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Home My WebLink AboutDAQ-2025-002352 DAQE-GN160410002-25 {{$d1 }} Dan Fitzgerald Las Vegas Paving 4420 S Decatur Boulevard Las Vegas, NV 89103 dan.fitzgerald@lasvegaspaving.com Dear Mr. Fitzgerald: RE: New Aggregate Processing Facility – CDS B; NSPS (Part 60), Title V (Part 70) Area Source, Project Number: N160410001 The Utah Division of Air Quality (DAQ) has approved your request for an 18-month extension to commence construction of the New Aggregate Processing Facility (Grantsville Pit). DAQ has extended the period to commence construction of the Grantsville Pit to no later than October 18, 2026. The Grantsville Pit is permitted under Approval Order (AO) DAQE-AN160410001-22, issued on April 18, 2022, to Las Vegas Paving Corporation (LVP). LVP notified DAQ on July 17, 2023, that the Grantsville Pit was not going to be operational by the 18-month construction commencement deadline of October 18, 2023. LVP then requested an extension of an additional 18 months as per AO DAQE- AN160410001-22 Condition II.8. The deadline of this extension was April 18, 2025. On April 14, 2025, LVP notified the DAQ that the Grantsville pit was still not operational and requested an additional 18- month extension. LVP also submitted a BACT analysis of the facility to the DAQ. The DAQ reviewed this submitted BACT analysis and determined that the requirements in AO DAQE- AN160410001-22 met current BACT standards and no changes to the AO were necessary. The DAQ approved the request for extension based on the submitted BACT analysis. Las Vegas Paving shall submit another update on the status of construction on or before the end of the 18-month extension (i.e., October 18, 2026). The DAQ will evaluate this information to determine whether reasonable progress is being made. At that time, the DAQ may take one of the following courses of action based on the information submitted: 1) approve the request for additional time to construct with no further action; 2) require a revised BACT analysis and an updated NOI based on the results of the revised BACT analysis; or 3) revoke the AO. 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 Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director 6ÞĄÛÙÛÞ DAQE-GN160410002-25 Page 2 The charge for the review done in making this change is a flat fee plus a filing fee as authorized by the Utah Legislature. You will receive an invoice for these charges shortly. If you have any questions, please contact John Persons, who can be reached at (385) 306-6503 or jpersons@utah.gov. Sincerely, {{$s }} Jon L. Black, Manager New Source Review Section JLB:JP:jg {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}} * ) ' & — 4 D v A ? A D @ B w D C ˜ UTAH DIVISION OF AIR QUALITY – NOTICE OF INTENT Las Vegas Paving - Grantsville, Utah New Approval Order Prepared By: TRINITY CONSULTANTS 4525 Wasatch Boulevard Suite 200 Salt Lake City, Utah 84124 (801) 272-3000 Submitted on Behalf of: LAS VEGAS PAVING 4420 S Decatur Blvd Las Vegas, NV 89103 December 2020 Project 204502.0036 Las Vegas Paving | Notice of Intent i TABLE OF CONTENTS EXECUTIVE SUMMARY 1-1 GENERAL INFORMATION 2-1 2.1 Description of LVP’s Installation ............................................................................. 2-1 2.2 Fees ........................................................................................................................ 2-2 2.3 Forms ...................................................................................................................... 2-2 DESCRIPTION OF PROJECT AND PROCESS 3-1 3.1 Description of LVP’s Project .................................................................................... 3-1 3.2 Description of LVP’s Process ................................................................................... 3-1 LVP Crushing and Screening Circuit......................................................................................... 3-1 LVP Wash Circuit................................................................................................................... 3-3 3.3 Site Plan.................................................................................................................. 3-4 EMISSIONS RELATED INFORMATION 4-1 4.1 LVP Crushing and Screening ................................................................................... 4-1 4.2 LVP Material Loading, Unloading and Transfer ........................................................ 4-1 4.3 LVP Stockpiles ........................................................................................................ 4-2 4.4 LVP Bulldozer Use ................................................................................................... 4-2 4.5 LVP Roads ............................................................................................................... 4-3 4.6 LVP Blasting ............................................................................................................ 4-4 4.7 LVP Drilling ............................................................................................................. 4-5 4.8 LVP Source Size Determination ............................................................................... 4-6 BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS 5-1 5.1 LVP Crushing and Screening Aggregate Operations ................................................ 5-1 PM10 and PM2.5 Emissions ....................................................................................................... 5-1 Baghouse/Fabric Filter ................................................................................................................5-1 Cyclone .....................................................................................................................................5-2 Electrostatic Precipitator .............................................................................................................5-2 Enclosures .................................................................................................................................5-2 Management/Operation Practices ................................................................................................5-2 Watering and Material Moisture Content ......................................................................................5-2 Wet Scrubber.............................................................................................................................5-3 5.2 LVP Road Emissions ................................................................................................ 5-4 Fugitive PM10 and PM2.5 Emissions .......................................................................................... 5-4 Chemical Treatment ...................................................................................................................5-4 Reduced Speed ..........................................................................................................................5-5 Road Paving ..............................................................................................................................5-5 Silt Content Reduction ................................................................................................................5-5 Street Sweeping.........................................................................................................................5-5 Watering and Material Moisture Content ......................................................................................5-5 5.3 LVP Drilling and Blasting ......................................................................................... 5-6 NOX and SO2 – Blasting ......................................................................................................... 5-6 PM10 and PM2.5 – Drilling and Blasting ..................................................................................... 5-6 Shroud Application to Drilling Equipment .....................................................................................5-7 Best Management and Operational Practices for Drilling and Blasting ............................................5-7 Las Vegas Paving | Notice of Intent ii Dust Collection System on Drilling Equipment ..............................................................................5-7 Water Spray on Drilling Equipment ..............................................................................................5-7 Drilling and Blasting PM10 and PM2.5 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ........................................................................................................................ 5-8 Drilling and Blasting PM10 and PM2.5 Step 4 – Evaluate Most-Effective Controls and Document Results ........................................................................................................................................... 5-8 Drilling and Blasting PM10 and PM2.5 Step 5 – Select BACT ......................................................... 5-9 5.4 LVP Disturbed Grounds ........................................................................................... 5-9 EMISSION IMPACT ANALYSIS 6-1 6.1 LVP Comparison to Modeling Thresholds ................................................................ 6-1 NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING 7-1 7.1 LVP Offset Applicability ........................................................................................... 7-1 APPLICABLE REGULATIONS 8-1 8.1 General Introduction – LVP Utah Regulations ......................................................... 8-1 UAC R307-101 General Requirements: .................................................................................... 8-4 UAC R307-107 General Requirements: Breakdowns .................................................................. 8-5 UAC R307-150 Emission Inventories: ...................................................................................... 8-5 UAC R307-201 Emission Standards: General Emission Standards: .............................................. 8-5 UAC R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust: .................................. 8-5 UAC R307-307 Road Salting and Sanding ................................................................................ 8-6 UAC R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust: ....................................................................................................................... 8-6 UAC R307-312 Aggregate Processing Operations for PM2.5 Nonattainment Areas: ........................ 8-7 UAC R307-401-8: Approval Order: .......................................................................................... 8-7 UAC R307-410 Permits: Emission Impact Analysis: ................................................................... 8-8 UAC R307-414 Permits: Fees for Approval Orders: ................................................................... 8-8 8.2 LVP Federal Regulations ......................................................................................... 8-8 NSPS Subpart A: General Provisions ........................................................................................ 8-8 NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants ............ 8-8 NESHAP Subpart A (General Provisions) .................................................................................. 8-9 FORMS A EMISSION CALCULATIONS B AIR DISPERSION MODELING PROTOCOL/REPORT C Las Vegas Paving | Notice of Intent 1-1 EXECUTIVE SUMMARY Las Vegas Paving Corp. (LVP) is a heavy civil construction company, that provides a comprehensive list of services from paving to roto-milling, excavating, and recycling. LVP is proposing to operate a permanent aggregate mining, sizing, washing, and sales and distribution operations at Lhoist North America of Arizona, Inc. (Lhoist or LNA) Grantsville Plant, in Grantsville, Utah in Tooele County. The proposed LVP operation is located within an area of Tooele County designated as a non-attainment area of the National Ambient Air Quality Standards (NAAQS) for particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5) and 2015 8-hour ozone. In addition, nitrogen oxide (NOX), sulfur dioxide (SO2), volatile organic compounds (VOCs) and ammonia (NH3) are considered precursors to PM2.5 in Utah. LVP currently operates temporary crushing and screening activities under a temporary relocation of portable equipment permit. LVP is submitting a Notice of Intent (NOI) air quality permit application to the Utah Division of Air Quality (UDAQ) to obtain an air quality Approval Order (AO) to establish a permanent operation in Grantsville, Utah. The NOI application is for mining, crushing, and screening operations, washing, and sales to be conducted only by LVP at the Grantsville Operation. As LVP is proposing to install equipment and operations on LNA’s existing Grantsville Plant Title V facility, an agreement between the two parties establishes that all LVP operations will cease during any 24-hour period (i.e., midnight-to-midnight) that LNA would be operating existing equipment in accordance with its current Title V air operating permit (Permit Number 4500005003).1 This condition was agreed upon based on the current demand for lime products from LNA’s operations. Emissions from the LVP installation and operations will consist of particulate matter (PM) with an aerodynamic diameter of 10 microns or less (PM10) and of filterable PM2.5 fugitives. Fugitive dust controls will be implemented through the use of water and/or chemical suppressant throughout the processes. The facility is proposed to be permitted as a minor source and will be subject to 40 CFR 60, New Source Performance Standards (NSPS) Subpart OOO. Additionally, the emissions triggered an impact analysis included in Appendix C. Emission calculations were performed for the LVP’s Grantsville installation and operations to determine the proposed emissions of criteria pollutants (see Appendix B). The proposed emissions constitute the LVP Grantsville potential to emit (PTE); see Table 4-1. PTE values for criteria pollutants, given in tons per year (tpy) are proposed as follows: PM10 = 21.67, PM2.5 = 3.57, NOX = 8.50, CO = 33.50, SO2 = 0.06, VOC = 0.00, and HAPs = 0.00. The LVP’s Grantsville Operation is proposed to be permitted as a minor source. This NOI application has been developed pursuant Utah Administrative Code (UAC) R307-401-5 and Utah’s application guidance including but 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. 1 Lhoist submitted a renewal application on June 25, 2020 within 180 days prior to the expiration of its Title V air operating permit. Las Vegas Paving | Notice of Intent 2-1 GENERAL INFORMATION 2.1 Description of LVP’s Installation The LVP Grantsville Operation will be a standalone, aggregate mining, crushing, and screening, and sales operation located at 8700 North Ellerbeck Rd. Grantsville, Utah 84029. Although co-located with LNA’s Grantsville Lime Plant, the LVP Grantsville Operation will be separate from the lime plant and mining activities. The LVP Grantsville Operation’s end product is processed aggregate, whereas LNA’s Lime Plant operation mines and processes high-quality dolomitic limestone for various quicklime products sold. For LVP to produce processed aggregate, drilling and blasting operations will be conducted within the mining area to produce aggregate in a manageable size, which will then be transported to the crushing and screening operations. The aggregate crushing and screening operations will consist of two (2) operations; a Crushing and Screening Circuit and a Wash Circuit. This equipment will be separate and standalone from LNA’s existing crushing and screening equipment. The Crushing and Screening Circuit will size and stockpile aggregate that is blasted from the mining area. The Wash Circuit will then wash, screen, and stack a portion of the aggregate processed in the Crushing and Screening Circuit. Aggregate processed by both the Crushing and Screening Circuit and the Wash Circuit will then be sold and removed from the site using haul trucks. Some unprocessed aggregate will be sold and loaded into haul trucks directly after being blasted. In order to prepare an area for mining, stripping of overburden soil and stone is typically required. Some bulldozing emissions have been accounted for in overburden removal, although this activity is anticipated to be minimal for the proposed mining operation. Likewise, bulldozing emissions have been addressed for the reclamation requirements at the site. As addressed in the emission calculations, these emissions are anticipated to be minimal. The LVP Grantsville installation and operation are proposed to be permitted as a minor source (see Table 4- 1). The Standard Industrial Classification (SIC) code for the LVP Grantsville Operation is 1442, Construction Sand and Gravel. The LVP operation is under a separate SIC code than LNA, which is 3274, Lime. Accordingly, they are separate operations. LVP operations are currently under way at the site under a temporary relocation permit, DAQC-1217-20. The AO that LVP is seeking is proposed to be a standalone permit separate and apart from LNA’s AO and Title V operating permit.2 If this operating scenario would change in the future, LVP, on behalf of LNA and LVP, will notify the UDAQ 30 days prior to the change, or submit a revised NOI air permit application. The Universal Transverse Mercator (UTM) coordinates for the LVP Grantsville Operation are as follows: ► Easting: 366,928.49 ► Northing: 4,506,861.12 ► Zone: 12T ► 1984 World Geodetic System All correspondence regarding this submission should be addressed to: Mr. Dan Fitzgerald 4420 S Decatur Blvd Las Vegas, NV 89103 dan.fitzgerald@lasvegaspaving.com Phone: (702) 353-4607 2 LNA currently maintains Title V air operating permit number 4500005003 and Approval Order DAQE-AN0707015-06. Las Vegas Paving | Notice of Intent 2-2 2.2 Fees LVP will use UDAQ’s Payment Portal to prepay the following UDAQ NOI fees associated with this submittal: ► “Application Filing Fee” for the “New Minor Source and Major (not PSD) Source” source type = $500 ► “Application Review Fee” for the “New Minor Source” source type = $2,000 ► Total UDAQ fees = $2,500 LVP understands that the total permit review fee is based on the total actual time spent by UDAQ staff processing this NOI. Upon issuance of the AO, if the total review time is more than twenty (20) standard hours, UDAQ will invoice LVP at $100 per hour for the additional time above twenty (20) standard hours. 2.3 Forms The following UDAQ forms have been included in Appendix A of this application: ► Form 1: Notice of Intent (NOI) Application Checklist ► Form 2: Company Information/Notice of Intent ► Form 3: Process Information ► Form 5: Emissions Information ► Form 15: Rock Crushing and Screening Las Vegas Paving | Notice of Intent 3-1 DESCRIPTION OF PROJECT AND PROCESS 3.1 Description of LVP’s Project LVP is proposing to install an aggregate Crushing and Screening Circuit, a wash plant (Wash Circuit), and aggregate mine at LNA, Grantsville Plant in Grantsville, Utah in Tooele County. The facility is operating under a temporary permit. LVP is submitting this NOI air quality permit application to obtain an AO for the Crushing and Screening Circuit, the Wash Circuit, and the mining of aggregate. Both the Crushing and Screening and Wash Circuits will be powered by line power. Installations and the associated emission sources are as shown below. Site-wide emission projections based on this equipment are detailed in Section 4. Crushing and Screening Circuit ► One (1) Feeder [800 tph]; ► One (1) Horizontal Shaft Impact (HSI) Crusher [400 tph]; ► One (1) Vertical Shaft Impact (VSI) Crusher [400 tph]; ► One (1) Cone Crusher [400 tph]; ► One (1) Primary Triple-deck Screen [800 tph]; ► One (1) Secondary Triple-deck Screen [400 tph]; ► One (1) Tertiary Triple-deck Screen [400 tph]; ► 19 Various Conveyors [≤ 800 tph]; ► Five (5) Stackers [≤ 400 tph]; and ► Five (5) Stockpiles. Wash Circuit ► Three (3) Bin Feeders [400 tph]; ► One (1) Wash Screen [400 tph]; ► One (1) De-Water Screen [400 tph]; ► Six (6) Conveyors [≤ 400 tph]; ► Four (4) Stackers [≤ 400 tph]; ► Four (4) Stockpiles; ► One (1) Sand Screw Washer [400 tph]; and ► One (1) Clarifier [10 tph]. Mining Operations ► Drilling; ► Blasting; ► One (1) Bulldozer [Off-Hwy Equipment]; ► Two (2) Front-end Loaders [Off-Hwy Equipment]; and ► Truck (Future Operations) ► Five (5) Acres of Disturbed Ground. 3.2 Description of LVP’s Process LVP Crushing and Screening Circuit Figure 1 shows a process flow diagram (PFD) of the Crushing and Screening Circuit portion of the crushing and screening operations. Material is blasted from the mine area, wetted (as necessary), and then transported to the primary feeder by front-end loaders and/or haul truck loaded by loaders. Aggregate is fed Las Vegas Paving | Notice of Intent 3-2 into the horizontal shaft impact (HSI) crusher for sizing. Crushed aggregate is then screened through a triple deck screen, which separates the aggregate by size. Some of the screened aggregate is initially stockpiled into two (2) stockpiles, one (1) by a conveyor drop and one (1) by a stacker. Some of the screened aggregate is sent to a vertical shaft impact (VSI) crusher, which further reduces the size of the aggregate, before it is sent to another triple-deck screen. Screened aggregate is then stockpiled into two (2) stockpiles. From the first triple-deck screen, the aggregate that is not stockpiled or sent to the VSI crusher is sent to a cone crusher for further sizing. The cone crusher feeds a triple-deck screen that separates the crushed aggregate into different sizes. Some of the screened material is recycled back into the cone crusher, some is fed into the VSI crusher, and some is stacked into a stockpile with a stacker. This Crushing and Screening Circuit process 90% of the total, 1,500,000 tpy of mined aggregate. The remaining 10% is sold as unprocessed aggregate immediately following blasting and wetting. A portion of the processed aggregate that exits the Crushing and Screening Circuit is then sent to the Wash Circuit, which is shown in Figure 2. Figure 3-1. Crushing and Screening Circuit Process Flow Diagram. Las Vegas Paving | Notice of Intent 3-3 LVP Wash Circuit Figure 2 shows the PFD of the Wash Circuit portion of the crushing and screening operations. Processed material from the Crushing and Screening Circuit is loaded into the bin feeders with front-end loaders, where it is then washed and saturated with water in the wash screen. Sized material is then immediately stockpiled via three (3) separate stackers or it is de-watered by a de-water screen and then stockpiled via a fourth stacker. Some water is removed from the washed aggregate in a sand screw and sent to a clarifier to allow particulate matter to settle. The clarifier sends water and particulate matter to a tailings pond for treatment. Figure 3-2. Wash Circuit Process Flow Diagram. Las Vegas Paving | Notice of Intent 3-4 3.3 Site Plan Figure 3-3, shown below, provides a vicinity map of the LNA Grantsville Plant where LVP is proposing to operate. The property boundaries are shown in green. Figure 3-4 provides a closer view of the site boundaries and shows the haul road route followed by customer haul trucks hauling sold product off site (blue). Figure 3-3. Site Vicinity Las Vegas Paving | Notice of Intent 3-5 Figure 3-4. Property Boundary Close-up and Main Haul Road Las Vegas Paving | Notice of Intent 4-1 EMISSIONS RELATED INFORMATION This section details the methodology used to calculated controlled and uncontrolled emissions for criteria pollutants, greenhouse gases, and hazardous air pollutants (HAPs) associated with each new unit and its associated fugitives as regulated by R307-401-5(2)(b). Additionally, a comparison to major source thresholds is conducted. Detailed emission calculation tables are included in Appendix B. 4.1 LVP Crushing and Screening PM, PM10, and PM2.5 emissions generated from the crushing and screening of aggregate are estimated by multiplying the material throughput by the appropriate emission factor (EF). Uncontrolled EFs for screening and 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: Annual Emissions (tpy)=EF �lbton�× Annual Throughput (tpy)× �ton2,000 lb�× Equipment Quantity Crushing and screening operations are divided into two (2) different circuits, the Crushing and Screening Circuit and the Wash Circuit. The former crushes and screens all 1,500,000 tpy of mined material; the latter reprocesses a portion of that quantity. In the Crushing and Screening Circuit, water sprays will be used in addition to the inherent moisture content of mined material to contain fugitive dust emissions. Aggregate processed in the Wash Circuit will have any potential fugitive dust emissions essentially eliminated by its saturation in water as part of the washing process. It is thus assumed that PM emissions from the Wash Circuit will be negligible. This will be discussed further in Section 5. 4.2 LVP Material Loading, Unloading and Transfer For conveyor transfer points, EFs from AP-42, Section 11.19.2 were used. For Crushing and Screening, dropped material transfer, including stacker drops resulting from the Crushing and Screening Circuit, material loading in both circuits, and material unloading in the Crushing and Screening Circuit, the uncontrolled PM10 and PM2.5 EFs were obtained from the “drop equation” in AP-42, Section 13.2.4 (November 2006). Fugitive dust emissions resulting from Wash Circuit material transfer and unloading are assumed to be negligible due to the washing process and the saturation of the aggregate in water. The equation for all emitting drops is: E =k(0.0032)× �U5�1.3 �M2�1.4 where: E = emission factors (lb/ton) k = particle size multiplier (dimensionless) U = mean wind speed (mph) M = material moisture content (%) Parameter “U” is determined from historical data retrieved from the Salt Lake City Airport in Salt Lake City, UT over the past five (5) years (January 2015 – January 2020). The material moisture content used in this equation for the Crushing and Screening Circuit is based on values previously recommended by UDAQ. Las Vegas Paving | Notice of Intent 4-2 Material throughput for transfer will incorporate the maximum site-wide throughput of 1,500,000 tpy and the appropriate equipment throughput ratio for each process. The annual PM emissions rate for the Crushing and Screening Circuit, given in tpy, is given by the equation below. The EF corresponds to the annual emissions of the criteria pollutant in question at the time of use of the equation; namely, PM10 or PM2.5. Annual Crushing and Screening PTE (tpy)=Potential Annual Throughput (tpy)× EF�lbton�× Number of Units or Drop Points×Conversion�1 ton2,000 lb� It is assumed that the Wash Circuit will not have PM emissions resulting from material transfer due to the washing process and the saturation of its aggregate in water. 4.3 LVP Stockpiles A maximum, total stockpile area was determined based on a conservative engineering estimate of the facility. It is assumed that the total stockpile area will not exceed the reported size on any given day. The maximum pile area is multiplied by an EF, along with several conversion factors, to determine the potential emissions associated with each stockpile. EFs are chosen based on what size the particle is (PM2.5 or PM10), and whether the stockpile is controlled or uncontrolled. All stockpiles will be controlled with water application; stockpiles from the Crushing and Screening Circuit will have water applied via a water spray, whereas stockpiles from the Wash Circuit will be saturated with water from the washing process. Uncontrolled EFs were obtained from AP-42 Fourth Edition Table 8.19.1-1 and AP-42 Appendix B.2 Table B.2-2.3,4 Annual Stockpile Emissions (tpy)=Max.Pile Area (acre)× EF �lbday⋅acre�× Conversion�365 day × 1 ton1 year × 2,000 lb� 4.4 LVP Bulldozer Use PM10, and PM2.5 emissions generated from bulldozing were calculated assuming one (1) bulldozer operating 1,000 hours per year. Bulldozer emissions are multiplied by the EFs given in AP-42, Section 11.9 (October 1998). AP-42 Table 11.9-1 provides the following equations for calculating EFs for total suspended solids (TSP) and PM15 from bulldozing operation: TSP =5.7(s)1.2(M)1.3 PM15 =1.0(s)1.5(M)1.4 where: TSP and PM15 = emission factors (lb/hr) s = material silt content (%), M = material moisture content (%), 3 AP-42 Fourth Edition, Table 8.19.1-1. https://www3.epa.gov/ttn/chief/ap42/oldeditions/4th_edition/ap42_4thed_orig.pdf 4 AP-42 Appendix B.2, Table B.2-2. https://www3.epa.gov/ttn/chief/ap42/appendix/appb-2.pdf Las Vegas Paving | Notice of Intent 4-3 The material silt content was provided by LVP while the material moisture content was suggested by UDAQ. Note that the silt content for bulldozing is lower than those values given for bulldozing of overburden in AP- 42 Section 11.9. This is due to the highly exposed nature of the consolidated calcium carbonate and minimal overburden covering where LVP’s bulldozing operations occur. As AP-42 Section 11.9 only accounts for Western Surface Coal Mining, and as the given silt value is particular to LVP’s location, this value is deemed appropriate for LVP’s bulldozing operations. AP-42 Section 11, Table 11.9-1, provides scaling factors that are applied to TSP and/or PM15 EFs to obtain PM10, and PM2.5 EFs. PM10 and PM2.5 EFs were calculated as follows: ► PM10 = 0.75 x PM15; and ► PM2.5 = 0.105 x TSP. The annual PM emissions generated by bulldozer use are estimated by utilizing the EFs stated above. The EF is multiplied by the maximum annual operating hours, the application of the control efficiency, the number of bulldozers, and the conversion factor of pounds to tons. Annual Dozing Emissions (tpy)=EF �lbhr�× Max.Operating Hours�hryr�× [1 −Control Efficiency (%)]× Number of Dozers×Conversion�1 ton2,000 lb� 4.5 LVP Roads The haul roads at the LVP Grantsville Operation consist solely of unpaved roads. PM10 and PM2.5 emissions were derived using the guidance found in UDAQ’s March 10, 2008 memorandum regarding EFs for unpaved haul roads5. Emissions from these roads were calculated using the following equation: PM =k × �s12�a × �W3�b × D × 1 ton2,000 lb × (1 − η) Where: PM = PM/PM10/PM2.5 emissions (tpy) k = PM/PM10/PM2.5 k-Factor (lb/VMT) s = Average silt content (%) W = Mean vehicle weight (tons) D = Distance traveled (VMT/yr) a = Constant for equation (varies for PM/PM10/PM2.5) (unit less) b = Constant for equation (varies for PM/PM10/PM2.5) (unit less) η = Control efficiency (%) Parameter (W) is determined for each vehicle type by taking the average of the mean loaded and unloaded weights of the different types of vehicles; in this case, tractor trailers, medium front-end loaders, and large front-end loaders.6,7 Parameter (D) is determined by using the product throughput divided by the difference in full and empty vehicle weight to determine the total number of hauls required. This value is multiplied by 5 Per memorandum issued by UDAQ; “Emission Factors for Paved and Unpaved Haul Roads” dated January 12, 2015. 6 National Academy of Sciences, Technologies and Approaches to Reducing the Fuel Consumption of Medium and Heavy-Duty Vehicles, prepublication copy, March 2010, pp. 2-2 and 5-42. Table 5.13. 7 Per UAC R909-2-5. Table 2. Las Vegas Paving | Notice of Intent 4-4 the round-trip distance traveled by the customer trucks. The average silt content used in this equation was given by LVP based on engineering estimates. As a means of control, a watering truck regularly applies water to suppress fugitive PM emissions at the LVP Grantsville Operation for loader travel. In addition, chemical suppressant is applied as necessary to the main haul route. Therefore, using guidance from the memorandum issued by UDAQ regarding emission factors for paved and unpaved haul roads, a control factor of 70% for basic watering and a control factor of 85% chemical suppressant application and watering were used for fugitive emissions related to vehicle traffic. Loader tram lengths are conservatively estimated to be 100 feet per haul, as the majority of loader operations serve to load equipment or vehicles in distinct areas. Emissions were projected based on the Pit’s road layouts, vehicle weights, and hauling capacity. 4.6 LVP Blasting For LVP to produce processed aggregate, drilling and blasting operations will be conducted within the mining area to produce aggregate in a manageable size, which will then be transported via a single conveyor to the crushing and screening operations. The following assumptions were made for blasting operations: ► At most, a blasting event will occur once per day; ► The maximum blasting area per blast is 25,000 square feet (ft2) and was provided per design basis; ► Blasting will occur no nearer than 300 feet from the property boundary; and, ► During a blasting day, hours of operation for the Pit will be reduced from 16 to 14 hours per day, from 4:00AM-8:00PM. The blasting SO2 emission factor is obtained from AP-42 Section 13.3-1. The SO2 EF was developed using a mass balance that assumes a 6% fuel oil mixture with 500 ppm sulfur content, consistent with EPA non- road standards. EFSO2 �lbton�=Sulfur Content (ppm)× %Fuel Oil Mixture × Conversion Both the NOX and CO EF is that of the ANFO blasting agent factor from AP-42 Section 13.3; and PM10 and PM2.5 EFs were based on the blasting PM EF given in AP-42 11.9, where a maximum blasting depth of 70 feet is used, by the following equation: EFPM �lbblast�=1.4 × 10−5 × A(ft2)1.5 Where EFPM is the EF of PM in pounds per blast, and A is the average daily blast area in square feet. Scaling factors were applied to the TSP EF to calculate PM10 and PM2.5 EFs, respectively, per AP-42 Table 11.9, as seen below. It is conservatively assumed that the PM EF is equal to the TSP EF. EFPM10 �lbblast�=EFPM �lbblast�× 0.52 EFPM2.5 �lbblast�=EFPM �lbblast�× 0.03 Where EFPM10 is the EF of PM10 given in pounds per blast and EFPM2.5 is the EF of PM2.5 given in pounds per blast. Note that, as there is only one (1) blast per day, pounds per blast is equivalent to pounds per day. Las Vegas Paving | Notice of Intent 4-5 Daily fugitive dust (PM, PM10, and PM2.5) blasting emissions were calculated using blasting material quantities, which were provided per design basis. Blasting emissions are calculated as follows: Daily Fugitive Dust Emissions �lbsday�=EF �lbsblast�× (1 −%control)× �1 blastday� Where the EF is that of PM, PM10, or PM2.5, whichever is calculated. Annual fugitive dust (PM, PM10, and PM2.5) blasting emissions are given as follows: Annual Emissions (tpy)=Daily Fugitive Dust Emissions �lbsday�× Annual # of Blasts × Conversion �tons ⋅daylb⋅year � Where the Daily Fugitive Dust Emissions are those of PM, PM10, or PM2.5, whichever is calculated. Daily emissions for SO2, NOX, and CO are calculated for each pollutant as follows: Daily Emissions �lbsday�=EF�lbston�× Annual ANFO Use (tpy)× Conversion �yeardays� Annual emissions for SO2, NOX, and CO are calculated for each pollutant as follows: Annual Emissions (tpy)=EF �lbston�× Annual ANFO Use (tpy)× Conversion �tonslb� 4.7 LVP Drilling Drilling operations precede blasting operations, allowing for the placement of explosives beneath the surface of the mine. For drilling emissions, the following assumptions are applied: The drilling PM EF is retrieved from AP-42 Section 11.9, utilizing the conservative drilling PM EF given for overburden material. As no EFs are provided for PM10 and PM2.5 drilling operations, EFs were calculated using the PM10 and PM2.5 to TSP ratios for blasting overburden per AP-42 Section 11.9, where the factor for PM10 is 0.52 and the factor for PM2.5 is 0.03, as shown below; EFPM10 =EFPM15 × 0.52 And EFPM2.5 =EFTSP × 0.03 For the purposes of determining the PM10 and PM2.5 EFs, the EF for PM, PM15, and TSP are considered equivalent. Fugitive dust emissions from drilling operations will be controlled through the use of wet drilling in conjunction with a dust collection (i.e., bin vent or baghouse) system. The EPA reports that baghouses can achieve a 95-99.9% control efficiency, while the National Institute for Occupational Safety and Health (NIOSH) reports that wet drilling achieves a control of fugitive emissions between 86-97.8,9 As both control methods will be used in conjunction one with the other, it is conservatively assumed that the highest control 8 From EPA Air Pollution Control Technology Fact Sheet for baghouses: https://www3.epa.gov/ttnchie1/mkb/documents/ff-pulse.pdf (EPA-452/F-03-025). 9 Summary of NIOSH research completed on dust control methods for surface and underground drilling, Pg 2, December 2008 Las Vegas Paving | Notice of Intent 4-6 efficiency of wet drilling and the average control efficiency of baghouses is achieved for drilling operations (97%). The daily emissions of PM, PM10, and PM2.5 were calculated as follows: Daily Emissions �lbday�=EF �lbhole�× Daily # of Holes �holesday�× (1 −%control) Where both the daily emissions and the EF are those of the pollutant in question (i.e., PM, PM10, or PM2.5). The annual emissions of PM, PM10, and PM2.5 were calculated as follows: Annual Emissions (tpy)=EF�lbhole�× Annual Holes Drilled �holesyear�× (1 −%control)× Conversion �tonlb� Where both the annual emissions and the EF are those of the pollutant in question (i.e., PM, PM10, or PM2.5). 4.8 LVP Source Size Determination The results of criteria pollutant emission calculations done for the LVP Grantsville Operation are compared against major source thresholds in Table 4-1, below. The emissions presented are only for the LVP installation and operation and do not include emissions from LNA’s Grantsville Plant as they are standalone operations under a separate permit. The LVP Grantsville Operation is located in an area of nonattainment for PM2.5 and ozone, but in attainment area for all other pollutants. As previously mentioned, NOX, SO2, VOCs, and ammonia are all precursors of PM2.5. As presented in the table below, none of the proposed emissions at the LVP Grantsville Operation are greater than major source thresholds (i.e., 100 tpy for any criteria pollutant with exception to direct PM2.5 and its precursors for which the major source threshold is 70 tpy, 10 tpy for any HAP, 25 tpy for all HAPs combined, and 100,000 tpy for CO2e). Therefore, the LVP Grantsville Operation will be classified as a minor source. Table 4-1. Proposed LVP Installation and Operations Emissions Versus Major Source Thresholds. Emissions (tpy) PM10 PM2.5 NOX CO SO2 VOC CO2e Crushing and Screening Operations 1.68 0.24 0.00 0.00 0.00 0.00 0.00 Stockpiles and Disturbed Grounds 3.77 1.59 0.00 0.00 0.00 0.00 0.00 Bulldozers and Drops 1.56 0.30 0.00 0.00 0.00 0.00 0.00 Drilling and Blasting 0.74 0.04 8.50 33.50 0.06 0.00 -- Roads 13.91 1.39 0.00 0.00 0.00 0.00 0.00 Proposed Site-Wide Emissions1 21.67 3.57 8.50 33.50 0.06 0.00 0.00 Major Source Thresholds2 100 70 70 100 70 70 100,000 Threshold Exceeded? No No No No No No No 1. Ammonia and HAPs emissions were considered in the LVP Grantsville Operation’s facility-wide emissions; however, these emissions are not applicable, as site power is provided by line power and there are no other sources of ammonia or HAPs. 2. Values are per UAC R307-403-5(2)(b)(ii) Las Vegas Paving | 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 LVP Crushing and Screening Aggregate Operations PM10 and PM2.5 Emissions The LVP Grantsville Operation have two (2) crushing and screening operations for aggregate mined on site; a Crushing and Screening Circuit and a Wash Circuit. The equipment associated with these operations include the following classifications: ► Crushing ► Screening ► Conveyor transfer points ► Stackers ► Stockpiles This BACT analysis has been completed for all material handling operations within the Crushing and Screening Circuit, but only for material loading operations within the Wash Circuit. It is assumed that PM2.5 and PM10 emissions resulting from material transfer within and material unloading from the Wash Circuit are negligible. This is due to the washing process and saturation of aggregate that is processed in the Wash Circuit. 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 January 6, 2020 review of relevant entries in EPA’s RACT/BACT/LAER Clearinghouse (RBLC): ► Baghouse/Fabric Filter ► Cyclone ► Electrostatic Precipitator ► Enclosures ► Management/Operation Practices ► Watering and Material Moisture Content ► Wet Scrubber 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%10. This is generally accomplished through the installation of ductwork, capture hoods, fans, motors, starters, stacks, and other 10 From EPA Air Pollution Control Technology Fact Sheet for baghouses: https://www3.epa.gov/ttnchie1/mkb/documents/ff-pulse.pdf (EPA-452/F-03-025). Las Vegas Paving | Notice of Intent 5-2 stationary equipment. Material at the LVP Grantsville Operation travels through a series of mobile conveyors that extend hundreds of feet. The process requires flexibility to alter on-site stockpile configurations and the location of crushing and screening operations. In other words, the crushing and screening 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 PM2.5 and PM10 removal is likely to achieve between 20% to 70% removal for PM2.5 and 60% to 95% removal for PM10, respectively.11 Like a baghouse, cyclone feasibility is based on routing emissions to a stationary control system via ductwork, capture hoods, fans, etc. This caveat results in a cyclone being technically infeasible for the LVP Grantsville Operation, 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%12. 