at any time. [R307-165-2,
R307-401-8]

II.B.12
NEW
Stationary Diesel-Fired Engines:

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II.B.12.a
NEW
The owner/operator shall comply with the applicable requirements in 40 CFR 63 Subpart
ZZZZ and 40 CFR 60 Subpart IIII for all stationary engines. An engine is considered a
stationary engine if the engine meets the definition of "stationary reciprocating internal
combustion engine (RICE)" in 40 CFR 63.6675 or "stationary internal combustion engine" in
40 CFR 60.4219. In determining whether an engine is considered a stationary engine, the time
the engine remains at a location shall be considered. 40 CFR 1068.30 states that an engine is a
stationary engine if:

A. The engine remains at a location for more than 12 consecutive months.

B. The engine remains at a seasonal source during the full annual operating period of the
seasonal source. A seasonal source is a stationary source that remains in a single
location on a permanent basis (i.e., at least two years) and that operates at that single
location approximately three months (or more) each year.

[40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.12.b
NEW
The owner/operator shall not allow visible emissions from any stationary diesel-fired engine
subject to this AO to exceed 20 percent opacity. [R307-201-3, R307-305-3, R307-401-8]

II.B.12.c
NEW
The sulfur content of any fuel oil or diesel fuel burned in a stationary diesel-fired engine
subject to this AO shall not exceed 15 ppm. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart
ZZZZ, R307-401-8]

II.B.12.c.1
NEW
The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of diesel fuel shall be either by the owner/operator's own testing or
by test reports from the diesel fuel marketer. [R307-203-1, R307-401-8]

II.B.12.c.2
NEW
The owner/operator shall keep and maintain records of the test certification of sulfur content
in diesel fuel. Records of the test certification shall be kept for all periods when the plant is in
operation. [R307-203-1, R307-401-8]

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Page 17
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Is Derived From NOI dated February 26, 2023

REVIEWER COMMENTS

1. Comment regarding NSPS and MACT Applicability:
NSPS
40 CFR 60 Subpart IIII applies to "owner and operators of stationary CI ICE that commence
construction after July 11, 2005". Because the source operates a stationary CI ICE manufactured
after 2005, NSPS Subpart IIII applies to the source.

40 CFR 60 Subpart I applies to sources who operate hot mix asphalt facilities constructed after June
11, 1973. Because the source operates a hot mix asphalt facility using this portable AO, NSPS
Subpart I applies to the source.

40 CFR 60 Subpart OOO applies to each crusher, screening operation, and belt conveyor in fixed or
portable nonmetallic mineral processing plant manufactured after August 31, 1983. If the source
decides to operate any of this equipment using this portable AO, Subpart OOO will apply to the
source.

MACT
40 CFR 63 Subpart ZZZZ applies to owners and operators of a RICE at any area source of HAP
emissions. Because this source operates a RICE at a site(s) that are considered area sources, MACT
Subpart ZZZZ applies to this source. [Last updated February 29, 2024]

2. Comment regarding Title V Applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following:

1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources;
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants.
4. Any Title IV affected source.

The portable equipment in this AO is not part of a major source or a Title IV source, and is not
subject to 40 CFR 61 requirements, but the facility is subject to 40 CFR 60 NSPS Subpart I and
OOO requirements. Therefore, Title V applies to the source where this portable equipment operates
[Last updated February 29, 2024]

3. Comment regarding Recordkeeping:
This AO contains numerous recordkeeping requirements to demonstrate compliance. To assist the
owner/operator, this Review Comment lists all the records that are required by this AO.

1. The initial relocation date at each location
2. Working days at each location

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3. Consecutive days at each location
4. The date production occurs at each location
5. The production for each date at each location
6. The total production at each location
7. The time operations began each day at each location
8. The time operations ended each day at each location
9. The emission factors used to estimate emissions for each location
10. All variables used in the emission estimates for each location
11. The emissions from each emission unit, each source of fugitive dust, and each source of fugitive
emissions at each location
12. Date the water spray inspections were made
13. Any corrective actions taken for the water sprays
14. Control mechanism used if sprays are not operating.
15. The initial performance test for each affected facility as defined in NSPS Subpart OOO
16. The certification of sulfur content in fuel oil used in the asphalt plants
17. The pressure gauge reading for each day of operation
18. The applicable records contained in 40 CFR 60 Subpart IIII and 40 CFR 63 Subpart ZZZZ for
each stationary engine subject to this AO
19. The certification of sulfur content in diesel fuel used in the stationary engines [Last updated
February 29, 2024]

