Department Decision Air Quality Synthetic Minor Construction Permit Permit No. 0640-0080-CA Luck Stone – Chester Quarry Route 9 East Chester, South Carolina 29706 March 31, 2020 In accordance with the 1976 Code of Laws of South Carolina, as amended, including SC Code Section 44-1-60(D), a Department Decision has been made to issue Air Quality Synthetic Minor Construction Permit No. 0640-0080-CA to the above-named permittee. This permit was previously placed on public notice and open for public comment from October 16, 2019, through December 4, 2019. A public hearing was held by SC DHEC’s Bureau of Air Quality on November 19, 2019, to receive oral and written comments on the proposed project. Adverse public comments were received by SC DHEC during the comment period. Comments received during the formal comment period regarding air quality issues have been addressed in SC DHEC’s Responses to Comments on Air Quality document attached to this Department Decision. SC DHEC’s decision to issue this permit has been made after consideration and a complete review of the following: the air permit application, applicable state and federal air quality regulations, comments and concerns made at the public hearing and all other comments received within the required time frame, the public hearing transcript, and all other pertinent information. This Department Decision regarding Air Quality Synthetic Minor Construction Permit No. 0640-0080- CA includes the following; a) the issued permit (Attachment A) which meets the requirements of all applicable air quality regulations; b) a summary of the project, permit, and applicable regulations as outlined in the Statement of Basis (Attachment B); and c) a summary of the comments made by concerned citizens regarding air quality issues and responses by the Bureau of Air Quality, as outlined in the Responses to Comments on Air Quality Permit No. 0640-0080-CA (Attachment C). This Department Decision (including attachments) will be included in SC DHEC’s administrative record for this permit decision. Steve McCaslin, P. E., Director Air Permitting Division Bureau of Air Quality
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
Department Decision
Air Quality Synthetic Minor Construction Permit
Permit No. 0640-0080-CA
Luck Stone – Chester Quarry
Route 9 East
Chester, South Carolina 29706
March 31, 2020
In accordance with the 1976 Code of Laws of South Carolina, as amended, including SC Code Section
44-1-60(D), a Department Decision has been made to issue Air Quality Synthetic Minor Construction Permit No. 0640-0080-CA to the above-named permittee. This permit was previously placed on public notice and open for public comment from October 16, 2019, through December 4, 2019. A public hearing was held by SC DHEC’s Bureau of Air Quality on November 19, 2019, to receive oral and written comments on the proposed project. Adverse public comments were received by SC DHEC during the comment period. Comments received during the formal comment period regarding air quality issues have been addressed in SC DHEC’s Responses to Comments on Air Quality document attached to this Department Decision. SC DHEC’s decision to issue this permit has been made after consideration and a complete review of the following: the air permit application, applicable state and federal air quality regulations, comments and concerns made at the public hearing and all other comments received within the required time frame, the public hearing transcript, and all other pertinent information.
This Department Decision regarding Air Quality Synthetic Minor Construction Permit No. 0640-0080-
CA includes the following; a) the issued permit (Attachment A) which meets the requirements of all
applicable air quality regulations; b) a summary of the project, permit, and applicable regulations as
outlined in the Statement of Basis (Attachment B); and c) a summary of the comments made by
concerned citizens regarding air quality issues and responses by the Bureau of Air Quality, as outlined
in the Responses to Comments on Air Quality Permit No. 0640-0080-CA (Attachment C). This Department
Decision (including attachments) will be included in SC DHEC’s administrative record for this permit
decision.
Steve McCaslin, P. E., Director
Air Permitting Division
Bureau of Air Quality
Attachment A
Air Quality Synthetic Minor Construction Permit
Permit No. 0640-0080-CA
Bureau of Air Quality
Synthetic Minor Construction Permit
Luck Stone – Chester Quarry
Route 9 East
Chester, South Carolina 29706
Chester County
In accordance with the provisions of the Pollution Control Act, Sections 48-1-50(5), 48-1-100(A), and
48-1-110(a), the 1976 Code of Laws of South Carolina, as amended, and South Carolina Regulation 61-
62, Air Pollution Control Regulations and Standards, the Bureau of Air Quality authorizes the
construction of this facility and the equipment specified herein in accordance with the plans,
specifications, and other information submitted in the construction permit application received on
August 28, 2019, as amended. All official correspondence, plans, permit applications, and written
statements are an integral part of the permit. Any false information or misrepresentation in the
application for a construction permit may be grounds for permit revocation.
