HomeMy WebLinkAbout790679.tiff pF•COz
COLORADO DEPARTMENT OF HEALTH
Richard D. Lamm s," vi")/** Frank A.Traylor, M.D.
Governor 1876 Executive Director
October 16, 1979
CERTIFIED MAIL NO. WELD CIUNI! COMMISSIONERS
DI lrrizocmi4?c
Mary Ann Feuerstein iI
Weld County Clerk 0CT 2 2 1979 1'U
Weld County Centennial Center
915 10th Street GREELEY. COLO, O' ��
Greeley, Colorado 80631
Attention: Weld County Commissioners
RE: Notice of Violation as Prescribed by 25-7-122
Gentlemen:
Your attention is directed to Section 25-7-114(4) , C.R.S. 1973, which reads
in part as follows:
"(4) No person shall construct or substantially alter any building,
facility, structure, or installation, except single-family residential
dwellings, or install any machine, equipment, or other device, or
commence the conduct of any such activity, or commence performance
of any combinations thereof, or commence operations of any of the
same which will or do constitute a new stationary source or a new
indirect air pollution source without first obtaining or having a
valid permit therefor from the division, board, or commission, as
the case may be; except that no permit shall be required for new
indirect air pollution sources until regulations regarding permits
for such sources have been promulgated by the commission. The
commission shall establish rules, regulations, and procedures in
accordance with the provisions of this article for the granting or
denial of permits which shall be in conformity with the purposes
of this article, as set forth in section 25-7-102; but in no event
shall regulations governing indirect air pollution sources be more
stringent than those required for compliance with the federal act
and final rules and regulations adopted pursuant thereto. Such
procedures shall include, but not be limited to, the following:"
Your rock crusher, located at the Hoekstra Pit in the North 1/2 Section 2
Township 2 North Range 68 West,was observed to be in operation on October 16,
1979. Mr. Richard Fox of the Colorado Department of Health, Air Pollution
Control Division, made this observation. A review of the Division files
revealed that an Emission Permit application for said crusher had been denied
790679
k r i d
• 4210 EAST 11TH AVENUE DENVER,COLORADO 80220 PHONE (303) 320-8333
Mary Ann Feuerstein
October 17, 1979
Page Two
in writing on September 25, 1978. Since that time there has not been any further
application and no valid permit has been issued.
Should the operation of the crusher continue without first obtaining a valid Emis-
sion Permit, you will be subject to enforcement action in accord with Section
25-7-121 (1 ) (court injunction) , C.R,S. 1973, which reads in part as follows:
"In the event any person fails to comply with a final order of the board,
the division, or the commission that is not subject to stay pending
administrative review, or in the event any person constructs, modifies,
or commences operation of an air pollution source in violation of section
25-7-114(4) , the board, the division, or the commission, as the case may
be, may request the district attorney for the district in which the
alleged violation occurs or the attorney general to bring, and if so
requested it is his duty to bring, a suit for an injunction to prevent
any further or continued violation of such order or of section 25-7-114(4) . "
Additionally, be advised that you are subject to civil penalties up to $25,000,00
per day as provided by Section 25-7-122(1 ) (b) , C.R.S. 1973, which reads as
follows:
"Any person who violates the requirements of section 25-7-114(4) regard-
ing construction, modification, or commencement of operation of an air
pollution source without a permit from the board, the division, or the
commission and who operates or commences operation of an air pollution
source without such a permit shall be subject to a civil penalty of not
more than twenty-five thousand dollars per day for each day of operation
after receipt of the notice of noncompliance or violation. "
Pursuant to the provisions of 25-7-114 and 25-7-112, C.R.S. 1973, this letter
serves as NOTICE OF VIOLATION for operation without a permit, Operation prior to
initial approval of an emission permit is a violation of Section 25-7-114(4) ,
C,R.S. 1973. After submission of the permit application a preliminary analysis
will be made of the proposed activity to assure compliance with all regulations
and air quality standards. If the preliminary analysis demonstrates compliance
with all statutory and regulatory requirements, then an initial approval will
be issued allowing you at that time to operate the crusher.
All operation must be discontinued upon receipt of this letter until such time
as an emission permit has been obtained or action will be taken under the above
cited sections of Title 25, Article 7, C.R.S. 1973.
Should you have any questions, please contact this office at 320-4180.
Sincerely,
� --
62J,L I) Bk.
Richard D. Fox
Air Pollution Control Specialist
Air Pollution Control Division
RDF:dg
cc: Weld County Health Department
SILVER ENGINEERING WORKS, INC.
3309 BLAKE STREET • DE 1VER, COLORADO. USA 80205
CLAIR H. IVERSON
CHIEF ENGINEER
October 22, 1979
Board of County Commissioners
Weld County
Greeley, Colorado 80631
Gentlemen :
I have been retained as a consultant by the URS Company to study and
recommend to you an air pollution abatement plan for your portable
gravel crushing plant. The plan to be selected is subject to the
acceptance of the Colorado Health Department , Division of Air Pollu-
tion Control . Such acceptance is not necessarily a technical/econo-
mic judgement by the Division, but could be one of personal prejudice
on the part of the person making the final approval for the state.