4. Comment regarding Reporting:
R307-401-17 requires that "records of the working days at each site, consecutive days at each site,
and actual production rate shall be submitted to the director at the end of each 180 calendar days."
The owner/operator must submit this information to be in compliance with R307-401-17. [Last
updated February 29, 2024]

5. Comment regarding Hot Mix Asphalt Plant Condensable PM Emissions:
Condensable PM emissions shall not be used for compliance demonstration during stack testing;
however, condensable PM emissions shall be used for inventory purposes. There are several reasons
condensable PM emissions will not be used for compliance demonstration.

A. NSPS Subpart I does not limit condensable PM emissions. DAQ is unaware of any other
regulation that limits PM emissions, including condensable PM emissions, from hot mix asphalt
plants. Since federal regulations only limit filterable PM emissions, only filterable PM emissions
will be used for compliance demonstration.

B. The control device used to control PM emissions from a hot mix asphalt plant is a baghouse. A
baghouse is unable to control condensable PM emissions from a hot mix asphalt plant. One of the
purposes of a stack test is to ensure the control device is operating correctly. Since the baghouse can
only control filterable PM emissions, only filterable PM emissions will be used for compliance
demonstration.

C. The majority of uncontrolled emissions from a hot mix asphalt plant is filterable emissions.
Based on AP-42, an uncontrolled 400 tph hot mix asphalt plant will emit 11,200 pounds of filterable
PM per hour and 7.8 pounds of condensable PM per hour. The amount of uncontrolled filterable PM
emissions is over 1,400 times higher than the condensable PM emissions. Since the uncontrolled
filterable PM emissions are so high, only filterable PM emissions will be tested for compliance
demonstration.

D. Condensable PM emissions can vary depending on the fuel being combusted, the burner, the

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Page 19
material being fed into the hot mix asphalt plant, and other factors. It is inappropriate to put a single
limit in a permit that could apply to different locations, different plants, different materials, and
different fuels. Due to the high variability of these factors, condensable emissions will not be used
for compliance demonstration for this portable source.

Due to the reasons above, condensable PM emissions will not be tested for compliance
demonstration; however, condensable PM emissions will be used for inventory purposes. The
Director may require an emissions inventory at any time according to R307-150-1(4). Because this
source is a Title V area source, this source is required to pay Title V fees according to R307-415-9.
Both filterable and condensable PM emissions are considered chargeable pollutants; therefore, the
owner/operator must test for condensable PM emissions for inventory purposes. [Last updated
February 29, 2024]

6. Comment regarding Definition of Stationary Engines:
The definition of stationary internal combustion engine in NSPS Subpart IIII (40 CFR 60.4219) is as
follows:
Stationary internal combustion engine means any internal combustion engine, except combustion
turbines, that converts heat energy into mechanical work and is not mobile. Stationary ICE differ
from mobile ICE in that a stationary internal combustion engine is not a nonroad engine as defined
at 40 CFR 1068.30 (excluding paragraph (2)(ii) of that definition), and is not used to propel a motor
vehicle, aircraft, or a vehicle used solely for competition. Stationary ICE include reciprocating ICE,
rotary ICE, and other ICE, except combustion turbines.

The definition of nonroad engine in 40 CFR 1068.30 is as follows:

Nonroad engine means:

(1) Except as discussed in paragraph (2) of this definition, a nonroad engine is an internal
combustion engine that meets any of the following criteria:

(i) It is (or will be) used in or on a piece of equipment that is self-propelled or serves a dual purpose
by both propelling itself and performing another function (such as garden tractors, off-highway
mobile cranes and bulldozers).

(ii) It is (or will be) used in or on a piece of equipment that is intended to be propelled while
performing its function (such as lawnmowers and string trimmers).

(iii) By itself or in or on a piece of equipment, it is portable or transportable, meaning designed to be
and capable of being carried or moved from one location to another. Indicia of transportability
include, but are not limited to, wheels, skids, carrying handles, dolly, trailer, or platform.

