DAQ-2024-011002

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DAQC-CI106170002-24
Site ID 10617 (B1)

MEMORANDUM

TO: FILE – HOLLIDAY CONSTRUCTION INCORPORATED – Bluff Pit

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: October 11, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, San Juan County

INSPECTION DATE: April 18, 2024

SOURCE LOCATION: 4 miles west of Bluff at the intersection of U.S. Routes 163 and
191, San Juan County

DIRECTIONS: The site is located at the southwest corner of Highway 163 and
Highway 191. The site entrance is located on Highway 191.

SOURCE CONTACTS: Jason Holliday, Owner
435-979-5351, [e-mail]

Clara H, Secretary
435-678-2028, [e-mail]

OPERATING STATUS: Not operating at the time of inspection. Work is done at this site
infrequently.

PROCESS DESCRIPTION: Holliday Construction owns an aggregate processing pit near
Bluff. Raw aggregate material mined from the walls of the
quarry is fed into the crusher/screening circuit where it is
separated according to size class. Material that is too large to
pass through the screen is crushed in a crusher and re-routed
through the screens. Separated aggregate is conveyed to various
storage piles by stacking conveyors. A water truck is used to
control dust in the yard and operational areas, and water sprays
are used to control dust in the crusher/screening circuit. The
aggregate operation is powered by a 400-kW diesel generator
with an Oxy Catalyst. A wash plant is also present onsite. The
wash plant and water pump were powered by a 180-kW diesel
generator, which is no longer operational.

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APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN106170002-15, dated
November 5, 2015
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

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Holliday Construction Incorporated - Bluff Pit
PO Box 502
4 miles west of Bluff at the intersection of U.S.
Routes 163 and 191
Blanding, UT 84511 San Juan County, UT

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.
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Section II: SPECIAL PROVISIONS

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

II.A.1 Bluff Pit
II.A.2 One (1) Feeder/Jaw Crusher Capacity: 400 tph Manufacture Date: 2001
II.A.3 Two (2) Cone Crushers Size: 54" and 45"
II.A.4 One (1) Triple-Deck Screen Size: 6' x 20' Manufacture Date: 1994
II.A.5 One (1) Triple-Deck Screen Size: 4' x 14'
II.A.6 Various Conveyors
II.A.7 One (1) 400 kW Generator Fuel: Diesel Fuel
II.A.8 One (1) Wash Plant Generator Rating: 270 hp Fuel: Diesel Manufacture Date: 1974
II.A.9 Wash Plant *Listed for Informational Purposes Only*
Status: In Compliance. No unpermitted equipment was observed. The 270 hp wash plant generator listed in II.A.8 is no longer operational, and the source intends to replace it. They were advised to submit an NOI prior to installing a new generator. The 400kw generator listed in II.A.7 was on site but had broken down a few days prior and was under repair.

II.B Requirements and Limitations

II.B.1 Site Wide Requirements II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20 percent opacity. [R307-201-3] II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. The equipment was not operating during the inspection. No visible emissions were observed from haul roads or other fugitive dust sources. II.B.2 Aggregate Processing Requirements II.B.2.a The owner/operator shall not produce more than 100,000 tons of aggregate material, including bank-run material, per rolling 12-month period. [R307-401-8]

