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Home My WebLink About20173849.tiffCOLORADO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 November 1, 2017 Dear Sir or Madam: RECEIVED NOV 062017 WELD COUNTY COMMISSIONERS On November 2, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Martin Marietta Materials, Inc. - Highway 34. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Pc.)bI;c RVle.w cc=PLCml1`)/ TP), HL.C3T,) / 1 3 / i 7 PGuC£R /CH IJ'M/CK) 11(?/ I7 2017-3849 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Martin Marietta Materials, Inc. - Highway 34 - Weld County Notice Period Begins: November 2, 2017 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Martin Marietta Materials, Inc. Facility: Highway 34 Asphalt Paving Materials Plant South Half of Section 18, Township 5N, Range 67W Weld County The proposed project or activity is as follows: Construction of a new asphalt paving materials plant. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE0578 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: KC Houlden Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd®state.co.us AIR POLLUTION CONTROL DIVISION PRELIMINARY ANALYSIS PERMIT NUMBER: 17WE0578 DATE: October 31, 2017 APPLICANT: Martin Marietta Materials, Inc. ENGINEER: KC Houlden - CP SUPERVISOR: R K Hancock Ili, PE PROJECT DESCRIPTION The company listed above has applied for an air emission permit to construct and operate a asphalt paving materials plant, to be located at South half of Section 18, Township 5N, Range 67W, Weld County, Colorado. Air Emissions Potential to Emit Controlled Emissions (Permit Pollutant Limit) CO 162.5 tons/yr 39.0 tons/yr The Division has determined that the above emission source will comply with all applicable regulations and standards, and plans to issue emission permits for each facility. Copies of the draft permits are included in the public comment packets. SOURCE CLASSIFICATION Martin Marietta Materials, Inc. proposes to construct and operate an asphalt paving materials plant. The facility has the potential to emit (PTE) 162.5 tons of Carbon Monoxide (CO) per year. The draft permit has limitations that will reduce emissions to 39.0 tons per year of CO. Since this source has the potential to emit greater than 100 tons per year of CO, but is willing to accept limits to bring the emissions below 100 tons per year, this source is considered to be a synthetic minor source for CO and as such, this permit is subject to public comment per Regulation 3, Part B, Section III.C.1. Permit number: Date issued: Issued to: DC) on trol Division Department of Public Health & Environment CONSTRUCTION PERMIT 17WE0578 Issuance: 1 Martin Marietta Materials, Inc. Facility Name: Plant AIRS ID: Physical Location: County: General Description: Highway 34 Asphalt Plant 123/9E8B South half of Section 18, Township 5N, Range 67W Weld Asphalt paving material plant, and associated materials storage, unloading, loading and stockpiles facility Equipment or activity subject to this permit: AIRS Point Description Allowable Fuels 003 One (1) MAKE: Gencor, Model: Ultradrum Model 500, Serial Number: TBD, Counter Flow Drum Mix plant, design rated at 500 tons per hour. One (1) MAKE: Gencor, Model: Ultrall-150H, Serial Number: TBD, Burner design rated at 150 MMBTU/hr. Particulate matter emissions are controlled by a fabric filter bag house with a knock -out box. Silo emissions, of particulate matter, are controlled by a fabric filter baghouse. natural gas Fugitive emissions of particulate matter resulting from on -site truck traffic and material handling. Particulate control measures listed at the end of this permit are used to control fugitive emissions. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25- 7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL APPROVAL 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS) COLORADO Air Pollution Control Division P;ttic 1natth 9 F.itvtltrrrwit Page 1 of 13 form to the Divi'i. ."' he •" e • "" rt '• • form . be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever is later, compliance with the conditions contained on this permit must be demonstrated to the Division. It is the permittee's responsibility to self certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit or enforcement action by the Division. Information on how to certify compliance was mailed with the permit or can be obtained from the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Reference: Regulation Number 3, Part B, IlI.G.2). 3. This permit will expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either the date of issuance of this initial approval permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; or (iii) does not complete construction within a reasonable time of the estimated completion date (See General Condition Number 6., Item 1.). Upon a showing of good cause by the permittee, the Division may grant extensions of the permit. (Reference: Regulation Number 3, Part B, III.F.4.) 4. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever is later, the operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self - certification process. (Reference: Regulation Number 3, Part B, III.G.2.) 5. The owner or operator must develop an operating and maintenance (O&M) plan, along with a recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. Compliance with the O&M plan must commence at startup. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever is later, the owner or operator must submit the O&M plan to the Division. Failure to submit an acceptable operating and maintenance plan could result in revocation of the permit. Note that the Division may modify the monitoring requirements as part of the Title V Operating Permit if this facility is subject to Title V permitting (Reference: Regulation Number 3, Part B, III.G.7.). 6. Within thirty (30) days after commencement of operation or issuance of this permit, whichever is later, the permit number must be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 7. The serial number of the subject equipment must be provided to the Division within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever is later. (Reference: Regulation Number 3, Part B, III.G.2.) EMISSION LIMITATIONS AND RECORDS 8. Emissions of air pollutants must not exceed the following limitations. Monthly records of the actual emission rates must be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4.) COLORADO Air Pollution Control Division _T?:mem of Public hlEy?ry fi E:+r nr,Cn1 Page 2 of 13 Quarter of annual nilAR Production limit (tons) Tons per Quarter (point source emissions) PM PMio PM2,5 NO. SO2 VOC CO Dec. - Feb. 6 36,000 0.48 0.12 0.03 0.47 - 0.74 2.34 Mar. - May 14 84,000 1.12 0.27 0.07 1.10 - 1.71 5.46 June - Aug. 47 282,000 3.76 0.90 0.24 3.67 - 5.73 18.33 Sept. - Nov. 33 198,000 2.64 0.63 0.17 2.58 - 4.02 12.87 Rolling 12 Month Total 100 600,000 8.0 1.9 0.5 7.8 - 12.2 39.0 The owner or operator must calculate quarterly emissions based on the calendar month. Annual Limits: AIRS Point Tons per Year Emission Type pM Palo PM2.5 NO. SO2 VOC CO 003 8.0 1.9 0.5 7.8 - 12.2 39.0 Point 003 1.3 0.4 0.1 - - - Fugitive See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Note: In the absence of credible evidence to the contrary, compliance with the fugitive emission limits is demonstrated by complying with the production limits listed below and by following the attached particulate emissions control plan. During the first twelve (12) months of operation, compliance with both the quarterly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. All emission calculations must be made using the emission factors and format specified in Notes to Permit Holder. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 9. The particulate emission control measures listed on the attached page (as approved by the Division) must be applied to the particulate emission producing sources as required by Regulation Number 1, III.D.1.b. 10. The following control equipment must be maintained and operated to ensure satisfactory performance. The uncontrolled emissions must be reduced by at least the control efficiencies listed below. The owner or operator must monitor compliance with this condition through the results of approved compliance tests (when required), compliance with the Operating and Maintenance Plan, compliance records, and other methods as approved by the Division. (Reference: Regulation Number 3, Part B, III.E.) COLORADO Air Pollution Control Division axi mat Ptbhc Heat ) s trrs ron:rc:it Page 3 of 13 Description AIRS Point Control Device Controlled Pollutants Main stack 003 Fabric filter baghouse PM, PM10, PM2.5 Storage silo 003 Fabric filter baghouse PM, PM10, PM2.5 PROCESS LIMITATIONS AND RECORDS 11. This source must be limited to the following maximum consumption, processing and/or operational rates as listed below. Quarterly and Annual records of the actual process rate must be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Quarterly Limits % of annual HMA Produced (tons) Dec. - Feb. 6 36,000 Mar. - May 14 84,000 June - Aug. 47 282,000 Sept. - Nov. 33 198,000 Rolling 12 Month Total 100 600,000 Process/Consumption Limits AIRS Point Process Parameter Annual Limit 003 Production of asphalt must not exceed 600,000 tons During the first twelve (12) months of operation, compliance with both the quarterly and yearly process limitations must be required. After the first twelve (12) months of operation, compliance with only the yearly limitation must be required. Compliance with the yearly process limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate monthly process rates and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. Visible emissions must not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions must not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Opacity must be determined using EPA Method 9. (Reference: Regulation Number 1, II.A.1. It 4.) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. This source is subject to Regulation No. 6 - Standards of Performance for New Stationary Sources, Part A - Federal Register Regulations Adopted By Reference, Subpart I - Standards of Performance for Hot Mix Asphalt Facilities, including, but not limited to, the following: COLORADO Air Pollution Control Division c'epw-tr?te g of Pubt;c Heath s Puri ori°f;C:'!; Page 4 of 13 [The requiremen " . - ow r= t " =" e ` • of 4Part 60 Subpart I published in the Federal Register on 4/10/1986. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart I.] a. Concentration of particulate matter in the gases discharged into the atmosphere shall not be in excess of 0.04 grain per dry standard cubic foot. Discharge into the atmosphere shall not exhibit 20 % opacity, or greater. 15. The owner or operator of this facility is subject to the following requirements of Regulation Number 6, Part A, Subpart A, General Provisions (40CFR part 60, Subpart A). a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation 6, Part A. General Provisions from 40CFR60.11) b. No article, machine, equipment or process shall be used to conceal an emission that would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard that is based on the concentration of a pollutant in the gases discharged to the atmosphere. (5 60.12) c. Records of startups, shutdowns, and malfunctions shall be maintained, as required under S 60.7. d. Performance tests shall be conducted as required under 5 60.8. e. Compliance with opacity standards shall be demonstrated according to S 60.11. 16. This source is located in an ozone non -attainment or attainment -maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2. RACT for this source is determined to be "no control" due to limits on fuel use and emissions and the excessive cost per ton of emission removed. OPERATING Et MAINTENANCE REQUIREMENTS 17. The owner or operator must develop an operating and maintenance (O&M) plan, along with a recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. Compliance with the O&M plan must commence at startup. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever is later, the owner or operator must submit the OEtM plan to the Division. Failure to submit an acceptable operating and maintenance plan could result in revocation of the permit. Note that the Division may modify the monitoring requirements as part of the Title V Operating Permit if this facility is subject to Title V permitting (Reference: Regulation Number 3, Part B, III.G.7.). 18. Using a portable emissions analyzer or similar emissions measurement device, the drum burner must be tuned at least annually. Tuning activities must be recorded in a plant maintenance log book and made available for Division review upon request. (Reference: Regulation Number 3, Part B III.E.) E. ) COLORADO I Air Pollution Control Division £°deft:.Of P3v`?ice HfilNf J Environment Page 5 of 13 COMPLIANCE TESTI Initial Testing Requirements 19. The owner or operator must demonstrate compliance with Condition 14 (NSPS Subpart I), using EPA Method 9 to measure opacity from the main stack. For purposes of determining initial compliance, the minimum total time of observations must be 3 hours and the opacity observations must be conducted concurrently with the initial performance test required in $60.8. (Reference: Regulation Number 6, Part A, Subpart A, General Provisions S 60.11) 20. A source initial compliance test must be conducted at the main stack on this plant to demonstrate compliance with the pollutant emission rates listed below. The test protocol, test and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual using EPA approved methods. The protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test must be conducted without prior approval from the Division. (Reference: Common Provisions II.C and Regulation Number 3, Part B; IIl.G.3) Particulate Matter (PM): 8.0 tons per year 0.0265 pounds per ton of asphalt produced 0.04 grains per dscf of exhaust. (NSPS Subpart I) Carbon Monoxide (CO): 39.0 tons per year 0.13 pounds per ton of asphalt produced Oxides of Nitrogen (NOx): 7.8 tons per year 0.026 pounds per ton of asphalt produced ADDITIONAL REQUIREMENTS 21. The permit number must be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 22. A revised Air Pollutant Emission Notice (APEN) must be filed: (Reference: Regulation Number 3, Part A, II.C) a. By April 30 of the year following a significant increase in emissions. A significant increase in emissions is defined as follows: For any criteria pollutant: For sources emitting less than 100 tons per year of a criteria pollutant, a change in annual actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO„) in ozone nonattainment areas emitting less than one hundred tons ot VOC or NO„ per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more of a criteria pollutant, a change in annual actual emissions of five percent or fifty (50) tons per year or more, whichever is less, above the level reported on the last APEN submitted; or COLORADO Air Pollution Control MIAs n tie.'proirrwnt :>f I attic i{eam & &I . -Torment Page 6 of 13 For sources emitting -any amount of lead, a change in actua[ emissions of fifty (50) pounds of lead above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 23. Public access must be precluded in all areas within the modeling receptor exclusion zone as submitted with the modeling in the application. The exclusion zone must be fenced and/or contain other barriers to entry and be posted with no trespassing signs. (Reference: Regulation Number 3, Part B, III.B.5) 24. The operations of the asphalt plant, asphalt plant silo loading, asphalt plant screen and material transfers, asphalt plant material transfers, and asphalt plant lime silo are limited to the hours of 5:00 am to 9:00 pm daily. HMA truck loading, hot oil heaters, and asphalt cement silos are not limited by operational hours. 25. The facility must be constructed using the approximate layout and road locations depicted in the application and attachment A of this permit. GENERAL TERMS AND CONDITIONS: 26. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the Division as provided in Regulation Number 3, Part B, II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 27. If this permit specifically states that final approval has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit is considered initial approval and does not provide "final" approval for this activity or operation of this source. Final approval of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, III.G. Final approval cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final approval. Details for obtaining final approval to operate are located in the Requirements to Self -Certify for Final Approval section of this permit. The operator must retain the permit final approval letter issued by the Division after completion of self -certification with the most current construction permit. 28. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations COLORADO ution Control Muni; Page 7 of 13 made by the app = ` or a:: a ` .�en valid o "'' or the equipment and operations or activity(ies) specifically identified in this permit. If subsequent operations or testing at the source indicate the information supplied to obtain this permit and relied upon in the creation and issuance of this permit is inaccurate, the source must submit an application to modify the permit to address the inaccuracy(ies). (Reference: Regulation Number 3, Part B III.E.) By: By: KC Houlden Permit Engineer rmit Histo R K Hancock III, P.E. Construction Permits Unit Supervisor Issuance Date Description Issuance #1 This Issuance Issued to Martin Marietta Materials, Inc. Notes to permit holder: 1) The production or raw material processing limits and emission limits contained in this permit are based on the production/processing rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedence of any specific emission control regulation or any ambient air quality standard. A revised air pollutant emission notice (APEN) and application form must be submitted with a request for a permit revision. (Reference: Regulation Number 3, Part B II.A.4.) 