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HomeMy WebLinkAboutDAQ-2024-0112001 DAQC-CI105650001-24 Site ID 10565 (B1) MEMORANDUM TO: FILE – GENEVA ROCK PRODUCTS – Point of the Mountain (Hansen-Lehi) Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Connor Kijowski, Environmental Scientist DATE: September 26, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: July 3, 2024 SOURCE LOCATION: 15547 South Minuteman Drive Draper, UT 84020 DIRECTIONS: Check in at main office building near the entrance. SOURCE CONTACTS: Grant Ensign, Environmental Manager (801) 802-6954; gensign@clydeinc.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Aggregate mining, crushing, and screening facilities: Aggregate is taken from the bank via FEL and is screened, crushed, and washed along the lines. The processed aggregate is stored in piles at the pit. Water sprays control emissions. The product is either used on site in the concrete or asphalt plants or is transferred off site by haul trucks as straight sales. The L4 plant has a feeder and belt going to two crushers, dry screens, wet screens, and a log washer (to remove clay from ¾ rock). The L8 plant has several overland belts going to a splitter then to a 3-deck screen and 1-deck screens. The screens feed oversize material to a 54-inch cone and the sized material to separate piles to include various sizes of rock (3/4 - 7/16, 7/16 - 3/16, and 3/16 minus). The rock oversize goes to a VSI and back to the beginning of the circuit. Road base can be produced from either of the two screens if rock sizes are not needed. L11 is a small plant that is based in the eastern edge of the pit. It consists of a grizzly, conveyors, and one screen. This area has a large content of clay in the material, and stays moist without much added water. 2 Concrete plant: The plant is fully enclosed in a building (including the conveyor to and from the batching/mixing process). The cement and aggregate are apportioned and blended and transferred to a mix truck. Water is measured and added to the mixture in the truck. The contents are then transported to the various construction sites. Emissions from the three cement powder and one fly ash silo are controlled by baghouses during charging. The silos have overfill vents that vent to the outside of the building. The pug mill and conveyor are controlled by a baghouse that vents out the side of the building. There is a portable fly ash tank on-site. Asphalt plant: The asphalt plant is permitted to operate on used fuel oil. The material for the asphalt mix is processed on site. The aggregate is loaded from storage piles by FEL to feed bins and transferred in metered amounts to a mixing drum. The asphalt oil is stored in heated tanks and a measured amount is pumped into the asphalt drum and mixed with the aggregate to specification. The final product is conveyed to a heated storage silo and gravity fed to trucks in the load out area. Emissions from the mixing drum are controlled by a baghouse. The plant can process recycled asphalt and has a lime slurry pug mill. There is a new storage area for the winter mix. Fugitive dust and emissions are controlled with water sprays and a water truck. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN105650021-23, dated October 25, 2023 NSPS (Part 60) OOO: Standards of Performance for Nonmetallic Mineral Processing Plants, NSPS (Part 60) I: Standards of Performance for Hot Mix Asphalt Facilities, NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, MACT (Part 63) JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources, MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities 3 SOURCE EVALUATION: Name of Permittee: Permitted Location: Geneva Rock Products- Point of the Mountain (Hansen-Lehi) Facility 730 N 1500 West 15547 South Minuteman Drive Orem, UT 84057 Draper, UT 84020 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] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] Status: In Compliance. Each condition from Section I was reviewed with the source and appeared to be in compliance. The 2023 Emission Inventory was submitted by the required date. 4 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Point of the Mountain, Hansen-Lehi, Plant II.A.2 Crusher 1 Rated Capacity: 385 tph II.A.3 Crusher 2 Rated Capacity: 335 tph II.A.4 Crusher 3 Rated Capacity: 400 tph II.A.5 Crusher 4 Rated Capacity: 380 tph