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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 belt scale records, scale house records, or bucket scale records. The records of production shall be kept on a daily basis. [R307-401-8] 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. For the rolling 12-month period ending in March 2024, a total of 31,853.80 tons of aggregate material were produced. II.B.2.b The owner/operator shall not allow visible emissions from any crusher on site to exceed 15 percent opacity. [40 CFR 60 Subpart OOO] Status: Not Observed. The crusher was not operating during the inspection. II.B.2.c The owner/operator shall not allow visible emissions from any screen on site to exceed 10 percent opacity. [40 CFR 60 Subpart OOO] Status: Not Observed. No screens were operating during the inspection. II.B.2.d The owner/operator shall not allow visible emissions from any conveyor transfer point on site to exceed 10 percent opacity. [40 CFR 60 Subpart OOO] Status: Not Observed. No conveyors were operating during the inspection. II.B.2.e The owner/operator shall not allow visible emissions from any conveyor drop point on site to exceed 20 percent opacity. [R307-205-4] Status: Not Observed. No conveyors were operating during the inspection. II.B.2.f The owner/operator shall install water sprays on all crushers, all screens, and all unenclosed conveyor transfer points on site to control fugitive emissions. Sprays shall operate as required to maintain the opacity limits listed in this AO. [R307-401-8] Status: In Compliance. Water sprays have been installed as required. II.B.2.g Within 60 days after achieving the maximum production rate but not later than 180 days after initial startup, the owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site manufactured after August 31, 1983. 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.2.g.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR 60.675(c). The owner or operator may use methods and procedures specified in 40 CFR 60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c). [40 CFR 60 Subpart OOO] II.B.2.g.2 The owner/operator shall submit written reports to the Executive Secretary 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: In Compliance. Holliday Construction conducted the initial VEOs for the existing associated wash plant equipment that included conveyors and the two screens on January 31, 2012. Copies of the observation were submitted to the DAQ on February 1, 2012, and are present in the DAQ files (DAQC-149-12).
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II.B.3 Engine Requirements II.B.3.a The 400-kW diesel generator shall not exceed 2,400 hours of operation per rolling 12-month period. [R307-401-8] Status: In Compliance. For the rolling 12-month period ending in March 2024, the generator operated for a total of 1,350 hours. 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. Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. [R307-401-8] Status: In Compliance. Operations logs are maintained to track the generator operating hours. II.B.3.b The wash plant diesel generator shall not exceed 500 hours of operation 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 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: Not Applicable. The wash plant generator has been removed from the site. II.B.3.c The owner/operator shall not allow visible emissions from any stationary diesel engine on site to exceed 20 percent opacity. [R307-201-3] Status: Not Observed. The source was not operating at the time of inspection. II.B.3.d The sulfur content of diesel fuel burned in the stationary diesel engines on site shall not exceed 15 ppm by weight. [40 CFR 63 Subpart ZZZZ] 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. Ultra-low sulfur fuel is utilized at this source. A fuel invoice was provided after the inspection via email. II.B.4 Haul Road and Fugitive Dust Requirements II.B.4.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources on site to exceed 20 percent opacity at all times. [R307-205-4] II.B.4.a.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. [R307-205-4] Status: In Compliance. No fugitive emissions were observed at the time of inspection. The source has a water truck on site and waters as needed to mitigate dust. II.B.4.b The haul road shall be no greater than 2,640 feet in length. [R307-401-8] Status: In Compliance. According to the source, the haul road length is 2,524 feet in length.
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II.B.4.c The owner/operator shall use water application on all haul roads, storage piles, and operational areas to maintain opacity limits listed in this AO. The owner/operator may stop applying water to the haul roads, storage piles, and operational areas when the temperature is below freezing. [R307-401-8] II.B.4.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 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. Watering records are kept in a notebook in the water truck according to this condition. II.B.4.d All bulldozers on site shall not operate more than 40 hours combined per rolling 12-month period. [R307-401-8] II.B.4.d.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. [R307-401-8] Status: In Compliance. For the rolling 12-month period ending in March 2024, the bulldozer operated for 35 hours. II.B.4.e The owner/operator shall control disturbed or stripped areas at all times (24 hours per day, every day) for the duration of the project/operation until the area is reclaimed. Records of reclamation shall be kept for all periods when the plant is in operation. [R307-401-8] Status: In Compliance. No visible emissions were observed from the storage piles or pit banks.

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 engines on the AO were installed prior to 2006.
NSPS (Part 60) -OOO: Standards of Performance for Nonmetallic Mineral Processing Plants

Status: In Compliance. This subpart applies to the permitted crushers and screens. This source has
conducted initial observations (January 2011) in accordance with the 40 CFR Subpart OOO for the
crushers and screens. The site was not operating and no opacity was observed during the inspection.
Spray bars are installed at all applicable points. Daily spray bar inspections occur as part of the routine
checklist prior to starting operations each day. Spray bar inspections are not explicitly stated on the
checklist but is included, according to the site supervisor. Compliance assistance was provided to
include this as a written item for daily checks.
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MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. The source did not retest the 400-kW generator engine in 2020. This generator is
required to be retested every 8,760 hours or 3 years (Table 3), whichever comes first. A Compliance
Advisory was sent on April 20, 2022, addressing the noncompliant equipment (DAQC-485-22). A
response was received on May 3, 2022, stating that they will stack test the 400-kW generator in August
2022. Delays and mechanical issues pushed the test back to November 18, 2023. The test began, failed
immediately, and was not completed. A pre-test protocol was received on March 13, 2024, and approved
on March 19, 2024 (DAQC-256-24), to stack test the generator engine. The source performed a stack
test on the 400-kW generator engine on July 2, 2024. The source submitted the test results to the DAQ
on July 17, 2024, and the results were approved on July 19, 2024 (DAQC-733-24).

An Early Settlement Agreement was issued (DAQC-038-24) to address the previous stack test failures.
The source signed and paid the Early Settlement Agreement on July 29, 2024 (DAQC-756-24).
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 this source. A fuel invoice was provided
after the inspection via email.