The construction and subsequent operation of this facility is subject to and conditioned upon the
terms, limitations, standards, and schedules contained herein or as specified by this permit and its
accompanying attachments.
Permit Number:
Issue Date:
0640-0080-CA
March 31, 2020
Steve McCaslin, P. E., Director
Air Permitting Division
Bureau of Air Quality
Luck Stone – Chester Quarry
0640-0080-CA
Page 2 of 16
RECORD OF REVISIONS
Date Description of Changes
Luck Stone – Chester Quarry
0640-0080-CA
Page 3 of 16
A. PROJECT DESCRIPTION
Permission is hereby granted to construct a new 550 tph crushed granite processing plant. It will consist of stone
crushing, conveying, screening, and washing operations.
B.1 – EQUIPMENT FOR EMISSION UNIT 01 – STONE CRUSHING
Equipment
ID Equipment Description Capacity
Subject to
NSPS Subpart
OOO
Control
Device ID
Emission
Point ID
P1 Portable 3044 Jaw Plant 550 tph Yes WS V1
P4 Kodiak Cone Crusher 550 tph Yes WS V11
B.2 – EQUIPMENT FOR EMISSION UNIT 02 – STONE CONVEYING
Equipment
ID Equipment Description Capacity
Subject to
NSPS Subpart
OOO
Control
Device ID
Emission
Point ID
P1a 54” x 46’ Under Jaw Conveyor 550 tph Yes WS V2
P2 30” x 13’6” Under Grizzly Reject Conveyor 550 tph Yes WS V4
Between 2002 and 2014, South Carolina saw a 47% reduction in total annual NOX
emissions, as well as a 36% reduction in total annual VOC emissions. These emissions
reductions reflect the success of federal and state air regulations, and are mirrored
in the reduction of ozone design values over a similar period, as seen in the figure
below. The Department believes that ozone precursor emissions in South Carolina
have recently declined, and will continue to decline, because of the continuing
decline in the use of coal-fired EGUs, greater use of natural gas in industrial and utility
boilers, and turnover in the fleet to favor newer, lower NOX-emitting, mobile sources.
0
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
2000 2002 2004 2006 2008 2010 2012 2014 2016
Tota
l Em
issi
on
s (t
on
s)South Carolina Total Emissions from NEI, 2002-
2014
NOx
VOC
For the multistate Charlotte NC-Rock Hill SC Core-based Statistical Area (CBSA), over
the period 2007-2016, the 8-hour ozone design value decreased by 23%, meeting
both the 2008 ozone NAAQS and the more stringent 2015 ozone NAAQS. For the
Spartanburg CBSA which lies entirely in South Carolina, the 8-hour ozone design
value declined by 19% over the same period. Every CBSA in South Carolina saw an
improvement in ozone design values over this nine-year period, again reflecting the
success of state and federal regulations in reducing the precursors essential to
tropospheric ozone formation.
Travel Distance of Respirable Dust – Comments were received regarding the travel
distance of respirable dust and any potential health risks due to travel distance.
It is well known that respirable dust, i.e. PM10, can travel many miles from the source
of the PM10 emissions. That said, the Quarry submitted air dispersion modeling that
demonstrates the emissions from the Quarry will meet the PM10 NAAQS of 150 µg/m3
as calculated for a 24-hr averaging period. The NAAQS are established by EPA based
on scientific data and human health risk exposure to be protective of public health,
including the health of sensitive populations such as asthmatics, children, and the
elderly.
As is normal with most facilities, the air dispersion modeling indicates the highest
total predicted concentration (including the conservative 42 µg/m3 Cayce City Hall
background concentration) of 123 µg/m3 will occur at the facility boundary. The PM10
emissions are diluted as they are dispersed in the area surrounding the facility and
quickly decrease with distance from the Quarry. Within several hundred meters, the
predicted PM10 concentrations from the facility decrease to less than 10 µg/m3 (less
than 52 µg/m3 including the background concentration). Within 2 km of the Quarry,
the predicted PM10 concentrations fall to near ambient concentrations. Thus, while
the emitted respirable dust may travel many miles from the Quarry, air dispersion
modeling indicates the total predicted concentrations, which include a conservative
background concentration, will be well less than the PM10 NAAQS of 150 µg/m3 at the
facility boundary and beyond. It is worth noting that the air dispersion modeling
analysis conservatively assumes the facility will operate at maximum capacity
continuously for 24 hours/day, every day, which is both unrealistic and physically
impossible. When the facility is in actual operation, we expect actual air quality to be
better than what has been predicted in the air quality analysis. Thus, public health,
including the health of sensitive populations like vulnerable adults with chronic
conditions, seniors, and children, will be protected.
