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HomeMy WebLinkAboutDAQ-2024-0109741 DAQC-CI160350001-24 Site ID 16035 (B1) MEMORANDUM TO: FILE – KENNECOTT UTAH COPPER, LLC – Bonneville Borrow Area THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Connor Kijowski, Environmental Scientist DATE: September 25, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: June 25, 2024 SOURCE LOCATION: 2500 South 9180 West Magna, UT 84044 SOURCE CONTACTS: Sean Daly, Senior Environmental Advisor 801-913-4456; sean.daly3@riotinto.com OPERATING STATUS: Not operating. Two front-end loaders were present. No stationary equipment has been installed. PROCESS DESCRIPTION: The Bonneville Borrow Area is a small aggregate plant used to supply material for reclamation or construction projects at Kennecott. Currently, there are only two loaders removing material from the hillside and loading into trucks. The Approval Order has been written to allow for rented equipment such as crushers and screens to be brought onto site, and if necessary for longer projects, a diesel-powered Jaw Crusher and emergency engine. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN160350001-21, dated March 18, 2021 NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, NSPS (Part 60) OOO: Standards of Performance for Nonmetallic Mineral Processing Plants, MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Kennecott Utah Copper, LLC - Bonneville Borrow Area 4700 Daybreak Parkway 2500 South 9180 West South Jordan, UT 84095 Magna, UT 84044 SIC Code: 1442: (Construction Sand & Gravel) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] Status: In Compliance. Each condition from Section I was reviewed with the source and appeared to be in compliance. The 2023 Emission Inventory was submitted by the required date. The source submitted a construction status update on July 1, 2024, requesting an 18-month extension as the permitted equipment has not been installed. Refer to the attachments for more details. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Bonneville Borrow Plant II.A.2 Primary Crushers Maximum combined capacity: 1,500 tph NSPS Applicability: Subpart OOO II.A.3 Secondary Screens Maximum Combined Capacity: 1000 tph NSPS Applicability: Subpart OOO II.A.4 Emergency Generator Engine Quantity: 1 Rating: 130 kW (175 hp) Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.5 Jaw Crusher Engine Quantity: 1 Rating: 450 hp Fuel: Diesel II.A.6 Space Heater Quantity: 1 Rating: 5 MMBtu/hr Fuel: Natural gas II.A.7 Various Conveyors NSPS Applicability: Subpart OOO II.A.8 Mobile Equipment Front-end loaders and haul trucks, listed for information purposes Status: Not Observed. No stationary equipment has been installed. II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall be limited to the following production limits: A. 550,000 tons of aggregate per rolling 12-month period B. 1,350 hours of operation per rolling 12-month period for the diesel engine used to power the portable jaw crusher. [R307-401-8] II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records of production and hours of operation shall be kept for all periods when the plant is in operation. Production shall be determined by scale records. Hours of operation shall be determined by a non-resettable hour meter or operations log. The records of production and hours of operation shall be kept on a daily basis. [R307-401-8] Status: Not Applicable. The crushers, screens, and engine have not been installed. 4 II.B.1.b Unless otherwise specified in this AO, visible emissions from the following emission points shall not exceed the following opacity values: A. Crushers - 12% B. Screens - 7% C. All Conveyor Transfer Points - 7% D. Diesel Engines - 20% E. Natural gas-fired heater - 10% F. All Other Points - 20%. [40 CFR 60 Subpart OOO, R307-309, R307-401-8] II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of emission from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3] Status: In Compliance. No opacity was observed during the inspection. II.B.1.c The owner/operator shall maintain the following records for all equipment brought on site: A. Make and model B. Rating or capacity C. Date of start of operation D. Date of end of operation E. Date of initial performance test for all crushers, screens, and conveyor transfer points subject to 40 CFR 60 Subpart OOO. [R307-401-8] Status: Not Applicable. No equipment other than front end loaders have been brought onto site. Only surface mining of loose material has occurred at this location. II.B.1.d The owner/operator shall install water sprays at the following points to control fugitive emissions: A. All crushers B. All screens C. All conveyor transfer points. [40 CFR 60 Subpart OOO, R307-401-8] Status: Not Applicable. No crushers, screens, or conveyors have been installed yet. Only surface mining of loose material has occurred at this