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HomeMy WebLinkAboutDAQ-2024-011120 DAQE-AN114360003-24 {{$d1 }} Lee Ware Kilgore Companies, LLC PO Box 869 Magna, UT 84044 lee.ware@kilgorecompanies.com Dear Mr. Ware: Re: Approval Order: Minor Modification to Approval Order DAQE-AN114360002-16 to add a Crusher and Storage Tank and Remove Equipment Project Number: N114360003 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on November 16, 2023. Kilgore Companies, LLC must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Dylan Frederick, who can be contacted at (385) 306-6529 or dfrederick@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:DF:jg cc: Utah 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 October 7, 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-AN114360003-24 Minor Modification to Approval Order DAQE-AN114360002-16 to add a Crusher and Storage Tank and Remove Equipment Prepared By Dylan Frederick, Engineer (385) 306-6529 dfrederick@utah.gov Issued to Kilgore Companies, LLC - Highland Pit Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality October 7, 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 .................................................................................... 4 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 6 PERMIT HISTORY ................................................................................................................... 10 ACRONYMS ............................................................................................................................... 11 DAQE-AN114360003-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Kilgore Companies, LLC Kilgore Companies, LLC - Highland Pit Mailing Address Physical Address PO Box 869 4600 West 11200 North Magna, UT 84044 Highland City, UT 84060 Source Contact UTM Coordinates Name: Lee Ware 435,200 m Easting Phone: (801) 831-7402 4,476,500 m Northing Email: lee.ware@kilgorecompanies.com Datum NAD83 UTM Zone 12 SIC code 1442 (Construction Sand & Gravel) SOURCE INFORMATION General Description Kilgore Companies, LLC (Kilgore) owns and operates the Highland Aggregate Plant. Aggregate material is moved from the mining area to the feeder. From the feeder, the material is crushed and screened. The sorted material is then transported off-site. The plant processes up to 1,650,000 tons of aggregate material annually. NSR Classification Minor Modification at Minor Source Source Classification Located in Provo UT PM2.5 NAA Utah 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 Title V (Part 70) Area Source DAQE-AN114360003-24 Page 4 Project Description Kilgore has requested the following additions to the approval order: 1. Installation of a Jaw Crusher rated 600 tph. 2. Installation of a 5,000-gallon diesel storage tank with an annual throughput of 25,000 gallons. Kilgore has also requested the removal of a double deck screen, concrete batch truck mix, storage silos, and water heater from the approval order. Emission estimates for the new equipment have been made, and modeling requirements have been updated. 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 0 264.00 Carbon Monoxide 0 0.30 Nitrogen Oxides 0 0.98 Particulate Matter - PM10 0.12 28.55 Particulate Matter - PM2.5 0.02 8.57 Sulfur Dioxide 0 0.05 Volatile Organic Compounds 0 0.08 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 20 Change (TPY) Total (TPY) Total HAPs 0 0.01 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] DAQE-AN114360003-24 Page 5 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] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Highland Aggregate Pit and Wash Plant II.A.2 One (1) Triple-Deck Wet Screen Size: 8' x 20' Manufacturer: Cedar Rapids II.A.3 Two (2) Twin Sand Screws* Sand Screw #1 Size: 44" x 32' Manufacturer: Eagle Sand Screw #2 Size: 66" x 35' Manufacturer: Aztec *Included for informational purposes only. II.A.4 Two (2) Double Screens Size: 5' x 16' each Manufacturer: JCI II.A.5 One (1) Jaw Crusher Capacity: 600 tph DAQE-AN114360003-24 Page 6 II.A.6 One (1) Cone Crusher One (1) cone crusher Capacity: 300 tph Model Number: MVP-450X Serial Number: TRXRX450EOKFEO762 Manufacture Date: May 2015 II.A.7 Various Conveyors and Stackers II.A.8 One (1) Track-Mounted Jaw Crusher Capacity: 200 tph II.A.9 One (1) Crusher Engine Rating: 300 hp Fuel: Diesel Fuel Emission Standard: Tier IV Transitional (Manufactured after 2011) II.A.10 One (1) Diesel Storage Tank Capacity: 12,000 gallons II.A.11 One (1) Diesel Storage Tank Capacity: 5,000 gallons II.A.12 Various Water and Admixture Storage Tanks *listed for informational purposes only. II.A.13 Various Mobile Equipment Includes: Bulldozers, Track Hoes, Back Hoes, Loaders, Water Trucks, Haul Trucks, etc. *listed for informational purposes only. SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 The Highland Aggregate Pit shall be subject to the following: II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20 percent opacity. [R307-305-3] II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3] II.B.2 The Aggregate Processing Equipment shall be subject to the following: II.B.2.a The owner/operator shall not produce more than 1,650,000 tons of aggregate per rolling 12-month period. [R307-401-8] DAQE-AN114360003-24 Page 7 II.B.2.a.1 The owner/operator shall: A. Determine production by scale house records or vendor receipts. B. Record production on a daily basis. C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.2.a.2 The owner/operator shall weigh and account for all aggregate material prior to the aggregate material leaving the site or being used in another process on site. [R307-401-8] II.B.2.b The owner/operator shall not operate the aggregate processing plant and associated equipment more than 4,000 hours per rolling 12-month period and 16 hours per day. [R307-410-4] II.B.2.b.1 The owner/operator shall: A. Determine hours of operation with a supervisor monitoring and maintaining an operations log. B. Record hours of operation each day. C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8] II.B.2.c The owner/operator shall install and operate a feeder and conveyor transfer system in the mining area. Aggregate material shall be loaded into the feeder, and the conveyor transfer system shall transport all aggregate material to be processed to the aggregate processing plant. [R307-401-8] II.B.2.d The owner/operator shall not allow visible emissions from any crusher on site to exceed 12 percent opacity on site and 10 percent opacity at property boundary. [R307-312] II.B.2.e The owner/operator shall not allow visible emissions from any screen on site to exceed 7 percent opacity. [R307-312] II.B.2.f The owner/operator shall not allow visible emissions from any conveyor transfer point on site to exceed 7 percent opacity. [R307-312] II.B.2.f.1 The owner/operator shall conduct visible emission observations for each conveyor transfer point that relies on water carryover at least once per week. The records will include the following: A. Date of each observation. B. Time of each observation. C. The result of each opacity observation. [R307-401-8] DAQE-AN114360003-24 Page 8 II.B.2.g The owner/operator shall not allow visible emissions from any conveyor drop point to exceed 20 percent opacity on site and 10 percent opacity at property boundary. [R307-309-5] II.B.2.h The owner/operator shall install water sprays or chemical dust suppression sprays on crushers, screens, and conveyor transfer points as needed to control fugitive emissions. Sprays shall operate as needed when the temperature is above freezing to maintain the opacity limits listed in this AO. [R307-401-8] II.B.2.i The moisture content of the aggregate material being processed in the aggregate processing plant shall not be less than 4.0 percent. [R307-401-8] II.B.2.i.1 The owner/operator shall measure the moisture content of the aggregate material from each crusher and from each screen that does not have water sprays installed at least once per month. Moisture content shall be determined by ASTM Method D2216, D4643, D4959, or approved equivalent. Records shall include the following: A. Location of each sample. B. The date and time when each sample was taken. C. The moisture content of each sample. [R307-401-8] II.B.2.j The owner/operator shall inspect the upstream water sprays of conveyor transfer points that rely on water carryover to control fugitive emissions at least once per month to check that water is flowing to the spray nozzles. [R307-401-8] II.B.2.j.1 The owner/operator shall: A. Record the date and time of each inspection. B. The status of the water sprays. C. Any corrective action taken. [R307-401-8] II.B.3 The Track-Mounted Jaw Crusher and the Crusher Engine shall be subject to the following: II.B.3.a The Track-Mounted Jaw Crusher shall not produce more than 40,000 tons of aggregate per rolling 12-month period. [R307-401-8] II.B.3.a.1 The owner/operator shall: A. Determine production by examination of belt scale and/or bucket scale 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.3.b The Crusher Engine shall not consume more than 2,400 gallons of diesel fuel per rolling 12-month period. [R307-401-8] DAQE-AN114360003-24 Page 9 II.B.3.b.1 The owner/operator shall: A. Determine fuel consumption by examination of supervisor monitoring and maintaining of an operations log. B. Record consumption on a daily basis. C. Use the consumption data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep consumption records for all periods when the plant is in operation. [R307-401-8] II.B.3.c The owner/operator shall not allow visible emissions from the Crusher Engine to exceed 20 percent opacity. [R307-305-3] II.B.3.d The sulfur content of any diesel fuel burned in any diesel engine on site shall not exceed 15 ppm by weight. [40 CFR 60 Subpart IIII] II.B.3.d.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved equivalent. Certification of diesel fuel shall be either by the owner/operator's own testing or by test reports from the diesel fuel marketer. [R307-203-1] II.B.4 The Bulldozing Operations on site shall be subject to the following: II.B.4.a All bulldozers on site shall not exceed 4,000 hours of operation combined per rolling 12-month period. [R307-401-8] II.B.4.a.1 The owner/operator shall: A. Determine hours of operation by supervisor monitoring and maintenance of an operations log. B. Record hours of operation on a daily basis. C. Keep records of the number of hours each bulldozer operated each day and the total hours of operation for all bulldozers each day. D. Use the operations log to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. E. Keep operation records for all periods when the plant is in operation. [R307-401-8] II.B.5 All Haul Roads and Fugitive Dust Sources on site shall be subject to the following: II.B.5.a The owner/operator shall apply chemical dust suppressants on all unpaved haul roads and operational areas and shall use water application on all haul roads to maintain opacity limits listed in this AO. The owner/operator may stop applying water to the haul roads, loader routes, and wheeled-vehicle operational areas when the temperature is below freezing but shall still maintain the opacity limits listed in this AO. [R307-401-8] DAQE-AN114360003-24 Page 10 II.B.5.a.1 Records of chemical application and water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made. B. Number of treatments made and quantity of water applied. C. Rainfall amount received, if any. D. Records of temperature, if the temperature is below freezing. [R307-401-8] II.B.5.b The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20 percent opacity on site and 10 percent opacity at the property boundary. [R307-309-5] II.B.5.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5] II.B.5.c The haul road to the aggregate processing plant shall not exceed 1.01 miles in length (2.02 miles round-trip). [R307-401-8] II.B.5.d The owner/operator shall apply water to the storage piles and disturbed or stripped areas on site to maintain the opacity limits listed in this AO. Control of disturbed or stripped areas is required at all times (24 hours per day, every day) for the duration of the project/operation until the area is reclaimed. Records of treatment and/or reclamation shall be kept for all periods when the plant is in operation. [R307-401-8] II.B.5.e The owner/operator shall comply with all applicable requirements of R307-309 for Fugitive Emission and Fugitive Dust sources on site. [R307-309] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN114360002-16 dated March 7, 2016 Is Derived From NOI dated November 16, 2023 Incorporates Additional Information dated January 11, 2024 Incorporates Additional Information dated April 3, 2024 DAQE-AN114360003-24 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 DAQE-IN114360003-24 August 26, 2024 Lee Ware Kilgore Companies, LLC PO Box 869 Magna, UT 84044 lee.ware@kilgorecompanies.com Dear Mr. Ware: Re: Intent to Approve: Minor Modification to Approval Order DAQE-AN114360002-16 to add a Crusher and Storage Tank and Remove Equipment Project Number: N114360003 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, Dylan Frederick, as well as the DAQE number as shown on the upper right-hand corner of this letter. Dylan Frederick, can be reached at (385) 306-6529 or dfrederick@utah.gov, if you have any questions. Sincerely, {{$s }} Alan D. Humpherys, Manager New Source Review Section ADH:DF:jg cc: Utah County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN114360003-24 Minor Modification to Approval Order DAQE-AN114360002-16 to add a Crusher and Storage Tank and Remove Equipment Prepared By Dylan Frederick, Engineer (385) 306-6529 dfrederick@utah.gov Issued to Kilgore Companies, LLC - Highland Pit Issued On August 26, 2024 {{$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............................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 11 ACRONYMS ............................................................................................................................... 12 DAQE-IN114360003-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Kilgore Companies, LLC Kilgore Companies, LLC - Highland Pit Mailing Address Physical Address PO Box 869 4600 West 11200 North Magna, UT 84044 Highland City, UT 84060 Source Contact UTM Coordinates Name: Lee Ware 435,200 m Easting Phone: (801) 831-7402 4,476,500 m Northing Email: lee.ware@kilgorecompanies.com Datum NAD83 UTM Zone 12 SIC code 1442 (Construction Sand & Gravel) SOURCE INFORMATION General Description Kilgore Companies (Kilgore) owns and operates the Highland Aggregate Plant. Aggregate material is moved from the mining area to the feeder. From the feeder, the material is crushed and screened. The sorted material is then transported off-site. The plant processes up to 1,650,000 tons of aggregate material annually. NSR Classification Minor Modification at Minor Source Source Classification Located in Provo UT PM2.5 NAA Utah 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 Title V (Part 70) Area Source DAQE-IN114360003-24 Page 4 Project Description Kilgore has requested the following additions to the approval order: 1. Installation of a Jaw Crusher rated 600 tph. 2. Installation of a 5,000-gallon diesel storage tank with an annual throughput of 25,000 gallons. Kilgore has also requested the removal of a double deck screen, concrete batch truck mix, storage silos, and water heater from the approval order. Emission estimates for the new equipment have been made, and modeling requirements have been updated. 