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HomeMy WebLinkAboutDAQ-2024-009598 DAQE-AN161530001-24 {{$d1 }} Sam Cusick CMC Rock, LLC 897 West Baxter Drive South Jordan, UT 84095 samc@cmcrock.com Dear Mr. Cusick: Re: Approval Order: New Heber City Concrete Batch Plant Project Number: N161530001 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on May 25, 2023. CMC Rock, LLC must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Mr. Enqiang He, who can be contacted at (801) 556-1580 or ehe@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:EH:jg cc: Wasatch County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director July 26, 2024 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN161530001-24 New Heber City Concrete Batch Plant Prepared By Mr. Enqiang He, Engineer (801) 556-1580 ehe@utah.gov Issued to CMC Rock, LLC - Heber City Concrete Batch Plant Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality July 26, 2024 TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 10 ACRONYMS ............................................................................................................................... 11 DAQE-AN161530001-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name CMC Rock, LLC CMC Rock, LLC - Heber City Concrete Batch Plant Mailing Address Physical Address 897 West Baxter Drive 2399 South 390 West South Jordan, UT 84095 Heber City, UT 84032 Source Contact UTM Coordinates Name: Sam Cusick 464,351 m Easting Phone: (801) 368-9011 4,480,793 m Northing Email: samc@cmcrock.com Datum NAD83 UTM Zone 12 SIC code 3273 (Ready-Mixed Concrete) SOURCE INFORMATION General Description CMC Rock, LLC (CMC Rock) has proposed a new central mix concrete batch plant near Heber City in Wasatch County. Cement and fly ash are delivered by trucks, pneumatically loaded by conveyors, and stored in silos. Cement and fly ash are transferred to the central mixing drum along with aggregate and sand and then mixed with water. Admixtures are also delivered by trucks and transferred by electric pumps. The batch plant is enclosed and controlled with a dust collector. The facility includes a crusher and screen plant to process 350,000 tons of recycled concrete per year. A diesel-fired engine provides power to the equipment on site. The facility also operates a boiler. Annual concrete production is limited to 250,000 cubic yards. NSR Classification New Minor Source Source Classification Located in Attainment Area Wasatch County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines DAQE-AN161530001-24 Page 4 MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Description The central mix concrete batch plant includes the following equipment: 1. Three (3) cement silos with dust collectors. Each silo has a capacity of 1,480 cubic feet (cf). 2. One (1) fly ash silo with a dust collector. The silo has a capacity of 1,480 cf. 3. Six (6) aggregate and sand bins, each rated at 2,000 cf. 4. One (1) aggregate sand conveyor rated at 360 tons per hour (tph). 5. One (1) weigh scale rated at 61 tph. 6. Four (4) cement screw conveyors. 7. One (1) cement surge hopper. 8. One (1) concrete mixer with a capacity of 6 cubic yards 9. One (1) natural gas-fired boiler rated at 6.83 MMBtu/hr, and 10. One (1) baghouse controls the batch plant enclosure. The aggregate plant includes the following equipment: 1. One (1) concrete crusher rated at 300 tph. 2. One (1) screen rated at 300 tph. 3. Five (5) conveyors, each rated at 300 tph. 4. One (1) superstacker rated at 300 tph. 5. One (1) grizzly feeder rated at 300 tph, and 6. One (1) Tier 4 diesel-fired engine rated at 450 hp. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 5759.00 Carbon Monoxide 13.76 Nitrogen Oxides 1.74 Particulate Matter - PM10 3.39 Particulate Matter - PM2.5 0.42 Sulfur Dioxide 0.04 Volatile Organic Compounds 5.03 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 220 Change (TPY) Total (TPY) Total HAPs 0.11 DAQE-AN161530001-24 Page 5 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] DAQE-AN161530001-24 Page 6 SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 The Heber City Concrete Batch Plant Aggregate and Concrete Mix Production II.A.2 One (1) Central Mix Concrete Batch Plant Rated at 218 cubic yards per hour (cy/hr) The plant includes the following components: One (1) concrete mixer, 6 cy capacity Three (3) cement silos (1,480 cf each) with dust collectors One (1) fly ash silo (1,480 cf capacity) with a dust collector Six (6) aggregate and sand bins, each rated at 2,000 cf One (1) aggregate sand conveyor rated at 360 tph One (1) weigh scale rated at 61 tph Four (4) cement screw conveyors One (1) cement surge hopper II.A.3 One (1) Baghouse Controls the concrete batch plant enclosure II.A.4 One (1) Aggregate Processing Plant The plant includes the following equipment: One (1) concrete crusher rated at 300 tph One (1) screen rated at 300 tph Five (5) conveyors, each rated at 300 tph One (1) superstacker rated at 300 tph, and One (1) grizzly feeder rated at 300 tph All NSPS Subpart OOO equipment II.A.5 One (1) Natural Gas-Fired Boiler Rated at 6.83 MMBtu/hr II.A.6 One (1) Diesel-Fired Tier 4 Engine Rated at 450 hp Equipped with SCR and EGR systems NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.7 One (1) Diesel Fuel Storage Tank Rated Capacity: 10,000 gallons II.A.8 Mobile Equipment Including a front-end loader and haul trucks Listed for informational purposes only. DAQE-AN161530001-24 Page 7 SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 The Heber Concrete Batch Plant shall be subject to the following: II.B.1.a The owner/operator shall not produce more than 250,000 cubic yards of concrete per rolling 12-month period. [R307-401-8] II.B.1.a.1 The owner/operator shall: A. Determine production by examination of haul truck or sales records. B. Record production on a daily basis. C. Use the production data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep production records for all periods when the plant is in operation. [R307-401-8] II.B.1.b Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All crushers - 12% opacity. B. All screens - 7% opacity. C All conveyor transfer points - 7% opacity. D. All conveyor drop points - 20% opacity. E. All concrete batch plants - 10% opacity. F. The diesel-fired engine - 20% opacity. G. The natural gas-fired boiler - 10% opacity. H. The baghouse and dust collectors - 10% opacity. I. All other points - 20% opacity. [R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 Baghouse Requirements II.B.2.a The owner/operator shall use a baghouse or dust collectors to control emissions from the cement silos, the fly ash silo, and the concrete batch plant enclosure. All exhaust air streams from the silos and the concrete batch plant enclosure shall be vented to the baghouse or dust collectors before being vented to the atmosphere. [R307-401-8] II.B.2.b The owner/operator shall install a manometer, a magnehelic pressure gauge, or an electronic differential pressure meter to measure the static pressure differential across the baghouse. [R307-401-8] DAQE-AN161530001-24 Page 8 II.B.2.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.2.b.2 The pressure gauge shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] II.B.2.c The owner/operator shall maintain the static pressure differential of the baghouse in accordance with the manufacturer's recommendations. [R307-401-8] II.B.2.c.1 The owner/operator shall record the static pressure differentials at least once per operating day while the baghouse is operating. [R307-401-8] II.B.2.c.2 The owner/operator shall maintain the following records of the static pressure differentials: A. Unit identification. B. Manufacturer recommended static pressure differential for the unit. C. Daily static pressure differential readings. D. Date of reading. [R307-401-8] II.B.2.d At least once every 12 months, the owner/operator shall calibrate the baghouse pressure gauges in accordance with the manufacturer's instructions or replace the pressure gauges. [R307-401-8] II.B.2.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] II.B.3 The Aggregate Processing Plant shall be subject to the following II.B.3.a The owner/operator shall not produce more than 350,000 tons of aggregate per rolling 12-month period. [R307-401-8] II.B.3.a.1 The owner/operator shall: A. Determine aggregate production by belt scale records, scale house records, or bucket scale records. B. Account for all aggregate materials produced prior to the aggregate materials leaving the site. C. Record production on a daily basis. 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. E. Keep production records for all periods when the plant is in operation. [R307-401-8] II.B.3.b The owner/operator shall install water sprays on each crusher, screen, conveyor transfer point, and conveyor drop point on site to control emissions. Water sprays shall operate as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] DAQE-AN161530001-24 Page 9 II.B.3.b.1 The owner/operator shall conduct monthly inspections of each crusher, screen, and conveyor manufactured after April 22, 2008, to check that water is flowing to discharge spray nozzles in the wet suppression system. [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.b.2 The owner/operator shall maintain records of wet suppression system inspections according to 40 CFR 60 Subpart OOO. [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.c The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving the maximum production rate but not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.c.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR 60.675(c). The owner or operator may use methods and procedures specified in 40 CFR 60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c). [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.c.2 The owner/operator shall keep records of the initial performance test for each crusher, screen, and conveyor for the life of the equipment. [40 CFR 60 Subpart OOO, R307-401-8] II.B.4 Haul Roads and Fugitive Dust Sources shall be subject to the following: II.B.4.a The owner/operator shall pave all in-plant haul roads. [R307-401-8] II.B.4.b The owner/operator shall not allow visible emissions from the in-plant paved haul roads and other fugitive emission sources to exceed 20% opacity. [R307-401-8] 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. [R307-205-4] II.B.4.c The owner/ operator shall sweep and water spray the paved in-plant haul road as necessary to maintain the listed opacity limits in this AO. [R307-401-8] II.B.4.c.1 Records of cleaning the paved haul roads shall be made available to the Director or the Director's representative upon request. [R307-401-8] II.B.4.d The combined area occupied by all storage piles on site associated with aggregate processing plant shall not exceed 2.5 acres. [R307-401-8] II.B.4.d.1 The owner/operator shall measure the total area of the storage piles at least once every six months and shall maintain a record of the total acres of the storage piles. Records of the total acres of the storage piles shall contain the following: A. Date of measurements. B. Size of each storage pile on site. C. Total acres of all storage piles combined. [R307-401-8] II.B.4.e The owner/operator shall apply water sprays on all storage piles on site to control fugitive emissions. Sprays shall operate as required to maintain the opacity limit listed in this AO when the temperature is above freezing. [R307-401-8] DAQE-AN161530001-24 Page 10 II.B.5 The Natural Gas-Fired Boiler shall be subject to the following: II.B.5.a The owner/operator shall use natural gas as fuel in the boiler. [R307-401-8] II.B.6 The Diesel-Fired Engine shall be subject to the following: II.B.6.a The owner/operator shall install and operate an engine that is certified to meet the following EPA Tier 4 standards: HC = 0.14 g/hp-hr NOx = 0.30 g/hp-hr PM = 0.01 g/hp-hr [R307-401-8] II.B.6.a.1 The owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] II.B.6.