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HomeMy WebLinkAboutDAQ-2024-0110061 DAQC-CI130390001-24 Site ID 13039 (B1) MEMORANDUM TO: FILE – GENEVA ROCK PRODUCTS – Bauer Pit THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: September 3, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Tooele County INSPECTION DATE: June 13, 2024 SOURCE LOCATION: 2830 South Bauer Road Stockton, UT 84071 DIRECTIONS: From Tooele, head south and turn right onto Bauer Road from SR36. Continue on Bauer Road past the waste management facility. The site is about 1 mile to the west past the Rulon Harper Construction pit on the left side of the road. SOURCE CONTACTS: Dave Putnick, Foreman 801-367-0787 Grant Ensign, Environmental Specialist 801-802-6954 gensign@clydeinc.com OPERATING STATUS: Wash plant was operating, the crushing circuit was down. PROCESS DESCRIPTION: The wash plant washes aggregate from storage piles. The crushing circuit contains both screening and crushing equipment. Washed aggregate and sand are stored on site to provide material for the Tooele batch plant. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN130390005-22, dated March 16, 2022 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, 0 0 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Geneva Rock Products - Bauer Pit 730 N 1500 West 2830 South Bauer Road Orem, UT 84057 Stockton, UT 84071 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 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: In Compliance. No limits appear to have been exceeded. No modifications have been made to equipment or process. Records are maintained for the required time. No reportable breakdowns have occurred since the previous inspection. A 2023 emission inventory was submitted to DAQ. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Bauer Pit II.A.2 One (1) Concrete Batch Plant Capacity: 12 cubic yards 200 cubic yards/hour Flyash Silo: with binvent Cement Silo: with binvent II.A.3 Three (3) Crushers Capacity: 300 tons/hour each II.A.4 Four (4) Screens Capacity: 400 tons/hour each II.A.5 Miscellaneous Aggregate Processing Equipment Grizzlies, Feeders, Splitters, Traps, Load Bins, Conveyors, Screws, Cyclones, Clarifiers, and Stackers II.A.6 Two (2) Diesel Generators Capacity: 600 hp each II.A.7 Various Storage Tanks Contents: Fuel Oil and Diesel II.A.8 One (1) Diesel Fired Hot Water Heater - listed for informational purposes only - II.A.9 Various Off Highway Vehicles - listed for informational purposes only - front-end loaders, bulldozers, scrapers, draglines, track-hoes, haul trucks, water trucks, sweeper truck, forklift trucks, boom trucks, etc. II.A.10 Miscellaneous Equipment - listed for informational purposes only - welders, pumps, motors, pressure washers, parts washers, and other equipment associated with construction materials processing, manufacture, and maintenance. Status: In Compliance. The equipment observed on site was consistent with that listed except for the absence of the concrete batch plant which was removed from the site many years ago with no plans of bringing it back. II.B Requirements and Limitations II.B.1 The Bauer Pit shall be subject to the following II.B.1.a The owner/operator shall not produce more than: A. 100,000 cubic yards of concrete per rolling 12-month period B. 350,000 tons of processed aggregate material per rolling 12-month period. [R307-401-8] 4 II.B.1.a.1 The owner/operator shall: A. Determine production by scale house records or vendor receipts B. Record production on a daily basis C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation. [R307-401-8] Status: In Compliance. The source produced the following amounts during the corresponding 12-month period: 0 cubic yards of concrete. 129,920 tons of processed aggregate. II.B.1.b The owner/operator shall not consume more than 76,800 gallons of diesel fuel (fuel oil) by stationary generators per rolling 12-month period. [R307-401-8] II.B.1.b.1 The owner/operator shall: A. Determine fuel consumption by purchase records or other documented proof of fuel usage B. Record consumption on a daily basis C. Use the fuel consumption data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the consumption records for all periods the plant is in operation. [R307-401-8] Status: In Compliance. The source consumed 28,120.5 gallons of diesel fuel during the 12-month period. II.B.1.c The owner/operator shall not transfer more than 300,000 gallons of diesel fuel through the diesel fuel storage tanks per rolling 12-month period. [R307-401-8] II.B.1.c.1 The owner/operator shall: A. Determine fuel consumption by purchase records or other documented proof of fuel usage B. Record consumption on a daily basis C. Use the fuel consumption data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the consumption records for all periods the plant is in operation. [R307-401-8] Status: In Compliance. The source transferred 53,443.8 gallons of diesel fuel through the storage tanks during the 12-month period. 5 II.B.1.d Unless otherwise specified in this AO, visible emissions from the following emission points shall not exceed the following values: A. All crushers - 12% opacity B. All screens - 7% opacity C. All conveyor transfer points - 7% opacity D. All baghouse and binvent emission points - 10% opacity E. All diesel engines - 20% opacity F. Conveyor drop points - 20% opacity G. All other points - 20% opacity. [R307-312-4, R307-401-8] II.B.1.d.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. [R307-401-8] Status: In Compliance. The crushing circuit was not operating. The wash plant had no visible emissions and haul traffic emissions were within limits. II.B.1.e The concrete batch plant silos shall be pneumatically loaded with cement or fly ash. The displaced air from the silos and mixers generated during filling shall be passed through a binvent before being vented to the atmosphere. [R307-401-8] Status: Not Applicable. The concrete batch plant has been removed from the site. II.B.1.f The owner/operator shall use #1, #2 or a combination of #1 and #2 diesel fuel in the on-site equipment. [R307-401-8] Status: In Compliance. Fuel is used as outlined. II.B.2 All Haul Roads & Fugitive Dust Sources shall be subject to the following II.B.2.a The owner/operator shall not allow visible emissions from paved haul roads and fugitive dust sources to exceed 20% opacity on site and 10% opacity at the property boundary. [R307-309-5] II.B.2.