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 0 264.00 Carbon Monoxide 0 0.30 Nitrogen Oxides 0 0.98 Particulate Matter - PM10 0.12 28.55 Particulate Matter - PM2.5 0.02 8.57 Sulfur Dioxide 0 0.05 Volatile Organic Compounds 0 0.08 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 20 Change (TPY) Total (TPY) Total HAPs 0 0.01 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 Daily Herald on August 28, 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. DAQE-IN114360003-24 Page 5 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] 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 Highland Aggregate Pit and Wash Plant DAQE-IN114360003-24 Page 6 II.A.2 One (1) Triple-Deck Wet Screen Size: 8' x 20' Manufacturer: Cedar Rapids II.A.3 Two (2) Twin Sand Screws* Sand Screw #1 Size: 44" x 32' Manufacturer: Eagle Sand Screw #2 Size: 66"X35' Manufacturer: Aztec *Included for informational purposes only. II.A.4 Two (2) Double Screens Size: 5' x 16' each Manufacturer: JCI II.A.5 One (1) Jaw Crusher Capacity: 600 tph II.A.6 One (1) Cone Crusher One (1) cone crusher Capacity: 300 tph Model Number: MVP-450X Serial Number: TRXRX450EOKFEO762 Manufacture Date: May 2015 II.A.7 Various Conveyors and Stackers II.A.8 One (1) Track-Mounted Jaw Crusher Capacity: 200 tph II.A.9 One (1) Crusher Engine Rating: 300 hp Fuel: Diesel Fuel Emission Standard: Tier IV Transitional (Manufactured after 2011) II.A.10 One (1) Diesel Storage Tank Capacity: 12,000 gallons II.A.11 One (1) Diesel Storage Tank Capacity: 5,000 gallons II.A.12 Various Water and Admixture Storage Tanks - listed for informational purposes only - II.A.13 Various Mobile Equipment Includes: Bulldozers, Track Hoes, Back Hoes, Loaders, Water Trucks, Haul Trucks, etc. - listed for informational purposes only - DAQE-IN114360003-24 Page 7 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 Highland Aggregate Pit shall be subject to the following: II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20 percent opacity. [R307-305-3] II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3] II.B.2 The Aggregate Processing Equipment shall be subject to the following: II.B.2.a The owner/operator shall not produce more than 1,650,000 tons of aggregate per rolling 12-month period. [R307-401-8] II.B.2.a.1 The owner/operator shall: A. Determine production by scale house records or vendor receipts. B. Record production on a daily basis. C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.2.a.2 The owner/operator shall weigh and account for all aggregate material prior to the aggregate material leaving the site or being used in another process on site. [R307-401-8] II.B.2.b The owner/operator shall not operate the aggregate processing plant and associated equipment more than 4,000 hours per rolling 12-month period and 16 hours per day. [R307-410-4] II.B.2.b.1 The owner/operator shall: A. Determine hours of operation with a supervisor monitoring and maintaining an operations log. B. Record hours of operation each day. C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8] II.B.2.c The owner/operator shall install and operate a feeder and conveyor transfer system in the mining area. Aggregate material shall be loaded into the feeder, and the conveyor transfer system shall transport all aggregate material to be processed to the aggregate processing plant. [R307-401-8] DAQE-IN114360003-24 Page 8 II.B.2.d The owner/operator shall not allow visible emissions from any crusher on site to exceed 12 percent opacity on site and 10 percent opacity at property boundary. [R307-312] II.B.2.e The owner/operator shall not allow visible emissions from any screen on site to exceed 7 percent opacity. [R307-312] II.B.2.f The owner/operator shall not allow visible emissions from any conveyor transfer point on site to exceed 7 percent opacity. [R307-312] II.B.2.f.1 The owner/operator shall conduct visible emission observations for each conveyor transfer point that relies on water carryover at least once per week. The records will include the following: A. Date of each observation. B. Time of each observation. C. The result of each opacity observation. [R307-401-8] II.B.2.g The owner/operator shall not allow visible emissions from any conveyor drop point to exceed 20 percent opacity on site and 10 percent opacity at property boundary. [R307-309-5] II.B.2.h The owner/operator shall install water sprays or chemical dust suppression sprays on crushers, screens, and conveyor transfer points as needed to control fugitive emissions. Sprays shall operate as needed when the temperature is above freezing to maintain the opacity limits listed in this AO. [R307-401-8] II.B.2.i The moisture content of the aggregate material being processed in the aggregate processing plant shall not be less than 4.0%. [R307-401-8] II.B.2.i.1 The owner/operator shall measure the moisture content of the aggregate material from each crusher and from each screen that does not have water sprays installed at least once per month. Moisture content shall be determined by ASTM Method D2216, D4643, D4959, or approved equivalent. Records shall include the following: A. Location of each sample. B. The date and time when each sample was taken. C. The moisture content of each sample. [R307-401-8] II.B.2.j The owner/operator shall inspect the upstream water sprays of conveyor transfer points that rely on water carryover to control fugitive emissions at least once per month to check that water is flowing to the spray nozzles. [R307-401-8] II.B.2.j.1 The owner/operator shall: A. Record the date and time of each inspection. B. The status of the water sprays. C. Any corrective action taken. [R307-401-8] DAQE-IN114360003-24 Page 9 II.B.3 The Track-Mounted Jaw Crusher and the Crusher Engine shall be subject to the following: II.B.3.a The Track-Mounted Jaw Crusher shall not produce more than 40,000 tons of aggregate per rolling 12-month period. [R307-401-8] II.B.3.a.1 The owner/operator shall: A. Determine production by examination of belt scale and/or bucket scale 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.3.b The Crusher Engine shall not consume more than 2,400 gallons of diesel fuel per rolling 12-month period. [R307-401-8] II.B.3.b.1 The owner/operator shall: A. Determine fuel consumption by examination of supervisor monitoring and maintaining of an operations log. B. Record consumption on a daily basis. C. Use the consumption data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep consumption records for all periods when the plant is in operation. [R307-401-8] II.B.3.c The owner/operator shall not allow visible emissions from the Crusher Engine to exceed 20 percent opacity. [R307-305-3] II.B.3.d The sulfur content of any diesel fuel burned in any diesel engine on site shall not exceed 15 ppm by weight. [40 CFR 60 Subpart IIII] II.B.3.d.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved equivalent. Certification of diesel fuel shall be either by the owner/operator's own testing or by test reports from the diesel fuel marketer. [R307-203-1] II.B.4 The Bulldozing Operations on site shall be subject to the following: II.B.4.a All bulldozers on site shall not exceed 4,000 hours of operation combined per rolling 12-month period. [R307-401-8] DAQE-IN114360003-24 Page 10 II.B.4.a.1 The owner/operator shall: A. Determine hours of operation by supervisor monitoring and maintenance of an operations log. B. Record hours of operation on a daily basis. C. Keep records of the number of hours each bulldozer operated each day and the total hours of operation for all bulldozers each day. D. Use the operations log to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. E. Keep operation records for all periods when the plant is in operation. [R307-401-8] II.B.5 All Haul Roads and Fugitive Dust Sources on site shall be subject to the following: II.B.5.a The owner/operator shall apply chemical dust suppressants on all unpaved haul roads and operational areas and shall use water application on all haul roads to maintain opacity limits listed in this AO. The owner/operator may stop applying water to the haul roads, loader routes, and wheeled-vehicle operational areas when the temperature is below freezing but shall still maintain the opacity limits listed in this AO. [R307-401-8] II.B.5.a.1 Records of chemical application and water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made. B. Number of treatments made and quantity of water applied. C. Rainfall amount received, if any. D. Records of temperature, if the temperature is below freezing. [R307-401-8] II.B.5.b The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% opacity at the property boundary. [R307-309-5] II.B.5.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5] II.B.5.c The haul road to the aggregate processing plant shall not exceed 1.01 miles in length (2.02 miles round-trip). [R307-401-8] II.B.5.d The owner/operator shall apply water to the storage piles and disturbed or stripped areas on site to maintain the opacity limits listed in this AO. Control of disturbed or stripped areas is required at all times (24 hours per day, every day) for the duration of the project/operation until the area is reclaimed. Records of treatment and/or reclamation shall be kept for all periods when the plant is in operation. [R307-401-8] DAQE-IN114360003-24 Page 11 II.B.5.e The owner/operator shall comply with all applicable requirements of R307-309 for Fugitive Emission and Fugitive Dust sources on site. [R307-309] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN114360002-16 dated March 7, 2016 Is Derived From NOI dated November 16, 2023 Incorporates Additional Information dated January 11, 2024 Incorporates Additional Information dated April 3, 2024 DAQE-IN114360003-24 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 Daily Herald Publication Name: Daily Herald Publication URL: Publication City and State: Provo, UT Publication County: Utah Notice Popular Keyword Category: Notice Keywords: Notice Authentication Number: 202408281139564302559 1761527914 Notice URL: Back Notice Publish Date: Wednesday, August 28, 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: Location: Kilgore Companies, LLC Location: Kilgore Companies, LLC Kilgore Companies, LLC - Highland Pit - 4600 West 11200 North, Highland City, UT Project Description: Kilgore Companies owns and operates an aggregate processing plant in Highland City, Utah. Kilgore is installing a Jaw Crusher and a 5,000-gallon diesel storage tank. The facility is also removing a double deck screen, storage silos, a water heater, and a concrete batch truck mix from the approval order. The facility will keep its current limit on aggregate production the same at 1,650,000 tons of material annually. 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 September 27, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at dfrederick@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: August 28, 2024 Legal Notice 13176 Published in the Daily Herald on August 28, 2024 Back DAQE-NN114360003-24 August 26, 2024 The Daily Herald Legal Advertising Dept 1555 N 200 W Provo, UT 84601 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in The Daily Herald on August 28, 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: Mountainland Association of Governments cc: Utah County 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-NN114360003-24 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: Kilgore Companies, LLC Location: Kilgore Companies, LLC - Highland Pit – 4600 West 11200 North, Highland City, UT Project Description: Kilgore Companies owns and operates an aggregate processing plant in Highland City, Utah. Kilgore is installing a Jaw Crusher and a 5,000-gallon diesel storage tank. The facility is also removing a double deck screen, storage silos, a water heater, and a concrete batch truck mix from the approval order. The facility will keep its current limit on aggregate production the same at 1,650,000 tons of material annually. 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 September 27, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at dfrederick@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: August 28, 2024 {{#s=Sig_es_:signer1:signature}} DAQE- RN114360003 August 6, 2024 Lee Ware Kilgore Companies, LLC PO Box 869 Magna, UT 84044 lee.ware@kilgorecompanies.com Dear Lee Ware, Re: Engineer Review: Minor Modification to DAQE-AN114360002-16 to add a Crusher and Storage Tank and Remove Equipment Project Number: N114360003 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. Kilgore Companies, LLC should complete this review within 10 business days of receipt. Kilgore Companies, LLC should contact Dylan Frederick at (385) 306-6529 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dylan Frederick at dfrederick@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 Kilgore Companies, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Kilgore Companies, 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 N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N114360003 Owner Name Kilgore Companies, LLC Mailing Address PO Box 869 Magna, UT, 84044 Source Name Kilgore Companies, LLC - Highland Pit Source Location 4600 West 11200 North Highland City, UT 84060 UTM Projection 435,200 m Easting, 4,476,500 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1442 (Construction Sand & Gravel) Source Contact Lee Ware Phone Number (801) 831-7402 Email lee.ware@kilgorecompanies.com Billing Contact Lee Ware Phone Number (801) 831-7402 Email lee.ware@kilgorecompanies.com Project Engineer Dylan Frederick, Engineer Phone Number (385) 306-6529 Email dfrederick@utah.gov Notice of Intent (NOI) Submitted November 16, 2023 Date of Accepted Application February 15, 2024 Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 2 SOURCE DESCRIPTION General Description Kilgore Companies (Kilgore) owns and operates the Highland Aggregate plant. Aggregate material is moved from the mining area to the feeder. From the feeder, the material is crushed and screened. The sorted material is then transported off site. The plant processes up to 1,650,000 tons of aggregate material annually. NSR Classification: Minor Modification at Minor Source Source Classification Located in , Provo UT PM2.5 NAA, Utah 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 Title V (Part 70) Area Source Project Proposal Minor Modification to DAQE-AN114360002-16 to add a Crusher and Storage Tank and Remove Equipment Project Description Kilgore has requested the following additions to the approval order: 1. Installation of a Jaw Crusher rated 600 tph 2. Installation of a 5,000 gallon diesel storage tank with an annual throughput of 25,000 gallons. Kilgore has also requested the removal of a double deck screen, concrete batch truck mix, storage silos, and water heater from the approval order. Emission estimates for the new equipment have been made, and modeling requirements updated. EMISSION IMPACT ANALYSIS A 24-hour PM10 model was completed by the DAQ (see memo DAQE-MN114360003-24). The 24-hour PM10 model predicted the maximum total concentration would be 87.3% of the NAAQS. The following operational restrictions were added as a result of the modeling: • Operating hours for the entire facility shall be limited to no more than 16 hours per day. No other criteria pollutants or HAPs were modeled as they are below the modeling thresholds contained in R307-410-4 and R307-410-5, or the source is in a non-attainment area for the pollutant. [Last updated June 13, 2024] Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 3 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 0 264.00 Carbon Monoxide 0 0.30 Nitrogen Oxides 0 0.98 Particulate Matter - PM10 0.12 28.55 Particulate Matter - PM2.5 0.02 8.57 Sulfur Dioxide 0 0.05 