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, ' followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc- regs. 3) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (lb/yr) Are the emissions reportable ? Controlled Emission Rate (lb/yr) 003 Hexane 110543 552 YES 552 Toluene 108883 90 NO 90 Formaldehyde 50000 1860 YES 1860 Benzene 71432 234 NO 234 `COLORADO Air Pollution Control Division De a :nutet of P.wtt Hftith Eravirz,nmeqt Page 8 of 13 5) The emission levels contained in this permit are based on the following emission factors: Point 001 Drum Mixer when operating on. Natural Gas: Pollutant Emission Uncontrolled lb/ton of asphalt Factors - Source Emission Controlled lb/ton of asphalt Factors - Source PM 28.0000 AP -42 11.1-3 0.02649 Division derived PM10 6.5000 AP -42 11.1-3 0.00615 Division derived PM2.5 1.5400 AP -42 11.1-4 0.00146 Division derived NO„ 0.0260 AP -42 11.1-7 0.0260 AP -42 11.1-7 CO 0.13 AP -42 11.1-7 0.13 AP -42 11.1-7 VOC 0.0320 AP -42 11.1-7 0.0320 AP -42 11.1-7 Hexane 0.00092 AP -4211.1-10 0.00092 AP -4211.1-10 Toluene 0.00015 AP -42 11.1-10 0.00015 AP -42 11.1-10 Formaldehyde 0.0031 AP -42 11.1-10 0.0031 AP -42 11.1-10 Benzene 0.00039 AP -42 11.1-10 0.00039 AP -42 11.1-10 Point 001 Asphalt Silo: Pollutant Emission Factors Uncontrolled lb/ton of asphalt - Source Emission Factors Controlled lb/ton of asphalt - Source VOC 0.00873 AP -42 w/default values* 0.00873 AP -42 w/default values* *Asphalt Silo Operations VOC emission factor developed from the following equation: Volatile Organic Compounds (VOCs) = 0.0676(-V)e(o.o251)rr+460)-20.43) Where: V = asphalt volatility, as determined by ASTM Method D2872-88 the Division used the default value of -0.5 T = asphalt mix temperature in °F the Division used the default value of 300°F Point 001 Lime Silo: Pollutant Emission Uncontrolled lb/ton of lime Factors - Source Emission Factors - Controlled lb/ton of lime - Source PM 3.14 AP -42 11-12-2 0.00314 99.9% control for bag filter 6) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source for CO PSD True Minor Source NANSR True Minor Source COLORADO Pollution Control, Division t Publx, }{ewh & Er,+rz w,,m-5.t Page 9 of 13 7) Full text of the 1 ` - , Pr '- ti: •` nv`"'`: = "" Elec 'ic Code of Federal Regulations can be found at the website listed below: http: / /www. ecf r. gov/ cgi-bin /text- idx?gp=&SID=2a3fbebe8f5c2f47006ad49ae4b4c0808mc=truefttpl=/ecfrbrowse/Title40/40tab 02 .tpl Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-60.19 Subpart A NSPS 60.90-60.93 Subpart I 8) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. Failure to pay the invoice will result in revocation of this permit. The permit holder must pay the invoice within 30 days of receipt of the invoice (Reference: Regulation Number 3, Part A, VI.B.). 9) Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the Division to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 10) Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Division on grounds set forth in the Colorado Air Pollution Prevention and Control Act and regulations of the AQCC including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. (Reference: Regulation Number 3, Part B III.F.) 11) Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollutant Emission Notice (APEN) must pay an annual emission fee. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 12) Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO Air Pollution Control Division :rFa€traterx �PP;t:: HCasa �rmer Page 10 of 13 PARTICULATE EMISSION RO""`"`�' PRONG ACTIVITIES THE FOLLOWING PARTICULATE EMISSIONS CONTROL MEASURES MUST BE USED FOR COMPLIANCE PURPOSES ON THE ACTIVITIES COVERED BY THIS PERMIT, AS REQUIRED BY THE AIR QUALITY CONTROL COMMISSION REGULATION NUMBER 1, III.D.1.b. THIS SOURCE IS SUBJECT TO THE FOLLOWING EMISSION GUIDELINES: a. Processing Activities - Visible emissions not to exceed 20%, no off -property transport of visible emissions. b. Haul Roads - No off -property transport of visible emissions must apply to on -site haul roads, the nuisance guidelines must apply to off -site haul roads. b. Haul Trucks - There must be no off -property transport of visible emissions from hauls trucks when operating on the property of the owner or operator. There must be no off -vehicle transport of visible emissions from the material in the haul trucks when operating off of the property of the owner or operator. CONTROL MEASURES 1. Material stockpiles must be watered as necessary to control fugitive particulate emissions. Aggregate materials must be sprayed with water during material loading into the storage bins or stockpiles as necessary such that the above guidelines are met. 2. Dirt haul roads must be graveled, treated with chemical stabilizer per manufacturer's recommendations, and watered as often as needed to control fugitive particulate emissions such that the above guidelines are met. 3. Paved haul roads must be swept and watered as often as needed to control fugitive particulate emissions such that the above guidelines are met. 4. Vehicle speed on unpaved haul roads and unpaved service roads must be restricted to 10 miles per hour. Speed limit signs must be posted. OLORADO Pollution Control Division Page 11 of 13 DO on trol Division Department of Public Health Et Environment Attachment A Topographic Map: Source Level: 504,004: sfw;vl sns t 500:0FI 505, i1TM l ttt(m} 5000,00 500,700 NAD 198aU IZone13hi ftt7 do , 0 Parini Source ® Area Source Volume Source O ttea^tprfrr COLORADO Mr Pollution Control Division Deportment of Y a tr. &::.nwonrrrent Page 12 of 13 0 DO on trot Division D,epartmeiitof Public.Health &`Environrrient •50G iuo SOS+9.u` 505 aOp sits vU • NAD 19A1'Ui'lrl' Tone t'a�1' 04?09 SOakoY Legend' 005 050 Flgure 5:,3, ;Aerial Image ;Source Level Unt Last (in) Pencaliiie D llu ldln� O Point Soutie Area Source 4blani S0urra::O•Revepior COL.0R:AD0 Air Pollution Control Division Rpartinont of flthlic Heath fi tnwdnrnent S0.50G Page 13 of 13 06.1.3.2,0 i-( Asphalt Paving Materials Plant APEN Form APCD-225 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal - This APEN is to be used for Asphalt Paving Materials (APM) Plants, also called Hot Mix Asphalt Plants. If your emission source is not an APM Plant, there may be a more specific APEN for your operation (e.g. crusher, screen, or mining operation). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options do not meet your reporting needs. A list of specialty APENs and the General APEN are available on the Air Pollution Control Division (APCD) website at www.colorado.gov/cdphe/apcd. This emission notice is valid for five {5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: v7 tJ E 0578 AIRS ID Number: 12. -5 /QESB/ 00 3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Martin Marietta Materials, Inc. Highway 34 Asphalt Plant Site Location South Half of Section 18, County: Weld Township 5N, Range 67W Mailing Address: (Include Zip Code) 1627 Cole Blvd., Suite 200 Portable Source Home Base: Lakewood, CO 80401 NAICS or SIC Code: 324121 Permit Contact: Walt Wright Phone Number: 303-406-8593 E -Mail Address2: walter.wright@martinmarietta.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-225 - APM Plant APEN - Revision 6/2017 364% COLORADO 1 I MY�"t Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action Q NEW permit OR newly -reported emission source (check one below) ❑✓ STATIONARY source El PORTABLE source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Ft Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Spring 2018 Was this APM plant constructed, modified, or reconstructed after June 11, 1973? ® Yes Normal Hours of Source Operation: 1 6-24 hours/day 7 days/week 52 weeks/year ❑ No Seasonal use percentage4: Dec -Feb: Varies Mar -May: Varies June -Aug: Varies Sept -Nov: Varies All sources except the asphalt loadout, hot oil heaters, and storage piles will operate a maximum of 16 hrs/day. Asphalt loadout, hot oil heaters, and wind erosion are potentially 24/7. 4 The reported "seasonal use percentage" may become quarterly permit limits that apply during the first year of operation only. After the first year, requested annual limits will apply, as reported in Section 4B of this APEN. For example, if you report an anticipated 0% seasonal use during Dec -Feb, you may be limited to zero tons of production during the first winter of operation, but the total annual limits will apply in subsequent years. Seasonal use percentages must sum to equal 100%. Form APCD-225 - APM Plant APEN - Revision 6/2017 COLORADO 2I, V Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit t and AIRS ID] Section 4 - Processing Information &t Material Use With this application, you must submit a site map, drawn to scale, which shows the on -site haul roads, public roads, property boundary, fence boundary, aggregate storage bins, APM processing equipment, and storage silos and tanks. Total Area of Site: 120 acres Shortest Distance from APM Plant to property boundary: —200 feet Plant Type: ❑ Drum Mix Parallel Flow ❑✓ Drum Mix Counter Flow ❑ Batch Mix Plant Plant design rate (maximum capacity per hour) 500 tons/hour (finished product) Maximum burner design rate: 12 l 50 Million BTU per hour Drum Mixer: Make Gencor Model Ultradrum Model 500 Serial TBD Drum Burner: Make Gencor Model Ultra II -150H Serial TBD Section 4A: Main Burner Fuel Type(s): Primary Fuel Type: (check fuel for which approval is requested) ❑ Diesel (No. 2 Fuel Oil) ❑ Propane ❑ On -Specification Industrial Oil in compliance with 40 CFR Part 279 ❑✓ Natural Gas ❑ Other: Backup or Alternative Fuel Type (if applicable, check all fuels for which approval is requested): ❑ Diesel (No. 2 Fuel Oil) ❑ Propane El On -Specification Industrial Oil in compliance with 40 CFR Part 279 ❑ Natural Gas ❑ Other: Section 48: Production of Asphalt Paving Materials (APM): APM temperature range: 260-325 ° F (e.g. 280 - 320 ° F) Requested total annual permit limits: 600,000 tons/year Requested total annual permit limit of APM produced using backup or alternative fuel (if applicable)s: NA tons/year Actual annual production level: From what year is the actual annual production level, as listed above? NA NA tons/year (e.g. 2015) Primary Emissions Control Type of control device: Baghouse (baghouse, scrubber, etc.) Overall control efficiency (% reduction in emissions): 99.968% Manufacturer: Gencor Model: CFS-225 Serial: TBD Secondary Emissions Control Type of control device: Knockout Box (knockout box, cyclone, etc.) Manufacturer: Gencor Model: CFS-225 Serial: TBD Section 4C: Lime or Mineral Filler Storage Silos: Requested annual throughput: 6,000 tons/year Actual annual throughput: NA tons/year From what year is the actual annual (e.g. 2015) throughput? NA What type of emissions controls are on storage silo(s) for loading? Baghouse (bag filter, bin vents, etc.) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. p COLORADO Form APCD-225 - APM Plant APEN - Revision 6/2017 3 I LA11° "mow Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4D: APM Product Silo Capture and Control System: Type of control device: Return Air (from top of silo) to burner/baghouse (mist eliminator, return air/blue smoke control, etc.) Overall control efficiency (% reduction in emissions): Manufacturer Gencor Model NA Serial NA Section 5 - Main APM Plant Stack Information eographical Coordinates Lat►tude/Longitude or UTM) 505149, 4471739 (UTM Zone 13N) e a a Stac D o: r�r��(� Dii liar e i ove Ground e elm fie ��>-�x�,�`�"....: emp .a r Flow Ra e (ACFM�f�ff ` eloci y t/sec HMAPT 30'3" 275 91,366 60.38 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 68 E Square/rectangle Interior stack width (inches): Interior stack depth (inches): O Other (describe): Section 6 - Fugitive Dust Emission Sources What type of dust controls are used for aggregate storage piles? None expected for intermediate storage piles in the vicinity of the asphalt plant (INTSP), but the longterm storage piles (covered by Aggregate Yard Permit) have watering as needed. (Emissions controls for storage piles may include, but are not limited to: full or partial enclosures, use of pre -washed aggregate, watering, etc.) Section 6A: Transport of aggregate to the site from an off -site location (if plant is not located at a mine). Max amount of aggregate + RAP received: 7,600 tons/day 570,000 tons/year Haul Vehicle 1 Haul Vehicle 2 Haul Vehicle 3 Haul vehicle capacity: NA, aggregate received by rail tons Haul vehicle empty weight: NA tons Max number of trips per day: NA Haul road length (avg. one way): NA feet Posted speed limit on haul road: NA mph Form APCD-225 - APM Plant APEN - Revision 6/2017 4'l MVCOLORADO I11=t74 Permit Number: AIRS ID Number: / [Leave blank unless APCD has already assigned a permit # and AIRS ID] List all air pollution controls used for the on -site haul roads to transport aggregate to the site: ❑ Paved Surface Street sweeping: ❑ No ❑ Yes ❑ Unpaved Surface Watering: ❑ None ❑ As needed ❑ Frequent6: Surface is graveled: ❑ No ❑ Yes Chemical stabilizer applied: ❑ No ❑ Yes Type: times/day Section 6B: On -site moving of aggregate from storage piles to storage bins. Loader 1 Loader 2 Haul vehicle capacity: 6.8 Haul vehicle empty weight: 27.4 Max number of trips per day: 1,126 Haul road length (avg. one way): 300 Posted speed limit on haul road: 10 mph (e.g. mag chloride, resin, etc.) Loader 3 tons tons feet List all air pollution controls used for the on -site haul roads between aggregate storage piles and the APM storage bins: ❑ Paved Surface Street sweeping: ❑ No ❑ Yes ❑✓ Unpaved Surface Watering: ❑ None As needed ❑ Frequent6: times/day Surface is. graveled: ❑ No ❑✓ Yes Chemical stabilizer applied: ❑ No ❑✓ Yes Type: TBD (e.g. mag chloride, resin, etc.) In addition, a speed limit of 10 mph will be posted for additional fugitive dust control. 6 If "Frequent" is selected, your permit may include a requirement to water haul roads daily as often as listed in this APEN. Section 6C: Removal of asphalt paving material from the site. Haul Vehicle 1 Haul Vehicle 2 Haul Vehicle 3 Haul vehicle capacity: 14 tons Haul vehicle empty weight: 11.25 tons Max number of trips per day: 873 Haul road length (avg. one way): —1613 feet Posted speed limit on haul road: 25 mph Form APCD-225 - APM Plant APEN - Revision 6/2017 5I .CLORADO IOo.. Permit Number: AIRS ID Number: [L,eave blank unless APCD has already assigned a permit 1 and AIRS ID] List all air pollution controls used for the on -site haul roads between APM plant and the site exit: ❑✓ Paved Surface Street sweeping: ❑ No 2 Yes ❑ Unpaved Surface Watering: ❑ None ❑ As needed El Frequent6: Surface is graveled: ❑ No ❑ Yes Chemical stabilizer applied: ❑ No ❑ Yes Type: times/day (e.g. mag chloride, resin, etc.) 6 If "Frequent" is selected, your permit may include a requirement to water haul roads daily as often as listed in this APEN. Section 7 - Criteria Pollutant Emissions Information ❑✓ Check this box if the APEN is for a new or previously unreported APM Plant (i.e. no permit has been issued) and skip to Section 9. Attach all emission calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? Use the following tables to report criteria pollutant emissions from each individual point source and the total combined APM plant emissions: NA (Use the data reported in Section 4 and emission factors located in the "Notes to Permit Holder" section of your permit to calculate these emissions.) Main Plant Mixer emissions while operating on primary fuel: (natural #2 diesel, etc. TSP (PM) ncontrolled, Emission actor (fb/ton of APM) Controlled Emission Factor (ib/ton,of APM) Emission Factor Source (AP42.Mfg Permit, etc) Uncontrolled Controlled? flans/year) (tons/year) Natural Gas_ 0.033 Spec Sheet 9.90 PM1 o 0.012 Spec Sheet 3.52 PM2.5 O.0091 Spec Sheet 2.73 SOx 0.0034 0.0034 AP -42 1.02 1.02 NO. 0.026 0.026 AP -42 7.80 7.80 CO 0.13 0.13 AP -42 39.0 39.0 VOC 0.032 0.032 AP -42 9.60 9.60 7 Annual emission fees will be based on the reported actual controlled emissions. Form APCD-225 - APM Plant APEN - Revision 6/2017 ............................................... COLQRADO 6 I'V I ° TSP (PM) TSP (PM) TSP (PM) Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit u and AIRS ID] Drum Mixer emissions while operating on secondary or backup fuel (if applicable): 0 Check this box if the drum mixer burner did not combust a secondary fuel during this reporting period or the permit does not include emission factors for this activity, and skip to the next table. Uncontrolled Emission Factor (fb/ton of APM) Controlled Emission Factor (lb/ton'of APM) Emission Factor Source (AP -42, Mfg. Permit. etc) ontrolled7 (tons/year) Uncontrolled PMo PM2.5 SOX NOX CO VOC Finished asphalt paving material storage silo emissions: ❑ Check this box if the permit does not include emission factors for this point, and skip to the next table. Uncontrolled Emission- :Factor (lb/ton of APM) Controlled Emission Factor (lb/ton ofAPM) Emission Factor:! Source: (AP42,Mfg Permit, ::etc) Uncontrolled Controlled? ;(tons/year), (tons/year) 4.68E-04 7.01 E-05 AP -42 0.14 0.02 PM1 o 4.68E-04 7.01 E-05 AP -42 0.14 0.02 PM2.5 4.68E-04 7.01 E-05 AP -42 0.14 0.02 VOC 6.51 E-03 6.51 E-03 AP -42 1.95 1.95 Suction pulls dust back into burner and the transfer is enclosed. Lime silo emissions: ❑ Check this box if the permit does not include emission factors for this point and skip to the next table. t]ncontrolled ::Emission Factor (lb✓ton of lime) 0.0089 Emission Factor Source 64."'.74.;.; Mfg Permit, :etc) . AP -42 Uncontrolled (tons%year) Control led' (tons�year) 0.027 PMto 0.0049 AP -42 0.015 PM2.5 0.00074 AP -42 0.0022 7 Annual emission fees will be based on the reported actual controlled emissions. Form APCD-225 - APM Plant APEN Revision 6/2017 coLb RADO 7I MY' TSP (PM) 11.98 (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 lbs/year? Permit Number: AIRS ID Number: / J [Leave blank unless APCD has already assigned a permit #r and AIRS ID] Total combined point source criteria pollutant emissions (combined values from previous emissions tables): ncontrolled tons/year) Controlled? (tons/year) PMt o 4.31 PM2.5 3.02 Sox 1.03 NO,, 9.52 CO 40.85 V0C 12.38 Note: Additional misc material transfers and asphalt screen are included in the total emissions. For additional detailed calculation information see application package. Section 8 - Non -Criteria Pollutant Emissions Information Check this box if the APEN is for a new or previously unreported APM Plant (i.e. no permit has been issued) and skip to Section 9. Does the emissions source have any actual emissions of individual non -criteria pollutantsIZ Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from this source: umber 110-54-3 Hexane Overall Control Efficiency Uncontrolled Emission Factor' (specify units) Emission Factor Source (AP 42, Permit Mfg.; "etc) Uncontrolled Actual Emissions abs/year)' . ontrolled Actual " missron57 (lbs/year) NA Multi (Asphalt Plant) AP -42, Section11.1 558 558 50-00-0 Formaldehyde NA Multi (Asphalt Plant) AP -42, Section11.1 1,889 1,889 74-85-1 Ethylene NA Multi (Asphalt Plant) AP -42, Section11.1 4,254 4,254 109-67-1 1-pentene NA 2.2E-03 AP -42, Section11.1 1,320 1,320 763-29-1 2-Methyl-1-pentene NA 4.0E-03 AP -42, Section11.1 2,400 2,400 513-35-9 2-Methyl-2-butene NA 5.8E-04 AP -42, Section11.1 348 348 106-97-8 Butane NA 6.70E-04 AP -42, Section11.1 402 402 142-82-5 Heptane NA 9.40E-03 AP -42, Section11.1 5640 5640 7 Annual emission fees will be based on the reported actualcontrolled emissions. COLORADO Form APCD-225 - APM Plant APEN - Revision 6/2017 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that -all information contained herein and information submitted with this application is complete, true and correct. 