SOUTHWEST REGIONAL OFFICE MEMO

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Air Quality Permit File SOOP # 56-00025

Jesse S. Parihar Air Quality Engineering Specialist Air Quality Program

Thomas J. Jose;~ Environmental ~~ Air Quality Program

April 26, 2016

Mark R. Gorog, P.E./111 f} h Regional Program Manager Air Quality Program

Review of SOOP Renewal Application New Enterprise Stone & Lime Company, Inc. Bakersville Quarry Jefferson Township, Somerset County AUTH # 1107283; APS# 890540; PF# 250166

BACKGROUND:

New Enterprise Stone & Lime Company, Inc. (NESL) supplies aggregates, lime, stone, and concrete products for a variety of applications. The NESL Company was originally founded in 1977, which owns and operates limestone, dolomite, gravel, and sandstone mines; stone and sand quarries; ready-mix concrete; and hot-mix blacktop plants throughout Pennsylvania, western New York, and Delaware. Subsidiaries include Buffalo Crushed Stone, Martin Limestone, Valley Quarries, and the Port of Buffalo on eastern Lake Erie. NESL operates under SIC Code No. 1422 - Mining - Crushed and Broken Limestone. The original authorized Operating Permit was issued on September 16, 1977, for the crushing and screening process of limestone construction aggregates. The original permit renewal application was received on June 16, 1997, which was updated with site inventory on June 1, 2001 , August 8, 2003 , December 2, 2005, August 6, 2008, and March 1, 2011 to include equipment authorized through various plan approvals.

On November 25, 2015, the Department received a State Only Operating Permit (SOOP) renewal application for NESL/Bakersville Quarry for the operation of a limestone crushing and screening plant located in Jefferson Township, Somerset County. NESL has complied with the municipal notification requirements contained in 25 Pa. Code §127.413 and the application fee requirements contained in 25 Pa. Code §127.703(b)(3). On February 4, 2016, the applicant was informed that his application was determined to be administratively complete. Currently, the facility is operating under SOOP 56-00025 issued on April28, 2011 , and expiring on April28, 2016.

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NOV:

On September 13, 2012, the Department sent NESL, a notice of violation (NOV) per 25 Pa Code § 123 .2, for emitting the fugitive particulate emissions into the outdoor atmosphere via trucks exiting the plant's haul road onto SR 31. On August 2, 2013, the Department and NESL entered into a Consent Assessment of Civil Penalty (CACP) and a civil penalty in the amount of one thousand five hundred dollars ($ 1 ,500) was received from NESL. No other violations have been noted since the last issued operating permit.

RFD:

On February 9, 2016, the Department received a request for determination (RFD) from NESL for the addition of three (3) new sources in the existing facility which include a screen (Deister 7x16) rated at 890 tph and two (2) Crushers; AC 1650 Crushed and AC 6-51 Crusher; each rated at 200 tph. On April21 , 2016, the RDF was approved by the Department as a de-minimis emission increase under 25 PA Code §127.449 and per 25 Pa. Code §127.14(d) listed as No. 36 in the Department's Plan Approval and Operating Permit Exemptions list under 25 Pa. Code §127.14(a)(8). These sources are being included in Source ID 108 in this operating permit renewal. All the additional sources are equipped with water spray systems and have not resulted in an emission increase beyond existing operating permit limitations.

SOURCES, CONTROL DEVICES and EMISSIONS:

NESL operates under an active Large Surface Mining Permit (SMP-4074SM12) last issued on April 5, 2007. Limestone is crushed into various construction aggregate products. The site has been in operation since 1977.

Source 108- Crushing/Screening Process:

The processing plant consists of nine crushers, eight screens, three water spray systems, two baghouses, and approximately 13 stockpiles. This includes the equipment described in the above RFD.