Volatile Organic Compounds 0 0.08 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 20 Change (TPY) Total (TPY) Total HAPs 0 0.01 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding Crusher The new jaw crusher will increase fugitive emissions of PM10 and PM2.5 at the facility. Kilgore evaluated add on controls for the jaw crusher to reduce emissions, such as a baghouse, electrostatic precipitator, wet scrubber and cyclone. All of these methods would require enclosures to be installed. This is not possible due to the nature of the operations at the facility requiring flexibility and shifting locations as mine material moves from one place to another over time. This makes add-on controls including enclosures technically infeasible to implement. The only remaining control for the crusher would be the use of watering or water sprays. Watering achieves a control of 50-90% for particulate matter. This option is both technically and economically feasible to implement and is accepted as BACT. Kilgore will also conduct regular maintenance and inspection of watering equipment and process equipment. BACT for control of PM10 and PM2.5 from the new jaw crusher will be the installation of water sprays to maintain an opacity limit of 12%. [Last updated February 15, 2024] 2. BACT review regarding Storage Tank The new diesel storage tank will increase emissions of VOCs and HAPs due to working and breathing losses from the tank. The tank has an annual throughput of 25,000 gallons. Kilgore evaluated controls for the storage tank, including a vapor recovery system, submerged filling of the tanks, and good operating practices. VOC and HAP Emissions from the storage tank are estimated to be less than a pound per year. Due to these low emissions, the cost to install a vapor recovery system or upgrade to a storage tank with submerged filling capability would be economically infeasible. The only remaining option are good operating practices including keeping the tank closed when not in use, and immediately cleaning any fuel spills. BACT for control of the 5,000 gallon diesel storage tank is good operating practices. [Last updated June 27, 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] Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 5 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] 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 Highland Aggregate Pit and Wash Plant II.A.2 One (1) Triple-Deck Wet Screen Size: 8' x 20' Manufacturer: Cedar Rapids Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 6 II.A.3 Two (2) Twin Sand Screws* Sand Screw #1 Size: 44" x 32' Manufacturer: Eagle Sand Screw #2 Size: 66"X35' Manufacturer: Aztec *Included for informational purposes only. II.A.4 Two (2) Double Screens Size: 5' x 16' each Manufacturer: JCI II.A.5 NEW One (1) Jaw Crusher Capacity: 600 tph II.A.6 One (1) Cone Crusher One (1) cone crusher Capacity: 300 tph Model Number: MVP-450X Serial Number: TRXRX450EOKFEO762 Manufacture Date: May 2015 II.A.7 Various Conveyors and Stackers II.A.8 One (1) Track-Mounted Jaw Crusher Capacity: 200 tph II.A.9 One (1) Crusher Engine Rating: 300 hp Fuel: Diesel Fuel Emission Standard: Tier IV Transitional (Manufactured after 2011) II.A.10 One (1) Diesel Storage Tank Capacity: 12,000 gallons II.A.11 NEW One (1) Diesel Storage Tank Capacity: 5,000 gallons II.A.12 Various Water and Admixture Storage Tanks - listed for informational purposes only - II.A.13 Various Mobile Equipment Includes: Bulldozers, Track Hoes, Back Hoes, Loaders, Water Trucks, Haul Trucks, etc. - listed for informational purposes only - Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 7 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 The Highland Aggregate Pit shall be subject to the following: II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20 percent opacity. [R307-305-3] II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3] II.B.2 The Aggregate Processing Equipment shall be subject to the following: II.B.2.a NEW The owner/operator shall not produce more than 1,650,000 tons of aggregate per rolling 12-month period. [R307-401-8] II.B.2.a.1 NEW The owner/operator shall: A. Determine production by scale house records or vendor receipts. B. Record production on a daily basis C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.2.a.2 The owner/operator shall weigh and account for all aggregate material prior to the aggregate material leaving the site or being used in another process on site. [R307-401-8] II.B.2.b NEW The owner/operator shall not operate the aggregate processing plant and associated equipment more than 4,000 hours per rolling 12-month period and 16 hours per day. [R307-410-4] II.B.2.b.1 NEW The owner/operator shall: A. Determine hours of operation with a supervisor monitoring and maintaining an operations log B. Record hours of operation each day C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8] Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 8 II.B.2.c NEW The owner/operator shall install and operate a feeder and conveyor transfer system in the mining area. Aggregate material shall be loaded into the feeder and the conveyor transfer system shall transport all aggregate material to be processed, to the aggregate processing plant. [R307-401-8] II.B.2.d The owner/operator shall not allow visible emissions from any crusher on site to exceed 12 percent opacity on site and 10 percent opacity at property boundary. [R307-312] II.B.2.e The owner/operator shall not allow visible emissions from any screen on site to exceed 7 percent opacity. [R307-312] II.B.2.f The owner/operator shall not allow visible emissions from any conveyor transfer point on site to exceed 7 percent opacity. [R307-312] II.B.2.f.1 NEW The owner/operator shall conduct visible emission observations for each conveyor transfer point that relies on water carryover at least once per week. The records will include the following: A. Date of each observation B. Time of each observation C. The result of each opacity observation. [R307-401-8] II.B.2.g The owner/operator shall not allow visible emissions from any conveyor drop point to exceed 20 percent opacity on site and 10 percent opacity at property boundary. [R307-309-5] II.B.2.h The owner/operator shall install water sprays or chemical dust suppression sprays on crushers, screens, and conveyor transfer points as needed to control fugitive emissions. Sprays shall operate as needed when the temperature is above freezing to maintain the opacity limits listed in this AO. [R307-401-8] II.B.2.i The moisture content of the aggregate material being processed in the aggregate processing plant shall not be less than 4.0%. [R307-401-8] II.B.2.i.1 NEW The owner/operator shall measure the moisture content of the aggregate material from each crusher and from each screen that does not have water sprays installed at least once per month. Moisture content shall be determined by ASTM Method D2216, D4643, D4959, or approved equivalent. Records shall include the following: A. Location of each sample B. The date and time when each sample was taken C. The moisture content of each sample. [R307-401-8] II.B.2.j The owner/operator shall inspect the upstream water sprays of conveyor transfer points that rely on water carryover to control fugitive emissions at least once per month to check that water is flowing to the spray nozzles. [R307-401-8] Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 9 II.B.2.j.1 NEW The owner/operator shall: A. Record the date and time of each inspection B. The status of the water sprays C. Any corrective action taken. [R307-401-8] II.B.3 The Track-Mounted Jaw Crusher and the Crusher Engine shall be subject to the following: II.B.3.a The Track-Mounted Jaw Crusher shall not produce more than 40,000 tons of aggregate per rolling 12-month period. [R307-401-8] II.B.3.a.1 NEW The owner/operator shall: A. Determine production by examination of belt scale and/or bucket scale 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.3.b The Crusher Engine shall not consume more than 2,400 gallons of diesel fuel per rolling 12-month period. [R307-401-8] II.B.3.b.1 NEW The owner/operator shall: A. Determine fuel consumption by examination of supervisor monitoring and maintaining of an operations log B. Record consumption on a daily basis C. Use the consumption data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep consumption records for all periods when the plant is in operation. [R307-401-8] II.B.3.c NEW The owner/operator shall not allow visible emissions from the Crusher Engine to exceed 20 percent opacity. [R307-305-3] II.B.3.d The sulfur content of any diesel fuel burned in any diesel engine on site shall not exceed 15 ppm by weight. [40 CFR 60 Subpart IIII] II.B.3.d.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved equivalent. Certification of diesel fuel shall be either by the owner/operator's own testing or by test reports from the diesel fuel marketer. [R307-203-1] II.B.4 The Bulldozing Operations on site shall be subject to the following: Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 10 II.B.4.a All bulldozers on site shall not exceed 4,000 hours of operation combined per rolling 12-month period. [R307-401-8] II.B.4.a.1 NEW The owner/operator shall: A. Determine hours of operation by supervisor monitoring and maintenance of an operations log B. Record hours of operation on a daily basis C. Keep records of the number of hours each bulldozer operated each day and the total hours of operation for all bulldozers each day D. Use the operations log to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months E. Keep operation records for all periods when the plant is in operation. [R307-401-8] II.B.5 All Haul Roads and Fugitive Dust Sources on site shall be subject to the following: II.B.5.a The owner/operator shall apply chemical dust suppressants on all unpaved haul roads and operational areas and shall use water application on all haul roads to maintain opacity limits listed in this AO. The owner/operator may stop applying water to the haul roads, loader routes, and wheeled-vehicle operational areas when the temperature is below freezing but shall still maintain the opacity limits listed in this AO. [R307-401-8] II.B.5.a.1 NEW Records of chemical application and water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature is below freezing. [R307-401-8] II.B.5.b The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% opacity at the property boundary. [R307-309-5] II.B.5.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5] II.B.5.c NEW The haul road to the aggregate processing plant shall not exceed 1.01 miles in length (2.02 miles round-trip). [R307-401-8] Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 11 II.B.5.d The owner/operator shall apply water to the storage piles and disturbed or stripped areas on site to maintain the opacity limits listed in this AO. Control of disturbed or stripped areas is required at all times (24 hours per day, every day) for the duration of the project/operation until the area is reclaimed. Records of treatment and/or reclamation shall be kept for all periods when the plant is in operation. [R307-401-8] II.B.5.e The owner/operator shall comply with all applicable requirements of R307-309 for Fugitive Emission and Fugitive Dust sources on site. [R307-309] Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 12 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN114360002-16 dated March 7, 2016 Is Derived From NOI dated November 16, 2023 Incorporates Additional Information dated January 11, 2024 Incorporates Additional Information dated April 3, 2024 REVIEWER COMMENTS 1. Comment regarding Emission Estimates: Emission estimates for this modification were calculated with the following methods: Jaw Crusher - An annual throughput of 1,650,000 tons of aggregate material are assumed to pass through the crusher. Emissions are controlled with wet suppression (water sprays). Controlled emission factors from AP-42 section 11.19.2 are used to determine fugitive PM10 and PM2.5 emissions. PM2.5 emissions were determined from AP-42, Chapter 13.2.4, using the equation PM2.5 = PM10 * 0.053/0.35. Diesel Storage Tank - Emissions from the new diesel storage tank were determined using methods from AP-42 Chapter 7: Liquid Storage Tanks to determine working and standing losses from the tank. A throughput of 25,000 gallons was assumed. The tank has a capacity of 5,000 gallons, a diameter of eight feet, a height of 13.33 feet, and is a fixed roof storage tank. [Last updated February 15, 2024] 2. Comment regarding NSPS and MACT Review: 40 CFR 60 (NSPS) Subpart Dc does not apply to the facility, as the facility has a steam generating unit on site, but it does not have a maximum design heat input capacity of 10 MMBtu/hr or greater. 40 CFR 60 (NSPS) Subpart Kb does not apply to the facility, as there are diesel storage tanks at the facility, but no storage tank has a capacity above 75 cubic meters, or 19,800 gallons. Therefore, no storage tank meets the applicability requirements listed in this subpart. 40 CFR 60 (NSPS) Subpart OOO applies to "each crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truck or railcar loading station" in nonmetallic mineral processing plants. Nonmetallic mineral processing plants are "any combination of equipment that is used to crush or grind any nonmetallic mineral wherever located..." which applies to this facility as it crushes or grinds nonmetallic aggregate material. The site has several crushers, and screening operations that must adhere to requirements listed in table 2 of this subpart. 40 CFR 60 (NSPS) Subpart JJJJ does not apply to the facility as the generators are all compression ignition ICE, not spark ignition engines. 40 CFR 60 (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, and are not fire pump engines." All engines on site commenced construction after July 11, 2005, therefore this subpart is applicable to the engines. The crusher engine must comply with Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 13 the applicable requirements listed in 40 CFR 60.4204. 