II.A.6 Crusher 5 Rated Capacity: 275 tph II.A.7 Crusher 6 Rated Capacity: 620 tph II.A.8 Crusher 7 Rated Capacity: 250 tph II.A.9 Portable Oversized Crusher Rated Capacity: 400 tph II.A.10 Screen 1 Rated Capacity: 750 tph II.A.11 Screen 2 Rated Capacity: 750 tph II.A.12 Screen 3 Rated Capacity: 750 tph II.A.13 Screen 4 Rated Capacity: 660 tph II.A.14 Screen 5 Rated Capacity: 275 tph II.A.15 Screen 6 Rated Capacity: 920 tph II.A.16 Screen 7 Rated Capacity: 920 tph II.A.17 Screen 8 Rated Capacity: 920 tph II.A.18 Screen 9 Rated Capacity: 550 tph II.A.19 Screen 10 Rated Capacity: 550 tph 5 II.A.20 Screen 11 Rated Capacity: 400 tph II.A.21 Screen 12 Rated Capacity: 400 tph II.A.22 Screen 13 Rated Capacity: 400 tph II.A.23 Generator Engine 1 Fuel Type: Diesel Rating: 817 hp II.A.24 Generator Engine 2 Fuel Type: Diesel Rating: 665 hp II.A.25 Generator Engine 3 Fuel Type: Diesel Rating: 120 hp II.A.26 Generator Engine 4 Fuel Type: Diesel Rating: 65 hp II.A.27 Generator Engine 5 Fuel Type: Diesel Rating: 65 hp II.A.28 Generator Engine 6 Fuel Type: Diesel Rating: 400 hp II.A.29 One (1) Hot Mix Asphalt Plant Rated Capacity: 500 tph Control: Baghouse (110,000 acfm) II.A.30 One (1) Drum Mixer Fuel Type: Natural Gas, Liquid Propane, #2 thru #6 Fuel Oil, & Used Oil II.A.31 Two (2) Scalping Screens Rated Capacity: 550 tph each II.A.32 Hot Oil Heater 1 Rating: 7.5 MMBtu/hr Fuel: Natural Gas Control: Flue Gas Recirculation II.A.33 Various Hot Oil Heaters Rated Capacity: Less than 5 MMBtu/hr Fuel: Natural Gas Informational purposes only II.A.34 One (1) Central Mix Concrete Batch Plant Unit ID - CCBP Rated Capacity: 280 cubic yards/hr Control Device: Baghouse 6 II.A.35 One (1) Portable Truck Mix Concrete Batch Plant Unit ID - PCBP Rated Capacity: 220 cubic yards/hr Control Device: Bin-vent II.A.36 One (1) Hot Water Heater/Boiler Unit ID - WHB-CCBP Fuel: Natural Gas/Propane Rating: 9.9 MMBtu/hr II.A.37 One (1) Hot Water Heater/Boiler Unit ID - WHB-PCBP Fuel: Diesel Rating: 2.9 MMBtu/hr II.A.38 Part Washers Solvent-based part washers II.A.39 Miscellaneous Processing Equipment Grizzlies, feeders, splitters, traps, load bins, cold feed bins, conveyors, wet screens, fine material washers, coarse material washers, screws, cyclones, clarifiers, stackers, drilling/blasting equipment, material storage silos and volatile organic liquid storage tanks. II.A.40 Miscellaneous Off Highway Vehicles For Informational Purposes Only Front-end loaders, bulldozers, scrapers, drag-lines, track-hoes, haul trucks, water trucks, sweeper truck, fork-lifts and boom trucks. Status: In Compliance. No unapproved equipment was observed at the time of inspection. Additional Information: II.A.23 – II.A.28: All the generator engines have been removed from the site. II.A.35: The Truck Mix Batch Plant has been off site for more than 12 months. II.B Requirements and Limitations II.B.1 The Hansen-Lehi Facility shall be subject to the following: II.B.1.a Visible emissions from the following emission points shall not exceed the following values: A. All conveyor transfer points - 7% opacity B. All diesel engines - 20% opacity C. All conveyor drop points - 15% opacity D. All concrete batch plants - 7% opacity E. All crushers- 10% opacity F. All screens- 7% opacity G. All baghouses and bin vent exhaust points- 10% opacity H. All other source on site- 20% opacity on site and 10% opacity at property boundary. [40 CFR 60 Subpart OOO, R307-305-3, R307-309-5, R307-312-4, R307-401-8] 7 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. [R307-305] Status: In Compliance. Visible emissions from any of the listed emission points did not exceed the limits set forth in this condition. The hot mix asphalt plant bin vent averaged 6.25% opacity according to EPA Method 9. Refer to the VEO Form in the attachments for more details. II.B.1.b The owner/operator shall equip each lime, cement, and flash storage silos with a fabric filter to control particulate emissions. [R307-401-8] Status: In Compliance. Each storage silo is equipped with a fabric filter to control particulate emissions. II.B.1.c The owner/operator shall not exceed the following throughput limits: A. 1,834,500 gallons of diesel fuel throughput for the diesel fuel storage tanks per rolling 12-month period. B. 1,600,000 gallons of waste or burner fuel oil throughput for the storage tanks per rolling 12-month period. [R307-401-8] II.B.1.c.1 