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.13 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. Although effective, industrial enclosures are permanent structures. As discussed, the LVP Grantsville Operation operate with mobile equipment, which requires flexibility of stockpile configurations. Therefore, enclosures are technically infeasible as control technology. Management/Operation Practices Management practices during material movement, such as minimizing drop heights, will minimize PM2.5 and PM10 emissions and will be implemented in 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 emissions14. This control measure is considered technically feasible for material handling. 11 From Air Pollution Control Technology Fact Sheet for cyclones: https://www3.epa.gov/ttn/catc/dir1/fcyclon.pdf (EPA-452/F- 03-005) 12 From EPA Air Pollution Control Technology Fact Sheet for Crushing and Screening Electrostatic Precipitators: https://www3.epa.gov/ttn/catc/dir1/fdespwpi.pdf (EPA-452/F-03-028) 13 Ibid. 14 From Western Regional Air Partnership, Fugitive Dust Handbook; Executive Summary, p. 3, September 2006. Las Vegas Paving | Notice of Intent 5-3 Wet Scrubber Wet gas scrubbers can achieve 50-95% control of PM emissions15. However, they face the same difficulties in mobile mining facilities 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. Material Handling PM10 and PM2.5 Step 3 – Rank Remaining Control Technologies by Control Effectiveness Table 5-1. Summary of PM10 and PM2.5 for Material Handling. Control Technologies Rank Percent Control Feasibl e 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 U.S. Environmental Protection Agency (EPA) in 200816. 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 rules. EPA’s review of permits and other available information 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. Material Handling PM10 and PM2.5 Step 4 – Evaluate Most Effective Controls and Document Results The BDT control systems identified in EPA’s NSPS evaluations achieve a reduction in PM10 and PM2.5, along with reduction in larger PM particles required to meet NSPS, Subpart OOO emission standards. Additionally, as the LVP Grantsville Operation is located in a PM2.5 Nonattainment Area, it is subject to R307-312 Aggregate Processing Operations. Furthermore, because the selected technologies provide the highest control efficiencies feasible, a cost analysis is not necessary. Therefore, the selected controls are the most effective for the proposed crushing and screening plant. Material Handling PM10 and PM2.5 Step 5 – Select BACT LVP proposes that BACT consists of restricting fugitive emissions to opacity standards set forth by NSPS Subpart OOO, Standards of Performance for NMPP, namely 7% opacity for belt conveyors, transfer points, 15 From EPA Air Pollution Control Technology Fact Sheet for Packed-Bed/Packed-Tower Wet Scrubber (EPA-452/F-03-015) 16 U.S. EPA revised NSPS, Subpart OOO in 73 Federal Register (FR) 78, April 22, 2008. Las Vegas Paving | Notice of Intent 5-4 screens, storage bins, and enclosed trucks; and 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; ► Application of water sprays to crushing operations; and ► Moisture content carryover during transportation on conveyors. Furthermore, management and best operational practices will be applied. These include, but are not limited to: ► Minimizing drop distance for material transfers; and ► Periodic inspections of material handling. 5.2 LVP Road Emissions Fugitive PM10 and PM2.5 Emissions There is one (1) unpaved, primary entrance road for offsite shipments which travels from the exterior of the property to the scale and loading areas. Two (2) unpaved tram routes for front-end loader movement are also accounted for. Fugitive emissions are generated from road use by customer trucks, support vehicles, and heavy equipment used in mining operations. Fugitive dust from production activities such as loading, unloading, storage of bulk materials, and material transporting may cause PM to be deposited on plant roads. Vehicular traffic in these areas may then disturb dust deposited on plant roads, resulting in more PM emissions. Roads PM10 and PM2.5 Step 1 - Identify All Control Technologies Control technologies identified for PM10 and PM2.5 emissions from roads are as follows, based on May 6, 2020 review of relevant entries in EPA’s RBLC: ► Chemical Treatment (Applicable to Unpaved Roads Only) ► Reduced Speed (Applicable to Unpaved Roads Only) ► Road Paving (Applicable to Unpaved Roads Only) ► Silt Content Reduction (Applicable to Unpaved Roads Only) ► Street Sweeping (Applicable to Paved Roads Only) ► Watering and Material Moisture Content Roads PM10 and PM2.5 Step 2 – Eliminate Technically Infeasible Options Chemical Treatment Applying chemical treatment to unpaved roads binds surface particles together and inhibits fugitive emissions by up to 85%17. This is feasible for haul roads, but not for paths on which bulldozers and/or front-end loaders operate. Chemical treatment applied in such areas may contaminate mined aggregate and cause technical problems during the crushing and screening process. Furthermore, product stockpiles may 17 UDAQ Guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015 Las Vegas Paving | Notice of Intent 5-5 become contaminated and the effects of chemical treatment are reduced due to the frequent turning of front-end loaders while loading customer haul trucks. Reduced Speed Reducing the speed on plant roads reduces the generation of fugitive dust. The Western Regional Air Partnership (WRAP) Fugitive Dust Handbook reports that a 57% reduction in emissions occurs when speeds are restricted to less than fifteen miles per hour (15 mph), and a 44% reduction in emissions when speeds are restricted to 25 mph18. This control method is considered technically feasible. Road Paving Paving provides effective controls on fugitive road emissions. Guidelines from UDAQ indicate that paved roadways, combined with sweeping and watering, provide a 90% control efficiency for particulate emissions19. Paving roads is not technically feasible near dynamic mining operations at the LVP Grantsville Operation, as route configurations are subject to change according to mine development. Furthermore, emissions from paved roads in disrepair due to impact from heavy equipment are higher than properly treated unpaved roads. Similarly, the benefits from applying chemical dust suppressants are negated in areas where trucks turn and tracked equipment is used because those activities cause chemical dust suppressants to deteriorate more quickly than is useful. The main haul road, which is used for product export, will remain unpaved throughout the life of the mine. This is due to the frequent travel of high volume, heavy-weight equipment on the road. Travel of this sort rapidly deteriorates paved road surfaces, which is an accepted, significant concern for paved roads. If the main haul road were paved, the frequent re-paving and road construction that would be necessary due to its regular deterioration would hinder haul truck travel and subsequently obstruct the selling of processed aggregate. The application of chemical suppressant and regular watering that will be done on the main haul road will achieve nearly the same control as if the roads were paved.20 As such, paving of the main haul road is considered technically infeasible. Silt Content Reduction Silt content reduction involves covering unpaved road surfaces with material that has a lower silt content than what is naturally present, e.g., gravel or slag. Combined with watering, this method achieves up to 75% control efficiency21. This is considered technically feasible and will be applied where appropriate. Street Sweeping Street sweeping is a method of PM control that utilizes a mobile street sweeping unit to remove loose material from paved road surfaces. This control technology is technically infeasible due to the stated inability to adequately maintain paved roads at the LVP Grantsville Operation. Watering and Material Moisture Content Watering of haul roads reduces fugitive PM2.5 and PM10 emissions by binding soil particles together, preventing their being picked up by wind or vehicles. Water is applied on a scheduled basis and supplemented as needed based on driver observation of dust conditions. Basic watering results in a dust 18 Western Regional Air Partnership, Fugitive Dust Handbook. Executive Summary, p. 3, September 2006. 19 UDAQ Guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015 20 Western Regional Air Partnership (WRAP) Fugitive Dust Handbook, 2006. 21 UDAQ Guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015 Las Vegas Paving | Notice of Intent 5-6 control efficiency of up to 70%22. This control technology is considered technically feasible and will be used at the LVP Grantsville Operation. Roads PM10 and PM2.5 Step 3 – Rank Remaining Control Technologies by Control Effectiveness Table 5-2. Fugitive PM10 and PM2.5 Control Technologies and Efficiencies for Roads. Control Method Control Efficiency (%) Chemical Suppressant and Watering 85 Basic Watering and Road Base 75 Basic Watering 70 Reduced Speed 44 For the technologies applied to unpaved roads, any grouping of silt-content reduction, watering, and speed reduction can be applied together, as they are not competitive. Note that variable control technologies include: ► Silt Content Reduction: Varies with current, uncontrolled road conditions, per AP-42 13.2.2. Roads PM10 and PM2.5 Step 4 – Evaluate Most Effective Controls and Document Results Since the highest available controls include implementing chemical suppression, road watering, speed reduction, and silt content reduction on unpaved roads, no detailed economic, energetic, or environmental impact evaluations were conducted. Roads PM10 and PM2.5 Step 5 – Select BACT Fugitive road emissions are generated from road use by customer trucks, employee vehicles, and front-end loaders. The haul roads at the LVP Grantsville Operation are unpaved. BACT for these permanent haul roads is considered to consist of chemical application, watering, and silt-content reduction to minimize fugitives as practical. BACT for non-permanent roads – e.g., roads in proximity to the mining face – is considered to consist of watering and silt content reduction to minimize fugitive dust. The LVP Grantsville Operation will implement these controls. 5.3 LVP Drilling and Blasting NOX and SO2 – Blasting Blasting operations incorporate combustion of compounds containing ammonium nitrate in order to pulverize material in the mining area. Blasting operations will produce fugitive NOX and SO2 emissions. However, there are no control technologies that can be used to mitigate NOX and SO2 emissions associated with blasting. As such, no BACT analysis has been conducted for these emissions. PM10 and PM2.5 – Drilling and Blasting Drilling and blasting methods loosen raw materials in the mining area in order to access the desired aggregate embedded in the ground. These activities create fugitive dust. 22 Ibid. Las Vegas Paving | Notice of Intent 5-7 Drilling and Blasting PM10 and PM2.5 Step 1 – Identify All Control Technologies Control technologies identified for PM10 and PM2.5 emissions from drilling and blasting have been identified using the following sources: ► Utah Division of Air Quality Fugitive Dust Control Plans (Revised 1/13) BMP 02; ► Dust Control Handbook for Industrial Minerals Mining and Processing, NIOSH, January 2012 ► WRAP Fugitive Dust Handbook, Countess Environmental, September 2006 The following methods have been identified as control technologies to reduce fugitive dust emissions from drilling and blasting: ► Apply a shroud to the drilling equipment; ► Apply best management and operational practices for drilling and blasting; ► Install a dust collection system on drilling equipment; and ► Install a water spray on drilling equipment, i.e., use of wet drilling practices. Drilling and Blasting PM10 and PM2.5 Step 2 – Eliminate Technically Infeasible Options Shroud Application to Drilling Equipment Installing a shroud at the drilling location is one common method for controlling fugitive dust emissions from drilling operations. Shrouds can vary in shape (rectangular vs. circular) and complexity in order to adapt to mining operations. When installed and replaced correctly, shrouds can control 88% of fugitive dust emissions.23 Using a shroud during drilling operations is technically feasible. Best Management and Operational Practices for Drilling and Blasting Best management and operational practices for blasting operations includes the following: using sufficient stem length and refraining from blasting operations during high winds.24 Best management and operational practices for drilling operations includes conducting routine inspections of drilling control technologies. This may include repairing and/or replacing shrouds when they become damaged. Best management and operational practices for controlling both drilling and blasting operations are technically feasible. Dust Collection System on Drilling Equipment Dust control is often accomplished using a fan-powered dust-collection system. For drilling operations, these collection systems are mounted on the drill. If properly maintained, these systems can be up to 99% efficient.25 For drilling operations, installing a dust collection system is technically feasible. Water Spray on Drilling Equipment Fugitive emissions for drilling equipment can be significantly reduced through wet drilling, using a water spray which provides continuous water flow during drilling operations. With a high volumetric flow rate, dust control efficiencies often attain 86-97%. However, when water flow rates approach one (1) gallon per minute (gpm) operational problems such as drill bit plugging, and drill rotation binding often occur. Dust 23 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 137. NIOSH, March, 2019 24 The Office of Surface Mining, U.S. Department of Interior, Controlling the Adverse Effects of Blasting, Methods to Reduce Airblast 25 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 124. NIOSH, March, 2019 Las Vegas Paving | Notice of Intent 5-8 control efficiencies are reduced when water flow rates are reduced.26 Watering is technically feasible for drilling operations. Drilling and Blasting PM10 and PM2.5 Step 3 – Rank Remaining Control Technologies by Control Effectiveness The most-effective control technologies for fugitive dust generated from drilling operations are provided in the table below, according to effectiveness. Table 5-3. Summary of PM2.5 and PM10 Control Methods for Drilling Control Technologies Rank Percent Control Feasible BACT Dust Collection System27 1 95-99.9% Yes Yes Using Water Spray (Wet Drilling)28 2 86-97% Yes Yes Shroud Use29 3 63-88% Yes Yes Best Management and Operational Practices 4 Varies Yes Yes The most-effective control technologies for fugitive dust generated from blasting operations are provided in the table below, according to effectiveness. Table 5-4. Summary of PM2.5 and PM10 Control Techniques for Drilling and Blasting Control Technologies Rank Percent Control Feasible BACT Best Management and Operational Practices 5 Varies Yes Yes Drilling and Blasting PM10 and PM2.5 Step 4 – Evaluate Most-Effective Controls and Document Results For drilling operations, dust collection systems such as baghouses provide the highest degree of PM control, from 95 to 99.9%.30 Wet drilling through a water spray can provide up to 97% control efficiency. Implementing a shroud can control 88% of PM emissions. For blasting operations, good management practices provide the highest reduction in PM emissions. These practices include preventing blasting operations during high wind events. 26 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 80-82. NIOSH, January, 2012 27 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 124. NIOSH, March, 2019 28 Summary of NIOSH Research Completed on Dust Control Methods for Surface and Underground Drilling, Pg. 2, December 2008 29 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 137. NIOSH, March, 2019 30 From EPA Air Pollution Control Technology Fact Sheet for baghouses: https://www3.epa.gov/ttnchie1/mkb/documents/ff-pulse.pdf (EPA-452/F-03-025). Las Vegas Paving | Notice of Intent 5-9 Drilling and Blasting PM10 and PM2.5 Step 5 – Select BACT BACT for drilling will be accomplished through adhering to best management practices, and using a dust collection system or wet drilling practices proposed as BACT for drilling operations. BACT for blasting will be accomplished by applying best management practices, minimizing the blasting area, and limiting the size of blasting operations closer than 300 feet from the property boundary, and avoiding blasting operations during high winds. Additionally, blasting and drilling are events will not occur on the same day. These practices will mitigate fugitive dust from blasting operations. 5.4 LVP Disturbed Grounds Fugitive PM10 and PM2.5 emissions are generated through wind disturbance on exposed aggregate. Various operational practices can be considered for BACT. One option is to spray water on all areas not covered with vegetation or synthetic material. The large volume of exposed area at the LVP Grantsville Operation would require extensive amounts of water. Due to the constant movement of aggregate equipment and working areas, the infrastructure required for the sprays is not technically feasible. Therefore, this option is not considered BACT. Additionally, the aggregate being mined at the Grantsville pit is hard-rock and not weathered material. As a result, the amount of fines on the mine surface will be minimal. Best management practices and maintaining established opacity limitations are considered BACT to control fugitive dust from disturbed grounds on site. Las Vegas Paving | Notice of Intent 6-1 EMISSION IMPACT ANALYSIS 6.1 LVP Comparison to Modeling Thresholds Table 6-1 compares criteria pollutant total proposed emissions to applicable modeling thresholds contained in R307-403-4 through 7, and R307-410-4. Table 6-1. LVP Equipment and Operations Emissions and Comparison to Major Source and Modeling Thresholds. Description Potential to Emit (tpy)1,2 PM10 PM2.5 NOX CO SO2 VOC CO2e Crushing and Screening Operations 1.68 0.24 0.00 0.00 0.00 0.00 0.00 Stockpiles and Disturbed Grounds 3.77 1.59 0.00 0.00 0.00 0.00 0.00 Bulldozers and Drops 1.56 0.30 0.00 0.00 0.00 0.00 0.00 Drilling and Blasting 0.74 0.04 8.50 33.50 0.06 0.00 - Roads 13.91 1.39 0.00 0.00 0.00 0.00 0.00 Proposed Site-Wide Emissions 21.67 3.57 8.50 33.50 0.06 0.00 0.00 Modeling Limits3 5/15 None 40 100 40 None None Threshold Exceeded? Yes No No No No No No Major Source Thresholds4 100 70 70 100 70 70 100,000 Threshold Exceeded? No No No No No No No 1. The LVP Grantsville Operation is located in Tooele County, which is in serious nonattainment for PM2.5. Values are per UAC R307-403-5(2)(b)(ii). 2. Ammonia and HAPs were considered in the LVP Grantsville Operation’s facility-wide emissions; however, these emissions are not applicable, as site power is provided by line power. 3. Per Emissions Impact Assessment Guidelines published by UDAQ. 4. Values are per UAC R307-403-5(2)(b)(ii) The air dispersion modeling analysis will be performed to demonstrate that the impacts of the site-wide PM10 emissions from the LVP Grantsville Operation will not exceed the NAAQS. As a supplement to this application, LVP will submit a modeling protocol and an air dispersion modeling analysis for PM10 24-hour NAAQS. If this operating scenario would change in the future, LVP, on behalf of LNA and LVP, will notify the UDAQ 30 days prior to the change, or submit a revised NOI air permit application. Because the total emission increases at the LVP Grantsville Operation do not constitute a major source, a visibility analysis is not required.31 31 R307-406-2 Las Vegas Paving | Notice of Intent 7-1 NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING Per UDAQ’s Form 1 for NOI and R307-420 and R307-421, this section should include offset requirements for nonattainment and maintenance areas. The LVP Grantsville Operation is located within a PM2.5 nonattainment area. 7.1 LVP 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 R307-403-5(2)(b) as “any stationary 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, VOCs, and ammonia].” The LVP Grantsville Operation 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. The LVP Grantsville Operation is located in Tooele County, and does not impact either Salt Lake County or Utah County. The LVP Grantsville Operation 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 the LVP Grantsville Operation is located in Tooele County, ozone offsets are not applicable. Furthermore, "significant" means, for the purposes of determining what is a significant emission increase or a significant net emission increase and therefore a major modification, a rate of emissions that would equal or exceed any of the following rates: (1) for volatile organic compounds, 25 tons per year, (2) for nitrogen oxides, 40 tons per year. The PTE of the LVP Grantsville Operation presented in Appendix B is less than 25 tpy of VOCs, solidifying the inapplicability of ozone offsets established in R307-420-3. Las Vegas Paving | Notice of Intent 8-1 APPLICABLE REGULATIONS 8.1 General Introduction – LVP Utah Regulations LVP has evaluated the applicability of each rule under the Utah Administrative Code (UAC) Title R307. Rules generally applicable to the LVP Grantsville Operation; specifically, but not associated with one specific proposed change will not be discussed in this section, while all other applicable rules associated with the project described in this NOI 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 1 Conflict of Interest X R307-105 1 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 1 General Requirements: Tax Exemption for Air Pollution Control Equipment X R307-121 2 General Requirements: Clean Air and Efficient Vehicle Tax Credit X R307-122 2 General Requirements: Heavy Duty Vehicle Tax Credit X R307-123 2 General Requirements: Clean Fuels and Vehicle Technology Grant and Loan Program X R307-124 2 General Requirements: Conversion to Alternative Fuel Grant Program X R307-125 2 Clean Air Retrofit, Replacement, and Off-Road Technology Program X R307-130 1 General Penalty Policy X R307-135 Enforcement Policy for Asbestos Hazard Emergency Response Act X R307-150 Emission Inventories X R307-165 Emission Testing X R307-170 Continuous Emission Monitoring Program X R307-201 Emission Standards: General Emission Standards X Las Vegas Paving | Notice of Intent 8-2 Reference Regulation Name Applicability Yes No R307-202 Emission Standards: General Burning X R307-203 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 1 Standards of Performance for New Stationary Sources X R307-214 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 Las Vegas Paving | 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 Las Vegas Paving | 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 1 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 2 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 the LVP Grantsville Operation; however, this rule is not specific to operational compliance requirements, and is therefore not discussed in the enclosed NOI. 2. At the time of submission of this NOI, this rule does not apply. 3. Applicable NSPS and NESHAP regulations are detailed under appropriate project headings UAC R307-101 General Requirements: The LVP Grantsville Operation will comply and conform to the definitions, terms, abbreviations, and references used in the UAC R307-101 and 40 CFR. Las Vegas Paving | Notice of Intent 8-5 UAC R307-107 General Requirements: Breakdowns The LVP Grantsville Operation 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. UAC R307-150 Emission Inventories: For every third year, the LVP Grantsville Operation 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. UAC R307-201 Emission Standards: General Emission Standards: All rules applicable to the LVP Grantsville Operation are incorporated by reference from 40 CFR Part 60. Applicability and requirements for these rules are outlined in Section I.2 of this submittal. UAC R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust: UAC R307-205-4 Emission Standards – Fugitive Emissions The LVP Grantsville Operation is located in Tooele County, which is a nonattainment area for PM2.5. 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. The LVP Grantsville Operation 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 The LVP Grantsville Operation 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 Las Vegas Paving | Notice of Intent 8-6 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. The LVP Grantsville Operation will comply with minimization techniques described in R307-205-7. The LVP Grantsville Operation will also engage in various techniques aimed to reduce fugitive dust from mining activities. Techniques include, but are not limited to: water controls, maintaining both paved and unpaved roads, restricting the speed of vehicles in and around mining operations, and control of dust from storage piles. UAC R307-307 Road Salting and Sanding UAC R307-307-1 Road Salting and Sanding – Applicability All persons who apply salt or abrasives such as crushed slag and sand to roads in PM10 and PM2.5 nonattainment and maintenance areas as defined in 40 CFR 81.345 (July 1, 2011) and geographically described as all regions of Davis, Salt Lake, and Utah counties. UAC R307-307-2 Road Salting and Sanding – Records (1) Any person who applies salt or abrasives such as crushed slag and sand to roads in PM10 and PM2.5 nonattainment and maintenance areas shall maintain records of the material applied. (a) For salt, the records shall include the quantity applied, the percent by weight of insoluble solids in the salt, and the percentage of the material that is sodium chloride (NaCl), magnesium chloride (MgCl2), calcium chloride (CaCl2), or potassium chloride (KCl). (b) For abrasives such as sand or crushed slag, the records shall include the quantity applied and the percent by weight of fine material which passes the number 200 sieve in a standard gradation analysis. (2) All records shall be maintained for a period of at least two years, and the records shall be made available to the director or his designated representative upon request. UAC R307-307-3 Road Salting and Sanding – Content (1) After October 1, 1993, any salt applied to roads in Salt Lake, Davis, or Utah counties shall be at least 92% NaCl, MgCl2, CaCl2, and/or KCl. (2) After January 1, 2014, any salt applied to roads in all other areas specified in R307-307-1 shall be no less than 92% by weight NaCl, MgCl2, CaCl2, and/or KCl. The LVP Grantsville Operation is located in a PM2.5 nonattainment area. As a result, LVP will ensure that any salt or crushed slag will be no less than 92% by weight NaCl, MgCl2, CaCl2, and/or KCl on its roads. 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 Las Vegas Paving | Notice of Intent 8-7 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. The LVP Grantsville Operation will minimize fugitive dust created from the construction and maintenance of the existing paved road to the extent both practical and possible. 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% The LVP Grantsville Operation will comply with visible emissions for aggregate processing operations described in R307-312. 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, 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 proposed installation 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) R307-420, Permits: Ozone Offset Requirements in Davis and Salt Lake Counties; (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. Las Vegas Paving | Notice of Intent 8-8 (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. The LVP Grantsville Operation 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. UAC R307-410 Permits: Emission Impact Analysis: Emission impacts associated with the LVP Grantsville Operation are addressed in Section 9 of this submittal. UAC R307-414 Permits: Fees for Approval Orders: Fees associated with the submission of this NOI are addressed in Section 2 of this submittal. 8.2 LVP Federal Regulations 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 ► General recordkeeping requirements ► Semiannual monitoring system and/or excess emission reports NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants NSPS Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants, 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: ► Crusher ► Screening Operation ► Belt Conveyor ► 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 Las Vegas Paving | Notice of Intent 8-9 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. LVP 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 NESHAP Subpart A (General Provisions) All affected sources are subject to the general provisions of Part 63 NESHAP Subpart A unless specifically excluded by the source-specific NESHAP. These provisions include initial notification and performance testing, recordkeeping, and monitoring requirements for all other subparts as applicable. Las Vegas Paving | Notice of Intent A FORMS Form 1 Date December 2020 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] $NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements %Alternative site analysis, Major source ownership compliance certification Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406] %Visibility impact analysis, Class I area impact 6LJQDWXUHRQ$SSOLFDWLRQ 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. Las Vegas Paving ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ 1of 1 Form 2 Company Information/Notice of Intent (NOI) Utah Division of Air Quality New Source Review Section Application for: Ƒ Initial Approval Order Ƒ Approval Order Modification General Owner and Source Information 1.Company name and mailing address: ____________________________ ____________________________ ____________________________Phone No.:Fax No.: 2. Company** contact for environmental matters: ____________________________ Phone no.: Email:_______________________BBBBBBBBBBBBBBBBBBBBB ** Company contact only; consultant or independent contractor contact information can be provided in a cover letter 3. Source name and physical address (if different fromabove):__________________BBBB _____________________B ______________________Phone no.: Fax no.: 4. Source Property Universal Transverse Mercatorcoordinates (UTM), including System and Datum: UTM:BBBBBBBBBBBBBBBBBBBBBBBBB X:_____B_________BBBBBBBBBBBB Y:_________BBBBBBBBBBBBBBBBBB 5. The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)__ __ __ __ 7. If request for modification, AO# to be modified: DAQE #__________________BBBBBBBBBBDATED: ____/____/____ 8. Brief (50 words or less) description of process. Electronic NOI9. A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black (jlblack@utah.gov) or AlanHumpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal Electronic Copy Submittal Ƒ %RWK Authorization/Signature I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on reasonable inquiry made by me and to the best of my knowledge and belief. Signature: Title: _______________________________________Name (Type or print) Telephone Number: Email: Date: Date: December 2020 ✔ Las Vegas Paving Dan Fitzgerald 4420 S Decatur Blvd (702)353-4607 dan.fitzgerald@lasvegaspaving.comLas Vegas, NV 89103 (702)353-4607 Grantsville Pit Zone 12T8700 N Ellerbeck Rd. 366,928.5Grantsville, UT 84029 4,506,861.1 Tooele 1 4 42 NA Crushing and screening operations to process aggregate mined at the site. ✔ Dan Peressini 12.08.2020 702.236.3520 DanP@RiverBasin. net Division Manager Page 1 of 1 Form 3 Company____________________ Process Information Site________________________ Utah Division of Air Quality New Source Review Section Process Information)RU1HZ3HUPLW21/< 1. Name of process:2. End product of this process: 3. Process Description*: Operating Data 4. Maximum operating schedule: __________hrs/day __________days/week __________weeks/year 5. Percent annual production by quarter: Winter ________ Spring _______ Summer ________ Fall _______ 6. Maximum Hourly production (indicate units.): _____TBD_______ 7. 8. Type of operation: Continuous Batch Intermittent 9. If batch, indicate minutes per cycle ________ Minutes between cycles ________ 10. Materials and quantities used in process.* Material Maximum Annual Quantity (indicate units) 11.Process-Emitting Units with pollution control equipment* Emitting Unit(s)Capacity(s)Manufacture Date(s) *If additional space is required, please create a spreadsheet or Word processing document and attach to form. Las Vegas Paving Grantsville Pit Crushing and Screening Processed Aggregate Crushing and screening operations to process aggregate mined at thesite. A wash plant washes a portion of the processed aggregate.Processed aggregate, washed and unwashed, is stacked and sold. 16 7 52 Maximum annual production (indicate units): ______TBD_________(tpy) ✔ Aggregate 1,500,000 (tpy) ANFO 1,000 (tpy) Crushing and Screening (Dry Circuit)400 (tph) Crushing and Screening (Wash Circuit)400 (tph) Page 1 of 1 Company___________________________ 6LWH_____________________________ Form Emissions Information Criteria/GHGs/ HAP’s 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 NOxSO2CO 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 4FF"UUBDIFEGPS &NJTTJPO*OGPSNBUJPO 4FF"UUBDIFEGPS &NJTTJPO*OGPSNBUJPO 4FF"UUBDIFEGPS &NJTTJPO*OGPSNBUJPO Las Vegas Paving Grantsville Pit Utah Division of Air Quality Date December 2020 New Source Review Section Company_____________________________Site ___ Form 15 Aggregate Processing Operations Equipment Information 1. Check the appropriate crushing operations used inyour process: Type of Unit: Crushing and Screening Manufacturer/ModelDesign Capacity: 400 tphDate Manufactured: TBDPrimary 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) Triple_________________________________ 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: 1.5 MM __ tons/yr BD ___ tons/hr TBDTBD__ hrs/yr ____ hrs/day 5. Water sprays used on storage piles? _ Yes _ No 6a. Number of conveyor belt transfer and drop points: 28 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 outthis 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, additionalinformation may be requested for the engineering review. Instructions1. 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 Las Vegas Paving Grantsville Pit ✔ ✔✔ ✔✔ ✔✔ ✔✔ Aggregate is wetted prior to its introduction to the crushing and screening process. It is further wetted at strategic locations in the process. Moisture carryover mitigates dust. T ✔ Storage pile size:_________________ Sprayed as necessary to maintain opacity limits. Las Vegas Paving | Notice of Intent B EMISSION CALCULATIONS Description Value Unit Potential Daily Operating Hours 16 (hr/day) Desired Annual Operating Days 365 (day/yr) Proposed Annual Unprocessed Throughput 150,000 (tpy) Proposed Annual Processed Throughput 1,350,000 (tpy) Total Proposed Annual Throughput 1,500,000 (tpy) Throughput Percent Maximum Hourly Limit Potential Annual Throughput Potential Total Annual Throughput (%)(tph)(tpy/unit)(tpy) Primary HSI Crusher 1 Dry Circuit 40.00%400 600,000 600,000 Secondary Cone Crusher 1 Dry Circuit 35.00%250 525,000 525,000 Tertiary VSI Crusher 1 Dry Circuit 18.75%170 281,250 281,250 Feeder 1 Dry Circuit 90.00%800 1,350,000 1,350,000 Bin Feeders 3 Wash Circuit 45.00%400 225,000 675,000 Primary Screening 1 Dry Circuit 90.00%800 1,350,000 1,350,000 Secondary Screening 1 Dry Circuit 35.00%250 525,000 525,000 Tertiary Screening 1 Dry Circuit 18.75%170 281,250 281,250 Wash Screen 1 Wash Circuit 45.00%400 675,000 675,000 Conveyors (800)3 Dry Circuit 90.00%800 1,350,000 4,050,000 Conveyors (400, 50%)2 Dry Circuit 50.00%400 750,000 1,500,000 Conveyor (400, 45%)1 Wash Circuit 45.00%400 675,000 675,000 Conveyors (250)2 Dry Circuit 35.00%250 525,000 1,050,000 Conveyors (200)2 Dry Circuit 25.00%200 375,000 750,000 Conveyors (170)2 Dry Circuit 18.75%170 281,250 562,500 Conveyor (160)1 Dry Circuit 17.50%160 262,500 262,500 Conveyor (150)1 Wash Circuit 22.50%150 337,500 337,500 Conveyors (140)2 Wash Circuit 20.25%140 303,750 607,500 Conveyor (120)1 Dry Circuit 15.00%120 225,000 225,000 Conveyors (80, 10%)2 Dry Circuit 10.00%80 150,000 300,000 Conveyors (80, 9.375%)2 Dry Circuit 9.375%80 140,625 281,250 Conveyor (60)1 Wash Circuit 11.25%60 168,750 168,750 Conveyor (40, 11.25%)1 Wash Circuit 11.25%40 168,750 168,750 Conveyor (40, 8.75%)1 Dry Circuit 8.75%40 131,250 131,250 Conveyor (40, 4.6875%)1 Dry Circuit 4.69%40 70,313 70,313 Future Conveyors 3 Mine 90.00%800 1,350,000 4,050,000 Stacker A 1 Dry Circuit 50.00%400 750,000 750,000 Stacker C 1 Dry Circuit 17.50%160 262,500 262,500 Stacker D 1 Dry Circuit 4.69%40 70,313 70,313 Stacker E 1 Dry Circuit 9.38%80 140,625 140,625 Stacker F 1 Wash Circuit 20.25%140 303,750 303,750 Stacker G 1 Wash Circuit 11.25%60 168,750 168,750 Stacker H 1 Wash Circuit 22.50%150 337,500 337,500 Stacker I 1 Wash Circuit 11.25%40 168,750 168,750 Sand Screw 1 Wash Circuit 22.50%150 337,500 337,500 Dewater Screen 1 Wash Circuit 20.25%140 303,750 303,750 Clarifier 1 Wash Circuit 2.25%10 33,750 33,750 Loader to Feeder 1 Dry Circuit 90.00%800 1,350,000 1,350,000 Loader to Wash Bins 1 Wash Circuit 45.00%400 675,000 675,000 Loader to Haul Trucks (Final Product)1 Stockpile 90.00%800 1,350,000 1,350,000 Loader to Haul Trucks (Muckpile)1 Mine 10.00%800 150,000 150,000 Location1 1. It is assumed that all Wash Circuit equipment (excepting Bin Feeders) will have no fugitive dust emissions due to their water-saturated environment. Table C-2. Equipment List Table C-1. Operating Parameters Type of Equipment / Activities Number of Units or Drop Points Las Vegas Paving Grantsville Operations Page 1 of 11 Trinity Consultants December 2020 Table C-3. Stockpiles and Disturbed Grounds Type of Equipment / Activities1 Quantity Maximum Area (Acres) Stockpile A 1 0.1 Stockpile B 1 0.1 Stockpile C 1 0.1 Stockpile D 1 0.1 Stockpile E 1 0.1 Stockpile F 1 0.1 Stockpile G 1 0.1 Stockpile H 1 0.1 Stockpile I 1 0.1 Stockpile J 1 3.3 Stockpile K 1 3.3 Disturbed Area 1 5.0 Total -- 12.50 Maximum Annual Operating Hours (hr/yr/unit) Front-End Loaders 2 4,000 Bulldozers 1 1,000 Parameter1 Quantity Unit Main Haul Route 1.01 (miles) Paved Main Haul Route 0.00 (miles) Main Haul Route 1.01 (miles) Total Mine Haul Route 0.34 (miles) Paved Mine Haul Route 0.00 (miles) Muckpile Haul Route 0.34 (miles) Loadout Tram Length 0.11 (miles) Muckpile/Quarry Tram Length 0.02 (miles) Empty Single-Trailer Trucks 17.00 (tons) Loaded Single-Trailer Trucks 40.00 (tons) Empty Double-Aluminum Trucks 22.50 (tons) Loaded Double-Aluminum Trucks 64.50 (tons) Empty Double-Trailer Trucks 27.00 (tons) Loaded Double-Trailer Trucks 64.50 (tons) Empty Loadout Loader Weight 33.00 (tons) Loaded Loadout Loader Weight 44.00 (tons) Empty Quarry Feed Loader Weight 56.00 (tons) Loaded Quarry Feed Loader Weight 67.50 (tons) Table C-6. Drilling and Blasting Parameter Blasting Units Drilling Units Daily Maximum Frequency 1 (blast/day) 42 (holes/day) Annual Maximum Frequency 50 (blasts/yr) 2,000 (holes/yr) Annual Maximum Area 375,000 (ft2/yr)-- -- Daily Maximum Area 25,000 (ft2/day)-- -- ANFO Usage 40,000 (lbs/blast) -- -- Maximum Annual ANFO Usage 1,000 (tpy) -- -- ANFO Heat Content 912 (cal/g) -- -- Location Specification Value Unit Dozers1 Moisture 2.00 % Dozers2 Silt 2.00 % Loaders1 Moisture 2.00 % Loaders2 Silt 4.00 % Roads2 Silt 6.00 % 2. Provided by Las Vegas Paving on 08/25/2020. Table C-4. Supporting Equipment 1. The mine will have a maximum of five (5) acres of disturbed area during any one (1) year. Disturbed area will be stabilized (backfilled and reclaimed) as the mining area is moved each year. 1. Moisture content for dozers was previously recommended by UDAQ. Table C-5. Roads Table C-7. Silt and Moisture Values 1. All haul and tram route distances are given as roundtrip distances. Type of Equipment Quantity Las Vegas Paving Grantsville Operations Page 2 of 11 Trinity Consultants December 2020 PM10 PM2.5 NOX CO SO2 VOC CO2e Proposed Site-Wide Emissions 21.67 3.57 8.50 33.50 0.06 0.00 0.00 Major Source Thresholds1,2 70 70 70 100 70 70 NA Threshold Exceeded?No No No No No No No Modeling Limits3 15 No Limit 40 100 40 No Limit No Limit Threshold Exceeded?Yes No No No No No No 3. Per Emissions Impact Assessment Guidelines published by UDAQ. Table C-8. Facility-Wide Emissions Emissions (tpy) 1. The Grantsville site is located in Tooele County, which is in serious nonattainment for PM2.5. Values are per UAC R307- 403-5(2)(b)(ii). 2. Ammonia and HAPs emissions were considered in the Grantsville Site’s facility-wide emissions; however, these emissions are not applicable, as site power is provided by line power. Las Vegas Paving Grantsville Operations Page 3 of 11 Trinity Consultants December 2020 Process PM10 (tpy) PM2.5 (tpy) NOX (tpy) CO (tpy) SO2 (tpy) VOC (tpy) CO2e (tpy) Crushing and Screening Operations 1.68 0.24 0.00 0.00 0.00 0.00 0.00 Stock Piles and Disturbed Grounds 3.77 1.59 0.00 0.00 0.00 0.00 0.00 Bulldozers & Drops 1.56 0.30 0.00 0.00 0.00 0.00 0.00 Roads 13.91 1.39 0.00 0.00 0.00 0.00 0.00 Drilling and Blasting 0.74 0.04 8.50 33.50 0.06 0.00 -- Total Potential Emissions (tpy)21.67 3.57 8.50 33.50 0.06 0.00 0.00 Table C-9. Annual Potential Emissions Increase Summary Proposed Project Emissions Las Vegas Paving Grantsville Operations Page 4 of 11 Trinity Consultants December 2020 PM10 PM2.5 Primary Crushing Controlled 6.00E-04 9.09E-05 Secondary Crushing Controlled 2.70E-04 4.09E-05 Tertiary Crushing Controlled 5.40E-04 1.00E-04 Screening Controlled 7.40E-04 5.00E-05 Drop Controlled 6.08E-04 9.21E-05 Conveyor Transfer Controlled 4.60E-05 1.30E-05 Particle size multiplier (dimensionless)PM PM10 PM2.5 where:0.74 0.35 0.053 1. Emission factors per EPA Potential to Emit Calculator for Stone Quarrying, Crushing, and Screening Plants last updated November 2013 and AP-42 11.19.2. 