40 CFR 63 (MACT) Subpart ZZZZ applies to owners/operators of "...stationary RICE at a major or area source of HAP emissions...." The facility is an area HAP source and operates a crusher engine, so Subpart ZZZZ applies to this facility. Compliance with Subpart ZZZZ is met through compliance with NSPS Subpart IIII [Last updated February 17, 2024] 3. Comment regarding 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 and is not a Title IV source. The facility is subject to 40 CFR 60 (NSPS) and 40 CFR 63 (MACT) regulations. It is not subject to 40 CFR 61 (NESHAP) regulations. Because NSPS OOO regulations apply to this source, Title V applies to the facility as an area source. There is no requirement for this source to apply for an initial Title V operating permit under current UDAQ and EPA rules. The source will be charged applicable Title V fees and Title V funds may be used for inventory and compliance inspections of this source. [Last updated February 28, 2024] 4. Comment regarding Removed conditions: The previous permit had two conditions in the haul road section of the requirements. The first was a requirement for moisture content to be maintained at 4% by weight for storage piles and disturbed ground. The second was to prevent the silt content of haul roads from exceeding 4.8%. These conditions did not have recordkeeping requirements associated with them in the previous permit. These limits come from assumptions used in AP-42 section 13.2.4 for silt and moisture content. These values would require testing by the source and are difficult to track and enforce compared to opacity limits. Because opacity limits can effectively encourage the source to keep fugitive dust emissions from storage piles to a minimum with watering, specific testing of the moisture content and silt content are not necessary. Therefore, these have been removed from the approval order. The storage piles and disturbed area are still controlled via watering, and must maintain a 20% opacity limit per condition II.B.1.a. Additionally, several equipment items from the last permit were removed as a 2023 compliance inspection noted the items were no longer on site. Kilgore confirmed that the double deck screen, concrete batch truck mix, storage silos, and water heater were all removed. Conditions relating to the removed equipment items were also removed as a result. Condition II.B.2.a of the previous AO had a 600 ton per hour limit on aggregate production. This was removed as there was no associated modeling requirements enforcing this condition, and the emission calculations associated with aggregate production use annual totals to determine emissions. Because this limit was not enforcing a modeling requirement or assumption needed to determine emissions, it was removed from the approval order to simplify tracking and recordkeeping for the source. [Last updated June 28, 2024] Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 2024 Page 14 5. Comment regarding Modeling The current PM10 model recommended a limit of 16 hours of operation per day at the facility. In the last approval order, modeling recommendations led to a 4,000 hour limit on operation at the facility. While that limit was not recommended by modeling, this limit has been kept in the permit, so that previous emission estimates and assumptions would remain enforced. [Last updated June 13, 2024] Engineer Review N114360003: Kilgore Companies, LLC - Highland Pit August 6, 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 Dylan Frederick <dfrederick@utah.gov> Source Review 114360003-24 Kilgore Highland 21 messages Dylan Frederick <dfrederick@utah.gov>Fri, Jun 28, 2024 at 1:29 PM To: Lee Ware <lee.ware@kilgorecompanies.com> Lee, Please see the attached ER, and let me know if you have any comments or questions. Once we have any changes addressed we can send this out to public comment. -- Dylan Frederick Environmental Engineer | Minor NSR Section P: (385) 306-6529 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. RN114360003-24.rtf 1587K Lee Ware <Lee.Ware@kilgorecompanies.com>Mon, Jul 1, 2024 at 12:18 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Thanks Dylan, We have received this. We will review and get back to you ASAP. Thanks! Regards, Lee Ware Manager of Land Development - West Region 7057 W 2100 S | Salt Lake City, UT 84128 M (801) 831-7402 O (801) 250-0132 E lee.ware@kilgorecompanies.com 8/19/24, 4:19 PM State of Utah Mail - Source Review 114360003-24 Kilgore Highland https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r689441114105683681&simpl=msg-a:r-1495142660423407…1/7 [Quoted text hidden] image001.png 23K Dylan Frederick <dfrederick@utah.gov>Tue, Jul 9, 2024 at 11:22 AM To: Lee Ware <Lee.Ware@kilgorecompanies.com> Cc: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Hey all, Just wanted to check in on this project. Have you had time to review it? [Quoted text hidden] Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com>Fri, Jul 12, 2024 at 11:26 AM To: Dylan Frederick <dfrederick@utah.gov>, Lee Ware <Lee.Ware@kilgorecompanies.com> Hi Dylan, I apologize for the wait on this. We have reviewed and have a few changes that we would like to make: Under the Source Description, It is still listing the Concrete Plants as onsite. II.A.2 - Is supposed to be a Triple-Deck Wet Screen Manufacturer Cedar Rapids and should be an 8’X20’ II.A.3 - We need to add an additional Twin Sand Screw manufacturer Aztec 66”X35’ II.B.2.d - Can the verbiage of the feeder shall be loaded with a bulldozer be removed? II.B.5.c – This also mentions the haul road length of the concrete batch plant on site. Could we have the concrete batch portion of this removed and extend the aggregate processing plant haul road with the 0.42 miles? Let us know if you have any questions or concerns. Thank you, Bryan Jorgensen Environmental Director – West Region M (801) 597-4471 O (801) 250-0132 E bryan.jorgensen@kilgorecompanies.com [Quoted text hidden] 8/19/24, 4:19 PM State of Utah Mail - Source Review 114360003-24 Kilgore Highland https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r689441114105683681&simpl=msg-a:r-1495142660423407…2/7 Dylan Frederick <dfrederick@utah.gov>Fri, Jul 12, 2024 at 5:26 PM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Bryan, I can make all these changes and have them to you by Monday. Thanks for getting these back to me. [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Thu, Jul 18, 2024 at 12:17 PM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Hey all, I believe in order to add a second twin sand screw, we need a BACT analysis for it. Can you submit a BACT analysis to install a new twin sand screw? I've made the other changes, II.B.2.c now reads "The owner/operator shall install and operate a feeder and conveyor transfer system in the mining area. Aggregate material shall be loaded into the feeder and the conveyor transfer system shall transport all aggregate material to be processed, to the aggregate processing plant.". and II.B.5.c now reads "The haul road to the aggregate processing plant shall not exceed 1.01 miles in length (2.02 miles round-trip)." [Quoted text hidden] Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com>Thu, Jul 18, 2024 at 12:19 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Hi Dylan, Thank you for making those changes. With the Sand Screw being a part of the wash plant, do we need to have a BACT analysis performed for this? [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Thu, Jul 18, 2024 at 12:36 PM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Bryan, I don't see a reference to a wash plant on the approval order, should that be referenced somewhere? But if the equipment will be a source of emissions at the facility we would need a BACT analysis for it. I'm not sure how the calculations were done on this equipment previously but any new equipment counts as a modification and needs to be evaluated. [Quoted text hidden] Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com>Thu, Jul 18, 2024 at 12:59 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Dylan, Section II.A.2 and II.A.3 refers to the equipment associated with the wash plant. If you’d like, Section II.A.1 could read “Highland Aggregate Pit and Wash Plant” instead of concrete batch plant. The sand screw is a piece of equipment that takes the sand out of a “water bath/tank” and then sends it to be stock piled to dry out more before use. I can’t think of any better emission control than that! 8/19/24, 4:19 PM State of Utah Mail - Source Review 114360003-24 Kilgore Highland https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r689441114105683681&simpl=msg-a:r-1495142660423407…3/7 Let me know what you think. Thanks much! [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Thu, Jul 18, 2024 at 1:38 PM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Bryan, Let me check in with my manager and see what he thinks we should do for this or if I'm forgetting something. I don't think there are very many emissions associated with that equipment, so it's likely we don't need an extensive BACT analysis. [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Thu, Jul 18, 2024 at 5:16 PM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Bryan, So my manager did confirm we need a BACT for the additional sand screw, and we would also need to see an updated emission calculation for the process the equipment is being added to. I'm not sure I've seen emission calculations for this kind of equipment before, I'm assuming it's similar to a conveyor calculation? Please let me know if I can help clarify this in any way. [Quoted text hidden] Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com>Thu, Jul 18, 2024 at 5:35 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Dylan, Could we set up a call to discuss this with your manager as well? There are no emissions from this piece of equipment and is not comparable to a conveyor. It is literally taking sand from under water and spiraling it up to get the water out of the sand, as a part of the washing process. Also as a reminder, we are removing an entire concrete batch plant off this AO so I’m not understanding why any BACT analysis needs to be done. The picture below is not of the actual sand screws onsite, but what they typically look like and their function. We are simply trying to make the equipment list correct on the AO. 8/19/24, 4:19 PM State of Utah Mail - Source Review 114360003-24 Kilgore Highland https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r689441114105683681&simpl=msg-a:r-1495142660423407…4/7 Let me know when we can schedule a meeting or call regarding this. Thanks, [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Fri, Jul 19, 2024 at 9:33 AM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Bryan, I can definitely do that. I thought because this equipment was listed in the approval order there were emissions associated with it. A BACT analysis has to be done for any new or modified equipment even if the modification is an overall decrease. But if it does not increase emissions at the site a BACT analysis would not be required. I can't seem to find any calculations for this equipment so if that is the case I can add that in. Let me know if you'd like to set up a call with my manager next week. [Quoted text hidden] Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com>Fri, Jul 19, 2024 at 10:03 AM To: Dylan Frederick <dfrederick@utah.gov> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Hey Dylan, Thank you for adding this in. We could have a meeting next week just to clarify if there are any new precedents being set towards wash plants. We appreciate your help with this. [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Fri, Jul 19, 2024 at 5:32 PM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> 8/19/24, 4:19 PM State of Utah Mail - Source Review 114360003-24 Kilgore Highland https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r689441114105683681&simpl=msg-a:r-1495142660423407…5/7 Bryan, I met with my manager earlier and since the equipment doesn't have associated emissions we can add the second one into the AO without any issues. A BACT and emission calculation isn't necessary here, I will just add a note that the two sand screws are there for informational purposes only. [Quoted text hidden] Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com>Fri, Jul 19, 2024 at 5:35 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Dylan, Thank you for following up with this. I hope you have a great weekend! Regards, [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Tue, Aug 6, 2024 at 4:18 PM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Hey all, Sorry for the delay on getting this back to you. Please review this and let me know if made the changes you requested correctly or if there's any other things you noticed. If it looks good, please return the cover letter with a signature, thanks! [Quoted text hidden] RN114360003-24.rtf 1588K Dylan Frederick <dfrederick@utah.gov>Thu, Aug 15, 2024 at 10:42 AM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Hey all, Have you had a chance to look over the updated approval order? [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Mon, Aug 19, 2024 at 3:41 PM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Hey all, Is there anything I can do to get the final sign off for the revised approval order done? [Quoted text hidden] Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com>Mon, Aug 19, 2024 at 4:12 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> 8/19/24, 4:19 PM State of Utah Mail - Source Review 114360003-24 Kilgore Highland https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r689441114105683681&simpl=msg-a:r-1495142660423407…6/7 Hi Dylan, Thank you for making those changes in the AO. It looks good to me to move forward with. [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Mon, Aug 19, 2024 at 4:18 PM To: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Cc: Lee Ware <Lee.Ware@kilgorecompanies.com> Thank you Bryan. If you can send me a signed cover page of the ER that would be great, I need it for the source file. [Quoted text hidden] 8/19/24, 4:19 PM State of Utah Mail - Source Review 114360003-24 Kilgore Highland https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r689441114105683681&simpl=msg-a:r-1495142660423407…7/7 4/12/24, 2:03 PM State of Utah Mail - Kilgore Highland Information Request https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-4842214402790826103&simpl=msg-a:r86009147453142…1/3 Dylan Frederick <dfrederick@utah.gov> Kilgore Highland Information Request 7 messages Dylan Frederick <dfrederick@utah.gov>Tue, Nov 21, 2023 at 2:49 PM To: Lee Ware <lee.ware@kilgorecompanies.com> Good afternoon Lee, I got a request from our modeler Dave regarding the new Jaw Crusher. He has requested the location of the new equipment to evaluate it for modeling the SIL. If you can provide a map with the crusher location, that would help get the modeling review done. Thank you, Dylan -- Dylan Frederick Environmental Engineer | Minor NSR Section P: (385) 306-6529 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Dylan Frederick <dfrederick@utah.gov>Tue, Dec 19, 2023 at 4:43 PM To: Lee Ware <lee.ware@kilgorecompanies.com> Lee, Have you gotten a chance to look over this information request for the Highland pit? [Quoted text hidden] Lee Ware <Lee.Ware@kilgorecompanies.com>Tue, Dec 19, 2023 at 4:48 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Dylan, Will do. Thanks for keeping us on track. Thanks! Lee Ware Environmental Director – West Region M (801) 831-7402 O (801) 250-0132 4/12/24, 2:03 PM State of Utah Mail - Kilgore Highland Information Request https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-4842214402790826103&simpl=msg-a:r86009147453142…2/3 E lee.ware@kilgorecompanies.com From: Dylan Frederick <dfrederick@utah.gov> Sent: Tuesday, December 19, 2023 4:44 PM To: Lee Ware <Lee.Ware@kilgorecompanies.com> Subject: Re: Kilgore Highland Information Request This message originated from outside your organization [Quoted text hidden] [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Tue, Mar 26, 2024 at 1:24 PM To: Lee Ware <Lee.Ware@kilgorecompanies.com> Cc: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Lee, I just wanted to confirm per our phone call today that the following equipment should be removed from the approval order: One (1) Double-Deck Screen Size: 4' x 10' Manufacturer: Simplicity One (1) Truck-Mix Concrete Batch Plant Capacity: 150 cubic yards Manufacturer: Con-E-Co Three (3) Cement & Supplement Silos Capacity: 3,000 barrels One (1) Water Heater Rating: 7.0 MMBtu/hr Fuel: Propane Manufacturer: Kemco As per our discussion, we will remove these from the equipment list and any associated conditions, but emission calculations wont change to keep the permit moving forward. I'll have an engineer comment on the review explaining this. [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Tue, Apr 2, 2024 at 6:04 PM To: Lee Ware <Lee.Ware@kilgorecompanies.com> Cc: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Lee, Can I get confirmation that these items are no longer at the site? [Quoted text hidden] Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com>Tue, Apr 