0 c,/ei 7 Signature of Legally Authorize> rson (not a vendor or consultant) i /> Z• Name (print) Title Date Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-225 - APM Plant APEN - Revision 6/2017 9 1UM* lotarlammat COLORADO Colorado Depaitiuent of Public Health and Environment Air Pollution Control Division Stationary Sources Program O6.i3.7o11 Page 1 of 3 Supplement to Air Pollutant Emission Notice (APEN) for Storage Tanks Note: Please complete one supplement for each tank containing liquids. Permit Number Company Name: Tank Location: Person to Contact: Contact Title: New Pit-4.8 I7vJEm518 Martin Marietta Materials, Inc. 1Z3INE8$f OO3 AIRS Number New Permit -- a Highway 34 Facility Walt Wright Senior Environmental Engineer Signature of Responsible (not a vendor or consultant) Name of Responsible Official (Please'Orint Section 1 Tank Information Tank Identification: AC 1 - (Asphalt Cement Tank 1) Tank Installation Date: 2018 Tank Type: (Check all that apply) ❑ Pressurized ❑ Open Top ❑ Roofed ❑ Horizontal ❑ Vertical Tank Dimensions Shell Length / Height: Shell Diameter: Maximum Liquid Height: Average Liquid Height: Tank Capacity: Tank Turnovers Per Year: Tank Throughput: 40 100 34.04 17.02 2,000,000 0.95 1,900,000 Is the Tank Heated? Yes / No =YES Is the Tank Underground? Yes / No NO Breather Vent Settings Vacuum Setting Pressure Setting 0.00 0.00 Tank Emissions Vent To © Atmosphere County: Weld Phone Number: 303-406-8593 Fax Number: 303-657-4422 o/z// 7 Date Roof Type: (Check one) ® Fixed Roof ❑ Internal Floating Roof ❑ External Floating Roof ❑ Domed External Floating Roof Feet Feet Feet (Vertical Tanks Only) Feet (Vertical Tanks Only) Gallons Gallons Per Year (Equal To Capacity x Turnovers) psig psig ❑ Flare Condenser Other: carbon system for odor reduction Revised July 2001 http://www.cdphe.state.co.us/ap/stationarv.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 2 Fixed Roof Characteristics Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) 0 Light Gray ❑ Medium Gray ❑ Red ❑ Other: Shell Condition: Good / Poor = Good Roof Paint Condition: Good / Poor = Good Roof Type: Cone / Dome = Cone Cone / Dome Height: 0.06 Feet Section 3 Floating Roof Characteristics External Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ❑ Other: External Shell Condition Good / Poor Roof Paint Condition: Good / Poor Rim Seal System: Primary Seal (Check one) ❑ Mechanical Shoe ❑ Liquid -Mounted ❑ Vapor -Mounted Deck Type: Bolted / Welded Revised July 2001 Page 2 of 3 Tank ID AC1 Roof Color / Shade (Check one) O White O Aluminum Specular (Shiny Finish) O Aluminum Diffuse (Flat Finish) 0 Light Gray O Medium Gray Red Other: Not Applicable Roof Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) O Aluminum Diffuse (Flat Finish) O Light Gray ❑ Medium Gray ❑ Red O Other: Internal Shell Condition: (Check one) ❑ Light Rust ❑ Dense Rust ❑ Gunite Lining Secondary Seal (Check one) O O Weather Shield Rim -Mounted None http://www.cdphe.state. co.us/ap/stationarv.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 4 Meteorological Data Nearest City (Check one) ❑ Colorado-Alamosa ❑ Colorado — Colorado Springs ❑ Colorado —Denver ❑ Colorado — Grand Junction ❑ Colorado — Pueblo ❑ Kansas — Goodland ❑ Nebraska — Scotts Bluff ❑ Wyoming - Cheyenne Section 5 Tank Contents Product Type: El Single Component Liquid O Multi -Component Liquid Product Stored*: Product Density: Product Vapor Pressure: For Solutions: Not Applicable Name of Solvent*: Name of Solute Dissolved*: Concentration of Material Dissolved Asphalt Cement 8.84 0.0092 Tank ID AC1 Pounds per Gallon RVP, or psia at 300 % By Weight, or % By Volume * Note: Please attach Material Safety Data Sheets (MSDS) for the uncommon materials. Additional Comments Page 3 of 3 °F Revised July 2001 http://www.cdphe.state.co.us/ap/stationarv.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program cb.-e.3, Page 1 of 3 Supplement to Air Pollutant Emission Notice (APEN) for Storage Tanks Note: Please complete one supplement for each tank containing liquids. Permit Number I - li w Em 57$ AIRS Number NOW Pc it - TDD' 123 19 E.$ Company Name: Tank Location: Person to Contact: Contact Title: Martin Marietta Materials, Inc. Highway 34 Facility Walt Wright Senior Environmental Engineer Signature of Responsiblc`O Name of Responsible Official (Pleaae Print fficial (not a vendor or consultant) County: Weld Phone Number: 303-406-8593 Fax Number: 303-657-4422 Date Section 1 Tank Information ,av Tank Identification: AC2 - (Asphalt Cement Tank 2) Tank Installation Date: 2018 Tank Type: (Check all that apply) ❑ Pressurized CI 0 x❑ Open Top Roofed Horizontal Vertical Tank Dimensions Shell Length / Height: Shell Diameter: Maximum Liquid Height: Average Liquid Height: Tank Capacity: Tank Turnovers Per Year: Tank Throughput: 45 12 35.46 17.73 30,000 61.59 1,847,575 Is the Tank Heated? Yes / No =YES Is the Tank Underground? Yes / No NO Breather Vent Settings Vacuum Setting 0.00 psig Pressure Setting 0.00 psig Tank Emissions Vent To 0 Atmosphere Title Roof Type: (Check one) ® Fixed Roof ❑ Internal Floating Roof ❑ External Floating Roof O Domed External Floating Roof Feet Feet Feet (Vertical Tanks Only) Feet (Vertical Tanks Only) Gallons Gallons Per Year (Equal To Capacity x Turnovers) ❑ Flare ❑ Condenser 0 Other: carbon system for odor reduction oO3 Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 2 Fixed Roof Characteristics Shell Color / Shade (Check one) • White ❑ Aluminum Specular (Shiny Finish) O Aluminum Diffuse (Flat Finish) 0 Light Gray O Medium Gray O Red O Other: Shell Condition: Good / Poor = Good Roof Paint Condition: Good / Poor = Good Roof Type: Cone / Dome = Cone Cone / Dome Height: 0.06 Feet Page 2 of 3 Tank ID AC2 Roof Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) O Aluminum Diffuse (Flat Finish) O Light Gray ❑ Medium Gray ❑ Red ❑ Other: Section 3 Floating Roof Characteristics Not Applicable External Shell Color / Shade (Check one) Roof Color / Shade (Check one) • White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray O Red ❑ Other: ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ❑ Other: External Shell Condition Good / Poor Internal Shell Condition: (Check one) ❑ Light Rust Roof Paint Condition: Good / Poor O Dense Rust ❑ Gunite Lining Rim Seal System: Primary Seal (Check one) Secondary Seal (Check one) • Mechanical Shoe O Weather Shield O Liquid -Mounted O Rim -Mounted O Vapor -Mounted O None Deck Type: Bolted / Welded Revised July 2001 http://www.cdphe.state.co.us/ap/stationarv.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 4 Meteorological Data Nearest City (Check one) ❑ Colorado — Alamosa ❑ Colorado — Colorado Springs ® Colorado — Denver Colorado — Grand Junction Colorado — Pueblo Kansas — Goodland Nebraska — Scotts Bluff Wyoming - Cheyenne Section 5 Tank Contents Product Type: ® Single Component Liquid O Multi -Component Liquid Product Stored*: Product Density: Product Vapor Pressure: For Solutions: Not Applicable Name of Solvent*: Name of Solute Dissolved*: Concentration of Material Dissolved Asphalt Cement 8.84 0.0092 Tank ID =AC2 Pounds per Gallon RVP, or psia at 300 % By Weight, or % By Volume * Note: Please attach Material Safety Data Sheets (MSDS) for the uncommon materials. Additional Comments F Page 3 of 3 Revised July 2001 http://www.cdphe.state.co.us/ap/stationarv.html Colorado Depaitiuent of Public Health and Environment Air Pollution Control Division Stationary Sources Program REc$ O6.7.3.- °rr Page 1 of 3 Supplement to Air Pollutant Emission Notice (APEN) for Storage Tanks Note: Please complete one supplement for each tank containing liquids. Permit Number - 11 $ .(Z) 7% AIRS Number New Permit - TBD• (X319 Cg Q 1O°3 Company Name: Tank Location: Person to Contact: Contact Title: Martin Marietta Materials, Inc. Highway 34 Facility Walt Wright Senior Environmental Engineer County: Weld Phone Number: 303-406-8593 Fax Number: 303-657-4422 Signature of Responsible Official (not a vendor or consultant) PC1.O% iJ Section 1 Name of Responsible Official (Please Print) Tank Information Tank Identification: AC3 - (Asphalt Cement Tank 3) Tank Installation Date: 2018 Tank Type: (Check all that apply) O Pressurized ❑ Open Top O Roofed O Horizontal ® Vertical Tank Dimensions Shell Length / Height: Shell Diameter: Maximum Liquid Height: Average Liquid Height: Tank Capacity: Tank Turnovers Per Year: Tank Throughput:. 45 12 35.46 17.73 30,000 61.59 1,847.575 Is the Tank Heated? Yes / No =YES Is the Tank Underground? Yes / No NO Breather Vent Settings Vacuum Setting Pressure Setting 0.00 psig 0.00 psig Date Title Roof Type: (Check one) ® Fixed Roof ❑ Internal Floating Roof ❑ External Floating Roof O Domed External Floating Roof Feet Feet Feet (Vertical Tanks Only) Feet (Vertical Tanks Only) Gallons Gallons Per Year (Equal To Capacity x Turnovers) Tank Emissions Vent To © Atmosphere 0 Flare 0 Condenser ® Other: carbon system for odor reduction Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.html ,a Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 2 Fixed Roof Characteristics Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) O Light Gray ❑ Medium Gray ❑ Red ❑ Other: Shell Condition: Roof Paint Condition: Roof Type: Good / Poor Good / Poor Cone / Dome Cone / Dome Height: 0.06 Section 3 Floating Roof Characteristics = Good = Good = Cone Feet External Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) O Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray O Red ❑ Other: External Shell Condition Roof Paint Condition: Rim Seal System: Primary Seal (Check one) ❑ Mechanical Shoe ❑ Liquid -Mounted ❑ Vapor -Mounted Good / Poor Good / Poor Deck Type: Bolted / Welded Revised July 2001 Secondary Seal Page 2 of 3 Tank ID AC3 Roof Color / Shade (Check one) White Aluminum Specular (Shiny Finish) Aluminum Diffuse (Flat Finish) Light Gray Medium Gray Red Other: ❑x 0 Not Applicable Roof Color / Shade (Check one) White Aluminum Specular (Shiny Finish) Aluminum Diffuse (Flat Finish) Light Gray Medium Gray Red Other: Internal Shell Condition: (Check one) ❑ Light Rust ❑ Dense Rust ❑ Gunite Lining (Check one) ❑ Weather Shield ❑ Rim -Mounted O None http://www.cdphe.state.co.us/ap/stationarv.html J Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 4 Meteorological Data Nearest City (Check one) • Colorado-Alamosa ❑ Colorado —Colorado Springs ® Colorado —Denver O Colorado — Grand Junction ❑ Colorado — Pueblo ❑ Kansas — Goodland ❑ Nebraska— Scotts Bluff ❑ Wyoming - Cheyenne Section 5 Tank Contents Product Type: ® Single Component Liquid O Multi -Component Liquid Product Stored*: Product Density: Product Vapor Pressure: For Solutions: Not Applicable Name of Solvent*: Name of Solute Dissolved*: Concentration of Material Dissolved Asphalt Cement 8.84 0.0092 Page3of3 Tank ID _AC3 16 Pounds per Gallon RVP, or psia at 300 % By Weight, or % By Volume * Note: Please attach Material Safety Data Sheets (MSDS) for the uncommon materials. Additional Comments °F Revised July 2001 http://www.cdphe.state.co.us/ap/stationarv.html Colorado Depaituient of Public Health and Environment Air Pollution Control Division Stationary Sources Program %M.> O6 ,'t3 , Zo ►'7 Page 1 of 3 Supplement to Air Pollutant Emission Notice (APEN) for Storage Tanks Note: Please complete one supplement for each tank containing liquids. Permit Number - 17 W Ems -7$ AIRS Numbef N W PenTri BIi— Company Name: Tank Location: Person to Contact: Contact Title: Martin Marietta Materials, Inc. Highway 34 Facility Walt Wright Senior Environmental Engineer IZ314E8B j003 County: Weld Phone Number: 303-406-8593 Fax Number: 303-657-4422 Signature of Responsible Off (not a vendor or consultant) Date O Section 1 Name of Responsible Official (Please Print) Tank Information Tank Identification: AC4 - (Asphalt Cement Tank 4) Tank Installation Date: 2018 Tank Type: (Check all that apply) O Pressurized O Open Top O Roofed ❑ Horizontal © Vertical Tank Dimensions Shell Length / Height: Shell Diameter: Maximum Liquid Height: Average Liquid Height: Tank Capacity: Tank Turnovers Per Year: Tank Throughput: 45 12 35.46 17.73 30,000 61.59 1,847,575 Is the Tank Heated? Yes / No =YES Is the Tank Underground? Yes / No =NO Breather Vent Settings Vacuum Setting Pressure Setting 0.00 0.00 Tank Emissions Vent To © Atmosphere Title Roof Type: (Check one) ® Fixed Roof O Internal Floating Roof O External Floating Roof O Domed External Floating Roof Feet Feet Feet (Vertical Tanks Only) Feet (Vertical Tanks Only) Gallons Gallons Per Year (Equal To Capacity x Turnovers) psig psig 0 Flare 0 Condenser ® Other: carbon system for odor reduction Revised July 2001 http://www.cdphe.state.co.us/ap/stationarv.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 2 Fixed Roof Characteristics Shell Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑x Light Gray ❑ Medium Gray ❑ Red ❑ Other: Shell Condition: Roof Paint Condition: Roof Type: Cone / Dome Height: Good / Poor = Good Good / Poor = Good Cone / Dome = Cone 0.06 Feet Page 2 of 3 Tank ID AC4 Roof Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) E Light Gray ❑ Medium Gray ❑ Red ❑ Other: Section 3 Floating Roof Characteristics Not Applicable External Shell Color / Shade (Check one) O White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red O Other: External Shell Condition Good / Poor Roof Paint Condition: Good / Poor Rim Seal System: Primary Seal (Check one) O Mechanical Shoe ❑ Liquid -Mounted ❑ Vapor -Mounted Deck Type: Bolted / Welded Roof Color / Shade (Check one) ❑ White ❑ Aluminum Specular (Shiny Finish) ❑ Aluminum Diffuse (Flat Finish) ❑ Light Gray ❑ Medium Gray ❑ Red ❑ Other: Internal Shell Condition: (Check one) ❑ Light Rust ❑ Dense Rust ❑ Gunite Lining Secondary Seal (Check one) ❑ Weather Shield ❑ Rim -Mounted O None Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.html Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program Section 4 Meteorological Data Nearest City (Check one) ❑ Colorado—Alamosa ❑ Colorado — Colorado Springs ❑ Colorado — Denver ❑ Colorado — Grand Junction ❑ Colorado - Pueblo ▪ Kansas — Goodland ❑ Nebraska — Scotts Bluff ❑ Wyoming - Cheyenne Section 5 Tank Contents Product Type: ❑ Single Component Liquid ❑ Multi -Component Liquid Product Stored*: Product Density: Product Vapor Pressure: For Solutions: Not Applicable Name of Solvent*: Name of Solute Dissolved*: Concentration of Material Dissolved Asphalt Cement 8.84 0.0092 Tank ID _ AC4 Pounds per Gallon RVP, or psia at 300 % By Weight, or % By Volume * Note: Please attach Material Safety Data Sheets (MSDS) for the uncommon materials. Additional Comments F Page 3 of 3 Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.html COPHE, APCD Preliminary Analysis - Requested Emissions Emissions from HMA Plant: Drum Mixer Make, Model, SN: Gencor, Ultradrum Model 500, SN: TBD Drum Mixer Design Rate: Requested Annual 500 tph Production Limit: 600,000 tpy Burner Make, Model, SN: Gencor, Ultra II -150H, SN: TBD Burner Design Rate: 150 MMBtu/hr Burner Fuel Types: natural gas - Cyclone & Baghouse Make, Model, SN: Gencor, CF5-225, SN: TOD Stack Temperature: 734.67 R Stack Flow Rate: 91,366 ACFM 492 R- standard temp 51,397 scfm 38,630 dscfm Stack Moisture Atmospheric Pressure: 0.84 atm Content: 24,84 % -. NSPS Standard: 0.04 gr/dscf 1.00 atm -standard pressure - Normal Operation of Source: 16 hr/day 7 day/week 52 week/yr EF PTE' Uncontrolled Controlled Criteria Pollutant Ib/ton HMA Produced tpy tpy tpy lb/hr lb/day EF Source Control Device Control Efficiency PM 28.00000 33.1 8400.0 7.95 13.2 317.9 Uncontrolled:AP-42.Ch. 11.1/ Bag House 99,968 PM10 6.50000 7.7 1950.0 `1.84 3.1 73.8 Controlled: NIPS Subpart I Bag House 99.968 PM2.5 1.54000 1.8 462.0 0.44 0:7 17.5 Standard Bag House - 99,95$; 502 0.00340 4.3 1.0 - 1.02 1.7 40.8 AP -42 Table 11.1-7 None Q NOx 0.02000 32.5 7.8 7.80 13.0 . 312.0 AP -02 Table 11.1-7 None 0 CO 0.13000 162.5 39.0 39.0 65.0 1560.0 AP -42 Table ll.1.7 None D'. VOC 0.03200 40.0 9.6 9.60 16.0 384.0 AP -42 Table, 11.1-8 None 0 '" EF (gas) PTE Uncontrolled Controlled HAP lb/ton HMA Produced tpy lb/yr tpy lb/yr tpy EF Source Control Device Control Efficiency Benzene 0.00033 0.9 234.0 0.1 234.0 0.1 AP -42 Table 11.1-10 None 0 Hexane 0.00092 2.0 552.0 0.3 552.0 0.3 AP -42 Table 11.1-10 None 0 Toluene 0.00015 0.3 90.0 0.0 90.0 0.0 AP -42 Table 11.1-10 None 0 Formaldehyde 0.00310 6.8 1860.0 0.9 1860.0 0.9 AP -42 Table 11.1-10 None 0 'Assumes 5000 hours pe year of potential operating time. Red text = input SCC: 3-05-002-59 Fugitive: No NSPS:I MAR: None Emissions from HMA Silo Filling: HMA Temperature: 300 F Criteria Pollutant EF lb/ton HMA Produced PTE' tpy Uncontrolled tpy tpy Controlled lb/hr lb/day EF Source Control Device Control Efficiency PM PM10 PM2.5 VOC. 0.000 0.000 0.000 0.00651 0.6 0.6 0.6 8.1 0.1 0.1 0.1 2.0 0.14 0.14 0.14 1.95' 0.2 0.2 0.2 3.3 5.6 5.6 5.6 78.1 AP -42 Table 11.1-14 Assume PM10=PM Assume PM2.5 = PM AP -42 Table 11,1-14 0 0 0 0 'Assumes 5000 hours pe year of potential operating time. SCC: 3-05-002-13 Fugitive: No NSPS: I MAR: None Emissions from Drum or Batch Mix HMA Load -Out: Criteria Pollutant EF lb/ton HMA Produced PTE' tpy Uncontrolled tpy tpy Controlled lb/hr lb/day EF Source Control Device Control Efficiency PM 0.000 0.5 0.1 0.1 0.2 4.4 AP -42 Table 11.1-14 None 0 PM10 0.000 0.5 0.1 0.1 0.2 4.4 Assume PM10 = PM None 0 PM2.5 0.000 0.5 0.1 0.1 0.2 4.4 Assume PM2.5 = PM - None 0 CO 0.001 0.9 0.2 0.2 0.4 8.6 AP -42 Table 11.1-14 None .' 0 VOC 0.002 2.6 - 0.6 0.6 1.0 25.0 AP -42 Table 11.1-14 None 0 SCC: 3-05-002-14 Fugitive: No NSPS: I MACT: None Emissions from Lime Silo Filling: Requested Throughput: 15000 tpy Design rate of silo: 55 tph, - Criteria Pollutant EF lb/tan of lime PTE tpy Uncontrolled tpy tpy Controlled Ib/hr lb/day EF Source Control Device - Control Efficiency PM PM10 PM2.5 3.140 1.100 1.100 0.1 0.1 0.1 23.6 8.3 8.3 0.024 0.008 .0.008 0.17 0.06 0.06 41 1.5 1.5 AP -42 Table 11.12-2 AP -42 Table 11.12-2 AP -42 Table 11.12-2 eaghouse Baghouse Beanouse 99.9. 