DAQ-2024-010971

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DAQC-CI103020001-24
Site ID 10302 (B1)

MEMORANDUM

TO: FILE – CANYON FUEL COMPANY LLC – Levan Loadout (Sufco Mine)

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: September 19, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Juab County

INSPECTION DATE: July 29, 2024

SOURCE LOCATION: Approximately 3 miles west of Levan on Highway 78 and 1.5
miles north on North Elevator Road
Levan, UT 84639
DIRECTIONS: 3 miles west of Levan, Juab County. Take Highway 78 west
from Levan and turn right onto the road paralleling the railroad
as Highway 78 bends towards the south. Continue north to load
out. Entrance is at the south end of source.

SOURCE CONTACTS: Bryant Bunnell, Senior Environmental Engineer
435-286-4490 [e-mail]

OPERATING STATUS: Not operating at the time of inspection. No production has
occurred in the past 12 months.

PROCESS DESCRIPTION: Coal load out source. Coal is trucked to the load out from mines
operated by Sufco and belly dumped onto an underground
feeder. The coal is conveyed to a belt stacker and stacked onto
storage piles. Mobile equipment is used to move the material
around the piles for better storage and compaction. The coal is
then pushed off the storage piles onto another under-pile feeder
and conveyed to a storage silo, which drops the coal into rail
cars. Approximately 500-600 train cars are loaded each week
and sent to various locations (each train consists of ~104 cars).
Fugitive dust is controlled at the source by water truck and water
sprays.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN103020005-22, dated
November 8, 2022

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Canyon Fuel Company LLC- Levan Loadout
(Sufco Mine)
A Subsidiary of Wolverine Fuels, LLC
597 South SR 24

Remote approximately 3 miles west of Levan on
Hwy 78 and 1.5 miles North on North Elevator
Road
Salina, UT 84654 Levan, UT 84639

SIC Code: 1222: (Bituminous Coal Underground Mining)

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. No limits set forth in this AO appear to have been exceeded. The source stated that there have been no modifications to the equipment or processes. The equipment appeared to be properly operated and maintained according to manufacturer recommendations. Records are kept as required and were made available after the inspection. No breakdowns have been reported since the previous inspection. This source is not required to submit an emissions report at this time.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Levan Loadout Facility
II.A.2 Various Conveyors and Transfer Points
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II.A.3 Trucks and Various Loading and Transport Equipment Fuel: Diesel *For informational purposes only
II.A.4 Coal Stockpile Areas
Status: In Compliance. No unapproved equipment was observed at the time of inspection.

II.B Requirements and Limitations
II.B.1 Operation Requirements II.B.1.a The owner/operator shall not produce more than 6,000,000 tons of coal per rolling 12-month period. [R307-401-8] II.B.1.a.1 The owner/operator shall: A. Determine production by examining operator records B. Record production on a daily basis C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation. [R307-401-8] Status: In Compliance. For the rolling 12-month period from July 2023 - June 2024, a total of 0 tons of coal were produced. II.B.2 Opacity Requirements II.B.2.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All conveyer transfer points - 10% opacity B. All conveyer drop points - 20% opacity C. All diesel engines - 20% opacity D. All other points - 20% opacity. [R307-401-8] II.B.2.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Opacity observations of visible emissions from intermittent sources shall use procedures similar to Method 9, but the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. Any time-interval with no visible emissions shall not be included. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point at the time of inspection. Method 9 was utilized to verify opacity limits. See attached VEO form.