2, 2024 at 10:54 PM 4/12/24, 2:03 PM State of Utah Mail - Kilgore Highland Information Request https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-4842214402790826103&simpl=msg-a:r86009147453142…3/3 To: Dylan Frederick <dfrederick@utah.gov>, Lee Ware <Lee.Ware@kilgorecompanies.com> Dylan, I just want to follow up with our operations folk bout the screen deck. All of the other listed equipment is for sure, and I’m pretty sure that the screen deck is also not there, just want to make 100% sure. I will follow up with you tomorrow. Thanks, Bryan Jorgensen Environmental Director – West Region M (801) 597-4471 O (801) 250-0132 E bryan.jorgensen@kilgorecompanies.com [Quoted text hidden] Lee Ware <Lee.Ware@kilgorecompanies.com>Wed, Apr 3, 2024 at 7:01 AM To: Dylan Frederick <dfrederick@utah.gov> Cc: Bryan Jorgensen <Bryan.Jorgensen@kilgorecompanies.com> Thanks, Dylan for the follow up. Yes, that is correct. The identified equipment is no longer on site. Regards, Lee Ware Manger of Land Development - West Region [Quoted text hidden] Jaw Crusher Location UTAH DIVISION OF AIR QUALITY NOTICE OF INTENT Kilgore Companies > Highland Pit Modify Approval Order: DAQE-AN114360002-16 Prepared By: TRINITY CONSULTANTS 4525 Wasatch Boulevard Suite 200 Salt Lake City, Utah 84124 (801) 272-3000 Submitted on behalf of: KILGORE COMPANIES 7057 West 2100 South Salt Lake City, UT 84128 November 2023 Kilgore Companies - Highland | Notice of Intent ii TABLE OF CONTENTS EXECUTIVE SUMMARY 1-1 GENERAL INFORMATION 2-1 2.1 Source Identification Summary................................................................................2-1 2.2 Area Designation ......................................................................................................2-1 2.3 Source Size Determination .......................................................................................2-1 2.4 Notice of Intent Forms..............................................................................................2-1 2.5 Notice of Intent Fees................................................................................................2-1 DESCRIPTION OF PROJECT AND PROCESS 3-1 3.1 ................................................................................3-1 3.2 ...............................................................................3-1 3.3 Site Plan....................................................................................................................3-2 EMISSIONS RELATED INFORMATION 4-1 4.1 Crushing....................................................................................................................4-1 4.2 Tanks ........................................................................................................................4-1 BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS 5-1 5.1 PM10 and PM2.5 Emissions - Crushing Aggregate Operations....................................5-1 5.2 VOC Emissions Fuel Oil Storage Tanks...................................................................5-4 EMISSION IMPACT ANALYSIS 6-1 6.1 Comparison to Modeling Thresholds.........................................................................6-1 NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING 7-1 7.1 Offset Applicability ...................................................................................................7-1 APPLICABLE REGULATIONS 8-1 8.1 General Introduction Utah Regulations.................................................................8-1 UAC R307-205-4 Emission Standards Fugitive Emissions..........................................................8-5 UAC R307-205-5 Emission Standards - Fugitive Dust..................................................................8-5 UAC R307-205-7 Emission Standards Roads............................................................................8-5 UAC R307-205-7 Emission Standards Mining Activities .............................................................8-5 Kilgore Companies - Highland | Notice of Intent iii R307-312-4 Visible Emissions...................................................................................................8-6 8.2 Federal Regulations..................................................................................................8-7 FORMS A EMISSION CALCULATIONS B Kilgore Companies - Highland | Notice of Intent 1-1 EXECUTIVE SUMMARY Kilgore currently operates aggregate mining activities under approval order (AO) DAQE-AN114360002-16. Kilgore is submitting this Notice of Intent (NOI) air permit application to the Utah Division of Air Quality (UDAQ) to modify the Highland by adding one (1) Jaw Crusher and one (1) 5,000 gallon capacity diesel storage tank. The Highland Pit is located at 4600 West 11200 North Highland City, UT 84003, within an area of Utah County designated as a non-attainment area of the National Ambient Air Quality Standards (NAAQS) for 24 hour 2006 particulate matter (PM) with an aerodynamic diameter of 2.5 microns or less (PM2.5), and 8 hour 2015 ozone. Oxides of nitrogen (NOX), sulfur dioxide (SO2), volatile organic compounds (VOCs) and ammonia (NH3) are considered precursors to PM2.5.as the area is in Serious Nonattainment. NOX and VOCs are considered precursors to ozone. This area of Utah County is in attainment for all other criteria pollutants. Emissions from this modification will consist of PM10, PM2.5, and VOCs. The Highland Pit is proposed to be permitted as a minor source and will be subject to 40 CFR 60, New Source Performance Standards (NSPS) Subpart OOO. Emission calculations were performed for both the project increase as well as the new, site-wide total for the Highland Pit due to the addition of the Jaw Crusher and increase in diesel fuel usage. The proposed increase in emissions for criteria pollutants, given in tons per year (tpy), are as follows: PM10 = 0.12, PM2.5 = 0.02, and VOC = 8.07E-05. The site-wide potential to emit (PTE), given in tpy, is as follows: PM10 = 28.55, PM2.5 = 8.57, NOX = 0.98, carbon monoxide (CO) = 0.30, sulfur dioxide (SO2) = 0.05, VOCs = 0.08, and Total HAPs = 0.01. Refer to Table 6-1 and Appendix Table B-1 for details. This NOI air permit application has been developed pursuant to Utah Administrative Code (UAC) R307-401-5 , and includes, but is not limited to: NOI Forms and Fees; Process Description; Site Plan; Potential Emission Calculations; Best Available Control Technology (BACT) Analysis; Applicable Requirements; and Emission Impact Analysis. Kilgore Companies - Highland | Notice of Intent 2-1 GENERAL INFORMATION section of UDAQ . 2.1 Source Identification Summary Company Name: Kilgore Companies Site Address: 4600 West 11200 North Highland City, UT 84003 County: Utah UTM Coordinates: 435,200m Easting, 4,476,500m Northing, UTM Zone 12 Primary SIC Code: 1442 (Construction Sand and Gravel) Area Designation: Nonattainment area of PM10 and PM2.5, 8-hour ozone Source Size Determination: Minor Source Current AO: DAQE-AN114360002-16 All correspondence regarding this submission should be addressed to: Mr. Lee Ware 7057 West 2100 South Salt Lake City, UT 84128 lee.ware@kilgorecompanies.com Phone: (801) 831-7402 2.2 Area Designation The Highland Pit is located at 4600 West 11200 North, Highland UT, within an area of Utah County designated as a non-attainment area of the NAAQS for PM2.5, PM10, and 8-hour ozone. NOX, SO2, VOCs and NH3 are considered precursors to PM2.5 and PM10. NOX and VOCs are considered precursors to ozone. All other criteria pollutants are in attainment. 2.3 Source Size Determination As presented in Appendix B, Table B-1, site-wide emissions at the Highland Pit are less than the major source thresholds (MST) for all criteria pollutants and HAPs. This application is a minor modification to an existing minor source under New Source Review (NSR). 2.4 Notice of Intent Forms The following UDAQ forms have been included with the NOI air permit application: Form 1 Notice of Intent Application Checklist Form 2 Source Identification Information Form 4 Project Information Form 5 Emissions Information Criteria/GHGs/HAPs Form 15 Aggregate Processing Operations Form 20 Organic Liquid Storage Tanks 2.5 Notice of Intent Fees Kilgore air permit application fees associated with this submittal: Kilgore Companies - Highland | Notice of Intent 2-2 category = $500 category in maintenance or non-attainment areas = $2,300 Total UDAQ fees = $2,800 Kilgore understands that the total permit review fee is based on the total actual time spent by UDAQ staff processing this NOI air permit application. Upon issuance of the AO, if the total review time is more than 20 standard hours, UDAQ will invoice Kilgore at $115 per hour for the additional time above 20 standard hours. Kilgore Companies - Highland | Notice of Intent 3-1 DESCRIPTION OF PROJECT AND PROCESS 3.1 Description of Kilgore Project Kilgore is proposing to add a Jaw Crusher and a diesel storage tank at Highland Pit in Highland, Utah, located in Utah County. These additions will not affect the throughput of the facility under DAQE- AN114360002-16. The annual diesel throughput of the tank will be 25,000 gallons and will be used for mobile sources. Condition II.B.3.b of the AO will remain unchanged and the Crusher Engine will not consume more than 2,400 gallons of diesel per rolling 12-month period. This project proposes no other changes to the Highland site. Emission calculations associated the proposed Jaw Crusher and increased diesel usage are detailed in Section 4 of this NOI air permit application. 3.2 Figure 1 shows a process flow diagram (PFD) of the Highland operations. Material is dozed from the mine area and then transported to the primary feeder. Aggregate is fed from the feeder into the bin feeder or Jaw Crusher for initial sizing. Material is screened to size, with large reject material being crushed in the VSI crusher. Properly sized material is stockpiled before being hauled off-site. Figure 3-1. Highland Process Flow Diagram Kilgore Companies - Highland | Notice of Intent 3-2 3.3 Site Plan Figure 3-2, shown below, provides a vicinity map of the Highland Pit where Kilgore currently operates (site boundaries are given in blue). Figure 3-2. Site Plan Kilgore Companies - Highland | Notice of Intent 4-1 EMISSIONS RELATED INFORMATION This section details the methodology used to calculate controlled and uncontrolled emissions for criteria pollutants associated with each new unit and its associated fugitives as regulated by R307-401-5(2)(b). Detailed emission calculation tables are included in Appendix B. 4.1 Crushing PM, PM10, and PM2.5 emissions generated from the crushing aggregate are estimated by multiplying the material throughput by the appropriate emission factor (EF). Controlled EFs for crushing were obtained from AP-42, Section 11.19.2 (Crushed Stone Processing and Pulverized Mineral Processing), August 2004. The equation used is as follows: 4.2 Tanks Annual VOC emissions from the fixed-roof storage tank was calculated using the methodology provided in the Fifth Edition (2020) of AP-42 Chapter 7: Liquid Storage Tanks, last updated in March of 2020; all equations, tables, and figures referenced here refer to AP-42, Section 7.1. The potential VOC emission estimates account for the working and standing losses associated with changes in temperature, pressure, and liquid level. Liquid throughput for the tank is 25,000 gallons per year. Per Equation 1-1, the total routine losses form the fixed roof tanks are equal to the sum of the standing loss and working loss: Where: LT = total losses, lb/yr LS = standing storage losses, lb/yr LW = working losses, lb/yr The standing storage loss and working loss components of the total loss equation are discussed in the subsections below. Standing Storage Loss Annual fixed roof standing losses can be estimated using Equation 1-2: Where: LS = standing storage loss, lb/yr VV = vapor space volume, ft 3 Wv = stock vapor density, lb/ft 3 KE = vapor space expansion factor, dimensionless KS = vented vapor saturation factor, dimensionless 365 = constant, the number of daily events in a year, days/yr Kilgore Companies - Highland | Notice of Intent 4-2 Tank Vapor Space Volume, VV The tank vapor space volume (VV) is calculated using Equation 1-3: Where: VV = vapor space volume, ft3 D = internal tank diameter, ft HVO = vapor space outage, ft The standing loss equation can be simplified by combining Equation 1-2 with Equation 1-3 to derive Equation 1-4: Where: LS = standing storage loss, lb/yr KE = vapor space expansion factor, dimensionless D = internal tank diameter, ft HVO = vapor space outage, ft KS = vented vapor saturation factor, dimensionless Wv = stock vapor density, lb/ft3 365 = constant, the number of daily events in a year, days/yr Vapor Space Expansion Factor, KE The calculation of the vapor space expansion factor, KE, depends upon the properties of the liquid in the tank and the breather vent settings, and is represented by Equation 1-5: Where: TV = average daily vapor temperature range, OR PV = average daily vapor pressure range, psi PB = breather vent pressure setting range, psi PA = atmospheric pressure, psia PVA = vapor pressure at average daily liquid surface temperature, psia TLA = average daily liquid surface temperature, OR For an uninsulated tank, the average daily vapor temperature range is calculated using Equation 1-6: Where: TV = average daily vapor temperature range, OR HS = tank shell height, ft D = internal tank diameter, ft Kilgore Companies - Highland | Notice of Intent 4-3 TA = average daily ambient temperature range, OR R = tank roof surface solar absorptance, dimensionless S = tank shell surface solar absorptance, dimensionless I = average daily total insolation factor, Btu/ft2 day API assigns a default value of HS R S, resulting in the simplified equation for an uninsulated tank: Where: = average tank surface solar absorptance, dimensionless V) is calculated from Equation 1-9: Where: PVX and PVN are the vapor pressures at TLX and TLN; respectively. Vapor Space Outage, HVO For horizontal tanks, the vapor space outage (HVO) is estimated as: Where: HE = effective height of an equivalent upright cylinder, ft D = diameter of a vertical cross-section of the horizontal tank, ft Vented Vapor Saturation Factor, KS The vented vapor saturation factor (KS) is calculated using Equation 1-21: Where: KS = vented vapor saturation factor, dimensionless PVA = vapor pressure at average daily liquid temperature, psia HVO = vapor space outage, ft Stock Vapor Density, WV The density of the vapor (WV) is calculated using Equation 1-22: Where: WV = vapor density, lb/ft3 MV = vapor molecular weight, lb/l-mol Kilgore Companies - Highland | Notice of Intent 4-4 R = the ideal gas constant, 10.731 psia ft3/lb-mole OR PVA = vapor pressure at daily average liquid surface temperature, psia TV = average vapor temperature, OR Working Loss Annual fixed roof tank working losses are estimated using Equation 1-35: Where: Lw = working loss, lb/yr VQ = net working loss throughput, ft3/yr KN = working loss turnover (saturation) factor, dimensionless For turnovers > 36, KN = (180 + N)/6N N = number of turnovers per year, dimensionless N = Q/V Q = annual net throughput, gal/yr V = working volume, gal KP = working loss product factor, dimensionless Kp = 1 for organic liquids except crude oils WV = vapor density, lb/ft3 KB = vent setting correction factor, dimensionless, KB = 1 When the breather vent settings are greater than the typical values of ±0.03 psig, and the condition expressed in Equation 1-40 is met, a vent setting correction factor, KB, must be determined using equation 1-41. This value of KB will be used in Equation 1-25 to