(2) An internal combustion engine is not a nonroad engine if it meets any of the following criteria:

(i) The engine is used to propel a motor vehicle, an aircraft, or equipment used solely for
competition.

(ii) The engine is regulated under 40 CFR part 60, (or otherwise regulated by a federal New Source
Performance Standard promulgated under section 111 of the Clean Air Act (42 U.S.C. 7411)). Note
that this criterion does not apply for engines meeting any of the criteria of paragraph (1) of this
definition that are voluntarily certified under 40 CFR part 60.

(iii) The engine otherwise included in paragraph (1)(iii) of this definition remains or will remain at a

Engineer Review N162000001: Southwest Grading and Paving, LLC- Portable Aggregate Source
February 29, 2024
Page 20
location for more than 12 consecutive months or a shorter period of time for an engine located at a
seasonal source. A location is any single site at a building, structure, facility, or installation. For any
engine (or engines) that replaces an engine at a location and that is intended to perform the same or
similar function as the engine replaced, include the time period of both engines in calculating the
consecutive time period. An engine located at a seasonal source is an engine that remains at a
seasonal source during the full annual operating period of the seasonal source. A seasonal source is a
stationary source that remains in a single location on a permanent basis (i.e., at least two years) and
that operates at that single location approximately three months (or more) each year. See §1068.31
for provisions that apply if the engine is removed from the location. [Last updated February 29,
2024]

7. Comment regarding Definition of Stationary Engines (Cont'd):
40 CFR 1068.31 has the following requirements:

(b) A stationary engine becomes a new nonroad engine if-

(1) It is used in an application that meets the criteria specified in paragraphs (1)(i) or (ii) in the
definition of "nonroad engine" in §1068.30.

(2) It meets the criteria specified in paragraph (1)(iii) of the definition of "nonroad engine" in
§1068.30 and is moved so that it fails to meet (or no longer meets) the criteria specified in paragraph
(2)(iii) in the definition of "nonroad engine" in §1068.30.

(c) A stationary engine does not become a new nonroad engine if it is moved but continues to meet
the criteria specified in paragraph (2)(iii) in the definition of "nonroad engine" in §1068.30 in its new
location. For example, a transportable engine that is used in a single specific location for 18 months
and is later moved to a second specific location where it will remain for at least 12 months is
considered to be a stationary engine in both locations. Note that for stationary engines that are
neither portable nor transportable in actual use, the residence-time restrictions in the definition of
"nonroad engine" generally do not apply.

(e) A nonroad engine ceases to be a nonroad engine and becomes a new stationary engine if-

(1) At any time, it meets the criteria specified in paragraph (2)(iii) in the definition of "nonroad
engine" in §1068.30. For example, a portable generator engine ceases to be a nonroad engine if it is
used or will be used in a single specific location for 12 months or longer. If we determine that an
engine will be or has been used in a single specific location for 12 months or longer, it ceased to be a
nonroad engine when it was placed in that location.

(2) It is otherwise regulated by a federal New Source Performance Standard promulgated under
section 111 of the Clean Air Act (42 U.S.C. 7411). [Last updated February 29, 2024]

Engineer Review N162000001: Southwest Grading and Paving, LLC- Portable Aggregate Source
February 29, 2024
Page 21
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

3143 E. Lyndale Avenue ● Helena, MT 59601 ● 406-442-5768
E-MAIL: [e-mail] ● www.bison-eng.com

February 26, 2024

Dungan Adams
Air Quality Bureau
Minor NSR Section
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116

Dear Mr. Adams:

RE: 2024 Portable Permit Application for Asphalt Plant

On behalf of Southwest Grading and Paving, Bison Engineering is submitting the following
required documents for the Southwest Grading and Paving portable permit application:
 Form 01b – Best Available Control Technology
 Form 15b – Equipment Registration Form for Generic Portable Equipment
 Form 15c – Portable General Permit Application

I hereby certify that, based on information and belief formed after reasonable inquiry, the
statements and information provided herein are true, accurate, and complete.