2. Where PM2.5 emission factors (EF) are not provided, a ratio of aerodynamic particle size multipliers from AP-42 Ch. 13.2.4 was used to estimate PM2.5 emission factors. PM2.5 EF = (PM10 EF/0.35)*0.053. Source1,2 Emission Factor (lb/ton) Table C-10. Emission Factors for Crushing, Screening, & Material Handling Las Vegas Paving Grantsville Operations Page 5 of 11 Trinity Consultants December 2020 Throughput Percent Potential Annual Throughput (%) (tpy)PM10 PM2.5 PM10 PM2.5 PM10 PM2.5 Primary Crushing Primary HSI Crusher 1 40%600,000 Moisture Carryover 6.00E-04 9.09E-05 0.99 0.15 0.18 2.73E-02 Secondary Crushing Secondary Cone Crusher 1 35%525,000 Wet Suppression 2.70E-04 4.09E-05 0.39 0.06 0.07 1.07E-02 Tertiary Crushing Tertiary VSI Crusher 1 19%281,250 Wet Suppression 5.40E-04 1.00E-04 0.42 0.08 0.08 1.41E-02 Conveyor Transfer Feeder 1 90%1,350,000 Moisture Carryover 4.60E-05 1.30E-05 0.17 0.05 0.03 8.78E-03 Drop Bin Feeders 3 45%225,000 Moisture Carryover 6.08E-04 9.21E-05 1.12 0.17 0.21 3.11E-02 Screening Primary Screening 1 90%1,350,000 Moisture Carryover 7.40E-04 5.00E-05 2.74 0.18 0.50 0.03 Screening Secondary Screening 1 35%525,000 Moisture Carryover 7.40E-04 5.00E-05 1.06 0.07 0.19 1.31E-02 Screening Tertiary Screening 1 19%281,250 Moisture Carryover 7.40E-04 5.00E-05 0.57 0.04 0.10 7.03E-03 Conveyor Transfer Conveyors (800)3 90%1,350,000 Moisture Carryover 4.60E-05 1.30E-05 0.51 0.14 0.09 2.63E-02 Conveyor Transfer Conveyors (400, 50%) 2 50%750,000 Moisture Carryover 4.60E-05 1.30E-05 0.19 0.05 0.03 9.75E-03 Conveyor Transfer Conveyor (400, 45%) 1 45%675,000 Moisture Carryover 4.60E-05 1.30E-05 0.09 2.40E-02 0.02 4.39E-03 Conveyor Transfer Conveyors (250)2 35%525,000 Moisture Carryover 4.60E-05 1.30E-05 0.13 0.04 0.02 6.83E-03 Conveyor Transfer Conveyors (200)2 25%375,000 Moisture Carryover 4.60E-05 1.30E-05 0.09 2.67E-02 0.02 4.88E-03 Conveyor Transfer Conveyors (170)2 19%281,250 Moisture Carryover 4.60E-05 1.30E-05 0.07 2.00E-02 1.29E-02 3.66E-03 Conveyor Transfer Conveyor (160)1 18%262,500 Moisture Carryover 4.60E-05 1.30E-05 0.03 9.35E-03 6.04E-03 1.71E-03 Conveyor Transfer Conveyor (150)1 23%337,500 Fully Saturated ------ Conveyor Transfer Conveyors (140)2 20%303,750 Fully Saturated ------ Conveyor Transfer Conveyor (120)1 15%225,000 Moisture Carryover 4.60E-05 1.30E-05 0.03 8.01E-03 5.18E-03 1.46E-03 Conveyor Transfer Conveyors (80, 10%)2 10%150,000 Moisture Carryover 4.60E-05 1.30E-05 0.04 1.07E-02 6.90E-03 1.95E-03 Conveyor Transfer Conveyors (80, 9.375%) 2 9%140,625 Moisture Carryover 4.60E-05 1.30E-05 0.04 1.00E-02 6.47E-03 1.83E-03 Conveyor Transfer Conveyor (60)1 11%168,750 Fully Saturated ------ Conveyor Transfer Conveyor (40, 11.25%) 1 11%168,750 Fully Saturated ------ Conveyor Transfer Conveyor (40, 8.75%) 1 9%131,250 Moisture Carryover 4.60E-05 1.30E-05 0.02 4.67E-03 3.02E-03 8.53E-04 Conveyor Transfer Conveyor (40, 4.6875%) 1 5%70,313 Moisture Carryover 4.60E-05 1.30E-05 8.86E-03 2.50E-03 1.62E-03 4.57E-04 Conveyor Transfer Sand Screw 1 23%337,500 Fully Saturated ------ Screening Dewater Screen 1 20%303,750 Fully Saturated ------ Conveyor Transfer Future Conveyors 3 90%1,350,000 Moisture Carryover 4.60E-05 1.30E-05 0.51 0.14 0.09 2.63E-02 9.21 1.29 1.68 0.24 2 "Fully Saturated" indicates that the equipment is part of the Wash Circuit. Due to the fully saturated nature of aggregate within the Wash Circuit, these emissions are assumed to be negligible. Table C-11. Annual Aggregate Processed Total Emissions: Daily PTE Emissions (lb/day) Annual PTE Emissions (tpy)1Controls 1,2Number of Units or Drop Points 1 Water application will be used to control PM emissions on strategic transfer points throughout the crushing and screening operations. Equipment / Activity Source Description Emission Factor (lb/ton) Las Vegas Paving Grantsville Operations Page 6 of 11 Trinity Consultants December 2020 PM10 PM2.5 PM10 PM2.5 PM10 PM2.5 Stockpile A 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile B 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile C 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile D 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile E 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile F 0.10 1.00 6.3 1.85 0.63 0.19 0.01 0.00 Stockpile G 0.10 1.00 6.3 1.85 0.63 0.19 0.01 0.00 Stockpile H 0.10 1.00 6.3 1.85 0.63 0.19 0.01 0.00 Stockpile I 0.10 1.00 6.3 1.85 0.63 0.19 0.01 0.00 Stockpile J 3.30 1.00 6.3 1.85 2.14 1.11 1.29 0.67 Stockpile K 3.30 1.00 6.3 1.85 2.14 1.11 1.29 0.67 Mine Disturbed Area 5.00 1.00 Reclamation 1.04 0.16 0.35 0.09 0.95 0.14 12.50 ------3.77 1.59 TSP emission factor:0.38 4 Where no PM10 or PM2.5 emission PM10 content: PM2.5 content: PM Type Moisture Carryover Water Saturation PM10 Control Efficiency 66% 90% PM2.5 Control Efficiency 40% 90% 7 PM10 and PM2.5 control efficiencies for moisture carryover are weighted according to UDAQ's guidelines from data received from AP-42 Appendix B.2, Table B.2-3. PM10 and PM 2.5 control efficiencies for water saturation are given per Western Regional Air Partnership's (WRAP's) 2006 Fugitive Dust Handbook value for watering of storage piles. Table C-12. Stockpiles - Potential Emissions Moisture Carryover Water Saturation 1 PM10 emission factors for stockpiles taken from AP-42, Fourth Edition Table 8.19.1-1, per UDAQ guidance. EF(PM2.5) [uncontrolled, inactive] = EF(PM2.5) [uncontrolled, active] * EF(PM10) [uncontrolled, inactive] / EF(PM10) [uncontrolled, active] 6 PM2.5 uncontrolled, inactive emission factor for stockpiles is based on the ratio of the uncontrolled, active PM10 and PM2.5 emission factors. 5 PM10 uncontrolled, inactive emission factors for stockpiles taken from AP-42 Fourth Edition, Table 8.19.1-1. 0.075 0.50 ton/acre-yr Where: 3 Per U.S. EPA AP-42, Section 11.9 (Western Surface Coal Mining), Table 11.9-4; August 1998, for Disturbed Area. 2 PM2.5 emission factors for stockpiles calculated using data from AP-42 Appendix B.2 Table B.2-2, per UDAQ guidance. Location Control Efficiency7 Annual Active Emissions (tpy)Quantity Control Uncontrolled Active Emission Factor (lb/day/acre)1,2,3 Controlled Active Emission Factor (lb/day/acre) Dry Circuit Wash Circuit Total Source Maximum Area (Acres) Overflow Moisture Carryover Las Vegas Paving Grantsville Operations Page 7 of 11 Trinity Consultants December 2020 PM10 PM2.5 Bulldozing Operations 0.12 0.08 Loading Operations 1.44 0.22 Total Loading and Dozing Emissions 1.56 0.30 (hr/yr)PM10 PM2.5 (%)PM10 PM2.5 PM10 PM2.5 Bulldozers 1,000 1 0.80 0.56 70% 0.66 0.46 0.12 0.08 0.66 0.46 0.12 0.08 where: s = 2.00 M = 2.00 PM10 PM2.5 Bulldozer 0.75 0.105 Per AP-42, Section 11.9 (October 1998), Table 11.9-1 Table C-15. Loader and Stacker Emissions (Supporting Operations) (tpy)PM10 PM2.5 (%)PM10 PM2.5 PM10 PM2.5 Loader to Haul Trucks (Muckpile)150,000 2.03E-03 3.07E-04 70% 0.25 0.04 0.05 0.01 Loader to Haul Trucks (Final Product)1,350,000 2.03E-03 3.07E-04 70% 2.25 0.34 0.41 0.06 Loader to Feeder 1,350,000 2.03E-03 3.07E-04 70% 2.25 0.34 0.41 0.06 Loader to Wash Bins 675,000 2.03E-03 3.07E-04 70% 1.12 0.17 0.21 0.03 Stacker A 750,000 2.03E-03 3.07E-04 70% 1.25 0.19 0.23 0.03 Stacker C 262,500 2.03E-03 3.07E-04 70% 0.44 0.07 0.08 0.01 Stacker D 70,313 2.03E-03 3.07E-04 70% 0.12 0.02 0.02 0.00 Stacker E 140,625 2.03E-03 3.07E-04 70% 0.23 0.04 0.04 0.01 7.91 1.20 1.44 0.22 E = Emission factor where: PM PM10 PM2.5 k =0.74 0.35 0.053 U = 7.89 M = 2.00 Material moisture content (%) previously recommended by UDAQ. 1. Uncontrolled emission factors using the "drop equation" contained in U.S. EPA AP-42, Section 13.2.4 (Aggregate Handling and Storage Piles), November 2006: Control Efficiency2 Daily Emissions (lb/day) Annual Emissions (tpy) Annual Emissions (tpy) Total Dozing Emissions: 1. Emissions for the bulldozer were characterized using AP-42, Section 11.9 (October 1998), Table 11.9-1 and Table 11.9-3 Mean wind speed (mph) is determined from historical data retrieved from Salt Lake International Airport, averaged over 2015-2020. Particle size multiplier (dimensionless) Percent (%) provided by Las Vegas Paving on 08/25/2020. 2. All daily feed will be watered during excavation and crushing and screening operations. The Dry Circuit will implement water sprays, resulting in a 70% control efficiency, per the average control value for wet suppression in the WRAP Fugitive Dust Handbook, 2006. The Wash Circuit will totally saturate its processed material; therefore, it is assumed that there will be no fugitive dust emissions from the stacking of Wash Circuit material. Table C-13. Dozing and Loading Emissions Source Annual Emissions (tpy)2 Vehicle Type Maximum Annual Operating Hours Quantity Emission Factor1 (lb/hr) Total Loading Emissions Table C-14. Dozing Emissions Material moisture content (%) previously recommended by UDAQ. Emission Activity Potential Total Annual Throughput Uncontrolled Emission Factor1 (lb/ton) Control Efficiency Daily Emissions (lb/day) Las Vegas Paving Grantsville Operations Page 8 of 11 Trinity Consultants December 2020 Table C-16. Roads Emissions - PTE Emissions PM10 PM2.5 PM10 PM2.5 Unpaved, Chemical Application (Trucks)47.23 4.72 8.33 0.83 Unpaved, Water Application (Trucks)0.00 0.00 0.00 0.00 Unpaved, Water Application (Loaders)30.58 3.06 5.58 0.56 Total 77.81 7.78 13.91 1.39 Table C-17. Roads Emissions - Traveling Parameters (Supporting Operations) Empty Single-Trailer Trucks Loaded Single- Trailer Trucks Empty Double- Aluminum Trucks Loaded Double- Aluminum Trucks Empty Double- Trailer Trucks Loaded Double- Trailer Trucks (tpy) (tons) (tons) (tons) (tons) (tons) (tons) (tons/haul) (tons/haul) (tons/haul) Main Haul Route 1,500,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 118 1.01 119 43,453 Muckpile Haul Route 150,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 12 0.34 4.10 1.23 Loader (Product Loadout) 1,350,000 33 44.0 NA NA NA NA 11.0 NA NA 336 0.11 38 13,946 Loader (Muckpile/Quarry) 1,500,000 56 67.5 NA NA NA NA 11.5 NA NA 357 0.02 7 2,470 Annual Days Vehicles Operate: Percent Single-Trailer Trucks: Percent Double Aluminum Trucks: Percent Double-Trailer Trucks: Unpaved (VMT/yr) Double Aluminum Haul Product Throughput Mean Trailer Weight, Single Trailer (tons)2,3 Mean Trailer Weight, Double Aluminum (tons)Single Trailer Haul Mean Trailer Weight, Double Trailer (tons)Double Trailer Haul Daily Total Travel Distance perHaul(VMT/haul) Total Vehicle Miles Traveled Haul/ Day Unpaved Unpaved Road Source Controlled Emissions Daily Emissions (lb/day)1 Annual Emissions (tpy)1 365 3 Maximum Gross Vehicle Weight (GVW) limitation per R909-2-5 Table 2. 10% Annual (VMT/day) 1 Daily and annual controlled emissions are calculated by applying the controlled emission factor (per UDAQ's control efficiencies) to the vehicular miles traveled per day (paved and unpaved). Daily Emissions (lb/day) = Miles Travelled per Day (VMT/day) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂) Annual Emissions (tpy) = Miles Travelled per Day (VMT/yr) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂) Percent of Potential Annual Throughput Increase via Muckpile Haul Route: Percent of Potential Annual Throughput via Main Haul Route: Road Source1 2 Truck weights per communication with Dan Peresinni, Las Vegas Paving, on August 25, 2020. 100% 1 Division of road travel: 30% 40% 30% Las Vegas Paving Grantsville Operations Page 9 of 11 Trinity Consultants December 2020 Table C-18. Roads Emissions - Emission Factors PM10 PM2.5 PM10 PM2.5 PM10 PM2.5 Unpaved None 0%2.56 0.26 2.53 0.25 3.14 0.31 Unpaved Watering 70%0.77 0.08 0.76 0.08 0.94 0.09 Unpaved Watering and Road Base 75%0.64 0.06 0.63 0.06 0.78 0.08 Unpaved Chemical Suppressant and Watering 85%0.38 0.04 0.38 0.04 0.47 0.05 Paved Pave Road Surface with Sweeping and Watering 90%0.26 0.03 0.25 0.03 0.31 0.03 Unpaved Roads where E = Size-specific emission factor (lb/VMT) k, a, b = Constants for equation 1a PM PM10 PM2.5 k =4.9 1.5 0.15 a =0.7 0.9 0.9 b =0.45 0.45 0.45 s = surface material silt content (%) s =6.0 WHT =39.3 Mean haul truck weight (tons) WLL=38.5 Mean loadout loader weight (tons) WQF=61.8 Mean quarry feed loader weight (tons) Per Las Vegas Paving, 08/25/2020. Road Surface Controls 1 Control Efficiency (%) Haul Truck Emission Factor 2 (lb/VMT) 1 Emission controls for vehicular traffic on paved and unpaved roads per UDAQ guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015. 2 Emission factors for vehicular traffic on unpaved roads for sand and gravel processing per U.S. EPA AP-42, Section 13.2.2 (Unpaved Roads), November 2006. Loadout Loader Emission Factor 2 (lb/VMT) Quarry Feed Loader Emission Factor 2 (lb/VMT) Las Vegas Paving Grantsville Operations Page 10 of 11 Trinity Consultants December 2020 Table C-19. Blasting and Drilling Area Maximum Annual Blast Frequency (blasts/yr) Maximum Annual Area Blasted (ft2/yr) Maximum Daily Blast Area (ft2/blast) Minimum Daily Blast Area (ft2/blast) 50 375,000 25,000 12,500 Table C-20. Drilling and Blasting Emission Factors Value Units Value Units Value Units Value Units Value Units Value Units Blasting (Max) 55.34 (lb/blast) 28.78 (lb/blast) 1.66 (lb/blast) Blasting (Min) 19.57 (lb/blast) 10.17 (lb/blast) 0.59 (lb/blast) Drilling Annual # of Drill Holes 2,000 (holes/yr) 1.30 (lb/hole) 0.68 (lb/hole) 3.90E-02 (lb/hole) - (lb/ton) - (lb/ton) - (lb/ton) PM10:0.52 PM2.5:0.03 PM10 = PM15 * 0.52 PM2.5 = TSP * 0.03 Table C-21. Blasting and Drilling Emissions Control Efficiency1 (%)PM PM10 PM2.5 SO2 NOX CO PM PM10 PM2.5 SO2 NOX CO Blasting 0% 55.34 28.78 1.66 2.40 340.00 1,340.00 1.38 0.72 0.04 0.06 8.50 33.50 Drilling 97.0% 1.64 0.85 0.05 -- -- -- 0.04 0.02 1.17E-03 -- -- -- 56.98 29.63 1.71 2.40 340.00 1,340.00 1.42 0.74 0.04 0.06 8.50 33.50 2Daily Blasting PM Emissions (lb/day) = Emission Factor (lbs/day) as only one blast is allowed per day. 3SO2, NOX, & CO Daily Blasting Emissions (lb/day) = Emission Factor (lb/ton) * Annual ANFO Throughput (tpy) / Annual Blasts (blasts/yr) 4Daily PM Drilling Emissions (lb/day) = Emission Factor (lb/hole) * Drill Holes/yr / Expected Working Days/Year 5SO2, NOX, & CO Annual Blasting Emissions (tpy) = Emission Factor (lbs/ton) * Annual ANFO Throughput (tpy) * 1 ton/2000 lbs 6Annual Blasting PM Emissions (tpy) = Emission Factor (lb/blast) * 50 blasts/yr * 1 ton/2000 lbs 7Annual PM Drilling Emissions (tpy) = Emission Factor (lb/hole) * Drill Holes/yr * 1 ton/2000 lb 6 Blast and drilling quantities provided per design basis. 1Drilling operations will be controlled through wet-drilling. NIOSH reports a range from 86% to 97% control efficiency for controlling fugitive emissions via wet-drilling (per Summary of NIOSH research completed on dust control methods for surface and underground drilling, Pg 2, December 2008). LVP has elected to implement wet-drilling control technologies to reduce fugitive drilling emissions. Because LVP will use a dust collector in addition to wet drilling, the maximum 97% control efficiency value for wet-drilling is assumed to be applicable. Scaling factors were applied to PM15 and TSP emission factors to calculate PM10 and PM2.5 emission factors respectively per Table 11.9-1: As there is not data for the PM15 emission factor equation, PM15 is conservatively assumed to be equal to TSP. 4 Blasting NOX and CO emission factors retrieved from ANFO blasting agent factor from AP-42 13.3-1. 3 Blasting SO2 emission factor developed using a mass balance assuming 6% fuel oil mixture with 500 ppm sulfur content, consistent with EPA non-road standards. Since no emission factors are provided for PM10 and PM2.5 drilling operations, emission factors were calculated using the PM10 and PM2.5 to TSP ratios for blasting overburden per AP-42 11.9, Table 11.9-1, where: 2Drilling PM emission factor is retrieved from AP-42 11.9, Table 11.9-4, where the drilling PM emission factor is for overburden material for conservatism. The coal PM emission factor is lower and may be appropriate for some drilling operations. Total Annual Emissions: Source Description Annual Emissions (tpy)5,6,7Max Daily Emissions (lbs/day)2,3,6 SO2Source Activity ThroughputSource Description Units Emission Factor1,2,3,4,5,6 PM10 PM2.5 NOX COPM 0.000014(A)^1.5 A = horizontal area (ft2), with blasting depth ≤ 70 ft 0.12 17.00 67.00(lb/ton)(lb/ton) 1Blasting PM emission factors retrieved from AP-42 11.9, Table 11.9-1. Using the equation below the horizontal area blasted (A) is assumed to be the average daily Blast Area. ANFO 1,000 (tpy)(lb/ton) Las Vegas Paving Grantsville Operations Page 11 of 11 Trinity Consultants December 2020 Las Vegas Paving | Notice of Intent C AIR DISPERSION MODELING PROTOCOL/REPORT Submitted under separate cover. Entrance Road BACT Future Plant Area Asphalt Entrance Road Best Available Control Technology - Asphalt pavement vs Uncontrolled dirt road. - only applicable in areas not traveled by track-style equipment 580 ft length (0.22 miles Round Trip) 24 ft wide (14,000 SF)4" Asphaltic Concrete, 6" Aggregate Base Best Available Control Technology - Asphalt pavement vs Uncontrolled dirt road. - only applicable in areas not traveled by track-style equipment 580 ft length (0.22 miles Round Trip)24 ft wide (14,000 SF)4" Asphaltic Concrete, 6" Aggregate Base Entrance Road BACT Future Plant Area Asphalt Entrance Road DAQE- RN160410001 February 8, 2022 Dan Fitzgerald Las Vegas Paving 4420 S Decatur Blvd Las Vegas, NV 89103 dan.fitzgerald@lasvegaspaving.com Dear Dan Fitzgerald, Re: Engineer Review: New Aggregate Processing Facility Project Number: N160410001 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. Las Vegas Paving should complete this review within 10 business days of receipt. Las Vegas Paving should contact Sarah Foran at (385) 306-6724 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email sforan@utah.gov the signed cover letter to Sarah Foran. 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 AO for signature by the DAQ Director. If Las Vegas Paving does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Las Vegas Paving 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 N160410001: Las Vegas Paving February 8, 2022 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N160410001 Owner Name Las Vegas Paving Mailing Address 4420 S Decatur Blvd Las Vegas, NV, 89103 Source Name Las Vegas Paving Source Location 8700 N Ellerbeck Rd Grantsville Pit Grantsville, UT 84029 UTM Projection 366,929 m Easting, 4,506,861 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1442 (Construction Sand & Gravel) Source Contact Dan Fitzgerald Phone Number (702) 353-4607 Email dan.fitzgerald@lasvegaspaving.com Project Engineer Sarah Foran, Engineer Phone Number (385) 306-6724 Email sforan@utah.gov Notice of Intent (NOI) Submitted December 7, 2020 Date of Accepted Application July 9, 2021 Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 2 SOURCE DESCRIPTION General Description Las Vegas Paving Corp. (LVP) will operate an aggregate crushing and screen plant in Tooele County. The plant will mine, size, wash and distribute aggregate. Drilling and blasting will be performed to access aggregate materials. Bulldozers will operate to move the materials. The aggregate crushing and screening operations will consist of two (2) operations; a Crushing and Screening Circuit and a Wash Circuit. The site will process up to 1.5 million tons of aggregate per year. NSR Classification: New Minor Source Source Classification Located in Tooele 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 Title V (Part 70) Area Source Project Proposal New Aggregate Processing Facility Project Description LVP has requested a new AO for an aggregate facility co-located with LHoist Chemical (LHoist), which is permitted under DAQE-AN0707015-06 dated August 14, 2006. The proposed aggregate facility will operate independently from LHoist. Upon evaluation, there are no shared products or co-mining between the two companies. LVP will mine from areas in which materials are unsuitable for LHoist's operations. LVP will also not operate at any period in which LHoist is operating. Therefore, LVP is a true minor source. The facility will operate as an aggregate mining operation. Materials on-site will be crushed, screened, and conveyed to storage piles. Condition II.B.1.g is unique to the operation. It will ensure that LVP does not operate at any time when LHoist is operating. This is to ensure compliance with the NAAQS. EMISSION IMPACT ANALYSIS Modeling was completed for PM10 emissions. All other pollutants were below the thresholds of R307-401-4 and R307-401-5. The results of the PM10 model are as follows: Pollutant Period Pollutant Period Prediction( μg/m3) Others(μg/m3) Backgroun d(μg/m3) Total(μg/m3) NAAQS(μ g/m3) Percent NAAQS PM10 24-Hour 93.30 0.00 50 143.3 150 95.5% As a result of the model the following conditions were added (Condition II.B.3.b and Condition II.B.1.g): · Blasting may occur one (1) hour per day between the hours of 10:00 am and 4:00 pm. · Drilling and Blasting may not occur on the same day. Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 3 · The facility may operate only when the Lhoist facility is not operating. · All operations except blasting must not operate during the hour that blasting occurs. [Last updated July 16, 2021] Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 4 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 0.00 Carbon Monoxide 35.50 33.50 Nitrogen Oxides 8.50 8.50 Particulate Matter - PM10 11.55 11.55 Particulate Matter - PM2.5 1.96 1.96 Sulfur Dioxide 0.06 0.06 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 0 Change (TPY) Total (TPY) Total HAPs 0.00 0.00 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 5 Review of BACT for New/Modified Emission Units 1. BACT review regarding Site-Wide Emission sources Crushing, Screening, and Material Handling Operations Crushing, screening, and material handling generate PM10 and PM2.5 emissions. Add-on controls for crushing and screening operations include: electrostatic precipitators (ESPs), enclosures, baghouses, and cyclones. Due to the mobile nature of crushers and screens, add-on controls are not technically feasible for this operation. Water sprays can be used to maintain material moisture and reduce emissions. Water sprays will be used on site. BACT for material handling is the use of water sprays to maintain visible emissions at or below 12% opacity for crushing and 7% for all conveyors, transfer points, and screens. Haul Roads Haul road and loader routes used on-site will generate PM10 and PM2.5 emissions. Possible controls include paving and sweeping (90%), chemical treatment and watering (85%), and water application (70%). The main haul roads on-site total 0.60 miles, these routes are the only permanent roads on-site. The cost effectiveness of paving and chemical treatment was evaluated for this route. The haul roads and routes total 0.971 miles (5127 feet) This is a total of the main haul route entries and east and west loops; the muckpile haul route; and loadout tram. Uncontrolled emissions from this route are estimated at 10.81 tons per year for PM10 and 1.01 tons per year of PM2.5. Paving the route would reduce emissions of PM10 by 9.07 tons per year. The annualized cost of this reduction is $11,402 per ton of PM10 reduced. This is not a cost-effective control option. LVP did not do a cost evaluation of chemical treatment, but has selected chemical treatment as BACT for the main haul routes- the main haul routes total 0.62 miles. The remaining haul roads and routes are short term loader and pit roads which are used to access materials throughout the facility. Due to the short-term nature of these roads, paving and chemically treating is not operationally feasible. Therefore, watering (70%) will be applied to all other roads and routes. LVP additionally proposed speed limit constraints for emission limitations. However, haul road emission calculations do not account for truck speed. The 20% opacity on-site and 10% at the property boundary for visible emissions is a sufficient limitation to ensure the PTE is not exceeded. As visible emissions vary due to on-site conditions, trucks must limit their speed to ensure the visible emissions are not exceeded. A limitation of speed limit was, therefore, not included and is not considered BACT for this facility. BACT for haul roads and loader routes is chemical treatment and watering of the main haul route, watering all other routes and maintaining visible emissions at or below 20% opacity on-site and 10% at the property boundary. Drilling and Blasting NOx, SO2, CO, PM10 and PM2.5 are generated from drilling and blasting operations. There are no available add-on controls for blasting operations. BACT for blasting is best management practices including limiting blasts and best engineering practices. Add-on controls for drilling include a shroud (88%), a shroud with a baghouse/dust collection system (99%), and wet drilling (70%). The source has selected to use water sprays and a baghouse/dust collection system on drilling operations. This and maintaining visible emissions at or below 20% on-site and 10% at the property boundary is BACT for drilling. [Last updated November 1, 2021] Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 6 SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] 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] Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 7 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 NEW Aggregate Mining II.A.2 NEW Crushing and Screening Circuit II.A.3 NEW One (1) Feeder Size: 800 TPH NSPS Applicability: Subpart OOO II.A.4 NEW One (1) Horizontal Shaft Impact (HSI) Crusher Size: 400 TPH NSPS Applicability: Subpart OOO II.A.5 NEW One (1) Vertical Shaft Impact (VSI) Crusher Size: 400 TPH NSPS Applicability: Subpart OOO II.A.6 NEW One (1) Cone Crusher Size: 400 TPH NSPS Applicability: Subpart OOO II.A.7 NEW One (1) Primary Triple-deck Screen Size: 400 TPH NSPS Applicability: Subpart OOO II.A.8 NEW One (1) Secondary Triple-deck Screen Size: 400 TPH NSPS Applicability: Subpart OOO II.A.9 NEW One (1) Tertiary Triple-deck Screen Size: 400 TPH NSPS Applicability: Subpart OOO II.A.10 NEW Various Conveyors* NSPS Applicability: Subpart OOO II.A.11 NEW Five (5) Stackers Maximum Size: 400 TPH NSPS Applicability: Subpart OOO II.A.12 NEW Wash Circuit Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 8 II.A.13 NEW Three (3) Bin Feeders Size: 400 TPH NSPS Applicability: Subpart OOO II.A.14 NEW One (1) Wash Screen* Size: 400 TPH NSPS Applicability: Subpart OOO II.A.15 NEW One (1) De-Water Screen Size: 400 TPH NSPS Applicability: Subpart OOO II.A.16 NEW Various Conveyors NSPS Applicability: Subpart OOO II.A.17 NEW Four (4) Stackers NSPS Applicability: Subpart OOO II.A.18 NEW One (1) Sand Screw Washer* II.A.19 NEW One (1) Clarifier* *Included for informational purposes SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 NEW Site-Wide Requirements II.B.1.a NEW The owner/operator shall not process more than 1,350,000 tons of aggregate and 150,000 tons of bank-run material per rolling 12-month period. [R307-401-8] II.B.1.a.1 NEW To demonstrate compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records of processed materials shall be maintained in an operations log and include: A. Daily Records for all periods when the plant is in operation B. Processed materials, determined by scale house records or vendor receipts. [R307-401-8] Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 9 II.B.1.b NEW The owner/operator shall not allow visible emissions from the following emission points to exceed the following opacity values: A. Crushers - 12% B. Screens - 7% C. All Conveyor Transfer Points - 7% D. All Conveyor Drop Points - 20% and 10% at the property boundary. [R307-312, R307-401-8] II.B.1.c NEW The owner/operator shall install water sprays on all crushers, all screens, all conveyor transfer points, and all conveyor drop points to control emissions. Sprays shall operate as required to ensure the opacity limits in this AO are not exceeded. [40 CFR 60 Subpart OOO, R307-401-8] II.B.1.d NEW The owner/operator shall perform monthly periodic inspections to check that water is flowing to discharge spray nozzles associated with each crusher, screen, and conveyor. If the owner/operator finds that water is not flowing properly during an inspection of the water spray nozzles, the owner/operator shall initiate corrective action within 24 hours and complete corrective action as expediently as practical. [40 CFR 60 Subpart OOO, R307-401-8] II.B.1.d.1 NEW Records of the water spray inspections shall be kept and maintained in a logbook for all periods when the plant is in operation. The records shall include the following items: A. Date the inspections were made B. Any corrective actions taken C. Control mechanism used if sprays are not operating. [40 CFR 60 Subpart OOO, R307-401-8] II.B.1.e NEW The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving maximum production rate but not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 of Subpart OOO. Records of initial performance tests shall be kept and maintained on site for the lifetime of the equipment. [40 CFR 60 Subpart OOO, R307-401-8] II.B.1.e.1 NEW Initial performance tests for fugitive emission limits shall be conducted according to 40 CFR 60.675(c). The owner/operator may use methods and procedures specified in 40 CFR 60.675(e) as an alternative. [40 CFR 60 Subpart OOO] II.B.1.e.2 NEW The owner/operator shall submit written reports of the results of all performance tests conducted to demonstrate compliance with 40 CFR 60.675 to the Director, attn.: Compliance Section. The submission shall be postmarked no later than 180 days from the date of this AO or no later than 180 days from equipment startup, whichever is later. [40 CFR 60 Subpart OOO, R307-401-8] Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 10 II.B.1.f NEW The owner/operator shall not exceed 1,000 hours of bulldozing operations per rolling 12-month total. [R307-401-8] II.B.1.f.1 NEW To demonstrate compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records of monthly bulldozer use shall be maintained in an operations log. [R307-401-8] II.B.1.g NEW The owner/operator shall halt all on-site operations at any period when the LHoist North America (LNA)- Grantsville Plant is operating. On-site operations are defined as crushing, drilling, blasting, hauling, and emission generating activities excluding maintenance operations. Operations may only resume once LNA operations end. [R307-401-8, R307-410] II.B.2 NEW Haul Roads and Fugitive Dust Sources Requirements II.B.2.a NEW Within 30 days of the date of this AO, the owner/operator shall submit a FDCP in electronic or written format. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the FDCP for control of all fugitive dust sources associated with aggregate operations. [R307-309-6] II.B.2.b NEW The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% at the property boundary. [R307-309-5, R307-401-8] II.B.2.b.1 NEW Visible emission determinations for fugitive dust from haul roads and operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5] II.B.2.c NEW The owner/operator shall not exceed 5,127 feet (about 0.97 miles) of unpaved roads and routes on-site. [R307-401-8] II.B.2.c.1 NEW The road and route lengths shall be determined through source records and Global Positioning System (GPS) measurements. [R307-401-8] II.B.2.d NEW The owner/operator shall apply chemical suppressant treatments to on-site haul roads for no less than 0.62 miles. The owner/operator shall apply water to all on-site roads as necessary to maintain the listed opacity requirements unless the temperature is below freezing. [R307-401-8] Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 11 II.B.2.d.1 NEW Records of water and chemical suppressant treatments on roads shall include the following: A. Date and time of application B. Location of application C. Temperature, if below freezing D. Type and manufacture recommendations for chemical suppressant treatment applications. [R307-401-8] II.B.2.d.2 NEW The owner/operator shall adhere to the chemical suppressants manufacturer's recommendations for application frequency. [R307-401-8] II.B.2.d.3 NEW Records of water and chemical suppressant application shall be kept for all periods when the plant is in operation. [R307-401-8] II.B.2.e NEW The owner/operator shall not exceed the following area limitations: A. 5 acres of disturbed ground B. 7.5 acres of stockpiles. [R307-401-8] II.B.2.e.1 NEW Compliance shall be determined through GPS measurements or aerial photographs. Reclaimed areas such as those with emerged vegetation or hydro-seeded do not contribute to the acreage totals. [R307-401-8] II.B.3 NEW Drilling and Blasting Requirements II.B.3.a NEW The owner/operator shall operate all drilling operations with a dust collection system and/or water sprays/wet drilling. [R307-401-8] Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 12 II.B.3.b NEW The owner/operator shall conduct drilling and blasting operations as follows: A. The owner/operator shall not exceed 375,000 square feet of blasted area per rolling 12- month period and 25,000 square feet of blasted area per 24-hour period. B. Drilling operations shall not occur within 24 hours of any blasting operations. Blasting shall not occur within 24 hours of drilling operations. C. The owner/operator shall not exceed one (1) hour of blasting per 24-hour period D. Blasting shall not occur before 10:00 AM and after 4:00 PM E. During blasting operations, the owner/operator shall not operate any aggregate operations on-site, with the exception of the blasting operations. The facility shall not operate for one (1) hour from the time of the blast. [R307-401-8, R307-410] II.B.3.b.1 NEW The owner/operator shall maintain a log of all drilling and blasting operations. The log shall include: A. The date and operation completed (drilling and blasting) B. The time of blasting or drilling C. The time when facility aggregate operations resumed after blasting D. Area, in square feet, of each blast. [R307-401-8] II.B.3.b.2 NEW To demonstrate compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. [R307-401-8] Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 13 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated December 20, 2021 Incorporates Additional Information dated February 12, 2021 Incorporates Additional Information dated May 6, 2021 Incorporates Additional Information dated June 24, 2021 REVIEWER COMMENTS 1. Comment regarding Emission Estimates: Emissions were based on a 1,500,000 tons per year of aggregate throughput (1,350,000 of crushed material and 150,000 tons of uncrushed/bankrun material). (Condition II.B.1.a) Crushing and screening emissions were based on emission factors in AP-42 Section 11.19.2 Table 11.19.2-2 for PM10 and PM2.5 emissions. As aggregate is sized by crushers and screens a certain percentage drops out as the desired size is met. Loading, unloading, and transfer emissions of PM10 and PM2.5 were estimated based on emission factors from AP-42 Section 11.19.2 and AP-42 Section 13.2.4. Stockpiles and disturbed ground emissions for the 12.5 total proposed acres were based on emission factors from AP-42 Section 8.19.1-- Table 8.19.1-1 Particulate size distribution was based on Appendix B.2 Table B.2-2. (Condition II.B.2.e) Bulldozer emissions of PM10 and PM2.5 emission from bulldozers were estimated at 1,000 hours per year using emission factors and scaling factors from AP-42 Section 11.9 Table 11.9-1. (Condition II.B.1.f) Road PM10 and PM2.5 emissions were calculated using equation 1a from AP-42 Section 13.2.2. An 85% control efficiency was used for chemically treated routes (0.62 miles) and 70% for watered routes (0.351 miles). Updated haul route lengths and emissions were submitted on May 5, 2021. (Condition II.B.2.c) SO2, NOx, and CO emissions from blasting were calculated using emission factors from AP-42 Section 13.3. PM10 and PM2.5 emissions were estimated using emission factors from AP-42 Section 11.9. Emissions were based on 375,000 square feet blasted per year and 25,000 square foot area blasted per day. (Condition II.B.3.b) PM10 and PM2.5 emissions from drilling were based on emission factors from AP-42 Section 11.9. A control factor of 97% was used for a combined control efficiency of baghouses and wet drilling. (Condition II.B.3.a) [Last updated February 8, 2022] Engineer Review N160410001: Las Vegas Paving February 8, 2022 Page 14 2. Comment regarding NSPS Applicability: Standards of Performance for Nonmetallic Mineral Processing Plant applies to fixed above ground nonmetallic mineral processing plants, including; crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truck or railcar loading stations. This site operates nonmetallic aggregate crushing, storage, and transfer processes. The aggregate equipment on-site is subject to this subpart. Applicable equipment is denoted in the equipment list. Subpart OOO requires an initial opacity observation for new on-site equipment. This requirement is reflected in the conditions of this AO. [Last updated November 1, 2021] 4. 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 source is subject to 40 CFR 60 NSPS Subparts A and OOO. NSPS Subparts OOO does not exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. Therefore, this source is a Title V area source and Title V applies to this facility. [Last updated August 25, 2021] Engineer Review N160410001: Las Vegas Paving February 8, 2022 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 7/26/2021 State of Utah Mail - LVP Roads BACT https://mail.google.com/mail/u/0?ik=b363bbe9c3&view=pt&search=all&permmsgid=msg-f%3A1706376048404900016&simpl=msg-f%3A17063760484…1/1 Sarah Foran <sforan@utah.gov> LVP Roads BACT Dan Fitzgerald <Dan.Fitzgerald@lasvegaspaving.com>Mon, Jul 26, 2021 at 1:16 PM To: Sarah Foran <sforan@utah.gov> Cc: Chase Peterson <CPeterson@trinityconsultants.com>, Brian Mensinger <bmensinger@trinityconsultants.com> Sarah, Sorry for the delay. We’ve had this quote for a while, but it was on someone else’s computer and we did not have access. Please use this as necessary and let me know the next step in the permitting process. We want to wrap this up as soon as possible. Thank you, Danny Fitzgerald Las Vegas Paving 702-353-4607 From: Sarah Foran <sforan@utah.gov> Sent: Tuesday, June 29, 2021 8:46 AM To: Brian Mensinger <bmensinger@trinityconsultants.com> Cc: Dan Fitzgerald <Dan.Fitzgerald@lasvegaspaving.com>; Chase Peterson <CPeterson@trinityconsultants.com> Subject: Re: LVP Roads BACT CAUTION: NOT AN LVP SENDER: This email originated from outside of the company. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hi All, [Quoted text hidden] [Quoted text hidden] 20210722_142944.pdf 483K LVP BACT Cost Analysis - Paving Entrance Road BACT Economics Analysis Value Units Value Reference PM10 Reduction %33%Calculated PM10 Unpaved Application tpy 3.41 [1] PM10 Paved tpy 2.28 [2] PM10 Reduced by Paving tpy 1.14 Calculated Total Capital Cost $$264,039 [3] Capital Recovery Factor %10.98%[4] Annualized Cost $/yr $28,990 Calculated Admin, Taxes, Insurance $/yr $10,562 [5] Street Sweeping $/yr $17,500 [6] Total Annual Cost $/yr $57,052 Calculated: Sum of Annualized Costs Cost of Control $/ton removed $50,154 Calculated: Cost per ton removed Interest Rate 7%Per EPA Air Pollution Control Cost Manual, Seventh Ed., 2017, Sect. 2.5.2, pg 14-17. Useful life of source 15 Per EPA's 2015 report of Construction and Demolition Debris Generation in the United States, Table 2. Capital Recovery Factor 10.98%Per EPA Air Pollution Control Cost Manual, Seventh Ed., 2017, Sect. 2.5.4.2, pg 22. 5 Admin, Taxes, Insurance assumed to be:4.00%Per EPA Air Pollution Control Cost Manual, Seventh Ed., 2017, Sect. 2.6.5.8, pg 2-35. Capital Implementation Costs Cost of Compliance (Statutory Factor 1) Table D-5. Las Vegas Paving - Haul Roads - Paving Cost Analysis Paving Haul RoadsParameter Potential PM10 Reduction 1 Per potential to Emit Calculation for haul truck travel on unpaved haul roads. 2 Per potential to Emit Calculation for haul truck travel on paved haul roads. 3 Per quote from competitor, provided on 04/19/2021. 4 Capital Recovery factor (CRF) calculated as follows. Paving minus the cost of chemical application. 6 Salary of operator 50% of time. Salary based on Salary.com for street sweeper operator in Salt Lake City. Las Vegas Paving - NOI Supplement Page 16 of 16 Grantsville, Utah 90% 22.73 2.27 20.46 22.73 * (1-0.9) = 2.27 22.73-2.27= 20.46 tpy reduced 57,052 $/yr / 20.46 = 2,788 $/ ton removed 3.41/0.15=22.73 tpy ¥ < LVP BACT Cost Analysis - Paving Entrance RoadInputs Table 1a. Las Vegas Paving - InputsParameter Value Units Notes Road width 42.65 ft Per Modeling Specifications Road length to pave 1,181 ft Per Modeling Specifications Price of paving 4.50 $/square foot Based on competitor's paving quotation provided on 04/19/2021. Estimate includes preparing a road base. Total cost of paving 226,694.41 $Calculated Las Vegas Paving - NOI Supplement Page 1 of 3 Grantsville, Utah LVP BACT Cost Analysis - Paving Entrance Road Inputs Table 1b-1. Roads Emissions - Traveling Parameters (Supporting Operations) Empty Single-Trailer Trucks Loaded Single-Trailer Trucks Empty Double-Aluminum Trucks Loaded Double Aluminum Trucks Empty Double Trailer Trucks Loaded Double-Trailer Trucks (tpy)(tons)(tons)(tons)(tons)(tons)(tons)(tons/haul)(tons/haul)(tons/haul)(Miles/haul)(VMT/day)(VMT/yr) Main Haul Road (Entry)1,500,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 118 0.22 26.4 9,635Main Haul Road (W Loop)750,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 59 0.14 8.1 2,944 Main Haul Road (E Loop)750,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 59 0.09 5.5 2,007 Main Haul Road (E Loop Entry)750,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 59 0.15 8.8 3,211 Annual Days Vehicles Operate: Percent Single-Trailer Trucks: Percent Double Aluminum Trucks: Percent Double-Trailer Trucks: Table 1b-2. Roads Emissions - Emission Factors PM10 PM2.5UnpavedNone0%2.09 0.21 Unpaved Watering 70%0.63 0.06 Unpaved Watering and Road Base 75%0.52 0.05 Unpaved Chemical Suppressant and Watering 85%0.31 0.03 Paved Pave Road Surface with Sweeping and Watering 90%0.21 0.02 Unpaved Roads where E =Size-specific emission factor (lb/VMT) k, a, b = Constants for equation 1a PM PM10 PM2.5k =4.9 1.5 0.15 a =0.7 0.9 0.9 b =0.45 0.45 0.45 s =surface material silt content (%) s =4.8 WHT =39.3 Mean haul truck weight (tons) Table 1b-3. Main Haul Road Emissions - PTE Emissions PM10 PM2.5 PM10 PM2.5Unpaved, No Controls (Trucks)55.21 5.52 10.08 1.01Paved Roads 5.52 0.55 1.01 0.10 2 Truck weights per communication with Dan Peresinni, Las Vegas Paving, on August 25, 2020. 