location. II.B.1.d.1 The sprays shall operate to maintain the opacity limits in this AO. [40 CFR 60 Subpart OOO, R307-401-8] Status: Not Applicable. No equipment other than front end loaders have been brought onto site. Only surface mining of loose material has occurred at this location. II.B.1.e The owner/operator shall perform monthly periodic inspections to check that water is flowing to discharge spray nozzles associated with each crusher, screen, and conveyor. If the owner/operator finds that water is not flowing properly during an inspection of the water spray nozzles, the owner/operator shall initiate corrective action within 24 hours and complete corrective action as expediently as practical. [40 CFR 60 Subpart OOO, R307-401-8] II.B.1.e.1 Records of the water sprays inspections shall be kept and maintained in a logbook for all periods when the plant is in operation. The records shall include the following items: A. Date the inspections were made B. Any corrective actions taken C. Control mechanism used if sprays are not operating. [40 CFR 60 Subpart OOO, R307-401-8] Status: Not Applicable. No equipment other than front end loaders have been brought onto site. Only surface mining of loose material has occurred at this location. 5 II.B.1.f Within 180 days of this AO or prior to bringing equipment on site, the owner/operator shall submit a FDCP in electronic or written format. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit Application Website. If a written FDCP is submitted, it shall be completed in accordance with R307-309-6 and submitted to the Director, attention: Compliance Branch, for review and acceptance. The owner/operator shall comply with the FDCP for control of all fugitive dust sources associated with this source. [R307-309-6] Status: In Compliance. A FDCP for the Kennecott Borrow Area was submitted online January 31, 2022. II.B.2 Haul Roads and Fugitive Dust Sources Requirements II.B.2.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% at the property boundary. [R307-309-5, R307-401-8] II.B.2.a.1 Visible determinations for fugitive dust emissions from haul-road traffic and mobile equipment shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5] Status: In Compliance. No opacity was observed from the haul roads or any other fugitive dust source during the inspection. The ground was visibly wet during the inspection. The source has two water trucks available to spray the hillside where they are removing material and to water the haul roads. II.B.2.b The haul roads shall not exceed the following lengths: A. Unpaved haul roads - 3.0 miles B. Paved haul roads - 2.0 miles. [R307-401-8] II.B.2.b.1 Compliance shall be determined through GPS measurements or aerial photographs. [R307-401-8] Status: In Compliance. Records received after the inspection show that the unpaved haul road length is 0.6 miles in length, and the paved road length is 0.4 miles in length. Refer to the current map in the attachments. II.B.2.c To prevent visible emissions from exceeding the opacity limits listed in this AO, the owner/operator shall sweep paved roads and apply water or chemical suppressants to all fugitive dust sources on site (including haul roads). The owner/operator may stop applying water to fugitive dust sources when the temperature is below freezing but shall apply other controls as necessary to prevent visible emissions from exceeding the opacity limits listed in the AO. [R307-401-8] II.B.2.c.1 Records of water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time water application was made B. Number of water applications made and quantity of water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature was below freezing. [R307-309, R307-401-8] Status: In Compliance. The source uses an app called Raken to log water applications. An example of the watering logs for April and May 2024, are included in the attachments. II.B.2.d The owner/operator shall not exceed 10 acres of all disturbed areas combined and the area occupied by storage piles shall not exceed 1.5 acres. [R307-401-8] 6 II.B.2.d.1 To determine compliance with the total disturbed areas and storage pile areas, the owner/operator shall measure the total disturbed area at least once every six (6) months and shall maintain a record of the total disturbed acres. To determine the disturbed acres on site, the owner/operator shall use GPS measurements or an aerial drone survey of each disturbed area on site to calculate each disturbed areas and storage pile areas. Records of the total disturbed areas and storage pile areas shall contain the following: A. Date of measurements B. Size of each disturbed area and storage area on site C. Total acres of all disturbed areas and storage areas combined. [R307-401-8] Status: In Compliance. Records received after the inspection show that the total disturbed area is 8.561 acres, and the storage piles are 0.35 acres. Refer to the current map in the attachments. Disturbed acreage was last measured August 8, 2024. II.B.3 Crusher, Screens, and Conveyors Subject to NSPS Subpart OOO Requirement II.B.3.a The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving the maximum production rate but not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO. Records of initial performance tests shall be kept and maintained on site for the life of the equipment. [40 CFR 60 Subpart OOO] II.B.3.