Boulders/shot rock from the quarry face is loaded onto off road trucks and hauled to the primary crusher (Allis-Chalmers 4265). The 36" minus rock is reduced to a 1 0" minus rock through this crusher. The 1 0" minus rock is conveyed to the secondary plant where it is conveyed to the Hewlett-Robbins 8x20 screen. 1 W' minus rock is separated from the flow and conveyed either to the 2A-2RC stockpile or it is further screened after being conveyed to a stockpile. The material is then hauled to the quarry face for use in reclamation. 1 W' minus - 7 /8" plus rock from this screen is conveyed back to the crushing plant for further processing. 1 W' plus rock from the Hewlett-Robbins screen is conveyed to the Telsmith 6614 crusher for further reduction. This rock is then conveyed

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to the Telsmith 5x12 screen where 2A and #4 sized rock is removed from the flow and conveyed to the stockpiles.

The remaining rock is conveyed to the Allis-Chalmers 600 crusher for further reduction. Material from this crusher is conveyed to the two Telsmith 8x24 screens where lB, 2B and dust is removed from the flow and conveyed to stockpiles. Alternatively, the 1B, 2B or dust can be conveyed to the wet plant and washed. Oversized material from the two 8x24 screens is conveyed to the two Allis-Chalmers 60" crushers for further reduction and then conveyed back to the two 8x24 screens for separation into final products.

There is a second crushing operation available where rock from the original quarry is hauled to the Telsmith 3648 jaw crusher and is reduced to a minus 6" rock. This rock is conveyed to a Telesmith 5x14 screen to separate out the 1 W' minus rock. The 1 W' plus rock is conveyed to the Allis-Chalmers 1650 crusher for further reduction. This material is then conveyed to the Telsmith 5x12 screen described above and then conveyed to the remainder of the plant as described above.

The potential emissions generated by this operation are controlled though the use of the three water-spray systems and two (2) Aeropulse Baghouse Collection Systems. Aeropulse (PR225-12) Baghouse is rated at 23 ,000 ACFM at ambient temperature with 99.9 percent removal efficiency and Aeropulse (PR225-10) Baghouse, is rated at 10,000 ACFM at ambient temperature with 99% (ninety nine percent) removal efficiency. NESL can obtain water from two different sources, primarily a spring and also from the pit pond as needed. Water to the crushing plant holding tank was previously supplied by the spring only. However, NESL installed a new water line to connect the upper pit pond supply line to the holding tank for the crushing plant. NESL maintains and operates two water trucks as needed to minimize fugitive emissions from the roadways. The facility generally operates from mid-March until mid-November, weather depending. The facility estimates a maximum seasonal operation of 5,700 hours per year. The facility utilizes electricity supplied by an electric utility company. There are no emergency generators on-site.

A list of the equipment as approved by the Department via RFD is given below on the following Table.

Table: 1 Proposed Equipment (RFD)

ID # Maximum Throughput Equipment (tph) Operating Hours

*015 Deister 7x 16 Screen 890 1,800 016 Allis-Chalmers 1650 Crusher 200 5,700 017 Allis-Chalmers 6-51 Crusher 200 5,700

• De1ster 7x 16 Screen 1s llm1ted to 1,800 hours of operation.

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The following is the previously installed equipment and its operating status at NESL quarry.

Table: 2 Existing Crushing/Screening Equipment

Maximum Mfg. Operating ID# Equipment Throughput Date Status

(tonslhr) 001 Allis-Chalmers 4265 Gyratory Crusher 1,500 1967 Yes

Primary (Bakersville #2) 002 Hewlett-Robbins 8x20 Vibratory Screen 1,000 1980 Yes

Secondary (Bakersville # 1) 003 SECO 8x20 Vibratory Screen 100 1989 Seldom

Secondary (Bakersville # 1) 004 Telsmith 6614 Crusher 900 1963 Yes

Secondary (Bakersville # 1) 005 Telsmith 5x12 Vibratory Screen 700 1953 Yes

Tertiary (Bakersville #1-Bottom Plant) 006 Allis-Chalmers 600 Crusher 600 1973 Yes

Terti~_ (Bakersville # 1-Bottom Plant) 007 Telsmith 8x24 Vibratory Screen 600 1983 Yes

Tertiary (Bakersville #1 -Bottom Plant) 008 Telsmith 8x24 Vibratory Screen 225 1997 Yes

Tertiary (Bakersville #1 -Bottom Plant) 009 Allis-Chalmers 60 Crusher 225 1959 Yes