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the engine. [R307-401-8] II.B.6.c 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. [R307-401-8] II.B.6.c.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. [R307-401-8] II.B.6.d The owner/operator shall operate and maintain the engine's SCR and EGR systems at all times when the engine is operated in accordance with the manufacturer's instructions and/or recommendations. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated May 25, 2023 Incorporates Additional information dated December 7, 2023 Incorporates Additional information dated March 12, 2024 DAQE-AN161530001-24 Page 11 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds Wasatch Wave Publication Name: Wasatch Wave Publication URL: www.wasatchwave.com Publication City and State: Heber City, UT Publication County: Wasatch Notice Popular Keyword Category: Notice Keywords: cmc rock Notice Authentication Number: 202406190944375007630 1761527914 Notice URL: Back Notice Publish Date: Wednesday, June 19, 2024 Notice Content NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: CMC Rock, LLC Location: CMC Rock, LLC - Heber City Concrete Batch Plant – 2399 South 390 West, Heber City, UT Project Description: CMC Rock, LLC has proposed a new central mix concrete batch plant near Heber City in Wasatch County. Cement and fly ash are delivered by trucks, pneumatically loaded by conveyors, and stored in silos. Cement and fly ash are transferred to the central mixing drum along with aggregate and sand and then mixed with water. Admixtures are also delivered by trucks and transferred by electric pumps. The batch plant is enclosed and controlled with a dust collector. The facility includes a crusher and screen plant to process 350,000 tons of recycled concrete per year. A diesel-fired engine provides power to the equipment on site. The facility also operates a boiler. Annual concrete production is limited to 250,000 cubic yards. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before July 19, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at ehe@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: June 19, 2024 Published in The Wasatch Wave June 19, 2024. Back DAQE-NN161530001-24 June 13, 2024 Wasatch Wave Legal Advertising Dept. P.O. Box 128 Heber City, UT 84032 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Wasatch Wave (Account Number: 895) on June 19, 2024. Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any questions, contact Jeree Greenwood, who may be reached at (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Wasatch County cc: Mountainland Association of Governments 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director DAQE-NN161530001-24 Page 2 NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: CMC Rock, LLC Location: CMC Rock, LLC - Heber City Concrete Batch Plant – 2399 South 390 West, Heber City, UT Project Description: CMC Rock, LLC has proposed a new central mix concrete batch plant near Heber City in Wasatch County. Cement and fly ash are delivered by trucks, pneumatically loaded by conveyors, and stored in silos. Cement and fly ash are transferred to the central mixing drum along with aggregate and sand and then mixed with water. Admixtures are also delivered by trucks and transferred by electric pumps. The batch plant is enclosed and controlled with a dust collector. The facility includes a crusher and screen plant to process 350,000 tons of recycled concrete per year. A diesel-fired engine provides power to the equipment on site. The facility also operates a boiler. Annual concrete production is limited to 250,000 cubic yards. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before July 19, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at ehe@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: June 19, 2024 {{#s=Sig_es_:signer1:signature}} DAQE-IN161530001-24 June 13, 2024 Sam Cusick CMC Rock, LLC 897 West Baxter Drive South Jordan, UT 84095 samc@cmcrock.com Dear Mr. Cusick: Re: Intent to Approve: New Heber City Concrete Batch Plant Project Number: N161530001 The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is subject to public review. Any comments received shall be considered before an Approval Order (AO) is issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO. Future correspondence on this ITA should include the engineer's name, Mr. Enqiang He, as well as the DAQE number as shown on the upper right-hand corner of this letter. Mr. Enqiang He, can be reached at (801) 556-1580 or ehe@utah.gov, if you have any questions. Sincerely, {{$s }} Alan D. Humpherys, Manager New Source Review Section ADH:EH:jg cc: Wasatch County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN161530001-24 New Heber City Concrete Batch Plant Prepared By Mr. Enqiang He, Engineer (801) 556-1580 ehe@utah.gov Issued to CMC Rock, LLC - Heber City Concrete Batch Plant Issued On June 13, 2024 {{$s }} New Source Review Section Manager Alan D. Humpherys {{#s=Sig_es_:signer1:signature}} TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 PUBLIC NOTICE STATEMENT............................................................................................... 5 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 11 ACRONYMS ............................................................................................................................... 12 DAQE-IN161530001-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name CMC Rock, LLC CMC Rock, LLC - Heber City Concrete Batch Plant Mailing Address Physical Address 897 West Baxter Drive 2399 South 390 West South Jordan, UT 84095 Heber City, UT Source Contact UTM Coordinates Name: Sam Cusick 464,351 m Easting Phone: (801) 368-9011 4,480,793 m Northing Email: samc@cmcrock.com Datum NAD83 UTM Zone 12 SIC code 3273 (Ready-Mixed Concrete) SOURCE INFORMATION General Description CMC Rock, LLC (CMC Rock) has proposed a new central mix concrete batch plant near Heber City in Wasatch County. Cement and fly ash are delivered by trucks, pneumatically loaded by conveyors, and stored in silos. Cement and fly ash are transferred to the central mixing drum along with aggregate and sand and then mixed with water. Admixtures are also delivered by trucks and transferred by electric pumps. The batch plant is enclosed and controlled with a dust collector. The facility includes a crusher and screen plant to process 350,000 tons of recycled concrete per year. A diesel-fired engine provides power to the equipment on site. The facility also operates a boiler. Annual concrete production is limited to 250,000 cubic yards. NSR Classification New Minor Source Source Classification Located in Attainment Area Wasatch County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions DAQE-IN161530001-24 Page 4 MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Description The central mix concrete batch plant includes the following equipment: 1. Three (3) cement silos with dust collectors. Each silo has a capacity of 1,480 cubic feet (cf). 2. One (1) fly ash silo with a dust collector. The silo has a capacity of 1,480 cf. 3. Six (6) aggregate and sand bins, each rated at 2,000 cf. 4. One (1) aggregate sand conveyor rated at 360 tons per hour (tph). 5. One (1) weigh scale rated at 61 tph. 6. Four (4) cement screw conveyors. 7. One (1) cement surge hopper. 8. One (1) concrete mixer with a capacity of 6 cubic yards. 9. One (1) natural gas-fired boiler rated at 6.83 MMBtu/hr, and 10. One (1) baghouse controls the batch plant enclosure. The aggregate plant includes the following equipment: 1. One (1) concrete crusher rated at 300 tph. 2. One (1) screen rated at 300 tph. 3. Five (5) conveyors, each rated at 300 tph. 4. One (1) superstacker rated at 300 tph. 5. One (1) grizzly feeder rated at 300 tph, and 6. One (1) Tier 4 diesel-fired engine rated at 450 hp. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 5759.00 Carbon Monoxide 13.76 Nitrogen Oxides 1.74 Particulate Matter - PM10 3.39 Particulate Matter - PM2.5 0.42 Sulfur Dioxide 0.04 Volatile Organic Compounds 5.03 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 220 Change (TPY) Total (TPY) Total HAPs 0.11 DAQE-IN161530001-24 Page 5 PUBLIC NOTICE STATEMENT The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Wasatch Wave on June 19, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received. SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. 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] DAQE-IN161530001-24 Page 6 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] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT II.A.1 The Heber City Concrete Batch Plant Aggregate and Concrete Mix Production II.A.2 One (1) Central Mix Concrete Batch Plant Rated at 218 cubic yards per hour (cy/hr), The plant includes the following components: One (1) concrete mixer, 6 cy capacity Three (3) cement silos (1,480 cf each) with dust collectors One (1) fly ash silo (1,480 cf capacity) with a dust collector Six (6) aggregate and sand bins, each rated at 2,000 cf One (1) aggregate sand conveyor rated at 360 tons per hour (tph) One (1) weigh scale rated at 61 tph Four (4) cement screw conveyors One (1) cement surge hopper II.A.3 One (1) Baghouse Controls the concrete batch plant enclosure II.A.4 One (1) Aggregate Processing Plant The plant includes the following equipment: One (1) concrete crusher rated at 300 tph One (1) screen rated at 300 tph Five (5) conveyors, each rated at 300 tph One (1) superstacker rated at 300 tph, and One (1) grizzly feeder rated at 300 tph All NSPS Subpart OOO equipment II.A.5 One (1) Natural Gas-Fired Boiler Rated at 6.83 MMBtu/hr DAQE-IN161530001-24 Page 7 II.A.6 One (1) Diesel-Fired Tier 4 Engine Rated at 450 hp Equipped with SCR and EGR systems NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.7 One (1) Diesel Fuel Storage Tank Rated Capacity: 10,000 gallons II.A.8 Mobile Equipment Including a front-end loader and haul trucks Listed for informational purposes only. SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 The Heber Concrete Batch Plant shall be subject to the following: II.B.1.a The owner/operator shall not produce more than 250,000 cubic yards of concrete per rolling 12-month period. [R307-401-8] II.B.1.a.1 The owner/operator shall: A. Determine production by examination of haul truck or sales records. B. Record production on a daily basis. C. Use the production data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep production records for all periods when the plant is in operation. [R307-401-8] DAQE-IN161530001-24 Page 8 II.B.1.b Unless otherwise specified in this AO, owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All crushers - 12% opacity. B. All screens - 7% opacity. C. All conveyor transfer points - 7% opacity. D. All conveyor drop points - 20% opacity. E. All concrete batch plants - 10% opacity . F. The diesel-fired engine - 20% opacity. G. The natural gas-fired boiler - 10% opacity. H. The baghouse and dust collectors - 10% opacity. I. All other points - 20% opacity. [R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 Baghouse Requirements II.B.2.a The owner/operator shall use a baghouse or dust collectors to control emissions from the cement silos, the fly ash silo, and the concrete batch plant enclosure. All exhaust air streams from the silos and the concrete batch plant enclosure shall be vented to the baghouse or dust collectors before being vented to the atmosphere. [R307-401-8] II.B.2.b The owner/operator shall install a manometer, a magnehelic pressure gauge, or an electronic differential pressure meter to measure the static pressure differential across the baghouse. [R307-401-8] II.B.2.