3 Maximum Gross Vehicle Weight (GVW) limitation per R909-2-5 Table 2.365 30% Mean Trailer Weight, Double Aluminum (tons)Mean Trailer Weight, Double Trailer (tons)Single Trailer Haul 100% 10% 1 Division of road travel: Daily AnnualTotal Travel Distance per Haul Percent of Potential Annual Throughput Increase via Muckpile Haul Route: Percent of Potential Annual Throughput via Main Haul Route: Double Aluminum Haul Double Trailer Haul Haul/Day Total Vehicle Miles Traveled Road Source1 Product Throughput Mean Trailer Weight, Single Trailer (tons)2,3 40% Road Surface Haul Truck Emission Factor 2 (lb/VMT) 1 Emission controls for vehicular traffic on paved and unpaved roads per UDAQ guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015. 2 Emission factors for vehicular traffic on unpaved roads for sand and gravel processing per U.S. EPA AP-42, Section 13.2.2 (Unpaved Roads), November 2006. 30% Per UDAQ Guidance on Paved and Unpaved Haul Roads, 2015. Controls 1 Control Efficiency (%) Annual Emissions (tpy) = Miles Travelled per Day (VMT/yr) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂𝜂) Road Source1 Daily Emissions (lb/day)2 Annual Emissions (tpy)2 2 Daily and annual controlled emissions are calculated by applying the controlled emission factor (per UDAQ's control efficiencies) to the vehicular miles traveled per day (paved and unpaved). Daily Emissions (lb/day) = Miles Travelled per Day (VMT/day) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂𝜂) 1 Calculations are made based on the paving of the Main Haul Road (Entry). Las Vegas Paving - NOI Supplement Page 2 of 3 Grantsville, Utah LVP BACT Cost Analysis - Paving Entrance RoadInputs Value Units Value Reference PM10 Reduction %90%[1] PM10 Unpaved Application tpy 10.08 [2] PM10 Paved tpy 1.01 [3] PM10 Reduced by Paving tpy 9.07 Calculated Total Capital Cost $$226,694 [4] Capital Recovery Factor %14.24%[5] Annualized Cost $/yr $32,276 Calculated Admin, Taxes, Insurance $/yr $9,068 [6] Street Sweeping $/yr $62,054 [7] Total Annual Cost $/yr $103,398 Calculated: Sum of Annualized Costs Cost of Control $/ton removed $11,402 Calculated: Cost per ton removed 7%Per EPA Air Pollution Control Cost Manual, Seventh Ed., 2017, Sect. 2.5.2, pg 14-17. 10 Per EPA's 2015 report of Construction and Demolition Debris Generation in the United States, Table 2. 14.24%Per EPA Air Pollution Control Cost Manual, Seventh Ed., 2017, Sect. 2.5.4.2, pg 22. 6 Admin, Taxes, Insurance assumed to be:4.00%Per EPA Air Pollution Control Cost Manual, Seventh Ed., 2017, Sect. 2.6.5.8, pg 2-35. $190 Per Western Regional Air Partnership (WRAP) Fugitive Dust Handbook, 2006, Appendix B, pg B-1. Assumes that street sweeping is done four (4) times per day. Capital Recovery Factor Useful life of source Interest Rate 7 Street Sweeping Costs 2 Per potential to Emit Calculation for haul truck travel on unpaved haul roads. 3 Per potential to Emit Calculation for haul truck travel on paved haul roads. 4 Based on quote from competitor, provided on 04/19/2021. 5 Capital Recovery factor (CRF) calculated as follows. Paving minus the cost of chemical application. 1 Per paved road surface with sweeping and watering control from UDAQ's Guidelines on "Emission Factors for Paved and Unpaved Haul Roads", January 12, 2015. Capital Implementation Costs Cost of Compliance (Statutory Factor 1) Table 2. Las Vegas Paving - Haul Roads - Paving Cost Analysis Paving Haul RoadsParameter Potential PM10 Reduction Las Vegas Paving - NOI Supplement Page 3 of 3 Grantsville, Utah MEMORANDUM 4525 Wasatch Blvd, Ste 200, Salt Lake City, UT 84124 P 801.272.3000 / F 801.272.3040 To: Sarah Foran, Utah Division of Air Quality From: Brian Mensinger, Trinity Consultants CC: Danny Fitzgerald, Las Vegas Paving Dan Peressini, Las Vegas Paving Chase Peterson, Trinity Consultants Date: May 5, 2021 RE: Permitting of Las Vegas Paving’s Grantsville Operations Dear Sarah, On December 9, 2020, a Notice of Intent (NOI) air permit application was submitted for Las Vegas Paving’s (LVP’s) proposed installation and operations at Lhoist North America’s (LNA’s) Grantsville Plant in Grantsville, Utah, Tooele County. After review of the submitted NOI air permit application, you had some remaining questions as addressed in your April 2, 2020 email, and subsequent follow-up call on April 8, 2021. This memo addresses those questions, with each question given in italics, below, and the response given immediately thereafter. The supplemental information provided in this memorandum is requested to replace the corresponding sections of the December 9, 2020 NOI air permit application. Furthermore, changes indicated in this submittal have been addressed to update LVP’s NOI air permit application resulting from the National Ambient Air Quality Standards (NAAQS) PM10 modeling exercise. Revisions to the information submitted in the original application have been addressed in each section of the following text. Please do not hesitate to contact me with any questions with respect to the contents of this response. Brian Mensinger Trinity Consultants LVP’s response to the questions asked by the Utah Division of Air Quality (UDAQ) have been addressed below: 1. For the BACT: The state does not consider aggregate haul trucks to be too heavy for paving. As these vehicles travel on highways and public roads, a Best Available Control Technology (BACT) evaluation for haul routes must include a cost evaluation for paving (especially for main haul routes which do not change). In LVP’s NOI air permit application submitted on December 9, 2020, the BACT evaluation of roads was combined considering both highway customer trucks entering the site and mine haul trucks and heavy equipment conducting mining operations. Based on a follow-up conversation with UDAQ, it was requested that LVP consider the entrance haul route separately in the BACT analysis since on-highway trucks for customer delivery will be traveling on these roads. Accordingly, LVP has provided additional information in section “5. BACT” of this memorandum to supplement the NOI air permit application and address consideration of paving the entrance road for the BACT evaluation. See section “5. BACT” for the revisions to the BACT analysis. This evaluation is intended to be separate and apart from the mine haul routes on which trucks, bulldozers, loaders and/or excavators travel. Some of these vehicles could be tracked vehicles. As the mine haul roads are temporary in location following a progressive mining sequence and this heavy May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 2 of 16 equipment will quickly degrade paving on these roads, paving the mine haul roads remains technically infeasible. 2. The calculations use varying, vaguely explained, aggregate throughput rates. Based on my understanding of the operations, it looks like the actual aggregate throughput operations are closest to 600,000 tpy (1.35 million is screened but only 0.6 million is crushed). While the summary indicates a throughput of 1.5 million my current understanding is that the allowable throughput should be around 600,000 tpy. As described throughout the application, LVP is proposing to mine 1.5 million tons per year. Of this total, 1.35 million (i.e., 90% of aggregate) will be crushed and screened (i.e., processed). The remaining 10% will be run-of-mine and loaded into customer trucks without further processing for crushing and screening. In the emissions calculations developed for the NOI air permit application, the HSI Crusher was inadvertently listed as processing 40% of the throughput, which gives the appearance of a reduced throughput. However, as demonstrated in the NOI air permit application and the remainder of the emissions calculations, the remaining downstream equipment, including the primary screen, operates at 90% (equivalent to 1.35 million tons per year), thus necessitating a 90% throughput through the HSI Crusher as well. Although the throughput of the HSI Crusher was given as 40% of the total throughput of the LVP installation and operation in the emission calculations, it will operate at 90% and has been updated accordingly. This is the percentage of material that is mined and fed into the feeder, which then feeds into the HSI Crusher. This change has been made in the emissions calculations, and updated tables are given in the pages that follow. Although the potential-to-emit (PTE) will change for particulate matter with an aerodynamic diameter of less than ten microns (PM10) and less than 2.5 microns (PM2.5) on an annual basis, the results of the air dispersion modeling done for PM10 at LVP’s Grantsville Operation will not be affected. This is because the air dispersion modeling is based on the maximum hourly throughput of each piece of equipment rather than its annual PTE. In this instance, the HSI Crusher’s maximum hourly throughput of 400 tons per hour (tph) will remain unchanged, thus resulting in no change to the results of the PM10 air dispersion modeling. In addition to the changes ensuing from UDAQ’s questions, other changes were made during the process of demonstrating compliance with the NAAQS through performing air dispersion modeling for PM10. Specifically, the configuration of the entrance road for customer haul trucks was updated, resulting in a shortened entrance haul road. Please refer to Figure 2-1 in the Modeling Report submitted to UDAQ on January 13, 2021 for the current configuration. This shortened haul road decreased the PTE of LVP’s installation and operations, a change that is represented in the following portions of this memo. LVP requests that changes - starting with Sections 1, 3, 4, 6, and Appendix B to the December 9, 2020 NOI air permit application - be made in the following sections to this memorandum, as necessitated by the UDAQ’s inquiry and as a result of the changes made during the air dispersion modeling exercise. 3. The used oil house: I am not sure if this is an issue or even applicable to the air permit. A compliance inspector, who evaluated Lhoist's site, indicated I should ask about a used oil house. As we discussed on our call on April 8, 2021, the oil house only contains sealed containers and oil tanks. The oil house is not being used by LVP, but rather will continue to be used by Lhoist. Therefore, the oil house does not apply to LVP’s NOI air permit application and has not been addressed further. May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 3 of 16 NOI Air Permit Application – Supplemental Information 1. EXECUTIVE SUMMARY Please redact the fifth paragraph of Section 1 and replace it with the following: Emission calculations were performed for the LVP’s Grantsville installation and operations to determine the proposed emissions of criteria pollutants (see Appendix B). The proposed emissions constitute the LVP Grantsville potential to emit (PTE); see Table 4-1. PTE values for criteria pollutants, given in tons per year (tpy) are proposed as follows: PM10 = 11.55, PM2.5 = 1.96, NOX = 8.50, CO = 33.50, SO2 = 0.06, VOC = 0.00, and HAPs = 0.00. The LVP’s Grantsville Operation is proposed to be permitted as a minor source. 3. DESCRIPTION OF PROJECT AND PROCESS Please redact Figure 3-4 in Section 3 and replace it with the following image of the same name: Figure 3-4. Property Boundary Close-up and Main Haul Road May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 4 of 16 Figures 3-5 and 3-6, shown below, show the maximum potential percentage of the total throughput that could be handled or processed by each labeled stream or piece of equipment. Because the maximum potential percentage of the throughput has been given, the values do not sum evenly. This was done to provide a conservative PTE value and to allow for operational flexibility. Figure 3-5. Dry Circuit Crushing and Screening Process Flow Diagram. Figure 3-6. Wash Circuit Crushing and Screening Process Flow Diagram. May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 5 of 16 4. EMISSIONS RELATED INFORMATION Please redact Table 4-1 in Section 4.8 and replace it with the following table of the same name: Table 4-1. Proposed LVP Installation and Operations Emissions Versus Major Source Thresholds. Site-Wide Emissions Criterion PM10 PM2.5 NOX CO SO2 VOC CO2e Crushing and Screening Operations 1.91 0.27 0.00 0.00 0.00 0.00 0.00 Stockpiles and Disturbed Grounds 2.32 0.84 0.00 0.00 0.00 0.00 0.00 Bulldozers and Drops 1.56 0.30 0.00 0.00 0.00 0.00 0.00 Drilling and Blasting 0.74 0.04 8.50 33.50 0.06 0.00 -- Roads 5.02 0.50 0.00 0.00 0.00 0.00 0.00 Proposed Site-Wide Emissions1 11.55 1.96 8.50 33.50 0.06 0.00 0.00 Major Source Thresholds2 100 70 70 100 70 70 100,000 Threshold Exceeded? No No No No No No No 1. Ammonia and HAPs emissions were considered in the LVP Grantsville Operation’s facility-wide emissions; however, these emissions are not applicable, as site power is provided by line power and there are no other sources of ammonia or HAPs. 2. Values are per UAC R307-403-5(2)(b)(ii) 5. BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS Per UDAQ request, a BACT analysis has been done specifically regarding the feasibility of paving the haul roads at the LVP installation and operation. Please redact the second paragraph under “Road Paving” in Section 5.2 of Section 5 and replace it with the following. The main haul road, which is used for product export, is currently unpaved. Paving the main haul road can result in the mitigation of fugitive dust as a long as some form of dust removal (e.g., street sweeping) is applied thereafter. Paving of the main haul road is considered technically feasible. Please redact Table 5-2 from Section 5.2 and replace it with the following table of the same name. Table 5-2. Fugitive PM10 and PM2.5 Control Technologies and Efficiencies for Roads. Control Method Control Efficiency (%) Road Paving, Sweeping, and Watering 90 Chemical Suppressant and Watering 85 Basic Watering and Road Base 75 Basic Watering 70 Reduced Speed 44 Please redact the paragraph under Step 4 in Section 5.2 and replace it with the following paragraph. Since the highest available controls for unpaved roads include implementing chemical suppression, road watering, speed reduction, and silt content reduction on unpaved roads, no detailed economic, energetic, or environmental impact evaluations were conducted on the mining roads. However, since the main haul road used for product export could be paved as on-road trucks primarily use this road an economics analysis has been included in Appendix D to supplement the NOI air permit application. May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 6 of 16 Paving of the main haul road is considered technically feasible and achieves the highest control efficiency of the control methods listed in Table 5-2. However, an economic analysis shows that paving of the haul road is economically infeasible, as the cost per ton of pollutant removed is $50,154. See the economic analysis given in Attachment A to this memorandum. May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 7 of 16 6. COMPARISON TO MODELING THRESHOLDS Please redact Table 6-1 from Section 6.1 and replace it with the following table of the same name: Table 6-1. LVP Equipment and Operations Emissions and Comparison to Major Source and Modeling Thresholds. Potential to Emit (tpy)1,2 Description PM10 PM2.5 NOX CO SO2 VOC CO2e Crushing and Screening Operations 1.91 0.27 -- -- -- -- -- Stockpiles and Disturbed Grounds 2.32 0.84 -- -- -- -- -- Bulldozers and Drops 1.56 0.30 -- -- -- -- -- Drilling and Blasting 0.74 0.04 8.50 33.50 0.06 -- -- Roads 5.02 0.50 -- -- -- -- -- Proposed Site-Wide Emissions 11.55 1.96 8.50 33.50 0.06 0.00 0.00 Modeling Limits3 5/15 None 40 100 40 None None Threshold Exceeded? No No No No No No No Major Source Thresholds4 100 70 70 100 70 70 100,000 Threshold Exceeded? No No No No No No No 1. The LVP Grantsville Operation is located in Tooele County, which is in serious nonattainment for PM2.5. Values are per UAC R307-403-5(2)(b)(ii). 2. Ammonia emissions were considered in the LVP Grantsville Operation’s facility-wide emissions; however, these emissions are not applicable, as site power is provided by line power. 3. Per Emissions Impact Assessment Guidelines published by UDAQ. 4. Values are per UAC R307-403-5(2)(b)(ii). APPENDIX B. EMISSION CALCULATIONS Please redact the following tables from Appendix B and replace them with the following tables of the same names: Table C-2. Equipment List Type of Equipment / Activities Number of Units or Drop Points Location1 Throughput Percent Max. Hourly Limit Potential Annual Throughput Potential Total Annual Throughput (%) (tph) (tpy/unit) (tpy) Primary HSI Crusher 1 Dry Circuit 90.00% 400 1,350,000 1,350,000 Secondary Cone Crusher 1 Dry Circuit 35.00% 250 525,000 525,000 Tertiary VSI Crusher 1 Dry Circuit 18.75% 170 281,250 281,250 Feeder 1 Dry Circuit 90.00% 800 1,350,000 1,350,000 Bin Feeders 3 Wash Circuit 45.00% 400 225,000 675,000 Primary Screening 1 Dry Circuit 90.00% 800 1,350,000 1,350,000 Secondary Screening 1 Dry Circuit 35.00% 250 525,000 525,000 Tertiary Screening 1 Dry Circuit 18.75% 170 281,250 281,250 Wash Screen 1 Wash Circuit 45.00% 400 675,000 675,000 May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 8 of 16 Type of Equipment / Activities Number of Units or Drop Points Location1 Throughput Percent Max. Hourly Limit Potential Annual Throughput Potential Total Annual Throughput (%) (tph) (tpy/unit) (tpy) Conveyors (800) 3 Dry Circuit 90.00% 800 1,350,000 4,050,000 Conveyors (400, 50%) 2 Dry Circuit 50.00% 400 750,000 1,500,000 Conveyor (400, 45%) 1 Wash Circuit 45.00% 400 675,000 675,000 Conveyors (250) 2 Dry Circuit 35.00% 250 525,000 1,050,000 Conveyors (200) 2 Dry Circuit 25.00% 200 375,000 750,000 Conveyors (170) 2 Dry Circuit 18.75% 170 281,250 562,500 Conveyor (160) 1 Dry Circuit 17.50% 160 262,500 262,500 Conveyor (150) 1 Wash Circuit 22.50% 150 337,500 337,500 Conveyors (140) 2 Wash Circuit 20.25% 140 303,750 607,500 Conveyor (120) 1 Dry Circuit 15.00% 120 225,000 225,000 Conveyors (80, 10%) 2 Dry Circuit 10.00% 80 150,000 300,000 Conveyors (80, 9.375%) 2 Dry Circuit 9.375% 80 140,625 281,250 Conveyor (60) 1 Wash Circuit 11.25% 60 168,750 168,750 Conveyor (40, 11.25%) 1 Wash Circuit 11.25% 40 168,750 168,750 Conveyor (40, 8.75%) 1 Dry Circuit 8.75% 40 131,250 131,250 Conveyor (40, 4.6875%) 1 Dry Circuit 4.69% 40 70,313 70,313 Future Conveyors 3 Mine 90.00% 800 1,350,000 4,050,000 Stacker A 1 Dry Circuit 50.00% 400 750,000 750,000 Stacker C 1 Dry Circuit 17.50% 160 262,500 262,500 Stacker D 1 Dry Circuit 4.69% 40 70,313 70,313 Stacker E 1 Dry Circuit 9.38% 80 140,625 140,625 Stacker F 1 Wash Circuit 20.25% 140 303,750 303,750 Stacker G 1 Wash Circuit 11.25% 60 168,750 168,750 Stacker H 1 Wash Circuit 22.50% 150 337,500 337,500 Stacker I 1 Wash Circuit 11.25% 40 168,750 168,750 Sand Screw 1 Wash Circuit 22.50% 150 337,500 337,500 Dewater Screen 1 Wash Circuit 20.25% 140 303,750 303,750 Clarifier 1 Wash Circuit 2.25% 10 33,750 33,750 Loader to Feeder 1 Dry Circuit 90.00% 800 1,350,000 1,350,000 Loader to Wash Bins 1 Wash Circuit 45.00% 400 675,000 675,000 Loader to Haul Trucks (Final Product) 1 Stockpile 90.00% 800 1,350,000 1,350,000 Loader to Haul Trucks (Muckpile) 1 Mine 10.00% 800 150,000 150,000 1. It is assumed that all Wash Circuit equipment (excepting Bin Feeders) will have no fugitive dust emissions due to their water-saturated environment. May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 9 of 16 Table C-5. Roads Parameter1 Quantity Unit Main Haul Road (Entry) 0.22 (miles) Main Haul Road (W Loop) 0.14 (miles) Main Haul Road (E Loop) 0.09 (miles) Main Haul Road (E Loop Entry) 0.15 (miles) Muckpile Haul Route 0.34 (miles) Loadout Tram Length 0.011 (miles) Muckpile/Quarry Tram Length 0.02 (miles) Empty Single-Trailer Trucks 17.00 (tons) Loaded Single-Trailer Trucks 40.00 (tons) Empty Double-Aluminum Trucks 22.50 (tons) Loaded Double-Aluminum Trucks 64.50 (tons) Empty Double-Trailer Trucks 27.00 (tons) Loaded Double-Trailer Trucks 64.50 (tons) Empty Loadout Loader Weight 33.00 (tons) Loaded Loadout Loader Weight 44.00 (tons) Empty Quarry Feed Loader Weight 56.00 (tons) Loaded Quarry Feed Loader Weight 67.50 (tons) 1. All haul and tram route distances are given as roundtrip distances, except fot the main haul road W Loop and E Loop, which are one way travel distance to account for trucks using the loop to turn around. Table C-8. Facility-Wide Emissions Emissions (tpy) PM10 PM2.5 NOX CO SO2 VOC CO2e Proposed Site-Wide Emissions 11.55 1.96 8.50 33.50 0.06 0.00E+00 0.00E+00 Major Source Thresholds1,2 70 70 70 100 70 70 NA Threshold Exceeded? No No No No No No No Modeling Limits3 15 No Limit 40 100 40 No Limit No Limit Threshold Exceeded? No No No No No No No 1. The Grantsville site is located in Tooele County, which is in serious nonattainment for PM2.5. Values are per UAC R307-403-5(2)(b)(ii). 2. Ammonia and HAPs emissions were considered in the Grantsville Site’s facility-wide emissions; however, these emissions are not applicable, as site power is provided by line power. 3. Per Emissions Impact Assessment Guidelines published by UDAQ. May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 10 of 16 Table C-9. Annual Potential Emissions Increase Summary Process PM10 (tpy) PM2.5 (tpy) NOX (tpy) CO (tpy) SO2 (tpy) VOC (tpy) CO2e (tpy) Proposed Project Emissions Crushing and Screening Operations 1.91 0.27 0.00 0.00 0.00 0.00 0.00 Stock Piles and Disturbed Grounds 2.32 0.84 0.00 0.00 0.00 0.00 0.00 Bulldozers & Drops 1.56 0.30 0.00 0.00 0.00 0.00 0.00 Roads 5.02 0.50 0.00 0.00 0.00 0.00 0.00 Drilling and Blasting 0.74 0.04 8.50 33.50 0.06 0.00 -- Total Potential Emissions (tpy) 11.55 1.96 8.50 33.50 0.06 0.00 0.00 Throughput Percent Potential Annual Throughput (%) (tpy)PM10 PM2.5 PM10 PM2.5 PM10 PM2.5 Primary Crushing Primary HSI Crusher 1 90%1,350,000 Moisture Carryover 6.00E-04 9.09E-05 2.22 0.34 0.41 6.13E-02 Secondary Crushing Secondary Cone Crusher 1 35%525,000 Wet Suppression 2.70E-04 4.09E-05 0.39 0.06 0.07 1.07E-02 Tertiary Crushing Tertiary VSI Crusher 1 19%281,250 Wet Suppression 5.40E-04 1.00E-04 0.42 0.08 0.08 1.41E-02 Conveyor Transfer Feeder 1 90%1,350,000 Moisture Carryover 4.60E-05 1.30E-05 0.17 0.05 0.03 8.78E-03 Drop Bin Feeders 3 45%225,000 Moisture Carryover 6.08E-04 9.21E-05 1.12 0.17 0.21 3.11E-02 Screening Primary Screening 1 90%1,350,000 Moisture Carryover 7.40E-04 5.00E-05 2.74 0.18 0.50 0.03 Screening Secondary Screening 1 35%525,000 Moisture Carryover 7.40E-04 5.00E-05 1.06 0.07 0.19 1.31E-02 Screening Tertiary Screening 1 19%281,250 Moisture Carryover 7.40E-04 5.00E-05 0.57 0.04 0.10 7.03E-03 Conveyor Transfer Conveyors (800)3 90%1,350,000 Moisture Carryover 4.60E-05 1.30E-05 0.51 0.14 0.09 2.63E-02 Conveyor Transfer Conveyors (400, 50%) 2 50%750,000 Moisture Carryover 4.60E-05 1.30E-05 0.19 0.05 0.03 9.75E-03 Conveyor Transfer Conveyor (400, 45%) 1 45%675,000 Moisture Carryover 4.60E-05 1.30E-05 0.09 2.40E-02 0.02 4.39E-03 Conveyor Transfer Conveyors (250)2 35%525,000 Moisture Carryover 4.60E-05 1.30E-05 0.13 0.04 0.02 6.83E-03 Conveyor Transfer Conveyors (200)2 25%375,000 Moisture Carryover 4.60E-05 1.30E-05 0.09 2.67E-02 0.02 4.88E-03 Conveyor Transfer Conveyors (170)2 19%281,250 Moisture Carryover 4.60E-05 1.30E-05 0.07 2.00E-02 1.29E-02 3.66E-03 Conveyor Transfer Conveyor (160)1 18%262,500 Moisture Carryover 4.60E-05 1.30E-05 0.03 9.35E-03 6.04E-03 1.71E-03 Conveyor Transfer Conveyor (150)1 23%337,500 Fully Saturated ------ Conveyor Transfer Conveyors (140)2 20%303,750 Fully Saturated ------ Conveyor Transfer Conveyor (120)1 15%225,000 Moisture Carryover 4.60E-05 1.30E-05 0.03 8.01E-03 5.18E-03 1.46E-03 Conveyor Transfer Conveyors (80, 10%)2 10%150,000 Moisture Carryover 4.60E-05 1.30E-05 0.04 1.07E-02 6.90E-03 1.95E-03 Conveyor Transfer Conveyors (80, 9.375%) 2 9%140,625 Moisture Carryover 4.60E-05 1.30E-05 0.04 1.00E-02 6.47E-03 1.83E-03 Conveyor Transfer Conveyor (60)1 11%168,750 Fully Saturated ------ Conveyor Transfer Conveyor (40, 11.25%) 1 11%168,750 Fully Saturated ------ Conveyor Transfer Conveyor (40, 8.75%) 1 9%131,250 Moisture Carryover 4.60E-05 1.30E-05 0.02 4.67E-03 3.02E-03 8.53E-04 Conveyor Transfer Conveyor (40, 4.6875%) 1 5%70,313 Moisture Carryover 4.60E-05 1.30E-05 8.86E-03 2.50E-03 1.62E-03 4.57E-04 Conveyor Transfer Sand Screw 1 23%337,500 Fully Saturated ------ Screening Dewater Screen 1 20%303,750 Fully Saturated ------ Conveyor Transfer Future Conveyors 3 90%1,350,000 Moisture Carryover 4.60E-05 1.30E-05 0.51 0.14 0.09 2.63E-02 10.44 1.48 1.91 0.27 2 "Fully Saturated" indicates that the equipment is part of the Wash Circuit. Due to the fully saturated nature of aggregate within the Wash Circuit, these emissions are assumed to be negligible. Table C-11. Annual Aggregate Processed Total Emissions: Daily PTE Emissions (lb/day) Annual PTE Emissions (tpy)1Controls 1,2Number of Units or Drop Points 1 Water application will be used to control PM emissions on strategic transfer points throughout the crushing and screening operations. Equipment / Activity Source Description Emission Factor (lb/ton) Las Vegas Paving Grantsville Operations Page 11 of 16 Trinity ConsultantsApril 2021 May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 12 of 16 Table C-16. Roads Emissions - PTE Emissions Road Source Controlled Emissions Daily Emissions (lb/day)1 Annual Emissions (tpy)1 PM10 PM2.5 PM10 PM2.5 Unpaved, Chemical Application (Trucks) 20.27 2.03 3.41 0.34 Unpaved, Water Application (Trucks) 0.00 0.00 0.00 0.00 Unpaved, Water Application (Loaders) 8.79 0.88 1.60 0.16 Total 29.06 2.91 5.02 0.50 1 Daily and annual controlled emissions are calculated by applying the controlled emission factor (per UDAQ's control efficiencies) to the vehicular miles traveled per day (paved and unpaved). Daily Emissions (lb/day) = Miles Travelled per Day (VMT/day) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂𝜂) Annual Emissions (tpy) = Miles Travelled per Day (VMT/yr) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂𝜂) May 5, 2021 Las Vegas Paving – Grantsville – Response to UDAQ Page 13 of 16 LVP BACT Cost Analysis - Paving Entrance RoadInputs Table D-1. Las Vegas Paving - Inputs Parameter Value Units Notes Total cost of chemicals used on haul roads 7,413.21 $/year Estimated. Road width 42.65 ft Per Modeling Specifications Road length to pave 3,182 ft Per Modeling Specifications Price of paving 2 $/square foot Per paving quotation provided on 04/19/2021. Estimate does not include preparing road base which could also be added to this cost. The price provided is conservatively low. Total cost of paving 271,452.28 $Calculated Las Vegas Paving - NOI Supplement Page 14 of 16 Grantsville, Utah LVP BACT Cost Analysis - Paving Entrance RoadRoad Emissions Calculations Table D-2. Roads Emissions - Traveling Parameters (Supporting Operations) Empty Single-Trailer Trucks Loaded Single-Trailer Trucks Empty Double-Aluminum Trucks Loaded Double Aluminum Trucks Empty Double Trailer Trucks Loaded Double-Trailer Trucks (tpy)(tons)(tons)(tons)(tons)(tons)(tons)(tons/haul)(tons/haul)(tons/haul)(Miles/haul)(VMT/day)(VMT/yr) Main Haul Road (Entry)1,500,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 118 0.22 26.4 9,635 Main Haul Road (W Loop)750,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 59 0.14 8.1 2,944Main Haul Road (E Loop)750,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 59 0.09 5.5 2,007 Main Haul Road (E Loop Entry)750,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 59 0.15 8.8 3,211 Annual Days Vehicles Operate: Percent Single-Trailer Trucks: Percent Double Aluminum Trucks: Percent Double-Trailer Trucks: Table D-3. Roads Emissions - Emission Factors PM10 PM2.5 Unpaved Chemical Suppressant and Watering 85%0.38 0.04 Paved Pave Road Surface with Sweeping and Watering 90%0.26 0.03 Unpaved Roads where E =Size-specific emission factor (lb/VMT) k, a, b = Constants for equation 1a PM PM10 PM2.5 k =4.9 1.5 0.15 a =0.7 0.9 0.9 b =0.45 0.45 0.45 s =surface material silt content (%) s =6.0 WHT =39.3 Mean haul truck weight (tons) Table D-4. Main Haul Road Emissions - PTE Emissions PM10 PM2.5 PM10 PM2.5Unpaved, Chemical Application (Trucks)18.70 1.87 3.41 0.34 Paved Roads 12.47 1.25 2.28 0.23 Per Las Vegas Paving, 08/25/2020. Controls 1 Control Efficiency (%) Annual Emissions (tpy) = Miles Travelled per Day (VMT/yr) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂𝜂) Road Source Daily Emissions (lb/day)1 Annual Emissions (tpy)1 1 Daily and annual controlled emissions are calculated by applying the controlled emission factor (per UDAQ's control efficiencies) to the vehicular miles traveled per day (paved and unpaved). Daily Emissions (lb/day) = Miles Travelled per Day (VMT/day) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂𝜂) 40% Road Surface Haul Truck Emission Factor 2 (lb/VMT) 1 Emission controls for vehicular traffic on paved and unpaved roads per UDAQ guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015. 2 Emission factors for vehicular traffic on unpaved roads for sand and gravel processing per U.S. EPA AP-42, Section 13.2.2 (Unpaved Roads), November 2006. 30% Double Trailer Haul Haul/Day Total Vehicle Miles Traveled Road Source1 Product Throughput Mean Trailer Weight, Single Trailer (tons)2,3 2 Truck weights per communication with Dan Peresinni, Las Vegas Paving, on August 25, 2020. 3 Maximum Gross Vehicle Weight (GVW) limitation per R909-2-5 Table 2.365 30% Mean Trailer Weight, Double Aluminum (tons)Mean Trailer Weight, Double Trailer (tons)Single Trailer Haul 100% 10% 1 Division of road travel: Daily AnnualTotal Travel Distance per Haul Percent of Potential Annual Throughput Increase via Muckpile Haul Route: Percent of Potential Annual Throughput via Main Haul Route: Double Aluminum Haul Las Vegas Paving - NOI Supplement Page 15 of 16 Grantsville, Utah LVP BACT Cost Analysis - Paving Entrance RoadBACT Economics Analysis Value Units Value Reference PM10 Reduction %33%Calculated PM10 Unpaved Application tpy 3.41 [1] PM10 Paved tpy 2.28 [2] PM10 Reduced by Paving tpy 1.14 Calculated Total Capital Cost $$264,039 [3] Capital Recovery Factor %10.98%[4] Annualized Cost $/yr $28,990 Calculated Admin, Taxes, Insurance $/yr $10,562 [5] Street Sweeping $/yr $17,500 [6] Total Annual Cost $/yr $57,052 Calculated: Sum of Annualized Costs Cost of Control $/ton removed $50,154 Calculated: Cost per ton removed Interest Rate 7%Per EPA Air Pollution Control Cost Manual, Seventh Ed., 2017, Sect. 2.5.2, pg 14-17. Useful life of source 15 Per EPA's 2015 report of Construction and Demolition Debris Generation in the United States, Table 2. Capital Recovery Factor 10.98%Per EPA Air Pollution Control Cost Manual, Seventh Ed., 2017, Sect. 2.5.4.2, pg 22. 5 Admin, Taxes, Insurance assumed to be:4.00%Per EPA Air Pollution Control Cost Manual, Seventh Ed., 2017, Sect. 2.6.5.8, pg 2-35. Capital Implementation Costs Cost of Compliance (Statutory Factor 1) Table D-5. Las Vegas Paving - Haul Roads - Paving Cost Analysis Paving Haul RoadsParameter Potential PM10 Reduction 1 Per potential to Emit Calculation for haul truck travel on unpaved haul roads.2 Per potential to Emit Calculation for haul truck travel on paved haul roads.3 Per quote from competitor, provided on 04/19/2021. 4 Capital Recovery factor (CRF) calculated as follows. Paving minus the cost of chemical application. 6 Salary of operator 50% of time. Salary based on Salary.com for street sweeper operator in Salt Lake City. Las Vegas Paving - NOI Supplement Page 16 of 16 Grantsville, Utah UTAH DIVISION OF AIR QUALITY – NOTICE OF INTENT Las Vegas Paving - Grantsville, Utah New Approval Order Prepared By: TRINITY CONSULTANTS 4525 Wasatch Boulevard Suite 200 Salt Lake City, Utah 84124 (801) 272-3000 Submitted on Behalf of: LAS VEGAS PAVING 4420 S Decatur Blvd Las Vegas, NV 89103 December 2020 Project 204502.0036 Las Vegas Paving | Notice of Intent i TABLE OF CONTENTS EXECUTIVE SUMMARY 1-1 GENERAL INFORMATION 2-1 2.1 Description of LVP’s Installation ............................................................................. 2-1 2.2 Fees ........................................................................................................................ 2-2 2.3 Forms ...................................................................................................................... 2-2 DESCRIPTION OF PROJECT AND PROCESS 3-1 3.1 Description of LVP’s Project .................................................................................... 3-1 3.2 Description of LVP’s Process ................................................................................... 3-1 LVP Crushing and Screening Circuit......................................................................................... 3-1 LVP Wash Circuit................................................................................................................... 3-3 3.3 Site Plan.................................................................................................................. 3-4 EMISSIONS RELATED INFORMATION 4-1 4.1 LVP Crushing and Screening ................................................................................... 4-1 4.2 LVP Material Loading, Unloading and Transfer ........................................................ 4-1 4.3 LVP Stockpiles ........................................................................................................ 4-2 4.4 LVP Bulldozer Use ................................................................................................... 4-2 4.5 LVP Roads ............................................................................................................... 4-3 4.6 LVP Blasting ............................................................................................................ 4-4 4.7 LVP Drilling ............................................................................................................. 4-5 4.8 LVP Source Size Determination ............................................................................... 4-6 BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS 5-1 5.1 LVP Crushing and Screening Aggregate Operations ................................................ 5-1 PM10 and PM2.5 Emissions ....................................................................................................... 5-1 Baghouse/Fabric Filter ................................................................................................................5-1 Cyclone .....................................................................................................................................5-2 Electrostatic Precipitator .............................................................................................................5-2 Enclosures .................................................................................................................................5-2 Management/Operation Practices ................................................................................................5-2 Watering and Material Moisture Content ......................................................................................5-2 Wet Scrubber.............................................................................................................................5-3 5.2 LVP Road Emissions ................................................................................................ 5-4 Fugitive PM10 and PM2.5 Emissions .......................................................................................... 5-4 Chemical Treatment ...................................................................................................................5-4 Reduced Speed ..........................................................................................................................5-5 Road Paving ..............................................................................................................................5-5 Silt Content Reduction ................................................................................................................5-5 Street Sweeping.........................................................................................................................5-5 Watering and Material Moisture Content ......................................................................................5-5 5.3 LVP Drilling and Blasting ......................................................................................... 5-6 NOX and SO2 – Blasting ......................................................................................................... 5-6 PM10 and PM2.5 – Drilling and Blasting ..................................................................................... 5-6 Shroud Application to Drilling Equipment .....................................................................................5-7 Best Management and Operational Practices for Drilling and Blasting ............................................5-7 Las Vegas Paving | Notice of Intent ii Dust Collection System on Drilling Equipment ..............................................................................5-7 Water Spray on Drilling Equipment ..............................................................................................5-7 Drilling and Blasting PM10 and PM2.5 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ........................................................................................................................ 5-8 Drilling and Blasting PM10 and PM2.5 Step 4 – Evaluate Most-Effective Controls and Document Results ........................................................................................................................................... 5-8 Drilling and Blasting PM10 and PM2.5 Step 5 – Select BACT ......................................................... 5-9 5.4 LVP Disturbed Grounds ........................................................................................... 5-9 EMISSION IMPACT ANALYSIS 6-1 6.1 LVP Comparison to Modeling Thresholds ................................................................ 6-1 NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING 7-1 7.1 LVP Offset Applicability ........................................................................................... 7-1 APPLICABLE REGULATIONS 8-1 8.1 General Introduction – LVP Utah Regulations ......................................................... 8-1 UAC R307-101 General Requirements: .................................................................................... 8-4 UAC R307-107 General Requirements: Breakdowns .................................................................. 8-5 UAC R307-150 Emission Inventories: ...................................................................................... 8-5 UAC R307-201 Emission Standards: General Emission Standards: .............................................. 8-5 UAC R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust: .................................. 8-5 UAC R307-307 Road Salting and Sanding ................................................................................ 8-6 UAC R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust: ....................................................................................................................... 8-6 UAC R307-312 Aggregate Processing Operations for PM2.5 Nonattainment Areas: ........................ 8-7 UAC R307-401-8: Approval Order: .......................................................................................... 8-7 UAC R307-410 Permits: Emission Impact Analysis: ................................................................... 8-8 UAC R307-414 Permits: Fees for Approval Orders: ................................................................... 8-8 8.2 LVP Federal Regulations ......................................................................................... 8-8 NSPS Subpart A: General Provisions ........................................................................................ 8-8 NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants ............ 8-8 NESHAP Subpart A (General Provisions) .................................................................................. 