Southwest Iron, LLC – Authority to Construct Application

Prepare application for an Authority to Construct (ATC) for a multi-plant stationary source located near Jean, NV. The area is located in the Prevention of Significant Deterioration (PSD): area as established by the Clark County Department of Air Quality and Environmental Management (Clark County DAQEM).

Justice & Associates prepared all necessary documentation required to obtain a new air quality permit from the Clark County DAQEM. The facility consists of a drum mix Hot Mix Asphalt (HMA) plant and a crushing and screening plant with two (2) diesel fueled engines to power the plants.

Since this is a new stationary source, Justice & Associates was asked to prepare a Best Available Control (BACT) analysis for aggregate moisture content, power generation and drum burner operation. The BACT analysis is used to determine the maximum degree of regulated pollutant emission reductions required for a new or modified emission unit. In this case, Justice & Associates was able to get the two diesel fueled engines permitted as well as allow the drum mixer to operate on diesel fuel. The aggregate moisture BACT analysis achieved the highest amount of particulate control while allowing the plant to run without creating operational problems. Justice & Associates also prepared a moisture sampling compliance plan that will ensure that the plant is operating at permitted moisture limits.

The stationary source was successfully permitted to produce 350,000 tons of asphalt, 350,000 tons of aggregate and combust over 150,000 gallons of diesel fuel. This was all accomplished without triggering any major regulatory issues such as public notice, modeling or pre/post construction monitoring. Justice & Associates will continue to help this source with compliance issues such as Subpart OOO “New Source Performance Standard for Non-Metallic Mineral Processing Facilities” and Subpart I “New Source Performance Standard for Hot Mix Asphalt Facilities” performance testing.

Justice & Associates also obtained a mineral contract through the Bureau of Land Management (BLM) to allow Southwest Iron to excavate material on BLM land. As part of the application process Justice & Associates prepared an aggregate and HMA haul truck emissions analysis which indicated that having the HMA and crushing and screening plant located on the same site would reduce on-road fugitive dust emissions and diesel combustion emissions.

Southwest Iron, LLC 2606 Losee Road North Las Vegas, NV Tracy Davis Phone: (702) 644-6454

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