99.9 999 SCC: 3-05-002-13 Fugitive: No NIPS: I MACT: None CDPHE, APCD Preliminary Analysis • Requested Emissions Emissions from Haul Roads - Aggregate intermediate pile to plant: SCC: 3-05-002-90 Fugitive: Yes NSPS: None MACE: None Unpaved Roads: E = k (s/12)a x (W/3)b Weight of Material per Load: Surface Material Silt Content: Potential Vehicle Miles Traveled (VMT): 7 tons 7.1 % Average Unloaded Truck Weight: Mean Vehicle Weight: Length of Road (one way): 34,955 miles/yr 27.4 tons 30.8 tons Average Loaded Truck Weight: Max. Number of Trips: Vehicle Miles 0.055 miles Traveled (VMT) PTE: 34,955 miles/yr 34 tons 84,444 trips/yr 873 trips/day 70 trips/hr Requested VMT: Requested VMT:. Requested VMT: 9,596 miles/y1 128 miles/day 8 miles/hr Criteria Pollutant PM PM10 PM2.5 EF lb/VMT 9.680 2.668 0.267 PTE tpy 169.2 46.6 4.7 Uncontrolled tpy 46.4 12.8 1.3 Controlled tpy lb/hr lb/day. 1.09 0.30 0.03 1.81 0.50 0.05 29.0 8.0 0.8 EF Source AP -42 Ch. 13.2.2 AP -42 -Ch. 13.2,2 AP -42 Ch. 13.2.2 Control Control Efficiency chemical stabilizer, graveled, watered as needed, 10MPH 97.66 97.66 97.66 Emissions from Haul Roads - Removal of HMA from Site: SCC: 3-05-002-90 Fugitive: Yes NSPS: None MACE: None Average Loaded Truck Weight: Paved Roads: E = k (sL)^0.91 x (W)^1.02 Weight of Material per Load: Surface Material Silt Content: 14 tons 8.2 g/m^2 Potential Vehicle Miles Traveled (VMT): 9,688,937 miles/yr Average Unloaded Truck Weight: Mean Vehicle Weight: 11.3 tons 18.1 tons Max. Number of Trips: 25 tons 43,636 trips/yr 873 trips/day 36 trips/hr Vehicle Miles Length of Road: 0.305 miles Traveled (VMT) PTE: 9,688,937 miles/yr Requested VMT: Requested VMT: Requested VMT: 26,618 miles/yr 533 miles/day 22 miles/hr Criteria Pollutant PM Pri/110 PM2.5 HF lb/VMT 1.434 0.287 0.070 PTE tpy 6944.7 1388.9 340.9 Uncontrolled tpy 19.1 3.8 0.9 Controlled tpy ib/hr lb/day 0.19 0.04 0.01 0.76 0.15 0.04 7.63 1.98 0.37 EF Source AP -42 Ch. 13.2.2 AP -42 Ch. 13.2.2 AP -42 Ch. 13.2.2 Control Control Efficiency 99 09 99 U 2 U U g.:- - mticc, w o a m o n ory f4 0 o m t-1 O U <y "a o 0 0 ry Uncontrolled lb/yr .. tpy 0 0 ry Uncontrolled tPY 8423 8 1958.5 470.5 1.0 7.8 39.0 12.2 PTE tpy Om V M N PTE tpy O ry 0 :o Criteria Pollutant u 2.a O O OU Z > Q Benzene Hexane Toluene Formaldehyde ' 00 s O d a Controlled tpy lb/hr lb/day m 1 tia Controlled lb/yr tpy o 0 0 ry Q N EN Uncontrolled lb/yr tpy Uncontrolled tpy PTE tpy ",;,,,-,•4-,,,,,,,,,, PTE tpy O ry o Criteria Pollutant d o 6 0 0 0U O � z V HAP Benzene Hexane Toluene Formaldehyde Colorado Department of Public Health and Environment Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 Summary The existing facility is located at 505149 E 4471739 N UTM Zone 13 NAD83, in Weld County, CO, under Permit No. 16WE0688 (ready mix plant) and Permit No. 16WE0689 (aggregate yard), AIRS # 123-9E8B. The facility submitted an air permit modification application to add an asphalt plant to the facility. The modifications requested by adding an asphalt plant include the addition of an asphalt flow drum mixer, lime silo, up to four (4) asphalt cement tanks, up to two (2) hot oil heaters, and conveyor transfer points and material handling. There are NAAQS and CAAQS currently in effect for the following pollutants and averaging periods: CO (1 -hr and 8 -hr), Pb (3 -month rolling average), NO2 (1 -hr and annual), PM10 (24 -hr), PM2.5 (24 -hr and annual), SO2 (1 -hr, 3-1u-, 24 -hr, and annual), and ozone (8 -hr). For this permit application, quantitative impact analyses are warranted to demonstrate compliance with the NAAQS/CAAQS for the following pollutants and averaging periods: CO (1 -hr and 8 -hr), NO2 (1 -hr), PM10 (24 -hr), PM2.5 (24 -hr), and SO2 (1 -hr, 3 -hr, and 24 -hr). The applicant submitted modeling analyses for all required pollutants and averaging periods except the NO2 (1 - hr) and SO2 (1 -hr, 3 -hr, and 24 -hr). The consultant allowed the MEIU to perform the SO2 (3 -hr and 24 -hr) modeling analyses. The SSP decided modeling for the 1 -hr NO2 and 1 -hr SO2 pollutants and averaging periods was not warranted per PS Memo 10-01. After review of the analyses submitted by the applicant with revisions by the MEIU, it is concluded that the Martin Marietta Highway 34 new facility will not cause or contribute to any modeled violation of the corresponding NAAQS/CAAQS. The MEIU conducted a modeling analysis for the 1 -hr NO2, 1 -hr SO2, 3 -hr SO2, and 24 -hr SO2 NAAQS and it is concluded that the Martin Marietta Highway 34 facility causes and/or contributes to modeled violations of the 1 -hr NO2 NAAQS. The compliance demonstration (excluding 1 -hr NO2) is valid under the following configuration (recommended permit conditions): 1. Hours of Operation: Modeled impacts were estimated assuming that the operations of the hot mix asphalt plant, hot mix asphalt plant silo loading, hot mix asphalt plant screen and material transfers, hot mix asphalt plant material transfers, and lime silo are restricted to 16 hours/day from 5:00 am to 9:00 pm. Emission rates in the model for the rest of the hours were assumed to be zero for these activities. The permit should contain a condition that for the duration of the permit effectiveness, the hours of operation of the hot mix asphalt plant, hot mix asphalt plant silo loading, hot mix asphalt plant screen and material transfers, hot mix asphalt plant material transfers, and lime silo will be restricted for 16 hours/day from 5:00 am to 9:00 pm. 2. Hours of Operation: Modeled impacts were estimated assuming that the operations of the train unloading and Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 1 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 aggregate sales and operations (haul roads for transfer from the aggregate piles to the intermediate storage piles, aggregate transfers occurring around and between the aggregate storage piles, railcar unloading, and plant conveyor transfers) are restricted to 14 hours/day from 6:00 am to 8:00 pm. Emission rates in the model for the rest of the hours were assumed to be zero for these activities. The permit should contain a condition that for the duration of the permit effectiveness, the hours of operation of the train unloading and aggregate sales and operations (haul roads for transfer from the aggregate piles to the intermediate storage piles, aggregate transfers occurring around and between the aggregate storage piles, railcar unloading, and plant conveyor transfers) will be restricted for 14 hours/day from 6:00 am to 8:00 pm. 3. Fencing and Preclusion of Public Access: Impacts were estimated at ambient air receptors only (i.e., an ambient air boundary and fencing was assumed in the modeling). The permit should contain a condition that for the duration of the permit effectiveness, the source operator shall maintain continuous fencing along the boundary depicted in Figures 2-1, 5-1, and 5-3 of the June 2017 submittal "Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report." Public access into these areas shall be precluded. 4. Stack Heights: Modeled impacts were estimated assuming the stack heights indicated as release heights in Tables D-23, D-24, D-25, and D-26 of the June 2017 submittal "Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report." The permit should contain a condition that the facility should be constructed with the layout and road location depicted in Figures 5-1, 5-3, 6- 1, 6-2, and 6-3. 5. Layout of Sources and Roads: Modeled impacts were estimated assuming that the location of the roads and the layout of buildings and sources within the facility correspond to the one indicated in Figures 5-1, 5-3, 6-1, 6-2, and 6-3 of the June 2017 submittal "Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report." The permit should contain a condition that the facility should be constructed with the layout and road location depicted in the aforementioned figures. The results of the modeling analyses are summarized below: For the 3 -hr and 8 -hr CO Significant Impact Analysis, the maximum modeled concentrations are shown in the following table: Ave Max Modeled Pollutant Period Concentration (First High) SIL Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 2 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 CO 1 -hr 435.66 ug/m3 2000 ug/m3 CO 8 -hr 86.36 ug/m3 500 ug/m3 The values are the first highest maximum 1 -hour and 8 -hour concentration. Since the SILs were not exceeded for both averaging periods, compliance is demonstrated for both 1 -hr and 8 -hr CO NAAQS. For the 1 -hr, 3 -hr, and 24 -hr SO2 Significant Impact Analysis, the maximum modeled concentrations are shown in the following table: Ave Max Modeled Pollutant Period Concentration (First High) SIL SO2 1 -hr 7.24 ug/m3 4 ug/m3 SO2 3 -hr 4.52 ug/m3 25 ug/m3 SO2 24 -hr 1.13 ug/m3 5 ug/m3 The 1 -hr value is the highest first high maximum daily 1 -hr concentration. The 3 -hr and 24 -hr values are the highest first high maximum 3 -hr and 24 -hr concentration. Since the SILs were not exceeded for the 3 -hr and 24 -hr averaging periods, compliance is demonstrated for both 3 -hr and 24 -hr SO2 NAAQS. Given the 1 -hr SIL was exceeded, a cumulative impact analysis was conducted and the results are shown in the table below: Ave Max Modeled Background Total Pollutant Period Concentration Concentration Impact NAAQS SO2 1 -hr 15.83 ug/m3 15.72 ug/m3 31.55 ug/m3 196.5 ug/m3 The value corresponds to the highest first high maximum daily 1 -hour concentration and given that the total impact is below the corresponding NAAQS, it can be concluded that the permitted facility does not cause or contribute to a modeled violation of this Standard. For the 24 -hr PM2.5 Significant Impact Analysis, the maximum concentration modeled as the highest first high 24 -hr average of the years modeled, is shown in the following table: Ave Max Modeled Pollutant Period Concentration (First High) SIL Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 3 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility' Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 PM2.5 24 -hr 11.20 ug/m3 1.2 ug/m3 The value is the highest first high 24 -hr concentration averaged acros the years modeled. Given that the SIL was exceeded, a cumulative impact analysis was conducted and the results are shown in the table below: Ave Modeled Background Total Pollutant Period Concentration Concentration Impact NAAQS PM2.5 24 -hr 12.99 ug/m3 22 ug/m3 34.99 ug/m3 35 ug/m3 The value corresponds to the highest modeled concentration that shows compliance with the corresponding NAAQS. The 24 -hr PM2.5 model analysis showed 995 modeled violations; however, at each modeled violation the Highway 34 facility does not contribute significantly. Since the contribution of Highway 34 is insignificant at all modeled violations, it can be concluded that the permitted facility shows compliance with the corresponding NAAQS. For the 24 -hr PM10 Significant Impact Analysis, the maximum concentration modeled as the highest first high 24 - hr average of the years modeled, is shown in the following table: Ave Max Modeled Pollutant Period Concentration (First High) SIL PM10 24 -hr 72.18 ug/m3 5 ug/m3 The value is the highest first high 24 -hr concentration averaged acros the years modeled. Given that the SIL was exceeded, a cumulative impact analysis was conducted and the results are shown in the table below: Ave Modeled Background Total Pollutant Period Concentration Concentration Impact NAAQS PM10 24 -hr 92.40 ug/m3 42 ug/m3 134.40 ug/m3 150 ug/m3 Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 4 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 The value corresponds to the highest modeled concentration that shows compliance with the corresponding NAAQS. The 24 -hr PM10 model analysis showed 2 modeled violations; however, at each modeled violation the Highway 34 facility does not contribute significantly. Since the contribution of Highway 34 is insignificant at all modeled violations, it can be concluded that the permitted facility shows compliance with the corresponding NAAQS. For the 1 -hr NO2 Significant Impact Analysis, the maximum modeled concentraion is shown in the following table: Ave Max Modeled Pollutant Period Concentration (First High) SIL NO2 1 -hr 65.60 ug/m3 7.5 ug/m3 The value is the highest first high daily maximum 1 -hour concentration. Given that the SIL was exceeded, a cumulative impact analysis was conducted and the results are shown in the table below: Ave Modeled Highway 34 Background Total Pollutant Period Concentration Contribution Concentration Impact NAAQS NO2 1 -hr 212.28 ug/m3 7.79 ug/m3 34 ug/m3 246.28 ug/m3 188 ug/m3 The value corresponds to the highest modeled concentration where Highway 34 contributes significantly. The 1 -hr NO2 model analysis showed 9 modeled violations that Highway 34 is contributing to signficantly (contribution of Highway 34 is above the SIL). This model analysis also showed 2759 modeled violations where Highway 34 is not contributing significantly. With the modeled results from this analysis, it can be concluded that Highway 34 causes and/or contributes to modeled violations of the 1 -hr NO2 NAAQS. Review Checklist 1. Topographic Map with Site and Receptor Locations Submitted with the application. Satisfactory 2. Plant/Site Plot Plan Satisfactory Submitted with the application. Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 5 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 3. Building Dimension Data Submitted with the application. Satisfactory 4. Determination of Fenceline Submitted with the application. Satisfactory 5. Identification of Nearby Nonattainment Areas The facility is located in a moderate nonattainment area for 8 -hr Ozone NAAQS. The area is unclassifable/attaimnent for all other pollutants and averaging periods. Not Applicable 6. Identification of Pollutants/Averaging Periods to Model Unsatisfactory There are NAAQS and CAAQS currently in effect for the following pollutants and averaging periods: CO (1 -hr and 8 -hr), Pb (3 -month rolling average), NO2 (1 -hr and annual), PM10 (24 -hr), PM2.5 (24 -hr and annual), SO2 (1 -hr, 3 -hr, 24 -hr, and annual), and ozone (8 -hr). For this permit application, quantitative impact analyses are warranted to demonstrate compliance with the NAAQS/CAAQS for the following pollutants and averaging periods: CO (1 -hr and 8 -hr), NO2 (1 -hr), PM10 (24 -hr), PM2.5 (24 -hr), and SO2 (1 -hr, 3 -hr, and 24 -hr). The applicant submitted modeling analyses for all required pollutants and averaging periods except the NO2 (1 -hr) and SO2 (1 -hr, 3 -hr, and 24 -hr). The consultant allowed the MEIU to perform the SO2 (3 -hr and 24 -hr) modeling analyses. The SSP decided modeling for the 1 -hr NO2 and 1 -hr SO2 pollutants and averaging periods was not warranted per PS Memo 10-01. 7. On -Site NAAQS/Non-Criteria Pollutant Emission Inventory Verification of emission rates and exhaust stack parameters of the modified facility is deferred to the permit engineer; However, the MEIU updated emission rates of several sources based on calculations. Unsatisfactory 8. On -Site PSD Increment Emission Inventory Not Applicable 1 A preliminary determination in June 1998 from the Colorado Attorney General's office suggests that rulemaking would be necessary before compliance with PSD increments is a requirement of permit issuance for minor sources and minor modifications. Therefore, increment consumption from minor source growth is assessed only during the modeling Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 6 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 process for new sources and modifications subject to PSD rules and during periodic increment studies. 9. Off -Site NAAQS/Non-Criteria Pollutant Emission Inventory Submitted with the application. The MEIU included several more nearby sources based on the significant imapct area for each pollutant and averaging period. Professional judgement was used by the MEIU to determine which nearby sources to include. Unsatisfactory 10. Off -Site PSD Increment Emission Inventory See Number 8 above. Not Applicable 11. Background Concentration(s) The following background concentrations were provided to the applicant by the APCD and used by the applicant: 24 -hr PM10 = 42 ug/m3; 24 -hr PM2.5 = 22 ug/m3. The MEIU obtained additional background concentrations in order to complete the remaining necessary modeling analyses. The following background concentraions were used by the MEIU: 1 -hr SO2 = 0.006 ppm; 3 -hr SO2 = 0.004 ppm; 24 -hr SO2 = 0.001 ppm; 1 -hr NO2 = 0.018 ppm. Satisfactory 12. Selection of Model(s) Satisfactory The applicant used the EPA regulatory model AERMOD, the terrain data processor AERMAP, and the building downwash parameters processor BPIPPRM. The applicant used the most current version of these programs available at the moment of submitting the application. The following versions were used: AERMOD v16216r, AERMAP v11103, and BPIPPRM v04274. The APCD provided the applicant with the AERMOD- ready meteorological files, so tehre was no need for the applicant to use the meteorological data processor AERMET. The meteorological files were processed with AERMET v16216. 