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Home My WebLink AboutDAQ-2024-0109941 DAQC-CI114360002-24 Site ID 11436 (B1) MEMORANDUM TO: FILE – KILGORE COMPANIES, LLC – Highland Pit THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Connor Kijowski, Environmental Scientist DATE: September 18, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County INSPECTION DATE: August 21, 2024 SOURCE LOCATION: 4600 West 11200 North Highland City, UT 84060 SOURCE CONTACTS: Bryan Jorgensen, Environmental Director 801-831-7402, bryan.jorgensen@kilgorecompanies.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Aggregate Pit: Bank run is hauled or bull dozed to an underground feeder dropped onto a conveyor system which transfers the raw material to the processing plant. The material is dropped into a triple deck screen with material being conveyed to a 1/8" minus and %" aggregate piles and the oversize being fed to a cone crusher. The crushed material is conveyed to a double deck screen where road base or sand is separated and the oversized is routed back to the crusher. Sand is processed through the wash plant consisting of a wet screen, two sand screws, a sand screen, and a dewatering bucket screw. Washed sand and V" aggregate are transported to the concrete batch plant via front-end loader. The concrete batch plant has been removed and no longer operates. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN114360002-16, dated March 7, 2016 NSPS (Part 60) OOO: Standards of Performance for Nonmetallic Mineral Processing Plants SOURCE EVALUATION: Name of Permittee: Permitted Location: Kilgore Companies, LLC Highland Pit 7057 West 2100 South 4600 West 11200 North Salt Lake City, UT 84128 Highland City, UT 84060 2 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] Status: In Compliance. Each condition from Section I was reviewed with the source and appeared to be in compliance. No unapproved modifications have occurred since the previous inspection. The source currently has a temporary relocation permit (DAQC-352-24) for an additional jaw crusher. This crusher will be included as permanent equipment once the new AO has been issued; the AO is currently in public comment. 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 Highland Aggregate Pit and Concrete Batch Plant II.A.2 One (1) Triple-Deck Wet Screen Size: 6' x 16' Manufacturer: JCI 3 II.A.3 One(1) Twin Sand Screw Size: 44" x 32' Manufacturer: Eagle II.A.4 Two (2) Double Screens Size: 5' x 16' each Manufacturer: JCI II.A.5 One (1) Double-Deck Screen Size: 4' x 10' Manufacturer: Simplicity II.A.6 One (1) Cone Crusher - new equipment One (1) cone crusher Capacity: 300 tph Model Number: MVP-450X Serial Number: TRXRX450EOKFEO762 Manufacture Date: May 2015 II.A.7 Various Conveyors and Stackers II.A.8 One (1) Track-Mounted Jaw Crusher Capacity: 200 tph II.A.9 One (1) Crusher Engine Rating: 300 hp Fuel: Diesel Fuel Emission Standard: Tier IV Transitional (Manufactured after 2011) II.A.10 One (1) Truck-Mix Concrete Batch Plant Capacity: 150 cubic yards Manufacturer: Con-E-Co II.A.11 Three (3) Cement & Supplement Silos Capacity: 3,000 barrels II.A.12 One (1) Water Heater Rating: 7.0 MMBtu/hr Fuel: Propane Manufacturer: Kemco II.A.13 One (1) Diesel Storage Tank Capacity: 12,000 gallons II.A.14 Various Water and Admixture Storage Tanks - listed for informational purposes only - 4 II.A.15 Various Mobile Equipment Includes: Bulldozers, Track Hoes, Back Hoes, Loaders, Water Trucks, Haul Trucks, etc. - listed for informational purposes only - Status: In Compliance. No unpermitted equipment was observed. One Astec CS3055 Jaw Crusher was operating according to the Temporary Relocation Permit (DAQC-352-24). Additional Information: II.A.5: This equipment has been removed from the site. II.A.8 – 12: This equipment has been removed from the site. II.B Requirements and Limitations II.B.1 The Highland Aggregate Pit shall be subject to the following: II.B.1.a The owner/operator shall notify the Director in writing when the new equipment listed in this AO has been installed and is operational. To ensure proper credit when notifying the Director, send your correspondence to the Director, attn: Compliance Section. If the owner/operator has not notified the Director in writing within 18 months from the date of this AO on the status of the construction and/or installation, the Director shall require documentation of the continuous construction and/or installation of the operation. If a continuous program of construction and/or installation is not proceeding, the Director may revoke the AO. [R307-401-18] Status: In Compliance. According to DAQC-1593-17, the notification of equipment installation was received as of November 17, 2017. II.B.1.b Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20 percent opacity. [R307-305-3] II.B.1.b.