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR 60.675(c). The owner/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.3.a.2 The owner/operator shall submit written reports to the Director of the results of all performance tests conducted to demonstrate compliance with the standards set forth in 40 CFR 60.672. [40 CFR 60 Subpart OOO] Status: Not Applicable. The source has not brought any Subpart OOO equipment to this site yet. II.B.4 Engine Requirement II.B.4.a The emergency engine and the jaw crusher engine shall be certified to meet the following emission rates: A. NOx - 0.40 g/kW-hr or less B. CO - 3.5 g/kW-hr or less C. PM - 0.02 g/kW-hr or less D. NMHC - 0.19 g/kW-hr or less. [R307-401-8]. II.B.4.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] Status: Not Applicable. No stationary engines have been brought onto the site as there has been no need for crushing equipment yet. II.B.4.b The owner/operator shall comply with the applicable requirements in 40 CFR 63 Subpart ZZZZ and 40 CFR 60 Subpart IIII for the jaw crusher engine if the jaw rusher engine is considered a stationary engine. 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: 7 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. Compliance with the length of operation of the jaw crusher engine shall be determined by the recordkeeping requirements in II.B.1.c. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] Status: Not Applicable. No stationary engines have been brought onto the site as there has been no need of crushing equipment yet. II.B.4.c The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] Status: Not Applicable. No emergency engine has been brought onto the site as there has been no need for crushing equipment yet. II.B.4.c.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 60 Subpart III, 40 CFR 63 Subpart ZZZZ, R307-401-8] Status: Not Applicable. No emergency engine has been brought onto the site as there has been no need for crushing equipment. II.B.4.d The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine and the jaw crusher engine. [R307-401-8] II.B.4.d.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.4.d.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In Compliance. The source uses only ULSD fuel for the mobile equipment on site. 8 Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: Not Applicable. The generator in II.A.4 and the Jaw Crusher Engine in II.A.5 have not been installed. NSPS (Part 60) OOO: Standards of Performance for Nonmetallic Mineral Processing Plants Status: Not Applicable. No crushers, screens, or conveyors have been installed. MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: Not Applicable. The generator in II.A.4 and the Jaw Crusher Engine in II.A.5 have not been installed. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. No visible emissions were observed from any point during the inspection. The haul road was watered prior to the inspection. The source has multiple water trucks available to spray multiple times a day according to records reviewed during the inspection. A Fugitive Dust Control Plan was submitted January 31, 2022. Aggregate Processing Operations for PM2.5 Nonattainment Areas [R307-312] Status: Not Applicable. No crushers, screens, or conveyors have been installed. 9 EMISSION INVENTORY: Listed before are the 2021 Actual Emissions Inventory provided from Kennecott Utah Copper, LLC - Bonneville Borrow Area. A comparison of the estimated total potential emissions (PTE) on Approval Order (AO) DAQE-AN160350001-21, dated March 18, 2021, is provided below. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 1561.96 N/A Carbon Monoxide 2.68 0.00 Nitrogen Oxides 1.26 0.00 Particulate Matter - PM10 18.93 1.613 Particulate Matter - PM10 (Fugitives) 18.84 N/A Particulate Matter - PM2.5 2.44 0.17 Particulate Matter - PM2.5 (Fugitives) 2.35 N/A Sulfur Dioxide 0.03 0.00 Volatile Organic Compounds 0.15 0.00 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Generic HAPs (CAS #GHAPS) 70 N/A PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN160350001-21, dated March 18, 2021: In Compliance. The facility appears to be well maintained and operated. Required records were current and made available during the inspection as well as afterwards via email. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect at the regular frequency for this type of source. Contact the source prior to inspection. Hard hat, safety glasses, safety vest, and steel toed shoes are required to tour the source. NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: Section I.8 Notification Letter, Watering Records, Unpaved Road Map, Paved Road Map, Disturbed Acreage Map Rio Tinto Kennecott, 4700 Daybreak Parkway, South Jordan, Utah, 84009 July 1, 2024 Mr. Bryce Bird, Director Department of Environmental Quality Division of Air Quality 195 N 1950 W Salt Lake City, UT 84116 Attention: NSR Section Subject: Status of Construction and Request for Extension for Jaw Crusher and Engine DAQE-AN160350001-21 Kennecott Utah Copper – Bonneville Borrow Area Plant Dear Mr. Bird, Kennecott Utah Copper LLC’s (Kennecott) operates the Bonneville Borrow Area Plant in accordance with Approval Order DAQE-AN160350001-21 issued by the Division on March 18, 2021. The facility is operational. Temporary mobile equipment have been brought in and out to facilitate operations at the site and these activities have been reviewed with the Division’s Minor Source compliance group. However, given the nature of the work being performed, no equipment has been onsite for more than 6 to 9 months and therefore Kennecott has not yet submitted a notification to the Director indicating operation of stationary equipment. As outlined in Condition I.8, documentation of the status of construction and operation shall be submitted to the Director within 18 months from the date the AO was issued. Kennecott submitted an original extension request in August 2022 and sent an email in March 2024. Kennecott is requesting to continue to be able to bring temporary material handling equipment to meet Kennecott’s current mining needs. Kennecott is requesting an additional 18 months to initiate construction and operation of the Jaw Crusher and Engine at the plant. Kennecott will notify the director in accordance with the requirements in Condition I.8 as deemed necessary. If you have any questions on the interpretation of the relevant conditions of the Approval Order, please reach out to me at (801) 569-6494 or jenny.esker@riotinto.com within 14 days of the receipt of this letter. Yours sincerely, Jenny Esker Evans Principal Advisor, Air Quality Rio Tinto Kennecott 4700 Daybreak Parkway South Jordan, Utah 84009 Tel: 801-204-2000 Ames Construction Date Equipment number Type Amount of loads Total gallons 4/22/2024 5606018 4k Gal Water Truck 13 52,000 4/23/2024 5606018 4k Gal Water Truck 15 60,000 4/24/2024 5606018 4k Gal Water Truck 10 40,000 4/25/2024 5606018 4k Gal Water Truck 11 44,000 4/29/2024 5606018 4k Gal Water Truck 10 40,000 4/30/2024 5605001 4k Gal Water Truck 12 48,000 5/1/2024 5605001 4k Gal Water Truck 9 36,000 5/2/2024 5605001 4k Gal Water Truck 14 56,000 5/3/2024 5605001 4k Gal Water Truck 8 32,000 5/8/2024 5605001 4k Gal Water Truck 10 40,000 5/9/2024 5606018 4k Gal Water Truck 4 16,000 5/13/2024 5606018 4k Gal Water Truck 7 28,000 5/14/2024 5606018 4k Gal Water Truck 8 32,000 Total Gallons 524,000 Water Tracking 2024 Capping Project RTK LITTLE VALLEY 2024 Prepared by Matt Steffes Aug 8, 2024 RTK LITTLE VALLEY 2024 Surveyed May 16, 2024 Coordinate reference system: 2023_11_20_KUC_SITE.jxl LITTLE VALLEY BORROW AREA Prepared by Matt Steffes Aug 8, 2024 View in Propeller 8/8/24, 3:40 PM Propeller Little Valley Borrow Area - RTK LITTLE VALLEY 2024 - 2024 05 16 RTK LITTLE VALLEY https://ames-utah.prpellr.com/p/viewer/site/pr7771ef24/workspace/ws-01HWXBBYV0J1WC5Q0E2X7F7H8K/dataset/ds1f91f917/outputs 1/4 RTK LITTLE VALLEY 2024 Prepared by Matt Steffes Aug 8, 2024 Surveyed May 16, 2024 8/8/24, 3:40 PM Propeller Little Valley Borrow Area - RTK LITTLE VALLEY 2024 - 2024 05 16 RTK LITTLE VALLEY https://ames-utah.prpellr.com/p/viewer/site/pr7771ef24/workspace/ws-01HWXBBYV0J1WC5Q0E2X7F7H8K/dataset/ds1f91f917/outputs 2/4 RTK LITTLE VALLEY 2024 Prepared by Matt Steffes Aug 8, 2024 SURFACE AREA Map reference / legend Measurement name Surface Area (acres)Horizontal Area (acres) Borrow Area 4.56 4.546 Borrow Area Slopes 4.227 4.015 8/8/24, 3:40 PM Propeller Little Valley Borrow Area - RTK LITTLE VALLEY 2024 - 2024 05 16 RTK LITTLE VALLEY https://ames-utah.prpellr.com/p/viewer/site/pr7771ef24/workspace/ws-01HWXBBYV0J1WC5Q0E2X7F7H8K/dataset/ds1f91f917/outputs 3/4 RTK LITTLE VALLEY 2024 Prepared by Matt Steffes Aug 8, 2024 Borrow Area Measurement name Borrow Area Created date Aug 8, 2024 Created by Matt Steffes Surface Area (acres)4.56 acres Horizontal Area (acres)4.546 acres Borrow Area Slopes Measurement name Borrow Area Slopes Created date Aug 8, 2024 Created by Matt Steffes Surface Area (acres)4.227 acres Horizontal Area (acres)4.015 acres 8/8/24, 3:40 PM Propeller Little Valley Borrow Area - RTK LITTLE VALLEY 2024 - 2024 05 16 RTK LITTLE VALLEY https://ames-utah.prpellr.com/p/viewer/site/pr7771ef24/workspace/ws-01HWXBBYV0J1WC5Q0E2X7F7H8K/dataset/ds1f91f917/outputs 4/4