DAQ-2024-010976

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DAQC-CI148470001-24
Site ID 14847 (B1)

MEMORANDUM

TO: FILE – GRANITE CONSTRUCTION COMPANY – Talons Cove Hot Mix Asphalt
Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: September 20, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: August 14, 2024

SOURCE LOCATION: 4288 East Ranches Parkway
Eagle Mountain, UT 84005
SOURCE CONTACTS: Quin Bingham, Environmental Manager
801-526-6050 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Granite Construction Company (GCC) operates a 400 ton per
hour asphalt plant with associated equipment at the Talons Cove
property shared with the TM Crushing aggregate operations. The
asphalt plant is situated north of the aggregate pit and can be
accessed by following the main TM haul road as it curves north
bound. Raw dry materials are kept in storage piles that can be
dropped by a front-end loader into a screen feed belt. The
material is blended with asphalt oils, mixed and then conveyed
to storage silos which then load through chutes into haul trucks.
Emissions are controlled with a baghouse. GCC runs its own
watering truck independent of TM Crushing's operations. A
modeling analysis for formaldehyde was required for this
operation. The modeling statement DAQE-MN148470001-13
documented emissions comply with the UDAQ-TSL (toxic
screening level).

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN148470001-14, dated January
22, 2014
NSPS (Part 60) OOO: Standards of Performance for Nonmetallic
Mineral Processing Plants,

NSPS (Part 60) I: Standards of Performance for Hot Mix Asphalt
Facilities

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Granite Construction Company - Talons Cove Hot
Mix Asphalt Plant

1000 North Warm Springs Road 4288 East Ranches Parkway
Salt Lake City, UT 84116 Eagle Mountain, UT 84005

SIC Code: 2951: (Asphalt Paving Mixtures & Blocks)

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: Out of Compliance with Condition I.3. The source installed and operates an
additional, unpermitted asphalt cement (AC) tank. This was observed and addressed during the previous inspection. See Section II.A and the Compliance Status and
Recommendations section for more information. The remaining conditions from Section I were reviewed with the source and appear to be in
compliance. The 2023 Emission Inventory was submitted by the required date.

Section II: SPECIAL PROVISIONS

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

II.A.1 Talons Cove Asphalt site Hot Mix Asphalt Plant
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II.A.2 CMI 400 T Drum Asphalt Plant Company equipment ID # 35.320801, drum mix
II.A.3 One scalping screen 3 feet x 8 feet RAP scalping screen
II.A.4 Equipment company ID # 80.3209 30 inches x 58 feet RAP conveyor
II.A.5 Equipment company ID # 85.5009 Lime Silo/Pugmill/Screw
II.A.6 Equipment company ID #82.5003 CMI Cold Feed Screen
II.A.7 Company equipment ID 80.5008 CMI 30 inches x 47 feet Conveyor
II.A.8 Company equipment ID # 87.5002 CMI Reverse Air Baghouse
II.A.9 Company equipment ID 80.5011 24 inches x 24 feet RAP conveyor
II.A.10 Company equipment ID #80.1788 30 inches x 30 feet Conveyor
II.A.11 No company ID number 24 inches x 40 feet conveyor
II.A.12 Company equipment ID # 86.088 CEI 1800A Hot Oil Heater
II.A.13 Company equipment ID # 86.5011 CEI 30K AC Tank
II.A.14 Company equipment ID # 86.373 Burke 25K AC Tank
II.A.15 Company equipment ID #86.718 Hyway 25K AC Tank
II.A.16 No company equipment ID Six (6) Astec AC Silos, 200 tons capacity each
Status: Out of Compliance. All of the above equipment was observed on site. A fourth, unpermitted AC tank is on site and was addressed by a Compliance Advisory (DAQC-1060-23) during the previous inspection. The source is in the final stages to receive an updated AO to address the additional AC Tank.