8-9 FORMS A EMISSION CALCULATIONS B AIR DISPERSION MODELING PROTOCOL/REPORT C Las Vegas Paving | Notice of Intent 1-1 EXECUTIVE SUMMARY Las Vegas Paving Corp. (LVP) is a heavy civil construction company, that provides a comprehensive list of services from paving to roto-milling, excavating, and recycling. LVP is proposing to operate a permanent aggregate mining, sizing, washing, and sales and distribution operations at Lhoist North America of Arizona, Inc. (Lhoist or LNA) Grantsville Plant, in Grantsville, Utah in Tooele County. The proposed LVP operation is located within an area of Tooele County designated as a non-attainment area of the National Ambient Air Quality Standards (NAAQS) for particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5) and 2015 8-hour ozone. In addition, nitrogen oxide (NOX), sulfur dioxide (SO2), volatile organic compounds (VOCs) and ammonia (NH3) are considered precursors to PM2.5 in Utah. LVP currently operates temporary crushing and screening activities under a temporary relocation of portable equipment permit. LVP is submitting a Notice of Intent (NOI) air quality permit application to the Utah Division of Air Quality (UDAQ) to obtain an air quality Approval Order (AO) to establish a permanent operation in Grantsville, Utah. The NOI application is for mining, crushing, and screening operations, washing, and sales to be conducted only by LVP at the Grantsville Operation. As LVP is proposing to install equipment and operations on LNA’s existing Grantsville Plant Title V facility, an agreement between the two parties establishes that all LVP operations will cease during any 24-hour period (i.e., midnight-to-midnight) that LNA would be operating existing equipment in accordance with its current Title V air operating permit (Permit Number 4500005003).1 This condition was agreed upon based on the current demand for lime products from LNA’s operations. Emissions from the LVP installation and operations will consist of particulate matter (PM) with an aerodynamic diameter of 10 microns or less (PM10) and of filterable PM2.5 fugitives. Fugitive dust controls will be implemented through the use of water and/or chemical suppressant throughout the processes. The facility is proposed to be permitted as a minor source and will be subject to 40 CFR 60, New Source Performance Standards (NSPS) Subpart OOO. Additionally, the emissions triggered an impact analysis included in Appendix C. Emission calculations were performed for the LVP’s Grantsville installation and operations to determine the proposed emissions of criteria pollutants (see Appendix B). The proposed emissions constitute the LVP Grantsville potential to emit (PTE); see Table 4-1. PTE values for criteria pollutants, given in tons per year (tpy) are proposed as follows: PM10 = 21.67, PM2.5 = 3.57, NOX = 8.50, CO = 33.50, SO2 = 0.06, VOC = 0.00, and HAPs = 0.00. The LVP’s Grantsville Operation is proposed to be permitted as a minor source. This NOI application has been developed pursuant Utah Administrative Code (UAC) R307-401-5 and Utah’s application guidance including but 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. 1 Lhoist submitted a renewal application on June 25, 2020 within 180 days prior to the expiration of its Title V air operating permit. Las Vegas Paving | Notice of Intent 2-1 GENERAL INFORMATION 2.1 Description of LVP’s Installation The LVP Grantsville Operation will be a standalone, aggregate mining, crushing, and screening, and sales operation located at 8700 North Ellerbeck Rd. Grantsville, Utah 84029. Although co-located with LNA’s Grantsville Lime Plant, the LVP Grantsville Operation will be separate from the lime plant and mining activities. The LVP Grantsville Operation’s end product is processed aggregate, whereas LNA’s Lime Plant operation mines and processes high-quality dolomitic limestone for various quicklime products sold. For LVP to produce processed aggregate, drilling and blasting operations will be conducted within the mining area to produce aggregate in a manageable size, which will then be transported to the crushing and screening operations. The aggregate crushing and screening operations will consist of two (2) operations; a Crushing and Screening Circuit and a Wash Circuit. This equipment will be separate and standalone from LNA’s existing crushing and screening equipment. The Crushing and Screening Circuit will size and stockpile aggregate that is blasted from the mining area. The Wash Circuit will then wash, screen, and stack a portion of the aggregate processed in the Crushing and Screening Circuit. Aggregate processed by both the Crushing and Screening Circuit and the Wash Circuit will then be sold and removed from the site using haul trucks. Some unprocessed aggregate will be sold and loaded into haul trucks directly after being blasted. In order to prepare an area for mining, stripping of overburden soil and stone is typically required. Some bulldozing emissions have been accounted for in overburden removal, although this activity is anticipated to be minimal for the proposed mining operation. Likewise, bulldozing emissions have been addressed for the reclamation requirements at the site. As addressed in the emission calculations, these emissions are anticipated to be minimal. The LVP Grantsville installation and operation are proposed to be permitted as a minor source (see Table 4- 1). The Standard Industrial Classification (SIC) code for the LVP Grantsville Operation is 1442, Construction Sand and Gravel. The LVP operation is under a separate SIC code than LNA, which is 3274, Lime. Accordingly, they are separate operations. LVP operations are currently under way at the site under a temporary relocation permit, DAQC-1217-20. The AO that LVP is seeking is proposed to be a standalone permit separate and apart from LNA’s AO and Title V operating permit.2 If this operating scenario would change in the future, LVP, on behalf of LNA and LVP, will notify the UDAQ 30 days prior to the change, or submit a revised NOI air permit application. The Universal Transverse Mercator (UTM) coordinates for the LVP Grantsville Operation are as follows: ► Easting: 366,928.49 ► Northing: 4,506,861.12 ► Zone: 12T ► 1984 World Geodetic System All correspondence regarding this submission should be addressed to: Mr. Dan Fitzgerald 4420 S Decatur Blvd Las Vegas, NV 89103 dan.fitzgerald@lasvegaspaving.com Phone: (702) 353-4607 2 LNA currently maintains Title V air operating permit number 4500005003 and Approval Order DAQE-AN0707015-06. Las Vegas Paving | Notice of Intent 2-2 2.2 Fees LVP will use UDAQ’s Payment Portal to prepay the following UDAQ NOI fees associated with this submittal: ► “Application Filing Fee” for the “New Minor Source and Major (not PSD) Source” source type = $500 ► “Application Review Fee” for the “New Minor Source” source type = $2,000 ► Total UDAQ fees = $2,500 LVP understands that the total permit review fee is based on the total actual time spent by UDAQ staff processing this NOI. Upon issuance of the AO, if the total review time is more than twenty (20) standard hours, UDAQ will invoice LVP at $100 per hour for the additional time above twenty (20) standard hours. 2.3 Forms The following UDAQ forms have been included in Appendix A of this application: ► Form 1: Notice of Intent (NOI) Application Checklist ► Form 2: Company Information/Notice of Intent ► Form 3: Process Information ► Form 5: Emissions Information ► Form 15: Rock Crushing and Screening Las Vegas Paving | Notice of Intent 3-1 DESCRIPTION OF PROJECT AND PROCESS 3.1 Description of LVP’s Project LVP is proposing to install an aggregate Crushing and Screening Circuit, a wash plant (Wash Circuit), and aggregate mine at LNA, Grantsville Plant in Grantsville, Utah in Tooele County. The facility is operating under a temporary permit. LVP is submitting this NOI air quality permit application to obtain an AO for the Crushing and Screening Circuit, the Wash Circuit, and the mining of aggregate. Both the Crushing and Screening and Wash Circuits will be powered by line power. Installations and the associated emission sources are as shown below. Site-wide emission projections based on this equipment are detailed in Section 4. Crushing and Screening Circuit ► One (1) Feeder [800 tph]; ► One (1) Horizontal Shaft Impact (HSI) Crusher [400 tph]; ► One (1) Vertical Shaft Impact (VSI) Crusher [400 tph]; ► One (1) Cone Crusher [400 tph]; ► One (1) Primary Triple-deck Screen [800 tph]; ► One (1) Secondary Triple-deck Screen [400 tph]; ► One (1) Tertiary Triple-deck Screen [400 tph]; ► 19 Various Conveyors [≤ 800 tph]; ► Five (5) Stackers [≤ 400 tph]; and ► Five (5) Stockpiles. Wash Circuit ► Three (3) Bin Feeders [400 tph]; ► One (1) Wash Screen [400 tph]; ► One (1) De-Water Screen [400 tph]; ► Six (6) Conveyors [≤ 400 tph]; ► Four (4) Stackers [≤ 400 tph]; ► Four (4) Stockpiles; ► One (1) Sand Screw Washer [400 tph]; and ► One (1) Clarifier [10 tph]. Mining Operations ► Drilling; ► Blasting; ► One (1) Bulldozer [Off-Hwy Equipment]; ► Two (2) Front-end Loaders [Off-Hwy Equipment]; and ► Truck (Future Operations) ► Five (5) Acres of Disturbed Ground. 3.2 Description of LVP’s Process LVP Crushing and Screening Circuit Figure 1 shows a process flow diagram (PFD) of the Crushing and Screening Circuit portion of the crushing and screening operations. Material is blasted from the mine area, wetted (as necessary), and then transported to the primary feeder by front-end loaders and/or haul truck loaded by loaders. Aggregate is fed Las Vegas Paving | Notice of Intent 3-2 into the horizontal shaft impact (HSI) crusher for sizing. Crushed aggregate is then screened through a triple deck screen, which separates the aggregate by size. Some of the screened aggregate is initially stockpiled into two (2) stockpiles, one (1) by a conveyor drop and one (1) by a stacker. Some of the screened aggregate is sent to a vertical shaft impact (VSI) crusher, which further reduces the size of the aggregate, before it is sent to another triple-deck screen. Screened aggregate is then stockpiled into two (2) stockpiles. From the first triple-deck screen, the aggregate that is not stockpiled or sent to the VSI crusher is sent to a cone crusher for further sizing. The cone crusher feeds a triple-deck screen that separates the crushed aggregate into different sizes. Some of the screened material is recycled back into the cone crusher, some is fed into the VSI crusher, and some is stacked into a stockpile with a stacker. This Crushing and Screening Circuit process 90% of the total, 1,500,000 tpy of mined aggregate. The remaining 10% is sold as unprocessed aggregate immediately following blasting and wetting. A portion of the processed aggregate that exits the Crushing and Screening Circuit is then sent to the Wash Circuit, which is shown in Figure 2. Figure 3-1. Crushing and Screening Circuit Process Flow Diagram. Las Vegas Paving | Notice of Intent 3-3 LVP Wash Circuit Figure 2 shows the PFD of the Wash Circuit portion of the crushing and screening operations. Processed material from the Crushing and Screening Circuit is loaded into the bin feeders with front-end loaders, where it is then washed and saturated with water in the wash screen. Sized material is then immediately stockpiled via three (3) separate stackers or it is de-watered by a de-water screen and then stockpiled via a fourth stacker. Some water is removed from the washed aggregate in a sand screw and sent to a clarifier to allow particulate matter to settle. The clarifier sends water and particulate matter to a tailings pond for treatment. Figure 3-2. Wash Circuit Process Flow Diagram. Las Vegas Paving | Notice of Intent 3-4 3.3 Site Plan Figure 3-3, shown below, provides a vicinity map of the LNA Grantsville Plant where LVP is proposing to operate. The property boundaries are shown in green. Figure 3-4 provides a closer view of the site boundaries and shows the haul road route followed by customer haul trucks hauling sold product off site (blue). Figure 3-3. Site Vicinity Las Vegas Paving | Notice of Intent 3-5 Figure 3-4. Property Boundary Close-up and Main Haul Road Las Vegas Paving | Notice of Intent 4-1 EMISSIONS RELATED INFORMATION This section details the methodology used to calculated controlled and uncontrolled emissions for criteria pollutants, greenhouse gases, and hazardous air pollutants (HAPs) associated with each new unit and its associated fugitives as regulated by R307-401-5(2)(b). Additionally, a comparison to major source thresholds is conducted. Detailed emission calculation tables are included in Appendix B. 4.1 LVP Crushing and Screening PM, PM10, and PM2.5 emissions generated from the crushing and screening of aggregate are estimated by multiplying the material throughput by the appropriate emission factor (EF). Uncontrolled EFs for screening and 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: Annual Emissions (tpy)=EF �lbton�× Annual Throughput (tpy)× �ton2,000 lb�× Equipment Quantity Crushing and screening operations are divided into two (2) different circuits, the Crushing and Screening Circuit and the Wash Circuit. The former crushes and screens all 1,500,000 tpy of mined material; the latter reprocesses a portion of that quantity. In the Crushing and Screening Circuit, water sprays will be used in addition to the inherent moisture content of mined material to contain fugitive dust emissions. Aggregate processed in the Wash Circuit will have any potential fugitive dust emissions essentially eliminated by its saturation in water as part of the washing process. It is thus assumed that PM emissions from the Wash Circuit will be negligible. This will be discussed further in Section 5. 4.2 LVP Material Loading, Unloading and Transfer For conveyor transfer points, EFs from AP-42, Section 11.19.2 were used. For Crushing and Screening, dropped material transfer, including stacker drops resulting from the Crushing and Screening Circuit, material loading in both circuits, and material unloading in the Crushing and Screening Circuit, the uncontrolled PM10 and PM2.5 EFs were obtained from the “drop equation” in AP-42, Section 13.2.4 (November 2006). Fugitive dust emissions resulting from Wash Circuit material transfer and unloading are assumed to be negligible due to the washing process and the saturation of the aggregate in water. The equation for all emitting drops is: E =k(0.0032)× �U5�1.3 �M2�1.4 where: E = emission factors (lb/ton) k = particle size multiplier (dimensionless) U = mean wind speed (mph) M = material moisture content (%) Parameter “U” is determined from historical data retrieved from the Salt Lake City Airport in Salt Lake City, UT over the past five (5) years (January 2015 – January 2020). The material moisture content used in this equation for the Crushing and Screening Circuit is based on values previously recommended by UDAQ. Las Vegas Paving | Notice of Intent 4-2 Material throughput for transfer will incorporate the maximum site-wide throughput of 1,500,000 tpy and the appropriate equipment throughput ratio for each process. The annual PM emissions rate for the Crushing and Screening Circuit, given in tpy, is given by the equation below. The EF corresponds to the annual emissions of the criteria pollutant in question at the time of use of the equation; namely, PM10 or PM2.5. Annual Crushing and Screening PTE (tpy)=Potential Annual Throughput (tpy)× EF�lbton�× Number of Units or Drop Points×Conversion�1 ton2,000 lb� It is assumed that the Wash Circuit will not have PM emissions resulting from material transfer due to the washing process and the saturation of its aggregate in water. 4.3 LVP Stockpiles A maximum, total stockpile area was determined based on a conservative engineering estimate of the facility. It is assumed that the total stockpile area will not exceed the reported size on any given day. The maximum pile area is multiplied by an EF, along with several conversion factors, to determine the potential emissions associated with each stockpile. EFs are chosen based on what size the particle is (PM2.5 or PM10), and whether the stockpile is controlled or uncontrolled. All stockpiles will be controlled with water application; stockpiles from the Crushing and Screening Circuit will have water applied via a water spray, whereas stockpiles from the Wash Circuit will be saturated with water from the washing process. Uncontrolled EFs were obtained from AP-42 Fourth Edition Table 8.19.1-1 and AP-42 Appendix B.2 Table B.2-2.3,4 Annual Stockpile Emissions (tpy)=Max.Pile Area (acre)× EF �lbday⋅acre�× Conversion�365 day × 1 ton1 year × 2,000 lb� 4.4 LVP Bulldozer Use PM10, and PM2.5 emissions generated from bulldozing were calculated assuming one (1) bulldozer operating 1,000 hours per year. Bulldozer emissions are multiplied by the EFs given in AP-42, Section 11.9 (October 1998). AP-42 Table 11.9-1 provides the following equations for calculating EFs for total suspended solids (TSP) and PM15 from bulldozing operation: TSP =5.7(s)1.2(M)1.3 PM15 =1.0(s)1.5(M)1.4 where: TSP and PM15 = emission factors (lb/hr) s = material silt content (%), M = material moisture content (%), 3 AP-42 Fourth Edition, Table 8.19.1-1. https://www3.epa.gov/ttn/chief/ap42/oldeditions/4th_edition/ap42_4thed_orig.pdf 4 AP-42 Appendix B.2, Table B.2-2. https://www3.epa.gov/ttn/chief/ap42/appendix/appb-2.pdf Las Vegas Paving | Notice of Intent 4-3 The material silt content was provided by LVP while the material moisture content was suggested by UDAQ. Note that the silt content for bulldozing is lower than those values given for bulldozing of overburden in AP- 42 Section 11.9. This is due to the highly exposed nature of the consolidated calcium carbonate and minimal overburden covering where LVP’s bulldozing operations occur. As AP-42 Section 11.9 only accounts for Western Surface Coal Mining, and as the given silt value is particular to LVP’s location, this value is deemed appropriate for LVP’s bulldozing operations. AP-42 Section 11, Table 11.9-1, provides scaling factors that are applied to TSP and/or PM15 EFs to obtain PM10, and PM2.5 EFs. PM10 and PM2.5 EFs were calculated as follows: ► PM10 = 0.75 x PM15; and ► PM2.5 = 0.105 x TSP. The annual PM emissions generated by bulldozer use are estimated by utilizing the EFs stated above. The EF is multiplied by the maximum annual operating hours, the application of the control efficiency, the number of bulldozers, and the conversion factor of pounds to tons. Annual Dozing Emissions (tpy)=EF �lbhr�× Max.Operating Hours�hryr�× [1 −Control Efficiency (%)]× Number of Dozers×Conversion�1 ton2,000 lb� 4.5 LVP Roads The haul roads at the LVP Grantsville Operation consist solely of unpaved roads. PM10 and PM2.5 emissions were derived using the guidance found in UDAQ’s March 10, 2008 memorandum regarding EFs for unpaved haul roads5. Emissions from these roads were calculated using the following equation: PM =k × �s12�a × �W3�b × D × 1 ton2,000 lb × (1 − η) Where: PM = PM/PM10/PM2.5 emissions (tpy) k = PM/PM10/PM2.5 k-Factor (lb/VMT) s = Average silt content (%) W = Mean vehicle weight (tons) D = Distance traveled (VMT/yr) a = Constant for equation (varies for PM/PM10/PM2.5) (unit less) b = Constant for equation (varies for PM/PM10/PM2.5) (unit less) η = Control efficiency (%) Parameter (W) is determined for each vehicle type by taking the average of the mean loaded and unloaded weights of the different types of vehicles; in this case, tractor trailers, medium front-end loaders, and large front-end loaders.6,7 Parameter (D) is determined by using the product throughput divided by the difference in full and empty vehicle weight to determine the total number of hauls required. This value is multiplied by 5 Per memorandum issued by UDAQ; “Emission Factors for Paved and Unpaved Haul Roads” dated January 12, 2015. 6 National Academy of Sciences, Technologies and Approaches to Reducing the Fuel Consumption of Medium and Heavy-Duty Vehicles, prepublication copy, March 2010, pp. 2-2 and 5-42. Table 5.13. 7 Per UAC R909-2-5. Table 2. Las Vegas Paving | Notice of Intent 4-4 the round-trip distance traveled by the customer trucks. The average silt content used in this equation was given by LVP based on engineering estimates. As a means of control, a watering truck regularly applies water to suppress fugitive PM emissions at the LVP Grantsville Operation for loader travel. In addition, chemical suppressant is applied as necessary to the main haul route. Therefore, using guidance from the memorandum issued by UDAQ regarding emission factors for paved and unpaved haul roads, a control factor of 70% for basic watering and a control factor of 85% chemical suppressant application and watering were used for fugitive emissions related to vehicle traffic. Loader tram lengths are conservatively estimated to be 100 feet per haul, as the majority of loader operations serve to load equipment or vehicles in distinct areas. Emissions were projected based on the Pit’s road layouts, vehicle weights, and hauling capacity. 4.6 LVP Blasting For LVP to produce processed aggregate, drilling and blasting operations will be conducted within the mining area to produce aggregate in a manageable size, which will then be transported via a single conveyor to the crushing and screening operations. The following assumptions were made for blasting operations: ► At most, a blasting event will occur once per day; ► The maximum blasting area per blast is 25,000 square feet (ft2) and was provided per design basis; ► Blasting will occur no nearer than 300 feet from the property boundary; and, ► During a blasting day, hours of operation for the Pit will be reduced from 16 to 14 hours per day, from 4:00AM-8:00PM. The blasting SO2 emission factor is obtained from AP-42 Section 13.3-1. The SO2 EF was developed using a mass balance that assumes a 6% fuel oil mixture with 500 ppm sulfur content, consistent with EPA non- road standards. EFSO2 �lbton�=Sulfur Content (ppm)× %Fuel Oil Mixture × Conversion Both the NOX and CO EF is that of the ANFO blasting agent factor from AP-42 Section 13.3; and PM10 and PM2.5 EFs were based on the blasting PM EF given in AP-42 11.9, where a maximum blasting depth of 70 feet is used, by the following equation: EFPM �lbblast�=1.4 × 10−5 × A(ft2)1.5 Where EFPM is the EF of PM in pounds per blast, and A is the average daily blast area in square feet. Scaling factors were applied to the TSP EF to calculate PM10 and PM2.5 EFs, respectively, per AP-42 Table 11.9, as seen below. It is conservatively assumed that the PM EF is equal to the TSP EF. EFPM10 �lbblast�=EFPM �lbblast�× 0.52 EFPM2.5 �lbblast�=EFPM �lbblast�× 0.03 Where EFPM10 is the EF of PM10 given in pounds per blast and EFPM2.5 is the EF of PM2.5 given in pounds per blast. Note that, as there is only one (1) blast per day, pounds per blast is equivalent to pounds per day. Las Vegas Paving | Notice of Intent 4-5 Daily fugitive dust (PM, PM10, and PM2.5) blasting emissions were calculated using blasting material quantities, which were provided per design basis. Blasting emissions are calculated as follows: Daily Fugitive Dust Emissions �lbsday�=EF �lbsblast�× (1 −%control)× �1 blastday� Where the EF is that of PM, PM10, or PM2.5, whichever is calculated. Annual fugitive dust (PM, PM10, and PM2.5) blasting emissions are given as follows: Annual Emissions (tpy)=Daily Fugitive Dust Emissions �lbsday�× Annual # of Blasts × Conversion �tons ⋅daylb⋅year � Where the Daily Fugitive Dust Emissions are those of PM, PM10, or PM2.5, whichever is calculated. Daily emissions for SO2, NOX, and CO are calculated for each pollutant as follows: Daily Emissions �lbsday�=EF�lbston�× Annual ANFO Use (tpy)× Conversion �yeardays� Annual emissions for SO2, NOX, and CO are calculated for each pollutant as follows: Annual Emissions (tpy)=EF �lbston�× Annual ANFO Use (tpy)× Conversion �tonslb� 4.7 LVP Drilling Drilling operations precede blasting operations, allowing for the placement of explosives beneath the surface of the mine. For drilling emissions, the following assumptions are applied: The drilling PM EF is retrieved from AP-42 Section 11.9, utilizing the conservative drilling PM EF given for overburden material. As no EFs are provided for PM10 and PM2.5 drilling operations, EFs were calculated using the PM10 and PM2.5 to TSP ratios for blasting overburden per AP-42 Section 11.9, where the factor for PM10 is 0.52 and the factor for PM2.5 is 0.03, as shown below; EFPM10 =EFPM15 × 0.52 And EFPM2.5 =EFTSP × 0.03 For the purposes of determining the PM10 and PM2.5 EFs, the EF for PM, PM15, and TSP are considered equivalent. Fugitive dust emissions from drilling operations will be controlled through the use of wet drilling in conjunction with a dust collection (i.e., bin vent or baghouse) system. The EPA reports that baghouses can achieve a 95-99.9% control efficiency, while the National Institute for Occupational Safety and Health (NIOSH) reports that wet drilling achieves a control of fugitive emissions between 86-97.8,9 As both control methods will be used in conjunction one with the other, it is conservatively assumed that the highest control 8 From EPA Air Pollution Control Technology Fact Sheet for baghouses: https://www3.epa.gov/ttnchie1/mkb/documents/ff-pulse.pdf (EPA-452/F-03-025). 9 Summary of NIOSH research completed on dust control methods for surface and underground drilling, Pg 2, December 2008 Las Vegas Paving | Notice of Intent 4-6 efficiency of wet drilling and the average control efficiency of baghouses is achieved for drilling operations (97%). The daily emissions of PM, PM10, and PM2.5 were calculated as follows: Daily Emissions �lbday�=EF �lbhole�× Daily # of Holes �holesday�× (1 −%control) Where both the daily emissions and the EF are those of the pollutant in question (i.e., PM, PM10, or PM2.5). The annual emissions of PM, PM10, and PM2.5 were calculated as follows: Annual Emissions (tpy)=EF�lbhole�× Annual Holes Drilled �holesyear�× (1 −%control)× Conversion �tonlb� Where both the annual emissions and the EF are those of the pollutant in question (i.e., PM, PM10, or PM2.5). 4.8 LVP Source Size Determination The results of criteria pollutant emission calculations done for the LVP Grantsville Operation are compared against major source thresholds in Table 4-1, below. The emissions presented are only for the LVP installation and operation and do not include emissions from LNA’s Grantsville Plant as they are standalone operations under a separate permit. The LVP Grantsville Operation is located in an area of nonattainment for PM2.5 and ozone, but in attainment area for all other pollutants. As previously mentioned, NOX, SO2, VOCs, and ammonia are all precursors of PM2.5. As presented in the table below, none of the proposed emissions at the LVP Grantsville Operation are greater than major source thresholds (i.e., 100 tpy for any criteria pollutant with exception to direct PM2.5 and its precursors for which the major source threshold is 70 tpy, 10 tpy for any HAP, 25 tpy for all HAPs combined, and 100,000 tpy for CO2e). Therefore, the LVP Grantsville Operation will be classified as a minor source. Table 4-1. Proposed LVP Installation and Operations Emissions Versus Major Source Thresholds. Emissions (tpy) PM10 PM2.5 NOX CO SO2 VOC CO2e Crushing and Screening Operations 1.68 0.24 0.00 0.00 0.00 0.00 0.00 Stockpiles and Disturbed Grounds 3.77 1.59 0.00 0.00 0.00 0.00 0.00 Bulldozers and Drops 1.56 0.30 0.00 0.00 0.00 0.00 0.00 Drilling and Blasting 0.74 0.04 8.50 33.50 0.06 0.00 -- Roads 13.91 1.39 0.00 0.00 0.00 0.00 0.00 Proposed Site-Wide Emissions1 21.67 3.57 8.50 33.50 0.06 0.00 0.00 Major Source Thresholds2 100 70 70 100 70 70 100,000 Threshold Exceeded? No No No No No No No 1. Ammonia and HAPs emissions were considered in the LVP Grantsville Operation’s facility-wide emissions; however, these emissions are not applicable, as site power is provided by line power and there are no other sources of ammonia or HAPs. 2. Values are per UAC R307-403-5(2)(b)(ii) Las Vegas Paving | 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 LVP Crushing and Screening Aggregate Operations PM10 and PM2.5 Emissions The LVP Grantsville Operation have two (2) crushing and screening operations for aggregate mined on site; a Crushing and Screening Circuit and a Wash Circuit. The equipment associated with these operations include the following classifications: ► Crushing ► Screening ► Conveyor transfer points ► Stackers ► Stockpiles This BACT analysis has been completed for all material handling operations within the Crushing and Screening Circuit, but only for material loading operations within the Wash Circuit. It is assumed that PM2.5 and PM10 emissions resulting from material transfer within and material unloading from the Wash Circuit are negligible. This is due to the washing process and saturation of aggregate that is processed in the Wash Circuit. 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 January 6, 2020 review of relevant entries in EPA’s RACT/BACT/LAER Clearinghouse (RBLC): ► Baghouse/Fabric Filter ► Cyclone ► Electrostatic Precipitator ► Enclosures ► Management/Operation Practices ► Watering and Material Moisture Content ► Wet Scrubber 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%10. This is generally accomplished through the installation of ductwork, capture hoods, fans, motors, starters, stacks, and other 10 From EPA Air Pollution Control Technology Fact Sheet for baghouses: https://www3.epa.gov/ttnchie1/mkb/documents/ff-pulse.pdf (EPA-452/F-03-025). Las Vegas Paving | Notice of Intent 5-2 stationary equipment. Material at the LVP Grantsville Operation travels through a series of mobile conveyors that extend hundreds of feet. The process requires flexibility to alter on-site stockpile configurations and the location of crushing and screening operations. In other words, the crushing and screening 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 PM2.5 and PM10 removal is likely to achieve between 20% to 70% removal for PM2.5 and 60% to 95% removal for PM10, respectively.11 Like a baghouse, cyclone feasibility is based on routing emissions to a stationary control system via ductwork, capture hoods, fans, etc. This caveat results in a cyclone being technically infeasible for the LVP Grantsville Operation, 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%12. 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.13 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. Although effective, industrial enclosures are permanent structures. As discussed, the LVP Grantsville Operation operate with mobile equipment, which requires flexibility of stockpile configurations. Therefore, enclosures are technically infeasible as control technology. Management/Operation Practices Management practices during material movement, such as minimizing drop heights, will minimize PM2.5 and PM10 emissions and will be implemented in 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 emissions14. This control measure is considered technically feasible for material handling. 11 From Air Pollution Control Technology Fact Sheet for cyclones: https://www3.epa.gov/ttn/catc/dir1/fcyclon.pdf (EPA-452/F- 03-005) 12 From EPA Air Pollution Control Technology Fact Sheet for Crushing and Screening Electrostatic Precipitators: https://www3.epa.gov/ttn/catc/dir1/fdespwpi.pdf (EPA-452/F-03-028) 13 Ibid. 14 From Western Regional Air Partnership, Fugitive Dust Handbook; Executive Summary, p. 3, September 2006. Las Vegas Paving | Notice of Intent 5-3 Wet Scrubber Wet gas scrubbers can achieve 50-95% control of PM emissions15. However, they face the same difficulties in mobile mining facilities 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. Material Handling PM10 and PM2.5 Step 3 – Rank Remaining Control Technologies by Control Effectiveness Table 5-1. Summary of PM10 and PM2.5 for Material Handling. Control Technologies Rank Percent Control Feasibl e 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 U.S. Environmental Protection Agency (EPA) in 200816. 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 rules. EPA’s review of permits and other available information 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. Material Handling PM10 and PM2.5 Step 4 – Evaluate Most Effective Controls and Document Results The BDT control systems identified in EPA’s NSPS evaluations achieve a reduction in PM10 and PM2.5, along with reduction in larger PM particles required to meet NSPS, Subpart OOO emission standards. Additionally, as the LVP Grantsville Operation is located in a PM2.5 Nonattainment Area, it is subject to R307-312 Aggregate Processing Operations. Furthermore, because the selected technologies provide the highest control efficiencies feasible, a cost analysis is not necessary. Therefore, the selected controls are the most effective for the proposed crushing and screening plant. Material Handling PM10 and PM2.5 Step 5 – Select BACT LVP proposes that BACT consists of restricting fugitive emissions to opacity standards set forth by NSPS Subpart OOO, Standards of Performance for NMPP, namely 7% opacity for belt conveyors, transfer points, 15 From EPA Air Pollution Control Technology Fact Sheet for Packed-Bed/Packed-Tower Wet Scrubber (EPA-452/F-03-015) 16 U.S. EPA revised NSPS, Subpart OOO in 73 Federal Register (FR) 78, April 22, 2008. Las Vegas Paving | Notice of Intent 5-4 screens, storage bins, and enclosed trucks; and 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; ► Application of water sprays to crushing operations; and ► Moisture content carryover during transportation on conveyors. Furthermore, management and best operational practices will be applied. These include, but are not limited to: ► Minimizing drop distance for material transfers; and ► Periodic inspections of material handling. 5.2 LVP Road Emissions Fugitive PM10 and PM2.5 Emissions There is one (1) unpaved, primary entrance road for offsite shipments which travels from the exterior of the property to the scale and loading areas. Two (2) unpaved tram routes for front-end loader movement are also accounted for. Fugitive emissions are generated from road use by customer trucks, support vehicles, and heavy equipment used in mining operations. Fugitive dust from production activities such as loading, unloading, storage of bulk materials, and material transporting may cause PM to be deposited on plant roads. Vehicular traffic in these areas may then disturb dust deposited on plant roads, resulting in more PM emissions. Roads PM10 and PM2.5 Step 1 - Identify All Control Technologies Control technologies identified for PM10 and PM2.5 emissions from roads are as follows, based on May 6, 2020 review of relevant entries in EPA’s RBLC: ► Chemical Treatment (Applicable to Unpaved Roads Only) ► Reduced Speed (Applicable to Unpaved Roads Only) ► Road Paving (Applicable to Unpaved Roads Only) ► Silt Content Reduction (Applicable to Unpaved Roads Only) ► Street Sweeping (Applicable to Paved Roads Only) ► Watering and Material Moisture Content Roads PM10 and PM2.5 Step 2 – Eliminate Technically Infeasible Options Chemical Treatment Applying chemical treatment to unpaved roads binds surface particles together and inhibits fugitive emissions by up to 85%17. This is feasible for haul roads, but not for paths on which bulldozers and/or front-end loaders operate. Chemical treatment applied in such areas may contaminate mined aggregate and cause technical problems during the crushing and screening process. Furthermore, product stockpiles may 17 UDAQ Guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015 Las Vegas Paving | Notice of Intent 5-5 become contaminated and the effects of chemical treatment are reduced due to the frequent turning of front-end loaders while loading customer haul trucks. Reduced Speed Reducing the speed on plant roads reduces the generation of fugitive dust. The Western Regional Air Partnership (WRAP) Fugitive Dust Handbook reports that a 57% reduction in emissions occurs when speeds are restricted to less than fifteen miles per hour (15 mph), and a 44% reduction in emissions when speeds are restricted to 25 mph18. This control method is considered technically feasible. Road Paving Paving provides effective controls on fugitive road emissions. Guidelines from UDAQ indicate that paved roadways, combined with sweeping and watering, provide a 90% control efficiency for particulate emissions19. Paving roads is not technically feasible near dynamic mining operations at the LVP Grantsville Operation, as route configurations are subject to change according to mine development. Furthermore, emissions from paved roads in disrepair due to impact from heavy equipment are higher than properly treated unpaved roads. Similarly, the benefits from applying chemical dust suppressants are negated in areas where trucks turn and tracked equipment is used because those activities cause chemical dust suppressants to deteriorate more quickly than is useful. The main haul road, which is used for product export, will remain unpaved throughout the life of the mine. This is due to the frequent travel of high volume, heavy-weight equipment on the road. Travel of this sort rapidly deteriorates paved road surfaces, which is an accepted, significant concern for paved roads. If the main haul road were paved, the frequent re-paving and road construction that would be necessary due to its regular deterioration would hinder haul truck travel and subsequently obstruct the selling of processed aggregate. The application of chemical suppressant and regular watering that will be done on the main haul road will achieve nearly the same control as if the roads were paved.20 As such, paving of the main haul road is considered technically infeasible. Silt Content Reduction Silt content reduction involves covering unpaved road surfaces with material that has a lower silt content than what is naturally present, e.g., gravel or slag. Combined with watering, this method achieves up to 75% control efficiency21. This is considered technically feasible and will be applied where appropriate. Street Sweeping Street sweeping is a method of PM control that utilizes a mobile street sweeping unit to remove loose material from paved road surfaces. This control technology is technically infeasible due to the stated inability to adequately maintain paved roads at the LVP Grantsville Operation. Watering and Material Moisture Content Watering of haul roads reduces fugitive PM2.5 and PM10 emissions by binding soil particles together, preventing their being picked up by wind or vehicles. Water is applied on a scheduled basis and supplemented as needed based on driver observation of dust conditions. Basic watering results in a dust 18 Western Regional Air Partnership, Fugitive Dust Handbook. Executive Summary, p. 3, September 2006. 19 UDAQ Guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015 20 Western Regional Air Partnership (WRAP) Fugitive Dust Handbook, 2006. 21 UDAQ Guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015 Las Vegas Paving | Notice of Intent 5-6 control efficiency of up to 70%22. This control technology is considered technically feasible and will be used at the LVP Grantsville Operation. Roads PM10 and PM2.5 Step 3 – Rank Remaining Control Technologies by Control Effectiveness Table 5-2. Fugitive PM10 and PM2.5 Control Technologies and Efficiencies for Roads. Control Method Control Efficiency (%) Chemical Suppressant and Watering 85 Basic Watering and Road Base 75 Basic Watering 70 Reduced Speed 44 For the technologies applied to unpaved roads, any grouping of silt-content reduction, watering, and speed reduction can be applied together, as they are not competitive. Note that variable control technologies include: ► Silt Content Reduction: Varies with current, uncontrolled road conditions, per AP-42 13.2.2. Roads PM10 and PM2.5 Step 4 – Evaluate Most Effective Controls and Document Results Since the highest available controls include implementing chemical suppression, road watering, speed reduction, and silt content reduction on unpaved roads, no detailed economic, energetic, or environmental impact evaluations were conducted. Roads PM10 and PM2.5 Step 5 – Select BACT Fugitive road emissions are generated from road use by customer trucks, employee vehicles, and front-end loaders. The haul roads at the LVP Grantsville Operation are unpaved. BACT for these permanent haul roads is considered to consist of chemical application, watering, and silt-content reduction to minimize fugitives as practical. BACT for non-permanent roads – e.g., roads in proximity to the mining face – is considered to consist of watering and silt content reduction to minimize fugitive dust. The LVP Grantsville Operation will implement these controls. 