Sincerely,

Kellen Sullivan
Consulting Director

cc: Keith Gilbert, Southwest Grading and Paving
Diane Lorenzen, P.E., Bison Engineering
Cade Barthuly, Bison Engineering

ATTACHMENTS:

Attachment A: Form 01b – Best Available Control Technology

Attachment B: Form 15b – Equipment Registration Form for
Generic Portable Equipment

Attachment C: Form 15c – Portable General Permit Application

ATTACHMENT A: Form 01b – Best Available Control
Technology
BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS

UACR R307-401-6 requires the owner or operator of a new or altered source the degree of pollution control
for emissions, to include fugitive emissions and fugitive dust, is at least best available control technology
except as otherwise provided in these regulations.

BACT Analysis Methodology

This BACT analysis follows the procedure outlined in the New Source Review Workshop Manual, Ofϐice of Air
Quality Planning and Standards, US EPA, Draft - October 1990. The methodology described in the manual is
the “top-down” method and consists of ϐive basic steps:

Step 1 - Identify all control technologies;
Step 2 - Eliminate technically infeasible options;
Step 3 - Rank remaining technologies by control effectiveness;
Step 4 - Evaluate most effective controls and document results; and
Step 5 - Select BACT.

Portable Asphalt Plant BACT analysis

The emissions inventory for the Southwest Grading and Paving (SWG) portable asphalt plant identiϐies four
point sources of emissions as follows:

1. Asphalt Drum Mixer Dryer
2. Plant Load-out
3. Silo Filling
4. Diesel-ϐired Electrical Generator Engine

The plant load-out and the silo ϐilling only emit particulate matter and have PTE emissions much lower than 1
tpy. BACT analysis is not included for these insigniϐicant sources.

BACT analysis is included for the asphalt drum dryer emissions and for the diesel-ϐired generator emissions.

A. Asphalt Drum Mixer

The applicant has reviewed relevant control options, as well as previous BACT determinations. The
following control options were reviewed in order to make the following BACT determinations:

 Fabric Filter Baghouse
 Electrostatic Precipitator
 Cyclone
 Wet Scrubber

All of the listed technologies are deemed technically feasible for this application. Technical feasible
control options, in order the highest control efficiency to the lowest control efficiency base on PM
control are as follows:

1. Fabric Filter Baghouse (99 – 99.9% efficient) (EPA Fact Sheet EPA-452/F-03-025,
07/15/03)
2. Electrostatic Precipitator (99 – 99.9% efficient) (EPA Fact Sheet EPA-452/F-03-028,
07/15/03)
3. Cyclone (up to 99% efficient) (EPA Fact Sheet EPA-452/F-03-005, 07/15/03)
4. Wet Scrubber (70 – greater than 99% efficient) (EPA Fact Sheet EPA-452/F-03- 0017,
07/15/03)

The asphalt plant purchased by SWG is equipped with a fabric filter baghouse for the control of
PM/PM10/PM2.5 from the exhaust of the asphalt drum mixer. Because SWG proposes to use a
control technology that is equivalent to the highest control efficiency, no further economic analysis
is needed to complete the BACT analysis.

The control option selected has control technology and a control cost comparable to other recently
permitted similar sources and is capable of achieving the appropriate emissions standards.
Operating and maintaining a baghouse will constitute BACT for the asphalt drum mixer. All asphalt
drum mixer emissions are limited to 0.04 grains per dry standard cubic foot (gr/dscf) for
particulate and 20 percent opacity in accordance with 40 CFR 60, Subpart I.

The Portable baghouse will control process streams from the asphalt plant drum mixer. This
baghouse is sized to handle the exhaust asphalt plant. All exhaust air from the drum mixer will be
routed through the baghouse before being vented to the atmosphere. Based on other asphalt plants
this is believed to be the best option for a control device in terms of cost and efϐiciency for the
asphalt plant.

B. Diesel Generator

The SWG equipment for the portable asphalt site will include a 280 kW diesel generator. The diesel
engine will be EPA certified for compliance with the Tier 2 or Tier 3 emission limits for a stationary
emergency engine. The engine will be required to comply with the federal engine emission
standards found in 40 CFR Part 63, Subpart ZZZZ and/or NSPS emission limitations for stationary CI
ICE (40 CFR 60, Subpart IIII).