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.2.b.2 The pressure gauge shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] II.B.2.c The owner/operator shall maintain the static pressure differential of the baghouse in accordance with the manufacturer's recommendations. [R307-401-8] II.B.2.c.1 The owner/operator shall record the static pressure differentials at least once per operating day while the baghouse is operating. [R307-401-8] DAQE-IN161530001-24 Page 9 II.B.2.c.2 The owner/operator shall maintain the following records of the static pressure differentials: A. Unit identification. B. Manufacturer recommended a static pressure differential for the unit. C. Daily static pressure differential readings. D. Date of reading. [R307-401-8] II.B.2.d At least once every 12 months, the owner/operator shall calibrate the baghouse pressure gauges in accordance with the manufacturer's instructions or replace the pressure gauges. [R307-401-8] II.B.2.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] II.B.3 The Aggregate Processing Plant shall be subject to the following: II.B.3.a The owner/operator shall not produce more than 350,000 tons of aggregate per rolling 12-month period. [R307-401-8] II.B.3.a.1 The owner/operator shall: A. Determine aggregate production by belt scale records, scale house records, or bucket scale records. B. Account for all aggregate materials produced prior to the aggregate materials leaving the site. C. Record production on a daily basis. 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. E. Keep production records for all periods when the plant is in operation. [R307-401-8] II.B.3.b The owner/operator shall install water sprays on each crusher, screen, conveyor transfer point, and conveyor drop point on site to control emissions. Water sprays shall operate as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] II.B.3.b.1 The owner/operator shall conduct monthly inspections of each crusher, screen, and conveyor manufactured after April 22, 2008, to check that water is flowing to discharge spray nozzles in the wet suppression system. [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.b.2 The owner/operator shall maintain records of wet suppression system inspections according to 40 CFR 60 Subpart OOO. [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.c The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving the maximum production rate but not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO, R307-401-8] DAQE-IN161530001-24 Page 10 II.B.3.c.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR 60.675(c). The owner or operator may use methods and procedures specified in 40 CFR 60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c). [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.c.2 The owner/operator shall keep records of the initial performance test for each crusher, screen, and conveyor for the life of the equipment. [40 CFR 60 Subpart OOO, R307-401-8] II.B.4 Haul Roads and Fugitive Dust Sources shall be subject to the following: II.B.4.a The owner/operator shall pave all in-plant haul roads. [R307-401-8] II.B.4.b The owner/operator shall not allow visible emissions from the in-plant paved haul roads and other fugitive emission sources to exceed 20% opacity. [R307-401-8] 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. [R307-205-4] II.B.4.c The owner/ operator shall sweep and water spray the paved in-plant haul road as necessary to maintain the listed opacity limits in this AO. [R307-401-8] II.B.4.c.1 Records of cleaning the paved haul roads shall be made available to the Director or the Director's representative upon request. [R307-401-8] II.B.4.d The combined area occupied by all storage piles on site associated with aggregate processing plant shall not exceed 2.5 acres. [R307-401-8] II.B.4.d.1 The owner/operator shall measure the total area of the storage piles at least once every six (6) months and shall maintain a record of the total acres of the storage piles. Records of the total acres of the storage piles shall contain the following: A. Date of measurements. B. Size of each storage pile on site. C. Total acres of all storage piles combined. [R307-401-8] II.B.4.e The owner/operator shall apply water sprays on all storage piles on site to control fugitive emissions. Sprays shall operate as required to maintain the opacity limit listed in this AO when the temperature is above freezing. [R307-401-8] II.B.5 The Natural Gas-Fired Boiler shall be subject to the following: II.B.5.a The owner/operator shall use natural gas as fuel in the boiler. [R307-401-8] DAQE-IN161530001-24 Page 11 II.B.6 The Diesel-Fired Engine shall be subject to the following: II.B.6.a The owner/operator shall install and operate an engine that is certified to meet the following EPA Tier 4 standards: HC = 0.14 g/hp-hr NOx = 0.30 g/hp-hr PM = 0.01 g/hp-hr [R307-401-8] II.B.6.a.1 The owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] II.B.6.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the engine. [R307-401-8] II.B.6.c 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. [R307-401-8] II.B.6.c.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. [R307-401-8] II.B.6.d The owner/operator shall operate and maintain the engine's SCR and EGR systems at all times when the engine is operated in accordance with the manufacturer's instructions and/or recommendations. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated May 25, 2023 Incorporates Additional information dated December 7, 2023 Incorporates Additional information dated March 12, 2024 DAQE-IN161530001-24 Page 12 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds DAQE- RN161530001 April 1, 2024 Sam Cusick CMC Rock, LLC 897 West Baxter Dr. South Jordan, UT 84095 samc@cmcrock.com Dear Sam Cusick, Re: Engineer Review: The Heber City Concrete Batch Plant Project Number: N161530001 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. CMC Rock, LLC should complete this review within 10 business days of receipt. CMC Rock, LLC should contact Mr. Enqiang He at (801) 556-1580 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Enqiang He at ehe@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If CMC Rock, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If CMC Rock, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N161530001 Owner Name CMC Rock, LLC Mailing Address 897 West Baxter Dr. South Jordan, UT 84095 Source Name CMC Rock, LLC - Heber City Concrete Batch Plant Source Location 2399 South 390 West Heber City, UT UTM Projection 464,351 m Easting, 4,480,793 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3273 (Ready-Mixed Concrete) Source Contact Sam Cusick Phone Number (801) 368-9011 Email samc@cmcrock.com Billing Contact Sam Cusick Phone Number (801) 368-9011 Email samc@cmcrock.com Project Engineer Mr. Enqiang He, Engineer Phone Number (801) 556-1580 Email ehe@utah.gov Notice of Intent (NOI) Submitted May 25, 2023 Date of Accepted Application March 14, 2024 Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 2 SOURCE DESCRIPTION General Description CMC Rock, Inc. (CMC Rock) has proposed a new central mix concrete batch plant near Heber City in Wasatch County. Cement and fly ash are delivered by trucks, pneumatically loaded by conveyors and stored in silos. Cement and fly ash are transferred to the central mix drum along with aggregate and sand and then mixed with water. Admixtures are also delivered by trucks and transferred by electric Pumps. The batch plant is enclosed and controlled with a dust collector. The facility includes a crusher and screen plant to process 350,000 tons of recycled concrete per year. A diesel-fired engine provides power to the equipment on site. The facility also operates a boiler. Annual concrete production is limited to 250,000 cubic yards. NSR Classification: New Minor Source Source Classification Located in Attainment Area Wasatch County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal The Heber City Concrete Batch Plant Project Description The central mix concrete batch plant includes the following equipment: 1. Three (3) cement silos with dust collectors. Each silo has a capacity of 1,480 cubic feet (cf). 2. One (1) fly ash silo with a dust collector. The silo has a capacity of 1,480 cf. 3. Six (6) aggregate and sand bins each rated at 2,000 cf. 4. One (1) aggregate sand conveyor rated at 360 tons per hour (tph). 5. One (1) weigh scale rated at 61 tph. 6. Four (4) cement screw conveyors. 7. One (1) cement surge hopper. 8. One (1) concrete mixer with a capacity of 6 cubic yards 9. One (1) natural gas-fired boiler rated at 6.83 MMBtu/hr, and 10. One (1) baghouse controls the batch plant enclosure. The aggregate plant includes the following equipment: 1. One (1) concrete crusher rated at 300 tph. 2. One (1) screen rated at 300 tph. 3. Five (5) conveyors each rated at 300 tph. 4. One (1) superstacker rated at 300 tph. Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 3 5. One (1) grizzly feeder rated at 300 tph, and 6. One (1) Tier 4 Diesel-fired engine rated at 450 hp. EMISSION IMPACT ANALYSIS Emission increases for the criteria pollutants and HAPs are below the modeling thresholds per R307-410-4 and R307-410-5; therefore, modeling is not required. [Last updated February 26, 2024] Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 4 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 5759.00 Carbon Monoxide 13.76 Nitrogen Oxides 1.74 Particulate Matter - PM10 3.39 Particulate Matter - PM2.5 0.42 Sulfur Dioxide 0.04 Volatile Organic Compounds 5.03 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 220 Change (TPY) Total (TPY) Total HAPs 0.11 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 5 Review of BACT for New/Modified Emission Units 1. BACT review regarding the concrete batch plant The three (3) cement silos and one (1) fly ash are controlled with dust collectors. The aggregate bins, cement surge hoppers, conveyors, weigh scale and the concrete mixer are enclosed and controlled with a baghouse. The dust collectors and baghouse will have control efficiencies over 99% for particulate emissions. Visible emissions from the control equipment are limited to 10% opacity. The Minor NSR Section recommend the controls and opacity limit as BACT. [Last updated September 14, 2023] 2. BACT review regarding Aggregate Plant Operations The crushing, screening, and conveying of aggregate materials creates PM10 and PM2.5 emission. Potential controls for these emissions include electrostatic precipitators (ESPs), wet scrubbers, cyclones, baghouses, enclosures, and water sprays. Due to the cost of the control and frequent changes in plant setup, the following control technologies are economically and/or technologically infeasible and were eliminated as BACT: ESPs, wet scrubbers, cyclones, enclosures, and baghouses. The remaining control option is water sprays. Water sprays are an effective control for PM emissions from crushing and screening operations as well as transfer and drop points. BACT requirements for material processing is the use of water sprays to meet the following opacity limitations applicable to process equipment: Crushers - 12% Screens - 7% Conveyor Transfer Points - 7% Conveyor Drop Points - 20% [Last updated September 14, 2023] 3. BACT review regarding fugitive dust sources Haul Roads PM10 and PM2.5 are emitted as fugitive dust from haul roads. Controls for these emissions include paving with vacuum sweeping (95%), paving with sweeping and watering (90%), chemical suppressants with watering (85%), and watering (70-75%). The most effective control for haul roads is paving combined with vacuum sweeping and watering on a regular basis. The source shall pave the haul roads and water spray and/or sweep the roads. Visible emissions from the paved haul roads are limited to 20% opacity. The Minor NSR Section recommends the control methods and opacity limit as BACT. Storage Piles Water sprays are an effective technology to control fugitive dust emissions from storage piles. Visible emissions from the storage piles are limited to 20% opacity. Minor NSR Section considers water sprays and the opacity limit as BACT. [Last updated February 26, 2024] 4. BACT review regarding 450-hp diesel-fired engine The engine provides mechanical power to the crusher and a generator. The engine is an EPA Tier 4 certified, and equipped with Exhaust Gas Recirculation (EGR) and Selective Catalytic Reduction (SCR). The Tier 4 emission standards for the engine are: HC = 0.14 g/hp-hr, NOx = 0.30 g/hp-hr, and PM = 0.01 g/hp-hr. The engine will also fire with ultra-low sulfur diesel fuel. Visible Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 6 emissions from the engine will be limited to 20% opacity. The Minor NSR Section considers the measures and the limits as BACT. [Last updated September 14, 2023] 5. BACT review regarding the boiler The boiler is natural gas fired and rated at 6.83 MMBtu/hr. The boiler is a turbomatic heating system specially designed for concrete batch plant applications. The flue gas exhausts through the filled aggregate bins to heat the aggregate. According to the manufacturer, the use of natural gas, back pressure and absorption of the filled materials in the storage bins, will reduce NOx emissions to 0.43 tpy with NOx concentration close to ultra-low NOx level at 12 ppm. Because of the already low level of NOx emissions, it is technologically infeasible and economically infeasible to reduce NOx emissions further by retrofitting the boiler. Visible emissions from the system will be limited to 10% opacity. The Minor NSR Section considers the turbomatic heating system and the opacity limit as BACT. [Last updated February 26, 2024] SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): 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] Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 7 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] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 The Heber City Concrete Batch Plant Aggregate and Concrete Mix Production II.A.2 NEW One (1) Central Mix Concrete Batch Plant Rated at 218 cubic yards per hour (cy/hr) The plant includes the following components: One (1) concrete mixer, 6 cy capacity Three (3) cement silos (1,480 cf each) with dust collectors One (1) fly ash silo (1,480 cf capacity) with a dust collector Six (6) aggregate and sand bins each rated at 2,000 cf One (1) aggregate sand conveyor rated at 360 tons per hour (tph) One (1) weigh scale rated at 61 tph Four (4) cement screw conveyors One (1) cement surge hopper II.A.3 NEW One (1) Baghouse Controls the concrete batch plant enclosure II.A.4 NEW One (1) Aggregate Processing Plant The plant includes the following equipment: One (1) concrete crusher rated at 300 tph One (1) screen rated at 300 tph Five (5) conveyors each rated at 300 tph One (1) superstacker rated at 300 tph, and One (1) grizzly feeder rated at 300 tph All NSPS Subpart OOO equipment Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 8 II.A.5 NEW One (1) Natural Gas-Fired Boiler Rated at 6.83 MMBtu/hr II.A.6 NEW One (1) Tier 4 Engine Rated at 450 hp and equipped with SCR and EGR systems NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.7 NEW Mobile Equipment Including a front-end loader and haul trucks II.A.8 NEW One (1) Diesel Fuel Storage Tank Rated Capacity: 10,000 gallons SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 NEW The Heber Concrete Batch Plant shall be subject to the following: II.B.1.a NEW The owner/operator shall not produce more than 250,000 cubic yards of concrete per rolling 12-month period. [R307-401-8] II.B.1.a.1 NEW The owner/operator shall: A. Determine production by examination of haul truck records B. Record production on a daily basis C. Use the production data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep production records for all periods when the plant is in operation [R307-401-8] Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 9 II.B.1.b NEW Unless otherwise specified in this AO, owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All crushers - 12% opacity B. All screens - 7% opacity C All conveyor transfer points - 7% opacity D. All conveyor drop points - 20% opacity E. All concrete batch plants - 10% opacity F. The diesel-fired engine - 20% opacity G. The natural gas-fired boiler - 10% opacity H. The baghouse and dust collectors - 10% opacity I. All other points - 20% opacity [R307-401-8] II.B.1.b.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 NEW Baghouse Requirements II.B.2.a NEW The owner/operator shall use a baghouse or dust collectors to control emissions from the cement silos, the fly ash silo, and the concrete batch plant enclosure. All exhaust air streams from the silos and the concrete batch plant enclosure shall be vented to the baghouse or dust collectors before being vented to the atmosphere. [R307-401-8] II.B.2.b NEW The owner/operator shall install a manometer, a magnehelic pressure gauge, or an electronic differential pressure meter to measure the static pressure differential across the baghouse. [R307-401-8] II.B.2.b.1 NEW The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.2.b.2 NEW The pressure gauge shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] II.B.2.c NEW The owner/operator shall maintain the static pressure differential of the baghouse in accordance with the manufacturer's recommendations. [R307-401-8] II.B.2.c.1 NEW The owner/operator shall record the static pressure differentials at least once per operating day while the baghouse is operating. [R307-401-8] Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 10 II.B.2.c.2 NEW The owner/operator shall maintain the following records of the static pressure differentials: A. Unit identification B. Manufacturer recommended static pressure differential for the unit (if applicable) C. Daily static pressure differential readings D. Date of reading. [R307-401-8] II.B.2.d NEW At least once every 12 months, the owner/operator shall calibrate the baghouse pressure gauges in accordance with the manufacturer's instructions or replace the pressure gauges. [R307-401-8] II.B.2.d.1 NEW The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] II.B.3 NEW The Aggregate Processing Plant shall be subject to the following II.B.3.a NEW The owner/operator shall not produce more than 350,000 tons of aggregate per rolling 12- month period. [R307-401-8] II.B.3.a.1 NEW The owner/operator shall: A. Determine aggregate production by belt scale records, scale house records, or bucket scale records B. Account for all aggregate materials produced prior to the aggregate materials leaving the site C. Record production on a daily basis 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 E. Keep production records for all periods when the plant is in operation. [R307-401-8] II.B.3.b NEW The owner/operator shall install water sprays on each crusher, screen, conveyor transfer point, and conveyor drop point on site to control emissions. Water sprays shall operate as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] II.B.3.b.1 NEW The owner/operator shall conduct monthly inspections of each crusher, screen, and conveyor manufactured after April 22, 2008, to check that water is flowing to discharge spray nozzles in the wet suppression system. [40 CFR 60 Subpart OOO, R307-401-8] Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 11 II.B.3.b.2 NEW The owner/operator shall maintain records of wet suppression system inspections according to 40 CFR 60 Subpart OOO. [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.c NEW The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving the maximum production rate but not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.c.1 NEW Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR 60.675(c). The owner or operator may use methods and procedures specified in 40 CFR 60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c). [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.c.2 NEW The owner/operator shall keep records of the initial performance test for each crusher, screen, and conveyor for the life of the equipment. [40 CFR 60 Subpart OOO, R307-401-8] II.B.4 NEW Haul Roads and Fugitive Dust Sources shall be subject to the following: II.B.4.a NEW The owner/operator shall pave all in-plant haul roads. The total paved haul roads shall not be less than 0.35 miles. [R307-401-8] II.B.4.a.1 NEW Compliance shall be determined through Global Positioning System (GPS) measurements or aerial photographs. [R307-401-8] II.B.4.b NEW The owner/operator shall not allow visible emissions from the in-plant paved haul roads and other fugitive emission