The owner/operator shall: A. Determine consumption by vendor receipts, fuel delivery/usage records, and/or any other appropriate mechanism B. Record consumption on a daily basis. C. Use the consumption data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. [R307-401-8] Status: In Compliance. The source calculates throughput according to this condition. These records were viewed during the inspection. The source utilizes an online tracking system through QR codes to submit all records which is then reviewed by the environmental team. This process was reviewed with the source during the inspection. The rolling 12-month totals from July 2023 - June 2024, were as follows: A) 716,021 gallons of diesel throughput B) 0 gallons of waste or burner fuel oil II.B.2 The Aggregate Plants on site shall be subject to the following II.B.2.a The owner/operator shall not produce more than 14,000,000 tons of aggregate material (including bank run material) per rolling 12-month period and no more than 10,275,000 tons of aggregate shall be passed through a crushing or screening unit prior to product usage or delivery per rolling 12-month period. [R307-401] 8 II.B.2.a.1 The owner/operator shall: A. Determine production using production scales, scale house records, and/or any other appropriate mechanism. 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. [R307-401] Status: In Compliance. Production totals are calculated according to this condition. This was reviewed with the source during the inspection. The rolling 12-month totals are as follows: A) 8,023,896 tons of aggregate material including bank run material. B) 8,023,896 tons of aggregate material were passed through the crushers and screens. II.B.2.b The owner/operator shall install water sprays or chemical dust suppression sprays on all crusher inlet and outlet points onsite, on all screens onsite, on all conveyor transfer points and stake drop points on site, and on all dry screens on site to control fugitive emissions. Sprays shall operate whenever conditions warrant, as outline the FDCP, or to meet the opacity requirements of this AO. [40 CFR 60 Subpart OOO, R307-401-8] Status: In Compliance. Water sprays are equipped on all points required by this condition and operate as needed to ensure the opacity requirements of the AO are met. Monthly spray inspections are conducted in accordance with 40 CFR 60 Subpart OOO. II.B.3 The Asphalt Plant on site shall be subject to the following II.B.3.a The owner operator shall not produce more than the following: A. 500 tons of asphalt per hour (virgin and recycled asphalt pavement (RAP) averaged over each operating day). B. 800,000 tons of asphalt (virgin and RAP combined) per rolling 12-month period. [R307-401-8] Status: In Compliance. The totals are as follows: A) The plant averaged around 250 tons of asphalt per hour. Records review of the previous 12 months showed no instances exceeding 500 tons per hour B) 521,369 tons of asphalt were produced for the rolling 12-month period II.B.3.b The owner/operator shall: A. Determine production by production scales, scale house records, vendor receipts and/or any other appropriate mechanism. B. Record production on a daily basis. C. Calculate a new hourly average based on the previous day's production averaged over each operating day (12 a.m. to 12 a.m.) D. 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. [R307-401] Status: In Compliance. Calculations were reviewed during the site visit and are according to this condition. 9 II.B.3.c The owner/operator shall not consume more than 44,000 tons of asphalt cement per rolling 12-month period. [R307-401-8] II.B.3.c.1 The owner/operator shall: A. Determine consumption by vendor receipts, and/or another appropriate mechanism. B. Records on consumption shall be kept on a daily basis. C. Use the consumption data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. [R307-401-8] Status: In Compliance. Totals are calculated according to this condition. This was reviewed with the source during the inspection. The rolling 12-month asphaltic cement consumption total was 9,646 tons. II.B.3.d The sulfur content of any fuel oil or used oil fuel burned in the Hot Mix Asphalt Plant burner shall not exceed 0.5 percent by weight. [R307-401-14] II.B.3.d.1 The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent. Certification of fuel oil shall be either by the