II.B Requirements and Limitations
II.B.1.a The baghouse shall control process streams from the CMI drum mix asphalt plant. All exhaust air from the asphalt-mixing drum shall be routed through its dedicated baghouse before being vented to the atmosphere. [R307-401-8] Status: In Compliance. All exhaust air from the asphalt mixing drum is routed through its dedicated baghouse before being vented to the atmosphere.
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II.B.1.b A manometer or magnehelic pressure gauge shall be installed on the asphalt plant baghouse to measure the differential pressure across the fabric filters. Static pressure differential across the fabric filters shall be between 4.0 to 7.0 inches of water column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The readings shall be accurate to within plus or minus one (1.0) inch of water column. Intermittent recording of the readings are required on a once-per-operational-day basis. [R307-401-8] Status: In Compliance. A magnehelic pressure gauge for the asphalt plant baghouse is installed in the plant operations trailer. The gauge read 4.0 inches of water column at the time of inspection. Readings are recorded on a daily basis and kept in a log book which was reviewed during the inspection. The readings for the past year were within the range specified in this condition. II.B.1.c Visible emissions from the following emission points shall not exceed the following values: 1. All screens - 10% opacity 2. All conveyor transfer points - 10% opacity 3. Baghouse exhaust stack - 20% opacity 4. Conveyor drop points - 20% opacity 5. All other points - 20% opacity [R307-401-8] II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. For sources that are subject to NSPS, opacity shall be determined by conducting observations in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed from any of the listed emission points. Only steam was observed from the asphalt plant baghouse. See the attached VEO Form for additional information. II.B.1.d The owner/operator shall not allow visible emissions from all paved in-plant haul roads to exceed 10 percent opacity and shall not allow visible emissions from all unpaved haul roads and fugitive dust sources on site to exceed 20 percent opacity. [R307-401-8] II.B.1.d.1 Visible emissions determinations for traffic sources 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 the vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5] Status: In Compliance. No fugitive dust was observed from any haul traffic. The area was watered upon arrival and the water truck was actively spraying during the inspection. See the attached VEO Form for additional information.

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II.B.1.e Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions: 1. All dry screens 2. All conveyor transfer and stacker drop points The sprays shall operate whenever conditions warrant to meet the opacity requirements of this AO. [R307-401-8] Status: In Compliance. Water sprays are installed at the screens, conveyor transfer points, and drop points to control fugitive emissions. The source operates the water sprays whenever conditions warrant. II.B.1.f The source shall not exceed the following limits: 1. 500,000 tons per rolling 12-month period of asphalt production 2. 3,840 hours per rolling 12-month period for HMA plant operation 3. 141,000 tons of recycled asphalt produced per rolling 12-month period [R307-401-8] II.B.1.f.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of production shall be kept for all periods when the plant is in operation. Production of the various products shall be determined by maintaining a production log for each material. The records of production shall be kept on a daily basis. Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. [R307-401-8] Status: In Compliance. The source determines compliance from daily production records when the plant is in operation and maintains an operations log. The operations log for the previous 12-month period from August 2023 - July 2024, was reviewed during the inspection. The calculated totals were provided after the inspection via email and are as follows: 1. 114,409 tons of asphalt production 2. 366 hours of HMA plant operation 3. 27,610 tons of recycled asphalt production See the attached email correspondence. II.B.1.g Emissions to the atmosphere at all times from the indicated emission point shall not exceed the following rates and concentrations: Source: (Drum Asphalt Plant Stack) Pollutant lb/hr grains/dscf (68 degrees F, 29.92 in Hg) PM10 (virgin) 9.53 0.024 PM10 (recycle) 11.12 0.028 [R307-401-8] Status: In Compliance. The most recent stack test was performed on August 19, 2022. DAQ results for the drum asphalt plant stack were 3.581 lb/hr, and 0.0211 gr/dscf for PM10. See DAQC-1303-22 for more information.
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II.B.1.h Stack testing to show compliance with the emission limitations stated in the above condition shall be performed as specified below: Emissions Point Pollutant Testing Status Test Frequency Asphalt Plant Stack PM10 * @ Testing Status (To be applied above) * Initial compliance testing has already been performed. @ Test every three years, or sooner, if directed by the Director. Tests may be required if the source is suspected to be in violation with other conditions of this AO. Compliance testing shall not be required for both virgin and recycled materials during the same testing period. Testing shall be performed for the product being produced during the time of testing. [R307-165] II.B.1.i Methods for pollutant PM10 For stack in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201 or 201a. The back half condensibles shall also be tested using the method specified by the Director. All particulate captured shall be considered PM10. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The back half condensibles shall also be tested using the method specified by the Director. The portion of the front half of the catch considered PM10 shall be based on information in AP-42, Appendix C or other data acceptable to the Director. The back half condensibles shall not be used for compliance demonstration but shall be used for inventory purposes. [R307-165] II.B.1.j Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-165] II.B.1.k Volumetric flow rate 40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director. [R307-165] II.B.1.l Calculation To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]