13. Selection of Modeling Parameters The regulatory default was used. The WSPEED keyword to vary emissions by wind speed was used for wind erosion sources. The HROFDY keyword to vary emissions by hour of day was used for sources limited to particular operating hours. The NOWETDPLT and DRYDPLT keywords were used to disable wet depletion processes and to incorporate dry depletion processes, respectively. Satisfactory Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 7 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 14. Receptor Network Satisfactory The extent and spacing of the receptor grid was adequate. The receptor network has the following spacing: -25 meter spacing along the facility boundary/fenceline - 100 meter spacing from facility boundary to 1 km - 250 meter spacing from 1 km to 3 km -500 meter spacing from 3 km to 10 km 15. Treatment of Atmospheric Chemistry (NOx conversion) A Tier 1 analysis was performed by the MEIU, meaning that 100% NOx to NO2 conversion was assumed. Satisfactory 16. Standard Temperature Pressure Corrections STP corrections are currently not required for permit modeling in Colorado. Not Applicable 17. Meteorological Data for Model(s) The meteorological determination for High 34 follows. Satisfactory The Division has completed the AERMOD meteorological determination for: Source: Highway 34 Approximate Location: UTME: 505120.580 m, UTMN: 4471929.046 m NAD 83, Zone 13 There are no existing meteorological data, to the Division's knowledge, that are adequately representative of dispersion conditions expected at this site. Consequently, the applicant may either collect a year of site -specific meteorological data (see option 1) to support a refined AERMOD modeling analysis, or the applicant may perform a screening impact analysis with AERMOD and the hourly meteorology presented in option 2. If AERMOD is used in a screening type mode with hourly meteorological data, design value restrictions will apply. The applicant is welcome to provide additional information to assist the meteorological determination process. OPTION 1: Collect at least one year of site specific meteorological data with a tower setup and Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 8 of 16 Modeling Review Comments APCD/TSPAVIMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 location approved by the Division. The monitoring program must be performed in accordance with U.S.EPA accepted procedures as approved by the Division. If this option is pursued, it is strongly recommended that a monitoring plan be prepared and submitted to the Division for review prior to collection of the data. Once data has been collected and approved by the Division, contact the Division for site -specific AERMET processing guidance. OPTION 2: SURFACE METEOROLOGY Met Site: Kodak Tower LAT/LONG: 40.4614 N, -104.8747 W Tower Elevation: 1455.7 m Tower type: private tower Data period: 1993 - 1997 Data type: PSD quality Data availability: attached to email UPPER AIR METEOROLOGY Site: KDEN (Denver, Colorado) WBAN number: 23062 Data type: Radiosonde Site LAT/LONG: 39.77N, 104.88W Collected by: National Weather Service Data format: NOAA Forecast Systems Laboratory (fsl) format Data availability: attached to email AERMOD Screening Impact Analysis Design Concentrations (for use with hourly met data of Option 2): *Use the highest modeled impact in the compliance demonstration from the "high 1st high" for averages less than or equal to 24 hours for short-term standards and "1st high" for annual standards from individual years. If the meteorology associated with the "high 1st high" is not plausible at the source location, please contact me for a re-evaluation of the design value. *For demonstrating compliance with standards that are attained from a multi -year Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 9 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 average (e.g., 3 -year average of the 98th percentile of the daily maximum 1 -hour NO2 concentrations or 3 -year average of the annual mean PM2.5 concentrations), the procedure above may be refined by using the maximum n -year average of the 1st -high corresponding averaging period concentrations determined on a receptor -by -receptor basis (where n equals the number of years modeled). *When determining compliance with the 1 -hr NO2 standard, use 100% conversion of NO to NO2. When determining compliance with the annual NO2 standard, use either the Tier 1 (100% conversion of NO to NO2) or Tier 2 (multiply the Tier 1 estimate(s) by 0.75, the recommended empirically -derived NO2/NOx value for Colorado) approach from 40 CFR 51 Appendix W. If a different NO2 conversion approach than those listed above is needed for estimating either 1 -hr or annual NO2 concentrations, contact Doris Jung (doris.jung@state.co.us) for details. This determination is not applicable for an unlimited period and may expire if there is a substantial delay between the date of this determination and the submittal of the permit application. If the location of the source moves or if additional modeling is warranted in the future at this site, contact the Division to confirm if this met determination is still valid. This determination is applicable provided that the permit application is not subject to the PSD rules. If the permitting action is subject to PSD rules, please contact the Division for a PSD pre -construction monitoring deter i,ination. FAQs on Air Quality Modeling Data and Techniques are available here http://www. colorado.gov/airquality/permits/FAQsOnAirQualityModelingDataAndTechni ques13Jul.pdf. National elevation data files are available here: http://www.colorado.gov/airquality/quad_selector_map.aspx. If there are questions, please contact Doris Jung (doris.jung@state.co.us). The completeness checklist for modeling submittals is available here: http://www. colorado. gov/airquality/permits/CompletenessChecklist- ModelingSubmitta114Feb. pdf. State law requires that the Division determine the completeness of an application or any supplemental information requested for the application by the Division within 60 days of receipt. If the application (this includes the modeling submittal) is deemed incomplete, the applicant will be notified regarding the deficiencies and asked to either supplement the application or submit a new complete application. It is important to note that our review will not begin until a complete application has been received. Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 10 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 18. Other Modeling Data Not Applicable 19. Modeling Input/Output Files Provided Electronically All modeling input and output files were provided electronically. Satisfactory 20. Comparison of Impacts with Significance Levels The results of the significant impact analyses are provided below: Satisfactory Ave Max Modeled Pollutant Period Concentration (First High) SIL CO 1 -hr 435.66 ug/m3 2000 ug/m3 CO 8 -hr 86.36 ug/m3 500 ug/m3 SO2 1 -hr 7.24 ug/m3 4 ug/m3 SO2 3 -hr 4.52 ug/m3 25 ug/m3 SO2 24 -hr 1.13 ug/m3 5 ug/m3 PM2.5 24 -hr 11.20 ug/m3 1.2 ug/m3 PM10 24 -hr 72.18 ug/m3 5 ug/m3 NO2 1 -hr 65.60 ug/m3 7.5 ug/m3 For CO, the 1 -hr value is the first highest maximum 1 -hour concentration averaged across the years modeled and the 8 -hr value if the first highest maximum 8 -hr concentration averaged across the years modeled. For SO2, the 1 -hr value is the highest first high maximum daily 1 -hr concentration. For SO2, the 3 -hr and 24 -hr values are the highest first high maximum 3 -hr and 24 -hr concentration, respectively. For PM2.5 the 24 - hr value is the highest of the receptor -specific average across the years of the first high 24 -hr modeled concentration. For PM10, the 24 -hr value is the highest first high 24 -hr averaged across the years modeled. For NO2, the 1 -hr value is the highest of the receptor -specific five-year average of the first highest daily maximum 1 -hr concentration. The corresponding SILs were exceeded for the following pollutants and averaging periods: 1 -hr SO2, 24 -hr PM2.5, 24 -hr PM10, and 1 -hr NO2. Cumulative impact analyses were conducted for the pollutants and averaging periods (just listed) that exceeded the corresponding SIL. Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 11 of ' 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 21. Comparison of Impacts with Class 124hr lug/m3 Rule The permitted facility is not subject to PSD requirements. Not Applicable 22. Compliance with "75% of Applicable Increment" Rule The permitted facility is not subject to PSD requirements. Not Applicable 23. Selection of Geographic Area for Full Impact Analysis The area selected for the full impact analysis was adequate. Satisfactory 24. Compliance with Class I PSD Increments The permitted facility is not subject to PSD requirements. Not Applicable 25. Compliance with Class II PSD Increments The permitted facility is not subject to PSD requirements. Not Applicable 26. Compliance with NAAQS and State Standards Unsatisfactory The applicant submitted modeling analyses for all required pollutants and averaging periods except the NO2 (1 -hr) and SO2 (1 -hr, 3 -hr, and 24 -hr). The consultant allowed the MEIU to perform the SO2 (3 -hr and 24 -hr) modeling analyses. The SSP decided modeling for the 1 -hr NO2 and 1 -hr SO2 pollutants and averaging periods was not warranted per PS Memo 10-01. After review of the analyses submitted by the applicant with revisions by the MEIU, it is concluded that the Martin Marietta Highway 34 new facility will not cause or contribute to any modeled violation of the corresponding NAAQS/CAAQS. The MEIU conducted a modeling analysis for the 1 -hr NO2, 1 -hr SO2, 3 -hr SO2, and 24 -hr SO2 NAAQS and it is concluded that the Martin Marietta Highway 34 facility causes and/or contributes to modeled violations of the 1 -hr NO2 NAAQS. The compliance demonstration (excluding 1 -hr NO2) is valid under the following configuration (recommended permit conditions): 1. Hours of Operation: Modeled impacts were estimated assuming that the operations of the hot mix asphalt plant, hot mix asphalt plant silo loading, hot mix asphalt plant screen and material transfers, hot mix asphalt plant material transfers, and lime silo are restricted to 16 hours/day from 5:00 am to 9:00 pm. Emission rates in the model for the Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 12 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 rest of the hours were assumed to be zero for these activities. The permit should contain a condition that for the duration of the permit effectiveness, the hours of operation of the hot mix asphalt plant, hot mix asphalt plant silo loading, hot mix asphalt plant screen and material transfers, hot mix asphalt plant material transfers, and lime silo will be restricted for 16 hours/day from 5:00 am to 9:00 pm. 2. Hours of Operation: Modeled impacts were estimated assuming that the operations of the train unloading and aggregate sales and operations (haul roads for transfer from the aggregate piles to the intermediate storage piles, aggregate transfers occurring around and between the aggregate storage piles, railcar unloading, and plant conveyor transfers) are restricted to 14 hours/day from 6:00 am to 8:00 pm. Emission rates in the model for the rest of the hours were assumed to be zero for these activities. The permit should contain a condition that for the duration of the permit effectiveness, the hours of operation of the train unloading and aggregate sales and operations (haul roads for transfer from the aggregate piles to the intermediate storage piles, aggregate transfers occurring around and between the aggregate storage piles, railcar unloading, and plant conveyor transfers) will be restricted for 14 hours/day from 6:00 am to 8:00 pm. 3. Fencing and Preclusion of Public Access: Impacts were estimated at ambient air receptors only (i.e., an ambient air boundary and fencing was assumed in the modeling). The permit should contain a condition that for the duration of the permit effectiveness, the source operator shall maintain continuous fencing along the boundary depicted in Figures 2-1, 5-1, and 5-3 of the June 2017 submittal "Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report." Public access into these areas shall be precluded. 4. Stack Heights: Modeled impacts were estimated assuming the stack heights indicated as release heights in Tables D-23, D-24, D-25, and D-26 of the June 2017 submittal "Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report." The permit should contain a condition that the facility should be constructed with the layout and road location depicted in Figures 5-1, 5-3, 6-1, 6-2, and 6-3. 5. Layout of Sources and Roads: Modeled impacts were estimated assuming that the location of the roads and the layout of buildings and sources within the facility correspond to the one indicated in Figures 5-1, 5-3, 6-1, 6-2, and 6-3 of the June 2017 Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 13 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 submittal "Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report." The permit should contain a condition that the facility should be constructed with the layout and road location depicted in the aforementioned figures. The resulting modeled concentrations are the following (this excludes the pollutants and averaging periods that were below the corresponding SIL and therefore did not trigger a cumulative impact analysis): Ave Modeled Pollutant Period Concentration Background Total Concentration Impact NAAQS SO2 1 -hr PM2.5 24 -hr PM10 24 -hr NO2 1 -hr 15.83 ug/m3 12.99 ug/m3 92.40 ug/m3 212.28 ug/m3 15.72 ug/m3 22 ug/m3 42 ug/m3 34 ug/m3 31.55 ug/m3 196.5 ug/m3 34.99 ug/m3 35 ug/m3 134.40 ug/m3 150 ug/m3 246.28 ug/m3 188 ug/m3 The SO2 1 -hr value corresponds to the highest first high maximum daily 1 -hour concentration. The PM2.5 24 -hr value corresponds to the highest modeled concentration that shows compliance with the corresponding NAAQS. The 24 -hr PM2.5 model analysis showed 995 modeled violations, however, at each modeled violation the Highway 34 facility does not contribute significantly. The PM 10 24 -hr value corresponds to the highest modeled concentration that shows compliance with the corresponding NAAQS. The 24 -hr PM10 model analysis showed 2 modeled violations; however, at each modeled violation the Highway 34 facility does not contribute significantly. The NO2 1 -hr value corresponds to the highest modeled concentration where Highway 34 contributes significantly. The 1 -hr NO2 model analysis showed 9 modeled violations that Highway 34 is contributing to signficantly (contribution of Highway 34 is above the SIL). This model analysis also showed 2759 modeled violations where Highway 34 is not contributing significantly. The total impact for 1 -hr SO2 is below the corresponding NAAQS, therefore it can be concluded that the permitted facility does not cause or contribute to a modeled violation of the 1 -hr SO2 NAAQS. Given that the contribution of the Highway 34 facility is insignificant at all modeled violations of the 24 -hr PM2.5 and 24 -hr PM10 NAAQS, it can be concluded that the permitted facility does not cause or contribute to a modeled Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 14 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 violation of the 24 -hr PM2.5 and 24 -hr PM10 NAAQS. Given that the Highway 34 facility contributes signifcantly to modeled violations of the 1 -hr NO2 NAAQS, it can be concluded that the permitted facility causes and/or contributes to modeled violations of the 1 -hr NO2 NAAQS; therefore, compliance is not demonstrated for the 1 -hr NO2 NAAQS. (The SSP decided modeling for the 1 -hr NO2 and 1 -hr SO2 pollutants and averaging periods was not warranted per PS Memo 10-01.) 27. Compliance with Non -Criteria Pollutant Thresholds Not Applicable 28. Determination of Pre -/Post -Monitoring Requirements The permitted facility is not subject to PSD requirements. Not Applicable 29. Visibility Impairment and AQRV Analyses Not Applicable J The permitted facility is not subject to PSD requirements. 30. Anticpated Growth/Soils/Vegetation Analyses The permitted facility is not subject to PSD requirements. Not Applicable 31. Compliance with Regulations in Affected Adjacent States Not Applicable 32. Risk Assessment Not Applicable Risk assessment and review of impacts from hazardous air pollutants are not performed on a routine basis and are only performed when a specific request is made by the Stationary Sources Program (SSP). The SSP dies not request a risk assessment for this application. Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 15 of 16 Modeling Review Comments APCD/TSP/MMEIU Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Document Reviewed: - Martin Marietta Materials Highway 34 Facility Asphalt Plant State New Source Review Application and Modeling Report. June 2017 Reviewed by: Marie Bernardo Review Completed: 9/22/2017 Access to data, notes, and files: All information necessary to form the basis of the air quality compliance demonstration is transmitted to the permit reviewer for inclusion in the permit file. In some cases, the Technical Services Program retains ambient air monitoring and modeling data, ambient monitoring and modeling plans and reports, electronic modeling input/output files, and other files. These files may contain documents that are considered to be part of a deliberative process. Date Printed: 10/17/2017 Air Pollution Control Division / Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Page 16 of 16 PROJECT NOTES Page 1 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 2/8/2017 Note entered into database by: Marie Bernardo Note: Forwarded message From: Malone - CDPHE, Emmett <emmett.malone@state.co.us> Date: Wed, Feb 8, 2017 at 12:20 PM Subject: Re: Meteorological determination for Highway 34 To: Anna Unruh <aunruh@trinityconsultants.com> Cc: Walter Wright<Walter.Wright@martinmarietta.com>, Ashley Jones <AVJones@trinityconsultants.com> Attachments: KODAK 1993-1997_ADJ U.zip; KPDAK_1993-1997.zip Hi, I have attached the Kodak data sets processed with AERMET 16216 with ADJ_U* and without ADJ_U*. I do not know if you want to use ADJ_U* but to save time I have included it. I should tell you that if you do use ADJ_U* be aware that the Division has received two applications where the use of ADJ_U* created higher impacts with wind speeds below 2.5 m/s. We has an idea of how/why this is happening but are still looking into it. This site is in the Big Thompson River Valley. It is expected that the diurnal winds will be oriented with the Big Thompson River Valley. At the High 34 site they are expected to be a northwest to southeast orientation. The Kodak data set is in the Cache la Poudre River Valley. It has more of a west to east orientation where the data was collected. Then there is a north wind that spills out of Wyoming (why Laramie and Cheyenne are so windy) it shows up in the Kodak data. This wind is less prominent the further south into Colorado so that it is not very apparent at Ft St Vrain. The Modeling and Emissions Inventory Unit (MEIU) does not know how much these north winds will affect the Highway 34 location. Because of these conditions MEIU believes the Kodak data when used in AERMOD will not place the maximum impacts in the location they are expected to occur at and may not predict the worst case impacts.These are two conditions Appendix W requires for meteorological data to be adequately representative. Emmett Malone Supervisor Modeling and Emissions Inventory Unit Technical Services Program Air Pollution Control Division Colorado Department of Public Health and Environment APCD-TS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-31361Emmett.Malone@state.co.us Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES On Sat, Feb 4, 2017 at 11:19 AM, Anna Unruh <aunruh@trinityconsultants.com> wrote: Hi Emmett, Page 2 of 35 After being on hold while designs were finalized, Martin Marietta is looking to resume modeling for the project described below. Will revised met data (processed with the new version of AERMET) be required for this project? If so, please provide the met data that the CDPHE would like Martin Marietta to use