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II.B.3 Fugitive Dust Source Requirements II.B.3.a The owner/operator shall not allow visible emissions from haul-road traffic and mobile equipment in operational areas to exceed 20% opacity on site. [R307-205-4, R307-401-8] Status: In Compliance. No visible fugitive emissions were observed at the time of inspection. See the attached VEO form. II.B.3.b Visible emissions determinations for traffic sources shall use procedures similar to Method 9; however, the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. Six (6) points, distributed along the length of the haul road or in the operational area, shall be chosen by the Director or the Director's representative. An opacity reading shall be made at each point when a vehicle passes the selected points. Opacity readings shall be made not less than one half vehicle length behind the vehicle and not less than one half the height of the vehicle. The accumulated six (6) readings shall be averaged for the compliance value. [R307-401-8] Status: In Compliance. No visible fugitive emissions were observed at the time of inspection. See the attached VEO form. II.B.3.c The owner/operator shall use water application and/or chemical suppressants for all unpaved haul roads and wheeled-vehicle operational areas to maintain opacity limits listed in this AO. If the temperature is below freezing, the owner/operator may stop applying water and/or chemical suppressant to the unpaved haul roads and wheeled-vehicle operational areas. The owner/operator shall resume applying water and/or chemical suppressants to the unpaved haul roads and wheeled-vehicle operational areas when the temperature is above freezing. If chemical treatment is to be used, the plan must be approved by the Director. [R307-401-8] II.B.3.c.1 Records of chemical suppressant and water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made, quantity of water applied, and chemical dilution ratio used C. Rainfall amount received, if any, and the approximate amount. [R307-401-8] Status: In Compliance. No visible fugitive emissions were observed at the time of inspection. The source maintains watering records. See the attached example from April and May 2024. II.B.3.d The owner/operator shall not exceed the following haul road limits: A. 2.4 miles in length for specialty coal (unpaved) B. 1.8 miles in length for North Stockpile (unpaved) C. 0.1 miles in length for Truck Dump (linear stacker) (unpaved). [R307-401-8] Status: In Compliance. None of the haul roads exceed this limit. See the attached diagram for more information. A) This road is ~1.2 miles in length B) This road is ~ 1 mile in length C) This road is < 0.1 miles in length

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II.B.3.e The owner/operator shall not exceed a haul road speed limit of 10 miles per hour. The haul road speed shall be posted, at a minimum, on site at the beginning of the haul road so that it is clearly visible from the haul road. [R307-401-8] Status: In Compliance. The speed limit is posted as required. II.B.3.f The owner/operator shall perform front end loading of coal only at the north storage pile and the specialty coal pile. [R307-401-8] Status: Not Observed. Trucks are not loaded at these piles. Coal is only loaded at the train tracks near the station. The source stated that if truck loading operations were conducted at this site, they would follow this location requirement. See the attached email correspondence. II.B.3.g The owner/operator shall install water sprays or chemical dust suppression sprays at all of the following points on site to control fugitive emissions: A. All conveyor drop points B. All truck drop points C. All storage piles. [R307-401-8] II.B.3.g.1 The owner/operator shall operate the water sprays as necessary to maintain the opacity limits listed in this AO, whenever warranted by dry conditions. [R307-401-8] Status: In Compliance. No loading has been done in the previous 12 months. Water sprays are installed to maintain opacity limits as required. II.B.3.h The owner/operate shall meet the following operating parameters at all times: A. Moisture content in coal shall be no less than 10% in transporting and dozer operations. B. Moisture content of coal shall be no less than 8% by weight during front end loading of railroad cars, and at all material drop points. C. The silt content of the coal in the storage piles shall be no greater than 5.1 % by weight. The silt content is defined as all material passing a #200 U.S. Standard Sieve. [R307-401-8] II.B.3.h.1 The moisture content shall be tested if required by the Director using the appropriate ASTM method. [R307-401-8] Status: Not Observed. There have not been any storage piles at this site for several years. As such, none of these tests have been performed. The source was asked to perform these tests twice a year if coal storage and loading resumes at this site. The source may also seek to modify this requirement in a future Notice of Intent. See the attached email correspondence with the source and Division of Air Quality Minor New Source Review. II.B.3.i The owner/operator shall comply with all applicable fugitive emissions and fugitive dust requirements of UAC R307-205, Emission Standards: Fugitive Emissions and Fugitive Dust. [R307-205, R307-401-8] Status: In Compliance. No visible fugitive emissions were observed at the time of inspection. The source maintains watering records. See the attached example from April and May 2024.

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II.B.4 Fuel Requirements II.B.4.a The owner/operator shall only use #2 fuel oil as fuel. [R307-401-8] Status: In Compliance. Only #2 ULSD fuel is used at this source. II.B.4.b The owner/operator shall only combust fuel oil or diesel that has a maximum sulfur content of 0.5 percent by weight. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.b.1 The sulfur content shall be determined by ASTM Method D-2880-71 or Method D-4294-89 or approved equivalent. Certification of fuel oil shall be either by the owner/operator's own testing or test reports from the used oil fuel marketer. [R307-401-8] Status: In Compliance. Only #2 ULSD fuel is used at this source. See the attached invoice from Pierce Oil Company, Inc. II.B.4.c The owner/operator shall keep records of fuel supplier's test reports available on-site for each load delivered. [R307-401-8] Status: In Compliance. See the attached invoice for the last fuel delivery in August 2023.
Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

Status: In Compliance. No visible fugitive emissions were observed at the time of inspection. The
source maintains watering records. See the attached example from April and May 2024.