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II.B.1.m Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The source test protocol shall be approved by the Director prior to performing the tests. The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.n Existing source operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. [R307-165] Status: In Compliance. All requirements with testing, reporting, and approval were followed. See DAQC-1303-22 for more information. II.B.1.o All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition. The opacity shall not exceed 20% during all times the areas are in use or unless it is below freezing. Records of water and chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date B. Number of treatments made, dilution ratio, and quantity C. Rainfall received, if any, and approximate amount D. Time of day treatments were made Records of treatment shall be made available to the Director upon request. [R307-309-5] Status: In Compliance. All unpaved roads and other unpaved operational areas are watered to control fugitive dust. Watering records were reviewed on site. These records include the date of treatment, number of treatments, moisture received, and time of day treatments were made. II.B.1.p The storage piles shall be watered to minimize generation of fugitive dusts, as dry conditions warrant or as determined necessary by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. Records of water and/or chemical treatment shall be made available to the Director or Director's representative upon request. [R307-401-8] Status: In Compliance. The water truck has the capability to water the storage piles and the piles are watered when necessary. Records are maintained and were reviewed during the inspection. II.B.1.q Granite Construction Company shall comply with a FDCP acceptable to the Director for control of all dust sources associated with the Talons Cove site. Granite Construction Company shall comply with the most current FDCP approved by the Director. The haul road speed shall be posted. [R307-309-6] Status: In Compliance. The most current Fugitive Dust Control Plan is dated May 22, 2013, and is followed accordingly. The haul road speed is posted and clearly visible.

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II.B.1.r The facility shall comply with all applicable requirements of R307-309 for PM10 and PM2.5 nonattainment areas for Fugitive Emission and Fugitive Dust sources. [R307-309] Status: In Compliance. No visible emissions were observed from any point at the time of inspection. See attached VEO Form for additional information. II.B.1.s The owner/operator shall use natural gas as fuel in the asphalt plant. [R307-401-8] Status: In Compliance. Natural gas is the only fuel used in the asphalt plant.

Section III: APPLICABLE FEDERAL REQUIREMENTS

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

NSPS (Part 60) OOO: Standards of Performance for Nonmetallic Mineral Processing Plants

Status: Not Applicable. A scalping screen and a cold feed screen are used to convey materials to the
asphalt plant but do not process aggregate product as per Subpart OOO.

NSPS (Part 60) I: Standards of Performance for Hot Mix Asphalt Facilities

Status: In Compliance. An initial stack test was performed for this previously portable plant on
September 21, 2013. The most recent stack test was performed on August 19, 2022 (see DAQC-1303-22).
An initial VEO for the plant was performed on September 18, 2013, and the results were submitted to
the DAQ with the stack testing results. This plant operates on natural gas.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Stationary Sources [R307-210]

Status: In Compliance. This rule is satisfied through compliance with NSPS Subpart OOO and
Subpart I. Refer to the Applicable Federal Requirements section for additional information.
Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. No visible emissions were observed from any point at the time of inspection.
See attached VEO Form for additional information.

Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. No fugitive dust was observed from the haul roads or surrounding
operational areas. The haul road was watered upon arrival and the water truck was actively spraying
during the inspection. The most recent Fugitive Dust Control Plan was submitted May 22, 2013. See
the attached VEO Form for additional information.
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Aggregate Processing Operations for PM2.5 Nonattainment Areas [R307-312]

Status: In Compliance. No visible emissions were observed from any point at the time of inspection.
See attached VEO Form for additional information.

EMISSION INVENTORY:
Listed below are the 2023 Actual Emissions Inventory provided from Granite Construction Company -
Talons Cove Hot Mix Asphalt Plant. A comparison of the estimated total potential emissions (PTE) on
AO: DAQE-AN148470001-14, dated January 22, 2014, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 47414.22 N/A
Carbon Monoxide 33.18 12.55
Nitrogen Dioxide 6.50 2.39
Particulate Matter - PM10 5.75 4.47
Particulate Matter - PM10 (Fugitives) 3.93 2.54
Particulate Matter - PM2.5 1.39 0.47
Sulfur Dioxide 0.85 0.44
Volatile Organic Compounds 11.84 2.233

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 1 N/A
Formaldehyde (CAS #50000) 6 N/A
Lead (CAS #7439921) 8 N/A
Toluene (CAS #108883) 2 N/A
Xylenes (Isomers And Mixture) (CAS #1330207) 4 N/A

PREVIOUS ENFORCEMENT
ACTIONS: Compliance Advisory was issued on October 3, 2023 (see
DAQC-1060-23). An Early Settlement Agreement was issued on
October 27, 2023 (see DAQC-1154-23).

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN148470001-14,
dated January 22, 2014, the overall status is: Out of Compliance.
The source operates an additional AC tank not listed on the
current AO. The source has been working with New Source
review to receive an updated AO based on an Administrative
Amendment to the current AO. This is to address the
unpermitted AC Tank and reduce the annual asphalt production.
It was determined that this new AO will result in a reduction in
air pollutants according to R307-401-12. For this reason, no
action is recommended. All other conditions appear to be in
compliance.