Wet Suppression System – Comments were received regarding the wet suppression
system, including concern that there is a lack of description of the system, how the
system will be used, and the frequency and nature of independent DHEC oversight
of implementation of the wet suppression systems.
Each piece of crushing, screening, and conveying equipment at the Quarry will be
equipped with a water spray valve that will dampen aggregate as needed (i.e. sprays
will not be on during a rainstorm or while a piece of equipment is not operating) to
help suppress dust as the aggregate is being processed and then conveyed to a
respective storage pile. The storage pile will be sprayed by a hose connected to a
water truck to further prevent fugitive dust. On-site roads will also be a source of
fugitive dust that will require the use of water trucks. The use of the water hose on
the water truck and the water truck itself will help suppress fugitive PM from storage
piles and on-site roads. This wet suppression equipment is identified in the permit
and statement of basis.
Luck Stone’s application states the following:
“Wet suppression on the mine hauling roads and customer access roads will be
accompanied by spray from mobile water trucks. Each crusher, screen, and conveyor
will be equipped with wet suppression valves. The wet suppression system will be
operating by the control room. Water spray valves will be activated prior to the
initiation of operations. Operation of the water spray valves will be controlled in
order to minimize water use such as closing water spray valves on non-operating
equipment.”
Condition C.6. of the construction permit requires:
“The owner/operator shall operate its wet suppression system except as necessary
for elevated material moisture content (i.e. rainfall).
In case the wet suppression system is not operating properly, then a portable water
spray system is acceptable for use until the permanent water spray system is back in
proper operation. If a portable water system is not available, then the process shall
be shut down until the permanent water spray system is back in proper operation.
The owner/operator shall perform weekly inspections of all wet suppression related
equipment including a check that water is flowing to discharge spray nozzles in the
wet suppression system. The owner/operator must initiate corrective action within
24 hours and complete corrective action as expediently as practical if the
owner/operator finds that water is not flowing properly during an inspection of the
water spray nozzles. The owner/operator must record each inspection of the water
spray nozzles, including the date of each inspection and any corrective actions taken
in the logbook…”
During a phone conversation with the facility’s air permit consultant, the consultant
was able to confirm that storage pile fugitive emissions will be controlled with water
trucks equipped with a spray hose. Please see the “Dust/Fugitive Particulate Matter
Emissions” and “Fugitive Dust Control Plan” sections below for more information on
DHEC’s oversight in the implementation of the wet suppression system.
Crystalline Silica and Other Lung Diseases - Comments were received regarding
adverse health effects from the facility’s air pollutant emissions. Specifically, concern
was expressed about exposure to crystalline silica, which is a component of granite
dust.
Crystalline silica is found abundantly in the earth’s crust and is a component of
granite, sand, soil, and other minerals. Several daily activities such as travelling on
dry-dirt roads and wind blowing across dry or sandy areas expose people to low
concentrations of silica.
Silicosis is a disease associated with long term exposure to very high concentrations
of silica in the workplace. Occupational regulations were developed to protect
workers from exposure to silica above certain levels.
In 1996, the EPA evaluated the scientific information available on occupational
exposure to silica, which included the medical histories of thousands of miners, as
well as available information regarding ambient exposure to silica. They concluded
that healthy individuals exposed to non-occupational silica concentrations are
adequately protected by the NAAQS for particulate matter, which was 50 µg/m3 at
that time.2 Since then, the EPA has strengthened PM standards to be more protective
of public health and the environment. Air dispersion modeling has shown the
facility’s PM10 concentration is below the current standard. Air dispersion modeling
for PM2.5 was not conducted because the controlled emissions of PM2.5 for the facility
are below threshold levels requiring an air quality analysis.
The EPA has adopted a health benchmark level for crystalline silica; however, based
on its evaluation of non-occupational exposure to silica, it has determined that
regulating silica exposure using the existing PM standards is protective of public
health. Therefore, the EPA has not set a NAAQS for silica nor included it on its list of
Hazardous Air Pollutants (HAP). As with the majority of states, SC DHEC regulations
focus on control measures in the permitting process and rely on the EPA’s conclusion
that regulating particulate emissions, a component of which is silica, is protective of
public health.