owner/operator's testing or by test reports from the fuel oil marketer. Certification of other fuels shall be either by owner/operator's testing or by test reports from the fuel marketer. [R307-401-8] Status: Not Applicable. The source has not consumed any fuel oil or used fuel oil in the last 12 months. II.B.3.e The owner/operator shall use natural gas, propane, fuel oil, on-specification used oil as defined in R315-15, or any combination thereof as fuel in the hot mix asphalt plant. [R307-401-14] Status: In Compliance. The source stated that only natural gas is used at this time. II.B.3.f The asphalt plant baghouse stack height shall be a minimum of 65 feet, as measured from the ground level. [R307-401-8] Status: In Compliance. The asphalt plant baghouse stack height appeared to be at least 65 feet from the ground. II.B.3.g The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s): Asphalt Plant Baghouse Pollutant lb/hr grains/dscf PM10 10.6 0.024. [R307-401-8] Status: In Compliance. The stack test conducted on September 2, 2021, showed an average PM10 emissions of 0.597 lb/hr and 0.0018 grains/dscf from the asphalt plant baghouse. See DAQC-1355-21 in the source file for full stack testing results. Stack testing was recently performed September 10, 2024, but the results have not been submitted for review. The stack pre-test protocol was submitted to the DAQ and found to be acceptable (DAQC-819-24). II.B.3.g.1 Compliance Demonstration To demonstrate compliance with the emissions limitations above, the owner/operator shall perform stack testing on the Asphalt Plant Baghouse according to the stack testing conditions contained in this permit. [R307-165-2] 10 II.B.3.g.2 Test Frequency The owner/operator shall conduct a stack test on the emission unit within three years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] II.B.3.g.3 Initial Testing The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. Initial testing has already been performed for the Asphalt Plant Baghouse. [R307-165-2] Status: In Compliance. Stack testing conducted on September 2, 2021, demonstrated compliance with all stack testing requirements listed in these conditions. See DAQC-1355-21 in the source file for full stack testing results. Stack testing was recently performed September 10, 2024, but the results have not been submitted for review. The stack pre-test protocol was submitted to the DAQ and found to be acceptable (DAQC-819-24). II.B.4 Stack Testing Requirement II.B.4.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.4.a.1 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.4.a.2 Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.4.a.3 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] II.B.4.a.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.4.a.5 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8] II.B.4.b Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8] II.B.4.b.1 Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] 11 II.B.4.b.2 PM10 Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. Condensable PM 40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to the Director. The condensable particulate emissions shall not be used for compliance demonstration but shall be used for inventory purposes. [R307-401-8] Status: In Compliance. Stack testing conducted on September 2, 2021, demonstrated compliance with all stack testing requirements listed in these conditions. See DAQC-1355-21 in the source file for full stack testing results. Stack testing was recently performed September 10, 2024, but the results have not been submitted for review. The stack pre-test protocol was submitted to the DAQ and found to be acceptable (DAQC-819-24). II.B.5 Baghouse Requirement II.B.5.a The owner/operator shall control emissions from the following sources using a baghouse fabric filter, for each source: A. Asphalt Plant B. Central Mix Plant. [R307-401-8] Status: In Compliance. A baghouse fabric filter is used to control emissions at each source. II.B.5.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across each baghouse. [R307-401-8] II.B.5.