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HomeMy WebLinkAboutDAQ-2024-0110051 DAQC-CI142140001-24 Site ID 14214 (B1) MEMORANDUM TO: FILE – WASATCH MINERALS – Slate Processing Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: September 11, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County INSPECTION DATE: July 1, 2024 SOURCE LOCATION: 10320 North 8800 West Lehi, UT 84043 DIRECTIONS: Go through Nationwide Trailer, Lehi, to get to Wasatch Minerals. SOURCE CONTACT: Garrett Vonk, Plant Manager, 801-899-5478, 801-766-5702 vonk@wasatchminerals.com OPERATING STATUS: Not in operation since 2021 PROCESS DESCRIPTION: Locally quarried slate is trucked in and stockpiled. A front-end loader places the slate into the hopper of the primary crusher (jaw crusher). A conveyor then moves the product into a three-sided building where it is stockpiled. A front-end loader is used to transport this crushed slate to a second feeder and the secondary crusher (impact crusher) located in another building. The crushed slate is then pneumatically transported to a sizing cyclone that removes larger pieces and redirects them back into the secondary crusher for additional crushing. Fines from the crusher are moved to the finished product silo which is equipped with baghouse #1. The finished material from the silo is conveyed pneumatically via a screw conveyor to the bagging station silo located inside the building. Emissions from the bagging station silo are controlled by baghouse #2. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN0142140001-10, dated January 25, 2010 NSPS (Part 60) - OOO: Standards of Performance for Nonmetallic Mineral Processing Plants, / : 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Wasatch Minerals - Slate Processing Plant 10320 North 8800 West 10320 North 8800 West Mesa, AZ 85210 Lehi, UT 84043 SIC Code: 1499: (Miscellaneous Nonmetallic Minerals, Except Fuels) 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 R307-150 Series. Inventories, Testing and Monitoring. [R307-150] I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: Compliance undetermined. According to Wasatch Minerals, the Slate Processing Plant has not been in operation since 2021. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Wasatch Minerals Slate processing plant II.A.2 Crushers One (1) jaw crusher and one (1) impact crusher rated at 600 tons/hr each, manufactured date unknown but prior to 2008 3 II.A.3 Hoppers Two hoppers, one for the jaw crusher and the other for the impact crusher II.A.4 Silo One (1) finished product silo II.A.5 Baghouse #1 One (1) baghouse for the finished product silo II.A.6 Silo One (1) bagging station silo II.A.7 Baghouse #2 One (1) baghouse for the bagging station silo II.A.8 Cyclone One (1) cyclone for material classification, not for emission control II.A.9 Conveyors Misc. conveyors for transporting material Status: Compliance undetermined. During this site visit, I did not observe any equipment. According to Wasatch Minerals, the Slate Processing Plant has not been in operation since 2021. II.B Requirements and Limitations II.B.2 Production Limit II.B.2.a The following production limit shall not be exceeded: 20,000 tons of slate processed per rolling 12-month period 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 an operation log. The records of production shall be kept on a daily basis. [R307-401-8] II.B.3 Conditions on Fugitive Dust Emissions II.B.3.a Wasatch Minerals shall comply with a fugitive dust control plan acceptable to the Executive Secretary for control of all dust sources associated with its operations. Wasatch Minerals shall submit a fugitive dust control plan to the Executive Secretary, attention: Compliance Section, for approval within 30 days of the date of this AO. [R307-309-6] II.B.3.b Visible emissions from the following emission points shall not exceed the following values: A. The crushers - 15% opacity B. All conveyor transfer points - 10% opacity C. Conveyor drop points - 20% opacity D. All other points - 20% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. For equipment subject to NSPS, such as crushers, belt conveyors and bagging operation, opacity shall be determined by conducting observations in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. 4 Initial visible emission observations shall consist of 30 observations of six minutes each in accordance with 40 CFR 60.11(b). Equipment subject to NSPS Subpart OOO shall comply with 40 CFR 60.675(3) or 40 CFR 60.675(4). All visible emission observations must be conducted in accordance with 40 CFR 60, Appendix A, Method 9. A certified observer must be used for these observations. Emission points which are subject to the initial observations are the jaw crusher and the conveyors. [R307-401-8] II.B.3.c Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed 20% opacity at any point. Visible emission determinations 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] II.B.1 Conditions on Baghouses II.B.1.a Baghouse #1 shall control process streams from the finished product silo, and Baghouse #2 shall control process streams from the bagging station. All exhaust air from the finished product silo and the bagging station shall be routed through their respective baghouses before being vented to the atmosphere. [R307-401-8] II.B.1.b A manometer or magnehelic pressure gauge shall be installed on each of the baghouses to measure the differential pressure across the fabric filter. Static pressure differential across the fabric filter shall be between 3 and 6 inches of water column. The pressure gauge shall be located such that an inspector /operator can safely read the indicator at any time. The reading shall be accurate to within plus or minus 1.0 inches water column. The instrument shall be calibrated according to the manufacturer's instructions at least once every 12-month period. Daily recording of the reading is required on days of operation. [R307-401-8] II.B.1.c Visible emissions from both baghouses shall not exceed 10% opacity. Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: Compliance undetermined. During this site visit, I did not observe any equipment or processes. According to Wasatch Minerals, the Slate Processing Plant has not been in operation since 2021. 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: Compliance undetermined. According to Wasatch Minerals, the Slate Processing Plant has not been in operation since 2021. 5 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-309 - Nonattainment and Maintenance Areas for PM10:Emissions and Fugitive Emissions and Fugitive Dust Status: Compliance undetermined. During this site visit, I did not observe any equipment. According to Wasatch Minerals, the Slate Processing Plant has not been in operation since 2021. R307-312 - Aggregate Processing Operations for PM2.5 Nonattainment Areas Status: Compliance undetermined. During this site visit, I did not observe any equipment or processes. According to Wasatch Minerals, the Slate Processing Plant has not been in operation since 2021. EMISSION INVENTORY: Wasatch Minerals last submitted an Emissions Inventory Report in 2017. Listed below is the estimated total potential emissions (PTE) on AO: DAQE-AN0142140001-10, dated January 25, 2010, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr Particulate Matter - PM10 0.38 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Compliance undetermined regarding the conditions of the Approval Order (AO) DAQE-AN0142140001-10, dated January 25, 2010. According to Wasatch Minerals, the Slate Processing Plant has not been in operation since 2021. During this inspection, a copy of the 2023 Aggregate Fee was given to Mr. Garrett Vonk. Wasatch Minerals was encouraged to address the outstanding fees immediately to avoid collections and additional charges. See the attachment for additional information. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Verify site operation status, equipment replacement status, and aggregate fee status. Required PPE includes steel-toe boots, safety glasses, reflective vest, hard hat. NSR RECOMMENDATION: Wasatch Minerals plans to replace equipment. ATTACHMENTS: Applicable Supporting Documentation Included