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. [R307-309-5] Status: In Compliance. Visible emissions were within limits. II.B.2.b The owner/operator shall comply with a fugitive dust control plan acceptable to the Director for control of all dust sources associated with the Bauer Pit. Geneva Rock Products shall comply with the most current fugitive dust control plan approved by the Director. [R307-401] Status: In Compliance. The source submitted a FDCP June 2, 2022. Visible emissions were within limits at the time of the site visit. 6 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. Previous inspection memos state that initial observations were conducted. Water spray inspections are conducted and records are kept. MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. Generators operate on ultra-low sulfur diesel fuel and regular maintenance is conducted. All engines have had oil changes within the last 12 months. The source is required to stack test to show that CO emissions are either 23 ppmvd at the outlet or have a 70% reduction between the inlet and outlet. The last stack test performed prior to the inspection was conducted in 2021 (DAQC-1525-21) which indicated a 99.6% reduction of CO between the inlet and the outlet and an outlet emission rate of 0.51 ppm. The source had a stack tested planned for a date later than the site visit for August 27, 2024 (DAQC-685-24), the results were submitted to DAQ, and resulted in a 99.6% reduction with an outlet CO emission rate of 2.1 ppm (DAQC-952-24). 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. All diesel fuel used on site is ultra-low sulfur. Standards of Performance for New Stationary Sources [R307-210] Status: In Compliance. See condition OOO above. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. See condition ZZZZ above. Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. All observed visible emissions were within limits. Aggregate Processing Operations for PM2.5 Nonattainment Areas [R307-312] Status: Not Observed. The crushing circuit was down during the site visit. 7 EMISSION INVENTORY: Listed below are the Actual Emissions Inventory provided from Geneva Rock Products- Bauer Pit. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN130390005-22, dated March 16, 2022, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr Carbon Monoxide 3.98 3.918 Nitrogen Oxides 15.11 14.818 Particulate Matter - PM10 5.91 1.956 Sulfur Dioxide 1.40 0.571 Volatile Organic Compounds 1.60 1.158 PREVIOUS ENFORCEMENT ACTIONS: None in the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN130390005-22, dated March 16, 2022, the overall status is: In Compliance. The facility appeared to be adequately maintained and operated properly. Records were provided by email post site visit. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. NSR RECOMMENDATIONS: Determine if the source wants to keep the concrete batch plant on the AO or if it should be removed. ATTACHMENTS: VEO Form, Records, Email. Jared James <jsjames@utah.gov> Air Quality Inspection - Bauer Pit 3 messages Jared James <jsjames@utah.gov>Tue, Jun 18, 2024 at 9:19 AM To: Grant Ensign <gensign@clydeinc.com> Hi Grant I conducted an inspection at the Bauer Pit on 6/13. Everything looked good during the inspection, I just need to get some records from you to finish up. Here are the records I need: - Produced aggregate tons (June '23 - May '24) - Diesel fuel gallons consumed (June '23 - May '24) - Diesel fuel throughput (June '23 - May '24) - Water spray bar/nozzle inspections (June '23 - May '24) - Date of the last oil change on the generators. If you would get those to me in the next week I would appreciate it. Thanks! -- Jared James | Environmental Scientist | Minor Source Compliance Phone:385-306-6501 email: jsjames@utah.gov 195 North 1950 West, Salt Lake City, UT 84116 Grant Ensign <gensign@clydeinc.com>Mon, Jun 24, 2024 at 12:59 PM To: Jared James <jsjames@utah.gov> Hi Jared, Please see the informaon below from your request. Please let me know if you have any quesons. Thanks. - Produced aggregate tons (June '23 - May '24) 12-month rolling total is 129,920 tons. 9/3/24, 4:17 PM State of Utah Mail - Air Quality Inspection - Bauer Pit https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-a:r-1090129906839340934&simpl=msg-a:r-17906885676221…1/3 - Diesel fuel gallons consumed (June '23 - May '24) 53,443.8 gallons (300,000 gallons is limit) - Diesel fuel throughput (June '23 - May '24) 28,120.5 gallons (76,500 gallon is limit) - Water spray bar/nozzle inspecons (June '23 - May '24) Plant was down for winter which accounts for missing months. 9/3/24, 4:17 PM State of Utah Mail - Air Quality Inspection - Bauer Pit https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-a:r-1090129906839340934&simpl=msg-a:r-17906885676221…2/3 - Date of the last oil change on the generators. 62-2180. 5/3/202462-2185. 3/27/2462-2186. 11/29/2023 Grant Ensign ENVIRONMENTAL SPECIALIST O (801) 802-6954  C (801) 633-7830 WWW.CLYDEINC.COM From: Jared James <jsjames@utah.gov> Sent: Tuesday, June 18, 2024 9:19 AM To: Grant Ensign <gensign@clydeinc.com> Subject: Air Quality Inspecon - Bauer Pit [Quoted text hidden] 560-FUELREPORT14051-14052.pdf 150K Jared James <jsjames@utah.gov>Tue, Jun 25, 2024 at 9:40 AM To: Grant Ensign <gensign@clydeinc.com> This is great, thank you! [Quoted text hidden] 9/3/24, 4:17 PM State of Utah Mail - Air Quality Inspection - Bauer Pit https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-a:r-1090129906839340934&simpl=msg-a:r-17906885676221…3/3