Due to the limited amount of emissions produced by the diesel engines and the lack of readily
available, cost effective add-on controls; add-on controls would be cost prohibitive. Therefore, the
Department determined proper operation and maintenance with no add-on controls would
constitute BACT for the diesel engines.

In addition, any stationary diesel engine would be required to comply with the federal engine
emission standards found in 40 CFR Part 63, Subpart ZZZZ and/or NSPS emission limitations for
stationary CI ICE (40 CFR 60, Subpart IIII).

C. Fugitive Emissions

SWG will take reasonable precautions to limit the fugitive emissions of airborne particulate matter
on haul roads, access roads, parking lots, and the general plant area. Reasonable precautions
include treating all unpaved portions of the haul roads, access roads, parking lots, or the general
plant area with water and/or chemical dust suppressant, as necessary. Using water and/or
chemical dust suppressant to comply with the reasonable precautions limitation will be considered
BACT.

ATTACHMENT B: Form 15b – Equipment Registration Form
for Generic Portable Equipment
Page 1 of 3

Contact Name
Company Name
Mailing Address
City, State, Zip
Division of Air Quality
New Source Review Section

Form 15b
Equipment Registration Form for Generic Portable Equipment

Keith Gilbert
Southwest Grading and Paving, LLC
871 E. Fiddler Canyon Road
Cedar City, UT 87421
Use the following guidelines to complete the information requested on the back of this form.

Equipment types to list: crushers, screens, generators, asphalt batch plants, and concrete batch plants
(include all grandfathered equipment.)
Various associated support equipment such as conveyors, loaders, dozers, water pumps, water trucks, haul
trucks, and service trucks do not need to be listed individually.
Applicable Federal standards: ►NSPS Subpart OOO applies to non-metallic mineral processing
facilities. This regulation applies to aggregate processing equipment that was
constructed, modified, or reconstructed* after August 31, 1983.
► NSPS Subpart I applies to hot mix asphalt facilities. This regulation applies
to all asphalt batch plants that were constructed, modified, or reconstructed*
after June 11, 1973.
► NSPS Subpart JJJJ applies to stationary spark ignition combustion engines
► NSPS Subpart IIII applies to stationary compression ignition internal
combustion engines.
► MACT Subpart ZZZZ applies to stationary reciprocating internal combustion
engines
► There are currently no applicable Federal standards for concrete batch plants.
* See 40 CFR 60 (Code of Federal Regulations, Title 40, Part 60) for definitions of construction,
modification, and reconstruction.

Instructions
This form is used to register all portable equipment. Please provide the following information:
1. Name of person the Division of Air Quality (DAQ) should contact concerning this form.
2. Name and address of company.
3. Fill in the indicated information for each piece of equipment. If the equipment has not been
inspected, started up, or tested, leave the dates blank. Attach additional sheets if needed.

Page 2 of 3
Equipment Registration Form for
Generic Portable Equipment

Form 15b (continued)

Equipment Type: Drum Dryer (Leave dates blank for actions that have not occurred )
Make/Model TM2000 Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity 80 TPH
NSPS Performance Test Date
Equipment Type: Baghouse (Leave dates blank for actions that have not occurred )
Make/Model Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity
NSPS Performance Test Date
Equipment Type: A/C Tank (Leave dates blank for actions that have not occurred )
Make/Model Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity 15000 gal
NSPS Performance Test Date
Equipment Type: Bin Feeder (Leave dates blank for actions that have not occurred )
Make/Model Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity
NSPS Performance Test Date
Equipment Type: Bucket Elevator (Leave dates blank for actions that have not occurred )
Make/Model Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity
NSPS Performance Test Date
Equipment Type: Batch Tower (Leave dates blank for actions that have not occurred )
Make/Model Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity
NSPS Performance Test Date

Page 3 of 3
Equipment Registration Form for
Generic Portable Equipment

Form 15b (continued)