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.5.b.2 The pressure gauge shall measure the static pressure differential in 0.5-inch water column increments or less. [R307-401-8] Status: In Compliance. The source has installed pressure gauges that can be safely read at both baghouses. Static pressure differentials are measured in 0.1 inch increments. II.B.5.c During operation of the baghouse, the owner/operator shall maintain the static pressure differential across the baghouse between 2 and 6 inches of water column. [R307-401-8] II.B.5.c.1 The owner/operator shall record the static pressure differential at least once per operating day while the baghouse is operating. [R307-401-8] 12 II.B.5.c.2 The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Daily static pressure differential readings; C. Date of reading. [R307-401-8] Status: In Compliance. The Asphalt Plant baghouse gauge averaged 2.5 inches of water column for the previous 12 months and read 2.4 inches at the time of the inspection. The Central Mix Plant baghouse gauge averaged 3.5 inches of water column for the previous 12 months and read 3.5 inches at the time of the inspection. II.B.5.d At least once every 12 months, the owner/operator shall calibrate the pressure gauge in accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8] II.B.5.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] Status: In Compliance. The Asphalt Plant baghouse gauge was calibrated July 2, 2024. The Central Mix Plant baghouse gauge was calibrated August 9, 2023, with plans for recalibration August 2024. II.B.6 The Central Mix and Truck Concrete Plant on site shall be subject to the following II.B.6.a The central mix concrete batch plant and truck concrete batch plant shall not produce more than 400,000 cubic yards of concrete combined per rolling 12-month period. [R307-401-8] II.B.6.a.1 The owner/operator shall: A. Determine production by production scales, scale house records, vendor receipts, and/or any other appropriate mechanism. 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. [R307-401-8] Status: In Compliance. Production totals are calculated according to this condition. This was reviewed with the source during the inspection. The rolling 12-month totals are as follows: A) 227,940 cubic yards for the Central Mix Plant B) 0 cubic yards for the Truck Mix Batch Plant II.B.6.b The truck mix batch plant shall use a hood covering the truck inlet when loading the concrete trucks. The hood exhaust shall pass through a bin-vent prior to being vented to the atmosphere. [R307-401-8] Status: Not Applicable. The Truck Mix Batch Plant has not operated on site for the last 12 months. II.B.7 All Stationary Engines on site shall be subject to the following: II.B.7.a Plant wide NOx emissions from the stationary diesel-fired generator engines shall not exceed 27.32 tons per rolling 12-month period. [R307-305] 13 II.B.7.a.1 The owner/operator shall: A. Determine generator operating hours using hour meters installed on the equipment or other appropriate method established by the owner/operator. B. Record usage on a monthly basis. C. Use the usage data to calculate the following: The amount of NOx emitted monthly, in tons, by all diesel generators shall be calculated by the following procedure: Diesel-Fired Generator Engines rating < 600 horsepower (hp) NOx = (0.031 lb/hp hr) x [Gen Rating (hp)] x (Operating hours) x (1 ton/2000lb) Diesel-Fired Generator Engines rating > 600 hp NOx = (0.024 lb/hp hr) x [Gen Rating (hp)] x (Operating hours) x (1 ton/2000lb). [R307-401] Status: Not Applicable. The stationary diesel-fired generator engines are no longer on site. II.B.7.b The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 60 Subpart ZZZZ, R307-401-8] II.B.7.b.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-203-1, R307-401-8] Status: In Compliance. The source only uses ULSD. This was determined by a fuel purchase invoice provided by the supplier. This invoice was viewed during the inspection. II.B.8 The Hot Oil Heaters and Hot Water Heaters on site shall be subject to the following II.B.8.a The owner/operator shall not exceed the following operational limits for the designated hot water heaters on site: A. 1,500 hours of operation for the 9.9 MMBTU/hr natural gas (or liquid propane) fired hot water heater per rolling 12-month period. B. 500 hours of operation for the 2.9 MMBTU/hr diesel-fired hot water heater per rolling 12-month period. [R307-401-8] II.B.8.a.1 The owner/operator shall: A. Determine hours of operation by supervisor monitoring and maintaining an operation log. B. Record hours of operation each day. C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of each month using the data from the previous 12 months. [R307-401] Status: In Compliance. Totals are calculated according to this condition. This was reviewed with the source during the inspection. The rolling 12-month totals are as follows: A) 427 hours of operation for the 9.9 MMBtu/hr water heater B) 0 hours for the 2.9 MMBtu/hr water heater 14 II.B.8.b The owner/operator shall install and operate Hot Oil Heater 1 with a certification from the manufacturer that NOx emissions will meet a concentration of 30 ppm or less. [R307-401-8] II.B.8.