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. [R307-305-3] Status: In Compliance. Emissions observed at the time of inspection did not exceed the 20% limit listed in this condition. Method 9 was utilized to verify opacity limits. See attached VEO form. II.B.2 The Aggregate Processing Equipment shall be subject to the following: II.B.2.a The owner/operator shall not produce more than 1,650,000 tons of aggregate per rolling 12-month period and 600 tons of aggregate per hour. [R307-401-8] II.B.2.a.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 shall be determined by scale house records. The records of production shall be kept on a daily basis. [R307-401-8] 5 II.B.2.a.2 The owner/operator shall weigh and account for all aggregate material prior to the aggregate material leaving the site or being used in another process on site. [R307-401-8] Status: In Compliance. The source produced 587,836 tons of aggregate and did not exceed the 600 tons of aggregate per hour requirement during the rolling 12-month period from August 2023 – July 2024. This record was reviewed during the site visit and verified to be calculated according to this condition. II.B.2.b The owner/operator shall not operate the aggregate processing plant and associated equipment more than 4,000 hours per rolling 12-month period and 16 hours per day. [R307-401-8] II.B.2.b.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. Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. [R307-401-8] Status: In Compliance. The source operated the aggregate processing plant for 2,277 hours during the rolling 12-month period from August 2023 – July 2024. This record was reviewed during the site visit and verified to be calculated according to this condition. Plant logs indicated no day exceeded 16 hours of operation during the previous 12 months. II.B.2.c The owner/operator shall install and operate a feeder and conveyor transfer system in the mining area. The feeder shall be loaded with aggregate material with a bulldozer, and the conveyor transfer system shall transport all aggregate material to be processed, to the aggregate processing plant. [R307-401-8] Status: In Compliance. The feeder and conveyor are operating as required. II.B.2.d The owner/operator shall not allow visible emissions from any crusher on site to exceed 12 percent opacity on site and 10 percent opacity at property boundary. [R307-312] Status: In Compliance. Opacity from any crusher did not exceed those listed in this requirement. See the attached VEO form. II.B.2.e The owner/operator shall not allow visible emissions from any screen on site to exceed 7 percent opacity. [R307-312] Status: In Compliance. Opacity from any screen did not exceed those listed in this requirement. See the attached VEO form. II.B.2.f The owner/operator shall not allow visible emissions from any conveyor transfer point on site to exceed 7 percent opacity. [R307-312] II.B.2.f.1 Opacity shall be measured from each conveyor transfer point that relies on water carryover at least once per week. Records shall include the date and time of each measurement and the result of each observation. [R307-401-8] Status: In Compliance. Opacity is measured as required from these points. Kilgore Companies, LLC currently has two EPA Method 9 certified observers on site. This weekly record was reviewed during the site inspection and is kept according to this condition. 6 II.B.2.g The owner/operator shall not allow visible emissions from any conveyor drop point to exceed 20 percent opacity on site and 10 percent opacity at property boundary. [R307-309-5] Status: In Compliance. Opacity from any conveyor drop point did not exceed those listed in this requirement. See the attached VEO form. II.B.2.h The owner/operator shall install water sprays or chemical dust suppression sprays on crushers, screens, and conveyor transfer points as needed to control fugitive emissions. Sprays shall operate as needed when the temperature is above freezing to maintain the opacity limits listed in this AO. [R307-401-8] Status: In Compliance. Water sprays are installed as required and operate as needed. II.B.2.i The moisture content of the aggregate material being processed in the aggregate processing plant shall not be less than 4.0%. [R307-401-8] II.B.2.i.1 The owner/operator shall measure the moisture content of the aggregate material from each crusher and from each screen that does not have water sprays installed at least once per month. Moisture content shall be determined by ASTM Method D2216, D4643, D4959, or approved equivalent. Records shall include the location of