sources to exceed 20% opacity. [R307-401-8] II.B.4.b.1 NEW 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. [R307-205-4] II.B.4.c NEW The owner/ operator shall sweep and water spray the paved in-plant haul road as necessary to maintain the listed opacity limits in this AO. [R307-401-8] II.B.4.c.1 NEW Records of cleaning the paved haul roads shall be made available to the Director or the Director's representative upon request. [R307-401-8] II.B.4.d NEW The combined area occupied by all storage piles on site associated with aggregate processing plant shall not exceed 2.5 acres. [R307-401-8] Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 12 II.B.4.d.1 NEW The owner/operator shall measure the total area of the storage piles at least once every six months and shall maintain a record of the total acres of the storage piles. Records of the total acres of the storage piles shall contain the following: A. Date of measurements B. Size of each storage pile on site C. Total acres of all storage piles combined. [R307-401-8] II.B.4.e NEW The owner/operator shall apply water sprays on all storage piles on site to control fugitive emissions. Sprays shall operate as required to maintain the opacity limit listed in this AO when the temperature is above freezing. [R307-401-8] II.B.5 NEW The Natural Gas-Fired Boiler shall be subject to the following: II.B.5.a NEW The owner/operator shall use natural gas as fuel in the boiler. [R307-401-8] II.B.6 NEW The Diesel-Fired Engine shall be subject to the following II.B.6.a NEW The owner/operator shall install and operate an engine that is certified to meet the following EPA Tier 4 standards: HC = 0.14 g/hp-hr NOx = 0.30 g/hp-hr PM = 0.01 g/hp-hr. [R307-401-8] II.B.6.a.1 NEW The owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] II.B.6.b NEW The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the engine. [R307-401-8] II.B.6.c NEW 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. [R307-401-8] II.B.6.c.1 NEW 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. [R307-401-8] II.B.6.d NEW The owner/operator shall operate and maintain the engine’s SCR and EGR systems at all times when the engine is operated in accordance with the manufacturer’s instructions and/or recommendations. [R307-401-8] Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 13 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated May 25, 2023 Incorporates Additional information dated December 7, 2023 Incorporates Additional information dated March 12, 2024 REVIEWER COMMENTS 1. Comment regarding Emission calculations: Emission calculations are partially based on the following site-wide production limits: Annual aggregate processing limit: 350,000 tons Annual concrete mix production: 250,000 cubic yards The engine and the boiler are operated at 8,760 hours per year Paved haul road length of 0.35 miles Total storage piles of 2.5 acres Emissions from the concrete batch plant are calculated using AP-42, Chapter 11.12 emission factors. Emissions from aggregate processing operations are estimated using AP-42, Chapter 11.19 emission factors Emissions from the storage piles are calculated using AP-42, Chapter 8.19.1 emission factors Emissions from the boiler are based on the emission factors in AP-42, Chapter 1.4. Engine emissions are calculated using EPA Tier 4 standards for VOC, NOx, CO, and PM10/PM2.5, South Coast AQMD emission factors for SO2, and an annual operation of 8,760 hours. Paved haul road emissions are calculated using the DAQ Haul Road Guidance and parameters in AP-42, Chapter 13.2.2. [Last updated February 26, 2024] 2. Comment regarding NSPS, MACT and Title V Applicability: NSPS NSPS Subpart OOO applies to each crusher, screening operation, and belt conveyor in fixed or portable nonmetallic mineral processing plants manufactured after August 31 1983. The source owns and operates the aggregate processing equipment to process nonmetallic minerals according to 40 CFR 60.671; therefore, NSPS Subpart OOO applies to this source. NSPS Subpart IIII applies to owners and operators of stationary CI ICE that commence construction after July 11, 2005, where the stationary CI ICE are manufactured after April 1, 2006. The stationary engine at this source was manufactured after April 1, 2006; therefore, NSPS Subpart IIII applies to this source. MACT 40 CFR 63 MACT Subpart ZZZZ applies to owners and operators of stationary RICE at a major or area source of HAP emissions. This source will have stationary RICE at an area source of HAP emissions; therefore, MACT Subpart ZZZZ will apply to the stationary engine at this source. Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 14 Title V Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a major source or a Title IV source. The source is subject to NSPS Subparts OOO and IIII, and MACT subpart ZZZZ. NSPS Subpart OOO does not exempts sources from the Title V requirements. Therefore, this facility is a Title V area source. [Last updated February 26, 2024] Engineer Review N161530001: CMC Rock, LLC - Heber City Concrete Batch Plant April 1, 2024 Page 15 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds BACT ANALYSIS The CMC Rock – Heber Valley Concrete Batch Plant facility is located in Wasatch County, which is in attainment for all criteria pollutants. According to the UDAQ Emissions Impact Assessment Guidelines, new sources, or modifications to existing sources, whose total controlled emission increase levels are greater than those listed in Table 1 (R307-410-4) are required to submit a dispersion modeling analysis as part of a complete NOI. Table 1 Pollutant Emissions Levels to Require Modeling (TPY) SO2 40 NO2 40 PM10 – Fugitive Emissions 5 PM10 – non-fugitive emissions 15 CO 100 Lead 0.6 The CMC Rock facility is a Minor Source with a potential to emit significantly below the thresholds listed in Table 1. Therefore, a dispersion modeling analysis is not included with the NOI. Instead, CMC Rock will rely on UDAQ’s in-house Emissions Impact Analysis (EIA). Utah regulation R301-401-5(2)(d) requires that an analysis of Best Available Control Technology (BACT) be applied to all regulated air pollutants emitted from a facility. A BACT determination is made on a case-by-case basis, with consideration given to technological practicability and economic reasonableness. In all cases BACT must establish emission limitations or specific design characteristics at least as stringent as applicable New Source Performance Standards. This BACT analysis provides a discussion on the feasibility of control options for PM10/PM2.5 from the fugitive emissions resulting from Concrete Batch Plant material handling operations as well as NOx, PM10/PM2.5, CO, and VOC BACT analyses for combustion sources (i.e., engines/boiler). CMC Rock believes, for purposes of this NOI, a detailed and comprehensive “top-down” presentation is not necessary for the Proposed CMC Rock facility equipment because: 1. The equipment is relatively simple and control technology options are limited. 2. Prior analyses and process knowledge have defined BACT categorically and reiteration of the analyses is not necessary. Consequently, for each type of equipment covered in the NOI, BACT is identified and the basis for the choice is discussed. BACT FOR CONCRETE BATCH PLANT EMISSIONS With this NOI, CMC Rock has proposed a 250,000 cubic yards per year central mix concrete batch plant. The batch plant is comprised of three silos for cement and a fly ash silo. Cement is transferred to a surge hopper via screw conveyors. Screw conveyors transfer the various grades of cement to the weigh hopper. Fly Ash is also fed from the silo to the weigh scale with screw conveyors. The Cement and fly ash are then transferred to the central mix drum along with aggregate/sand and water. The silos are loaded from delivery trucks via pneumatic conveyors and emissions are controlled by dust collectors. Admixtures are also delivered by truck and transferred by electric driven pumps. The batch plant equipment is enclosed and equipped with a dust collector as well. All dust collectors have a vendor stated fabric filter control efficiency of at least 99%. The plant includes a recycled concrete crusher and associated material handling grizzly feeder, screen, conveyors and super-stacker. The concrete impactor and screen plant is controlled by water spray. PM10/PM2.5 fugitive emissions from material handling operations include stockpile activity and wind erosion. PM10/PM2.5 non-fugitive emissions resulting from the facility crusher and associated screen and conveying operations are subject to NSPS 40 CFR Part 60, Subpart OOO. An April 2023 search revealed a posted BACT Determination on the San Joaquin Valley Air Pollution Control District BACT Clearinghouse. The determination incorporates BACT findings from the EPA/RACT/BACT/LEAR Clearinghouse, the ARB BACT Clearinghouse of Santa Barbara County APCD, South Coast AQMD, San Diego County APCD, Bay Area AQMD, and Sacramento Metropolitan AWMD. That determination (Guideline 6.2.2, dated July 31, 2018) lists the following applicable, technologically feasible and achievable controls. 1) Sand and Aggregate storage: Outdoor storage piles adequately wetted to prevent visible emissions >5% opacity. 2) SAND/AGGREGATE Handling: Equipped with water sprays on all transfer points. 3) STORAGE SILOS for CEMENT and FLYASH: Enclosed silo vented to a control device with 99% efficiency (baghouse, bin vent or equivalent). 4) CEMENT/FLYASH WEIGH BATCHER: Enclosed weigh batcher vented to a control device with 99% efficiency (baghouse or equivalent). 