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HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect the following year once the new AO has been issued.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO form, email correspondence with production totals.
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STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
EPA METHOD 9-VISIBLE EMISSION OBSERVATION FORM
~ource Name: (;--ao,k Con$\:t',(,@ _ 'Jq}M,S (cµ!. HA1A
Street Address: Y.~ baSh~mdrt.$ P0rbuf11
City /County: f'A91L Mcw1hl i /\ / U l-ct ½
OBSERVATION DATE: --=-~....L.)..1...(Y...J...l.)-=z}1:__1,,...._
Start time: \ 0 •.gs Stop time: IQ'.( I
Phone: Bbk S'.2{p-(9050
Site ID: \L\g'l,\,-
Facility: \\cA: MI >s ~q\ \: Pl&'\t
Equipment/Process: 3~, Cc>Avt'ijlb, 6vcrtf5
Control Equipment: ~~ ~C1/Se 1 Work.c
Emission Point:
Sky Conditions: Clear P(1 Partly Cloudy [ ] Overcast [ ]
Precipitation: No IX] Yes [ ] ____ _
Wind: Direction: cSS Speed: \C> mph
Ambient Temp: 3:l: °F RH: 9o %
Height Relative to Observer: Eb
Distance From Observer: l SJ
Condensed Water Vapor Present: No [ ] Yes ~
Attached [ ] Detached 1)(1
Length of Condensed Water Vapor Plume: __ 1_1£.,.._.) ...... k\:: .......... __
Background: ~\vv 5~
Sketch process unit: indicate observer position relative to
source; indicate potential emission points and/or actual
emission points.
Draw nonh IIITOW
Sun -C,-Wind Emission Point with Plume (I:=J
Observer Position x
Observer's Signature:
Distrib: white-file; canary-inspector; pi -owner/operator
0 15 30
1 C)
2
3
4
5
6
7
8
9
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COMMENTS:
I have received a copy of these obse ns:
SIGNATURE:
Title:
Page_of_
45
0
D
0
0
Connor Kijowski <[e-mail]>
Air Quality Inspection Records Request - Granite Construction Talons Cove HMA
5 messages
Connor Kijowski <[e-mail]>Wed, Aug 14, 2024 at 3:23 PM
To: "Bingham, Quin" <[e-mail]>
Good Afternoon Quin,
I recently performed a routine air quality inspection at the Talons Cove HMA Plant. To complete the inspection, there are
some records required. From the Approval Order (attached for your reference):
II.B.1.f: Tons of asphalt/recycled asphalt produced and hours of operation for the HMA Plant for the rolling 12-month
period (August 2023 - July 2024)
I also see that a compliance advisory was submitted last year to address an unpermitted asphalt cement storage tank. It
looks like the administrative amendment is being drafted to address this issue. I have reached out to the permitting
engineer but any update you can provide would be greatly appreciated as well. For the required records, please provide
these by August 26, 2024. Let me know if you have any questions.
Thank you,
--
Connor Kijowski
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
DAQE-AN148470001-14.pdf
95K
Bingham, Quin <[e-mail]>Thu, Aug 15, 2024 at 10:30 AM
To: Connor Kijowski <[e-mail]>
Hey Connor,

I will get you the production numbers later today or tomorrow.

Regarding our AO mod, last I heard from my permit engineer on 7/31 was they had everything they needed
from me and are drafting the modified AO.

-Quin

9/20/24, 12:19 PM State of Utah Mail - Air Quality Inspection Records Request - Granite Construction Talons Cove HMA
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-a:r1482116900969317564&simpl=msg-a:r-55287528794154…1/2
From: Connor Kijowski <[e-mail]>
Sent: Wednesday, August 14, 2024 3:23 PM
To: Bingham, Quin <[e-mail]>
Subject: Air Quality Inspecon Records Request - Granite Construcon Talons Cove HMA

CAUTION: External Email: Be Cyber-Alert
[Quoted text hidden]
Connor Kijowski <[e-mail]>Thu, Aug 15, 2024 at 10:30 AM
To: "Bingham, Quin" <[e-mail]>
Ok, thanks for the update.
[Quoted text hidden]
Bingham, Quin <[e-mail]>Mon, Aug 19, 2024 at 4:01 PM
To: Connor Kijowski <[e-mail]>
Hey Connor,

Below are the rolling 12-month values for Aug 2023 – July 2024:

HMA Tonnage: 114,409 tons
RAP: 27,610 tons
Operating Hours: 366 hours
[Quoted text hidden]
Connor Kijowski <[e-mail]>Tue, Aug 20, 2024 at 8:20 AM
To: "Bingham, Quin" <[e-mail]>
Thanks, Quin. I appreciate it. I will let you know if I have any questions.
Best,
Connor
[Quoted text hidden]
9/20/24, 12:19 PM State of Utah Mail - Air Quality Inspection Records Request - Granite Construction Talons Cove HMA
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-a:r1482116900969317564&simpl=msg-a:r-55287528794154…2/2