each sample, the date and time when each sample was taken, and the moisture content of each sample. [R307-401-8] Status: In Compliance. The only crusher that is not equipped with a water spray is the initial jaw crusher. The source explained that the material that enters this initial crusher is always moist and does not need any additional moisture to meet opacity requirements. All other crushers and screens are equipped with water sprays. Daily moisture samples are taken and recorded. These records were reviewed with the source during the inspection. Refer to the Highland Pit Moisture Sample record from August 22, 2024, in the attachments. II.B.2.j The owner/operator shall inspect the upstream water sprays of conveyor transfer points that rely on water carryover to control fugitive emissions at least once per month to check that water is flowing to the spray nozzles. [R307-401-8] II.B.2.j.1 Records shall include the date and time of each inspection, the status of the water sprays, and any corrective action taken. [R307-401-8] Status: In Compliance. Water spray bars are inspected monthly as required by this condition. These records were reviewed during the site inspection. II.B.3 The Track-Mounted Jaw Crusher and the Crusher Engine shall be subject to the following: II.B.3.a The Track-Mounted Jaw Crusher shall not produce more than 40,000 tons of aggregate per rolling 12-month period. [R307-401-8] II.B.3.a.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 shall be determined by belt scale and/or bucket scale records. The records of production shall be kept on a daily basis. [R307-401-8] Status: Not Applicable. The track crusher was removed prior to July 2021. No aggregate was produced using the track crusher in the last 12 months. 7 II.B.3.b The Crusher Engine shall not consume more than 2,400 gallons of diesel fuel per rolling 12- month period. [R307-401-8] II.B.3.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total for each day of the previous month by the twentieth day of each month using data from the previous 12 months. Amount of fuel consumed shall be determined by supervisor monitoring and maintaining of an operations log. Records fuel consumption shall include the amount of fuel used in the engine each day. [R307-401-8] Status: Not Applicable. The track crusher was removed prior to July 2021. No diesel was used for the crusher engine in the last 12 months. II.B.3.c The owner/operator shall not allow visible emissions from any diesel engine on site to exceed 20 percent opacity. [R307-305-3] Status: Not Applicable. The diesel engine is no longer on site. II.B.3.d The sulfur content of any diesel fuel burned in any diesel engine on site shall not exceed 15 ppm by weight. [40 CFR 60 Subpart IIII] II.B.3.d.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] Status: In Compliance. The sulfur content was verified to be ultra-low sulfur. This was determined by a fuel purchase invoice provided by the supplier, Rhinehart Oil. II.B.4 The Concrete Batch Plant shall be subject to the following: II.B.4.a The owner/operator shall not produce more than 210,000 cubic yards of concrete per rolling 12-month period and 150 cubic yards of concrete per hour. [R307-401-8] II.B.4.a.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 shall be determined by scale house records or vendor receipts. The records of production shall be kept on a daily basis. [R307-401-8] Status: Not Applicable. The concrete batch plant has been removed from the site. II.B.4.b The owner/operator shall use a baghouse to control emissions from the weigh hopper loading of the concrete batch plant. [R307-401-8] Status: Not Applicable. The concrete batch plant has been removed from the site. II.B.4.c The owner/operator shall install a fabric filter device on all material storage silos associated with the concrete batch plant. Displaced air from the silos shall pass through the fabric filter devices before being vented to the atmosphere. [R307-401-8] Status: Not Applicable. The concrete batch plant has been removed from the site. 8 II.B.4.d The owner/operator shall not allow visible emissions from the concrete batch plant baghouse or fabric filters on site to exceed 7 percent opacity. [R307-312] Status: Not Applicable. The concrete batch plant has been removed from the site. II.B.5 The Water Heater shall be subject to the following: II.B.5.a The owner/operator shall not combust more than 38,210 gallons of propane in the water heater per rolling 12-month period. [R307-401-8] II.B.5.a.