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HomeMy WebLinkAboutDAQ-2024-0071181 DAQC-CI115830001-24 Site ID 11583 (B1) MEMORANDUM TO: FILE – JACK B. PARSONS COMPANY – California Ready Mix Facility – Directors Row THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: February 20, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: November 30, 2023 SOURCE LOCATION: 3313 West 1100 South Salt Lake City, UT 84116 SOURCE CONTACT: Christian Boudreau, Environmental Specialist, West Division, 801-871-6704, 385-318-6938, Christian.boudreau@stakerparson.com OPERATING STATUS: In operation PROCESS DESCRIPTION: Jack B. Parson operates the California Batch Plant at this site. Washed sand and aggregate are delivered to the site by belly dump trucks. Trucks are unloaded into one of four drive over storage hoppers. Cement powder and fly ash are delivered by truck and are pneumatically unloaded into storage silos. Covered conveyors are used to transport the sand and aggregate from the drive over storage hoppers to an elevated storage hopper, which drops the material into a weigh hopper. Cement powder and fly ash are loaded into the cement batcher and the sand and aggregate are loaded into a weigh hopper. All of the above material is dropped into the central mixing drum, with water (wet batch). When the concrete is sufficiently mixed, it is poured into mixing trucks that transport the cement off-site to various projects. Emissions from the batcher (mixing drum) are controlled by use of a baghouse with local exhaust on the back end (loading end). Emissions from the fly ash and cement silos are controlled by use of baghouses, located at the top of the silos. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN115830007-16 dated January 8, 2016 / : 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Jack B. Parsons Company- California Ready Mix Facility - Directors Row 89 West 13490 South 3313 West 1100 South Draper, UT 84020 Salt Lake City, UT 84116 SIC Code: 3273: (Ready-Mixed Concrete) 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. According to Staker & Parsons, there has been no modifications to the equipment or processes as approved by this AO and no breakdowns resulting in an emissions event. Staker & Parsons maintains records for at least two years. According to SLEIS, this facility is not required to submit an Emissions Inventory Report at this time. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 California Ready Mix Facility II.A.2 One (1) Central Mix Drum - New Equipment Capacity: 12 cubic yards 3 II.A.3 One (1) Dust Collector - New Equipment Capacity: 6500 acfm II.A.4 One (1) Cement Batcher II.A.5 Four (4) Cement Storage Silos - New Equipment One (1) - 110 ton storage silo (silo has a dust collector- 2340 cfm) One (1) - 80 ton storage silo (silo has a dust collector - 2340 cfm) Two (2) - 100 ton storage silos (each silo has a dust collector - 2340cfm) II.A.6 One (1) Flyash Storage - New Equipment Capacity: 110 ton (2340 cfm dust collector) II.A.7 One (1) Drive-over Storage Hopper II.A.8 One (1) Elevated Storage Hopper II.A.9 Four (4) Open Conveyors II.A.10 One (1) 10MMBTU/hr Water Heater Status: In Compliance. There were no new or unapproved equipment observed during this inspection. The four conveyors indicated in AO Condition II.A.9 are completely covered. A small Safety Kleen Parts Washer was observed in the maintenance shop. II.B Requirements and Limitations II.B.1 The California Ready Mix Facility shall be subject to the following: II.B.1.a The owner/operator shall notify the Director in writing when the new equipment listed in this AO has been installed and is operational. To ensure proper credit when notifying the Director, send your correspondence to the Director, attn: Compliance Section. If the owner/operator has not notified the Director in writing within 18 months from the date of this AO on the status of the construction and/or installation, the Director shall require documentation of the continuous construction and/or installation of the operation. If a continuous program of construction and/or installation is not proceeding, the Director may revoke the AO. [R307-401-18] Status: In Compliance. According to DAQC-1426-19, the DAQ received a notification of installation letter on June 6, 2017. II.B.1.b The owner/operator shall not produce more than 450,000 cubic yards of mixed concrete per rolling 12-month period. [R307-401-8] Status: In Compliance. The rolling 12-month mixed concrete production from December 2022 to November 2023, indicated 147,928 cubic yards. II.B.1.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. Records of production shall be kept for all periods when the plant is in operation. Production shall be determined by sales receipts and/or supervisor monitoring and maintaining an operations log. The records of production shall be kept on a daily basis. [R307-401-8] Status: In Compliance. The production records were determined from the sales receipts and the daily operations log. 4 II.B.1.c Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20 percent opacity onsite and 10 percent opacity at the property boundary. [R307-309-5] II.B.1.c.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. [R307-305-3] Status: In Compliance. There were no visible emissions observed during this inspection. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. See the attachment for additional information II.B.2 The Baghouse Dust Collector shall be subject to the following: II.B.2.a The baghouse dust collector shall control particulate emissions from the cement silo, cement batcher, and central mixer. [R307-401-8] Status: In Compliance. During this inspection, the baghouse dust collector was determined to control particulate emissions from the cement silo, cement batcher, and central mixer. II.B.2.b Visible emissions from the baghouse dust collector shall not exceed 7% opacity. [R307-312] Status: In Compliance. There were no visible emissions observed from the baghouse dust collector during this inspection. II.B.2.c The pressure difference across the baghouse dust collector shall be within 1 to 7 inches water column. [R307-401-8] Status: Non-Compliance. During this inspection, the magnehelic gauge reading indicated 0.25 inches of water column. Compliance assistance provided to Staker & Parson to always check the pressure differential to ensure that the magnehelic gauge reading indicates compliance with this AO Condition. II.B.2.d A pressure monitor shall be placed on the baghouse to monitor the pressure difference. The monitor shall be located such that an inspector/operator can safely read the output at any time. The reading shall be accurate