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration. The record shall be kept for the life of the equipment. [R307-401-8] Status: In Compliance. A recent certification from July 26, 2024, showed NOx emissions at 22 ppm. This was provided after the inspection via email and can be viewed in the attachments. The certification is logged in the source electronic database and can be viewed at any time. II.B.9 All Haul Roads and Fugitive Dust Sources on site shall be subject to the following II.B.9.a The owner/operator shall comply with a fugitive dust control plan acceptable to the Director for control of all dust sources associated with the Hansen-Lehi Plant. [R307-309-6] Status: In Compliance. The source operates with a FDCP last updated August 7, 2020. II.B.9.b The owner/operator shall not allow visible emissions from haul roads, mobile equipment in operational areas, and fugitive dust sources to exceed 20 % opacity on site and 10% opacity at the property boundary. [R307-309-5] Status: In Compliance. Minimal fugitive dust was observed at the time of inspection. The haul roads were wet upon arrival and water trucks were actively spraying during the inspection. II.B.9.c Visible emission determinations for fugitive dust from haul roads and 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 one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-205-4, R307-309-5, R307-401-8] Status: In Compliance. Minimal fugitive dust was observed according to this condition. II.B.9.d The hours of operation for all bulldozers at the facility shall not exceed 24,000 hours of operation combined per rolling 12-month period. [R307-401] II.B.9.d.1 The owner/operator shall: A. Determine hours of operation by hour meters installed on the equipment or other appropriate method as established by owner/operator. B. Record hours of operation each day. C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of each month using the data from the previous 12 months. [R307-401] Status: In Compliance. Totals are calculated according to this condition. This was reviewed with the source during the inspection. The rolling 12-month bulldozer hours were 12,207. II.B.9.e The owner/operator shall address the control of surfaces subject to wind erosion within the FDCP. [R307-401] Status: In Compliance. The current FDCP states: "Disturbed land - long term stabilization and erosion control of large tracts of disturbed land that will not have continuing activity for more than 30 days.". 15 II.B.9.f The owner/operator shall use a shroud to control fugitive emissions associated with all air compression drilling operations. [R307-401] Status: Not Applicable. The source indicated that drilling has not occurred in at least five years. II.B.9.g The owner/operator shall use water application or other control options contained in R307-309 to minimize emissions from fugitive dust and fugitive emissions sources, including haul roads, storage piles, and disturbed areas. Controls shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-309, R307-401-8] II.B.9.g.1 Records of treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of treatment B. Number of treatments made, dilution ratio, and quantity C. Rainfall received, if any, and approximate amount D. Time of day treatments were made. [R307-401-8] Status: In Compliance. The source utilizes several water trucks to minimize fugitive dust as required by this condition. Storage piles are watered as needed and were wet at the time of inspection. Watering logs viewed during the inspection included the requirements of this condition. QR codes at the water storage tank are scanned to track the date, time, and number of treatments. 