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 propane combustion shall be kept for all periods when the plant is in operation. The amount of propane combusted shall be determined by purchasing receipts. The records of propane combustion shall be kept on a monthly basis. [R307-401-8] Status: Not Applicable. The water heater associated with the concrete batch plant is no longer on site. II.B.5.b The owner/operator shall not allow visible emissions from the water heater on site to exceed 10 percent opacity. [R307-401-8] Status: Not Applicable. The water heater associated with the concrete batch plant is no longer on site. II.B.6 The Bulldozing Operations on site shall be subject to the following: II.B.6.a All bulldozers on site shall not exceed 4,000 hours of operation combined per rolling 12-month period. [R307-401-8] II.B.6.a.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. Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. The records of operation shall be kept on a daily basis. Records shall include the following: A. The number of hours each bulldozer operated each day B. The total hours of operation for all bulldozers each day C. The rolling 12-month total hours of operation for all bulldozers [R307-401-8] Status: In Compliance. The source operated the bulldozers for 1,443 hours during the rolling 12-month period from August 2023 – July 2024. This record was reviewed during the site visit and was verified to include the number of hours each bulldozer operated per day, the total operating hours per day, and the rolling 12-month total hours for all bulldozers. II.B.7 All Haul Roads and Fugitive Dust Sources on site shall be subject to the following: 9 II.B.7.a The owner/operator shall apply chemical dust suppressants on all unpaved haul roads and operational areas and shall use water application on all haul roads to maintain opacity limits listed in this AO. The owner/operator may stop applying water to the haul roads, loader routes, and wheeled-vehicle operational areas when the temperature is below freezing but shall still maintain the opacity limits listed in this AO. [R307-401-8] II.B.7.a.1 Records of chemical application 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 and quantity of water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature is below freezing [R307-401-8] Status: In Compliance. Records of chemical and water application are kept and were viewed during the inspection. The most recent chemical application was July 2024. Watering records were verified to include the date and time of application, number of treatments, temperature, and weather. II.B.7.b The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% opacity at the property boundary. [R307-309-5] II.B.7.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in 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 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 fugitive dust was observed at the time of inspection. The haul road was watered upon arrival and a water truck was actively watering during the inspection. See the attached VEO form. II.B.7.c The haul road to the aggregate processing plant shall not exceed 0.59 miles in length (1.18 miles round-trip), and the haul road to the concrete batch plant shall not exceed 0.42 miles in length (0.84 miles round-trip). The vehicle speed along the haul road shall not exceed 12 miles per hour. The vehicle speed on the haul road 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. A 10 miles per hour speed limit sign is posted at the entrance to the pit. The haul road to the concrete batch plant is no longer in use, as the batch plant has been removed. The aggregate processing plant haul road did not appear to exceed the limit listed in this condition. II.B.7.d The owner/operator shall apply water to the storage piles and disturbed or stripped areas on site to maintain the opacity limits listed in this AO. Control of disturbed or stripped areas is required at all times (24 hours per day, every day) for the duration of the project/operation until the area is reclaimed. Records of treatment and/or reclamation shall be kept for all periods when the plant is in operation. [R307-401-8] Status: In Compliance. Storage piles appeared wet during the inspection. Records were viewed during the inspection. 