EMISSION INVENTORY:

The emissions listed below are an estimate of the total potential emissions (PTE) from Canyon Fuel
Company LLC - Levan Loadout (Sufco Mine) on the Approval Order (AO) DAQE-AN103020005-22,
dated November 8, 2022. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
Carbon Monoxide 9.02
Nitrogen Oxides 22.09
Particulate Matter - PM10 25.62
Particulate Matter - PM2.5 25.62
Sulfur Dioxide 2.29
Volatile Organic Compounds 1.70

Hazardous Air Pollutant PTE lbs/yr

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PREVIOUS ENFORCEMENT
ACTIONS: No enforcement action in the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN103020005-22,
dated November 8, 2022, the overall status is: In Compliance.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at low frequency.

NSR RECOMMENDATIONS: Consider setting frequency parameters for Condition II.B.3.h.

ATTACHMENTS: Email correspondence, source records, Minor NSR email
correspondence

Sufco Mine
597 South SR24
Salina, Utah 84654
(435)-286-4880
August 6, 2024
Bryce C. Bird
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84114-4820
ATTN: Daniel Riddle, Minor Source Compliance
Re: Canyon Fuel Company, Levan Coal Yard, AN103020005-22, Inspection Records Request
Dear Mr. Bird,
This letter is regarding an inspection completed by Daniel Riddle on July 30th, 2024. The requested
records are attached.
Please feel free to contact Bryant Bunnell at [phone] if you have any questions.
Regards,
Bryant Bunnell
Senior Environmental Engineer
Wolverine Fuels, LLC
SUFCO Mine
P: (435) 286 – 4490
E: [e-mail]
Cc: UDAQ Correspondence File
Levan Coal Yard - AO: AN103020005-22
Records Requested (D. Riddle, 7/30/2024)
II.B.1.a
12-Month Rolling Period July 2023-June 2024 (Tons)
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Watering Application Records
See Attached Photos
II.B.3.d The owner/operator shall not exceed the following haul road limits:
A. 2.4 miles in length for specialty coal (unpaved)
B. 1.8 miles in length for North Stockpile (unpaved)
C. 0.1 miles in length for Truck Dump (linear stacker) (unpaved)
[R307-401-8]
Haul Road Limits
See the Attached Diagram
The owner/operator shall not produce more than 6,000,000 tons of coal per rolling
12-month period. [R307-401-8]
The owner/operator shall use water application and/or chemical suppressants for all
unpaved haul roads and wheeled-vehicle operational areas to maintain opacity limits
listed in this AO. If the temperature is below freezing, the owner/operator may stop
applying water and/or chemical suppressant to the unpaved haul roads and wheeled-
vehicle operational areas. The owner/operator shall resume applying water and/or
chemical suppressants to the unpaved haul roads and wheeled-vehicle operational
areas when the temperature is above freezing. If chemical treatment is to be used,
the plan must be approved by the Director. [R307-401-8]
II.B.3.c
Time Period (2024)Number of Loads (5000
gal.)Water Applied (gal.)
April 9 45,000
May 25 125,000
June 35 175,000
July
August (1st-5th) 9 45,000
Haul Road Area Distance Used (mi.)
North Stockpile Area ~1
South Stock Pile Area ~1.2
Truck Dump Area <0.1
,000
Levan Coal Yard - AO: AN103020005-22
Records Requested (D. Riddle, 7/30/2024)
II.B.3.h The owner/operator shall meet the following operating parameters at all times:
A. Moisture content in coal shall be no less than 10% in transporting and
dozer operations
B. Moisture content of coal shall be no less than 8% by weight during front
end loading of railroad cars, and at all material drop points
C. The silt content of the coal in the storage piles shall be no greater than 5.1 % by
weight. The silt content is defined as all material passing a #200 U.S. Standard
Sieve.
[R307-401-8]
Moisture and Silt Content Requirements
NA
II.B.4.b
[40 CFR 63 Subpart ZZZZ, R307-401-8]
Fuel Sulfer Limitation
See Attached Fuel Invoice (Low Sulfer Indicated)
The owner/operator shall only combust fuel oil or diesel that has a maximum sulfur
content of 0.5 percent by weight.
Water Application Records –Log Book Photos (2024)
April/May

June

July

August

Haul Road Limits Diagram