calculate working losses. Therefore, when Equation 1-40: Then, Equation 1-41 becomes: Where: KB = vent setting correction factor, dimensionless PI = pressure of the vapor space at normal operating conditions, psig PA = atmospheric pressure, psia KN = working loss turnover (saturation) factor, dimensionless PVA = vapor pressure at the average daily liquid surface temperature, psia PBP = breather vent pressure setting, psig N = number of turnovers per year Where: Q = annual tank throughput, gal/yr C = tank capacity, gal Kilgore Companies - Highland | Notice of Intent 4-5 Hazardous Air Pollutant Speciation The individual HAP emissions from fixed roof storage tanks are estimated by multiplying the total loss by the weight fraction in the vapor phase of the desired component using Equation 40-1: Where: LTi = emission rate of component i, lb/yr ZVi = weight fraction of component i in the vapor phase, lb/lb LT = total losses, lb/yr fraction of the component in the liquid (xi) multiplied by the vapor pressure of the pure component (P) is equal to the partial pressure, Pi, of that component: Where: Pi = partial pressure of component i, psia P = vapor pressure of pure component i at the average daily liquid surface temperature, psia xi = liquid mole fraction, lb-mole/lb-mole : Where: xi = liquid mole fraction of component i, lb-mol/lb-mole ZLi = weight fraction of component i in the liquid, lb/lb ML = molecular weight of liquid stock, lb/lb-mole Mi = molecular weight of component i, lb/lb-mole The vapor mole fraction of the component can be determined from using Equation 40-5: Where: yi = vapor mole fraction of component i, lb-mol/lb-mol Pi = partial pressure of component i, psia PVA = total vapor pressure of liquid mixture, psia The weight fractions in the vapor phase are calculated from the mole fractions in the vapor phase: Where: ZVi = vapor weight fraction of component i, lb/lb yi = vapor mole fraction of component i, lb-mole/lb-mole Mi = molecular weight of component i, lb/lb-mole MV = molecular weight of vapor stock, lb/lb-mole Kilgore Companies - Highland | Notice of Intent 5-1 BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS In the State of Utah, under R307-401-5(2)(d), Notice of Intent, every facility, operation, or process that proposes any activity that would emit an air contaminant, must consider BACT for the proposed activity. The BACT analysis below was performed pursuant to this rule. It only addresses units which will be modified, installed, or otherwise altered according to this NOI. 5.1 PM10 and PM2.5 Emissions - Crushing Aggregate Operations Highland Pit is proposing to add one (1) Jaw Crusher to their existing crushing operations for aggregate mined on site (Crushing and Screening circuit). This BACT analysis has been completed for the new Jaw Crusher on the Crushing and Screening circuit. 5.1.1 Material Handling PM10 and PM2.5 Step 1 Identify All Control Technologies Control technologies identified for PM10 and PM2.5 emissions from material handling operations are as follows, based on October 18, 2023, review of relevant entries in () RACT/BACT/LAER Clearinghouse (RBLC): Baghouse/Fabric Filter Cyclone Electrostatic Precipitator Enclosures Management/Operation Practices Watering and Material Moisture Content Wet Scrubber 5.1.2 Material Handling PM10 and PM2.5 Step 2 Eliminate Technically Infeasible Options Baghouse/Fabric Filter Fabric filters (baghouses) are used for medium and low gas-flow streams with high particulate concentrations. The typical baghouse has a control efficiency between 95% to 99.9%.1 This is generally accomplished through the installation of ductwork, capture hoods, fans, motors, starters, stacks, and other stationary equipment. Material at Highland Pit travels through a series of mobile conveyors that extend hundreds of feet. The Crushing and Screening circuit requires flexibility to alter on-site stockpile configurations and the location of crushing and screening operations; i.e., the Crushing and Screening c equipment must remain mobile. This configuration is incompatible with stationary baghouse equipment, and thus renders the use of a baghouse technically infeasible. Cyclone A cyclone separator (cyclone) operates on the principle of centrifugal separation. A high-efficiency cyclone designed specifically for PM10 removal is likely to achieve between 20% to 70% removal for PM10.2 Cyclones are less efficient at removing PM2.5. Like a baghouse, cyclone feasibility is based on routing emissions to a stationary control system via ductwork, capture hoods, fans, etc. This results in a cyclone being technically 1 From EPA , EPA-452/F-03-025. 2 From EPA-452/F-03-005 Kilgore Companies - Highland | Notice of Intent 5-2 infeasible for the Crushing and Screening circuit, as the crushing and screening equipment used for production are mobile. Electrostatic Precipitator A dry electrostatic precipitator (ESP) is a particle control device that uses electrical forces to move coarse particles at high concentrations out of a gas stream and onto collector plates, and then into a hopper. This removal efficiency is typically between 90-99.9%.3 ESPs are sensitive to variations in gas streams and do not work well with streams that are highly variable, such as those present in crushing and screening.4 Therefore, implementation of this control technology is considered technically infeasible for all crushing and screening sources. Enclosures Enclosures confine emissions to the enclosed area, prohibiting PM from reaching ambient air. Enclosures are typically able to achieve a control efficiency of 50-90% of fugitive emissions.5 Although effective, industrial enclosures are permanent structures. As discussed, the Crushing and Screening circuit moves from time to time, which requires flexibility of stockpile configurations. Therefore, enclosures are technically infeasible for crushing and screening sources. Management/Operation Practices Management practices will minimize PM2.5 and PM10 emissions and will be implemented as part of this project. Best operating practices, such as regular inspection and maintenance, will be implemented as well. Watering and Material Moisture Content Watering changes the physical properties of the surface material by binding soil particles together such that fugitive emissions are minimized or not generated. Moreover, carryover of material moisture content from water sprays mitigates particulate emissions beyond the initial point of watering. Inherent moisture found in mined aggregate achieves the same effect as wetting by watering controls. Wet suppression is shown to achieve between 50-90% control of emissions.6 This control measure is considered technically feasible for crushing. Wet Scrubber Wet gas scrubbers can achieve 50-95% control of PM emissions.7 However, they face the same difficulties in crushers that move from time to time as baghouses and cyclones, namely, they rely on stationary ductwork and other equipment to route emissions to the scrubber itself. Due to the nature of mining, conveyors leading to crushing, screening, and drop points will be moved throughout the life of the mine. The incompatibility between the mobile crushing and screening equipment and stationary wet scrubber equipment renders the use of a wet scrubber technically infeasible in the Crushing and Screening circuit. 3 From EPA , EPA-452/F-03-028 4 Ibid. 5 Texas Commission on Environmental Quality, Material Handling: Source Types, Controls, Emission Calculations for mechanical conveyance, p 10. 6 From Western Regional Air Partnership, ; Executive Summary, p 3, September 2006. 7 From EPA , EPA-452/F-03-015 Kilgore Companies - Highland | Notice of Intent 5-3 5.1.3 Material Handling PM10 and PM2.5 Step 3 Rank Remaining Control Technologies by Control Effectiveness Table 5-1. PM10 and PM2.5 Control for Material Handling in the Crushing and Screening Circuit Control Technologies Rank Percent Control Feasible BACT Water Spray/Inherent Properties 1 50 90% Yes Yes Best Management/Operational Practices 2 Variable Yes Yes These operations are subject to NSPS, Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plant(s) (NMPP). These NSPS standards were updated by EPA in 20088. Section 111 of the Clean Air Act (CAA) requires that NSPS reflect the application of the best system of emission reductions, taking into consideration the cost of achieving such reductions, non-air quality health impact, environmental impact, and energy requirements. In this amendment, EPA made revisions to the emission limits for NMPP- affected facilities which commence construction, modification, or reconstruction after publishing the revised when revising these standards of performance did not reveal any new or emerging pollution-prevention measures or PM control technologies as best demonstrated technologies (BDT). EPA found that the NSPS, Subpart OOO fugitive emission limits are most commonly met through use of wet suppression (as needed) and water carryover. Wet dust suppression remains the method of choice for the vast majority of crushing and screening facilities. 5.1.4 Material Handling PM10 and PM2.5 Step 4 Evaluate Most Effective Controls and Document Results 10 and PM2.5, along with reduction in larger PM particles required to meet NSPS Subpart OOO emission standards. Additionally, as Highland Pit is located in a PM2.5 Nonattainment Area, it is subject to R307-312 Aggregate Processing Operations. Furthermore, because the selected technologies provide the best control efficiencies feasible for the Crushing and Screening circuit, a cost analysis is not necessary. Therefore, watering and best management practices are the most effective control technologies for the equipment in the Crushing and Screening circuit. 5.1.5 Material Handling PM10 and PM2.5 Step 5 Select BACT Kilgore proposes that BACT for the Crushing and Screening circuit consists of restricting fugitive emissions to opacity standards set forth by NSPS Subpart OOO, Standards of Performance for NMPP, namely 12% opacity for crushing operations. Like many crushing and screening facilities, this will be done by water application and material moisture content controls. This includes, but is not limited to: Application of water to stockpiles via water spray from stackers and/or the water truck; and Application of water sprays to crushing operations. Furthermore, management and best operational practices will be applied. These include, but are not limited to: Periodic inspections of crushing operations. 8 US EPA revised NSPS, Subpart OOO in 73 Federal Register (FR) 78, April 28, 2009. Kilgore Companies - Highland | Notice of Intent 5-4 5.2 VOC Emissions Fuel Oil Storage Tanks Kilgore is proposing the addition of one (1) 5,000 capacity diesel storage tank with an annual throughput of 25,000 gallons per year at the Highland Pit. The combined PTE of VOCs from the fuel oil storage tank is 8.07E-05 tpy. All tanks can be categorized as aboveground fixed-roof tanks. These tanks are not subject to regulations under NSPS Subpart Kb, , since the tank meets one of the three exemptions to the regulation: A capacity of less than 75 cubic meters (m3); A capacity of greater than or equal to 151 m3 and storing a liquid with a maximum true vapor pressure of less than 3.5 kilopascals (kPa); or A capacity of between 75 m3 and 151 m3 and storing a liquid with a maximum true vapor pressure of less than 15.0 kPa. 5.2.1 Fuel Oil Storage Tanks VOCs & Volatile HAPs Step 1 Identify All Control Technologies Emissions from the fixed-roof storage tank result from displacement of headspace vapor during filling operations (working losses) and during diurnal temperature and heating variations (breathing losses). Based on the review of the RBLC database, Bay Area Air Quality Management District (BAAQMD), California Air Resources Board (CARB), San Joaquin Valley Air Pollution Control District (SJVAPCD), Texas Commission on Environmental Quality (TCEQ), and similar operations, Kilgore has identified control technologies that could be applicable for controlling VOC emissions from the diesel tank. The proposed controls are as follows: Vapor Recovery System; Submerged Filling of Tanks; and Good Operating Practices and Maintenance; 5.2.2 Fuel Oil Storage Tanks VOCs & Volatile HAPs Steps 2 5 Kilgore reviewed submerged filling of the diesel tank and, to accomplish this option, the purchased tank would need to be specially equipped for submerged filling operations. Because the tank emits less than 1.00E-04 tpy of VOCs, it was determined that the purchase of the tank with submerged filling is economically infeasible at this time. Kilgore reviewed the possibility of the installation of a vapor recovery system on the tank. Vapor recovery systems typically control highly volatile substances with high VOC waste streams.9,10 A vapor recovery system has been eliminated from further consideration based on this technical infeasibility. Furthermore, implementation costs of $35,738-$103,95911 required for vapor recovery systems make the technology cost prohibitive for the low amounts of VOCs emitted from these tanks (at less than 1.00E-04 tpy, total). -site storage tanks is good operating practices and maintenance, with no additional add-on controls. 9 US EPA Documents, , 2015. 10 US EPA, , 2012. 11 US EPA, , October 2006 Kilgore Companies - Highland | Notice of Intent 6-1 EMISSION IMPACT ANALYSIS 6.1 Comparison to Modeling Thresholds Table 6-1 compares project and total criteria pollutant and HAPs potential to emit to applicable modeling thresholds contained in R307-403-4 through 7, and R307-410-4. Table 6-1. Kilgore Project Emissions and Comparison to Major Source and Modeling Thresholds Process Annual Emission Rates (tpy) PM10 PM2.5 NOX CO SO2 VOC Total HAP CO2e Project Totals 0.12 0.02 -- -- -- 8.07E-05 -- -- Modeling Limit1 5 -- 40 100 40 -- 10/25 -- Modeling Required? No No No No No No No No Currently Permitted Emissions2 28.43 8.55 0.98 0.30 0.05 0.08 0.01 264.00 Proposed PTE 28.55 8.57 0.98 0.30 0.05 0.08 0.01 264.00 Major Source Thresholds3,4 250 70 70 250 70 70 10/25 75,000 Exceeding Major Source Thresholds?No No No No No No No No 1. Modeling Limit is stated in UDAQ Emissions Impact Assessment Guidelines under Table 1: Total Controlled Emission Rates for New Sources. PM emissions from the Jaw Crusher are fugitive emissions. 2. Emission totals are from DAQE-AN114360002-16. 3. Major source thresholds defined by 40 CFR 51.165(a)(1)(iv)(A) and 40 CFR 52.21(b)(1)(i)(b). 4. Total HAP Threshold is stated in 40 CFR 63.2 under definition of a Major Source. If this operating scenario changes in the future, Kilgore will notify UDAQ 30 days prior to the change, or submit a revised NOI air permit application. Because the total emission increases at Highland Pit do not constitute a major source, a visibility analysis is not required.12 The proposed Jaw Crusher and tank will not result in an increase of site wide HAP emissions. As such, HAP modeling is not required. 12 R307-406-2 Kilgore Companies - Highland | Notice of Intent 7-1 NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING -420 and R307-421, this section should include offset requirements for nonattainment and maintenance areas.Highland Pit is located within PM10, PM2.5, and 8-hour ozone nonattainment areas. 