Exposure to silica dust is largely an occupational concern. Both the Occupational
Safety and Health Administration (OSHA) and the Mine Safety and Health
Administration (MSHA) regulate occupational exposure to silica. Silica is recognized
as a carcinogen and silicosis is a disease associated with long term exposure to very
high concentrations of silica in the workplace. Occupational regulations were
developed to protect workers from exposure to silica above certain levels. While
worker exposure limits are set to protect workers, measures used to reduce
2 “…[A] thorough analysis of the most extensive occupational studies available, each of which examined the medical histories of thousands of miners, suggests that the cumulative risk of silicosis among these South Dakotan, Canadian, and 8-9 South African miners from exposures at or below 1 mg crystalline silica/m years is close to 0%. 3 Using a high estimate of 10% for the crystalline silica fraction in PM from U.S. metropolitan 10 areas, 1 mg crystalline silica/m years is the highest CSE expected from continuous lifetime exposure at or below the annual PM NAAQS of 50 µg/m3. Thus, current data suggest that, for healthy individuals not compromised by other respiratory ailments and for ambient environments expected to contain 10% or less crystalline silica fraction in PM10, maintenance of the 50 µg/m3 annual NAAQS for PM should be adequate to protect against silicotic effects from ambient 10 crystalline silica exposures.” (US Environmental Protection Agency, 1996)
exposure for workers (for example, wet suppression) also reduce air emissions and
off-site impacts. Some of the permit requirements, like requiring dust from the
crushing, screening and conveying processes to be controlled through wet
suppression, reduce both workplace exposures and air emissions. The permit also
requires fugitive dust emissions to be minimized through the use of wet suppression,
water trucks, paving of roads, and other measures.
Dust/Fugitive Particulate Matter Emissions – Comments were received regarding
particulate matter (PM emissions), including fugitive PM emissions at the proposed
facility. These comments inquired about health impacts, dust on public and facility-
owned roads, dust during high levels of wind, dust on homes, plants, and animals,
oversight of reporting/maintenance and effectiveness of dust suppression.
Particulate matter (PM) emissions from the operating equipment and the on-site
roads are required to be controlled in accordance with air quality regulations. These
regulations limit PM emissions and opacity (amount of light blocked by dust
particles). Air dispersion modeling demonstrated that PM pollutant concentrations
did not exceed the NAAQS, which are protective of public health and the
environment. For health impact information, please see the “Air Pollution Impacts”
section above.
Using wet suppression to control PM emissions is required by the air permit. The
crushed stone processing plant (crushers, screens, conveyor systems) is regulated
under the federal EPA New Source Performance Standard for Nonmetallic Mineral
Processing Plants, 40 CFR Part 60, Subpart OOO, as well as State standards. These
regulations require the use of wet suppression and require maintenance, inspections
and, if necessary, corrective action on that control equipment. Water trucks (or other
dust control measure) will be used to control fugitive road and storage pile
emissions. When dust suppression is conducted in accordance with this permit, it is
effective in controlling dust emissions. To further reduce the potential for dust/dirt,
Luck Stone has committed to paving the road from the entrance to the facility on
Route 9 to the scale house. This additional stipulation has been added to the Fugitive
Dust Control Plan. For further information on impacts from truck traffic, see “Truck
Traffic” section below.
The facility must also develop and implement a comprehensive Fugitive Dust Control
Plan (plan) to ensure fugitive dust emissions are minimized. The plan requires the
facility to identify fugitive emission sources, detail what steps will be taken to
minimize emissions, record any excessive dust events and take corrective action to
mitigate emissions during any excess fugitive emission episode. This plan must be
submitted to the Department for approval 180 days prior to start of operations. The
plan shall address fugitive emissions from the crushed stone plant, truck traffic,
storage piles and any other potential source of fugitive dust emissions.
The air construction permit requires the facility to conduct weekly inspections on the
wet suppression related equipment to ensure they are operating properly. This data
is required to be recorded in a log book. During the Department’s unannounced air
inspections, the inspectors review all required records, observe the facility’s
processes while in operation, make visual emission observations, verify that the
equipment onsite matches those listed in the current permit, and review any other
pertinent information. Aside from unannounced inspections, inspections will also
occur on a complaint-driven basis. Any alleged violations are detailed in the
inspection report and referred to the Department’s Enforcement Section.
Fugitive Dust Control Plan – A question was received asking why the Fugitive Dust
Control Plan (Please see the “Dust/Fugitive Particulate Matter section above) is
submitted and reviewed 180 days prior to operation and not prior to issuance of a
construction permit.