Equipment Type: Deister Screen (Leave dates blank for actions that have not occurred )
Make/Model BF-2414-D Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity
NSPS Performance Test Date
Equipment Type: Control House (Leave dates blank for actions that have not occurred )
Make/Model Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity
NSPS Performance Test Date
Equipment Type: Scale (Leave dates blank for actions that have not occurred )
Make/Model AMD-1080-4-135-PVT Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity
NSPS Performance Test Date
Equipment Type: Fall off (Hand rails, legs, etc) (Leave dates blank for actions that have not occurred )
Make/Model Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart I
Design Capacity
NSPS Performance Test Date
Equipment Type: Diesel-Fired Generator (Leave dates blank for actions that have not occurred )
Make/Model C350D5B Initial Startup Date
Serial or ID # Initial Inspection Date
Manufactured Date Applicable Federal Standard NSPS Subpart IIII, MACT
ZZZZ
Design Capacity 18.5 gph
NSPS Performance Test Date

Owner or operator representative: Keith Gilbert

Signature

Date
NOTE: Call the DAQ at [phone] if you have problems or questions when completing this form. Ask for a New
Source Review engineer. We will be glad to help!

f:\aq\engineer\generic\Forms 2010\Form 15b Equipment Registration Form for Generic Portable Equipment.doc
Revised 12/20/10

ATTACHMENT C: Form 15c – Portable General Permit
Application

1
Utah Division of Air Quality Date 02/26/2024
New Source Review Section Company Southwest Grading &
Paving
Site/Source Cedar City, UT
Form 15c
Portable General Permit Application
An Approval Order to construct must be approved before any equipment can be operated. Please refer
to the Approval Order application instructions for specific details required to complete the application. Please print or type all
information requested. All information requested herein must be completed and submitted before an engineering review can
be completed. Please contact the New Source Review Section of the Division of Air Quality with any questions at (801) 536-
4000. Written inquiries may be addressed to: Division of Air Quality, New Source Review Section, P.O. Box 144820, Salt
Lake City, Utah 84114-4820.

General Owner And Facility Information
1. Company name and address:
Southwest Grading and Paving, LLC
871 E. Fiddler Canyon Road
Cedar City, UT 87421
2. Company contact for environmental issues:
Keith Gilbert

Phone No.: [phone]
FAX No.: ( )
E-mail address: [e-mail]

Phone No.: [phone]
FAX No.: ( )
3. Owners name and address:
Keith Gilbert
Same address as listed above.

Phone no.: [phone]
FAX no.: ( )
E-mail address: [e-mail]
4. Identify any current Approval Order(s):

AO# Date
AO# Date
AO# Date
AO# Date
AO# Date
AO# Date
5. If request for modification, previous permit # and date: DAQE-AN DATE: / /
6. Type of operation:  Aggregate Processing Plants  Asphalt Plants Concrete Batch Plants
7. Total company employees greater
than 100?
 Yes  No
8. Standard Industrial Classification Code
[2951]
9. Application for:
 New equipment 
 Existing equipment operating without permit