5.3 LVP Drilling and Blasting NOX and SO2 – Blasting Blasting operations incorporate combustion of compounds containing ammonium nitrate in order to pulverize material in the mining area. Blasting operations will produce fugitive NOX and SO2 emissions. However, there are no control technologies that can be used to mitigate NOX and SO2 emissions associated with blasting. As such, no BACT analysis has been conducted for these emissions. PM10 and PM2.5 – Drilling and Blasting Drilling and blasting methods loosen raw materials in the mining area in order to access the desired aggregate embedded in the ground. These activities create fugitive dust. 22 Ibid. Las Vegas Paving | Notice of Intent 5-7 Drilling and Blasting PM10 and PM2.5 Step 1 – Identify All Control Technologies Control technologies identified for PM10 and PM2.5 emissions from drilling and blasting have been identified using the following sources: ► Utah Division of Air Quality Fugitive Dust Control Plans (Revised 1/13) BMP 02; ► Dust Control Handbook for Industrial Minerals Mining and Processing, NIOSH, January 2012 ► WRAP Fugitive Dust Handbook, Countess Environmental, September 2006 The following methods have been identified as control technologies to reduce fugitive dust emissions from drilling and blasting: ► Apply a shroud to the drilling equipment; ► Apply best management and operational practices for drilling and blasting; ► Install a dust collection system on drilling equipment; and ► Install a water spray on drilling equipment, i.e., use of wet drilling practices. Drilling and Blasting PM10 and PM2.5 Step 2 – Eliminate Technically Infeasible Options Shroud Application to Drilling Equipment Installing a shroud at the drilling location is one common method for controlling fugitive dust emissions from drilling operations. Shrouds can vary in shape (rectangular vs. circular) and complexity in order to adapt to mining operations. When installed and replaced correctly, shrouds can control 88% of fugitive dust emissions.23 Using a shroud during drilling operations is technically feasible. Best Management and Operational Practices for Drilling and Blasting Best management and operational practices for blasting operations includes the following: using sufficient stem length and refraining from blasting operations during high winds.24 Best management and operational practices for drilling operations includes conducting routine inspections of drilling control technologies. This may include repairing and/or replacing shrouds when they become damaged. Best management and operational practices for controlling both drilling and blasting operations are technically feasible. Dust Collection System on Drilling Equipment Dust control is often accomplished using a fan-powered dust-collection system. For drilling operations, these collection systems are mounted on the drill. If properly maintained, these systems can be up to 99% efficient.25 For drilling operations, installing a dust collection system is technically feasible. Water Spray on Drilling Equipment Fugitive emissions for drilling equipment can be significantly reduced through wet drilling, using a water spray which provides continuous water flow during drilling operations. With a high volumetric flow rate, dust control efficiencies often attain 86-97%. However, when water flow rates approach one (1) gallon per minute (gpm) operational problems such as drill bit plugging, and drill rotation binding often occur. Dust 23 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 137. NIOSH, March, 2019 24 The Office of Surface Mining, U.S. Department of Interior, Controlling the Adverse Effects of Blasting, Methods to Reduce Airblast 25 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 124. NIOSH, March, 2019 Las Vegas Paving | Notice of Intent 5-8 control efficiencies are reduced when water flow rates are reduced.26 Watering is technically feasible for drilling operations. Drilling and Blasting PM10 and PM2.5 Step 3 – Rank Remaining Control Technologies by Control Effectiveness The most-effective control technologies for fugitive dust generated from drilling operations are provided in the table below, according to effectiveness. Table 5-3. Summary of PM2.5 and PM10 Control Methods for Drilling Control Technologies Rank Percent Control Feasible BACT Dust Collection System27 1 95-99.9% Yes Yes Using Water Spray (Wet Drilling)28 2 86-97% Yes Yes Shroud Use29 3 63-88% Yes Yes Best Management and Operational Practices 4 Varies Yes Yes The most-effective control technologies for fugitive dust generated from blasting operations are provided in the table below, according to effectiveness. Table 5-4. Summary of PM2.5 and PM10 Control Techniques for Drilling and Blasting Control Technologies Rank Percent Control Feasible BACT Best Management and Operational Practices 5 Varies Yes Yes Drilling and Blasting PM10 and PM2.5 Step 4 – Evaluate Most-Effective Controls and Document Results For drilling operations, dust collection systems such as baghouses provide the highest degree of PM control, from 95 to 99.9%.30 Wet drilling through a water spray can provide up to 97% control efficiency. Implementing a shroud can control 88% of PM emissions. For blasting operations, good management practices provide the highest reduction in PM emissions. These practices include preventing blasting operations during high wind events. 26 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 80-82. NIOSH, January, 2012 27 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 124. NIOSH, March, 2019 28 Summary of NIOSH Research Completed on Dust Control Methods for Surface and Underground Drilling, Pg. 2, December 2008 29 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 137. NIOSH, March, 2019 30 From EPA Air Pollution Control Technology Fact Sheet for baghouses: https://www3.epa.gov/ttnchie1/mkb/documents/ff-pulse.pdf (EPA-452/F-03-025). Las Vegas Paving | Notice of Intent 5-9 Drilling and Blasting PM10 and PM2.5 Step 5 – Select BACT BACT for drilling will be accomplished through adhering to best management practices, and using a dust collection system or wet drilling practices proposed as BACT for drilling operations. BACT for blasting will be accomplished by applying best management practices, minimizing the blasting area, and limiting the size of blasting operations closer than 300 feet from the property boundary, and avoiding blasting operations during high winds. Additionally, blasting and drilling are events will not occur on the same day. These practices will mitigate fugitive dust from blasting operations. 5.4 LVP Disturbed Grounds Fugitive PM10 and PM2.5 emissions are generated through wind disturbance on exposed aggregate. Various operational practices can be considered for BACT. One option is to spray water on all areas not covered with vegetation or synthetic material. The large volume of exposed area at the LVP Grantsville Operation would require extensive amounts of water. Due to the constant movement of aggregate equipment and working areas, the infrastructure required for the sprays is not technically feasible. Therefore, this option is not considered BACT. Additionally, the aggregate being mined at the Grantsville pit is hard-rock and not weathered material. As a result, the amount of fines on the mine surface will be minimal. Best management practices and maintaining established opacity limitations are considered BACT to control fugitive dust from disturbed grounds on site. Las Vegas Paving | Notice of Intent 6-1 EMISSION IMPACT ANALYSIS 6.1 LVP Comparison to Modeling Thresholds Table 6-1 compares criteria pollutant total proposed emissions to applicable modeling thresholds contained in R307-403-4 through 7, and R307-410-4. Table 6-1. LVP Equipment and Operations Emissions and Comparison to Major Source and Modeling Thresholds. Description Potential to Emit (tpy)1,2 PM10 PM2.5 NOX CO SO2 VOC CO2e Crushing and Screening Operations 1.68 0.24 0.00 0.00 0.00 0.00 0.00 Stockpiles and Disturbed Grounds 3.77 1.59 0.00 0.00 0.00 0.00 0.00 Bulldozers and Drops 1.56 0.30 0.00 0.00 0.00 0.00 0.00 Drilling and Blasting 0.74 0.04 8.50 33.50 0.06 0.00 - Roads 13.91 1.39 0.00 0.00 0.00 0.00 0.00 Proposed Site-Wide Emissions 21.67 3.57 8.50 33.50 0.06 0.00 0.00 Modeling Limits3 5/15 None 40 100 40 None None Threshold Exceeded? Yes No No No No No No Major Source Thresholds4 100 70 70 100 70 70 100,000 Threshold Exceeded? No No No No No No No 1. The LVP Grantsville Operation is located in Tooele County, which is in serious nonattainment for PM2.5. Values are per UAC R307-403-5(2)(b)(ii). 2. Ammonia and HAPs were considered in the LVP Grantsville Operation’s facility-wide emissions; however, these emissions are not applicable, as site power is provided by line power. 3. Per Emissions Impact Assessment Guidelines published by UDAQ. 4. Values are per UAC R307-403-5(2)(b)(ii) The air dispersion modeling analysis will be performed to demonstrate that the impacts of the site-wide PM10 emissions from the LVP Grantsville Operation will not exceed the NAAQS. As a supplement to this application, LVP will submit a modeling protocol and an air dispersion modeling analysis for PM10 24-hour NAAQS. If this operating scenario would change in the future, LVP, on behalf of LNA and LVP, will notify the UDAQ 30 days prior to the change, or submit a revised NOI air permit application. Because the total emission increases at the LVP Grantsville Operation do not constitute a major source, a visibility analysis is not required.31 31 R307-406-2 Las Vegas Paving | Notice of Intent 7-1 NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING Per UDAQ’s Form 1 for NOI and R307-420 and R307-421, this section should include offset requirements for nonattainment and maintenance areas. The LVP Grantsville Operation is located within a PM2.5 nonattainment area. 7.1 LVP 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 R307-403-5(2)(b) as “any stationary 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, VOCs, and ammonia].” The LVP Grantsville Operation 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. The LVP Grantsville Operation is located in Tooele County, and does not impact either Salt Lake County or Utah County. The LVP Grantsville Operation 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 the LVP Grantsville Operation is located in Tooele County, ozone offsets are not applicable. Furthermore, "significant" means, for the purposes of determining what is a significant emission increase or a significant net emission increase and therefore a major modification, a rate of emissions that would equal or exceed any of the following rates: (1) for volatile organic compounds, 25 tons per year, (2) for nitrogen oxides, 40 tons per year. The PTE of the LVP Grantsville Operation presented in Appendix B is less than 25 tpy of VOCs, solidifying the inapplicability of ozone offsets established in R307-420-3. Las Vegas Paving | Notice of Intent 8-1 APPLICABLE REGULATIONS 8.1 General Introduction – LVP Utah Regulations LVP has evaluated the applicability of each rule under the Utah Administrative Code (UAC) Title R307. Rules generally applicable to the LVP Grantsville Operation; specifically, but not associated with one specific proposed change will not be discussed in this section, while all other applicable rules associated with the project described in this NOI 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 1 Conflict of Interest X R307-105 1 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 1 General Requirements: Tax Exemption for Air Pollution Control Equipment X R307-121 2 General Requirements: Clean Air and Efficient Vehicle Tax Credit X R307-122 2 General Requirements: Heavy Duty Vehicle Tax Credit X R307-123 2 General Requirements: Clean Fuels and Vehicle Technology Grant and Loan Program X R307-124 2 General Requirements: Conversion to Alternative Fuel Grant Program X R307-125 2 Clean Air Retrofit, Replacement, and Off-Road Technology Program X R307-130 1 General Penalty Policy X R307-135 Enforcement Policy for Asbestos Hazard Emergency Response Act X R307-150 Emission Inventories X R307-165 Emission Testing X R307-170 Continuous Emission Monitoring Program X R307-201 Emission Standards: General Emission Standards X Las Vegas Paving | Notice of Intent 8-2 Reference Regulation Name Applicability Yes No R307-202 Emission Standards: General Burning X R307-203 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 1 Standards of Performance for New Stationary Sources X R307-214 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 Las Vegas Paving | 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 Las Vegas Paving | 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 1 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 2 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 the LVP Grantsville Operation; however, this rule is not specific to operational compliance requirements, and is therefore not discussed in the enclosed NOI. 2. At the time of submission of this NOI, this rule does not apply. 3. Applicable NSPS and NESHAP regulations are detailed under appropriate project headings UAC R307-101 General Requirements: The LVP Grantsville Operation will comply and conform to the definitions, terms, abbreviations, and references used in the UAC R307-101 and 40 CFR. Las Vegas Paving | Notice of Intent 8-5 UAC R307-107 General Requirements: Breakdowns The LVP Grantsville Operation 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. UAC R307-150 Emission Inventories: For every third year, the LVP Grantsville Operation 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. UAC R307-201 Emission Standards: General Emission Standards: All rules applicable to the LVP Grantsville Operation are incorporated by reference from 40 CFR Part 60. Applicability and requirements for these rules are outlined in Section I.2 of this submittal. UAC R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust: UAC R307-205-4 Emission Standards – Fugitive Emissions The LVP Grantsville Operation is located in Tooele County, which is a nonattainment area for PM2.5. 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. The LVP Grantsville Operation 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 The LVP Grantsville Operation 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 Las Vegas Paving | Notice of Intent 8-6 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. The LVP Grantsville Operation will comply with minimization techniques described in R307-205-7. The LVP Grantsville Operation will also engage in various techniques aimed to reduce fugitive dust from mining activities. Techniques include, but are not limited to: water controls, maintaining both paved and unpaved roads, restricting the speed of vehicles in and around mining operations, and control of dust from storage piles. UAC R307-307 Road Salting and Sanding UAC R307-307-1 Road Salting and Sanding – Applicability All persons who apply salt or abrasives such as crushed slag and sand to roads in PM10 and PM2.5 nonattainment and maintenance areas as defined in 40 CFR 81.345 (July 1, 2011) and geographically described as all regions of Davis, Salt Lake, and Utah counties. UAC R307-307-2 Road Salting and Sanding – Records (1) Any person who applies salt or abrasives such as crushed slag and sand to roads in PM10 and PM2.5 nonattainment and maintenance areas shall maintain records of the material applied. (a) For salt, the records shall include the quantity applied, the percent by weight of insoluble solids in the salt, and the percentage of the material that is sodium chloride (NaCl), magnesium chloride (MgCl2), calcium chloride (CaCl2), or potassium chloride (KCl). (b) For abrasives such as sand or crushed slag, the records shall include the quantity applied and the percent by weight of fine material which passes the number 200 sieve in a standard gradation analysis. (2) All records shall be maintained for a period of at least two years, and the records shall be made available to the director or his designated representative upon request. UAC R307-307-3 Road Salting and Sanding – Content (1) After October 1, 1993, any salt applied to roads in Salt Lake, Davis, or Utah counties shall be at least 92% NaCl, MgCl2, CaCl2, and/or KCl. (2) After January 1, 2014, any salt applied to roads in all other areas specified in R307-307-1 shall be no less than 92% by weight NaCl, MgCl2, CaCl2, and/or KCl. The LVP Grantsville Operation is located in a PM2.5 nonattainment area. As a result, LVP will ensure that any salt or crushed slag will be no less than 92% by weight NaCl, MgCl2, CaCl2, and/or KCl on its roads. 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 Las Vegas Paving | Notice of Intent 8-7 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. The LVP Grantsville Operation will minimize fugitive dust created from the construction and maintenance of the existing paved road to the extent both practical and possible. 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% The LVP Grantsville Operation will comply with visible emissions for aggregate processing operations described in R307-312. 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, 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 proposed installation 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) R307-420, Permits: Ozone Offset Requirements in Davis and Salt Lake Counties; (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. Las Vegas Paving | Notice of Intent 8-8 (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. The LVP Grantsville Operation 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. UAC R307-410 Permits: Emission Impact Analysis: Emission impacts associated with the LVP Grantsville Operation are addressed in Section 9 of this submittal. UAC R307-414 Permits: Fees for Approval Orders: Fees associated with the submission of this NOI are addressed in Section 2 of this submittal. 8.2 LVP Federal Regulations 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 ► General recordkeeping requirements ► Semiannual monitoring system and/or excess emission reports NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants NSPS Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants, 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: ► Crusher ► Screening Operation ► Belt Conveyor ► 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 Las Vegas Paving | Notice of Intent 8-9 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. LVP 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 NESHAP Subpart A (General Provisions) All affected sources are subject to the general provisions of Part 63 NESHAP Subpart A unless specifically excluded by the source-specific NESHAP. These provisions include initial notification and performance testing, recordkeeping, and monitoring requirements for all other subparts as applicable. Las Vegas Paving | Notice of Intent A FORMS Form 1 Date December 2020 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] $NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements %Alternative site analysis, Major source ownership compliance certification Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406] %Visibility impact analysis, Class I area impact 6LJQDWXUHRQ$SSOLFDWLRQ 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. Las Vegas Paving ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ 1of 1 Form 2 Company Information/Notice of Intent (NOI) Utah Division of Air Quality New Source Review Section Application for: Ƒ Initial Approval Order Ƒ Approval Order Modification General Owner and Source Information 1.Company name and mailing address: ____________________________ ____________________________ ____________________________Phone No.:Fax No.: 2. Company** contact for environmental matters: ____________________________ Phone no.: Email:_______________________BBBBBBBBBBBBBBBBBBBBB ** Company contact only; consultant or independent contractor contact information can be provided in a cover letter 3. Source name and physical address (if different fromabove):__________________BBBB _____________________B ______________________Phone no.: Fax no.: 4. Source Property Universal Transverse Mercatorcoordinates (UTM), including System and Datum: UTM:BBBBBBBBBBBBBBBBBBBBBBBBB X:_____B_________BBBBBBBBBBBB Y:_________BBBBBBBBBBBBBBBBBB 5. The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)__ __ __ __ 7. If request for modification, AO# to be modified: DAQE #__________________BBBBBBBBBBDATED: ____/____/____ 8. Brief (50 words or less) description of process. Electronic NOI9. A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black (jlblack@utah.gov) or AlanHumpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal Electronic Copy Submittal Ƒ %RWK Authorization/Signature I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on reasonable inquiry made by me and to the best of my knowledge and belief. Signature: Title: _______________________________________Name (Type or print) Telephone Number: Email: Date: Date: December 2020 ✔ Las Vegas Paving Dan Fitzgerald 4420 S Decatur Blvd (702)353-4607 dan.fitzgerald@lasvegaspaving.comLas Vegas, NV 89103 (702)353-4607 Grantsville Pit Zone 12T8700 N Ellerbeck Rd. 366,928.5Grantsville, UT 84029 4,506,861.1 Tooele 1 4 42 NA Crushing and screening operations to process aggregate mined at the site. ✔ Dan Peressini 12.08.2020 702.236.3520 DanP@RiverBasin. net Division Manager Page 1 of 1 Form 3 Company____________________ Process Information Site________________________ Utah Division of Air Quality New Source Review Section Process Information)RU1HZ3HUPLW21/< 1. Name of process:2. End product of this process: 3. Process Description*: Operating Data 4. Maximum operating schedule: __________hrs/day __________days/week __________weeks/year 5. Percent annual production by quarter: Winter ________ Spring _______ Summer ________ Fall _______ 6. Maximum Hourly production (indicate units.): _____TBD_______ 7. 8. Type of operation: Continuous Batch Intermittent 9. If batch, indicate minutes per cycle ________ Minutes between cycles ________ 10. Materials and quantities used in process.* Material Maximum Annual Quantity (indicate units) 11.Process-Emitting Units with pollution control equipment* Emitting Unit(s)Capacity(s)Manufacture Date(s) *If additional space is required, please create a spreadsheet or Word processing document and attach to form. Las Vegas Paving Grantsville Pit Crushing and Screening Processed Aggregate Crushing and screening operations to process aggregate mined at thesite. A wash plant washes a portion of the processed aggregate.Processed aggregate, washed and unwashed, is stacked and sold. 16 7 52 Maximum annual production (indicate units): ______TBD_________(tpy) ✔ Aggregate 1,500,000 (tpy) ANFO 1,000 (tpy) Crushing and Screening (Dry Circuit)400 (tph) Crushing and Screening (Wash Circuit)400 (tph) Page 1 of 1 Company___________________________ 6LWH_____________________________ Form Emissions Information Criteria/GHGs/ HAP’s 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 NOxSO2CO 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 4FF"UUBDIFEGPS &NJTTJPO*OGPSNBUJPO 4FF"UUBDIFEGPS &NJTTJPO*OGPSNBUJPO 4FF"UUBDIFEGPS &NJTTJPO*OGPSNBUJPO Las Vegas Paving Grantsville Pit Utah Division of Air Quality Date December 2020 New Source Review Section Company_____________________________Site ___ Form 15 Aggregate Processing Operations Equipment Information 1. Check the appropriate crushing operations used inyour process: Type of Unit: Crushing and Screening Manufacturer/ModelDesign Capacity: 400 tphDate Manufactured: TBDPrimary 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) Triple_________________________________ 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: 1.5 MM __ tons/yr BD ___ tons/hr TBDTBD__ hrs/yr ____ hrs/day 5. Water sprays used on storage piles? _ Yes _ No 6a. Number of conveyor belt transfer and drop points: 28 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 outthis 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, additionalinformation may be requested for the engineering review. Instructions1. 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 Las Vegas Paving Grantsville Pit ✔ ✔✔ ✔✔ ✔✔ ✔✔ Aggregate is wetted prior to its introduction to the crushing and screening process. It is further wetted at strategic locations in the process. Moisture carryover mitigates dust. T ✔ Storage pile size:_________________ Sprayed as necessary to maintain opacity limits. Las Vegas Paving | Notice of Intent B EMISSION CALCULATIONS Description Value Unit Potential Daily Operating Hours 16 (hr/day) Desired Annual Operating Days 365 (day/yr) Proposed Annual Unprocessed Throughput 150,000 (tpy) Proposed Annual Processed Throughput 1,350,000 (tpy) Total Proposed Annual Throughput 1,500,000 (tpy) Throughput Percent Maximum Hourly Limit Potential Annual Throughput Potential Total Annual Throughput (%)(tph)(tpy/unit)(tpy) Primary HSI Crusher 1 Dry Circuit 40.00%400 600,000 600,000 Secondary Cone Crusher 1 Dry Circuit 35.00%250 525,000 525,000 Tertiary VSI Crusher 1 Dry Circuit 18.75%170 281,250 281,250 Feeder 1 Dry Circuit 90.00%800 1,350,000 1,350,000 Bin Feeders 3 Wash Circuit 45.00%400 225,000 675,000 Primary Screening 1 Dry Circuit 90.00%800 1,350,000 1,350,000 Secondary Screening 1 Dry Circuit 35.00%250 525,000 525,000 Tertiary Screening 1 Dry Circuit 18.75%170 281,250 281,250 Wash Screen 1 Wash Circuit 45.00%400 675,000 675,000 Conveyors (800)3 Dry Circuit 90.00%800 1,350,000 4,050,000 Conveyors (400, 50%)2 Dry Circuit 50.00%400 750,000 1,500,000 Conveyor (400, 45%)1 Wash Circuit 45.00%400 675,000 675,000 Conveyors (250)2 Dry Circuit 35.00%250 525,000 1,050,000 Conveyors (200)2 Dry Circuit 25.00%200 375,000 750,000 Conveyors (170)2 Dry Circuit 18.75%170 281,250 562,500 Conveyor (160)1 Dry Circuit 17.50%160 262,500 262,500 Conveyor (150)1 Wash Circuit 22.50%150 337,500 337,500 Conveyors (140)2 Wash Circuit 20.25%140 303,750 607,500 Conveyor (120)1 Dry Circuit 15.00%120 225,000 225,000 Conveyors (80, 10%)2 Dry Circuit 10.00%80 150,000 300,000 Conveyors (80, 9.375%)2 Dry Circuit 9.375%80 140,625 281,250 Conveyor (60)1 Wash Circuit 11.25%60 168,750 168,750 Conveyor (40, 11.25%)1 Wash Circuit 11.25%40 168,750 168,750 Conveyor (40, 8.75%)1 Dry Circuit 8.75%40 131,250 131,250 Conveyor (40, 4.6875%)1 Dry Circuit 4.69%40 70,313 70,313 Future Conveyors 3 Mine 90.00%800 1,350,000 4,050,000 Stacker A 1 Dry Circuit 50.00%400 750,000 750,000 Stacker C 1 Dry Circuit 17.50%160 262,500 262,500 Stacker D 1 Dry Circuit 4.69%40 70,313 70,313 Stacker E 1 Dry Circuit 9.38%80 140,625 140,625 Stacker F 1 Wash Circuit 20.25%140 303,750 303,750 Stacker G 1 Wash Circuit 11.25%60 168,750 168,750 Stacker H 1 Wash Circuit 22.50%150 337,500 337,500 Stacker I 1 Wash Circuit 11.25%40 168,750 168,750 Sand Screw 1 Wash Circuit 22.50%150 337,500 337,500 Dewater Screen 1 Wash Circuit 20.25%140 303,750 303,750 Clarifier 1 Wash Circuit 2.25%10 33,750 33,750 Loader to Feeder 1 Dry Circuit 90.00%800 1,350,000 1,350,000 Loader to Wash Bins 1 Wash Circuit 45.00%400 675,000 675,000 Loader to Haul Trucks (Final Product)1 Stockpile 90.00%800 1,350,000 1,350,000 Loader to Haul Trucks (Muckpile)1 Mine 10.00%800 150,000 150,000 Location1 1. It is assumed that all Wash Circuit equipment (excepting Bin Feeders) will have no fugitive dust emissions due to their water-saturated environment. Table C-2. Equipment List Table C-1. Operating Parameters Type of Equipment / Activities Number of Units or Drop Points Las Vegas Paving Grantsville Operations Page 1 of 11 Trinity Consultants December 2020 Table C-3. Stockpiles and Disturbed Grounds Type of Equipment / Activities1 Quantity Maximum Area (Acres) Stockpile A 1 0.1 Stockpile B 1 0.1 Stockpile C 1 0.1 Stockpile D 1 0.1 Stockpile E 1 0.1 Stockpile F 1 0.1 Stockpile G 1 0.1 Stockpile H 1 0.1 Stockpile I 1 0.1 Stockpile J 1 3.3 Stockpile K 1 3.3 Disturbed Area 1 5.0 Total -- 12.50 Maximum Annual Operating Hours (hr/yr/unit) Front-End Loaders 2 4,000 Bulldozers 1 1,000 Parameter1 Quantity Unit Main Haul Route 1.01 (miles) Paved Main Haul Route 0.00 (miles) Main Haul Route 1.01 (miles) Total Mine Haul Route 0.34 (miles) Paved Mine Haul Route 0.00 (miles) Muckpile Haul Route 0.34 (miles) Loadout Tram Length 0.11 (miles) Muckpile/Quarry Tram Length 0.02 (miles) Empty Single-Trailer Trucks 17.00 (tons) Loaded Single-Trailer Trucks 40.00 (tons) Empty Double-Aluminum Trucks 22.50 (tons) Loaded Double-Aluminum Trucks 64.50 (tons) Empty Double-Trailer Trucks 27.00 (tons) Loaded Double-Trailer Trucks 64.50 (tons) Empty Loadout Loader Weight 33.00 (tons) Loaded Loadout Loader Weight 44.00 (tons) Empty Quarry Feed Loader Weight 56.00 (tons) Loaded Quarry Feed Loader Weight 67.50 (tons) Table C-6. Drilling and Blasting Parameter Blasting Units Drilling Units Daily Maximum Frequency 1 (blast/day) 42 (holes/day) Annual Maximum Frequency 50 (blasts/yr) 2,000 (holes/yr) Annual Maximum Area 375,000 (ft2/yr)-- -- Daily Maximum Area 25,000 (ft2/day)-- -- ANFO Usage 40,000 (lbs/blast) -- -- Maximum Annual ANFO Usage 1,000 (tpy) -- -- ANFO Heat Content 912 (cal/g) -- -- Location Specification Value Unit Dozers1 Moisture 2.00 % Dozers2 Silt 2.00 % Loaders1 Moisture 2.00 % Loaders2 Silt 4.00 % Roads2 Silt 6.00 % 2. Provided by Las Vegas Paving on 08/25/2020. Table C-4. Supporting Equipment 1. The mine will have a maximum of five (5) acres of disturbed area during any one (1) year. Disturbed area will be stabilized (backfilled and reclaimed) as the mining area is moved each year. 1. Moisture content for dozers was previously recommended by UDAQ. Table C-5. Roads Table C-7. Silt and Moisture Values 1. All haul and tram route distances are given as roundtrip distances. Type of Equipment Quantity Las Vegas Paving Grantsville Operations Page 2 of 11 Trinity Consultants December 2020 PM10 PM2.5 NOX CO SO2 VOC CO2e Proposed Site-Wide Emissions 21.67 3.57 8.50 33.50 0.06 0.00 0.00 Major Source Thresholds1,2 70 70 70 100 70 70 NA Threshold Exceeded?No No No No No No No Modeling Limits3 15 No Limit 40 100 40 No Limit No Limit Threshold Exceeded?Yes No No No No No No 3. Per Emissions Impact Assessment Guidelines published by UDAQ. Table C-8. Facility-Wide Emissions Emissions (tpy) 1. The Grantsville site is located in Tooele County, which is in serious nonattainment for PM2.5. Values are per UAC R307- 403-5(2)(b)(ii). 2. Ammonia and HAPs emissions were considered in the Grantsville Site’s facility-wide emissions; however, these emissions are not applicable, as site power is provided by line power. Las Vegas Paving Grantsville Operations Page 3 of 11 Trinity Consultants December 2020 Process PM10 (tpy) PM2.5 (tpy) NOX (tpy) CO (tpy) SO2 (tpy) VOC (tpy) CO2e (tpy) Crushing and Screening Operations 1.68 0.24 0.00 0.00 0.00 0.00 0.00 Stock Piles and Disturbed Grounds 3.77 1.59 0.00 0.00 0.00 0.00 0.00 Bulldozers & Drops 1.56 0.30 0.00 0.00 0.00 0.00 0.00 Roads 13.91 1.39 0.00 0.00 0.00 0.00 0.00 Drilling and Blasting 0.74 0.04 8.50 33.50 0.06 0.00 -- Total Potential Emissions (tpy)21.67 3.57 8.50 33.50 0.06 0.00 0.00 Table C-9. Annual Potential Emissions Increase Summary Proposed Project Emissions Las Vegas Paving Grantsville Operations Page 4 of 11 Trinity Consultants December 2020 PM10 PM2.5 Primary Crushing Controlled 6.00E-04 9.09E-05 Secondary Crushing Controlled 2.70E-04 4.09E-05 Tertiary Crushing Controlled 5.40E-04 1.00E-04 Screening Controlled 7.40E-04 5.00E-05 Drop Controlled 6.08E-04 9.21E-05 Conveyor Transfer Controlled 4.60E-05 1.30E-05 Particle size multiplier (dimensionless)PM PM10 PM2.5 where:0.74 0.35 0.053 1. Emission factors per EPA Potential to Emit Calculator for Stone Quarrying, Crushing, and Screening Plants last updated November 2013 and AP-42 11.19.2. 2. Where PM2.5 emission factors (EF) are not provided, a ratio of aerodynamic particle size multipliers from AP-42 Ch. 13.2.4 was used to estimate PM2.5 emission factors. PM2.5 EF = (PM10 EF/0.35)*0.053. Source1,2 Emission Factor (lb/ton) Table C-10. Emission Factors for Crushing, Screening, & Material Handling Las Vegas Paving Grantsville Operations Page 5 of 11 Trinity Consultants December 2020 Throughput Percent Potential Annual Throughput (%) (tpy)PM10 PM2.5 PM10 PM2.5 PM10 PM2.5 Primary Crushing Primary HSI Crusher 1 40%600,000 Moisture Carryover 6.00E-04 9.09E-05 0.99 0.15 0.18 2.73E-02 Secondary Crushing Secondary Cone Crusher 1 35%525,000 Wet Suppression 2.70E-04 4.09E-05 0.39 0.06 0.07 1.07E-02 Tertiary Crushing Tertiary VSI Crusher 1 19%281,250 Wet Suppression 5.40E-04 1.00E-04 0.42 0.08 0.08 1.41E-02 Conveyor Transfer Feeder 1 90%1,350,000 Moisture Carryover 4.60E-05 1.30E-05 0.17 0.05 0.03 8.78E-03 Drop Bin Feeders 3 45%225,000 Moisture Carryover 6.08E-04 9.21E-05 1.12 0.17 0.21 3.11E-02 Screening Primary Screening 1 90%1,350,000 Moisture Carryover 7.40E-04 5.00E-05 2.74 0.18 0.50 0.03 Screening Secondary Screening 1 35%525,000 Moisture Carryover 7.40E-04 5.00E-05 1.06 0.07 0.19 1.31E-02 Screening Tertiary Screening 1 19%281,250 Moisture Carryover 7.40E-04 5.00E-05 0.57 0.04 0.10 7.03E-03 Conveyor Transfer Conveyors (800)3 90%1,350,000 Moisture Carryover 4.60E-05 1.30E-05 0.51 0.14 0.09 2.63E-02 Conveyor Transfer Conveyors (400, 50%) 2 50%750,000 Moisture Carryover 4.60E-05 1.30E-05 0.19 0.05 0.03 9.75E-03 Conveyor Transfer Conveyor (400, 45%) 1 45%675,000 Moisture Carryover 4.60E-05 1.30E-05 0.09 2.40E-02 0.02 4.39E-03 Conveyor Transfer Conveyors (250)2 35%525,000 Moisture Carryover 4.60E-05 1.30E-05 0.13 0.04 0.02 6.83E-03 Conveyor Transfer Conveyors (200)2 25%375,000 Moisture Carryover 4.60E-05 1.30E-05 0.09 2.67E-02 0.02 4.88E-03 Conveyor Transfer Conveyors (170)2 19%281,250 Moisture Carryover 4.60E-05 1.30E-05 0.07 2.00E-02 1.29E-02 3.66E-03 Conveyor Transfer Conveyor (160)1 18%262,500 Moisture Carryover 4.60E-05 1.30E-05 0.03 9.35E-03 6.04E-03 1.71E-03 Conveyor Transfer Conveyor (150)1 23%337,500 Fully Saturated ------ Conveyor Transfer Conveyors (140)2 20%303,750 Fully Saturated ------ Conveyor Transfer Conveyor (120)1 15%225,000 Moisture Carryover 4.60E-05 1.30E-05 0.03 8.01E-03 5.18E-03 1.46E-03 Conveyor Transfer Conveyors (80, 10%)2 10%150,000 Moisture Carryover 4.60E-05 1.30E-05 0.04 1.07E-02 6.90E-03 1.95E-03 Conveyor Transfer Conveyors (80, 9.375%) 2 9%140,625 Moisture Carryover 4.60E-05 1.30E-05 0.04 1.00E-02 6.47E-03 1.83E-03 Conveyor Transfer Conveyor (60)1 11%168,750 Fully Saturated ------ Conveyor Transfer Conveyor (40, 11.25%) 1 11%168,750 Fully Saturated ------ Conveyor Transfer Conveyor (40, 8.75%) 1 9%131,250 Moisture Carryover 4.60E-05 1.30E-05 0.02 4.67E-03 3.02E-03 8.53E-04 Conveyor Transfer Conveyor (40, 4.6875%) 1 5%70,313 Moisture Carryover 4.60E-05 1.30E-05 8.86E-03 2.50E-03 1.62E-03 4.57E-04 Conveyor Transfer Sand Screw 1 23%337,500 Fully Saturated ------ Screening Dewater Screen 1 20%303,750 Fully Saturated ------ Conveyor Transfer Future Conveyors 3 90%1,350,000 Moisture Carryover 4.60E-05 1.30E-05 0.51 0.14 0.09 2.63E-02 9.21 1.29 1.68 0.24 2 "Fully Saturated" indicates that the equipment is part of the Wash Circuit. Due to the fully saturated nature of aggregate within the Wash Circuit, these emissions are assumed to be negligible. Table C-11. Annual Aggregate Processed Total Emissions: Daily PTE Emissions (lb/day) Annual PTE Emissions (tpy)1Controls 1,2Number of Units or Drop Points 1 Water application will be used to control PM emissions on strategic transfer points throughout the crushing and screening operations. Equipment / Activity Source Description Emission Factor (lb/ton) Las Vegas Paving Grantsville Operations Page 6 of 11 Trinity Consultants December 2020 PM10 PM2.5 PM10 PM2.5 PM10 PM2.5 Stockpile A 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile B 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile C 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile D 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile E 0.10 1.00 6.3 1.85 2.14 1.11 0.04 0.02 Stockpile F 0.10 1.00 6.3 1.85 0.63 0.19 0.01 0.00 Stockpile G 0.10 1.00 6.3 1.85 0.63 0.19 0.01 0.00 Stockpile H 0.10 1.00 6.3 1.85 0.63 0.19 0.01 0.00 Stockpile I 0.10 1.00 6.3 1.85 0.63 0.19 0.01 0.00 Stockpile J 3.30 1.00 6.3 1.85 2.14 1.11 1.29 0.67 Stockpile K 3.30 1.00 6.3 1.85 2.14 1.11 1.29 0.67 Mine Disturbed Area 5.00 1.00 Reclamation 1.04 0.16 0.35 0.09 0.95 0.14 12.50 ------3.77 1.59 TSP emission factor:0.38 4 Where no PM10 or PM2.5 emission PM10 content: PM2.5 content: PM Type Moisture Carryover Water Saturation PM10 Control Efficiency 66% 90% PM2.5 Control Efficiency 40% 90% 7 PM10 and PM2.5 control efficiencies for moisture carryover are weighted according to UDAQ's guidelines from data received from AP-42 Appendix B.2, Table B.2-3. PM10 and PM 2.5 control efficiencies for water saturation are given per Western Regional Air Partnership's (WRAP's) 2006 Fugitive Dust Handbook value for watering of storage piles. Table C-12. Stockpiles - Potential Emissions Moisture Carryover Water Saturation 1 PM10 emission factors for stockpiles taken from AP-42, Fourth Edition Table 8.19.1-1, per UDAQ guidance. EF(PM2.5) [uncontrolled, inactive] = EF(PM2.5) [uncontrolled, active] * EF(PM10) [uncontrolled, inactive] / EF(PM10) [uncontrolled, active] 6 PM2.5 uncontrolled, inactive emission factor for stockpiles is based on the ratio of the uncontrolled, active PM10 and PM2.5 emission factors. 5 PM10 uncontrolled, inactive emission factors for stockpiles taken from AP-42 Fourth Edition, Table 8.19.1-1. 0.075 0.50 ton/acre-yr Where: 3 Per U.S. EPA AP-42, Section 11.9 (Western Surface Coal Mining), Table 11.9-4; August 1998, for Disturbed Area. 2 PM2.5 emission factors for stockpiles calculated using data from AP-42 Appendix B.2 Table B.2-2, per UDAQ guidance. Location Control Efficiency7 Annual Active Emissions (tpy)Quantity Control Uncontrolled Active Emission Factor (lb/day/acre)1,2,3 Controlled Active Emission Factor (lb/day/acre) Dry Circuit Wash Circuit Total Source Maximum Area (Acres) Overflow Moisture Carryover Las Vegas Paving Grantsville Operations Page 7 of 11 Trinity Consultants December 2020 PM10 PM2.5 Bulldozing Operations 0.12 0.08 Loading Operations 1.44 0.22 Total Loading and Dozing Emissions 1.56 0.30 (hr/yr)PM10 PM2.5 (%)PM10 PM2.5 PM10 PM2.5 Bulldozers 1,000 1 0.80 0.56 70% 0.66 0.46 0.12 0.08 0.66 0.46 0.12 0.08 where: s = 2.00 M = 2.00 PM10 PM2.5 Bulldozer 0.75 0.105 Per AP-42, Section 11.9 (October 1998), Table 11.9-1 Table C-15. Loader and Stacker Emissions (Supporting Operations) (tpy)PM10 PM2.5 (%)PM10 PM2.5 PM10 PM2.5 Loader to Haul Trucks (Muckpile)150,000 2.03E-03 3.07E-04 70% 0.25 0.04 0.05 0.01 Loader to Haul Trucks (Final Product)1,350,000 2.03E-03 3.07E-04 70% 2.25 0.34 0.41 0.06 Loader to Feeder 1,350,000 2.03E-03 3.07E-04 70% 2.25 0.34 0.41 0.06 Loader to Wash Bins 675,000 2.03E-03 3.07E-04 70% 1.12 0.17 0.21 0.03 Stacker A 750,000 2.03E-03 3.07E-04 70% 1.25 0.19 0.23 0.03 Stacker C 262,500 2.03E-03 3.07E-04 70% 0.44 0.07 0.08 0.01 Stacker D 70,313 2.03E-03 3.07E-04 70% 0.12 0.02 0.02 0.00 Stacker E 140,625 2.03E-03 3.07E-04 70% 0.23 0.04 0.04 0.01 7.91 1.20 1.44 0.22 E = Emission factor where: PM PM10 PM2.5 k =0.74 0.35 0.053 U = 7.89 M = 2.00 Material moisture content (%) previously recommended by UDAQ. 1. Uncontrolled emission factors using the "drop equation" contained in U.S. EPA AP-42, Section 13.2.4 (Aggregate Handling and Storage Piles), November 2006: Control Efficiency2 Daily Emissions (lb/day) Annual Emissions (tpy) Annual Emissions (tpy) Total Dozing Emissions: 1. Emissions for the bulldozer were characterized using AP-42, Section 11.9 (October 1998), Table 11.9-1 and Table 11.9-3 Mean wind speed (mph) is determined from historical data retrieved from Salt Lake International Airport, averaged over 2015-2020. Particle size multiplier (dimensionless) Percent (%) provided by Las Vegas Paving on 08/25/2020. 2. All daily feed will be watered during excavation and crushing and screening operations. The Dry Circuit will implement water sprays, resulting in a 70% control efficiency, per the average control value for wet suppression in the WRAP Fugitive Dust Handbook, 2006. The Wash Circuit will totally saturate its processed material; therefore, it is assumed that there will be no fugitive dust emissions from the stacking of Wash Circuit material. Table C-13. Dozing and Loading Emissions Source Annual Emissions (tpy)2 Vehicle Type Maximum Annual Operating Hours Quantity Emission Factor1 (lb/hr) Total Loading Emissions Table C-14. Dozing Emissions Material moisture content (%) previously recommended by UDAQ. Emission Activity Potential Total Annual Throughput Uncontrolled Emission Factor1 (lb/ton) Control Efficiency Daily Emissions (lb/day) Las Vegas Paving Grantsville Operations Page 8 of 11 Trinity Consultants December 2020 Table C-16. Roads Emissions - PTE Emissions PM10 PM2.5 PM10 PM2.5 Unpaved, Chemical Application (Trucks)47.23 4.72 8.33 0.83 Unpaved, Water Application (Trucks)0.00 0.00 0.00 0.00 Unpaved, Water Application (Loaders)30.58 3.06 5.58 0.56 Total 77.81 7.78 13.91 1.39 Table C-17. Roads Emissions - Traveling Parameters (Supporting Operations) Empty Single-Trailer Trucks Loaded Single- Trailer Trucks Empty Double- Aluminum Trucks Loaded Double- Aluminum Trucks Empty Double- Trailer Trucks Loaded Double- Trailer Trucks (tpy) (tons) (tons) (tons) (tons) (tons) (tons) (tons/haul) (tons/haul) (tons/haul) Main Haul Route 1,500,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 118 1.01 119 43,453 Muckpile Haul Route 150,000 17 40 22.5 64.5 27 64.5 23 42.0 37.5 12 0.34 4.10 1.23 Loader (Product Loadout) 1,350,000 33 44.0 NA NA NA NA 11.0 NA NA 336 0.11 38 13,946 Loader (Muckpile/Quarry) 1,500,000 56 67.5 NA NA NA NA 11.5 NA NA 357 0.02 7 2,470 Annual Days Vehicles Operate: Percent Single-Trailer Trucks: Percent Double Aluminum Trucks: Percent Double-Trailer Trucks: Unpaved (VMT/yr) Double Aluminum Haul Product Throughput Mean Trailer Weight, Single Trailer (tons)2,3 Mean Trailer Weight, Double Aluminum (tons)Single Trailer Haul Mean Trailer Weight, Double Trailer (tons)Double Trailer Haul Daily Total Travel Distance perHaul(VMT/haul) Total Vehicle Miles Traveled Haul/ Day Unpaved Unpaved Road Source Controlled Emissions Daily Emissions (lb/day)1 Annual Emissions (tpy)1 365 3 Maximum Gross Vehicle Weight (GVW) limitation per R909-2-5 Table 2. 10% Annual (VMT/day) 1 Daily and annual controlled emissions are calculated by applying the controlled emission factor (per UDAQ's control efficiencies) to the vehicular miles traveled per day (paved and unpaved). Daily Emissions (lb/day) = Miles Travelled per Day (VMT/day) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂) Annual Emissions (tpy) = Miles Travelled per Day (VMT/yr) * Uncontrolled Emission Factor (lb/VMT) * (1 - 𝜂) Percent of Potential Annual Throughput Increase via Muckpile Haul Route: Percent of Potential Annual Throughput via Main Haul Route: Road Source1 2 Truck weights per communication with Dan Peresinni, Las Vegas Paving, on August 25, 2020. 