Condition C.5 of the air construction permit requires the following in a Fugitive Dust
Control Plan:
“Compliance with non-enclosed operations and fugitive dust requirements shall be
demonstrated by developing a facility-wide fugitive dust control plan for controlling
fugitive emissions from process operations, truck traffic, storage piles, and any other
areas within the permitted facility where fugitive dust emissions can be generated.
The plan shall be developed and submitted to the Director of Air Permitting for
approval 180 days prior to the start of operation. The owner/operator shall
implement the plan within 30 days of approval and create a schedule for its periodic
review and update. The plan shall be kept and maintained on-site with a record of
revisions. The plan shall address and/or contain at a minimum the following:
1. Water Trucks
a. Weekly operation and maintenance checks of water trucks
b. Operating scenarios for water truck failures or inadequacies
c. Dates the water trucks did not operate and the alternative(s) dust
control method used
2. Truck Traffic
a. Road speed limits
b. Vehicle loading, off-loading, transportation or dumping of material
procedures
c. Spillage and residual materials clean-up procedures
d. Weekly operation and maintenance checks of sprinklers
e. Signage with respect to SC Code of Laws Sections 56-5-4100 and 56-5-
4110 (which requires haul trucks transporting aggregate from all
quarries to prevent the escape of materials loaded onto the vehicles)
f. The roadway from the facility's entrance to the facility's scale house
shall be paved to help further reduce fugitive dust.
3. Storage Piles
a. Material stock piling procedures
4. Process Equipment
a. Weekly operation and maintenance checks of all plant equipment and
enclosures
b. Spillage and residual materials clean-up procedures
c. Written guidelines on how to handle opacity problems
The owner/operator shall develop logs or use other approved methods to comply
with the requirements of the plan.”
Fugitive dust considerations and requirements are specific to each site and as such
fugitive dust plans require accurate, site-specific detail on how dust, truck traffic,
process equipment, etc. at the facility will be controlled and maintained. Prior to the
issuance of a construction permit, the specific details required for the plan may not
be known for certain by the facility at that time.
A comment was also received requesting that the draft Fugitive Dust Control Plan be
made available to the public and that the review process should consider public
comments on the proposed plan prior to acceptance by DHEC. The Fugitive Dust
Control Plan is not a state or federal regulatory requirement. The Fugitive Dust
Control Plan permit requirement serves as a means to facilitate DHEC review of
facility-proposed procedures for demonstrating compliance with fugitive dust
related state regulations (South Carolina Regulations 61-62.5 Standard No. 4, and
South Carolina Regulation 61-62.6). The public comment period on the draft air
construction permit gives the opportunity to comment directly on the condition
(Condition C.5 of the draft construction permit) that details the criteria for developing
a fugitive dust control plan and what must be included. The plan will be subject to
Department review and approval, and, once approved, may be viewed on the Luck
Stone web page.
Truck Traffic – Comments were received regarding the impacts from increased truck
traffic, including emissions and the safety concerns for existing roads and bridges
due to the increased volume of truck traffic.
The Department regulates the fugitive dust from roads within the facility; however,
the Department does not have the authority to regulate truck traffic on the public
roads. Tailpipe emissions from mobile sources are regulated by the EPA under the
authority of the Clean Air Act. The permit requires the facility’s roadways to be paved
and/or treated (such as the use of water sprays) to minimize dust. The facility must
also develop and implement a comprehensive fugitive dust control plan to ensure
fugitive dust emissions are minimized.
Within the dust control plan, signage with respect to SC Code of Laws Sections 56-5-
4100 and 56-5-4110 shall be posted on site. To promote safety from hauling, these
laws require that haul trucks transporting aggregate from quarries to prevent the
escape of materials loaded onto vehicles, escaped substances or cargo be cleaned
from highways, and that loads and covers be firmly attached. To further reduce the
potential for dust on public roads, the facility has committed to paving the roadway
from the entrance to the facility to the scale house. This additional requirement has
been added to the Fugitive Dust Control Plan and is also within the mine operating
permit for the facility.
Proximity to Residences, Schools, and Land Value – Comments were received
concerning the location of the facility relative to residential areas and personal
property.
All zoning decisions are made at the local level by a city or county zoning authority,
usually before a permit request is submitted to the Department. The Department
cannot dictate where a facility locates or factor property value impacts into
permitting decisions. However, as noted above in the “Air Pollution Impact” section,
the facility demonstrated using an EPA approved air dispersion model that it would
not cause or contribute to any violation of ambient air quality standards. Please
contact your local city or county council representatives for more information on how
to get involved in local zoning and planning issues.