Modification
2
10. For new equipment or modification, enter estimated start date: 4/1/2024
11. For change of permittee, enter date
of occurrence:
12. For existing equipment in operation without prior permit, enter initial operation
date:
13. Has equipment been modified, moved or the capacity increased since November 29, 1969:  Yes No
If yes: Specify what equipment:
3
14.Equipment list (Table 1 and 2 Attach as Appendix A)
15.I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry and to the best of my knowledge and belief.
Signature:Title:
16.
Keith Gilbert
Name (Typed or printed)
17. Telephone Number:
[phone]
18. Date:
02/25/2024
General Permit Application
Form 15c
Instructions
1.Identify the name, address, phone number, and fax number of the legal entity that operates the equipment.
2.Identify the person who is to be contacted regarding this application; also include the phone number and fax number of this
person.
3.If you are not the owner of the equipment under this application, enter the name, address, phone number, and fax number of
the owner.
4.List any valid Approval Orders (AO) which are for equipment at this site.
5.Indicate previous AO number (if any) and date for AO modification.
6.State the type of operation.
7.Indicate if the total number of people employed by your company is over 100 people.
8.Using the provided list of business codes (page 8), enter the code which best describes your business activity at this facility.
9.Check all applicable boxes
Existing Equipment Operating Without permit - equipment which has been in operation without a prior permit issued by the
state.
Modification - existing equipment which is physically altered by the removal, addition, or non-identical replacement of parts.
10.Enter the start date new equipment or modification.
11.For cases in this category, enter the future date when the change is anticipated.
12.For this category of equipment, enter the date when this equipment was first operated.
13.This is for equipment that was operated before November 29, 1969. Indicate whether equipment has been moved, modified or
increased capacity since that date. Specify what equipment this includes.
14.Attach as Table 1 and 2 to the application a list of all portable equipment (NSPS/MACT - Table 1 and Non-NSPS - Table 2)
that is owned or operated by the company. Forms are available from DAQ for these two tables.
15.Signature of authorized company agent.
16.Name of signing party.
17.Telephone number of signing party.
18.Date of application.
Additional information may be required for some projects. If so, the reviewing engineer will contact the individual listed in question
number 2.
f:\aq\engineer\generic\Forms 2010\Form15c Portable Generic Permit Application.doc
Revised 12/20/10
2/28/24, 11:26 AM State of Utah Mail - Pre-NOI Meeting for SouthWest Grading and Paving
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r2404612233983376371&simpl=msg-a:r906489367155116…1/5
Dungan Adams <[e-mail]>
Pre-NOI Meeting for SouthWest Grading and Paving
15 messages
Dungan Adams <[e-mail]>Wed, Feb 14, 2024 at 10:38 AM
To: [e-mail]
Hi Keith,
The Utah Department of Air Quality (DAQ) has received your request for a Pre-NOI meeting. I have availability this
Thursday and Friday, as well as most days next week. Let me know what works best for you.
I would prefer to have the Pre-NOI meeting over Google Meet, but I can meet at our office located at 195 N 1950 W, Salt
Lake City, UT 84116.
If you have any specific questions, please send them to me ahead of our meeting so I can make sure to provide you with
the information you need. Otherwise, I will just go over the NOI process and what is required for a complete application.
Thanks,
Dungan
--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
keith gilbert <[e-mail]>Wed, Feb 14, 2024 at 10:47 AM
To: Dungan Adams <[e-mail]>
Can I call in on this meeting?
Keith Gilbert
On Feb 14, 2024, at 9:39 AM, Dungan Adams <[e-mail]> wrote:
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, Feb 14, 2024 at 10:49 AM
To: keith gilbert <[e-mail]>
Keith,
2/28/24, 11:26 AM State of Utah Mail - Pre-NOI Meeting for SouthWest Grading and Paving
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r2404612233983376371&simpl=msg-a:r906489367155116…2/5
Yes, you can join by phone. We can also just have a phone call if that is easier for you.
Thanks,
Dungan
[Quoted text hidden]
keith gilbert <[e-mail]>Wed, Feb 14, 2024 at 10:57 AM
To: Dungan Adams <[e-mail]>
Ok let me check with Bison and engineering and get a schedule back here in just a bit
Thanks
Keith Gilbert
On Feb 14, 2024, at 9:49 AM, Dungan Adams <[e-mail]> wrote:
[Quoted text hidden]
keith gilbert <[e-mail]>Wed, Feb 14, 2024 at 10:58 AM
To: Dungan Adams <[e-mail]>
Ok what time tomorrow works Kellen said he can make it work
Thanks
Keith Gilbert
On Feb 14, 2024, at 9:57 AM, keith gilbert <[e-mail]> wrote:
Ok let me check with Bison and engineering and get a schedule back here in just a bit
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, Feb 14, 2024 at 11:12 AM
To: keith gilbert <[e-mail]>
I am available any time from 10am - 2pm tomorrow. Does noon work for you?
Thanks,
Dungan
[Quoted text hidden]
keith gilbert <[e-mail]>Wed, Feb 14, 2024 at 11:23 AM
To: Dungan Adams <[e-mail]>
10 would be better for me will that work for you?
Keith Gilbert
On Feb 14, 2024, at 10:12 AM, Dungan Adams <[e-mail]> wrote:
[Quoted text hidden]
2/28/24, 11:26 AM State of Utah Mail - Pre-NOI Meeting for SouthWest Grading and Paving
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r2404612233983376371&simpl=msg-a:r906489367155116…3/5
Dungan Adams <[e-mail]>Wed, Feb 14, 2024 at 11:24 AM
To: keith gilbert <[e-mail]>
Yes, that works. I will send the meeting link shortly.
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Fri, Feb 16, 2024 at 10:50 AM
To: Kellen Sullivan <[e-mail]>, Diane Lorenzen <[e-mail]>
Cc: keith gilbert <[e-mail]>
Hi Kellen and Diane,
Attached are the two forms (15b and 15c) that need to be filled out for the portable permit application. Once you have
received the Approval Order (AO), a temporary relocation form will need to be submitted. It might be a good idea to
submit this at the end of the public comment period so the relocation can be accepted right away once the AO has been
approved. Here is a link to the fees breakdown for generic permits and temporary relocations.
Here is a link to modeling guidance. The Emission Impact Assessment Guideline lists the modeling thresholds (as does
State Rule R307-410). The Modeling Protocol can be submitted to Dave Prey ([e-mail]). Form 01b is BACT
guidance.
Please let me know if you have any questions or if there is any other information that would be helpful.
Thanks,
Dungan
[Quoted text hidden]
3 attachments
Form15b.pdf
43K
Form15c.pdf
42K
Form01b.pdf
51K
Kellen Sullivan <[e-mail]>Mon, Feb 26, 2024 at 12:00 PM
To: Dungan Adams <[e-mail]>
Cc: keith gilbert <[e-mail]>, Diane Lorenzen <[e-mail]>, Cade Barthuly <cbarthuly@bison-
eng.com>
Hi Dungan,