5) CENTRAL MIXER LOADING: Enclosed mixer vented to a control device with 99% efficiency (baghouse or equivalent). For the planned CMC Rock Concrete Batch Plant Operation: The concrete crusher and material handling operation are controlled with water spray at all transfer points. The aggregate outdoor storage piles located at the plant are sprayed with water as needed to maintain an adequate moisture content. The proposed baghouse/fabric filters for the concrete batch plant silos and enclosed aggregate bins, cement surge hopper, conveyors, weigh scale and mixer provide equivalent or greater control than available controls identified in the published BACT determination. CMC Rock considers the water spray controls for the aggregate crusher, material handling and storage piles, as well as the planned baghouse/fabric filter dust collection controls, located at the silos and enclosed central mix plant equipment as BACT. BACT FOR HAUL ROADS FUGITIVE EMISSIONS Fugitive particulate emissions are associated with haul roads. The vehicular disturbance of dust generates PM10/PM2.5 emissions. UAC R307-205 Emissions Standards: Fugitive Emissions and Fugitive Dust, requires that new source haul roads meet a 20% opacity limit. The controls implemented must ensure that the opacity limit is not exceeded. DAQ-2018-007161, BACT for Small Sources, list the following control options for Haul Roads in Table 2 below. Table 2 Pollutant Source Control Options PM10/PM2.5 Fugitives Haul Roads Paved Road with Vacuum Sweeping and Watering Paved Road with Sweeping and Watering Chemical Suppressant and Watering Watering Sweeping, water spray and paving provide the highest level of control (90-95 percent per Utah Department of Environmental Quality memorandum, January 12, 2015) of PM10/PM2.5 emissions. This is considered BACT for the paved roads at the CMC Rock facility. Fugitive emissions are subject to the fugitive dust control plan requirement of R307-309-6. CMC Rock believes it can effectively control fugitive dust emissions according to a fugitive dust emissions control plan and will utilize water sprays and/or sweeping as needed to meet the 20% opacity limit. BACT FOR DIESEL-FIRED GENERATOR EMISSIONS CMC Rock will have one 450 HP diesel engine coupled to the crusher and a generator to provide electricity to equipment. Pollutant emissions from the internal combustion engine includes NOx, PM10, PM2.5, CO, SO2, and VOCs. The generator is subject to NSPS 40 CFR Part 60, Subpart IIII. DAQ-2018-007161, BACT for Small Sources, list the following control options for Diesel Engines in Table 3 below. Table 3 Pollutant Control Technology NOX Exhaust Gas Recirculation (EGR) NOx Adsorber Catalyst Selective Reduction Catalyst (SCR) Turbocharging and After-Cooling Engine Ignition Timing Retardation Modifying Air to Fuel Ratio SO2 Ultra Low-Sulfur Fuel VOC Catalyzed Diesel Particulate Filter Diesel Oxidation Catalyst PM10/PM2.5 Catalyzed Diesel Particulate Filter Diesel Oxidation Catalyst Diesel Particulate Filter CMC Rock intends to purchase Tier 4f Engine required by NSPS Subpart IIII equipped with EGR and SCR. Due to the emissions being relatively small, CMC Rock believes that the installation of any additional controls would not be cost effective for these engines. DAQ-2018-007161, BACT for Small Sources, states the “DAQ did not find any controls that were cost effective for controlling PM2.5 emissions or VOC emissions. The document also indicates that an engine that complies with NSPS Subpart IIII requirements would be considered BACT for NOx and that use of Ultra Low-Sulfur fuel is BACT for SO2. Therefore, CMC Rock has determined that purchase of NSPS Subpart IIII compliant engines, proper maintenance and operation of the stationary diesel engines, and use of ultra low-sulfur diesel fuel is considered BACT for these engines. BACT FOR GAS-FIRED BOILER EMISSIONS With this NOI, CMC Rock has proposed a 6.83 MMBtu/hr Polarmatic Turbomatic Heating System (boiler). The Turbomatic heating unit is specially designed for concrete batch plant applications; integrated into the design operation of the plant to exhaust the Turbogas through the filled aggregate bins to heat the aggregate. See figure 1. The primary pollutants from the combustion of natural gas in boilers are NOX and CO. Particulates, SO2, VOC, and HAP are emitted at lower levels. An emissions report from the vendor reflects a factory test run in Finland, using propane gas as the fuel. The test run was optimized for CO; not NOx. CO tested concentration was 1 ppm. Propane fuel combustion is expected to emit 2.3 times as much NOx compared to natural gas combustion.1 The expected equivalent NOx concentration from natural gas combustion is 47 ppm (108 ppm / 2.3). Additionally, the filled aggregate bins provide exhaust back pressure. This increased pressure reduces NOx emissions.2 Based on conversations with the vendor and review of the scientific research, this back pressure effect is assumed to cut the NOx concentration in half; approximately 24 ppm entering the aggregate bins. Lastly, the filled aggregate bins absorb the Turbogas, providing significant control of the NOx emissions. Although it is not possible to measure the NOx at the top of the bins (no available stack), the vendor has very conservatively assumed the aggregate absorption provides at least 50% control of the NOx entering the bins; approximately 12 ppm exhausting from the top of the bins. Overall, the NOx emissions from the integrated heating system, considering exhaust backpressure and absorption by the aggregate bins, is close to what you would expect from ultra-low NOx burners. Ultra-low NOx or low-NOx burners are typically considered BACT, if commercially available. As previously stated, the Turbomatic heating unit is a specially designed machine and the existing burner is an integrated part of the machine. A burner retrofit would 1 https://www.engineeringtoolbox.com/nox-emission-combustion-fuels-d_1086.html 2 F. Biagioli, F. Güthe, Effect of pressure and fuel-air unmixedness on NOx emissions from industrial gas turbine burners, Combustion and Flame Fuel require a complete redesign of the machine and concrete batch plant itself. Therefore, installation of a lower NOx burner is technologically infeasible. There are no NSPS regulations applicable to boilers with input ratings less than or equal to 10 MMBtu/hr and gas-fired boilers are exempt from the requirements of 40 CFR 63 JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers). There are no Utah State rules applicable to PM2.5 emissions from boilers rated less than 10 MMBtu/hr. According to DAQ-2018-007161, BACT for Small Sources, DAQ recommends the use of natural gas as primary fuel and good combustion practices as BACT for boilers with input ratings less than or equal to 10 MMBtu/hr. Directions: Plant Aggregate Processing Capacity 350000 Tons/yr Plant Maximum Production Capacity 250000 Yards Mix/yr Storage Pile Size 2.5 Acres Engines and Heaters units Natural Gas-fired Auxiliary Heater(s) Capacity -6.83 MMBtu/hr Total Diesel-fired Engine (Crusher) Size -450 hp Total Fuel Sulfur %0.0015 Default = 0.0015 1 MW = 3.415 MMBtu MMBtu = million British thermal units hp = horsepower Roadway Traffic - Paved Roads Vehicle Type Transit Mix TruckGravel/Sand Delivery Truck * Average weight = (Tare wt. + Gross (Loaded) Weight) / 2 18200 0.3329.25 43.5 15475 0.37 Is the Dry Mix and Water Mixed Prior to Loading (Mixer Loading) or After Loading (Truck Loading)? [Choose One]Mixer Loading Average Weight of Vehicles (tons)* Trip Number (trips/yr) Round Trip Distance (mile/trip) Potential To Emit Calculator for Concrete Batch Plants Enter the facility's information below in the cells with red text. If the throughput capacity of a piece of equipment limits (or bottlenecks) the maximum throughput of other equipment, then input the bottlenecked capacity of that other equipment, but only if it impacts output of product. Facility Profile tons/yr Process PM PM10 PM2.5 SO2 NOX CO VOC CO2e Total HAPsBatch Mix Operation 1.73 0.72 0.09 ----2.48E-04Aggregate Processing 1.33 0.65 0.01 -----Auxiliary Heater(s)0.22 0.22 0.22 0.02 0.43 2.46 0.16 3502.21 0.06Crusher Engine 0.09 0.09 0.09 0.02 1.30 11.30 4.87 2256.41 0.05Vehicle Traffic 3.85 1.18 0.14 -----Storage Piles 1.12 0.53 0.50 -----Diesel Fuel Tank ------1.26E-03 - Controlled Emissions (ton/yr)8.33 3.39 0.42 0.04 1.74 13.76 5.03 5758.62 0.11 Fugitive Sources (ton/yr)1.71 Non-fugitive Sources (ton/yr)1.68 Potential To Emit Calculator for Concrete Batch Plants Summary - Total Potential to Emit Pollutant Calculation Methodology Tons/yr Yards Mix/yr250000 PM PM10 PM2.53 PM PM10 PM2.53 250000 0.0015 0.0007 0.00009 0.19 0.09 0.01 250000 0.0064 0.0031 0.00040 0.80 0.39 0.05 250000 0.0002 0.0001 0.00001 0.03 0.01 0.00 250000 0.0003 0.0002 0.00003 0.04 0.03 0.00 250000 0.000015 7E-06 0.00000 0.00 0.00 0.00 250000 6.4E-05 0.000031 0.00000 0.01 0.00 0.00 250000 7.9E-05 0.000038 0.00000 0.01 0.00 0.00 250000 7.9E-05 0.000038 0.00000 0.01 0.00 0.00 70500 0.0184 0.0055 0.00072 0.65 0.19 0.03 PTE (ton/yr)1.73 0.72 0.09 Note: 1 2 3 4 5 6 99% Methodology PTE (ton/yr) = Throughput (tons/yr) x EF (lb/ton) x 1 ton/2000 lb PTE (ton/yr) = Yards mix/yr x EF (lb/yard) x 1 ton/2000 lb PM 2.5 emission factors are from AP-42, Chapter 11.12, Concrete Batching, Background Document, Table 17.1. (June 2006) Central Mix Loading factor is from AP-42, Chapter 11.12, Table 11.12-2, lb/ton of cement and cement supplement The emission factors in Tables 11.12-5 and 11.12-6 are based upon the following composition of one yard of concrete. Coarse Aggregate 1865 pounds Sand 1428 pounds Cement 491 pounds Cement Supplement 73 pounds Water 20 gallons (167 pounds) Total: 4024 lbs South Coast AQMD Particulate Matter (PM) Emission Factors For Processes/Equipment at Asphalt, Cement, Concrete, and Aggregate Product Plants (rev. Dec 2021) Control Efficiency for enclosed conveyors and weigh hopper: Plant Maximum Production Capacity Sand Unloading Mixer Loading4,5 Emission factors are in terms of lb/cy mix, except for mixer loading factor Emission factors are from AP-42, Chapter 11.12, Concrete Batching, Table11.12-6. (June 2006) Aggregate Unloading Cement - Unloading to Elevated Storage Cement Supplement - Unloading to Elevated Storage Sand - Transfer Conveyor Aggregate - Transfer Conveyor Cement Conveyor to Surge Hopper Weigh Hopper Loading Potential To Emit Calculator for Concrete Batch Plants Controlled Emissions from Concrete Batch Mix Materials Handling - Criteria Pollutants Emission Factor (lb/unit)6 Potential to Emit Calculation Methodology Tons/yr3 Arsenic Berylium Cadmium Chromium Lead Manganese Nickel Phosphorus Selenium Arsenic Berylium Cadmium Chromium Lead Manganese Nickel Phosphorus Selenium 61375 4.24E-09 4.86E-10 ND 2.90E-08 1.09E-08 1.17E-07 4.18E-08 ND ND 0.00 0.00 0.00 0.00 0.00 0.00 9125 1.00E-06 9.04E-08 1.98E-10 1.22E-06 5.20E-07 2.56E-07 2.28E-06 3.54E-06 7.24E-08 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 70500 2.96E-07 ND 7.10E-10 1.27E-07 3.66E-08 3.78E-06 2.48E-07 1.20E-06 ND 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PTE (ton/yr)1.51E-05 4.27E-07 2.59E-08 1.09E-05 4.00E-06 1.38E-04 2.04E-05 5.85E-05 3.30E-07 Note: 1 2 3 4 Methodology PTE (ton/yr) = Ton/yr x EF (lb/ton) x 1 ton/2000 lb Cement - Unloading to Elevated Storage Cement Supplement - Unloading to Elevated Storage Potential To Emit Calculator for Concrete Batch PlantsControlled Emissions from Concrete Batch Mix Materials Handling - Hazardous Air Pollutants Emission Factor (lb/unit)Potential to Emit Plant Maximum Production Capacity Mixer Loading3 Emission factors are in terms of lb/ton Emission factors are from AP-42, Chapter 11.12, Concrete Batching, Table11.12-8. (June 2006) The throughputs are based upon the following composition of one yard of concrete. Coarse Aggregate 1865 pounds Sand 1428 pounds Cement 491 pounds Cement Supplement 73 pounds Water 20 gallons (167 pounds) Total: 4024 lbs Central Mix Loading factor is from AP-42, Chapter 11.12, lb/ton of cement and cement supplement Calculation Methodology Tons/yr Number of PM PM10 PM2.5 PM PM10 PM2.5 350000 0.003 0.0012 0.00007 1 0.53 0.21 0.01 350000 0.0036 0.0022 ND 1 0.63 0.39 350000 0.00014 0.000046 ND 1 0.02 0.01 350000 0.00014 0.000046 ND 5 0.12 0.04 350000 0.00014 0.000046 ND 1 0.02 0.01 PTE (ton/yr)1.33 0.65 0.01 Note: 1 PTE (ton/yr) = Throughput (tons/yr) x EF (lb/ton) x 8760 hr x 1 ton/2000 lb Plant Maximum Production Capacity Crusher Potential To Emit Calculator for Concrete Batch Plants Controlled Emissions from Concrete