Background Noise Levels – Comments were received concerning background noise
levels of the facility and related operations.
The Department does not have any noise standards in its air quality regulations and
therefore lacks authority to base a permit decision on noise levels. However,
excessive noise levels not usual for a site should be reported to the SC DHEC regional
office. This could be an indication that equipment is not operating properly.
Additionally, Chester County has local noise ordinances that may be found within The
Code of Ordinances of the County of Chester, South Carolina (Chapter 38, Article II,
Section 38-29 – “Noise”).
In addition, Mark Williams with Luck Companies submitted the following response in
an e-mail dated February 14, 2020, regarding concerns of noise:
“Luck Companies is committed to proactively addressing noise generated through their
activities by several mitigation tactics.
The operator shall use Best Management Practices (BMPs) to minimize noise from the
mine site. Vegetated earthen berms and buffers are used on-site to minimize noise beyond
the mine permit area. Other BMPs shall include, at a minimum, proper maintenance of
mufflers on equipment (trucks, trackhoes, pumps, etc.) and consideration of special
buffering measures if planning to operate equipment during nighttime hours. The
operating plant shall be located in an area where topography and buffers assist in
minimizing noise impacts to adjoining parcels. Additionally and when possible, Luck
Companies will work to exceed regulatory compliance standards set by MSHA through
identification and implementation of potential engineering controls to further reduce
noise. Where approved by regulators, Luck Companies shall employ broad band back-up
alerts on all company-owned mobile equipment.”
Further, the DHEC mining permit requires the facility to use best management
practices to minimize noise. Please see the Luck Stone mining permit for more
information.
Community/Quality of Life - Comments were received regarding the potential
impacts to the community’s way of life.
A community’s quality of life can be impacted both positively and negatively by a
variety of factors. The Department does not have the authority to base permit
decisions on these factors. Furthermore, as noted above, the Department does not
have the authority to dictate where a facility locates or make zoning decisions. The
permit decision is based on the Department’s technical review of the permit
application and the applicable air regulations and standards in place at the time of
the Department’s review. As mentioned previously in the Air Pollution Impacts Section,
these air quality regulations are set to protect public health and the environment.
General Opposition and Support – SC DHEC received several comments requesting
denial of the permit.
The Department appreciates all comments made regarding Luck Stone. However, the
Department does not have the authority to make permitting decisions based on
community, business, employee and customer approval or disapproval of the
company/facility. The Department’s decision is based on the Department’s technical
review of an application and the regulatory requirements in place at the time of the
Department’s review.
Other Sources of Air Emissions – Comments were received regarding dust directly
related to blasting and its associated particulate matter emissions and dust control.
The emission factors used to calculate the potential to emit for Luck Stone are from
the EPA-developed document, AP-42: Compilation of Air Emission Factors (AP-42).
Section 11.19.2 covers crushed stone processing and does not include emission
factors for excavating or particulate matter generated from blasting.
Although there are no known emission factors for blasting for stone quarries,
blasting is typically done while primary crushing and hauling are not in operation.
The blast area must be cleared before the blast and cannot resume until the blasting
contractors have inspected the blast area and determined the area safe to re-enter.
This operational shutdown typically lasts approximately 30 minutes while the actual
blast occurs in less than one minute. The emissions created from blasting are offset
by the cessation of emissions from primary crushing and hauling during that blasting
period.
The air permit does not address blasting activities, as such activities at a quarry are
regulated by the South Carolina Mining Act. The comments related to blasting were
considered by the BLWM as part of the review of the mining permit application.
Request for Elaboration on “Synthetic Minor” – A comment was received
requesting more detail on what a Synthetic Minor construction permit is.
On October 22, 2019, Lance Davis with the Bureau of Air Quality responded with an
email to the commenter. By way of summary, a synthetic minor construction permit
is one where the facility agrees to federally enforceable limitations on the amount of
pollutants that may be emitted to avoid “major source” levels under Prevention of
Significant Deterioration (PSD) and Title V regulations. In this case, the pollutants of
discussion are PM and PM10. For PM, the defined major threshold is 250.0 tons per
year (TPY) for PSD applicability. For PM10, the defined major threshold is 100.0 TPY
for Title V applicability and 250.0 TPY for PSD applicability. Through its air quality
permit, the Quarry has agreed to federally enforceable operating limitations to limit
its potential to emit to less than the above-referenced thresholds for PSD and Title V
for PM and PM10. Based on use of required controls (including wet suppression),
actual controlled emissions are estimated to be well below these thresholds.