for the analysis. Additionally, please provide an explanation as to why data from the Kodak met station is not adequately representative of the Highway 34 facility. Thanks, Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com From: Malone - CDPHE, Emmett [mailto:emmett.malone@state.co.us] Sent: Tuesday, June 02, 2015 8:28 AM To: Ashley Jones <AVJones@trinityconsultants.com> Cc: Thayer - CDPHE, David <david.thayer@state.co.us>; nancy.chick@state.co.us; Doris Jung - CDPHE <doris.jung@state.co.us>; Anna Unruh<aunruh@trinityconsultants.com>; Walter Wright <Walter.Wright@martinmarietta.com>; Rosendo Majano - CDPHE <rosendo.majano@state.co.us> Subject: Meteorological determination for Highway 34 Hi Ashley, The meteorological determination for High 34 follows. If you have any questions let me know. The Division has completed the AERMOD meteorological determination for: Source: Highway 34 Approximate Location: UTME: 505120.580 m, UTMN: 4471929.046 m NAD 83, Zone 13 There are no existing meteorological data, to the Division's knowledge, that are adequately representative of dispersion conditions expected at this site. Consequently, the applicant may either collect a year of site -specific meteorological data (see option 1) to support a refined AERMOD modeling analysis, or the applicant may perform a screening impact analysis with AERMOD and the hourly meteorology presented in option 2. If AERMOD is used in a screening type mode with hourly meteorological data, design value restrictions will apply. The applicant is welcome to provide additional information to assist the meteorological determination process. OPTION 1: Collect at least one year of site specific meteorological data with a tower setup and location approved by the Division. The monitoring program must be performed in accordance with U.S.EPA accepted procedures as approved by the Division. If this option is pursued, it is strongly recommended that a monitoring plan be prepared Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 3 of 35 and submitted to the Division for review prior to collection of the data. Once data has been collected and approved by the Division, contact the Division for site -specific AERMET processing guidance. OPTION 2: SURFACE METEOROLOGY Met Site: Kodak Tower LAT/LONG: 40.4614 N, -104.8747 W Tower Elevation: 1455.7 m Tower type: private tower Data period: 1993 - 1997 Data type: PSD quality Data availability: attached to email UPPER AIR METEOROLOGY Site: KDEN (Denver, Colorado) WBAN number: 23062 Data type: Radiosonde Site LAT/LONG: 39.77N, 104.88W Collected by: National Weather Service Data format: NOAA Forecast Systems Laboratory (fsl) format Data availability: attached to email AERMOD Screening Impact Analysis Design Concentrations (for use with hourly met data of Option 2): *Use the highest modeled impact in the compliance demonstration from the "high 1st high" for averages less than or equal to 24 hours for short-term standards and "1st high" for annual standards from individual years. If the meteorology associated with the "high 1st high" is not plausible at the source location, please contact me for a re- evaluation of the design value. *For demonstrating compliance with standards that are attained from a multi -year average (e.g., 3 -year average of the 98th percentile of the daily maximum 1 -hour NO2 concentrations or 3 -year average of the annual mean PM2.5 concentrations), the procedure above may be refined by using the maximum n -year average of the 1st -high corresponding averaging period concentrations determined on a receptor -by -receptor basis (where n equals the number of years modeled). *When determining compliance with the 1 -hr NO2 standard, use 100% conversion of NO to NO2. When determining compliance with the annual NO2 standard, use either the Tier 1 (100% conversion of NO to NO2) or Tier 2 (multiply the Tier 1 estimate(s) by 0.75, the recommended empirically -derived NO2/NOx value for Colorado) approach from 40 CFR 51 Appendix W. If a different NO2 conversion approach than those listed above is needed for estimating either 1 -hr or annual NO2 concentrations, contact Doris Jung (doris.jung@state.co.us) for details. This determination is not applicable for an unlimited period and may expire if there is a substantial delay between the date of this determination and the submittal of the permit application. If the location of the source moves or if additional modeling is warranted in the future at this site, contact the Division to confirm if this met determination is still valid. This determination is applicable provided that the permit application is not subject to the PSD rules. If the permitting action is subject to PSD rules, please contact the Division for a PSD pre -construction monitoring determination. FAQs on Air Quality Modeling Data and Techniques are available here Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 4 of 35 http://www.colorado.gov/airquality/permits/FAQsOnAirQualityModelingDataAndTechniquesl3Jul.pdf. National elevation data files are available here: http://www.colorado.gov/airquality/quad_selector_map.aspx. If there are questions, please contact Doris Jung (doris.jung@state.co.us). The completeness checklist for modeling submittals is available here: http: //www. colorado. gov/airquality/permits/CompletenessChecklist-ModelingSubmitta114Feb.pdf State law requires that the Division determine the completeness of an application or any supplemental information requested for the application by the Division within 60 days of receipt. If the application (this includes the modeling submittal) is deemed incomplete, the applicant will be notified regarding the deficiencies and asked to either supplement the application or submit a new complete application. It is important to note that our review will not begin until a complete application has been received. Emmett Malone Air Quality Meteorologist Modeling, Meteorology, and Emissions Inventory Unit Technical Services Program Air Pollution Control Division Colorado Department of Public Health and Environment APCD-TS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-31361 Emmett.Malone@state.co.us On Mon, Jun 1, 2015 at 2:24 PM, Ashley Jones <AVJones@trinityconsultants.com> wrote: Hi CDPHE Modeling Group, I would like to request a formal meteorological determination, nearby source inventory, and background concentration for a new proposed Martin Marietta facility. The proposed facility is —5 miles east of Loveland near the Larimer/Weld County line. Attached is a topographic map of the location with Latitude/Longitude coordinates (40.39795, -104.93966) of the approximate center of the proposed facility. The Proposed Facility: Tentative Site Name: Highway 34 Source Type: Aggregate processing, Ready -Mix facility, and Asphalt facility. No mining. Stack types: Short to mid -level point sources and low level fugitives Pollutants for Background Concentration and Inventory: PM10 PM2.5 We do not anticipate triggering gaseous pollutant state AAQS requirements, but will make the separate request for Carbon Monoxide if needed. Please let me know if you have any questions or need any additional data to process the request. Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 5 of 35 Also, if there are recent developments in regards to modeling requirements that we should be aware please let us know. Thanks, Ashley Ashley Jones I Senior Consultant Trinity Consultants 120819 72nd Avenue S., Suite 610 I Kent, WA 98032 P: 253.867.5600 I F: 253.867.5601 I E: avjones@trinityconsultants.com Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 6 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 4/13/2017 Note entered into database by: Marie Bernardo Note: From: David Thayer To: Anna Unruh; Emmett Malone; Marie Bernardo; Rosendo Majano; Will Vicars Subject: Request for Meteorological Data/Inventory Source Data/Background Concentration for proposed facility Attachment: Neaby Sources Hwy 34 facility.xlsx I have attached spreadsheets containing the data you requested. You will be invoiced $30 via US mail. If this is for a permit application currently being processed, I can apply the charges to the permit invoice. For me to do this I'll need the permit number. If you have any questions regarding these data please feel free to contact me. David Thayer, Public Health Engineer Colorado Department of Public Health and Environment Air Pollution Control Division / Stationary Sources Program david.thayer@state.co.us, Voice:303-692-3187, FAX:303-782-0278 On Wed, Apr 12, 2017 at 5:15 PM, Anna Unruh <aunruh@trinityconsultants.com> wrote: > Hi David, > The modeling analysis for this project was delayed significantly, therefore we would like to request updated nearby source data for the site described in the emails below. Please let me know if you need any additional information. > Thanks, > Anna > Anna Unruh > Senior Consultant > Trinity Consultants > 1391 N Speer Blvd Suite 350 I Denver, CO 80204 > Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 > Email: aunruh@trinityconsultants.com > > Original Message > From: Thayer - CDPHE, David[mailto:david.thayer@state.co.us] > Sent: Tuesday, February 09, 2016 3:46 PM Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 7 of 35 > To: Ashley Jones <AVJones@trinityconsultants.com> > Cc: Doris Jung - CDPHE <doris.jung@state.co.us>; emmett.malone <emmett.malone@state.co.us>; Rosendo Majano - CDPHE <rosendo.majano@state.co.us> > Subject: Re: Request for Meteorological Data/Inventory Source Data/Background Concentration for proposed facility > Ashley, > While investigating some SQL Server backend issues I noticed that numerous PM2.5 values which had originally been scaled from PM10 values hadn't been updated along with their corresponding PM10 records. I ran a batch update to correct this issue. > Since the source list I sent you last week likely contains affected records I have re -run the extraction and attached the results. > I apologize for any inconvenience this may have caused you. > dt > David Thayer, Public Health Engineer > Colorado Department of Public Health and Environment Air Pollution Control Division / Stationary Sources Program david.thayer@state.co.us, Voice:303-692-3187, FAX:303-782-0278 > On Thu, Feb 4, 2016 at 11:54 AM, Ashley Jones <AVJones@trinityconsultants.com> wrote: >> THANKS! >> Thanks, >> Ashley >> 253-867-5600 » Original Message >> From: Thayer - CDPHE, David [mailto:david.thayer@state.co.us] >> Sent: Thursday, February 04, 2016 10:54 AM >> To: Ashley Jones <AVJones@trinityconsultants.com> >> Cc: Doris Jung - CDPHE <doris.jung@state.co.us>; emmett.malone >> <emmett.malone@state.co.us>; Rosendo Majano - CDPHE >> <rosendo.majano@state.co.us> >> Subject: Re: Request for Meteorological Data/Inventory Source >> Data/Background Concentration for proposed facility >> D'oh! I knew there was some detail I forgot yesterday. >> See attached. » -- >> David Thayer, Public Health Engineer >> Colorado Department of Public Health and Environment Air Pollution >> Control Division / Stationary Sources Program >> david.thayer@state.co.us, Voice:303-692-3187, FAX:303-782-0278 Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 8 of 35 >> On Wed, Feb 3, 2016 at 11:02 AM, Ashley Jones <AVJones@trinityconsultants.com> wrote: >>> Hi David, »> >>> We are preparing to submit the NSR application for the Highway 34 project and realize it has been 8 months since we received the original inventory dataset, so based on my discussions with Emmett (he is reviewing the modeling protocol) he suggested I check in with you on whether there is a more recent inventory set that needs to be evaluated for the project. »> >>> If so, is it possible to pay the $30 fee with the APEN fee upon submittal? We expect to submit the application in the next couple weeks. »> >>> Thanks, >>> Ashley >>> 253-867-5600 »> >>> Original Message >>> From: Thayer - CDPHE, David [mailto:david.thayer@state.co.us] >>> Sent: Friday, June 05, 2015 4:34 PM >>> To: Ashley Jones <AVJones@trinityconsultants.com> >>> Cc: Doris Jung - CDPHE <doris.jung@state.co.us>; emmett.malone >>> <emmett.malone@state.co.us>; Rosendo Majano - CDPHE >>> <rosendo.majano@state.co.us> >>> Subject: Re: Request for Meteorological Data/Inventory Source >>> Data/Background Concentration for proposed facility »> »> I have attached spreadsheets containing the data you requested. You will be invoiced $30 via US mail. >>> >>> If you have any questions regarding these data please feel free to contact me. »> -- >>> David Thayer, Public Health Engineer >>> Colorado Department of Public Health and Environment Air Pollution >>> Control Division / Stationary Sources Program >>> david.thayer@state.co.us, Voice:303-692-3187, FAX:303-782-0278 »> >>> As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs. Additional fees may apply if an APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section II.A). If you need assistance, please refer to: >>> <https://www.colorado.gov/cdphe/APENforms>. >» »> >>> On Tue, Jun 2, 2015 at 9:04 AM, Ashley Jones <AVJones@trinityconsultants.com> wrote: >>>> To be on the safe side I will request a 55 km radius. >>» >>» Thanks, >>» >>» Ashley Report Date: /7 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 9 of 35 >>» >>>> 253-867-5600 >>» >>>> From: Thayer - CDPHE, David [mailto:david.thayer@state.co.us] >>>> Sent: Tuesday, June 02, 2015 7:33 AM >>>> To: Ashley Jones >>>> Subject: Re: Request for Meteorological Data/Inventory Source >>>> Data/Background Concentration for proposed facility >>» >>>> For the purposes of the inventory extraction, what is the required >>>> distance for selecting nearby sources? >>» >>» >>» dt >>»-- >>» >>>> David Thayer, Public Health Engineer Colorado Department of Public >>>> Health and Environment Air Pollution Control Division / Stationary >>>> Sources Program david.thayer@state.co.us, Voice:303-692-3187, >>» FAX:303-782-0278 >>» >>» >>» >>>> As of January 1, 2014, the Colorado Air Pollution Control Division >>>> no longer accepts blank or incomplete APENs. Additional fees may >>>> apply if an APEN is submitted without the necessary information. An >>>> application with missing information may result in longer processing >>» times. Please note that all APEN submissions should be completed >>>> using forms currently supplied by the Division (See Reg. 3, Part A, >>>> Section II.A). If you need assistance, please refer to: <https://www.colorado.gov/cdphe/APENforms>. >>» >>» >>» >>>> On Mon, Jun 1, 2015 at 2:24 PM, Ashley Jones >>>> <AVJones@trinityconsultants.com> wrote: >>» >>>> Hi CDPHE Modeling Group, >>» >>>> I would like to request a formal meteorological determination, >>>> nearby source inventory, and background concentration for a new proposed Martin Marietta >>>> facility. The proposed facility is —5 miles east of Loveland near the >>>> Larimer/Weld County line. >>» >>>> Attached is a topographic map of the location with >>>> Latitude/Longitude coordinates (40.39795, -104.93966) of the >>>> approximate center of the proposed facility. >>» >>>> The Proposed Facility: >>>> Tentative Site Name: Highway 34 >>>> Source Type: Aggregate processing, Ready -Mix facility, and Asphalt facility. Report Date: 17 -Oct -17 Colorado DPI -1E /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 10 of 35 >>>> No mining. >>>> Stack types: Short to mid -level point sources and low level >>>> fugitives >>» >>>> Pollutants for Background Concentration and Inventory: >>» >>>> PM10 >>>> PM2.5 >>» >>>> We do not anticipate triggering gaseous pollutant state AAQS >>>> requirements, but will make the separate request for Carbon Monoxide if needed. >>» >>>> Please let me know if you have any questions or need any additional >>>> data to process the request. >>» >>>> Also, if there are recent developments in regards to modeling >>>> requirements that we should be aware please let us know. >>» >>» Thanks, >>>> Ashley >>» >>>> Ashley Jones I Senior Consultant >>» >>>> Trinity Consultants 120819 72nd Avenue S., Suite 610 I Kent, »» WA >>» 98032 >>» >>>> P: 253.867.5600 I F: 253.867.5601 I E: >>>> avjones@trinityconsultants.com Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 11 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 5/30/2017 Note entered into database by: Marie Bernardo Note: From: Emmett Malone To: Ashley Jones, K.C. Houlden, Walter Wright, Anna Unruh, Rosendo Majano, Marie Bernardo, Will Vicars Subject: Modeling Protocol for Martin Marietta Highway 34 Site Hi Ashley, I wanted to thank you for the protocol. I also wanted to tell you, it most likely will be a couple weeks before one of the permit modelers is available to review it. If you have any questions let me know. Emmett Malone Supervisor Modeling and Emissions Inventory Unit Technical Services Program Air Pollution Control Division Colorado Department of Public Health and Environment APCD-TS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-31361Emmett.Malone@state.co.us On Mon, May 29, 2017 at 11:23 PM, Ashley Jones <AVJones@trinityconsultants.com> wrote: Hi Emmett and KC, Please find attached, a modeling protocol for the Martin Marietta Highway 34 facility. The facility will be submitting a construction permit application for a new asphalt plant in the near future and we would like to receive concurrence on the modeling approaches prior to submitting the application. If you have any questions or comments on the attached modeling protocol, please do not hesitate to reach out to Anna Unruh (Trinity Denver Office — (720) 638-7647) or myself (253-867-5600). KC — we would also like to chat with you prior to submitting the application to make sure we are all on the same page. Please let us know when you are available this week to discuss the upcoming project. We are hoping to submit the application as soon as possible, so the sooner the better. Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 12 of 35 Thank you, Ashley Ashley Jones I Senior Consultant Trinity Consultants 120819 72nd Avenue S., Suite 610 I Kent, WA 98032 P: 253.867.5600 I F: 253.867.5601 I E: avjones@trinityconsultants.com Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 13 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 6/1/2017 Note entered into database by: Marie Bernardo Note: From: Emmett Malone To: Ashley Jones, K.C. Houlden, Walter Wright, Anna Unruh, Rosendo Majano, Marie Bernardo, Will Vicars Subject: Modeling Protocol for Martin Marietta Highway 34 Site Hi Ashley, I thought that might be the case but trying to chase to many things right now I thought I would send it just to be sure. Have a good day. Emmett On Thu, Jun 1, 2017 at 9:12 AM, Ashley Jones <AVJones@trinityconsultants.com> wrote: Thanks, Emmett. We actually received the updated meteorological data from you in February 2017, and indicated we would be using the data processed with v16216 without ADJ_U*. I believe the original meteorological determination for the site was in 2015, but the reprocessed data was from 2017. I assume the dataset you just sent is the same as February but we will confirm we are using the most current dataset. Nancy - The original background concentration determination in 2015 was to use a background concentration from the Xcel Fort St. Vrain 2009-2010 monitor data, please let us know if this determination has changed. We have noted CDPHE's preferred data filling process for inventory sources. Thanks, Ashley 253-867-5600 From: Malone - CDPHE, Emmett [mailto:emmett.malone@state.co.us] Sent: Thursday, June 01, 2017 6:55 AM Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP / Modeling and Emission Inventory Unit PROJECT NOTES Page 14 of 35 To: Ashley Jones Cc: Houlden - CDPHE, Kenneth; Walter Wright; Anna Unruh; Rosendo Majano; William Vicars - CDPHE; Marie Bernardo - CDPHE; Chick, Nancy D. Subject: Re: Modeling Protocol for Martin Marietta Highway 34 Site Hi Ashley, After seeing my email to the permit modelers telling them what we talked about yesterday, one of the permit modelers took a quick look at the protocol this morning. He had the following comments: The meteorological determination was completed a couple years ago. He asked me if I would change it? I would not but, the meteorological data needs to be processed with the latest version of AERMET. The meteorological data processed with AERMET 16216 for ADJ_U* and without ADJ_U* are attached. The background data should be checked to see if there are any updates available. Please contact Nancy Chick (nancy.chick@state.co.us) to see if the background data needs updating. We understand that the some nearby source stack parameters may have missing values. For point sources we ask that stack parameters from similar types of equipment be substituted for the missing parameters. Hope this helps to avoid any issues later on. Emmett Malone Supervisor Modeling and Emissions Inventory Unit Technical Services Program Air Pollution Control Division Colorado Department of Public Health and Environment APCD-TS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-3136 Emmett.Malone@state.co.us Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP / Modeling and Emission Inventory Unit PROJECT NOTES Page 15 of 35 On Mon, May 29, 2017 at 11:23 PM, Ashley Jones<AVJones@trinityconsultants.com> wrote: Hi Emmett and KC, Please find attached, a modeling protocol for the Martin Marietta Highway 34 facility. The facility will be submitting a construction permit application for a new asphalt plant in the near future and we would like to receive concurrence on the modeling approaches prior to submitting the application. If you have any questions or comments on the attached modeling protocol, please do not hesitate to reach out to Anna Unruh (Trinity Denver Office — (720) 638-7647) or myself (253-867-5600). KC — we would also like to chat with you prior to submitting the application to make sure we are all on the same page. Please let us know when you are available this week to discuss the upcoming project. We are hoping to submit the application as soon as possible, so the sooner the better. Thank you, Ashley Ashley Jones I Senior Consultant Trinity Consultants 120819 72nd Avenue S., Suite 610 I Kent, WA 98032 P: 253.867.5600 I F: 253.867.5601 I E: avjones@trinityconsultants.com Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 16 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 6/14/2017 Note entered into database by: Marie Bernardo Note: From: Rosendo Majano To: Ashley Jones, Emmett Malone, K.C. Houlden Subject: Modeling Protocol for Martin Marietta Highway 34 Site Hi Ashley, I finally got around to reviewing this modeling protocol in more detail and we have the following comments: Comment 1. On Page 3-3 is indicated that some sources will be combined into a single source with an emission rate equal to the sum of the emissions of the individual sources that comprise it and with dimensions equal to the structure or area where they are located. It is further explained that the particle size distribution and deposition coefficients of the individual source that accounts for the majority of the emissions will be used for the rest of the individual sources. While adding the emission rates might be OK when combining several individual sources into one single source, using the deposition parameters of one source for the rest is not an adequate procedure. It would be a more accurate representation if each individual source is modeled separately with its own emission rate, its own particle size distribution & deposition coefficients, but with the dimensions of the structure or area where they are located and on the location of such structure or area. This way, all the individual sources will be overlaid one on top of the other having in common the location and dimensions of the structure or area where they are located, but each source will retain its own emission rate, and most important, each individual source will retain its own deposition parameters (particle size distribution & deposition coefficients). Comment 2. Also on Page 3-3 is indicated that for off -site sources for which particle size distribution is unknown, a mass fraction of 100% PM2.5 will be used with a particle diameter of 2.5 urn and a density of 1 g/cm3. In cases in which there are deposition parameters available for some of the sources but not for all of them, to be able to run the Method 1 deposition algorithm in AERMOD we recommend the use of a gaseous deposition velocity of 1.0E-17 m/s with the GASDEPVD key word in the control section in AERMOD. This will enable AERMOD to execute runs that contain both particulate sources with deposition parameters and gaseous/particulate sources with no deposition parameters. The use of the gas deposition velocity is for the Method 2 deposition algorithm, which is a non -default option in AERMOD. However, using such an extremely low gas deposition velocity is in practice equivalent to the particles not undergoing any deposition process at all; so what you would be achieving with this value is to provide the required deposition parameters for all the sources thus allowing AERMOD to run. We have consulted this procedure with EPA and EPA agreed that using this gas deposition velocity value is equivalent to having no deposition for those sources (i.e. you would get the same modeled concentration with this value as if you din't use the deposition algorithm) and therefore EPA approval as an alternative model will not be required for Method 2 under those circumstances. Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 17 of 35 Method 1 will be used for those sources that have deposition parameters specified, and Method 2 with this extremely low gas deposition velocity will be used for the rest of the sources. Note that when using gas deposition as explained above, you need to use the NOWETDPLT keyword to explicitly prevent wet depletion, which is not compatible with GASDEPVD. If I'm not mistaken the model will crash if this is not done. This approach is a more accurate representation of the situation than assuming values for sources for which no information is available, even if those values are conservative. Comment 3. The approach for modeling sources with horizontal stacks is explained on Page 3-7 of the protocol. While this approach is correct, it should be noted that the POINTHOR option is now a default regulatory option in AERMOD and can be used without needing case -by -case approval from EPA. Comment 4. It is indicated on Page 3-8 of the protocol that some transfer points, loading/unloading operations, and screening operations will be modeled as area sources with initial vertical dimensions of zero, and some of them with what is called the "CDPHE default" release height of 2 meters. Note that all these type of sources would be more accurately represented as volume sources because their emissions will have some initial plume depth. The area source algorithm is only appropriate for low or ground lever sources with no plume rise. It is recommended that these type of sources be represented as volume sources with modeling parameters (release height, and initial vertical & lateral dimensions) based on the actual dimensions of the sources. Comment 5. It is indicated on Page 3-8 of the protocol that storage piles will be represented as area sources with what is called the "CDPHE default" release height of 2 meters. Please note that the adequate release height for storage piles is half of the height of the pile, and that CDPHE has recommended a default release height of 2 meters for area sources in two situations only: a) As an initial approach for modeling nearby facilities when there is not information available to represent them, and provided that these facilities are located far enough from the permitted facility. b) For wind erosion emissions on disturbed land both on -site and off -site. The 2 -meter release height is not intended to be a default value for any other on -site source. Comment 6. The footnote 5 on Page 3-1 states that the Kodak surface station was determined to be the most representative data set for the project location. To avoid misunderstandings, I want to reiterate the statement in the meteorological determination saying that there are no existing meteorological data, to the Division's knowledge, that are adequately representative of the dispersion conditions expected at the project site. The Kodak data has been recommended for use with AERMOD as a screening tool which involves using a more stringent design concentration than the form of the corresponding NAAQS. Comment 7. The modeling protocol doesn't provide any emission rates of the applicable pollutants to justify which ones warrant a modeling analysis and which ones could be exempted. It is recommended that this explanation be included in the application to justify which pollutants and averaging periods have been excluded from the analysis. Comment 8. Several point sources are listed in the protocol, but the effect of downwash was not discussed. Please include in the application an explanation of whether there are buildings/structures at the facility, what are their locations in relation to the stacks (include plot plan), which of those create downwash effect on the point source emissions, and how this was accounted for in AERMOD. Comment 9. Please review the following documents to ensure that all the necessary information is included in the , application. a- "Completeness Checklist - Modeling Submittal". The document can be found on CDPHE's website at Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 18 of 35 http://www. colorado.gov/airqual ity/permits/CompletenessChecklist-ModelingSubmittal 14Feb.pdf b- "FAQs on Air Quality Modeling Data and Techniques". This document can also be found on CDPHE's website at http://www.colorado.gov/airquality/permits/FAQsOnAirQualityModelingDataAndTechniquesl3Jul.pdf c- "Colorado Modeling Guideline for Air Quality Permits". Also found on CDPHE's website at http://www.colorado.gov/airquality/permits/guide.pdf . Thank you for submitting a modeling protocoL It will allow for a more expeditious review of the application. Regards, Rosendo Majano Air Quality Scientist Modeling and Emission Inventory Unit Air Pollution Control Division Colorado Department of Public Health and Environment 303-692-3115 I rosendo.majano@state.co.us Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 19 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 6/27/2017 Note entered into database by: Marie Bernardo Note: From: Marie Bernardo To: Ashley Jones, Anna Unruh, K.C. Houlden, Emmett Malone BCC: Rosendo Majano, Will Vicars Subject: Modeling Completeness Check - Martin Marietta Materials Highway 34 Hi Ashley, The Modeling and Emissions Inventory Unit has conducted a completeness check for the ambient air impact analysis received on June 23, 2017 by Martin Marietta Materials as part of the application to construct an asphalt plant in addition to Permit No. 16WE0689 (aggregate yard) and 16WE0688 (ready mix plant) for its Highway 34 facility in Weld County, CO. The completeness check has been conducted to determine if all the information and data required to evaluate the application has been submitted to the Division. No determination is being made at this moment as to whether or not the information submitted is correct. The ambient air impact analysis is missing the following information that is needed to evaluate the application: 1 - Checklist Item: Overlay of modeled layout of the sources, buildings/structures,and receptor network onto USGS 1:24,000 -scale topographic map at various scales (zoom to, at a minimum, the source under review, the full modeling domain). This figure can be submitted in any of the following formats: *.TIF, *.JPG, *.PDF, *.SHP Figures 5-1 and 5-2 do satisfy this checklist item; however, the onsite sources have elevations taken from survey data. In order to verify the elevations of on -site sources, a map of the modeled layout of sources and buildings/structures with the contour lines from the survey data needs to also be included. The Elevation Plan provided in Appendix B contains the contour lines from the survey data, but it does not have an overlay of the modeled layout of sources and buildings/structures. Please provide a figure that overlays the modeled layout of sources and buildings/structures with the contour lines from the survey data. This figure can be submitted in any of the following formats: *.TIF, *.JPG, *.PDF, *.SHP Since there is only one small item missing from the application, the full review of the ambient air impact analysis will continue. The review cannot be completed, however, without receiving the figure described above. In addition to the item above, and although not part of the completeness check, the follow issue was identified that requires clarification: 1 - In Section 7.4, it is stated that the "facility will be restricted by physical barriers such as fencing and berms." The site plan provided in Appendix B shows where there will be fences, berms, and noise barrier walls. There also appears to be a few gaps between the physical barriers. Could you please clarify how public access will be precluded from the entire facility? Please let me know if you have any questions. Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 20 of 35 Thank you, Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 4300 Cherry Creek Drive South, Denver, CO 80246 marie.bernardo@state.co.us www.colorado.gov/airquality Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 21 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 7/24/2017 Note entered into database by: Marie Bernardo Note: From: Anna Unruh To: Walter Wright, Ashley Jones, Marie Bernardo, Emmett Malone, K.C. Houlden Subject: Martin Marietta - Highway 34 Modeling Analysis Hi Marie, Thank you for your quick response to my voicemail. See red text below for our responses to your questions. Please do not hesitate to contact me if you have any further questions. Thanks, Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com From: Bernardo - CDPHE, Marie[mailto:marie.bernardo@state.co.us] Sent: Thursday, July 20, 2017 3:59 PM To: Anna Unruh <aunruh@trinityconsultants.com> Cc: Emmett Malone - CDPHE <emmett.malone@state.co.us>; Kenneth Houlden - CDPHE <kenneth.houlden@state.co.us> Subject: Martin Marietta - Highway 34 Modeling Analysis Hi Anna, I received your voicemail and I thought it would be best to send you an email with a couple questions/clarifications that have come up in the past few days. 1. In Appendix D, Table D-3 indicates that the short-term SO2 emission is 1.7 lb/hour. This value is above the short- term modeling threshold of 0.46 lb/hour therefore the short term SO2 averaging periods should be modeled. The PS Memo mentioned in Table 7-1 only addresses the 1 -hour SO2 standard. There are also 3 -hour and 24 -hour SO2 NAAQS that are still in effect that will need to be modeled. Also, it should be noted that Colorado has a more stringent 3 -hour SO2 standard than the NAAQS. Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 22 of 35 The MEIU can perform these modeling analyses and include them in the report as long as we have all the necessary ,information. Are there any sources that emit SO2 that were not included in Appendix D? Please include any and all APEN exempt sources. All SO2 emitting sources are included in Appendix D. Specifically, these include the two hot oil heaters and the drum mixer. As noted in Footnote 1 to Table D-4, the heaters are actually APEN exempt, but have been included for modeling purposes. We are okay with CDPHE preparing the modeling runs for SO2 3 -hr and 24 -hr as we are confident that the analysis will demonstrate model compliance. 