10 II.B.7.e The moisture content of the material shall be maintained at a minimum of 4.0% by weight. The moisture content shall be tested if directed by the Director using the appropriate American Society of Testing and Methods (ASTM) method. [R307-401-8] Status: In Compliance. Moisture content is sampled by the source on a daily basis. Moisture sample test results from previous days were reviewed with the source during the inspection. Refer to the Highland Pit Moisture Sample record from August 22, 2024, in the attachments. II.B.7.f The silt content of the haul roads shall not exceed 4.8% by weight. The silt content shall be determined if directed by the Director using the appropriate ASTM method. The silt content is defined as all material passing a #200 U.S. Standard Sieve. [R307-401-8] Status: Not Observed. No silt content test of the haul roads has been requested from the Director. II.B.7.g The owner/operator shall comply with all applicable requirements of R307-309 for Fugitive Emission and Fugitive Dust sources on site. [R307-309] Status: In Compliance. No fugitive dust was observed at the time of inspection. Haul roads were watered upon arrival and were actively sprayed during the inspection. The most recent Fugitive Dust Control Plan was submitted April 10, 2024. See the attached VEO form. 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: In Compliance. According to DAQC-1593-17, the initial observations were received by DAQ on April 27, 2013, and are located in the Source Files. Water spray bars are installed and inspected monthly. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. Ultra-low sulfur fuel is utilized at the source. This was determined during the inspection through a fuel purchase invoice provided by the fuel supplier, Rhinehart Oil. 11 Stationary Sources [R307-210] Status: In Compliance. This rule is satisfied by compliance with NSPS Subpart OOO. Refer to the Applicable Federal Requirements section for more details. Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305] Status: In Compliance. Visible emissions did not exceed the 20% opacity threshold over a six-minute average. See the attached VEO form. Nonattainment and Maintenance Areas for PM10:Emissions and Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. No fugitive dust was observed at the time of inspection. Haul roads were watered upon arrival and were actively sprayed during the inspection. The most recent Fugitive Dust Control Plan was submitted April 10, 2024. See the attached VEO form. EMISSION INVENTORY: Listed below are the 2023 Actual Emissions Inventory provided from Kilgore Companies, LLC – Highland Pit. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN114360002-16, dated March 7, 2016, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 264.00 N/A Carbon Monoxide 0.30 0.16 Nitrogen Oxides 0.98 0.01 Particulate Matter - PM10 28.43 17.85 Particulate Matter - PM2.5 8.55 6.93 Sulfur Dioxide 0.05 0.00 Volatile Organic Compounds 0.08 0.01 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Generic HAPs (CAS #GHAPS) 20 N/A 12 PREVIOUS ENFORCEMENT ACTIONS: Compliance Advisory (DAQC-547-23) and Warning Letter (DAQC-660-23) to address an unpermitted generator engine. Compliance Advisory (DAQC-1196-23) and Early Settlement Agreement (DAQC-1289-23) to address excessive diesel fuel consumption. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN114360002-16, dated March 7, 2016, the overall status is: In Compliance. The source appears to be well maintained and operated. Records were current and provided during the inspection and afterwards via email. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect once the new AO has been issued. Hard hat, safety glasses, high visibility clothing, and steel toe boots are required to tour the site. NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: VEO Form, Highland Pit Moisture Sample Record fa 4 Cl L ** + z :r sztr- STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY EPA METHOD 9 -VISIBLE EMISSION OBSERVATION FORM OBSERVATION DATE: <3/~) lf1 Street Address=~\v ~:f lJ City/County: \ 'q ~/ , Phone: ~\-~<rt • 1.\1..\r\ Site ID: HL{:t2 Facility: ~ 1 rtja ~ ~ 'r Equipment/Process: lJvj'vef5 1 X[W\s. (aNJ<!(cr5 , &~•-lv'.1/ef ½1 Control Equipment: l0c{~ Emission Point: Sky Conditions: Clear l.] Partly Cloudy [ ] Overcast [ ] Precipitation: No lxJ Yes [ I Wind: Direction: S Speed: l(S--\) mph Ambient Temp: l\.t::: °F RH: ZO % Height Relative to Observer: __ _ Distance From Observer: --- Condensed Water Vapor Present: No [ ] Yes [ ] Attached [ ] Detached [ ] Start time: \L\ '. W Stop time: ~ (C min 0 15 30 1 2 / ~ 3 I/ ~ 4 V ~ J 5 / '-/ / ( 6 7 8 9 10 11 12 COMMENTS: Page _of_ 45 / ~ ~ Length of Condensed Water Vapor Plume: _____ _ JJo /Ji)I-¼, lA11SSIC¥' ~M }L. na,¼ (qi)~ Background: _____________ _ Sketch process unit: indicate observer position relative to source; indicate potential emission points and/or actual emission points. 0 IJ1.,v. 111111h ,11111" • ob~erver Sun f Wind ► Emission Point with Plume ~ Observer Position x Observer's Signature: Distrib: white-file; canary-inspector· I have received a SIGNATURE: Printed Na . . Title: S,r£ JAAAJAC.t/l. Highland Pit Moisture Samples Product Moisture %8/22/2024 Washed Concrete Sand 4.7 Washed Concrete Sand 2 6.6 Washed Chip 7.7 Crusher Feed / Road Base 5.3