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. Compliance with this subpart is satisfied by Conditions II.B.1.a and II.B.2.b of the AO and by conducting periodic water spray inspections. Monthly spray bar inspections are conducted and the records were viewed during the inspection. Refer to these conditions for more details. NSPS (Part 60) I: Standards of Performance for Hot Mix Asphalt Facilities Status: In Compliance. Compliance with this subpart is satisfied by Conditions II.B.1.a – G., II.B.3.g, and II.B.4 of the AO. Refer to these conditions for more details. NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: Not Applicable. None of the stationary engines referenced in the AO operated at the source location during the last 12 months. 16 MACT (Part 63) JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources Status: Not Applicable. This subpart is applicable only to the diesel-fired hot water heater/boiler (II.A.37). This equipment did not operate at the source location during the last 12 months. MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: Not Applicable. None of the stationary engines referenced in the AO operated at the source location during the last 12 months. MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities Status: In Compliance. The source dispenses less than 10,000 gallons of gasoline per month and meets the requirements of this subpart by operating in accordance with the best practices outlined in section 61.11116. The source dispensed a total of 1,950 gallons of gasoline for the previous 12 months. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Stationary Sources [R307-210] Status: In Compliance. This area source rule is satisfied through compliance with NSPS Subpart OOO, Subpart I, and Subpart IIII. Refer to the Federal Requirements section for more details. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. This area source rule is satisfied through compliance with MACT Subpart ZZZZ, Subpart JJJJJ, and Subpart CCCCCC. Refer to the Federal Requirements section for more details. Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305] Status: In Compliance. Compliance with this area source rule is satisfied by AO condition II.B.1.a. Refer to this condition for more details. Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. Compliance with this area source rule is satisfied by compliance with AO condition II.B.1.a, Section II.B.9, and maintaining a Fugitive Dust Control Plan. Refer to these conditions for more details. Aggregate Processing Operations for PM2.5 Nonattainment Areas [R307-312] Status: In Compliance. Compliance with this area source rule is satisfied by compliance with AO condition II.B.1.a and II.B.3.g. Refer to these conditions for more details. 17 Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325] Status: In Compliance. This area source rule is applicable to the parts washers in use at the vehicle maintenance shop at the source location. VOC containing materials are stored in closed containers. Degreasing [R307-335] Status: In Compliance. R307-335-4 requires the lid to be closed except during actual loading, unloading, or handling of parts. The parts washer lids were closed, had instructions posted, and used solvent was stored in a tank beneath the washer. All equipment appeared to be in good operating condition and no leaks were observed. EMISSION INVENTORY: Listed below are the 2023 Actual Emissions Inventory provided from Geneva Rock Products - Point of the Mountain (Hansen-Lehi) Facility. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN105650021-23, dated October 25, 2023, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr Carbon Monoxide 113.17 N/A Nitrogen Oxides 64.94 4.272 Particulate Matter - PM10 128.83 110.92 Sulfur Dioxide 25.76 0.673 Volatile Organic Compounds 20.89 7.002 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Ethyl Benzene (CAS #100414) 200 630 Formaldehyde (CAS #50000) 2480 321 Generic HAPs (CAS #GHAPS) 3758 N/A Toluene (CAS #108883) 2320 287.2 Xylenes (Isomers And Mixture) (CAS #1330207) 160 775 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN105650021-23, dated October 25, 2023, the overall status is: In Compliance. The source appears to be well maintained and operated. Records were current and provided during the inspection and after via email. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. Steel-toed boots, safety glasses, high-visibility clothing, and a hard hat are required PPE. 18 NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: VEO Form, Email Correspondence STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY Page _of_ EPA METHOD 9 -VISIBLE EMISSION OBSERVATION FORM Source Name: <20D~ -?o,A-\-o + ¾., /Vbu/\~ j Q StreetAddress: 155l\, fum f\J,bvh\'1W\ Dc,vc..- City/County: br"?ec / S&1 /J--L.ef)~e__.. Phone: 8'0 \ -R:Q--Z.--futj 33, Site ID: 1Q6Ct:,5 Facility: A~~JJ:k.-: > {i-,ryt(& • A?t7a ft Equipment/Process: c:r-.JS\.t.,r~ \.k.1 krs: l Gi2~~h?r 60_pN£ Control Equipment: ~19 ll)c,:.eL, 1 \J.,)C1)Gr --------------------------- Sky Conditions: Clear ~ Partly Cloudy [ ] Overcast [ ] Precipitation: No fXJ Yes [ ] Wind: Direction: Al Speed: s-= mph Ambient Temp: 73\ oF RH: ~o % Height Relative to Observer: 75 Distance From Observer: 'L-1-CS- Condensed Water Vapor Present: No [)g Yes [ ] Attached [ ] Detached [ ] Length of Condensed Water Vapor Plume: Background: B>)v0 Sk~ Sketch process unit: indicate observer position relative to source; indicate potential emission points and/or actual emission points. 0 D, J\4 uonh u1 "'"' \ • observer ~ Sun ♦ Wind ► Emission Point with Plume ( ....... )'-__, Observer Position X Observer's Signature: Distrib: white-file; canary-inspector; -owner/operator OBSERVATION DATE: l /2 [ ZL.f Start time: \''2.-' I'-'\ Stop time: ~ l'Z,'-Z.0 ~ c mm 0 15 30 45 1 5 _c; s-s 2 lo le; s-s- 3 s-"\r) s s 4 s-:c; )0 /CJ 5 s /0 s s 6 5 s-s-JO 7 8 --l,y ,.z,s CJ/! ") .--'C 9 10 1 1 12 COMMENTS: A~'?½al-} 1'ot M,~ Plq,,t: tJen+-s l,,ou< a ccois-k-'1+ V )S1't-Je ero,~1i;11£ ever --->k_ (cur&>..._ a£ -He iMpechc-1. n-~ver<'IBtO~ '2-2-5/'lo o?!c•q ~UN()? k .~c~ - /vn ,;vk,_ ~ ohruv:; h'ei,1.. ~ Jt.,.i "?peocccz1 P \oe:., '-\I\ I\CCvrg~ re~NSeo k he,/\ 0£---ke.. opec,:ih'ol). I have received a copy of these observat;O-Il_!;: SIGNATURE: Title: Connor Kijowski <ckijowski@utah.gov> Geneva Rock: Point of Mountain 6 messages Grant Ensign <gensign@clydeinc.com>Wed, Jul 3, 2024 at 1:23 PM To: Connor Kijowski <ckijowski@utah.gov> Hey Connor, I was able to track down our 12-'month rolling total for concrete production. 227,940 CY Please let me know if you need anything else. Thanks. ————— Grant Ensign Clyde CompaniesENVIRONMENTAL SPECIALIST O (801) 802-6954C (801) 633-7830 WWW.CLYDEINC.COM Connor Kijowski <ckijowski@utah.gov>Wed, Jul 3, 2024 at 2:08 PMTo: Grant Ensign <gensign@clydeinc.com> Thanks, Grant. That was the last record I needed to obtain. Thanks again to you and Scott for your assistance today. I will reach out if I have any questions. Have a great holiday week! -Connor [Quoted text hidden] --Connor Kijowski Environmental Scientist | Minor Source Compliance M: (385) 245-6720 airquality.utah.gov Grant Ensign <gensign@clydeinc.com>Wed, Jul 3, 2024 at 3:17 PMTo: Connor Kijowski <ckijowski@utah.gov> Thanks! Great chang with you today. Grant Ensign ENVIRONMENTAL SPECIALIST O (801) 802-6954  C (801) 633-7830 WWW.CLYDEINC.COM From: Connor Kijowski <ckijowski@utah.gov> Sent: Wednesday, July 3, 2024 2:08 PM To: Grant Ensign <gensign@clydeinc.com> Subject: Re: Geneva Rock: Point of Mountain [Quoted text hidden] Connor Kijowski <ckijowski@utah.gov>Fri, Oct 11, 2024 at 11:58 AMTo: Grant Ensign <gensign@clydeinc.com> Good Morning Grant, My manager just requested one additional document to complete the inspection from July. Can you provide the most recent combustion test for the Hot Oil Heater to confirm it meets theNOx limit of 30ppm? This is in reference to Condition II.B.8.b of the Approval Order. Thanks, Connor [Quoted text hidden] Grant Ensign <gensign@clydeinc.com>Fri, Oct 11 To: Connor Kijowski <ckijowski@utah.gov> Hey Connor, 10/16/24, 10:07 AM State of Utah Mail - Geneva Rock: Point of Mountain https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1803587004567643495&simpl=msg-f:18035870045676434…1/2 No problem. The last test was completed on July 26, 2024 and NOx came in at 22 PPM. Grant Ensign ENVIRONMENTAL SPECIALIST O (801) 802-6954  C (801) 633-7830 WWW.CLYDEINC.COM From: Connor Kijowski <ckijowski@utah.gov> Sent: Friday, October 11, 2024 11:58 AM [Quoted text hidden] [Quoted text hidden] Connor Kijowski <ckijowski@utah.gov>Fri, Oct 11, 2024 at 12:01 PMTo: Grant Ensign <gensign@clydeinc.com> Thanks, Grant. I appreciate it. [Quoted text hidden] Outlook-Clyde Comp.png5K 10/16/24, 10:07 AM State of Utah Mail - Geneva Rock: Point of Mountain https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1803587004567643495&simpl=msg-f:18035870045676434…2/2