to within plus or minus 0.5 inches water column. The instrument shall be calibrated against a primary standard annually. The primary standard shall be established by the company and shall be submitted to the Director for approval. Continuous or intermittent recording of the readings is not required. [R307-401-8] Status: Non-Compliance. During this inspection, the magnehelic gauge reading indicated 0.25 inches of water column. Compliance assistance provided to Staker & Parson to always check the pressure differential to ensure that the magnehelic gauge reading indicates compliance with this AO Condition. The magnehelic gauge was calibrated on February 13, 2024. See the calibration record in the attachment. II.B.3 The 10 MMBTU/hr Water Heater shall be subject to the following II.B.3.a The water heater shall not exceed 4,500 hours of operation per rolling 12-month period. [R307-401-8] In Compliance. The rolling 12-month hours of operation of the water heater from December 2022 to November 2023, indicated 580 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] In Compliance. Staker & Parson maintains an operations log for the hours of operation of the water heater. 5 II.B.3.b The owner/operator shall not allow visible emissions from the water heater to exceed 10 percent opacity. [R307-401-8] In Compliance. There were no visible emissions observed from the water heater during this inspection. II.B.3.c The owner/operator shall use only natural gas as fuel in the water heater. [R307-401-8] In Compliance. Staker & Parson confirmed that only natural gas is used as fuel in the water heater. II.B.4 All Haul Roads and Fugitive Dust Sources on site shall be subject to the following: II.B.4.a The owner/operator shall pave all haul roads and operational areas with cement or asphalt. The owner/operator shall sweep and spray with water all the haul roads and operational areas on site to maintain the opacity limits listed in this AO. If the temperature is below freezing, the owner/operator shall continue to sweep the road but may stop spraying the paved haul roads with water. Flushing the paved haul road with water shall resume when the temperature is above freezing. [R307-401-8] II.B.4.a.1 Records of sweeping and water spraying 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] In Compliance. There were no visible emissions observed from the haul roads during this inspection. The haul roads and operational areas are paved with concrete. See the Sweeping Records in the attachment. II.B.4.b The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20 percent opacity on site and 10 percent at the property boundary. [R307-309-5] II.B.4.b.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] In Compliance. There were no visible emissions observed from haul-road during this inspection. II.B.4.c The owner/operator shall install water sprays on all conveyor drop points and unenclosed conveyor transfer points on site. Sprays shall operate as required to maintain the opacity limits listed in this AO when the temperature is above freezing. The owner/operator may stop the water sprays when the temperature is below freezing. [R307-401-8] In Compliance. The conveyors are enclosed, and no visible emissions were observed from the conveyor transfer points during this inspection. II.B.4.d The owner/operator shall comply with a fugitive dust control plan acceptable to the Director for control of all dust sources associated with the California Ready Mix Facility. The owner/operator shall comply with the most current fugitive dust control plan approved by the Director. [R307-309-6] In Compliance. Staker & Parson maintains a Fugitive Dust Control Plan (FDCP) last updated on December 12, 2023. 6 II.B.4.e The owner/operator shall comply with all applicable requirements of R307-309 for Fugitive Emission and Fugitive Dust sources on site. [R307-309] In Compliance. Staker & Parson maintains a Fugitive Dust Control Plan (FDCP) last updated on December 12, 2023. The haul roads and operational areas are paved with concrete. See the Sweeping Records in the attachment. The conveyors are enclosed, and no visible emissions were observed from the conveyor transfer points during this inspection. 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, Subpart Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units In Compliance. Only natural gas is used in the boiler. The rolling 12-month hours of operation of the water heater from December 2022 to November 2023, indicated 580 hours. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: UAC R307-210 In Compliance. This area rule is applicable to NSPS Part 60, Subpart Dc. See Section III for additional information. UAC R307-305 Nonattainment and Maintenance Areas for PM10: Emission Standards In Compliance. There were no visible emissions observed during this inspection. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. See the attachment for additional information. UAC R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust In Compliance. Staker & Parson maintains a Fugitive Dust Control Plan (FDCP) last updated on December 12, 2023. The haul roads and operational areas are paved with concrete. See the Sweeping Records in the attachment. The conveyors are enclosed, and no visible emissions were observed from the conveyor transfer points during this inspection. UAC R307-335 Degreasing In Compliance. The lid was closed during this inspection. There were no open containers observed. 7 EMISSION INVENTORY: Not applicable. According to SLEIS, this facility is not required to submit an Emissions Inventory Report at this time. Below is the estimated total potential emissions (PTE) on AO DAQE-AN115830007-16 dated January 8, 2016. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 3086.00 Carbon Monoxide 1.80 Nitrogen Oxides 1.07 Particulate Matter - PM10 6.64 Particulate Matter - PM2.5 1.81 Sulfur Dioxide 0.01 Volatile Organic Compounds 0.12 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Generic HAPs (CAS #GHAPS) 80 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Compliance Assistance was provided to Staker & Parson for AO Conditions II.B.2.c and II.B.2.d of DAQE-AN115830007-16 dated January 8, 2016, for the magnehelic gauge reading of 0.25 inches of water column during this inspection. No further action required. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. Required PPE includes steel-toe boots, hard hat, reflective vest, safety glasses. NSR RECOMMENDATIONS: Consider including the Parts Washer to the Equipment List. Consider noting that the four conveyors in AO Condition II.A.9 are covered. ATTACHMENTS: Applicable Supporting Documentation Included.