Batch Aggregate Processing - Criteria Pollutants Emission Factor (lb/ton)Potential to Emit Screen Grizzly Feeder Transfer Point Conveyor Transfer Point Superstacker Transfer Point Emission Factors from AP-42, Chapter 11.19, Table 11.19.2-2 (controlled by wet suppression) Calculation Methodology Acre - Days2.5 PM PM10 PM2.53 PM PM10 PM2.5 821.25 2.64 1.26 1.188 1.08 0.52 0.49 91.25 0.7 0.34 0.315 0.03 0.02 0.01 PTE (ton/yr)1.12 0.53 0.50 Note: 1 2 3 PM Control Efficiency 80%PM10 Control Efficiency 80% PM2.5 Control Efficiency 40% Methodology PTE (ton/yr) = Throughput (tons/yr) x EF (lb/ton) x 8760 hr x 1 ton/2000 lb Plant Maximum Storage Pile Capacity (acres) Active Storage Pile2 Potential To Emit Calculator for Concrete Batch Plants Emissions from Aggregate/Sand Storage Piles - Criteria Pollutants Emission Factor (lb/Acre-Day)Potential to Emit Inactive Storage Pile (Wind Erosion Only)2 Emission Factors from San Diego County Air Pollution Control District, Material Storage Default Values (1/2022), adapted from AP-42, Chapter 8.19.1; Inlcudes the following distinct source operations in the storage cycle: (1) Loading of aggregate onto storage piles, (2) Equipment traffic in storage areas, (3) Wind erosion of pile. Assumes 8 to 12 hours of activity / 24 hours. Assumes 10% of days are inactive See AP-42 Appendix B.2 for particle size distribution of mechanically produced aggregate Natural Gas-fired Auxiliary Heater(s) Capacity -6.83 (MMBtu/hr) Worst Case PTE (ton/yr)PM PM10 PM2.5 SO2 NOX CO VOC HAPs 0.22 0.22 0.22 0.02 0.43 2.46 0.16 0.06 Fuel Type:Natural Gas Used Y PollutantPMPM102PM2.5 SO2 NOX3 CO VOC HAPs Emission Factor1 (lb/MMSCF)7.6 7.6 7.6 0.6 14.8 84 5.5 1.89 PTE (ton/yr)0.22 0.22 0.22 0.02 0.43 2.46 0.16 0.06 Note: 1. Emission factors (except NOx) are from AP-42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, and 1.4-4 (updated 07/98).2. Assumed PM and PM2.5 emissions are equal to PM10 emissions. 3. NOx emissions factor calculated from Vendor information Methodology PTE (ton/yr) = Heat Input (MMBtu/hr) x 1 MMSCF/1,020 MMBtu x EF (lb/MMSCF) x 8760 hr/yr x 1 ton/2000 lb Potential To Emit Calculator for Concrete Batch Plants Emissions from Auxiliary Heaters - Criteria Pollutants and Hazardous Air Pollutants Equation PPMV Values to Convert Pollutant PPMV Value Reference NOx 12 Pollutant Properties Pollutant Molar Weight Units Notes NOx 46.01 g/mol As NO2 Gas Properties Input Value Units Molar Volume 379.7 dscf/lb-mol at 1 atm and 60 °F Fd Factor 8710 Corrected Oxygen 3 percent Calculated lb/MMBtu Values Pollutant lb/MMBtu Value lb/MMScf Value NOx 0.0145 14.7545 CONVERT PPMV TO LB/MMBTU Vendor Information; 108 ppm / 2.3 (estimated from Propane combustion test result) * 50% (reduction from backpressure) * 50% (reduction from aggregate absorbent) dscf/MMBtu; Method 19, Table 19-2 450 hp Worst Case PTE (ton/yr)PM PM10 PM2.5 SO2 NOX CO VOC 0.09 0.09 0.09 0.02 1.30 11.30 4.87 Engine Type:Diesel Engine (<= 600 hp) Pollutant PM2,3 PM103 PM253 SO25 NOX2 CO2 VOC1,4 Emission Factor1 (lbs/hp-hr)4.41E-05 4.41E-05 4.41E-05 1.07E-05 6.61E-04 5.73E-03 2.47E-03 PTE (ton/yr)0.09 0.09 0.09 0.02 1.30 11.30 4.87 Note: 2. Tier 4 Diesel Engine Standards3. Assume PM and PM2.5 emissions are equal to PM10 emissions. 4. Assume TOC (total organic compounds) emissions equal to VOC emissions. 5. South Coast AQMD e.f. (rev. 2021): 0.21 lb/1000 gal * gal/138,000 btu * 7000 btu/hp-hr 6. Assume 8760 hours/yr of operation for a non-emergency engine Methodology PTE (ton/yr) = Engine Capacity (hp) x EF (lb/hp-hr) x 8760 hr x 1 ton/2000 lb Potential To Emit Calculator for Concrete Batch Plants Emissions from Non-Emergency Generator Engine - Criteria Pollutants and Hazardous Air Pollutants Diesel-fired Emergency Generator Engine Size: HAPs 0.0523 HAPs1 2.65328E-05 0.0523 AP 42 Emission Factors - Unpaved Roads E = k*(s/12)a (w/3)b) Where: E = emission factor (lb/vehicle mile traveled)Reference: k = empirical constant =4.9 for PM AP-42, Table 13.2.2-2 1.5 for PM10 AP-42, Table 13.2.2-2 0.15 for PM2.5 AP-42, Table 13.2.2-2 a = empirical constant =0.9 for PM AP-42, Table 13.2.2-2 0.9 for PM10 AP-42, Table 13.2.2-2 0.7 for PM2.5 AP-42, Table 13.2.2-2 0.45 for PM10 AP-42, Table 13.2.2-2 0.45 for PM2.5 AP-42, Table 13.2.2-2 s = road surface silt content =4.8 %AP-42, Table 13.2.2-1 Transit Mix Truck w = mean vehicle weight (tons) =29.3 tons Gravel/Sand Delivery Truck w = mean vehicle weight (tons) =43.5 tons The source will use paved roads with periodic sweeping and/or basic watering to control the fugitive dust emissions. Paved Control Efficiency (%):90% PM PM10 PM2.5 Transit Mix Truck 0.60 0.18 0.02 Gravel/Sand Delivery Truck 0.72 0.22 0.03 Potential to Emit Vehicle Traffic Road Type Avg. Wt. Trips/year Distance PM PM10 PM2.5 Paved Roads 29.25 18200 0.33 1.797 0.550 0.066 Paved Roads 43.5 15475 0.37 2.049 0.627 0.075 PTE (ton/yr)3.85 1.18 0.14 Methodology: PTE (tons/yr) = Trips/yr x Distance (miles) x Emission Factor (lb/mile) x 1 ton/2,000 lbs Note: 1 Vehicle Type Transit Mix Truck Gravel/Sand Delivery Truck Emission Factors from AP-42, Chapter 13.2.2; UDAQ guidance offers an alternative to use the "unpaved" roads emission factors and applying a control efficiency for paving, watering and sweeping. Potential To Emit Calculator for Concrete Batch Plants Emissions from Vehicle Traffic - Criteria Pollutants According to AP 42, Chapter 13.2.2 - Unpaved Roads (01/2011), the PM/PM10/PM2.5 emission factors for paved roads can be estimated from the following equation: Emission Factors (lb/mile) Pollutant Source Fuel Throughput Units Annual Operating Hours Conversions Natural Gas-fired Auxiliary Heater(s)Natural Gas 6.83 MMBtu/Hr 8760 Diesel Fired Engine(s)Diesel 450 HP 8760 7000 btu/hp-hr Table C-1 (EPA Default High Heat Values and Emission Factors) Default Emission Factor kg CO2 / MMBtu kg CH4/MMBtu kg NO2/MMBtu Natural Gas 53.06 1.0E-03 1.0E-04 No. 2 Fuel Oil 73.96 3.0E-03 6.0E-04 Still Gas 66.72 LPG 61.71 3.0E-03 6.0E-04 Propane 62.87 3.0E-03 6.0E-04 Isobutane 64.94 3.0E-03 6.0E-04 Butane 64.77 3.0E-03 6.0E-04 Conversion from BTU to Dth is 1.00 Dth = 1,000,000 Btu CO2 Equivalent Emissions; Global Warming Potential (GWP) Factors 1 28 265 GWP factors effective July 2023; AR5 CO2 CH4 N2O metric tons metric tons metric tons Natural Gas-fired Auxiliary Heater(s)3174.79 5.98E-02 5.98E-03 Diesel Fired Engine(s)2040.85 8.28E-02 1.66E-02 Potential To Emit Calculator for Concrete Batch Plants Emissions - Green House Gas Pollutants CO2e CO2e metric tons tons Natural Gas-fired Auxiliary Heater(s)3178.05 3502.21 Diesel Fired Engine(s)2047.56 2256.41 Energy 1 Dth (or 1 MMBtu) 59833.94 27594.00 Directions: Plant Aggregate Processing Capacity 350000 Tons/yr Plant Maximum Production Capacity 250000 Yards Mix/yr Storage Pile Size 2.5 Acres Engines and Heaters units Natural Gas-fired Auxiliary Heater(s) Capacity -6.83 MMBtu/hr Total Diesel-fired Engine (Crusher) Size -450 hp Total Fuel Sulfur %0.0015 Default = 0.0015 1 MW = 3.415 MMBtu MMBtu = million British thermal units hp = horsepower Roadway Traffic - Paved Roads Vehicle Type Transit Mix Truck Gravel/Sand Delivery Truck * Average weight = (Tare wt. + Gross (Loaded) Weight) / 2 18200 0.3329.25 43.5 15475 0.37 Is the Dry Mix and Water Mixed Prior to Loading (Mixer Loading) or After Loading (Truck Loading)? [Choose One]Mixer Loading Average Weight of Vehicles (tons)* Trip Number (trips/yr) Round Trip Distance (mile/trip) Potential To Emit Calculator for Concrete Batch Plants Enter the facility's information below in the cells with red text. If the throughput capacity of a piece of equipment limits (or bottlenecks) the maximum throughput of other equipment, then input the bottlenecked capacity of that other equipment, but only if it impacts output of product. Facility Profile tons/yr Process PM PM10 PM2.5 SO2 NOX CO VOC Total HAPs Batch Mix Operation 1.73 0.72 0.09 ----2.48E-04 Aggregate Processing 1.33 0.65 0.01 ----- Auxiliary Heater(s)0.22 0.22 0.22 0.02 0.43 2.46 0.16 0.06 Crusher Engine 0.09 0.09 0.09 0.02 1.30 11.30 4.87 0.05 Vehicle Traffic 3.85 1.18 0.14 ----- Storage Piles 1.12 0.53 0.50 ----- Controlled Emissions (ton/yr)8.33 3.39 0.42 0.04 1.74 13.76 5.03 0.11 Fugitive Sources (ton/yr)1.71 Non-fugitive Sources (ton/yr)1.68 Potential To Emit Calculator for Concrete Batch Plants Summary - Total Potential to Emit Pollutant Calculation Methodology Tons/yr Yards Mix/yr250000 PM PM10 PM2.53 PM PM10 PM2.53 250000 0.0015 0.0007 0.00009 0.19 0.09 0.01 250000 0.0064 0.0031 0.00040 0.80 0.39 0.05 250000 0.0002 0.0001 0.00001 0.03 0.01 0.00 250000 0.0003 0.0002 0.00003 0.04 0.03 0.00 250000 0.000015 7E-06 0.00000 0.00 0.00 0.00 250000 6.4E-05 0.000031 0.00000 0.01 0.00 0.00 250000 7.9E-05 0.000038 0.00000 0.01 0.00 0.00 250000 7.9E-05 0.000038 0.00000 0.01 0.00 0.00 70500 0.0184 0.0055 0.00072 0.65 0.19 0.03 PTE (ton/yr)1.73 0.72 0.09 Note: 1 2 3 4 5 6 99% Methodology PTE (ton/yr) = Throughput (tons/yr) x EF (lb/ton) x 1 ton/2000 lb PTE (ton/yr) = Yards mix/yr x EF (lb/yard) x 1 ton/2000 lb PM 2.5 emission factors are from AP-42, Chapter 11.12, Concrete Batching, Background Document, Table 17.1. (June 2006) Central Mix Loading factor is from AP-42, Chapter 11.12, Table 11.12-2, lb/ton of cement and cement supplement The emission factors in Tables 11.12-5 and 11.12-6 are based upon the following composition of one yard of concrete. Coarse Aggregate 1865 pounds Sand 1428 pounds Cement 491 pounds Cement Supplement 73 pounds Water 20 gallons (167 pounds) Total: 4024 lbs South Coast AQMD Particulate Matter (PM) Emission Factors For Processes/Equipment at Asphalt, Cement, Concrete, and Aggregate Product Plants (rev. Dec 2021) Control Efficiency for enclosed conveyors and weigh hopper: Plant Maximum Production Capacity Sand Unloading Mixer Loading4,5 Emission factors are in terms of lb/cy mix, except for mixer loading factor Emission factors are from AP-42, Chapter 11.12, Concrete Batching, Table11.12-6. (June 2006) Aggregate Unloading Cement - Unloading to Elevated Storage Cement Supplement - Unloading to Elevated Storage Sand - Transfer Conveyor Aggregate - Transfer Conveyor Cement Conveyor to Surge Hopper Weigh Hopper Loading Emissions Controlled Emissions from Concrete Batch Mix Materials Handling - Criteria Pollutants Emission Factor (lb/unit)6 Potential to Emit Calculation Methodology Tons/yr3 Arsenic Berylium Cadmium Chromium Lead Manganese Nickel Phosphorus Selenium Arsenic Berylium Cadmium Chromium Lead Manganese Nickel Phosphorus Selenium 61375 4.24E-09 4.86E-10 ND 2.90E-08 1.09E-08 1.17E-07 4.18E-08 ND ND 0.00 0.00 0.00 0.00 0.00 0.00 9125 1.00E-06 9.04E-08 1.98E-10 1.22E-06 5.20E-07 2.56E-07 2.28E-06 3.54E-06 7.24E-08 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 70500 2.96E-07 ND 7.10E-10 1.27E-07 3.66E-08 3.78E-06 2.48E-07 1.20E-06 ND 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PTE (ton/yr)1.51E-05 4.27E-07 2.59E-08 1.09E-05 4.00E-06 1.38E-04 2.04E-05 5.85E-05 3.30E-07 Note: 1 2 3 4 Methodology PTE (ton/yr) = Ton/yr x EF (lb/ton) x 1 ton/2000 lb Cement - Unloading to Elevated Storage Cement Supplement - Unloading