100% 1 Division of road travel: 30% 40% 30% Las Vegas Paving Grantsville Operations Page 9 of 11 Trinity Consultants December 2020 Table C-18. Roads Emissions - Emission Factors PM10 PM2.5 PM10 PM2.5 PM10 PM2.5 Unpaved None 0%2.56 0.26 2.53 0.25 3.14 0.31 Unpaved Watering 70%0.77 0.08 0.76 0.08 0.94 0.09 Unpaved Watering and Road Base 75%0.64 0.06 0.63 0.06 0.78 0.08 Unpaved Chemical Suppressant and Watering 85%0.38 0.04 0.38 0.04 0.47 0.05 Paved Pave Road Surface with Sweeping and Watering 90%0.26 0.03 0.25 0.03 0.31 0.03 Unpaved Roads where E = Size-specific emission factor (lb/VMT) k, a, b = Constants for equation 1a PM PM10 PM2.5 k =4.9 1.5 0.15 a =0.7 0.9 0.9 b =0.45 0.45 0.45 s = surface material silt content (%) s =6.0 WHT =39.3 Mean haul truck weight (tons) WLL=38.5 Mean loadout loader weight (tons) WQF=61.8 Mean quarry feed loader weight (tons) Per Las Vegas Paving, 08/25/2020. Road Surface Controls 1 Control Efficiency (%) Haul Truck Emission Factor 2 (lb/VMT) 1 Emission controls for vehicular traffic on paved and unpaved roads per UDAQ guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015. 2 Emission factors for vehicular traffic on unpaved roads for sand and gravel processing per U.S. EPA AP-42, Section 13.2.2 (Unpaved Roads), November 2006. Loadout Loader Emission Factor 2 (lb/VMT) Quarry Feed Loader Emission Factor 2 (lb/VMT) Las Vegas Paving Grantsville Operations Page 10 of 11 Trinity Consultants December 2020 Table C-19. Blasting and Drilling Area Maximum Annual Blast Frequency (blasts/yr) Maximum Annual Area Blasted (ft2/yr) Maximum Daily Blast Area (ft2/blast) Minimum Daily Blast Area (ft2/blast) 50 375,000 25,000 12,500 Table C-20. Drilling and Blasting Emission Factors Value Units Value Units Value Units Value Units Value Units Value Units Blasting (Max) 55.34 (lb/blast) 28.78 (lb/blast) 1.66 (lb/blast) Blasting (Min) 19.57 (lb/blast) 10.17 (lb/blast) 0.59 (lb/blast) Drilling Annual # of Drill Holes 2,000 (holes/yr) 1.30 (lb/hole) 0.68 (lb/hole) 3.90E-02 (lb/hole) - (lb/ton) - (lb/ton) - (lb/ton) PM10:0.52 PM2.5:0.03 PM10 = PM15 * 0.52 PM2.5 = TSP * 0.03 Table C-21. Blasting and Drilling Emissions Control Efficiency1 (%)PM PM10 PM2.5 SO2 NOX CO PM PM10 PM2.5 SO2 NOX CO Blasting 0% 55.34 28.78 1.66 2.40 340.00 1,340.00 1.38 0.72 0.04 0.06 8.50 33.50 Drilling 97.0% 1.64 0.85 0.05 -- -- -- 0.04 0.02 1.17E-03 -- -- -- 56.98 29.63 1.71 2.40 340.00 1,340.00 1.42 0.74 0.04 0.06 8.50 33.50 2Daily Blasting PM Emissions (lb/day) = Emission Factor (lbs/day) as only one blast is allowed per day. 3SO2, NOX, & CO Daily Blasting Emissions (lb/day) = Emission Factor (lb/ton) * Annual ANFO Throughput (tpy) / Annual Blasts (blasts/yr) 4Daily PM Drilling Emissions (lb/day) = Emission Factor (lb/hole) * Drill Holes/yr / Expected Working Days/Year 5SO2, NOX, & CO Annual Blasting Emissions (tpy) = Emission Factor (lbs/ton) * Annual ANFO Throughput (tpy) * 1 ton/2000 lbs 6Annual Blasting PM Emissions (tpy) = Emission Factor (lb/blast) * 50 blasts/yr * 1 ton/2000 lbs 7Annual PM Drilling Emissions (tpy) = Emission Factor (lb/hole) * Drill Holes/yr * 1 ton/2000 lb 6 Blast and drilling quantities provided per design basis. 1Drilling operations will be controlled through wet-drilling. NIOSH reports a range from 86% to 97% control efficiency for controlling fugitive emissions via wet-drilling (per Summary of NIOSH research completed on dust control methods for surface and underground drilling, Pg 2, December 2008). LVP has elected to implement wet-drilling control technologies to reduce fugitive drilling emissions. Because LVP will use a dust collector in addition to wet drilling, the maximum 97% control efficiency value for wet-drilling is assumed to be applicable. Scaling factors were applied to PM15 and TSP emission factors to calculate PM10 and PM2.5 emission factors respectively per Table 11.9-1: As there is not data for the PM15 emission factor equation, PM15 is conservatively assumed to be equal to TSP. 4 Blasting NOX and CO emission factors retrieved from ANFO blasting agent factor from AP-42 13.3-1. 3 Blasting SO2 emission factor developed using a mass balance assuming 6% fuel oil mixture with 500 ppm sulfur content, consistent with EPA non-road standards. Since no emission factors are provided for PM10 and PM2.5 drilling operations, emission factors were calculated using the PM10 and PM2.5 to TSP ratios for blasting overburden per AP-42 11.9, Table 11.9-1, where: 2Drilling PM emission factor is retrieved from AP-42 11.9, Table 11.9-4, where the drilling PM emission factor is for overburden material for conservatism. The coal PM emission factor is lower and may be appropriate for some drilling operations. Total Annual Emissions: Source Description Annual Emissions (tpy)5,6,7Max Daily Emissions (lbs/day)2,3,6 SO2Source Activity ThroughputSource Description Units Emission Factor1,2,3,4,5,6 PM10 PM2.5 NOX COPM 0.000014(A)^1.5 A = horizontal area (ft2), with blasting depth ≤ 70 ft 0.12 17.00 67.00(lb/ton)(lb/ton) 1Blasting PM emission factors retrieved from AP-42 11.9, Table 11.9-1. Using the equation below the horizontal area blasted (A) is assumed to be the average daily Blast Area. ANFO 1,000 (tpy)(lb/ton) Las Vegas Paving Grantsville Operations Page 11 of 11 Trinity Consultants December 2020 Las Vegas Paving | Notice of Intent C AIR DISPERSION MODELING PROTOCOL/REPORT Submitted under separate cover. MODELING REPORT PM10 24-hr NAAQS / Modeling Report Las Vegas Paving Corp. / Grantsville Plant Prepared By: TRINITY CONSULTANTS 4525 Wasatch Boulevard, Suite 200 Salt Lake City, UT 84124 (801) 272-3000 For: Las Vegas Paving 4420 S Decatur Blvd Las Vegas, NV 89103 January 2021 Project: 204502.0035 Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants i TABLE OF CONTENTS 1. INTRODUCTION 1-1 1.1 General Information ................................................................................................. 1-1 1.2 Proposed Installations .............................................................................................. 1-1 1.3 Plant Layout .............................................................................................................. 1-2 2. AIR DISPERSION MODELING DESCRIPTION 2-1 2.1 Model Selection ......................................................................................................... 2-1 2.2 Meteorological Data .................................................................................................. 2-1 2.3 Terrain Elevations ..................................................................................................... 2-1 2.4 Receptors .................................................................................................................. 2-1 2.5 UTM Coordinate System ............................................................................................ 2-4 2.6 Building Downwash .................................................................................................. 2-5 2.7 Particle Depletion ..................................................................................................... 2-5 3. SOURCE PARAMETERS AND EMISSION RATES 3-1 3.1 Volume Source Parameters and Emission Rates ........................................................ 3-1 3.1.1 Aggregate Material Handling Modeling Parameters and Emission Rates ........................ 3-1 3.1.2 Haul Road Modeling Parameters and Emission Rates .................................................. 3-1 3.1.3 Drilling and Blasting ................................................................................................ 3-2 3.2 Area Source Parameters and Emission Rates ............................................................ 3-3 3.2.1 Stockpile Erosion Modeling Parameters and Emission Rates ......................................... 3-3 3.2.2 Bulldozer Modeling Parameters ................................................................................. 3-3 3.2.3 Disturbed Ground Modeling Parameters ..................................................................... 3-4 3.3 Nearby Sources - Emission Rates .............................................................................. 3-4 3.3.1 Cargill, Inc.............................................................................................................. 3-4 3.3.2 Lhoist North America ............................................................................................... 3-4 4. MODELING ANALYSIS 4-1 4.1 Operating Scenarios .................................................................................................. 4-1 4.2 Blasting Hour of Day Screening Analysis ................................................................... 4-1 4.3 Background Concentrations ...................................................................................... 4-1 4.4 Modeled Concentration ............................................................................................. 4-2 4.5 24-Hour PM10 NAAQS Analysis Results ...................................................................... 4-2 APPENDIX A. GRANTSVILLE PIT MODELING PARAMETERS AND EMISSION RATES A-1 APPENDIX B. BLASTING SCREENING MODEL RESULTS B-1 Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 1-1 1. INTRODUCTION 1.1 General Information Las Vegas Paving Corp. (LVP) is a heavy civil construction company that provides a comprehensive list of services from paving to roto-milling, excavating to recycling. LVP is proposing to operate a permanent aggregate mining, sizing, washing, and sales and distribution operations at Lhoist North America of Arizona, Inc. (Lhoist or LNA) Grantsville Plant, in Grantsville, Utah in Tooele County. The Grantsville Plant is located within an area of Tooele County designated as a non-attainment area of the National Ambient Air Quality Standards (NAAQS) for particulate matter with an equivalent aerodynamic diameter of 2.5 microns or less (PM2.5). In addition, oxides of nitrogen (NOX), sulfur dioxide (SO2), volatile organic compounds (VOCs) and ammonia (NH3) are considered precursors to PM2.5 in Utah. LVP is located within an attainment area of the NAAQS for particulate matter with an equivalent aerodynamic diameter of 10 microns or less (PM10) and has a potential to emit (PTE) for fugitive PM10 in excess of 5 tons per year. Per Utah administrative code R307-410-4, LVP has conducted a PM10 modeling analysis to demonstrate compliance with the PM10 24-hour NAAQS in support of a Notice of Intent (NOI) air quality permit application for the Grantsville Pit. This modeling report outlines the methodology LVP used for the PM10 dispersion modeling analysis demonstrating compliance with the PM10 24-hour NAAQS and the results from this modeling analysis. 1.2 Proposed Installations The Grantsville Pit consists of an aggregate mine with aggregate crushing and screening operations that occur on a Dry Circuit and on a Wash Circuit. The Dry Circuit is comprised of various crushers, screens, conveyors, and stackers, and results in five (5) stockpiles. The Wash Circuit is comprised of various screens, conveyors, and stackers, and results in four (4) stockpiles. Supporting equipment will be utilized in both Circuits. In addition, there is one overflow stockpile area planned for the site. Installations to be permitted and included in this modeling analysis of the Grantsville Pit are as follows. ► Dry Circuit crushing and screening plant; ► Conveyors and stackers for Dry Circuit; ► Wash Circuit screening plant; ► Conveyors and stackers for Wash Circuit; ► Clarifier for Wash Circuit; ► Drilling and Blasting (not concurrent); and, ► Supporting Operations: • Truck Traffic; • Bulldozing; and • Front-end loader operation. The general facility layout is shown in Figure 1-1 below. Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 1-2 Figure 1-1. Grantsville Pit Site Plan 1.3 Plant Layout Figure 1-2 below presents a detailed layout of the Dry Circuit at the Grantsville Pit, and Figure 1-3 below presents a detailed layout of the Wash Circuit. Drilling and blasting loosens aggregate from the mine area, where it is then loaded by a front-end loader into the Dry Circuit’s primary feeder. Mined aggregate is then fed into the crushing and screening operations where it is crushed, screened, and stacked into stockpiles. Some of the stockpiled product from the Dry Circuit is then loaded into the Wash Circuit’s bin feeders by a front-end loader. This aggregate is then washed, screened, and stacked according to size in the Wash Circuit. Haul trucks are loaded by a front-end loader to haul both Dry Circuit and Wash Circuit products off- site. Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 1-3 Figure 1-2. Grantsville Pit Dry Circuit Figure 1-3. Grantsville Pit Wash Circuit Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 2-1 2. AIR DISPERSION MODELING DESCRIPTION This section describes the air quality dispersion modeling analysis performed to estimate the ambient air impacts of LVP’s operation of the Grantsville Pit. All modeling results were compared to the PM10 NAAQS for the 24-hour averaging period. The objective of the NAAQS analysis is to demonstrate through air quality dispersion modeling that emissions from the Grantsville Pit do not cause or contribute to an exceedance of the PM10 NAAQS in ambient air. Nearby offsite sources area were also included, and the combined impacts assessed against the PM10 NAAQS. Dispersion Modeling was conducted in accordance with R307-410-3 and 40 CFR Part 51, Appendix W Guideline on Air Quality Models. 2.1 Model Selection Near-field dispersion modeling was performed using the latest version of the AERMOD modeling system, version 19191, which is an EPA approved, steady-state Gaussian mathematical plume model. AERMOD is composed of three modular components: AERMAP, the terrain preprocessor that characterizes the terrain and generates source and receptor elevations and surrounding hill height scales; AERMET, the meteorological preprocessor that processes raw surface and upper air meteorological observations for use by AERMOD; and AERMOD, the control module and modeling processor. 2.2 Meteorological Data Meteorological data used in the dispersion modeling analysis was processed and provided by UDAQ. Data consists of five years (2008 through 2012) of National Weather Service (NWS) surface data collected at the Salt Lake City Airport in Utah. Concurrent upper air observations used in AERMET were obtained from the Salt Lake City Airport. 2.3 Terrain Elevations Terrain elevations for the Grantsville Pit’s sources, receptors and buildings were determined using National Elevation Dataset (NED), the primary elevation data product of the United States Geologic Survey (USGS).1 NED data are distributed in geographic coordinates in units of decimal degrees, and in conformance with the North American Datum of 1983 (NAD 83). The NED used for this analysis is at a resolution of 1/3 arc- second (about 10 meter) grid spacing. Elevations were converted from the NED grid spacing to the air dispersion model receptor spacing using the AERMOD preprocessor, AERMAP version 18081. All data obtained from the NED files was checked for completeness and spot-checked for accuracy. 2.4 Receptors A modeling domain was developed for the near-field analyses to encompass the location of the maximum modeled concentration from LVP’s sources. Discrete receptor locations in AERMOD were based on UTM coordinates in the NAD83 datum, Zone 12N. An initial modeling grid extending radially from the facility center was established. The receptor grid was developed to ensure that maximum pollutant concentrations were captured by the model. The ambient air boundary receptors were placed along the facility property boundary. Ellerbeck Road, a public access road, passes through the facility property. Public access cannot be precluded from Ellerbeck Road and the roadway is considered to be in the ambient air. Therefore, 1 NED data obtained at https://viewer.nationalmap.gov/basic/#/ downloaded December 23, 2020 Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 2-2 discrete receptors were placed along Ellerbeck Road on the portions of the roadway within the facility property boundary. The model receptors consisted of boundary receptors, gridded receptors, and roadway receptors with the following spacing: ► The ambient air boundary was placed at the facility property line and consists of discrete receptors placed at 25-meter intervals. ► The fine grid contains 100-meter spaced receptors extending to 3 kilometers from the center of the facility. ► The medium grid contains 250-meter spaced receptors extending to 6 kilometers from the center of the facility. ► The coarse grid contains 500-meter spaced receptors extending to 10 kilometers from the center of the facility. ► Receptors were placed on Ellerbeck Rd (the public access road) located within the eastern property boundary at 25-meter intervals. Figure 2-1 and Figure 2-2 below show the ambient air boundary receptors (shown in purple below), roadway receptors (yellow), and gridded offsite receptors (yellow). Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 2-3 Figure 2-1. Boundary Receptors and Roadway Receptors Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 2-4 Figure 2-2. Fine, Medium, and Coarse Grid and Boundary Receptors 2.5 UTM Coordinate System In all modeling analyses input and output data files, the locations of emission sources, structures, and receptors were represented in the Universal Transverse Mercator (UTM) coordinate system and based on NAD83. In this grid, the world is divided into 60 north-south zones, each covering a strip 6° wide in longitude. The general area of the site is located in UTM Zone 12N. In each UTM Zone, coordinates are measured north and east in meters. The northing values are measured continuously from zero at the Equator, in a northerly direction. A central meridian through the middle of each 6° zone is assigned an easting value of 500,000 meters. Grid values to the east of this central meridian, as in the case of the site, are greater than 500,000 meters. Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 2-5 2.6 Building Downwash The emission sources were evaluated in terms of their proximity to nearby structures. The Grantsville Pit is free of structures that would have the potential to induce downwash. A downwash evaluation is not included in this analysis. 2.7 Particle Depletion Dry deposition was selected for this modeling demonstration. The dry deposition of pollutants at the surface, whether particle or gaseous, results in removal of pollutant mass from the plume as the plume travels downwind from the source. This removal process is referred to as dry depletion, and acts to reduce ground-level concentrations and deposition fluxes.2 Particle size distributions for plume depletion of all non- blasting fugitive PM10 emission sources were provided by Utah DAQ and are shown in Table 2-1 below. Table 2-1. Non-Blasting Particle Size Distributions3 The particle size distributions above include all non-blasting sources except for dozing, disturbed ground, and drilling. Dozing used batch drop distributions as the most similar source approximation due the similar nature of material handling. The disturbed ground source used pile wind erosion size distributions due to the similarity of wind erosion from disturbed material storage. Drilling used crushing as the most similar 2 AERMOD Deposition Algorithms – Science Document (Revised Draft) March 19, 2004. https://www3.epa.gov/scram001/7thconf/aermod/aer_scid.pdf 3 Particle density given in grams per cubic centimeter (g/cm3) Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 2-6 source approximation due to the similar nature of mechanically impacting large pieces of rock within an enclosure. Particle size distributions for blasting sources was derived from AP-42 Table 11.9-1 which is the best available information for blasting sources in the western United States. Table 11.9-1 from section 11.9 of AP-42 lists the emission factors for Western Surface Coal Mining processes. The blasting emission factors were used to determine the distribution of emissions for particles with nominal diameters less than 10 microns (PM10). A 2nd degree polynomial was used to fit this data and determine the size distribution for other particle sizes. Figure 2-3 below shows the AP-42 particle size distribution and polynomial fit. Table 2-2 below shows the calculated particle size distribution that was used for blasting sources at LVP. Figure 2-3. Particle Size Distribution for Blasting Emissions Table 2-2. Particle Size Distribution for Blasting Emissions Diameter (microns) Mass Fraction Density (g/cm3) 2.2 0.069 2.44 3.17 0.128 2.44 6.1 0.385 2.44 7.82 0.224 2.44 9.32 0.194 2.44 Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 3-1 3.SOURCE PARAMETERS AND EMISSION RATES 3.1 Volume Source Parameters and Emission Rates Aggregate crushing and screening, material handling, raw material and product loading, customer truck export, drilling, and blasting were modeled as volume sources. All volume sources require release height, initial lateral dimension, initial vertical dimension, and emission rate as inputs to characterize the sources. This section explains the methodology to obtain the modelling parameters required for volume sources. All inputs for volume source parameters can be seen in Appendix A of this modeling analysis. 3.1.1 Aggregate Material Handling Modeling Parameters and Emission Rates The emissions from screening, crushing and associated material transfers were modeled as various volume sources and based on the dimensions of equipment. To be conservative and representative of the source, the initial lateral dimension of the single volume source was the smallest width of the unit divided by 4.3, the initial vertical dimension was the height from ground level to the highest point on the screen divided by 4.3.4 The release height of the single volume source was half of the height (center of the volume source). The Grantsville Pit emissions calculations and modeling analysis were conducted using a 1,500,000 tons per year (tpy) annual throughput, with 90% of the mass throughput processed in the crushing and screening operations. A maximum hourly throughput of 800 tons per hour (tph) was assumed for modeling of the primary feeder, and the remaining throughput of equipment is based on the expected percentage of material associated with each piece of equipment following estimated material splits. Modeling parameters for all fugitive material handling emission and emission rates can be found in Appendix A, Table A-1. 3.1.2 Haul Road Modeling Parameters and Emission Rates The Grantsville Pit has an unpaved road on which customer trucks travel to retrieve and haul aggregate off site. Guidance from the Haul Road Workgroup Final Report Submission to EPA-OAQPS Memo by Tyler Fox on March 2, 2012 was used to determine the modeling parameters of this haul road. Figure 1-1 shows the unpaved haul route in red which includes two loops (west and east) where trucks travel to retrieve aggregate. Trucks will travel on only one of the two loops and it is assumed that traffic will be evenly distributed among each loop. The adjusted road width, release height and emission rates are required volume source inputs for the road. The release height was half the top of the plume height, and the plume height was defined as 1.7 times the vehicle height.5 Customer trucks were modeled applying a vehicle height of 3.0 m. The vehicle width plus 6.0 m was applied as the width of the plume, also known as the adjusted vehicle width. The Grantsville Pit haul roads are wide enough for two lanes of travel, but haul truck travel frequency will be sparce enough that plumes from multiple trucks will not regularly combine. Therefore, the single lane calculation was used for development of haul road volume source parameters. Applying the adjusted vehicle width and adjacent option, several volume sources were generated which include the emission rate evenly divided between each volume source of the specified road. The initial 4 Table 3-1 of AERMOD User’s Guide, for single volume source the initial lateral dimension is determined as length of side divided by 4.3. In general, a smaller distance will produce a more conservative concentration. 5 Haul Road Workgroup Final Report Submission to EPA-OAQPS Memo by Tyler Fox on March 2, 2012. Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 3-2 lateral dimension, initial vertical dimension, and release height for each volume source within the haul road were all identical. The initial lateral dimension was calculated for use in AERMOD as the width of the plume (or adjusted vehicle width) divided by a factor of 2.15. The initial vertical dimension was calculated in AERMOD as the height of the plume divided by a factor of 2.15. The height of the plume was 1.7 times the truck height. The volume sources were spaced based on the “Adjacent” option, indicating they were spaced according to the adjusted vehicle width (i.e., the “adjusted vehicle width” defines the width of each volume source within a roadway and is also the distance between each volume source). Truck traffic at the Grantsville Pit will consist of customer trucks retrieving and hauling both processed and unprocessed aggregate off site. The average vehicle weight was determined by provided average weights based on the mass of empty and filled trucks. Information regarding vehicle weight and maximum gross vehicle weight were provided by the National Academy of Science and UAC R909-2 Utah Size and Weight Rule.6,7 Haul road modeling parameters and emissions rates can be found in Appendix A, Table A-2 of this modeling analysis. 3.1.3 Drilling and Blasting The Grantsville pit mining operations consist of drilling holes for packing explosives in and then blasting those explosives to loosen the material to be handled by loaders. The series of events consists of drilling holes in the days leading up to a blast day. On a day that blasting occurs, no drilling will occur, instead, explosive charges will be loaded into the already drilled holes. For this reason, two modeling scenarios were run, a drilling day scenario and a blasting day scenario. Blasting days are characterized by the following: ► No drilling will occur on a blasting day. ► Surrounding the time of a blast, all other operations (truck traffic, crushing and screening, loading, etc.) will cease before and after the blast, totaling two (2) hours of inactivity. ► No more than 25,000 ft2 of surface area may be blasted on any one day. ► The center of the blasting location may occur no closer than 265 feet from the property boundary. ► The emissions associated with blasting have been assumed to occur within a one hour blasting window. All sources in the pit (active mining area) including blasting and drilling as well as dozing and disturbed area (detailed in Section 3.2 below) were modeled at the worst-case year of the mine plan for emission impacts. Worst-case is determined to be the year where active mining takes place closest to the ambient air boundary. Drilling and blasting are modeled as centered at the 265 foot setback from the property boundary. Other sources are placed in the geographic center of the mine plan area for the worst-case year. The drilling plume height and width are based on engineering estimates of typical values for drilling operations at similar mines. The blasting plume height and width are based on the U.S. EPA Open Burn/Open Detonation Dispersion Model (OBODM). OBODM was applied to the designed blasting at the Grantsville pit and calculated a plume width and height of 70.71 meters. In addition to the OBODM blasting parameters, DEQ requested that a modeling analysis also be conducted with a 50 ft plume height. Separate modeling tabulations (modeled groups in AERMOD) were conducted that used either the OBODM or 50 ft plume height, with all other blasting parameters and sources kept equal. 6 National Academy of Sciences, Technologies, and Approaches to Reducing the Fuel Consumption of Medium and Heavy-Duty Vehicles, prepublication copy, March 2010, pp. 2-2 and 5-42. 7 Maximum Gross Vehicle Weight (GVW) limitation per R909-2-5 Table 2. Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 3-3 The drilling and blasting volume source parameters were all calculated using the same methodology. The release height was set equal to half of the plume height and the initial vertical and horizontal directions were set equal to the plume heights and widths divided by a factor of 4.3. 3.2 Area Source Parameters and Emission Rates Aggregate stockpiling, disturbed ground, and bulldozing were modeled as area sources. All area sources require release height, initial lateral dimension, initial vertical dimension, and emission rate as inputs to characterize the sources. This section explains the methodology to obtain the modelling parameters required for volume sources. All inputs for volume source parameters can be seen in Appendix A of this modeling analysis. 3.2.1 Stockpile Erosion Modeling Parameters and Emission Rates There will be ten (10) stockpiles located at the Grantsville Pit that store crushed stones of varying sizes. Stockpiles found at the Grantsville Pit will be as follows: ► Five (5) Stockpiles – Dry Circuit Stockpiles ► Four (4) Stockpiles – Wash Circuit Stockpiles ► One (1) Overflow Stockpile Area – Inactive Stockpile The nine (9) active stockpiles will be round shaped on the base and created by conveyor stackers; emissions from these piles were modeled as circular area sources. The overflow (inactive) stockpile may occupy any or all of an irregularly shaped area allocated for overflow aggregate storage. This was modeled as a polygon area source. Release height for each pile was determined to be half of the average height.8 This assumption balances the considerations that wind speed increases with elevation and leads to greater erosion, and the surface area above a certain height decreases as the given height increases. Initial vertical dispersion (sigma z) was the average pile height divided by 4.3.9 The release height for the storage pile is above ground level, and the cavity thickness was considered to represent the entire thickness of the plume. Therefore, the area source was considered an elevated source. The location of the vertices parameters was determined based on a known center point from the Dry and Wash Circuit areas. Base areas and distances were determined by engineering estimates provided by LVP. Stockpile modeling parameters and emissions rates are detailed in Appendix A, Table A-3 of this modeling analysis. 3.2.2 Bulldozer Modeling Parameters The Grantsville Pit will utilize drilling and blasting measures to break up solid material into aggregate material. Bulldozers will be used to maneuver blasted aggregate from the mining area toward the primary feeder. 8 According to Section 5.2.7 of "Modeling Fugitive Dust Sources with AERMOD" published by the National Stone, Sand, and Gravel Association (NSSGA). 9 According to Section 5.2.9 of "Modeling Fugitive Dust Sources with AERMOD" published by the National Stone, Sand and Gravel Association (NSSGA). Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 3-4 The release height and emission rates are required input for the bulldozer area source. The release height was half the top of the plume height; and the plume height was defined as 1.7 times the vehicle height.10 The initial vertical dimension was calculated in AERMOD as the height of the plume divided by a factor of 2.15, recall the height of the plume was 1.7 times the bulldozer height. The bulldozer was modeled applying a 4 m height. The bulldozer modeling parameters and emission rate are detailed in Appendix A, Table A-4 of this modeling analysis. 3.2.3 Disturbed Ground Modeling Parameters The Grantsville Pit will have up to five (5) acres of active, disturbed ground at any given time. While the total area of the mine during the course of its life is 40 acres, the inactive 35 acres will either be reclaimed or undisturbed. A 1.0 m release height and 2.0 m initial vertical dimension was provided for active, disturbed ground to account for any slope variation within the area. The disturbed ground parameters and emissions rate are detailed in Appendix A, Table A-5 of this modeling analysis. 3.3 Nearby Sources - Emission Rates Nearby sources of PM10 were obtained from UDAQ in an October 9, 2020 email (Cargill, Inc (Cargill)) and a follow-up phone call with Dave Prey of UDAQ on October 21, 2020 (Lhoist North America (Lhoist)). UDAQ requested that Cargill’s salt plant located at UTM coordinates 359,940 m Easting, 4,512,330 m Northing, UTM Zone 12 be included in the air dispersion model as a nearby source of PM10. 3.3.1 Cargill, Inc. The emissions from Cargill were calculated by converting the facility’s PM10 PTE as documented in approval order DAQE-AN107220016-16 (dated March 23, 2016) into a gram per second emission rate. Condition II.B.2.f of the approval order states hourly emission limits for four point sources at the facility. These hourly emission rates were scaled to annual emission rates by assuming 8,760 hours/year of operation of the emission sources and the associated annual emissions were deducted from the facility PM10 PTE. The remaining PM10 PTE was scaled to a grams per second emission rate by assuming 8,760 hours/year of operation and is represented in the model as a fugitive volume source. The Cargill point source release parameters are estimated using Cargill stack test reports obtained from the Utah Division of Air Quality's EQDocs search. The remaining emissions from Cargill fugitives were assigned release parameters estimated from aerial imagery of the onsite building dimensions. All Cargill sources were assigned particle size distributions for batch drop sources as shown in Table 2-1 as this is the best available representation for particulate sources at Cargill. 3.3.2 Lhoist North America The emissions from Lhoist were not included in the modeling analysis. LVP and Lhoist will not operate simultaneously at any time, therefore, LVP and Lhoist emissions were not aggregated for evaluation of ambient impacts. 10 Haul Road Workgroup Final Report Submission to EPA-OAQPS Memo by Tyler Fox on March 2, 2012. Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 4-1 4. MODELING ANALYSIS The modeling analysis predicts ambient concentrations of PM10 due to emissions from the Grantsville Pit and surrounding co-contributing sources. The modeling output includes tabulated modeling results as compared to the PM10 24-hour NAAQS. 4.1 Operating Scenarios The modeled operations were divided into two separate scenarios; drilling days and blasting days. Drilling and blasting are exclusive events; therefore, the emissions associated with either event will not occur simultaneously on any given day. Drilling days consist of normal operations with the addition of drilling holes in the mine area. Blasting days consist of normal operations without any drilling, and one blast per day. During a blasting event, all other onsite operations (loading, hauling, crushing, and screening operations, etc.) are suspended for a two (2) hour period. 4.2 Blasting Hour of Day Screening Analysis Blasting only occurs once per day and all emissions are contained within a single hour. The hour of the day selected for blasting affects the modeled 24-hour PM10 impacts due to variable meteorological conditions throughout each day. A screening analysis was conducted with blasting occurring at each hour of the day to rank the modeled impacts based on time of day. The screening analysis used only emissions from blasting and used the 50 ft plume height supplied by UDAQ. The results of the screening analysis are contained in Appendix B, Table B-1 and show the varying impacts at modeled hours of the day. Based on the results of the blasting screening, the worst-case meteorological impact hour between 10:00 am (start) and 4:00 pm (stop) was selected. This corresponded with blasting occurring during the 3:00-4:00 pm time frame. This blasting window was then utilized to generate the NAAQS assessment for the blast days. This is further discussed in Section 4.5 below. 4.3 Background Concentrations Background concentrations for PM10 for the Grantsville area were provided by UDAQ via email on October 9, 2020. The background data consists of monthly maximums of 24-hour PM10 for the years of 1995-1997. The value used in the modeling analysis is the first second highest day (H2H) from 1995-1997. The background concentrations for PM10 obtained from UDAQ are presented in Table 4-1 below. Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 4-2 Table 4-1. Background Concentrations Year 1995 1996 1997 3 Year Month Max Max Max H2H 1 50 17 16 50 2 33 72 23 72 3 49 25 27 49 4 36 5 15 36 5 19 23 26 26 6 32 32 32 32 7 39 33 22 39 8 55 50 26 55 9 28 43 20 43 10 29 29 22 29 11 38 29 32 38 12 41 10 45 45 4.4 Modeled Concentration The resulting concentration of PM10 from this air dispersion modeling analysis was compared against the PM10 NAAQS to demonstrate that emissions from the Grantsville Pit do not cause or contribute to an exceedance of the PM10 NAAQS. The primary NAAQS is the maximum concentration ceiling, measured in terms of total concentration of a pollutant in the atmosphere, which define the “level of air quality which the U.S. EPA judges are necessary, with an adequate margin of safety, to protect the public health.”11 The 24- hour PM10 NAAQS requires the 6th highest concentration over the five (5) modeled years be compared to the standard. The modeled concentration was added to the monthly background concentrations for comparison to the NAAQS. This calculation was completed within the AERMOD modeling system. 4.5 24-Hour PM10 NAAQS Analysis Results A NAAQS analysis considers the impact from the sources at the Grantsville Pit and background concentrations to yield a total concentration which is then compared to the NAAQS which, for 24-hour PM10, is 150 µg/m3. The blasting scenario was determined to be below the 24-hour PM10 NAAQS for blasting emissions beginning after 10:00 am and concluding by 4:00 pm. The blasting screening analysis showed that the emissions hour beginning at 3:00 pm was the worst case hour for modeled impacts within the time interval beginning at 10:00 am and concluding at 4:00 pm. Therefore, the results of the blasting scenario with blasting at the 3:00 pm hour are reported below and submitted with this report. Table 4-2 presents the model-predicted concentrations from the Grantsville Pit and background concentration, and 24-hour PM10 NAAQS comparison. 11 40 CFR 50.2(b). Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants 4-3 Table 4-2. PM10 24-Hour NAAQS Compliance Demonstration Operating Scenario Pollutant Averaging Period Model-Predicted H6H Concentration Including Background NAAQS Percent of NAAQS (µg/m3) (µg/m3) (%) Drilling PM10 24-hour 140.47 150 93.64% Blasting – OBODM Plume Height PM10 24-hour 139.57 150 93.05% Blasting – 50 ft Plume Height PM10 24-hour 139.58 150 93.05% In addition to this report, LVP is providing the AERMOD Input and Output files for UDAQ’s review. Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants A-1 APPENDIX A. GRANTSVILLE PIT MODELING PARAMETERS AND EMISSION RATES Table A-1. Controlled Emission Factors for Crushing & Screening Operations PM10 Emission Factor1 (lb/ton) Primary Crushing 6.00E-04 Secondary Crushing 2.70E-04 Tertiary Crushing 5.40E-04 Screening 7.40E-04 Drop 6.08E-04 Conveyor Transfer 4.60E-05 Source (lb/day) Drilling 0.85 Blasting 28.78 Source Table A-11. Cargill Volume Sources - Location and Emission Rate Table A-2. Modeling Parameters for Aggregate Material Handling Ground to Source/ Structure Min Height2 Ground to Source/ Building Max Height2 Source/ Building Width2 Ground to Source/ Structure Min Height2 Ground to Source/ Building Max Height2 Source/ Building Width2 Unscaled PM10 Emission Rate Maximum Hourly Limit PM10 Daily Emission Rate (ft) (ft) (ft) (m) (m) (m) (lb/ton)(tph)(g/s) Primary Crushing PCR_1 Primary HSI Crusher 0.00 15.00 6.67 0.00 4.57 2.03 Primary Crushing 6.00E-04 400 3.02E-02 Y Y Secondary Crushing SCR_1 Secondary Cone Crusher 0.00 15.00 6.67 0.00 4.57 2.03 Secondary Crushing 2.70E-04 250 8.50E-03 Y Y Tertiary Crushing TCR_1 Tertiary VSI Crusher 0.00 15.00 6.67 0.00 4.57 2.03 Tertiary Crushing 5.40E-04 170 1.16E-02 Y Y Screening SCRN_1 Primary Screening 0.00 15.00 6.67 0.00 4.57 2.03 Screening 7.40E-04 800 7.46E-02 Y Y Screening SCRN_2 Secondary Screening 0.00 15.00 6.67 0.00 4.57 2.03 Screening 7.40E-04 250 2.33E-02 Y Y Screening SCRN_3 Tertiary Screening 0.00 15.00 6.67 0.00 4.57 2.03 Screening 7.40E-04 170 1.59E-02 Y Y Drop FEED Bin Feeders 0.00 15.00 3.00 0.00 4.57 0.91 Drop 6.08E-04 400 3.07E-02 Y Y Conveyor Transfer C1 Feeder 2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 800 4.64E-03 Y Y Conveyor Transfer C2 Conveyors (800)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 800 4.64E-03 Y N Conveyor Transfer C3 Conveyors (800)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 800 4.64E-03 Y N Table A-11. Cargill Volume Sources - Location and Emission Rate C4 Conveyors (800)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 800 4.64E-03 Y N Conveyor Transfer C5 Conveyors (400, 50%)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 400 2.32E-03 Y N Conveyor Transfer C6 Conveyors (400, 50%)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 400 2.32E-03 Y N Conveyor Transfer C7 Conveyor (400, 45%)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 400 2.32E-03 Y N Conveyor Transfer C8 Conveyors (250)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 250 1.45E-03 Y N Conveyor Transfer C9 Conveyors (250)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 250 1.45E-03 Y N Conveyor Transfer C10 Conveyors (200)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 200 1.16E-03 Y N Conveyor Transfer C11 Conveyors (200)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 200 1.16E-03 Y N Conveyor Transfer C12 Conveyors (170)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 170 9.85E-04 Y N Conveyor Transfer C13 Conveyors (170)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 170 9.85E-04 Y N Conveyor Transfer C14 Conveyor (160)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 160 9.27E-04 Y N Conveyor Transfer C15 Conveyor (120)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 120 6.96E-04 Y N Conveyor Transfer C16 Conveyors (80, 10%)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 80 4.64E-04 Y N Conveyor Transfer C17 Conveyors (80, 10%)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 80 4.64E-04 Y N Conveyor Transfer C18 Conveyors (80, 9.375%)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 80 4.64E-04 Y N Conveyor Transfer C19 Conveyors (80, 9.375%)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 80 4.64E-04 Y N Conveyor Transfer C20 Conveyor (40, 8.75%)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 40 2.32E-04 Y N Conveyor Transfer C21 Conveyor (40, 4.6875%)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 40 2.32E-04 Y N Conveyor Transfer C22 Conveyors (800)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 800 4.64E-03 Y N Conveyor Transfer C23 Conveyors (800)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 800 4.64E-03 Y N Conveyor Transfer C24 Conveyors (800)2.00 6.00 3.00 0.61 1.83 0.91 Conveyor Transfer 4.60E-05 800 4.64E-03 Y N Drop STCK1 Stacker A 25.00 30.00 3.00 7.62 9.14 0.91 Drop 6.08E-04 400 3.07E-02 Y N Drop STCK2 Stacker C 25.00 30.00 3.00 7.62 9.14 0.91 Drop 6.08E-04 160 1.23E-02 Y N Drop STCK3 Stacker D 25.00 30.00 3.00 7.62 9.14 0.91 Drop 6.08E-04 40 3.07E-03 Y N Drop STCK4 Stacker E 25.00 30.00 3.00 7.62 9.14 0.91 Drop 6.08E-04 80 6.13E-03 Y N Drop LD1 Loader to Feeder 5 20 8.2 1.52 6.10 2.50 Drop 6.08E-04 800 6.13E-02 Y N Drop LD2 Loader to Wash Bins 5 20 8.2 1.52 6.10 2.50 Drop 6.08E-04 400 3.07E-02 Y N Drop LD3 Loader to Haul Trucks (Final Product)5 20 8.2 1.52 6.10 2.50 Drop 6.08E-04 800 6.13E-02 Y N Blasting1 B1_50 Blasting (50 ft plume height)0 50 232.0 0.00 15.24 70.71 Blasting 2.88E+01 -3.63 NN Blasting1 B1_OBODM Blasting (OBODM plume height)0 232.0 232.0 0.00 70.71 70.71 Blasting 2.88E+01 -3.63 NN Drilling D1 Drilling 0 5 72 0.00 1.52 21.95 Drilling 8.52E-01 -6.71E-03 YN 1. Blasting emissions assume one blast per day with all associated emissions occurring within a single hour. 2. Source dimensions are based on engineering assumptions. 