I’ve attached the Southwest Grading and Pav ing portable permit application as we discus sed on February 16, 2024.

Please l et us know if you have any ques ti ons regarding the permit application. I hope you had a good weekend!

Thank you,

Kellen Sullivan
2/28/24, 11:26 AM State of Utah Mail - Pre-NOI Meeting for SouthWest Grading and Paving
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r2404612233983376371&simpl=msg-a:r906489367155116…4/5
Consulting Director
Ambient Monitoring | Air Permitting | Compliance |
Emiss ions Testing | Gas Flow Monitors
O fice: 406.442.5768
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Southwest Grading and Paving Portable Permit Application 02262024.pdf
1005K
Kellen Sullivan <[e-mail]>Mon, Feb 26, 2024 at 1:37 PM
To: Dungan Adams <[e-mail]>
Cc: keith gilbert <[e-mail]>, Diane Lorenzen <[e-mail]>, Cade Barthuly <cbarthuly@bison-
eng.com>
Hi Dungan,

I real ized that Keith didn’t sign the Form 15c signature page s o I’ve updated the portable permit appli cation in this email
attachment.

Thanks,

Kellen
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Southwest Grading and Paving Portable Permit Application 02262024.pdf
1803K
Dungan Adams <[e-mail]>Mon, Feb 26, 2024 at 1:42 PM
To: Kellen Sullivan <[e-mail]>
Cc: keith gilbert <[e-mail]>, Diane Lorenzen <[e-mail]>, Cade Barthuly <cbarthuly@bison-
eng.com>
Hi Kellen,
Thanks for sending this over. I'll let you know if I have any questions as soon as I review the application.
Thanks,
Dungan
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2/28/24, 11:26 AM State of Utah Mail - Pre-NOI Meeting for SouthWest Grading and Paving
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r2404612233983376371&simpl=msg-a:r906489367155116…5/5
Dungan Adams <[e-mail]>Mon, Feb 26, 2024 at 4:01 PM
To: Alan Humpherys <[e-mail]>
Hi Alan,
After a Pre-NOI meeting a few weeks ago, this source sent over an application for a portable AO. Is there someone I need
to send the application to so the TEMPO site and ID can get set up?
Thanks,
Dungan
---------- Forwarded message ---------
From: Kellen Sullivan <[e-mail]>
Date: Mon, Feb 26, 2024 at 12:00 PM
Subject: RE: Pre-NOI Meeting for SouthWest Grading and Paving
To: Dungan Adams <[e-mail]>
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Southwest Grading and Paving Portable Permit Application 02262024.pdf
1005K
Alan Humpherys <[e-mail]>Tue, Feb 27, 2024 at 4:04 PM
To: Dungan Adams <[e-mail]>
Dungan,
Here is the information for this project. If you have any questions, please let me know.
Site ID: 16200
Peer: Dylan
Thanks,
Alan
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--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Dungan Adams <[e-mail]>Tue, Feb 27, 2024 at 4:05 PM
To: Alan Humpherys <[e-mail]>
Great, thanks!
Dungan
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