to Elevated Storage Potential To Emit Calculator for Concrete Batch PlantsControlled Emissions from Concrete Batch Mix Materials Handling - Hazardous Air Pollutants Emission Factor (lb/unit)Potential to Emit Plant Maximum Production Capacity Mixer Loading3 Emission factors are in terms of lb/ton Emission factors are from AP-42, Chapter 11.12, Concrete Batching, Table11.12-8. (June 2006) The throughputs are based upon the following composition of one yard of concrete. Coarse Aggregate 1865 pounds Sand 1428 pounds Cement 491 pounds Cement Supplement 73 pounds Water 20 gallons (167 pounds) Total: 4024 lbs Central Mix Loading factor is from AP-42, Chapter 11.12, lb/ton of cement and cement supplement Calculation Methodology Tons/yr Units PM PM10 PM2.5 PM PM10 PM2.5 350000 0.003 0.0012 0.00007 1 0.53 0.21 0.01 350000 0.0036 0.0022 ND 1 0.63 0.39 350000 0.00014 0.000046 ND 1 0.02 0.01 350000 0.00014 0.000046 ND 5 0.12 0.04 350000 0.00014 0.000046 ND 1 0.02 0.01 PTE (ton/yr)1.33 0.65 0.01 Note: 1 PTE (ton/yr) = Throughput (tons/yr) x EF (lb/ton) x 8760 hr x 1 ton/2000 lb Plant Maximum Production Capacity Crusher Potential To Emit Calculator for Concrete Batch Plants Controlled Emissions from Concrete Batch Aggregate Processing - Criteria Pollutants Emission Factor (lb/ton)Potential to Emit Screen Grizzly Feeder Transfer Point Conveyor Transfer Point Superstacker Transfer Point Emission Factors from AP-42, Chapter 11.19, Table 11.19.2-2 (controlled by wet suppression) Calculation Methodology Acre - Days2.5 PM PM10 PM2.53 PM PM10 PM2.5 821.25 2.64 1.26 1.188 1.08 0.52 0.49 91.25 0.7 0.34 0.315 0.03 0.02 0.01 PTE (ton/yr)1.12 0.53 0.50 Note: 1 2 3 PM Control Efficiency 80%PM10 Control Efficiency 80% PM2.5 Control Efficiency 40% Methodology PTE (ton/yr) = Throughput (tons/yr) x EF (lb/ton) x 8760 hr x 1 ton/2000 lb Plant Maximum Storage Pile Capacity (acres) Active Storage Pile2 Potential To Emit Calculator for Concrete Batch Plants Emissions from Aggregate/Sand Storage Piles - Criteria Pollutants Emission Factor (lb/Acre-Day)Potential to Emit Inactive Storage Pile (Wind Erosion Only)2 Emission Factors from San Diego County Air Pollution Control District, Material Storage Default Values (1/2022), adapted from AP-42, Chapter 8.19.1; Inlcudes the following distinct source operations in the storage cycle: (1) Loading of aggregate onto storage piles, (2) Equipment traffic in storage areas, (3) Wind erosion of pile. Assumes 8 to 12 hours of activity / 24 hours. Assumes 10% of days are inactive See AP-42 Appendix B.2 for particle size distribution of mechanically produced aggregate Natural Gas-fired Auxiliary Heater(s) Capacity -6.83 (MMBtu/hr) Worst Case PTE (ton/yr)PM PM10 PM2.5 SO2 NOX CO VOC HAPs 0.22 0.22 0.22 0.02 0.43 2.46 0.16 0.06 Fuel Type:Natural Gas Used Y Pollutant PM PM102 PM2.5 SO2 NOX3 CO VOC HAPs Emission Factor1 (lb/MMSCF)7.6 7.6 7.6 0.6 14.8 84 5.5 1.89 PTE (ton/yr)0.22 0.22 0.22 0.02 0.43 2.46 0.16 0.06 Note: 1. Emission factors (except NOx) are from AP-42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, and 1.4-4 (updated 07/98).2. Assumed PM and PM2.5 emissions are equal to PM10 emissions. 3. NOx emissions factor calculated from Vendor information Methodology PTE (ton/yr) = Heat Input (MMBtu/hr) x 1 MMSCF/1,020 MMBtu x EF (lb/MMSCF) x 8760 hr/yr x 1 ton/2000 lb Potential To Emit Calculator for Concrete Batch Plants Emissions from Auxiliary Heaters - Criteria Pollutants and Hazardous Air Pollutants Equation PPMV Values to Convert Pollutant PPMV Value Reference NOx 12 Pollutant Properties Pollutant Molar Weight Units Notes NOx 46.01 g/mol As NO2 Gas Properties Input Value Units Molar Volume 379.7 dscf/lb-mol at 1 atm and 60 °F Fd Factor 8710 Corrected Oxygen 3 percent Calculated lb/MMBtu Values Pollutant lb/MMBtu Value lb/MMScf Value NOx 0.0145 14.7545 CONVERT PPMV TO LB/MMBTU Vendor Information; 108 ppm / 2.3 (estimated from Propane combustion test result) * 50% (reduction from backpressure) * 50% (reduction from aggregate absorbent) dscf/MMBtu; Method 19, Table 19-2 450 hp Worst Case PTE (ton/yr)PM PM10 PM2.5 SO2 NOX CO VOC 0.09 0.09 0.09 0.02 1.30 11.30 4.87 Engine Type:Diesel Engine (<= 600 hp) Pollutant PM2,3 PM103 PM2.53 SO25 NOX2 CO2 VOC1,4 Emission Factor1 (lbs/hp-hr)4.41E-05 4.41E-05 4.41E-05 1.07E-05 6.61E-04 5.73E-03 2.47E-03 PTE (ton/yr)0.09 0.09 0.09 0.02 1.30 11.30 4.87 Note: 2. Tier 4 Diesel Engine Standards 3. Assume PM and PM2.5 emissions are equal to PM10 emissions. 4. Assume TOC (total organic compounds) emissions equal to VOC emissions. 5. South Coast AQMD e.f. (rev. 2021): 0.21 lb/1000 gal * gal/138,000 btu * 7000 btu/hp-hr 6. Assume 8760 hours/yr of operation for a non-emergency engine Methodology PTE (ton/yr) = Engine Capacity (hp) x EF (lb/hp-hr) x 8760 hr x 1 ton/2000 lb Potential To Emit Calculator for Concrete Batch Plants Emissions from Non-Emergency Generator Engine - Criteria Pollutants and Hazardous Air Pollutants Diesel-fired Emergency Generator Engine Size: HAPs 0.0523 HAPs1 2.65328E-05 0.0523 AP 42 Emission Factors - Unpaved Roads E = k*(s/12)a (w/3)b) Where: E = emission factor (lb/vehicle mile traveled)Reference: k = empirical constant =4.9 for PM AP-42, Table 13.2.2-2 1.5 for PM10 AP-42, Table 13.2.2-2 0.15 for PM2.5 AP-42, Table 13.2.2-2 a = empirical constant =0.9 for PM AP-42, Table 13.2.2-2 0.9 for PM10 AP-42, Table 13.2.2-2 0.7 for PM2.5 AP-42, Table 13.2.2-2 0.45 for PM10 AP-42, Table 13.2.2-2 0.45 for PM2.5 AP-42, Table 13.2.2-2 s = road surface silt content =4.8 %AP-42, Table 13.2.2-1 Transit Mix Truck w = mean vehicle weight (tons) =29.3 tons Gravel/Sand Delivery Truck w = mean vehicle weight (tons) =43.5 tons The source will use paved roads with periodic sweeping and/or basic watering to control the fugitive dust emissions. Paved Control Efficiency (%):90% PM PM10 PM2.5 Transit Mix Truck 0.60 0.18 0.02 Gravel/Sand Delivery Truck 0.72 0.22 0.03 Potential to Emit Vehicle Traffic Road Type Avg. Wt. Trips/year Distance PM PM10 PM2.5 Paved Roads 29.25 18200 0.33 1.797 0.550 0.066 Paved Roads 43.5 15475 0.37 2.049 0.627 0.075 PTE (ton/yr)3.85 1.18 0.14 Methodology: PTE (tons/yr) = Trips/yr x Distance (miles) x Emission Factor (lb/mile) x 1 ton/2,000 lbs Note: 1 Vehicle Type Transit Mix Truck Gravel/Sand Delivery Truck Emission Factors from AP-42, Chapter 13.2.2; UDAQ guidance offers an alternative to use the "unpaved" roads emission factors and applying a control efficiency for paving, watering and sweeping. Potential To Emit Calculator for Concrete Batch Plants Emissions from Vehicle Traffic - Criteria Pollutants According to AP 42, Chapter 13.2.2 - Unpaved Roads (01/2011), the PM/PM10/PM2.5 emission factors for paved roads can be estimated from the following equation: Emission Factors (lb/mile) Pollutant 3/14/24, 12:46 AM State of Utah Mail - CMC Rock NSR Application https://mail.google.com/mail/u/1/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1793348019919600593&simpl=msg-f:1793348019919600593 1/3 Enqiang He <ehe@utah.gov> CMC Rock NSR Application taylor@cmcrock.com <taylor@cmcrock.com>Tue, Mar 12, 2024 at 12:59 PM To: Enqiang He <ehe@utah.gov> Cc: Sam Cusick <samc@cmcrock.com> EQ, Attached you will find the calculations. We apologize but thought we had included some of these items in the last email. Also see my responses in red below. Thanks, Taylor Larson C: (801)369-0022 E: taylor@cmcrock.com From: Enqiang He <ehe@utah.gov> Sent: Tuesday, February 27, 2024 12:10 AM To: taylor@cmcrock.com Cc: Sam Cusick <samc@cmcrock.com> Subject: Re: CMC Rock NSR Applicaon Sam and Talor, I have finished reviewing the documents submitted last december. I have the following questions. Some of the questions were those I made in the email dated 9/14/23. I'm seeking your help with answers: 1. Is there any manufacturer's statement or tests regarding back pressure and absorption effect of the filled aggregate that can significantly reduce NOx emissions in the flue gas from the boiler/heater? Here is a statement 3/14/24, 12:46 AM State of Utah Mail - CMC Rock NSR Application https://mail.google.com/mail/u/1/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1793348019919600593&simpl=msg-f:1793348019919600593 2/3 received back from the manufacturer regarding the absorption and back pressure. “Secondly, this is the value after burner, before the TURBOgas, consisting of the flue gases and vapor, is led to aggregate bins filled with sand and stone. The material in the bins causes back pressure into the pipeline, through which the TURBOgas is led to the aggregate bins. It is found in scientific research that when pressure increases, the NOX value goes down, reference: [F. Biagioli, F. Güthe, Effect of pressure and fuel-air unmixedness on NOx emis-sions from industrial gas turbine burners, Combustion and Flame]. This already reduces the NOX remarkably prior to entering the aggregate bins.” 2. Provide the manufacturer's or installer's recommended pressure drop ranges for the baghouses. See below spec for bag houses. 3. Provide greenhouse gas (GHG) emission calculations. See attached 4. Are there diesel storage tanks on site? if yes, provide the tank capacity and emissions. See attached 5. Are there any disturbed areas on site? If yes, calculate emissions. All areas have been covered with gravel. [Quoted text hidden] 3/14/24, 12:46 AM State of Utah Mail - CMC Rock NSR Application https://mail.google.com/mail/u/1/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1793348019919600593&simpl=msg-f:1793348019919600593 3/3 [Quoted text hidden] PTE Calculations CMC Heber Central Mix Plant 3.11.2024.xlsx 328K 2/21/24, 10:33 AM State of Utah Mail - CMC Rock NSR Application https://mail.google.com/mail/u/1/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-a:r-3500422745614232866&simpl=msg-a:r-35004227456142…1/1 Enqiang He <ehe@utah.gov> CMC Rock NSR Application Enqiang He <ehe@utah.gov>Thu, Sep 14, 2023 at 6:49 PM To: Sam Cusick <samc@cmcrock.com> Cc: Taylor Larson <taylor@cmcrock.com> Sam, I have conducted technical reviews on your permit application (NOI). Here are some questions I'd like to ask you for help: 1. The capacities for conveyors/stackers are listed in tons per hour. We need their physical sizes, for example, 10' x 8'. 2. BACT analysis for the hot water boiler is inadequate. NOx concentration of 140 ppm seems very high. We'd like to see if low NOx burners and/or ultra-low NOx burners could be economically feasible to bring down the emissions. 3. Are there any disturbed areas on site not counting haul roads and storage piles? 4. Are there any fuel storage tanks on site? 5. Please show correct sources of emission factors for aggregate/sand storage piles. Maybe it's a good idea to email us a copy of spreadsheets that would show how the emission factors and emissions were calculated. Let me know if you have any questions. Please Provide the above information so we can move forward. Thank you. EQ He, CPM Permitting Engineer, Minor NSR Section, Permitting Branch | Division of Air Quality 1950 West 195 North, Salt Lake City, UT 84116 Phone: (801) 556-1580 ehe@utah.gov [Quoted text hidden]