3. Only large equipment such as screens and crushers have been assumed to be on or adjacent to structures. Modeled ID Source Description Source Type Controls?Subgroup On or Adjacent to Structure?3 Table A-3. Modeling Parameters and Emission Rates for Aggregate Material Handling UTM X UTM Y Elevation PM10 Daily Emission Rate 4 Release Height1 Initial Lateral Dimension (σy)2 Initial Vertical Dimension (σz)3 (m) (m) (m) (g/s) (m) (m) (m) PCR_1 Primary HSI Crusher 367102.5 4506462.7 1371.35 0.0302 2.2860 0.4726 2.1265 SCR_1 Secondary Cone Crusher 367093.0 4506704.4 1296.34 0.0085 2.2860 0.4726 2.1265 TCR_1 Tertiary VSI Crusher 367085.0 4506722.1 1299.02 0.0116 2.2860 0.4726 2.1265 SCRN_1 Primary Screening 367078.7 4506706.0 1298.00 0.0746 2.2860 0.4726 2.1265 SCRN_2 Secondary Screening 367089.9 4506712.2 1298.90 0.0233 2.2860 0.4726 2.1265 SCRN_3 Tertiary Screening 367075.2 4506734.7 1299.64 0.0159 2.2860 0.4726 2.1265 FEED Bin Feeders 367103.1 4506462.2 1371.25 0.0307 2.2860 0.2127 2.1265 C1 Feeder 367069.5 4506700.8 1299.71 0.00464 1.2192 0.2127 0.5671 C2 Conveyors (800) 367068.3 4506706.1 1300.35 0.00464 1.2192 0.2127 0.2835 C3 Conveyors (800) 367069.5 4506717.2 1300.97 0.00464 1.2192 0.2127 0.2835 C4 Conveyors (800) 367079.0 4506704.0 1297.56 0.00464 1.2192 0.2127 0.2835 C5 Conveyors (400, 50%) 367084.3 4506704.7 1296.93 0.00232 1.2192 0.2127 0.2835 C6 Conveyors (400, 50%) 367090.4 4506705.4 1296.84 0.00232 1.2192 0.2127 0.2835 C7 Conveyor (400, 45%) 367069.0 4506706.4 1300.03 0.00232 1.2192 0.2127 0.2835 C8 Conveyors (250) 367062.0 4506706.9 1303.61 0.00145 1.2192 0.2127 0.2835 C9 Conveyors (250) 367092.2 4506707.4 1297.42 0.00145 1.2192 0.2127 0.2835 C10 Conveyors (200) 367090.8 4506711.2 1298.66 0.00116 1.2192 0.2127 0.2835 C11 Conveyors (200) 367085.8 4506716.5 1298.94 0.00116 1.2192 0.2127 0.2835 C12 Conveyors (170) 367087.4 4506718.9 1298.91 0.000985 1.2192 0.2127 0.2835 C13 Conveyors (170) 367081.6 4506725.4 1299.23 0.000985 1.2192 0.2127 0.2835 C14 Conveyor (160) 367077.5 4506731.3 1299.49 0.000927 1.2192 0.2127 0.2835 C15 Conveyor (120) 367072.4 4506722.1 1300.79 0.000696 1.2192 0.2127 0.2835 C16 Conveyors (80, 10%) 367074.6 4506713.3 1299.74 0.000464 1.2192 0.2127 0.2835 C17 Conveyors (80, 10%) 367081.4 4506716.0 1299.18 0.000464 1.2192 0.2127 0.2835 C18 Conveyors (80, 9.375%) 367085.8 4506716.5 1298.94 0.000464 1.2192 0.2127 0.2835 C19 Conveyors (80, 9.375%) 367087.4 4506718.9 1298.91 0.000464 1.2192 0.2127 0.2835 C20 Conveyor (40, 8.75%) 367081.6 4506725.4 1299.23 0.000232 1.2192 0.2127 0.2835 C21 Conveyor (40, 4.6875%) 367077.5 4506731.3 1299.49 0.000232 1.2192 0.2127 0.2835 C22 Conveyors (800) 367072.4 4506722.1 1300.79 0.00464 1.2192 0.2127 0.2835 C23 Conveyors (800) 367074.6 4506713.3 1299.74 0.00464 1.2192 0.2127 0.2835 C24 Conveyors (800) 367081.4 4506716.0 1299.18 0.00464 1.2192 0.2127 0.2835 STCK1 Stacker A 367052.9 4506703.0 1308.40 0.0307 8.3820 0.2127 0.3544 STCK2 Stacker C 367052.1 4506712.9 1305.82 0.0123 8.3820 0.2127 0.3544 STCK3 Stacker D 367051.2 4506726.7 1306.18 0.0031 8.3820 0.2127 0.3544 STCK4 Stacker E 367053.3 4506742.9 1303.08 0.0061 8.3820 0.2127 0.3544 LD1 Loader to Feeder 367103.6 4506461.7 1371.18 0.0613 3.8100 0.5812 1.0633 LD2 Loader to Wash Bins 367063.7 4506701.5 1303.38 0.0307 3.8100 0.5812 1.0633 LD3 Loader to Haul Trucks (Final Product)367021.6 4506763.1 1296.44 0.0613 3.8100 0.5812 1.0633 B1_50 Blasting (50 ft plume height) 367193.2 4506460.6 1336.11 3.626 7.6200 16.4442 3.5442 B1_OBODM Blasting (OBODM plume height) 367193.2 4506460.6 1336.11 3.626 35.3550 16.4442 16.4442 D1 Drilling 367193.2 4506460.6 1336.11 0.0067 0.7620 5.1036 0.3544 2 The initial lateral dimension is calculated as the width of the volume source divided by a factor of 4.3. AERMOD User’s Guide issued by EPA, September 2004 (EPA-454/B-03-001). 3 If the source is a surface based source or an elevated source on or adjacent to a structure (structure based), the initial vertical dimension would be the vertical dimension of the source divided by 2.15. If the source is an elevated source not on or adjacent to a structure (elevated source), the initial vertical dimension would be the vertical dimension of the source divided by 4.3. Note a lattice structure is not considered a structure because it does not obstruct wind flow. AERMOD User’s Guide issued by EPA, September 2004 (EPA-454/B-03-001). Modeled ID Source Description 1 Guidance from AERMOD User’s Guide issued by EPA, September 2004 (EPA-454/B-03-001) is used to determine the release height, i.e. the center of the volume source. Table A-4. Stockpile and Disturbed Ground - Area Source Physical Parameters UTM X UTM Y Elevation Max. Pile Diameter1 Max. Pile Height2 Average Pile Height3 Max Pile Area Max. Pile Height Average Pile Height Max Pile Area (m) (m) (m) (ft) (ft) (ft)(ft2)(m) (m)(m2)(lb/day/acre)(g/s-m2) SPA Stockpile A 74 30 20.0 4356.0 9.1 6.1 404.7 2.14 2.779E-06 SPB Stockpile B 74 30 20.0 4356.0 9.1 6.1 404.7 2.14 2.779E-06 SPC Stockpile C 74 30 20.0 4356.0 9.1 6.1 404.7 2.14 2.779E-06 SPD Stockpile D 74 30 20.0 4356.0 9.1 6.1 404.7 2.14 2.779E-06 SPE Stockpile E 74 30 20.0 4356.0 9.1 6.1 404.7 2.14 2.779E-06 SPF Stockpile F 74 30 20.0 4356.0 9.1 6.1 404.7 0.63 8.173E-07 SPG Stockpile G 74 30 20.0 4356.0 9.1 6.1 404.7 0.63 8.173E-07 SPH Stockpile H 74 30 20.0 4356.0 9.1 6.1 404.7 0.63 8.173E-07 SPI Stockpile I 74 30 20.0 4356.0 9.1 6.1 404.7 0.63 8.173E-07 Table A-11. Cargill VolStockpile J 400 30 20.0 125888.9 9.1 6.1 11695.5 2.14 2.779E-06 DST_GRD Disturbed Area 527 0 0.0 217800.9 - - 20234.4 0.35 4.592E-07 1. Stockpiles A-I are estimated to have an area of 0.1 acres. Stock pile J is an overflow stockpile with area based on the physical dimensions of the space allocated for storage. 2. A max pile height of 30 feet was assumed for modeling. 3. For cone shaped piles, the average pile height is approximately 66% of the maximum average pile height. Table A-5a. Stockpiles and Disturbed Ground - Modeling Parameters and Emission Rates for Stock Piles Table A-5b. Stockpile J Polygon Area Source Vertices1 UTM X UTM Y Elevation Emission rate Release Height1 Radius Initial Vertical Dimension2,3 (σz) (m) (m) (m) (g/s-m 2) (m) (m) (m) SPA Stockpile A 2.779E-06 3.05 11.3 20 1.42 SPB Stockpile B 2.779E-06 3.05 11.3 20 1.42 SPC Stockpile C 2.779E-06 3.05 11.3 20 1.42 SPD Stockpile D 2.779E-06 3.05 11.3 20 1.42 SPE Stockpile E 2.779E-06 3.05 11.3 20 1.42 SPF Stockpile F 8.173E-07 3.05 11.3 20 1.42 SPG Stockpile G 8.173E-07 3.05 11.3 20 1.42 SPH Stockpile H 8.173E-07 3.05 11.3 20 1.42 SPI Stockpile I 8.173E-07 3.05 11.3 20 1.42 Table A-11. Cargill VolStockpile J 2.779E-06 3.05 N/A N/A 1.42 DST_GRD Disturbed Area 4.592E-07 0.00 80.3 20 2.00 1. All units are UTM NAD83, Zone 12N Populated from Model Placement 2. Initial vertical dimension is the average pile height divided by 4.3. 3. Initial vertical dimension for disturbed area assumes 2 m to account for terrain variation throughout the area. Modeled ID Source Description Coordinates Modeled Parameters Modeled ID Source Description Location (NAD83) Measured/Estimated Parameters Source Specific Emissions 366,894.9 Populated from Model Placement 1. The release height is half of the average pile height. According to Section 5.2.7 of "Modeling Fugitive Dust Sources with AERMOD" published by the National Stone, Sand, and Gravel Association (NSSGA). This assumption balances the considerations that wind speed increases with elevation and leads to greater erosion, and the surface area above a certain height decreases as the given height increases. Vertices 366,898.7 366,857.8 366,826.6 366,792.8 366,770.2 366,766.5 366,769.1 366,778.1 4,506,860.8 4,506,868.3 4,506,867.9 366,788.3 366,824.7 366,849.5 366,867.5 4,506,867.9 4,506,870.2 4,506,969.0 UTM X (m) UTM Y (m) 366,904.3 366,898.7 4,506,969.0 4,506,961.8 4,506,946.8 4,506,918.6 4,506,894.2 4,506,880.7 4,506,868.7 4,506,862.3 4,506,857.4 Table A-6. Modeling Parameters and Emission Rates for Haul Roads Vehicle Height (m) Vehicle Width (m) Road Width (m) Adjusted Road Width Release Height (m)1 Initial Lateral Dimension (σy) (m)2 Initial Vertical Dimension (σz) (m)3 Total Emission Rate Total Emission Rate Emission Rate per Volume Source VH VW RW RW + 6 =0.5 (1.7*VH)= (RW+6)/2.15 =(1.7*VH)/ 2.15 (lb/day) (g/s) (g/s/source) ROAD Main Haul Road (Entry)13.00 19.00 8.84 10.12 0.05 23 0.00231 ROAD Main Haul Road (W Loop)13.00 19.00 8.84 3.09 0.02 26 0.00062 ROAD Main Haul Road (E Loop)13.00 19.00 8.84 2.11 0.01 21 0.00053 ROAD Main Haul Road (E Loop Entry)13.00 19.00 8.84 3.37 0.02 11 0.00161 ROAD Muckpile Export 3.15 0.02 35 0.00047 ROAD Loader (Product Loadout)2.42 0.01 1 0.0127 ROAD Loader (Quarry)5.19 0.03 4 0.00681 Annual Days Vehicles Operate 365 Daily Hours Vehicles Operate 24 2.37 22.00 10.23 Number of Volume Sources Source ID Source Description 1 The release height is half the top of the plume height; and the plume height is defined as 1.7 times the vehicle height. Haul Road Workgroup Final Report Submission to EPA-OAQPS Memo by Tyler Fox on March 2, 2012. 2 The vehicle width plus 6 m is applied as the width of the plume, also known as the adjusted vehicle width. This adjusted vehicle width (9 m) is used as the spacing between roadway volume sources. The road width plus 6 m is the methodology used for a two lane roadway (road width measured at 13 meters. The initial lateral dimension is calculated for use as the width of the plume (or adjusted vehicle width) divided by a factor of 2.15. Haul Road Workgroup Final Report Submission to EPA-OAQPS Memo by Tyler Fox on March 2, 2012.Table A-11. Cargill Volume Sources - Location and Emission Rate 16.00 3.0 3.0 2.55 Table A-7. Modeling Inputs for Haul Roads UTM X UTM Y Elevation Emission Rate Per Source Release Height (m) Initial Lateral Dimension (σy) (m) Initial Vertical Dimension (σz) (m) (m) (m) (m) (g/s) =0.5 (1.7*VH)=(RW+6)/ 2.15 =(1.7*VH)/ 2.15 H_RDX1 Main Haul Road (Entry)367046.5 4506949.2 1290.15 0.00231 2.55 8.84 2.37 H_RDX2 Main Haul Road (Entry)367038.2 4506952.7 1290.12 0.00231 2.55 8.84 2.37 H_RDX3 Main Haul Road (Entry)367029.9 4506956.2 1290.13 0.00231 2.55 8.84 2.37 H_RDX4 Main Haul Road (Entry)367021.6 4506959.7 1290.18 0.00231 2.55 8.84 2.37 H_RDX5 Main Haul Road (Entry)367013.3 4506963.3 1290.21 0.00231 2.55 8.84 2.37 H_RDX6 Main Haul Road (Entry)367005.1 4506966.8 1290.18 0.00231 2.55 8.84 2.37 H_RDX7 Main Haul Road (Entry)366996.5 4506969.3 1290.17 0.00231 2.55 8.84 2.37 H_RDX8 Main Haul Road (Entry)366987.6 4506970.3 1290.19 0.00231 2.55 8.84 2.37 H_RDX9 Main Haul Road (Entry)366978.6 4506971.3 1290.22 0.00231 2.55 8.84 2.37 H_RDX10 Main Haul Road (Entry)366969.7 4506972.3 1290.22 0.00231 2.55 8.84 2.37 H_RDX11 Main Haul Road (Entry)366960.7 4506973.2 1290.23 0.00231 2.55 8.84 2.37 H_RDX12 Main Haul Road (Entry)366952.1 4506972.9 1290.27 0.00231 2.55 8.84 2.37 H_RDX13 Main Haul Road (Entry)366944.3 4506968.3 1290.39 0.00231 2.55 8.84 2.37 H_RDX14 Main Haul Road (Entry)366936.6 4506963.7 1290.48 0.00231 2.55 8.84 2.37 H_RDX15 Main Haul Road (Entry)366933.4 4506956.1 1290.57 0.00231 2.55 8.84 2.37 H_RDX16 Main Haul Road (Entry)366932.1 4506947.2 1290.7 0.00231 2.55 8.84 2.37 H_RDX17 Main Haul Road (Entry)366933 4506938.5 1290.82 0.00231 2.55 8.84 2.37 H_RDX18 Main Haul Road (Entry)366936.3 4506930.2 1290.94 0.00231 2.55 8.84 2.37 H_RDX19 Main Haul Road (Entry)366939.7 4506921.8 1291.1 0.00231 2.55 8.84 2.37 H_RDX20 Main Haul Road (Entry)366943 4506913.4 1291.23 0.00231 2.55 8.84 2.37 H_RDX21 Main Haul Road (Entry)366946.1 4506905 1291.31 0.00231 2.55 8.84 2.37 H_RDX22 Main Haul Road (Entry)366948.8 4506896.4 1291.4 0.00231 2.55 8.84 2.37 H_RDX23 Main Haul Road (Entry)366951.5 4506887.8 1291.53 0.00231 2.55 8.84 2.37 H_RDEX1 Main Haul Road (E Loop Entry)366960.4 4506878.1 1291.65 0.00161 2.55 8.84 2.37 H_RDEX2 Main Haul Road (E Loop Entry)366967.1 4506872.2 1291.76 0.00161 2.55 8.84 2.37 H_RDEX3 Main Haul Road (E Loop Entry)366973.9 4506866.2 1291.78 0.00161 2.55 8.84 2.37 H_RDEX4 Main Haul Road (E Loop Entry)366980.6 4506860.3 1291.85 0.00161 2.55 8.84 2.37 H_RDEX5 Main Haul Road (E Loop Entry)366987.4 4506854.3 1291.87 0.00161 2.55 8.84 2.37 H_RDEX6 Main Haul Road (E Loop Entry)366994.1 4506848.4 1291.94 0.00161 2.55 8.84 2.37 H_RDEX7 Main Haul Road (E Loop Entry)366997.2 4506840.2 1292.01 0.00161 2.55 8.84 2.37 H_RDEX8 Main Haul Road (E Loop Entry)366999.1 4506831.5 1292.02 0.00161 2.55 8.84 2.37 H_RDEX9 Main Haul Road (E Loop Entry)367001.1 4506822.7 1292.02 0.00161 2.55 8.84 2.37 H_RDEX10 Main Haul Road (E Loop Entry)367004.5 4506814.5 1292.04 0.00161 2.55 8.84 2.37 H_RDEX11 Main Haul Road (E Loop Entry)367009.7 4506807.2 1292.19 0.00161 2.55 8.84 2.37 H_RDE1 Main Haul Road (E Loop)367018.7 4506801.9 1292.31 0.00053 2.55 8.84 2.37 H_RDE2 Main Haul Road (E Loop)367027.2 4506798.9 1292.46 0.00053 2.55 8.84 2.37 H_RDE3 Main Haul Road (E Loop)367035.7 4506795.9 1292.47 0.00053 2.55 8.84 2.37 H_RDE4 Main Haul Road (E Loop)367044.4 4506794 1292.47 0.00053 2.55 8.84 2.37 H_RDE5 Main Haul Road (E Loop)367053.4 4506793.3 1292.54 0.00053 2.55 8.84 2.37 H_RDE6 Main Haul Road (E Loop)367062.4 4506792.6 1292.59 0.00053 2.55 8.84 2.37 H_RDE7 Main Haul Road (E Loop)367071.4 4506792 1292.54 0.00053 2.55 8.84 2.37 H_RDE8 Main Haul Road (E Loop)367080.3 4506791.3 1292.46 0.00053 2.55 8.84 2.37 H_RDE9 Main Haul Road (E Loop)367086.4 4506786.2 1292.5 0.00053 2.55 8.84 2.37 H_RDE10 Main Haul Road (E Loop)367090.5 4506778.2 1292.74 0.00053 2.55 8.84 2.37 H_RDE11 Main Haul Road (E Loop)367085.9 4506772.3 1293.29 0.00053 2.55 8.84 2.37 H_RDE12 Main Haul Road (E Loop)367077.8 4506769 1294.11 0.00053 2.55 8.84 2.37 H_RDE13 Main Haul Road (E Loop)367068.9 4506767.2 1294.63 0.00053 2.55 8.84 2.37 Source ID Source Description UTM X UTM Y Elevation Emission Rate Per Source Release Height (m) Initial Lateral Dimension (σy) (m) Initial Vertical Dimension (σz) (m) (m) (m) (m) (g/s) =0.5 (1.7*VH)=(RW+6)/ 2.15 =(1.7*VH)/ 2.15 H_RDE14 Main Haul Road (E Loop)367060.1 4506765.5 1295.21 0.00053 2.55 8.84 2.37 H_RDE15 Main Haul Road (E Loop)367051.4 4506765.1 1295.39 0.00053 2.55 8.84 2.37 H_RDE16 Main Haul Road (E Loop)367043 4506768.3 1294.86 0.00053 2.55 8.84 2.37 H_RDE17 Main Haul Road (E Loop)367034.6 4506771.5 1294.28 0.00053 2.55 8.84 2.37 H_RDE18 Main Haul Road (E Loop)367026.4 4506775.1 1293.48 0.00053 2.55 8.84 2.37 H_RDE19 Main Haul Road (E Loop)367020.3 4506781.7 1292.99 0.00053 2.55 8.84 2.37 H_RDE20 Main Haul Road (E Loop)367016.1 4506789.5 1292.69 0.00053 2.55 8.84 2.37 H_RDE21 Main Haul Road (E Loop)367012.7 4506797.8 1292.48 0.00053 2.55 8.84 2.37 H_RDW1 Main Haul Road (W Loop)366950.7 4506877.5 1291.75 0.00062 2.55 8.84 2.37 H_RDW2 Main Haul Road (W Loop)366950.2 4506868.5 1291.85 0.00062 2.55 8.84 2.37 H_RDW3 Main Haul Road (W Loop)366949.7 4506859.5 1291.94 0.00062 2.55 8.84 2.37 H_RDW4 Main Haul Road (W Loop)366949.2 4506850.5 1292.07 0.00062 2.55 8.84 2.37 H_RDW5 Main Haul Road (W Loop)366948.7 4506841.6 1292.2 0.00062 2.55 8.84 2.37 H_RDW6 Main Haul Road (W Loop)366948.2 4506832.6 1292.29 0.00062 2.55 8.84 2.37 H_RDW7 Main Haul Road (W Loop)366945 4506824.6 1292.35 0.00062 2.55 8.84 2.37 H_RDW8 Main Haul Road (W Loop)366939.5 4506817.5 1292.37 0.00062 2.55 8.84 2.37 H_RDW9 Main Haul Road (W Loop)366934 4506810.4 1292.41 0.00062 2.55 8.84 2.37 H_RDW10 Main Haul Road (W Loop)366931.5 4506802.8 1292.47 0.00062 2.55 8.84 2.37 H_RDW11 Main Haul Road (W Loop)366934.7 4506794.4 1292.59 0.00062 2.55 8.84 2.37 H_RDW12 Main Haul Road (W Loop)366939.2 4506787.0 1292.74 0.00062 2.55 8.84 2.37 H_RDW13 Main Haul Road (W Loop)366946.5 4506781.8 1292.7 0.00062 2.55 8.84 2.37 H_RDW14 Main Haul Road (W Loop)366953.3 4506779.1 1292.7 0.00062 2.55 8.84 2.37 H_RDW15 Main Haul Road (W Loop)366957.8 4506786.9 1292.64 0.00062 2.55 8.84 2.37 H_RDW16 Main Haul Road (W Loop)366962.4 4506794.7 1292.52 0.00062 2.55 8.84 2.37 H_RDW17 Main Haul Road (W Loop)366966.9 4506802.5 1292.42 0.00062 2.55 8.84 2.37 H_RDW18 Main Haul Road (W Loop)366971.4 4506810.2 1292.34 0.00062 2.55 8.84 2.37 H_RDW19 Main Haul Road (W Loop)366975.2 4506818.1 1292.24 0.00062 2.55 8.84 2.37 H_RDW20 Main Haul Road (W Loop)366972.2 4506826.6 1292.14 0.00062 2.55 8.84 2.37 H_RDW21 Main Haul Road (W Loop)366969.2 4506835.1 1292.03 0.00062 2.55 8.84 2.37 H_RDW22 Main Haul Road (W Loop)366966.2 4506843.5 1291.96 0.00062 2.55 8.84 2.37 H_RDW23 Main Haul Road (W Loop)366963.2 4506852.0 1291.9 0.00062 2.55 8.84 2.37 H_RDW24 Main Haul Road (W Loop)366960.2 4506860.5 1291.86 0.00062 2.55 8.84 2.37 H_RDW25 Main Haul Road (W Loop)366957.2 4506869.0 1291.81 0.00062 2.55 8.84 2.37 H_RDW26 Main Haul Road (W Loop)366954.2 4506877.5 1291.72 0.00062 2.55 8.84 2.37 PL_RD1 Loader (Product Loadout) 367025.1 4506837.6 1290.77 0.01271 2.55 10.23 2.37 M_RD1 Muckpile Export 367096.4 4506467.9 1372.51 0.00047 2.55 10.23 2.37 M_RD2 Muckpile Export 367097 4506476.9 1371.36 0.00047 2.55 10.23 2.37 M_RD3 Muckpile Export 367097.6 4506485.9 1370.03 0.00047 2.55 10.23 2.37 M_RD4 Muckpile Export 367098.2 4506494.8 1368.16 0.00047 2.55 10.23 2.37 M_RD5 Muckpile Export 367098.7 4506503.8 1366.28 0.00047 2.55 10.23 2.37 M_RD6 Muckpile Export 367099.3 4506512.8 1364.33 0.00047 2.55 10.23 2.37 M_RD7 Muckpile Export 367099.9 4506521.8 1362.47 0.00047 2.55 10.23 2.37 M_RD8 Muckpile Export 367100.5 4506530.8 1360.53 0.00047 2.55 10.23 2.37 M_RD9 Muckpile Export 367101.1 4506539.7 1358.43 0.00047 2.55 10.23 2.37 M_RD10 Muckpile Export 367101.7 4506548.7 1356.3 0.00047 2.55 10.23 2.37 M_RD11 Muckpile Export 367102.3 4506557.7 1354.09 0.00047 2.55 10.23 2.37 M_RD12 Muckpile Export 367102.9 4506566.7 1351.81 0.00047 2.55 10.23 2.37 M_RD13 Muckpile Export 367103.4 4506575.7 1349.56 0.00047 2.55 10.23 2.37M_RD14 Muckpile Export 367104 4506584.6 1346.84 0.00047 2.55 10.23 2.37 M_RD15 Muckpile Export 367104.6 4506593.6 1343.86 0.00047 2.55 10.23 2.37 Source ID Source Description UTM X UTM Y Elevation Emission Rate Per Source Release Height (m) Initial Lateral Dimension (σy) (m) Initial Vertical Dimension (σz) (m) (m) (m) (m) (g/s) =0.5 (1.7*VH)=(RW+6)/ 2.15 =(1.7*VH)/ 2.15 M_RD16 Muckpile Export 367105.2 4506602.6 1340.88 0.00047 2.55 10.23 2.37 M_RD17 Muckpile Export 367105.8 4506611.6 1337.99 0.00047 2.55 10.23 2.37 M_RD18 Muckpile Export 367106.4 4506620.6 1335.14 0.00047 2.55 10.23 2.37 M_RD19 Muckpile Export 367107 4506629.5 1331.79 0.00047 2.55 10.23 2.37 M_RD20 Muckpile Export 367107.5 4506638.5 1325.96 0.00047 2.55 10.23 2.37 M_RD21 Muckpile Export 367108.1 4506647.5 1318.4 0.00047 2.55 10.23 2.37 M_RD22 Muckpile Export 367108.7 4506656.5 1310.7 0.00047 2.55 10.23 2.37M_RD23 Muckpile Export 367109.3 4506665.5 1303.85 0.00047 2.55 10.23 2.37 M_RD24 Muckpile Export 367109.9 4506674.4 1298.19 0.00047 2.55 10.23 2.37M_RD25 Muckpile Export 367110.5 4506683.4 1294.23 0.00047 2.55 10.23 2.37 M_RD26 Muckpile Export 367111.1 4506692.4 1292.72 0.00047 2.55 10.23 2.37 M_RD27 Muckpile Export 367111.7 4506701.4 1293.13 0.00047 2.55 10.23 2.37 M_RD28 Muckpile Export 367112.2 4506710.4 1296.96 0.00047 2.55 10.23 2.37 M_RD29 Muckpile Export 367112.8 4506719.4 1299.04 0.00047 2.55 10.23 2.37 M_RD30 Muckpile Export 367110.6 4506727.9 1298.22 0.00047 2.55 10.23 2.37 M_RD31 Muckpile Export 367107.2 4506736.2 1296.83 0.00047 2.55 10.23 2.37 M_RD32 Muckpile Export 367103.8 4506744.6 1295.83 0.00047 2.55 10.23 2.37 M_RD33 Muckpile Export 367100.5 4506752.9 1295.41 0.00047 2.55 10.23 2.37 M_RD34 Muckpile Export 367097.1 4506761.3 1294.3 0.00047 2.55 10.23 2.37 M_RD35 Muckpile Export 367093.7 4506769.6 1293.47 0.00047 2.55 10.23 2.37 QL_RD1 Loader (Quarry) 367047.9 4506460.9 1369.95 0.00681 2.55 10.23 2.37 QL_RD2 Loader (Quarry) 367056.9 4506460.6 1367.29 0.00681 2.55 10.23 2.37 QL_RD3 Loader (Quarry) 367065.9 4506460.2 1364.89 0.00681 2.55 10.23 2.37 QL_RD4 Loader (Quarry) 367074.9 4506459.9 1362.14 0.00681 2.55 10.23 2.37 Source ID Source Description Table A-8. Modeling Parameters for Area Sources (Bulldozer) Vehicle Height (m) Vehicle Width (m) Release Height (m)1 Initial Vertical Dimension (σz) (m)2,3 Total Emission Rate Total Emission Rate VH VW =0.5 (1.7*VH) =(1.7*VH)/ 2.15 (lb/day) (g/s) BLLDZR Bulldozer 4.00 4.65 3.40 3.16 0.66 5.20E-03 Daily bulldozing hours: 16 Table A-9. Disturbed Area - Area Source Physical Parameters (Bulldozer) UTM X UTM Y Elevation Emission Rate1 Release Height X Length Y Length Angle Init. Vert . Dim (m) (m) (m)(g/s-m2)(m) (m) (m) (°) (m) me Sources - LocaBulldozer 367067 4506468 1379.78 6.157E-07 3.4 65 130 92 3.16 2. Bulldozing area (m2) =8,450 This value is the estimated area bulldozed in a day. Modeled ID Source Description Location Measured/Estimated Parameters Source ID Source Description 1 Release height for bulldozers is characterized similarly to that of haul trucks. The release height is half the top of the plume height; and the plume height is defined as 1.7 times the vehicle height. Haul Road Workgroup Final Report Submission to EPA-OAQPS Memo by Tyler Fox on March 2, 2012. 2 The initial vertical dimension is calculated as the height of the plume divided by a factor of 2.15, the height of the plume is 1.7 times the vehicle height. 3 A 2 meter initial vertical dimension is provided for disturbed area to account for any slope variation in the ground. Road Workgroup Final Report Submission to EPA-OAQPS Memo by Tyler Fox on March 2, 2012. Table A-10. Cargill Point Sources Height Temperature Temperature Velocity Diameter (m) (m) (m) (lb/hr) (g/s) (m) (F) (K) (m/s) (m) Fisher-Klosterman Cyclone 4V0AW0SN 359963.00 4512391.00 1287.1 8.82 1.1113 13.41 140 333.15 24.64 1.21 Four Carmen Industries Cyclone 4V0AW0SO 359963.00 4512391.00 1287.1 2.65 0.3339 13.02 140 333.15 15.75 1.21 Central Dust Collection System 4V0AW0SP 359963.00 4512391.00 1287.1 2.02 0.2545 15.54 64.00 290.93 15.24 0.91 BEPEX Press System 4V0AW0SQ 359963.00 4512391.00 1287.1 2.00 0.2520 18.29 80.00 299.82 19.81 0.89 1. Locations estimated using Google Earth. 2. Emission rates based on Cargill's emission point limits as established in approval order DAQE-AN107220016-16, condition II.B.2.f. 3. Stack parameters estimated using Cargill stack test reports obtained from the Utah Division of Air Quality's EQDocs search. Table A-11. Cargill Volume Sources - Location and Emission Rate UTM X UTM Y Elevation (m) (m) (m) (tpy) lb/hr (g/s) Cargill_Fugitve CRGL_F1 359961.2 4512391.3 1287.16 3.99 0.91 0.115 1. The fugitive emission rate is based on the facility's PM10 PTE of 71.84 tons per year as reported in approval order DAQE-AN107220016-16. Table A-12. Cargill Volume Sources - Release Parameters1 Ground to Source/ Structure Min Height Ground to Source/ Building Max Height Source/ Building Width Ground to Source/ Structure Min Height Ground to Source/ Building Max Height Source/ Building Width Release Height2 Initial Lateral Dimension (σy)2 Initial Vertical Dimension (σz)3 (ft) (ft) (ft) (m) (m) (m) (m) (m) (m) Cargill_Fugitve CRGL_F1 Cargill Fugitive 0.00 30.00 30.00 0.00 9.14 9.14 4.57 2.13 4.25 1. Release parameters estimated from aerial imagery of the onsite building dimensions 2. Guidance from AERMOD User’s Guide issued by EPA, September 2004 (EPA-454/B-03-001) is used to determine the release height, i.e. the center of the volume source. 3. The initial lateral dimension is calculated as the width of the volume source divided by a factor of 4.3. AERMOD User’s Guide issued by EPA, September 2004 (EPA-454/B-03-001). 4. If the source is a surface based source or an elevated source on or adjacent to a structure (structure based), the initial vertical dimension would be the vertical dimension of the source divided by 2.15. If the source is an elevated source not on or adjacent to a structure (elevated source), the initial vertical dimension would be the vertical dimension of the source divided by 4.3. AERMOD User’s Guide issued by EPA, September 2004 (EPA- 454/B-03-001). UTM North ElevationModeled ID Description Modeled ID PM10 Emission Rate2 PM10 Emission Rate1 Description Modeled ID Source Description Stack Parameters3 Description2 UTM East Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants B-1 APPENDIX B. BLASTING SCREENING MODEL RESULTS Table B-1. below shows the results of the blasting hour of day screening analysis described in Section 4.2. Gray highlighted rows indicate night-time hours where blasting would not be operationally possible. Daylight hours are highlighted orange or green. Orange indicates hours where the full NAAQS modeling does not predict compliance with the 24-hour PM10 NAAQS. Green indicates compliant hours. Table B-1. Blasting Hour of Day PM10 Screening Analysis Results Avg. Per. Grp ID High Modeled Impact (µg/m3) Date (YYMMDDHH) UTM East (m) UTM West (m) Elevation (m) Hill Ht. Scale (m) Start Hour 24-HR B1 1ST 188.62 9030124 367276.2 4506526.6 1291.81 2786.27 12:00 AM 24-HR B1 6TH 130.35 11041424 367275.6 4506427.8 1305.02 2786.27 12:00 AM 24-HR B2 1ST 158.56 8123124 367295.6 4506427.3 1296.44 2786.27 1:00 AM 24-HR B2 6TH 125.20 10072424 367275.1 4506466.6 1296.78 2786.27 1:00 AM 24-HR B3 1ST 191.45 9123124 367275.1 4506466.6 1296.78 2786.27 2:00 AM 24-HR B3 6TH 124.94 10020624 367275.5 4506486.6 1294.43 2786.27 2:00 AM 24-HR B4 1ST 190.55 8111824 367275.7 4506496.6 1293.6 2786.27 3:00 AM 24-HR B4 6TH 120.57 9122524 367274.9 4506456.6 1298.49 2786.27 3:00 AM 24-HR B5 1ST 156.30 11012424 367275.5 4506486.6 1294.43 2786.27 4:00 AM 24-HR B5 6TH 125.99 9102124 367275.9 4506506.6 1292.87 2786.27 4:00 AM 24-HR B6 1ST 153.84 10011724 367274.7 4506446.6 1300.88 2786.27 5:00 AM 24-HR B6 6TH 125.88 10082324 367275.3 4506476.6 1295.47 2786.27 5:00 AM 24-HR B7 1ST 162.27 10112824 367274.9 4506456.6 1298.49 2786.27 6:00 AM 24-HR B7 6TH 126.09 11110724 367274.9 4506456.6 1298.49 2786.27 6:00 AM 24-HR B8 1ST 157.34 12020524 367275.7 4506496.6 1293.6 2786.27 7:00 AM 24-HR B8 6TH 115.43 11110824 367276.4 4506536.6 1291.44 2786.27 7:00 AM 24-HR B9 1ST 175.42 8022124 367274.4 4506427.8 1305.89 2786.27 8:00 AM 24-HR B9 6TH 110.06 10021724 367275.7 4506496.6 1293.6 2786.27 8:00 AM 24-HR B10 1ST 139.65 10121824 367274.9 4506456.6 1298.49 2786.27 9:00 AM 24-HR B10 6TH 76.73 12121424 367275.1 4506466.6 1296.78 2786.27 9:00 AM 24-HR B11 1ST 72.21 12122424 367274.9 4506456.6 1298.49 2786.27 10:00 AM 24-HR B11 6TH 52.79 9122024 367274.7 4506446.6 1300.88 2786.27 10:00 AM 24-HR B12 1ST 53.95 10122424 367275.3 4506476.6 1295.47 2786.27 11:00 AM 24-HR B12 6TH 37.17 12123024 367275.1 4506466.6 1296.78 2786.27 11:00 AM 24-HR B13 1ST 63.21 9010624 367274.6 4506436.6 1303.52 2786.27 12:00 PM 24-HR B13 6TH 38.72 10011324 367274.6 4506436.6 1303.52 2786.27 12:00 PM 24-HR B14 1ST 59.62 10120424 367275.1 4506466.6 1296.78 2786.27 1:00 PM 24-HR B14 6TH 43.11 10122024 367275.1 4506466.6 1296.78 2786.27 1:00 PM 24-HR B15 1ST 81.09 10010524 367274.7 4506446.6 1300.88 2786.27 2:00 PM 24-HR B15 6TH 47.19 12110924 367274.6 4506436.6 1303.52 2786.27 2:00 PM 24-HR B16 1ST 127.54 10120424 367275.1 4506466.6 1296.78 2786.27 3:00 PM 24-HR B16 6TH 66.82 11122024 367275.1 4506466.6 1296.78 2786.27 3:00 PM 24-HR B17 1ST 134.99 10112924 367274.4 4506427.8 1305.89 2786.27 4:00 PM 24-HR B17 6TH 96.57 10011124 367274.4 4506427.8 1305.89 2786.27 4:00 PM 24-HR B18 1ST 163.75 10112724 367276.2 4506526.6 1291.81 2786.27 5:00 PM Las Vegas Paving | PM10 Modeling Analysis Trinity Consultants B-2 Avg. Per. Grp ID High Modeled Impact (µg/m3) Date (YYMMDDHH) UTM East (m) UTM West (m) Elevation (m) Hill Ht. Scale (m) Start Hour 24-HR B18 6TH 103.21 9112624 367274.4 4506427.8 1305.89 2786.27 5:00 PM 24-HR B19 1ST 166.39 9120124 367274.4 4506427.8 1305.89 2786.27 6:00 PM 24-HR B19 6TH 132.01 8120624 367275.7 4506496.6 1293.6 2786.27 6:00 PM 24-HR B20 1ST 162.16 9122624 367274.4 4506427.8 1305.89 2786.27 7:00 PM 24-HR B20 6TH 131.23 10122524 367274.4 4506427.8 1305.89 2786.27 7:00 PM 24-HR B21 1ST 152.26 10020424 367275.3 4506476.6 1295.47 2786.27 8:00 PM 24-HR B21 6TH 132.61 10010924 367275.1 4506466.6 1296.78 2786.27 8:00 PM 24-HR B22 1ST 157.25 8112724 367274.4 4506427.8 1305.89 2786.27 9:00 PM 24-HR B22 6TH 136.73 10110424 367274.6 4506436.6 1303.52 2786.27 9:00 PM 24-HR B23 1ST 200.55 10060524 367274.9 4506456.6 1298.49 2786.27 10:00 PM 24-HR B23 6TH 129.31 11121224 367276.6 4506546.6 1290.99 2786.27 10:00 PM 24-HR B24 1ST 160.66 8040824 367275.7 4506496.6 1293.6 2786.27 11:00 PM 24-HR B24 6TH 117.79 10062124 367275.9 4506506.6 1292.87 2786.27 11:00 PM DAQE-MN160410001-21 M E M O R A N D U M TO: Sarah Foran, NSR Engineer FROM: Dave Prey, Air Quality Modeler DATE: January 29, 2021 SUBJECT: Modeling Analysis Review for the Notice of Intent for Las Vegas Paving Corporation – Grantsville Pit, Tooele County, Utah This is not a Major Prevention of Significant Deterioration (PSD) Source. I. OBJECTIVE Las Vegas Paving Corporation (Applicant) is seeking a new approval for their Grantsville Pit, located in Tooele County, Utah. This facility consists of an aggregate processing plant. This report prepared by the staff of the NSR contains a review of the Applicant’s Air Quality Impact Analysis (AQIA) including the information, data, assumptions and modeling results used to determine if the facility would be in compliance with State and Federal concentration standards. II. APPLICABLE RULE(S) Utah Air Quality Rules: R307-401-6 Condition for Issuing an Approval Order R307-410-2 Use of Dispersion Models R307-410-4 Modeling of Criteria Pollutants in Attainment Areas III. MODELING METHODOLOGY A. Applicability Emissions from the facility include HAPS, PM10, NOx, CO, SO2, and VOC. The only criteria pollutant that exceeds the modeling threshold is PM10. All other pollutant increases were below modeling thresholds and therefore were not modeled. Modeling for PM10 was performed by the applicant. 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 Interim Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director SF SF DP DP DAQE-MN160410001-21 Page 2 B. Assumptions 1. Topography/Terrain The Plant is at an elevation of 4222 feet with terrain features that have an effect on concentration predictions. a. Zone: 12 b. Approximate Location: UTM (NAD83): 359963 meters East 4512391 meters North 2. Urban or Rural Area Designation After a review of the appropriate 7.5 minute quadrangles, it was concluded the area is “rural” for air modeling purposes. 3. Ambient Air It was determined the Plant boundary used in the AQIA meets the State’s definition of ambient air. 4. Building Downwash The Applicant used the U.S. Environmental Protection Agency (USEPA) Building Profile Input Program (BPIP) to determine GEP stack heights and building dimensions for input into the AERMOD model. Parameters from the stacks and dimensions from buildings were input into the BPIP. It was assumed ground level elevations for the stacks and buildings were the same. The output from BPIP showed all stacks to be less than their GEP formula stack height, thereby, required a wake effect evaluation. 5. Meteorology Five (5) years of off-site surface and upper air data were used in the analysis consisting of the following: Surface – NWS Salt Lake Airport: 2008 - 2012 Upper Air – NWS Salt Lake Airport: 2008 - 2012 6. Background Background concentrations were based on ambient air data monitored in Grantsville, Utah. DAQE-MN160410001-21 Page 3 7. Receptor and Terrain Elevations The modeling domain used by the Applicant consisted of various receptors including property boundary receptors. This area of the state contains mountainous terrain and the modeling domain has simple and complex terrain features in the near and far fields. Therefore, receptor points representing actual terrain elevations from the area were used in the analysis. 8. Model and Options The US EPA AERMOD model was used by the Applicant to predict air pollutant concentrations under a simple/complex terrain/wake effect situation. In quantifying concentrations, the regulatory default option was selected by the Applicant. 9. Air Pollutant Emission Rates Source UTM Coordinates Modeled Emission Rates Easting Northing PM10 (m) (m) (lb/hr) (tons/yr) hrs/year PCR_1 367103 4506463 0.2397 1.006 8395 SCR_1 367093 4506704 0.0675 0.283 8395 TCR_1 367085 4506722 0.0921 0.386 8395 SCRN_1 367079 4506706 0.5921 2.485 8395 SCRN_2 367090 4506712 0.1849 0.776 8395 SCRN_3 367075 4506735 0.1262 0.530 8395 FEED 367103 4506462 0.2437 1.023 8395 C1 367070 4506701 0.0365 0.153 8395 C2 367068 4506706 0.0365 0.153 8395 C3 367070 4506717 0.0365 0.153 8395 C4 367079 4506704 0.0365 0.153 8395 C5 367084 4506705 0.0183 0.077 8395 C6 367090 4506705 0.0183 0.077 8395 C7 367069 4506706 0.0183 0.077 8395 C8 367062 4506707 0.0111 0.047 8395 C9 367092 4506707 0.0111 0.047 8395 C10 367091 4506711 0.0095 0.040 8395 C11 367086 4506717 0.0095 0.040 8395 DST_GRD 367118 4506448 0.0738 0.310 8395 BLLDZR 367067 4506468 0.0413 0.173 8395 C12 367087 4506719 0.0079 0.033 8395 DAQE-MN160410001-21 Page 4 C13 367082 4506725 0.0079 0.033 8395 C14 367078 4506731 0.0074 0.031 8395 C15 367072 4506722 0.0056 0.023 8395 C16 367075 4506713 0.0037 0.015 8395 C17 367081 4506716 0.0037 0.015 8395 C18 367086 4506717 0.0037 0.015 8395 C19 367087 4506719 0.0037 0.015 8395 C20 367082 4506725 0.0018 0.008 8395 C21 367078 4506731 0.0018 0.008 8395 C22 367072 4506722 0.0365 0.153 8395 C23 367075 4506713 0.0365 0.153 8395 C24 367081 4506716 0.0365 0.153 8395 STCK1 367053 4506703 0.2437 1.023 8395 STCK2 367052 4506713 0.0976 0.410 8395 STCK3 367051 4506727 0.0246 0.103 8395 STCK4 367053 4506743 0.0484 0.203 8395 LD1 367104 4506462 0.4865 2.042 8395 LD2 367064 4506702 0.2437 1.023 8395 LD3 367022 4506763 0.4865 2.042 8395 4V0AW0SN 359963 4512391 8.8097 36.979 8395 4V0AW0SO 359963 4512391 2.6191 10.994 8395 4V0AW0SP 359963 4512391 1.9842 8.329 8395 4V0AW0SQ 359963 4512391 1.9842 8.329 8395 CRGL_F1 359961 4512391 0.9127 3.831 8395 QL_RD1 367108 4506461 0.0540 0.227 8395 QL_RD2 367117 4506461 0.0540 0.227 8395 QL_RD3 367126 4506460 0.0540 0.227 8395 QL_RD4 367135 4506460 0.0540 0.227 8395 PRDLD_RD 367022 4506767 0.1008 0.423 8395 SPA 366997 4506763 0.0089 0.037 8395 SPB 366987 4506802 0.0089 0.037 8395 SPC 366968 4506765 0.0089 0.037 8395 SPD 366974 4506740 0.0089 0.037 8395 SPE 366966 4506711 0.0089 0.037 8395 SPF 366977 4506683 0.0026 0.011 8395 SPG 366989 4506663 0.0026 0.011 8395 SPH 367012 4506661 0.0026 0.011 8395 DAQE-MN160410001-21 Page 5 SPI 367030 4506669 0.0026 0.011 8395 SPJ 366899 4506969 0.2334 0.980 8395 B1_50 367193 4506461 28.7784 5.252 365 B1_OBODM 367193 4506461 0.0000 0.000 0 M_RD 0.1306 0.548 8395 H_RDX 0.5622 2.360 8395 H_RDE 0.0883 0.371 8395 H_RDW 0.1279 0.537 8395 Total 50.2932 95.5606 Source Location and Parameters Source Type Source Parameters Elev Ht Temp Flow Dia Sigma-Y Sigma-Z X-Dim Y-Dim Area (ft) (m) (ft) (K) (m/s) (ft) (m) (m) (m) (m) (m^2) PCR_1 VOLUME 4499.2 2.3 7.5 0.00 2.13 2.0322 SCR_1 VOLUME 4253.1 2.3 7.5 0.00 2.13 2.0322 TCR_1 VOLUME 4261.9 2.3 7.5 0.00 2.13 2.0322 SCRN_1 VOLUME 4258.5 2.3 7.5 0.00 2.13 2.0322 SCRN_2 VOLUME 4261.5 2.3 7.5 0.00 2.13 2.0322 SCRN_3 VOLUME 4263.9 2.3 7.5 0.00 2.13 2.0322 FEED VOLUME 4498.9 2.3 7.5 0.00 2.13 0.9146 C1 VOLUME 4264.1 1.2 4.0 0.00 0.57 0.9146 C2 VOLUME 4266.2 1.2 4.0 0.00 0.28 0.9146 C3 VOLUME 4268.3 1.2 4.0 0.00 0.28 0.9146 C4 VOLUME 4257.1 1.2 4.0 0.00 0.28 0.9146 C5 VOLUME 4255.0 1.2 4.0 0.00 0.28 0.9146 C6 VOLUME 4254.7 1.2 4.0 0.00 0.28 0.9146 C7 VOLUME 4265.2 1.2 4.0 0.00 0.28 0.9146 C8 VOLUME 4276.9 1.2 4.0 0.00 0.28 0.9146 C9 VOLUME 4256.6 1.2 4.0 0.00 0.28 0.9146 C10 VOLUME 4260.7 1.2 4.0 0.00 0.28 0.9146 C11 VOLUME 4261.6 1.2 4.0 0.00 0.28 0.9146 DST_GRD AREA_CIRC 4489.6 0.0 0.0 80.30 0.00 2.00 20257.3 BLLDZR AREA 4526.8 3.4 11.2 0.00 3.16 65 130 8450 DAQE-MN160410001-21 Page 6 C12 VOLUME 4261.5 1.2 4.0 0.00 0.28 0.9146 C13 VOLUME 4262.6 1.2 4.0 0.00 0.28 0.9146 C14 VOLUME 4263.4 1.2 4.0 0.00 0.28 0.9146 C15 VOLUME 4267.7 1.2 4.0 0.00 0.28 0.9146 C16 VOLUME 4264.2 1.2 4.0 0.00 0.28 0.9146 C17 VOLUME 4262.4 1.2 4.0 0.00 0.28 0.9146 C18 VOLUME 4261.6 1.2 4.0 0.00 0.28 0.9146 C19 VOLUME 4261.5 1.2 4.0 0.00 0.28 0.9146 C20 VOLUME 4262.6 1.2 4.0 0.00 0.28 0.9146 C21 VOLUME 4263.4 1.2 4.0 0.00 0.28 0.9146 C22 VOLUME 4267.7 1.2 4.0 0.00 0.28 0.9146 C23 VOLUME 4264.2 1.2 4.0 0.00 0.28 0.9146 C24 VOLUME 4262.4 1.2 4.0 0.00 0.28 0.9146 STCK1 VOLUME 4292.7 8.4 27.5 0.00 0.35 0.9146 STCK2 VOLUME 4284.2 8.4 27.5 0.00 0.35 0.9146 STCK3 VOLUME 4285.4 8.4 27.5 0.00 0.35 0.9146 STCK4 VOLUME 4275.2 8.4 27.5 0.00 0.35 0.9146 LD1 VOLUME 4498.6 3.8 12.5 0.00 1.06 2.4992 LD2 VOLUME 4276.2 3.8 12.5 0.00 1.06 2.4992 LD3 VOLUME 4253.4 3.8 12.5 0.00 1.06 2.4992 4V0AW0SN POINT 4222.8 13.4 44.0 333 24.64 1.21 0.00 4V0AW0SO POINT 4222.8 13.0 42.7 333 15.75 1.21 0.00 4V0AW0SP POINT 4222.8 15.5 51.0 291 15.24 0.91 0.00 4V0AW0SQ POINT 4222.8 18.3 60.0 300 19.81 0.89 0.00 CRGL_F1 VOLUME 4223.0 4.6 15.0 0.00 4.25 9.159 QL_RD1 VOLUME 4494.6 2.6 8.4 0.00 2.37 43.989 QL_RD2 VOLUME 4485.9 2.6 8.4 0.00 2.37 43.989 QL_RD3 VOLUME 4478.0 2.6 8.4 0.00 2.37 43.989 QL_RD4 VOLUME 4469.0 2.6 8.4 0.00 2.37 43.989 PRDLD_RD VOLUME 4249.4 2.6 8.4 0.00 2.37 43.989 SPA AREA_CIRC 4246.2 3.1 10.0 11.30 0.00 1.42 401.15 SPB AREA_CIRC 4240.3 3.1 10.0 11.30 0.00 1.42 401.15 SPC AREA_CIRC 4242.8 3.1 10.0 11.30 0.00 1.42 401.15 SPD AREA_CIRC 4260.7 3.1 10.0 11.30 0.00 1.42 401.15 SPE AREA_CIRC 4288.2 3.1 10.0 11.30 0.00 1.42 401.15 SPF AREA_CIRC 4308.6 3.1 10.0 11.30 0.00 1.42 401.15 SPG AREA_CIRC 4344.7 3.1 10.0 11.30 0.00 1.42 401.15 DAQE-MN160410001-21 Page 7 SPH AREA_CIRC 4356.9 3.1 10.0 11.30 0.00 1.42 401.15 SPI AREA_CIRC 4356.5 3.1 10.0 11.30 0.00 1.42 401.15 SPJ AREA_POLY 4233.4 3.1 10.0 0.00 1.42 10580.6 B1_50 VOLUME 4383.6 7.6 25.0 0.00 3.54 70.71 1 B1_OBODM VOLUME 4383.6 35.4 116.0 0.00 16.44 70.71 1 M_RD LINE- VOLUME H_RDX LINE- VOLUME H_RDE LINE- VOLUME H_RDW LINE- VOLUME IV. RESULTS AND CONCLUSIONS A. NAAQS The below table provides a comparison of the predicted total air quality concentrations with the NAAQS. The predicted total concentrations are less than the NAAQS. Pollutant Period Prediction Others Background Total NAAQS Percent (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS PM10 24- Hour 93.30 0.00 50 143.3 150 95.5% V. PERMIT CONDITIONS The following suggested permit language should be included under the Terms and Conditions in the AO.  Blasting may occur one (1) hour per day between the hours of 10:00 am and 4:00 pm.  Drilling and Blasting may not occur on the same day.  The facility may operate only when the Lhoist facility is not operating.  All operations except blasting must not operate during the hour that blasting occurs. DP:sa Signature: Email: Signature: Email: Sarah Foran (Feb 1, 2021 10:00 MST) Sarah Foran . ! * - ) ½ 0 / # u " * 1 Dave Prey (Feb 2, 2021 09:04 MST) dprey@utah.gov Agenda Meeting with Utah Division of Air Quality Las Vegas Paving – Grantsville, Utah New Approval Order November 25, 2020, 1 PM MT MEETING ATTENDEES Dan Peressini – Las Vegas Paving Sarah Foran – UDAQ Permit Engineer Danny Fitzgerald – Las Vegas Paving Justin Andrews – Lhoist North America Ana Williams – UDAQ Permit Engineer Dave Prey – UDAQ Modeling Engineer Brian Mensinger – Trinity Consultants Chase Peterson – Trinity Consultants AGENDA ITEMS 1. Introductions 2. Meeting Objective 3. NOI Application Project Description and Location o Aggregates Mining, Crushing and Screening, and Wash Plant o LVP and Lhoist Operational Schedule Emission Calculations and Netting Regulatory Applicability Best Available Control Technology (BACT) Analysis Modeling 4. Timing and Project Schedule Application Submittal and Approval 5. 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