7.1 Offset Applicability PM2.5 Offsets PM2.5 offsets are applicable to major sources located within or impacting a PM2.5 nonattainment area of the NAAQS. A major source in a serious nonattainment area is defined in R307-403- source of air pollutants which emits or has the [PTE] 70 [TPY] or more of direct PM2.5 or any individual PM2.5 precursor as defined in R307-403-1(4)(c) [i.e., SO2, NOX Highland Pit is not a major source, and it is therefore not subject to the offset requirements of R307-403. PM10 Offsets PM10 offsets requirements are described in UAC R307-421-2. They apply to new or modified sources of SO2 or NOX that are located in or impact Salt Lake County or Utah County.Highland Pit is located in Utah County, however, this project does not change SO2 or NOX emissions. This project at Highland Pit is therefore not subject to the PM10 offset requirements of R307-421. Ozone Offsets Ozone offsets requirements recorded in UAC R307-420-3(2) and VOC offsets are applicable to significant sources located within or impacting an ozone nonattainment area of the NAAQS. In summary, significant sources located in Davis County or Salt Lake County shall offset the proposed increase in VOC emissions by a ratio of 1.2:1 before the Director may issue an AO to construct, modify, or relocate under R307-401. As Highland Pit is located in Utah County, ozone offsets are not applicable. Kilgore Companies - Highland | Notice of Intent 8-1 APPLICABLE REGULATIONS 8.1 General Introduction Utah Regulations Kilgore has evaluated the applicability of each rule under the Utah Administrative Code (UAC) Title R307. Rules that are generally applicable to Highland Pit, but not directly associated with the proposed changes described in this NOI, will not be discussed in this section. All applicable rules associated with this project will be discussed in the subsequent subsections. Table 8-1. Evaluation of UDAQ Air Quality Rules Reference Regulation Name Applicability Yes No R307-101 General Requirements X R307-102 1 General Requirements: Broadly Applicable Requirements X R307-103 1 Administrative Procedures X R307-104 Conflict of Interest X R307-105 General Requirements: Emergency controls X R307-107 General Requirements: Breakdowns X R307-110 1 General Requirements: State Implementation Plan X R307-115 1 General Conformity X R307-120 General Requirements: Tax Exemption for Air Pollution Control Equipment X R307-121 General Requirements: Clean Air and Efficient Vehicle Tax Credit X R307-122 General Requirements: Heavy Duty Vehicle Tax Credit X R307-123 General Requirements: Clean Fuels and Vehicle Technology Grant and Loan Program X R307-124 General Requirements: Conversion to Alternative Fuel Grant Program X R307-125 Clean Air Retrofit, Replacement, and Off-Road Technology Program X R307-130 General Penalty Policy X R307-135 Enforcement Policy for Asbestos Hazard Emergency Response Act X R307-150 Emission Inventories X R307-165 Stack Testing X R307-170 Continuous Emission Monitoring Program X R307-201 Emission Standards: General Emission Standards X Kilgore Companies - Highland | Notice of Intent 8-2 Reference Regulation Name Applicability Yes No R307-202 Emission Standards: General Burning X R307-203 1 Emission Standards: Sulfur Content of Fuels X R307-204 Emission Standards: Smoke Management X R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust X R307-206 Emission Standards: Abrasive Blasting X R307-207 Residential Fireplaces and Solid Fuel Burning Devices X R307-208 Outdoor Wood Boilers X R307-210 2 Standards of Performance for New Stationary Sources X R307-214 2 National Emission Standards for Hazardous Air Pollutants X R307-220 Emission Standards: Plan for Designated Facilities X R307-221 Emission Standards: Emission Controls for Existing Municipal Solid Waste Landfills X R307-222 Emission Standards: Existing Incinerator for Hospital, Medical, Infectious Waste X R307-223 Emission Standards: Existing Small Municipal Waste Combustion Units X R307-224 Mercury Emission Standards: Coal Fired Electric Generating Units X R307-230 NOX Emission Limits for Natural Gas-Fired Water Heaters X R307-250 Western Backstop Sulfur Dioxide Trading Program X R307-301 Utah and Weber Counties: Oxygenated Gasoline Program as a Contingency Measure X R307-302 Solid Fuel Burning Devices X R307-303 Commercial Cooking X R307-304 Solvent Cleaning X R307-305 Nonattainment and Maintenance Areas for PM10: Emission Standards X R307-306 PM10 Nonattainment and Maintenance Areas: Abrasive Blasting X R307-307 Road Salting and Sanding X Kilgore Companies - Highland | Notice of Intent 8-3 Reference Regulation Name Applicability Yes No R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust X R307-310 Salt Lake County: Trading of Emission Budgets for Transportation Conformity X R307-311 Utah County: Trading of Emission Budgets for Transportation Conformity X R307-312 Aggregate Processing Operations for PM2.5 Nonattainment Areas X R307-320 Ozone Maintenance Areas and Ogden City: Employer Based Trip Reduction X R307-325 Ozone Nonattainment and Maintenance Areas: General Requirements X R307-326 Ozone Nonattainment and Maintenance Areas: Control of Hydrocarbon Emissions in Petroleum Refineries X R307-327 Ozone Nonattainment and Maintenance Areas: Petroleum Liquid Storage X R307-328 Gasoline Transfer and Storage X R307-335 Degreasing X R307-341 Ozone Nonattainment and Maintenance Areas: Cutback Asphalt X R307-342 Adhesives and Sealants X R307-343 Wood Furniture Manufacturing Operations X R307-344 Paper, Film, and Foil Coatings X R307-345 Fabric and Vinyl Coatings X R307-346 Metal Furniture Surface Coatings X R307-347 Large Applicable Surface Coatings X R307-348 Magnet Wire Coatings X R307-349 Flat Wood Panel Coating X R307-350 Misc. Metal Parts and Product Coating X R307-351 Graphic Arts X R307-352 Metal Container, Closure, and Coil Coatings X R307-353 Plastic Parts Coatings X R307-354 Automotive Refinishing Coatings X Kilgore Companies - Highland | Notice of Intent 8-4 Reference Regulation Name Applicability Yes No R307-355 Aerospace Manufacture and Rework Facilities X R307-356 Appliance Pilot Light X R307-357 Consumer Products X R307-361 Architectural Coatings X R307-401 Permit: New and Modified Sources X R307-403 Permits: New and Modified Sources in Nonattainment and Maintenance Areas X R307-405 Permits: Major Sources in Attainment or Unclassified Areas (PSD) X R307-406 Visibility X R307-410 Permits: Emission Impact Analysis X R307-414 Permits: Fees for Approval Orders X R307-415 Permits: Operating Permit Requirements X R307-417 Permits: Acid Rain Sources X R307-420 Permits: Ozone Offset Requirements in Salt Lake County and Davis County X R307-421 Permits: PM10 Offset Requirements in Salt Lake County and Utah County X R307-424 Permits: Mercury Requirements for Electric Generating Units X R307-501 to 505 Oil and Gas Industry X R307-801 Utah Asbestos Rule X R307-840 Lead-Based Paint Program Purpose, Applicability, and Definitions X R307-841 Residential Property and Child-Occupied Facility Renovation X R307-842 Lead-Based Paint Activities X 1. The subject rule is or could be applicable to Highland Pit; however, this rule is not specific to this project, and is therefore not discussed in this NOI air permit application. 2. Applicable NSPS and NESHAP regulations are detailed under appropriate project headings. 8.1.1 UAC R307-101 General Requirements Highland Pit will comply and conform to the definitions, terms, abbreviations, and references used in the UAC R307-101 and 40 CFR. 8.1.2 UAC R307-107 General Requirements: Breakdowns Highland Pit will report breakdowns within 24 hours via telephone, electronic mail, fax, or other similar method and provide detailed written description within 14 days of the onset of the incident to UDAQ. Kilgore Companies - Highland | Notice of Intent 8-5 8.1.3 UAC R307-150 Emission Inventories For every third year, Highland Pit will report its emissions inventory in accordance with R307-150- 6. The emissions inventory shall include all criteria pollutants, including filterable and condensable PM, hazardous air pollutants not exempted in R307-150-8 and chargeable pollutants in accordance with R307- 150-6. 8.1.4 UAC R307-201 Emission Standards: General Emission Standards All rules applicable to Highland Pit are incorporated by reference from 40 CFR Part 60. Applicability and requirements for these rules are outlined in Section 8.2 of this submittal. 8.1.5 UAC R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust UAC R307-205-4 Emission Standards Fugitive Emissions Highland Pit is located in Utah County, which is a nonattainment area for PM2.5 and PM10. Fugitive emissions from sources shall not exceed 20% opacity. UAC R307-205-5 Emission Standards - Fugitive Dust Owning, operating, or maintaining a new or existing material storage, handling, or hauling operation shall take measures to minimize fugitive dust from such activities. Such control may include enclosures, covers, stabilization or other equivalent methods or techniques as approved by the director. Highland Pit will comply with minimization techniques as described in R307-205-5. Steps will be taken to minimize fugitive dusts. UAC R307-205-7 Emission Standards Roads Highland Pit will supply traffic count information as determined necessary and clean any deposited materials that may create fugitive dust. UAC R307-205-7 Emission Standards Mining Activities Minimizing fugitive dust shall be an integral part of site preparation mining activities and reclamation operations. Fugitive dust control measures include: periodic watering of unpaved roads and application of chemical suppressant to unpaved roads, and prompt removal of coal, rock minerals, soil, and other dust- forming debris from roads. Additional controls include: frequent scraping and compaction of unpaved roads to stabilize the road surface, restricting the speed of vehicles in and around the mining operation and restricting the travel of vehicles on other than established roads. Enclosing, covering, watering, or otherwise treating loaded haul trucks to minimize loss of material to wind and spillage is a viable means to control fugitive dust from haul trucks. Substitution of conveyor systems for haul trucks and the covering of conveyor systems are subject to wind erosion. Additionally, minimizing the disturbed grounds and engaging in activities such as revegetation, mulching, or otherwise stabilizing the surface of all areas adjoining roads that are source of fugitive dust. Highland Pit will comply with minimization techniques described in R307-205-7. Highland Pit will also engage in various techniques aimed to reduce fugitive dust from mining activities. Techniques include, but are not limited to: application of chemical suppressant, water controls, maintaining both paved Kilgore Companies - Highland | Notice of Intent 8-6 and unpaved roads, restricting the speed of vehicles in and around mining operations, and control of dust from storage piles. 8.1.6 UAC R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust Fugitive emissions from any sources shall not exceed 15% opacity. Fugitive dust shall not exceed the following opacity limits: (a) 10% at the property boundary; and (b) 20% on site Any person responsible for construction or maintenance of any existing road or having right-of-way easement or possessing the right to use the same whose activities result in fugitive dust from the road shall minimize fugitive dust to the maximum extent possible. Any such person who deposits materials that may create fugitive dust on a public or private paved road shall clean the road promptly. Highland Pit will minimize fugitive dust created from the construction and maintenance of the existing paved road to the extent both practical and possible. 8.1.7 UAC R307-312 Aggregate Processing Operations for PM2.5 Nonattainment Areas R307-312-4 Visible Emissions (1) Visible emissions from aggregate processing operations shall not exceed opacity limits as described in Appendix Table I-2. Table 8-2. Aggregate Processing Operations Visible Emissions Category Opacity Limit Crushers 12% Screens 7% Conveyor Transfer Points 7% Highland Pit will comply with visible emissions for aggregate processing operations described in R307-312. 8.1.8 UAC R307-325: Ozone Nonattainment and Maintenance Areas: General Requirements Kilgore will continue to comply with general requirements for the control of VOCs. Kilgore will not allow or cause VOCs to be spilled, discarded, or stored in open containers. 8.1.9 UAC R307-401-8: Approval Order (1) The director will issue an AO if all conditions and regulations have been met. (a) The degree of pollution control for emissions, to include fugitive emissions and fugitive dust, is at least best available control technology. When determining best available control technology for a new or modified source in an ozone nonattainment or maintenance area that will emit VOC or NOX, Kilgore Companies - Highland | Notice of Intent 8-7 best available control technology shall be at least as stringent as any Control Technique Guidance document that has been published by EPA that is applicable to the source. (b) The Highland Pit will meet the applicable requirements of: (i) R307-403, Permits: New and Modified Sources in Nonattainment Areas and Maintenance Areas; (ii) R307-405, Permits: Major Sources in Attainment or Unclassified Areas (PSD); (iii) R307-406, Visibility; (iv) R307-410, Emissions Impact Analysis; (v) R307-421, Permits: PM10 Offset Requirements in Salt Lake County and Utah County; (vi) R307-210, National Standards of Performance for New Stationary Sources; (vii) National Primary and Secondary Ambient Air Quality Standards; (viii) R307-214, National Emission Standards for Hazardous Air Pollutants; (ix) R307-110, Utah State Implementation Plan; and (x) All other provisions of R307. (2) The AO requires that all pollution control equipment be adequately and properly maintained. (3) Receipt of an AO does not relieve any owner or operator of the responsibility to comply with the provisions of R307 or the State Implementation Plan. Highland Pit will establish and maintain compliance through the following: (1) All pollution control equipment will be properly maintained; and (2) Provisions of R307 or SIP will be followed. BACT provisions specified in UAC R307-401 have been applied through control equipment installed and monitoring conditions. 8.1.10 UAC R307-410 Permits: Emission Impact Analysis Emission impacts are not applicable with the proposed modification of Highland Pit. 8.1.11 UAC R307-414 Permits: Fees for Approval Orders Fees associated with the submission of this NOI air permit application are addressed in Section 2 of this submittal. 8.2 Federal Regulations 8.2.1 NSPS Subpart A: General Provisions All affected sources subject to an NSPS are also subject to the general provisions of NSPS Subpart A unless specifically excluded by the source-specific NSPS. NSPS Subpart A requires the following of facilities subject to a source specific NSPS: Initial construction/reconstruction notification Initial startup notification Performance tests Performance test date initial notification General monitoring requirements Kilgore Companies - Highland | Notice of Intent 8-8 General recordkeeping requirements Semiannual monitoring system and/or excess emission reports 8.2.2 NSPS Subpart Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 All tanks can be categorized as aboveground fixed-roof tanks. These tanks are not subject to regulations under NSPS Subpart Kb, , since all tanks meet one of the three exemptions to the regulation: A capacity of less than 75 cubic meters (m3); A capacity of greater than or equal to 151 m3 and storing a liquid with a maximum true vapor pressure of less than 3.5 kilopascals (kPa); or A capacity of between 75 m3 and 151 m3 and storing a liquid with a maximum true vapor pressure of less than 15.0 kPa. 8.2.3 NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants NSPS Subpart OOO, , provide standards of performance for affected facilities located at fixed or portable nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August 31, 1983. The following are considered affected facilities under NSPS Subpart OOO: Crushers Screening Operation Belt Conveyors The proposed project will involve the installation of nonmetallic mineral affected facilities under NSPS Subpart OOO (e.g., crushers, screens, conveyor belts, etc.). Per 40 CFR 60.672(a), the affected facilities must meet the emission limits and compliance requirements in Table 2 of the standard within 60 days after achieving maximum production rate but no later than 180 days after initial startup. Monitoring must be conducted in accordance with 40 CFR 60.674(c) or (d). Finally, testing, recordkeeping and reporting must be met in accordance with 40 CFR 60.675 through 60.676. Kilgore will demonstrate compliance with the requirements upon completion of construction of the affected facilities. Table 8-3. NSPS Subpart OOO Visible Emissions Requirement Opacity Limit Regulatory Citation I. Fugitive Emission Limits Crushers Opacity must be less than 12 percent for crushers for which a capture system is not used. 60.672(b) Table 3 II. Additional Fugitive Emission Limits (Excluding Crushing) Opacity must be less than 7 percent for screening operations, transfer points on belt conveyors or from any other affected facility. 