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

Status: In Compliance. No fugitive emissions were observed at the time of inspection. The source has
a water truck on site and waters as needed to mitigate dust.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. This area source rule is determined through compliance with MACT Subpart
ZZZZ. Refer to the Federal Requirements section for more details.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Holliday Construction Incorporated -
Bluff Pit. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN106170002-15, dated November 5, 2015, is provided. PTE are supplied for supplemental
purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 819.00 N/A
Carbon Monoxide 4.75 1.48
Nitrogen Oxides 22.07 6.88
Particulate Matter - PM10 5.64 3.95
Particulate Matter - PM2.5 2.10 1.33
Sulfur Dioxide 1.46 0.45
Volatile Organic Compounds 1.65 0.56

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Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Generic HAPs (CAS #GHAPS) 40 N/A

PREVIOUS ENFORCEMENT
ACTIONS: Compliance Advisory and Early Settlement Agreement
(DAQC-1148-22) for an unpermitted generator engine.
Compliance Advisory and Warning Letter (DAQC-1153-23) for
an unpermitted generator engine. Compliance Advisory and
Early Settlement Agreement (DAQC-038-24) for a failed stack
test. Signed Early Settlement Agreement (DAQC-756-24).

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN106170002-15,
dated November 5, 2015: In Compliance. The source performed
the required stack test according to MACT Subpart ZZZZ on
July 2, 2024, and the results of the test were approved by the
DAQ on July 19, 2024.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Verify that no unpermitted generators are on site.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, Email Correspondence, Crushing Records, Fuel
Purchase Invoice
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
Page _of_
EPA METHOD 9 -VISIBLE EMISSION OBSERVATION FORM
SourceName: ~,\\;~'J Coct:.\-cK\:i~ -'3/,,Cf Pil
Street Address: 1:" \x,ucfie:1 0 f: Hw~ \(,~ ,>-lt~j \ 9 I
City/County: B111~~ / so{\ ]vol\
Phone: 435 _q7q :535'1
Site ID: )O\olt
Facility: G c'M,\ )-
Equipment/Process: Lrvfher S , Sccua,s , CotNco t-ac
Control Equipment: Wo.v
Emission Point: ~\'-ti'-, [v~iHi<--fMt!SJ't-:JS
Sky Conditions: Clear ( ] Partly Cloudy [ ] Overcast [ ]
1 Precipitation: No [ ] Yes [ ]
Wind: Direction: ___ Speed: __ _ mph
Ambient Temp: °F RH: ___ %
Height Relative to Observer: ---
Distance From Observer: ---
Condensed Water Vapor Present: No [ ] Yes [ ]
Attached [ ] Detached [ ]
Length of Condensed Water Vapor Plume: _____ _
Background: _____________ _
Sketch process unit: indicate observer position relative to
source; indicate potential emission points and/or actual
emission points.
0
OBSERVATION DATE: Lf /1 't-/
Start time: ___ Stop time: __ _
sec 0 15 30 45 min
1
2
3 I l"il--r1 1.1ra~AQ
7\J V \ ..... 1 ' ( 4
5
6
7
8
9
10
11
12
Roll•~ 12--MMµ., P,~ A~r~I Z,CZ-"3-M~4. '2c'2'{
COMMENTS:
itB.z.,g Toor oC. ~5~~¥-< /Yl~kt'.'i(\ I 'r roe( vuc/
it lb.~-a ', 400 b.i j.trV:9\cr c;:,1<Nh'11~ Lwvo:
· P.2 • i-\ • b ', H~ I C o,:J I< "i I:½
it .;. L\. c,,. •. wq w:~ rU-c rd s
I I I I I I ' • I I I i i I I 1>r.1v. 11~1nh 111w" :lo~«!10ll.r 9
• observer
Sun • Wind Emission Point with Plume
Observer Position X
Observer's Signature:
Distrib: white-file; canary-inspect ; pink-owner/operator
I have received a copy of these observations:
SIGNATURE: AA
Printed Name o/0" \\o\\;,\._
1 T,tle: Ope..ccrlo I
t • • I:
Connor Kijowski <[e-mail]>
Holliday Construction Crusher Records Bluff Pit.pdf
2 messages
Holliday Construction Inc <[e-mail]>Tue, Apr 23, 2024 at 9:33 AM
To: Connor Kijowski <[e-mail]>
Conner: Here is the records on the Bluff Pit.
Thanks Clara
Holliday Construction Crusher Records Bluff Pit.pdf
407K
Connor Kijowski <[e-mail]>Tue, Apr 23, 2024 at 10:30 AM
To: Holliday Construction Inc <[e-mail]>
Thanks, Clara. I will reach out if I have any questions.
Best,
Connor
[Quoted text hidden]
--
Connor Kijowski
Environmental Scientist | Minor Source Compliance
M: (385)-245-6720
airquality.utah.gov
5/21/24, 12:28 PM State of Utah Mail - Holliday Construction Crusher Records Bluff Pit.pdf
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1797140177390866400&simpl=msg-f:17971401773908664…1/1