Tertiary (Bakersville #1 -Bottom Plant) 010 Allis-Chalmers 60 Crusher 225 1980 Yes

Tertiary (Bakersville #1-Bottom Plant) 011 Telsmith 5x12 Wet Screen 225 1988 Yes

Tertiary (Bakersville #1-Bottom Plant) *012 Telsmith 3648 Jaw Crusher 300 1989 Not Used

Tertiary (Bakersville #1 -Bottom Plant) 020 Telsmith 8x24 Screen 225 2008 Yes

013 Telsmith 5x14 Vibratory Screen 300 1998 Removed Tertiary (Bakersville #1-Bottom Plant)

014 Allis-Chalmers 1650 Crusher 250 1987 Removed Tertiary (Bakersville # 1-Bottom PI ant)

-Note: Source ID # 013, Telsmtth 5xl4 Vtbratory Screen and Source lD #014, Allts-Chalmers 16:>0 Crusher was removed from stte according to Philip Sapala 's inspection report dated August 29, 202 2.

* As reported by field staff, Telsmith 3648 Jaw Crusher is out of operation for more than one year and no maintenance plan has been submitted. The source has been removed from the operating permit and authorization by the Department will be required before the source resumes the operation.

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The facility-wide projected emission from all the equipment which includes crushers, screens, truck loading/un-loading, stockpiles, and RFD is shown below in Table 3.

Table: 3 miSSIOD s 1ma e rom e XIS mg ources E . . E f t f th E . f S

Estimate Emission PM Estimate Emission PM10

Sources (lbslhr) (tpy) (lbslhr) (tpy)

Crushers 4.80 13.68 2.16 6.16

Screens 6.93 19.75 2.33 6.64

Truck 0.05 0.14 0.024 0.07 Loading!U nloading

Stockpiles 12.33 35.14 5.83 16.62

Unpaved Roadways 8.56 24.40 2.44 6.95

RFD - 1.55 - 1.55

Total 32.67 94.66 12.784 36.44

I. The emission estimate based on AP-42 emission factors. 2. The emission estimate is based on 5,700 hours of operation per year for all the equipment except for Deister 7xl6 screen which

is limited to 1,800 hours of operation per year. 3. The un-paved haul roadways emission for 900 feet length. 4. Values may be slightly off due to rounding.

REGULATORY ANALYSIS:

NESL is subject to the applicable requirements ofPA Code, Chapters 121 through 145 as incorporated into the proposed operating permit.

40 CFR Part 60, Subpart 000-Standard Performance for Nonmetallic Mineral Processing Plants was promulgated on August 1, 1985. Per §60.670(a), this subpart is applicable to the following affected facilities in fixed or portable nonmetallic mineral processing plants: each crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truck or railcar loading station. Per §60.670(e), an affected facility under paragraph (a) of this section that commences construction, modification, or reconstruction after August 31, 1983, is subject to the requirements of this part. The facility has been modified since 1983. Therefore the facility is subject to the emissions, testing, reporting, and recordkeeping requirements. Applicable requirements are incorporated into this proposed operating permit renewal.

The facility is subject to all the emission limits of a synthetic minor facility and also the following special conditions in addition to those above:

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• 25 Pa Code § 121.7 (Prohibition of air pollution). • New malfunctioning condition by replacing the previously established condition. • Deister 7x 16 Screen rated at 890 tph is limited to 1 ,800 hours of operation and the

owner/operator shall keep records of hours of operation.

RECOMMENDATIONS:

On June 21 , 2013 , an annual compliance monitoring inspection was performed by Mr. Phil Sapala, Air Quality Specialist. The Department has not noted any violations at the time of the inspection. It is my recommendation that the State Only Operating Permit renewal for New Enterprise Stone & Lime Company, Inc./Bakersville Quarry, SOOP 56-00025 , be issued.

On January 16, 2016, the "Intent to issue Notice" was published in the PA Bulletin for a 30-day public comment period or to date. No comments were received from the public during the commenting period. The proposed Operating Permit renewal will be submitted to NESL for review as well as the Department' s Air Quality Specialist and District Supervisor for any comments.

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