As I see it , there are two reasonable options open to you for the
abatement of dust emissions and these are as follows :
A. Capture the dust being generated at the points of generation and
filter the dust particles out of the air used to capture the dust.
This option I suggest we call the "baghouse" system.
B. Suppress the generation of dust by the application of water at
the strategic points in the process. Call this the "water spray"
system.
I have done some preliminary studies on these two systems to the
extent that budgetary estimates have been made and are presented
in the attached Exhibit "A". These estimates are based upon two
significant factors which are:
1 . No water is available at the operating site. This is presently
true at two of your four sites.
2. No electric power is available. I am not certain if this applies
to all sites.
In examining the alternatives, I considered water spray systems from
two different vendors , Chem-Jet and DeTer. For the baghouse system,
I contacted only one vendor, Flex-Kleen.
(SILVER/ TELEPHONE. (303) 623-0211 • TELEX 45-567 SILVERENGR DVR • CABLE SILVERENGR DENVER. USA
Board of County Commissioners - 2 - October 22, 1979
In observing the plant in operation at the Raymer site, which is a
dry pit , we found four major sources of dust from the plant. The
baghouse system captures the dust at these four major points but
ignores other points which can generate dust in minor quantities.
To capture all the points , it would take double the capacity of the
system estimated. The water spray systems would control the dust
at all points.
Unfortunately, the officials of the Division of Air Pollution Con-
trol consider the baghouse technology as the "Best Available Tech-
nology" (BAT) and will , therefore, try to force that solution as a
condition for granting a permit to operate.
In my opinion, the water spray system is the "Best Practical Treat-
ment" (BPT) as well as having the lowest first cost. The task is
to convince the Division that Water Spray is the way to go. Jeffer-
son County has at least one gravel plant operating with a water spray
system by Chem-Jet, and apparently well within the air pollution
emission standards. I suggest you contact Jefferson County about
this before making your final decision.
My recommendation to you is that you submit to the Division a per-
mit application which would use the water spray system, but be pre-
pared, if forced into it, to go to the baghouse system. I would
further recommend that you bring into each site electric power enough
to operate whichever abatement system is selected. This would sig-
nificantly reduce the capital and operating costs of each system. In
addition, I recommend that if the water spray system is selected,
water wells be drilled at each site where it is not now available.
This and the electric power would reduce the capital costs of the
water spray systems by a factor of nearly one-half which should be
more than pay for the power and water supply.
To point out the significant factors of each alternative, note as
follows :
A. Baghouse System
Advantages
1 . No water is needed.
2. Freezing problems insignificant.
3. No additives needed.
Disadvantages
I . Dust Disposal required.
2. Highest Capital Cost.
3. More equipment to maintain .
4. Highest energy costs.
[SILVER)
Board of County Commissioners - 3 - October 22, 1979
B. Water Spray System
Advantages
1 . Lower Capital Costs .
2. Simple installation.
3. Lower energy costs.
Disadvantages
1 . May not be approved by the State.
2. Requires water.
3. Must be protected from freezing.
4. Cost of surfactant agents.
To reiterate my recommendation, I suggest you proceed as follows :
A. Apply for a permit to operate using the Chem-Jet water spray
system as recommended by the vendor. Capital cost without power
and water - $58,690.
B. Be prepared to compromise with the baghouse system with only
one portable baghouse unit. Capital cost without power - $72,420.
C. If the single baghouse system fails to achieve approval , go for
a combination baghouse-water spray. Capital cost without power and
water - $131 , 110.
D. If all else fails, offer to use 2 portable baghouse systems. I
know that this can be sold because it is "best available technology"
(BAT) . Capital cost without power is $144,840.
E. In the event of the approval of a water spray system, drill a 10
gpm well and bring in purchased power. This will reduce capital costs
of the system by $26,290 at an added cost of $2,500 per well and what-
ever portion of the costs of bringing in power that the utility will
not pay for.
Once your decision is reached on the alternative of your choice, I
will proceed with preparing the appropriate permit application.
Very truly yours ,
CHI/dln
cc: R. C. McWhinnie, President
URS Company
/SILVER
EXHIBIT A
Cost Comparison
A B
Baghouse Water Spray
Chem-Jet DeTer
Capital Cost w/o Power & Water $72,420 $58,690 $69,080
w/ Power & Water 65,420 32,400 39,880
Operating Costs/day
Fuel $55 $19 $36
Additive none 15 $115
Water Requirements none 4800 g/d 1800 g/d
Operating Cost/year .
Fuel $10,450 $3,610 $6,840
Additive 2,850 $21 ,850
$10, 50 $ , 0 $2 , 90
Water Costs none ? 1
Cost of 200' well @ $8.50/ft = $1 ,700
10 gpm Pump 800
$2,500
/S —_ 7
ILVER/
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