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Home My WebLink AboutDAQ-2025-0007301 DAQC-091-25 Site ID 12670 (B1) MEMORANDUM TO: FILE – OLDCASTLE INFRASTRUCTURE, INC. – Concrete Pre-Cast Products & Pipe Manufacturing (OldCastle Precast) THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: January 15, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Weber County INSPECTION DATE: April 30, 2024 SOURCE LOCATION: 801 West 12th Street, Ogden, UT SOURCE CONTACTS: Dwight Allen, Safety Coordinator, 385-553-5400, Dwight.Allen@oldcastle.com Andrew Fillpot, Production Manager, 801-726-1620, Andrew.fillport@oldcastle.com OPERATING STATUS: In operation PROCESS DESCRIPTION: OldCastle Precast operates a concrete Batch Plant and produces concrete pipe, vaults, storm water culverts or other components used in municipal water, sewer and other projects. The maximum annual production through the pipe and precast central mix plants is 84,000 cubic yards of concrete. Washed sand and gravel arrive by truck. Raw materials are crushed, washed, screened, and sized before arriving at the OldCastle Precast property. From the storage piles, the raw materials are transferred to storage bins by either a conveyer belt or front end loader. Cement and Fly Ash arrive by truck, and are transferred pneumatically into storage silos. The silos are vented to a baghouse to control emissions while loading. All materials are transferred to a weigh hopper then to a mixer where water is added. From the mixer, the concrete is transferred by conveyer to the production building where it is poured into form compactors to cure until the forms are removed. The products are then transported by forklift to the storage and shipping areas. Baghouse dust collectors are used to control emissions from the mixing operations. Paved concrete operational areas and unpaved gravel-based haul roads are watered to minimize and to control dust. APPLICABLE REGULATION: Approval Order DAQE-AN0126700001-07, dated October 26, 2007 / : 2 SOURCE INSPECTION EVALUATION: General Conditions: 1. This AO applies to the following company: Facility Location: AMCOR Precast 801 West 12th Street P.O. Box 12730 Ogden, UT 84412-2730 Phone Number: (800) 776-8760 Fax Number: (801) 392-7849 The equipment listed below in this AO shall be operated at the following location: 801 West 12th Street, Ogden, Weber County Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27 4,566.2 kilometers Northing, 416.2 meters Easting, Zone 122. Status: In Compliance. The above information is correct. 2. Definitions of terms, abbreviations, and references used in this AO conform to those used in the UAC R307, and Series 40 of the Code of Federal Regulations (40 CFR). These definitions take precedence, unless specifically defined otherwise herein. Status: This is not a compliance issue. 3. The limits set forth in this AO shall not be exceeded without prior approval in accordance with R307-401. Status: In Compliance. OldCastle Precast did not exceed any limits set forth in this AO. 4. Any future modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be approved in accordance with R307-401. Status: In Compliance. There were no modifications to the equipment or processes observed during this inspection. 5. All records referenced in this AO, which are required to be kept by the owner/operator, shall be made available to the Executive Secretary or Executive Secretary’s representative upon request, and the records shall include the two-year period prior to the date of the request. All records shall be kept for a minimum period of two years. Status: In Compliance. OldCastle Precast maintains records for at least two years. 3 6. AMCOR precast shall operate the concrete plant according to the terms and conditions of this AO, which was written pursuant to AMCOR Precast’s NOI submitted to the Division of Air Quality (DAQ) on August 1, 2007. Status: In Compliance. OldCastle Precast maintains that they operate in accordance with the terms and conditions of the AO. 7. This AO shall replace DAQE-AN2670002-03, dated December 15, 2003. Status: In Compliance. This inspection was conducted in accordance with the conditions of the AO DAQE-AN0126700001-07, dated October 26, 2007. No other AO was necessary to determine compliance. 8. The approved installations shall consist of the following equipment or equivalent*: Pipe Plant A. Central Mix Concrete Batch Plant Maximum Design Rate: 22.5 tons/hour B. Mixer with Baghouse Capacity 2 yd3 C. Portland Cement Silo D. Fly Ash Silo E. Boiler Fuel type Natural gas Maximum rating 1.0 x 106 BTU/hr (MMBTU/hr) F. Steam Generator Maximum rating 3.4 MMBTU/hr G. Miscellaneous Equipment Weigh hoppers Conveyors Front-end loaders Precast Plant H. Central Mix Concrete Batch Plant Maximum Design Rate 22.5 tons/hour I. Mixer with Baghouse Capacity 4 yd3 J. Portland Cement Silo K. Fly Ash Silo L. Steam Generator Maximum rating 1.4 MMBTU/hr 4 M. Miscellaneous Equipment Weigh hoppers Conveyors Front-end loaders * Equivalency shall be determined by the Executive Secretary. Status: In Compliance. There was no new or unapproved equipment observed on site during this inspection. The Central Mix Concrete Batch Plant for the Precast Plant in AO Condition H is no longer on site. Limitations and Tests Procedures 9. Visible emissions from the following emission points shall not exceed the following values: A. All conveyor transfer points - 10% opacity B. Conveyor drop points - 20% opacity C. All baghouses – 10% 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. Status: In Compliance. There were no visible emissions observe from the conveyor transfer points, conveyor drop points, baghouses, and all other points during this inspection, to include the Mixer BH Stack pipe, the Flyash Silo BH Stack, and the MIXER BH Stack. The opacity observations were conducted in accordance with 40 CFR 60, Appendix A, Method 9. See the attachment for additional information. Emission point Opacity limit Opacity Observed Mixer BH Stack (pipe) 20% 0% Flyash Silo BH Stack 20% 0% Mixer BH Stack (precast) 20% 0% All of the opacity from the Mixer BH Stack (pipe), Flyash Silo BH Stack, and Mixer BH Stack (precast) has been superseded by 7% opacity limits for Concrete Batch Plants. See R307-312 for additional information. 10. Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed 20% opacity. Visible emissions determinations for traffic sources 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. Six points, distributed along the length of the haul road or in the operational area, shall be chosen by the Executive Secretary or the Executive Secretary’s representative. An opacity reading shall be made at each point when a vehicle passes the selected points. Opacity readings shall be made 1/2 the vehicle length or greater behind the vehicle and at approximately 1/2 the height of the vehicle or greater. The accumulated six readings shall be averaged for the compliance value. Status: In Compliance. There were no visible emissions observed from haul-road traffic and mobile equipment during this inspection. 11. The following production and/or consumption limits shall not be exceeded: 5 A. 200,000 tons of concrete produced per rolling 12-month period B. 2,340 hours of operation per 12-month rolling period on the pipe plant C. 2,340 hours of operation per 12-month rolling period on the precast plant Compliance with the limitations shall be determined on 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 consumption/production shall be kept for all periods when the plant is in operation. Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. Status: In Compliance. The concrete production and the hours of operation in a rolling 12-month total from May 2023 to April 2024 indicated the following: A. 118,898.96 tons of concrete produced per rolling 12-month period B. 2,016 hours of operation per 12-month rolling period on the pipe plant C. 2,016 hours of operation per 12-month rolling period on the precast plant See the attachment for additional information. 12. All process streams from the silos and mixers shall be controlled by a baghouse. All exhaust air from the silos and mixers shall be routed through the baghouse before being vented to the atmosphere. Status: In Compliance. During this inspection, all process streams from the silos and mixers were controlled by a baghouse, and all exhaust air from the silos and mixers was routed through the baghouse before being vented to the atmosphere. 13. The owner/operator shall use only natural gas as a primary fuel in the boiler and steam generators. Status: In Compliance. OldCastle Precast confirmed that only natural gas is used for fuel in the boiler and steam generator. 14. 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 Executive Secretary 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, and the records shall be maintained for a period of two years. Status: In Compliance. OldCastle Precast maintains records for at least two years, and also maintains records of maintenance activities performed on approved equipment. OldCastle appears to be operating and maintaining equipment in a manner consistent with good air pollution control practices. 15. The owner/operator shall comply with UAC, R307-150 Series. Inventories, Testing and Monitoring. Status: Not Applicable. OldCastle Precast is not required to submit an Emissions Inventory Report at this time. 6 16. The owner/operator shall comply with R307-107, UAC if applicable. General Requirements: Unavoidable Breakdowns. Status: In Compliance. According to OldCastle Precast, there were no unavoidable breakdowns resulting in an emissions event. AREA SOURCE RULES EVALUATION R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust. Status: In Compliance. There were no visible fugitive emissions observed during this inspection. The operational areas are paved with concrete. The unpaved haul roads have a gravel base and are watered as needed. The water truck is used to water unpaved haul roads to control fugitive dust. Aggregate is prewashed prior to use, and the conveyors are covered. See the attachment for additional information. R307-312: Aggregate Processing Operations for PM2.5 Nonattainment Areas Status: In Compliance. The mixer is equipped with a baghouse which controls particulate emissions. There were no visible emissions observed from the Mixer BH Stack (pipe), Flyash Silo BH Stack, and Mixer BH Stack (precast) of the Concrete Batch Plant during this inspection. See the attachment for additional information. EMISSION INVENTORY: Status: Not Applicable. OldCastle Precast is not required to submit an Emissions Inventory Report at this time. Below are the PTEs of Approval Order (AO) DAQE-AN0126700001-07, dated October 26, 2007: Pollutant Tons/yr A. PM10 ............... 8.00 B. NOx ................ 1.48 C. CO .................. 1.24 D. SO2 ................ 0.02 E. VOC…………0.04 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: OldCastle Precast is in compliance with the conditions in Approval Order (AO) DAQE-AN0126700001-07, dated October 26, 2007. OldCastle Precast maintains good housekeeping practices. RECOMMENDATION FOR NEXT INSPECTOR: Inspect as usual. Required PPE includes hard hat, steel toe boots, reflective vest, and safety glasses. 7 RECOMMENDATION FOR NSR: The Central Mix Concrete Batch Plant for the Precast Plant in AO Condition H is no longer on site. Please update the opacity limits in AO Condition 9 to those found in R307-312. ATTACHMENTS: Visible Emissions Observations Form, Email Communication, Photos, Rolling 12-month Concrete Production