2. The conversions from lb/hour to g/s don't seem to be correct for a lot of sources for both PM2.5 and PM10. I have attached a few sample calculations to show this. I am calculating higher g/s emission rates than what was modeled. Because the 24 -hour PM2.5 modeling required a contribution analysis, the small increases in emission rates might change the outcome of the contribution analysis. Based on your calculations, it appears that you are using the hourly throughputs, rather than the daily throughputs when determining the 24 -hour emission rate. As described in Section 7.9 of the report, the 24 -hour modeled emission rate is based on the maximum daily throughput. Martin Marietta understands that these daily throughputs will likely become permit limits. RC_ULOAD: The total throughput in a day will not exceed 12,600 tpd. Since this source will be limited to 14 hours of operation per day, the PM2.5 g/s emission rate was calculated as: (12,600 tpd) * (3.12E-05 lb/ton) * (1-0.99) * (453.592 g/lb) / (14 hr/day) / (3,600 s/hr) = 3.540E-05 g/s Similarly, while the Entrance/Exit haul roads will not be limited on operating hours, individual plants have operating hour limits, which will limit the number of trucks travelling into and out of the facility (i.e., trucks/day is not equal to trucks/hr * 24 hrs/day). Specifically, the ready -mix plant is limited to 16 hrs/day, and the aggregate truck loading source (AGGLOAD) is limited to 14 hours per day. As such, the PM2.5 calculation for this should be: (2,745 trucks/day) * (0.4 VMT/truck) * (0.07 lb/VMT) * (1-0.99) * (453.592 glib) / (24 hr/day) / (3,600 s/hr) / 27 sources = 1.492E-04 g/s Please let me know if you have any questions. Thank you, Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 23 of 35 4300 Cherry Creek Drive South, Denver, CO 80246 inarie.bernardo@state.co.us I www.colorado.gov/airquality Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP / Modeling and Emission Inventory Unit PROJECT NOTES Page 24 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 7/27/2017 Note entered into database by: Marie Bernardo Note: From: Anna Unruh To: Walter Wright, Ashley Jones, Marie Bernardo, Emmett Malone, K.C. Houlden Subject: Martin Marietta - Highway 34 Modeling Analysis Hi Marie, Thank you for taking the time to go talk through these items on the phone. To follow-up our conversation and provide written record, see notes below in red text. Please feel free to give me a call if you have further questions. Thanks, Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com From: Bernardo - CDPHE, Marie [mailto:marie.bernardo@state.co.us] Sent: Thursday, July 27, 2017 9:59 AM To: Anna Unruh <aunruh@trinityconsultants.com>; Ashley Jones<AVJones@trinityconsultants.cor>; Walter Wright <Walter.Wright@martinmarietta.com> Cc: Emmett Malone - CDPHE <emmett.malone@state.co.us>; Kenneth Houlden - CDPHE <kenneth.houlden@state.co.us> Subject: Re: Martin Marietta - Highway 34 Modeling Analysis Hi Anna, Thank you for your clarifications and confirming the emission sources for SO2. We do have some comments regarding how the emission rates were calculated and questions about the haul road emissions. As discussed, we understand that represented emissions (including those based on daily throughputs) may become pen -nit limits, thereby making them maximum allowable emission limits. The modeled emission rates need to be based on PTE or the maximum allowable emission limit. Using the daily Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 25 of 35 throughput for sources that operate less than 24 hours/day, dilutes the emissions and does not represent PTE. RC_ULOAD: 3000 ton/hr * 14 hr/day = 42000 ton/day which is far greater than 12600 ton/day As we discussed, 12,600 ton/day is equivalent to one train, which is the most that the facility would receive in a day. It would not be possible for the facility to unload at a rate of 3,000 tph for 14 hours. For RC_ULOAD and all other sources that operate less than 24 hours/day, the PTE would be the emission rate calculated from the hourly throughput and applied over the hours it operates per day using the EMISFACT HROFDY keyword. As is represented in Section 7.9 of the report, we used the HROFDY option wherever possible (i.e., for sources that are limited to operation during specific hours of the day, such as 8a -6p). However, there are some sources that will be limited in total hours of operation per day, but that may occasionally operate at night, and therefore we were not able to use the hour of day cards and exclude the nighttime hours. For these sources, we conserved the daily mass emission rate in the model by spreading the emissions out over the 24 -hour averaging period. The haul road emission rates need to be based on the maximum permitted throughput and the number of trucks required to move that throughput. It is unclear how the number of trucks was calculated. Please provide clarifications for the questions below: 1. What are the average characteristics (capacity, dimensions, etc.) of the trucks used to haul asphalt, cement, and aggregate? Are the same type of trucks used to haul the different materials? Please explain. 2. How many trucks are needed to move the daily throughput of asphalt? How many trucks are needed to move the daily throughput of cement? How many trucks are needed to move the daily throughput of aggregate? 3. What is the VMT per vehicle type (asphalt truck, cement truck, aggregate truck) per modeled segment? 4. Will there be a schedule for truck traffic? (i.e., cement trucks are limited to 16 hours/day) As we talked about, the trucks in Tables D-20 and D-21 correspond to the line -by-line emission calculations in Table D-22. Figure 6-2 of the report can be used to match up the Source ID's associated with each truck, as needed. Please let me know if you have any questions or wish to discuss anything further. Thank you, Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 4300 Cherry Creek Drive South, Denver, CO 80246 marie.bernardo@state.co.us I www.colorado.gov/airquality Are you curious about ground -level ozone in Colorado? Visit our ozone webpage to learn more. Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 26 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 8/7/2017 Note entered into database by: Marie Bernardo Note: From: Anna Unruh To: Marie Bernardo, Emmett Malone, K.C. Houlden, Ashley Jones, Walter Wright Subject: Martin Marietta - Highway 34 Cumulative Modeling Analysis Hi Marie, Thank you for the update. Please let us know if it appears that these sources will present any issues at our significant receptors. Thanks, Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com From: Bernardo - CDPHE, Marie [mailto:marie.bernardo@state.co.us] Sent: Friday, August 04, 2017 3:56 PM To: Anna Unruh <aunruh@trinityconsultants.com>; Ashley Jones<AVJones@trinityconsultants.com>; Walter Wright <Walter.Wright@martinmarietta.com> Cc: Emmett Malone - CDPHE <emmett.malone@state.co.us>; Kenneth Houlden - CDPHE <kenneth.houlden@state.co.us> Subject: Martin Marietta - Highway 34 Cumulative Modeling Analysis Hi Anna, I wanted to let you know that I have run the significant analysis model runs and am beginning the cumulative analysis model runs. As you know, the cumulative impact analysis includes contributions from nearby sources. As stated in the the Colorado Modeling Guidelines, "The procedure used to select nearby sources should be based on professional judgement...The following approach is generally acceptable. For new minor sources and minor modifications (not subject to PSD rules) with relatively low stack heights, obtain from the Division an emissions inventory of stationary sources within 5 kilometers of the significant impact area for the new source or modification Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 27 of 35 under review...Use professional judgement to decide if five kilometers is adequate." For the PM2.5 24 -HR cumulative impact analysis, only sources within 8.3 km were included (3.3 km of Significant Impact Area + 5 km). This procedure does follow the generally acceptable procedure of the Colorado Modeling Guidelines. However, when you use the APCD's Queried Sources of Air Pollution tool (https://www.colorado.gov/airquality/ss_map_wm.aspx), you will see that there are many large sources of PM2.5 that fall between 8.4 km and 11.1 km from the Martin Marietta Highway 34 facility. For example: 1. Bestway Concrete is 8.9 km away with 7.8 tpy PM2.5 2. Front Range Energy is 9.5 km away with 8.5 tpy PM2.5 3. Owens -Brockway Glass is 10.8 km away with 101.3 tpy PM2.5 4. Martin Marietta Three Bells Pit is 11.1 km away with 24.89 tpy PM2.5 These four sources combine to a total of 142.5 tpy PM2.5. These large emissions within an additional 2.8 km away from Highway 34 are not being considered in the cumulative impact analysis. In our professional judgement, these sources as well as others within the area should be included in the cumulative impact analysis in order to capture all potential impacts. The MEIU will include the additional sources from the inventory in the cumulative impact analysis model runs. Please let me know if you have any questions. Thank you, Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 4300 Cherry Creek Drive South, Denver, CO 80246 marie.bernardo@state.co.us www.colorado.gov/airquality Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 28 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 8/22/2017 Note entered into database by: Marie Bernardo Note: From: Marie Bernardo To: Anna Unruh, Ashley Jones, Walter Wright, Emmett Malone, K.C. Houlden BCC: Rosendo Majano, Will Vicars Subject: Martin Marietta Highway 34 - Modeling Analysis Hi Anna, We spoke last Thursday briefly about the status of the Martin Marietta Highway 34 modeling analysis and at the time, the review showed no significant contribution from the Highway 34 facility. As I continued the review, I found receptors where exceedances occur that Highway 34 is significant for both PM2.5 and PM10. I have attached a link where the files can be downloaded that I have been working with. Please note that the PM10 cumulative impact analysis was split into 4 runs (split the receptors into 4 sections). This was done to speed up run time as there were approximately 5000 significant receptors in the cumulative impact analysis. Also the emission rate calculated for PM10 for the HMAPT was actually lower than what was submitted. With this lower emission rate, the result is the same. The two Excel spreadsheets are the emission calculations where there is a summary tab that compares what was calculated and what was modeled. The remaining files are the input and output files for both PMI0 and PM2.5. I reviewed 42 receptors and 5 showed a significant contribution from Highway 34. I did not do a complete review of the contribution analysis for PM10 (as there were about 230 receptors with exceedances) so there may be more receptors with significant contributions from Highway 34. One of those receptors (504773.19 m E, 4469692.63 m N) has a modeled concentration of 458.56802 ug/m3. This receptor is very close to two nearby sources. It is unclear whether this receptor falls within those sources' property. If a receptor is within a nearby source's property, then the impact from that nearby source can be removed from that receptor. The contribution from other nearby sources and Highway 34 cannot be removed. The other four receptors found with significant contribution from Highway 34 seem to be in the middle of ranch land so this procedure would not apply. Something that may help show compliance would be to refine some of the nearby sources. This would include finding the actual coordinates of the emission sources, actual stack parameters, etc. and using a temporally representative level of actual operation reflective over the most recent 2 years. As you are aware, Table 8-2 in Appendix W slightly changed the way emissions are calculated for nearby sources. Some nearby sources have already been refined (Carestream Health, Owens Brockway, Rocky Mountain Transloading, and Vestas Blades) in the input files. These were refined for another applicant and due to current workloads, the MEIU does not have the time to refine any more nearby sources. We would ask that you gather the necessary information to refine any nearby source and that you please document the changes made and the basis for the changes. Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 29 of 35 The files can be downloaded here: https://www.colorado. gov/airquality/repository/mmei_file. aspx?file=MEIU+MMM+Highway+34+Files.zip Please let me know if you have any questions or wish to discuss anything further. Thank you, Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 4300 Cherry Creek Drive South, Denver, CO 80246 marie.bernardo@state.co.us www.colorado.gov/airquality Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 8/28/2017 Note entered into database by: Marie Bernardo Note: From: Marie Bernardo To: Anna Unruh, Emmett Malone, K.C. Houlden BCC: Rosendo Majano, Will Vicars Attachment: MMM HWY34 PM2.5 08.28.2017.zip Anna, As we discussed on the phone, the PM2.5 modeling analysis continues to show Highway 34 is significant at receptors with exceedances after the Silo height and initial lateral dimension were updated. The PM10 contribution analysis is currently being conducted so I cannot say whether Highway 34 is significant or not significant at receptors with exceedances. Attached are the PM2.5 files (AERMOD input and output files, receptor file, Plot file, MAXDCONT file). Please let me know if you have any questions. Thanks, Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 4300 Cherry Creek Drive South, Denver, CO 80246 marie.bernardo@state.co.us www.colorado.gov/airquality Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 30 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 9/28/2017 Note entered into database by: Marie Bernardo Note: From: Anna Unruh To: Marie Bernardo Subject: Checking in Regarding Martin Marietta Highway 34 Hi Marie, How is your report coming along? I checked in with K.C. this morning and he has not yet received it, but that he will be able to finish the draft permit once he does. As is the case with most projects, Martin Marietta is eager to push this along! Thanks, Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com From: Anna Unruh Sent: Thursday, September 21, 2017 8:24 AM To: 'Bernardo - CDPHE, Marie' <marie.bernardo@state.co.us> Subject: RE: Checking in Regarding Martin Marietta Highway 34 Hi Marie, Great! Thank you for the update. Thanks, Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 31 of 35 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com From: Bernardo - CDPHE, Marie [mailto:marie.bernardo@state.co.us] Sent: Thursday, September 21, 2017 7:38 AM To: Anna Unruh <aunruh@trinityoonsultants.com> Subject: Re: Checking in Regarding Martin Marietta Highway 34 Hi Anna, I have looked at the contribution analysis for both PM10 and 24 -hour PM2.5 and Highway 34 is not significant at the modeled exceedances. With these results, I will write up my final report and send it to the permit engineer. It will take a few days to finish everything up on my end. Thanks, Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 4300 Cherry Creek Drive South, Denver, CO 80246 marie.bernardo@state.co.us I www.colorado.gov/airquality Are you curious about ground -level ozone in Colorado? Visit our ozone webpage to learn more. On Wed, Sep 20, 2017 at 8:37 AM, Anna Unruh <aunruh@trinityconsultants.com> wrote: Hi Marie, Did you get a chance to look at the contribution analyses yesterday? Thanks, Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com From: Bernardo - CDPHE, Marie [mailto:marie.bernardo@state.co.us] Sent: Monday, September 18, 2017 12:54 PM To: Anna Unruh <aunruh@trinityconsultants.com> Subject: Re: Checking in Regarding Martin Marietta Highway 34 Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 32 of 35 Hi Anna, Sorry that I missed your call this morning. I have run the PM2.5 and PM10 analyses. I have yet to look at the contribution analyses for them as I have a deadline today that I must finish. I will look at them tomorrow and let you know, but from an initial glance it looked OK. Thanks, Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 4300 Cherry Creek Drive South, Denver, CO 80246 marie.bernardo@state.co.us J www.colorado.gov/airquality On Mon, Sep 18, 2017 at 11:38 AM, Anna Unruh <aunruh@trinityconsultants.com> wrote: Hi Marie, I just left you a voicemail, but there is a chance I had a case of the Mondays and it will be hard to hear (I use a headset and I may not have had the mic part of it by my mouth...). At any rate, I was just calling to see if you have results from the revised PM2.5 24 -hour run, and also to see where we are with the PM10 model. If you could let me know (either by phone or email) that would be great! Thanks, Anna Anna Unruh Senior Consultant Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 33 of 35 Project ID: 506-170626 Plant/Site Name: Martin Marietta Materials - Highway 34 Facility Date: 10/17/2017 Note entered into database by: Marie Bernardo Note: From: Anna Unruh To: Marie Bernardo Subject: Martin Marietta Highway 34 Modeling Hi Marie, Have you completed the report? Hoping to be able to pass good news along to Martin Marietta! Thanks, Anna Anna Unruh Senior Consultant From: Anna Unruh Sent: Thursday, October 12, 2017 3:13 PM To: 'Bernardo - CDPHE, Marie' <marie.bernardo@state.co.us> Subject: RE: Martin Marietta Highway 34 Modeling Ok, thanks! Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com From: Bernardo - CDPHE, Marie[mailto:marie.bernardo@state.co.us] Sent: Thursday, October 12, 2017 3:11 PM To: Anna Unruh <aunruh@trinityconsultants.com> Subject: Re: Martin Marietta Highway 34 Modeling Anna, Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 34 of 35 I am planning on having it done tomorrow, but it could end up being Monday or Tuesday next week too. Thanks, Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 4300 Cherry Creek Drive South, Denver, CO 80246 marie.bemardo@state.co.us I www.colorado.gov/airquality Are you curious about ground -level ozone in Colorado? Visit our ozone webpage to learn more. On Thu, Oct 12, 2017 at 3:08 PM, Anna Unruh <aunruh@trinityconsultants.com> wrote: Hi Marie, Thanks for the update. Martin Marietta is anxious to get this out for public comment as soon as possible. How soon do you anticipate being able to complete the report? Thanks, Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com From: Bernardo - CDPHE, Marie [mailto:marie.bemardo@state.co.us] Sent: Thursday, October 12, 2017 3:06 PM To: Anna Unruh <aunruh@trinityconsultants.com> Subject: Re: Martin Marietta Highway 34 Modeling Anna, I am working on the report. I apologize for the delay, but a high priority modeling review came in that has taken up most of my time. K.C. is aware of the status of the report and it will be sent to him as soon as it is done. Thank you, Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit PROJECT NOTES Page 35 of 35 Marie Bernardo Air Quality Scientist Modeling and Emissions Inventory Unit P 303.692.3249 4300 Cherry Creek Drive South, Denver, CO 80246 marie.bernardo@state.co.us I www.colorado.gov/airquality Are you curious about ground -level ozone in Colorado? Visit our ozone webpage to learn more. On Thu, Oct 12, 2017 at 2:35 PM, Anna Unruh <aunruh@trinityconsultants.com> wrote: Hi Marie, I just left you a voicemail but wanted to follow-up with an email as well. Where are things with the Martin Marietta Highway 34 modeling currently? I believe in your last email (dated September 21) you said you just needed to write up your report, which would take a few days. Martin Marietta checked in with the permit engineer (K.C. Houlden) and he said he is waiting on details from the modeling group before he can complete the draft. Thanks, Anna Anna Unruh Senior Consultant Trinity Consultants 1391 N Speer Blvd Suite 350 I Denver, CO 80204 Office: (720) 638-7647 x114 I Mobile: (316) 200-3099 Email: aunruh@trinityconsultants.com Report Date: 17 -Oct -17 Colorado DPHE /Air Pollution Control Division / TSP /Modeling and Emission Inventory Unit Hello