60.670 60.671 Table 3 Kilgore Companies - Highland | Notice of Intent A FORMS Form 1 Date __________________ Notice of Intent (NOI) Application Checklist Company __________________ Utah Division of Air Quality New Source Review Section Source Identification Information [R307-401-5] 1. Company name, mailing address, physical address and telephone number 2. Company contact (Name, mailing address, and telephone number) 3. Name and contact of person submitting NOI application (if different than 2) 4. Source Universal Transverse Mercator (UTM) coordinates 5. Source Standard Industrial Classification (SIC) code 6. Area designation (attainment, maintenance, or nonattainment) 7. Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.) 8. Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers NOI Application Information:[R307-401] N/A N/A A. Air quality analysis (air model, met data, background data, source impact analysis)N/A Detailed description of the project and source process Discussion of fuels, raw materials, and products consumed/produced Description of equipment used in the process and operating schedule Description of changes to the process, production rates, etc. Site plan of source with building dimensions, stack parameters, etc. Best Available Control Technology (BACT) Analysis [R307-401-8] BACT analysis for all new and modified equipment Emissions Related Information: [R307-401-2(b)] Emission calculations for each new/modified unit and site-wide (Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs) References/assumptions, SDS, for each calculation and pollutant All speciated HAP emissions (list in lbs/hr) Emissions Impact Analysis – Approved Modeling Protocol [R307-410] Composition and physical characteristics of effluent (emission rates, temperature, volume, pollutant types and concentrations) Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403] NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements Alternative site analysis, Major source ownership compliance certification Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406] Visibility impact analysis, Class I area impact N/A Note: The Division of Air Quality will not accept documents containing confidential information or data. Documents containing confidential information will be returned to the Source submitting the application. Page 1 of 1 Form 4 Company____________________________ Project Information Site ______________________________ Utah Division of Air Quality New Source Review Section Process Data -For Modification/Amendment ONLY 1. Permit Number_______________________________ If submitting a new permit, then use Form 3 Requested Changes 2. Name of process to be modified/added: _______________________________ End product of this process: _______________________________ 3. Permit Change Type: New Increase* Equipment Process Condition Change ____________________ Other ______________________________ Other ______________________________ Other ______________________________ 4. Does new emission unit affect existing permitted process limits? Yes No 5. Condition(s) Changing: 6. Description of Permit/Process Change** 7. New or modified materials and quantities used in process. ** Material Quantity Annually 8. New or modified process emitting units ** Emitting Unit(s) Capacity(s) Manufacture Date(s) *If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an emissions increase and a public comment period. **If additional space is required, please generate a document to accommodate and attach to form. Page 1 of 1 Company___________________________ _____________________________ Form Emissions Information Criteria/GHGs/ Utah Division of Air Quality New Source Review Section Potential to Emit* Criteria Pollutants & GHGs Criteria Pollutants Permitted Emissions (tons/yr) Emissions Increases (tons/yr) Proposed Emissions (tons/yr) PM10 Total PM10 Fugitive PM2.5 NOx SO2 CO VOC VOC Fugitive NH3 Greenhouse Gases CO2e CO2e CO2e CO2 CH4 N2O HFCs PFCs SF6 Total CO2e *Potential to emit to include pollution control equipment as defined by R307-401-2. Hazardous Air Pollutants**(**Defined in Section 112(b) of the Clean Air Act ) Hazardous Air Pollutant*** Permitted Emissions (tons/yr) Emission Increase (tons/yr) Proposed Emission (tons/yr) Emission Increase (lbs/hr) Total HAP *** Use additional sheets for pollutants if needed Utah Division of Air Quality Date _______________________________________ New Source Review Section Company_____________________________ Site ___ Form 15 Aggregate Processing Operations Equipment Information 1. Check the appropriate crushing operations used in your process: Type of Unit ___________________________ Manufacturer/Model________________________ Design Capacity______________________tons/hr Date Manufactured ________________________ _ Primary Crushing type _ Cone _ Jaw _ Ball _ Secondary Crushing type _ Cone _ Jaw _ Ball _ Tertiary Crushing type _ Cone _ Jaw _ Ball Screen Manufacturer __________________________ Model and Date Manufactured __________________ Screen type and size (triple, double, or single deck) _________________________________ 2. Dust sources will be controlled as follows: No Pre Water Bag Other Control Soaked Spray house (explain) _ Feed hopper _ _ _ _ _ _ All belt transfer points _ _ _ _ _ _ Inlet to all crushers _ _ _ _ _ _ Exit of all crushers _ _ _ _ _ _ All shaker screens _ _ _ _ _ 3. Water Sprays Total Water Rate to nozzles (gal/min): __________ Nozzle pressure (psi): _____________ Quantity of nozzles at each spray bar location: ______________ 4. Maximum Plant Production Rate and Operating Hours: _______ tons/yr ________ tons/hr _______ hrs/yr ________ hrs/day 5. Water sprays used on storage piles? _ Yes _ No Storage pile size:____________________ 6a. Number of conveyor belt transfer and drop points: 6b. List manufactured dates for all conveyor belts NOTE: 1. Submit this form in conjunction with Form 1 and Form 2. 2. To relocate an Aggregate Plant submit Form 15b. 3.Call the Division of Air Quality (DAQ) at (801) 536-4000 if you have problems or questions in filling out this form. Ask to speak with a New Source Review engineer. We will be glad to help! 4. Equipment listed on this form may be subject to New Source Performance Standards. If so, additional information may be requested for the engineering review. Instructions 1. Indicate the type, manufacturer/model, design capacity and manufactured date of the equipment. Mark the appropriate box for the kind of crushing at the facility and indicate the type (cone, ball, jaw) of crushing being done. 2. Mark the appropriate box for the control device for the emission points. 3. List the specifications of the water sprays. Check vendor literature or call sales agent. 4 Indicate the maximum amount of product that will be processed by the facility in tons per hour, the number of hours the facility will be run per day and number of days/year. 5. Are water sprinklers used on storage piles? Indicate the size of the storage piles. 6. Provide the number of belt drop points and list manufactured dates for all your conveyor belts. N:\engineers\ehe\word\form\Form 15 Aggregate Processing Operations Revised 12/20/2010 Page 1 of 2 New Source Review Section Date: _____________________________ Utah Division of Air Quality Company: _________________________ Site/Source:________________________ Form 20 rganic Liquid Storage Tank O Equipment 1. Tank manufacturer: ___________________________ 2. Identification number: _____________________ 3. Installation date: ______________________________ 4. Volume: __________________________ gallons 5. Inside tank diameter: ______________________ feet 6. Tank height: ________________________ feet 7. True vapor pressure of liquid: _______________ psia 8. Reid vapor pressure of liquid: ____________ psi 9. Outside color of tank: __________________________ 10. Maximum storage temperature: __________ F O 11. Average throughput: ____________ gallons per year 12. Turnovers/yearly ____ Monthly ____ Weekly ___ 13. Average liquid height (feet): _____________________ Yes No Number ______14. Access hatch: 15. T a. P r b. S Type: ________________________________ 16. D ll Yes No Number_____ ll ak ype of Seals: rimary seals: Mechanical shoe Resilient filled Liquid filled Vapor mounted Liquid mounted Flexible wipe econdary seal: eck Fittings: Gauge float we Gauge hatch/ sample we Yes No Number_____ Roof drains Yes No Number_____ Rim vents Yes No Number_____ Vacuum bre Yes No Number_____ Roof leg Yes No Number_____ Ladder well Yes No Number_____ Column well Yes No Number_____ Other:_________________________________ 17. S Deck Fitting Category: ________________________ 18. T ______________________________________ hell Characteristics: Condition: _________________________________ Breather Vent Settings: ________________________ Tank Construction: ___________________________ Roof Type: __________________________________ Deck Construction: ___________________________ ype of Construction: Vertical Fixed Roof Horizontal Fixed Roof Internal Floating Roof External Floating Roof Other (please specify) 19. Additional Controls: Gas Blanket Venting Carbon Adsorption Thermal Oxidation Other:_______________ 20.Single Liquid Information Liquid Name: __________________________________ CAS Number: __________________________________ Avg. Temperature: ______________________________ Vapor Pressure: ________________________________ Liquid Molecular Weight: ________________________ Liquid Molecular Weight: ________________________ Liquid Name: __________________________________ CAS Number: __________________________________ Avg. Temperature: ______________________________ Vapor Pressure: ________________________________ Kilgore Companies Highland City November 2023 TBD TBD 2023 2 ,000 ,000 8'' Light beige 100 Good Horizontal Fixed Diesel Fuel Oil No. 2 Distillate 40 F - 100 F 0.0031 psia - 0.022 psia 188 lb/lb-mol Page 2 of 2 Form 20 - Organic Liquid Storage Tank (Continued) 21.Chemical Components Information Chemical Name: ________________________________ Percent of Total Liquid Weight: _____________________ Molecular Weight: _______________________________ Avg. Liquid Temperature: _________________________ Vapor Pressure: ________________________________ Vapor Pressure: ________________________________ Chemical Name: ________________________________ Percent of Total Liquid Weight: _____________________ Molecular Weight: _______________________________ Avg. Liquid Temperature: _________________________ Emissions Calculations (PTE) 22. C Submit calculations as an appendix. Provide Material Safety Data Sheets for products being stored. alculated emissions for this device: VOC _________Lbs/hr_____ Tons/yr HAPs_________Lbs/hr (speciate)______Tons/yr (speciate) Instructions Note: 1. Submit this form in conjunction with Form 1 and Form 2. 2. or questions in filling out this form. Ask to speak with a New Source Review engineer. We will be glad to help! on number that will appear on the tank. s or barrels. r in feet. liquid (psi). ach during storage (degrees Fahrenheit). emptied and refilled per year, month or week. ss hatches and the number. 17. Specify condition of the tank, also include the following: d roof tanks el construction sizes and seam length olled, or detail 22.ations for all criteria pollutants and HAPs. Use AP-42 or manufacturers’ data to complete your calculations. ENERIC\Forms 2010\Form20 Organic Liquid Storage Tanks.doc Revised 12/20/10 Call the Division of Air Quality (DAQ) at (801) 536-4000 if you have problems 1. Indicate the tank manufacturer's name. 2. Supply the equipment identificati 3. Indicate the date of installation. 4. Indicate the capacity of the tank in gallon 5. Specify the inside tank diamete 6. Specify the tank height in feet. 7. Indicate the true vapor pressure of the liquid (psia). 8. Indicate the Reid vapor pressure of the 9. Indicate the outside color of the tank. 10. Supply the highest temperature the liquid will re 11. Indicate average annual throughput (gallons). 12. Specify how many times the tank will be 13. Specify the average liquid height (feet). 14. Indicate whether or not the tank has acce 15. Indicate what type of seals the tank has. 16. Indicate what types of deck fittings are installed. Breather vent settings in (psig) for fixe Tank construction, welded or riveted Roof type; pontoon, double deck, or self-supporting roof Deck construction; bolted or welded, sheet or pan Deck fitting category; typical, contr 18. Indicate the type of tank construction. 19. Indicate other types of additional controls which will be used. 20. Provide information on liquid being stored, add additional sheets as necessary. 21. Provide information on chemicals being stored, add additional sheets as necessary. Supply calcul f:\aq\ENGINEER\G Kilgore Companies - Highland | Notice of Intent B EMISSION CALCULATIONS PM PM NO CO SO VOC Total HAP CO e Jaw Crusher 0.12 0.02 ------------ Tank -- -- -- -- -- 8.07E-05 -- -- Project Totals 0.12 0.02 -- -- -- 8.07E-05 -- -- Modeling Limit 5 -- 40 100 40 -- 10/25 -- Modeling Required?No No No No No No No No Currently Permitted Emissions 28.43 8.55 0.98 0.30 0.05 0.08 0.01 264.00 Proposed PTE 28.55 8.57 0.98 0.30 0.05 0.08 0.01 264.00 Major Source Thresholds 250 70 70 250 70 70 10/25 75,000 Exceeding Major Source Thresholds?No No No No No No No No Process Annual Emission Rates (tpy) Table B-1. Annual Potential Emissions Increase Summary Throughput Percent Potential Annual Throughput per Unit(%) (tpy)PM PM PM PM PM PM Primary Crushing Primary Crusher (Jaw Crusher)1 100% 1,650,000 Wet Suppression 1.40E-04 2.12E-05 0.63 0.10 0.12 1.75E-02 Table B-2. Annual Potential Emissions - Aggregate Processed Emission Factor (lb/ton) Daily PTE Emissions (lb/day) Annual PTE Emissions (tpy)Equipment / Activity Source Description Number of Units Controls Appendix B - Emission Calculations Table B-3. Tank Parameters Parameter Value Tank Type Horizontal Tank Tank Stock No. 2 Distillate Fuel Oil Tank Capacity (gal)5,000 Annual throughput in gal.25,000 Diameter (ft)8.00 Height (ft)13.33 Roof Type Fixed Roof Insulation Condition Not Insulated Roof Finish Beige Shell Finish Beige Annual Operation (days)365 Pollutant Value Hourly VOC (lb/hr)1 1.84E-05 Annual VOCs (tpy)8.07E-05 1. Yearly operating time (hr/yr):8760 Table B-4. Annual Potential Emissions - Tank Kilgore - Highland Pit 3 of 3 Trinity Consultants November 2023