DAQ-2024-004562

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DAQC-CI124440003-23
Site ID 12444 (B1)
MEMORANDUM

TO: FILE – STAKER PARSON COMPANIES – Keigley Quarry

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: October 17, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: August 30, 2023

SOURCE LOCATION: 12370 South West Mountain Highway
Genola, Utah
DIRECTIONS: Directions from I-15 Southbound – Take Payson Exit 248 and
turn right onto 10900 South then turn left after 0.2 mile onto
1700 West. Turn right onto 10950 South after 1.2 miles then
turn right onto 120000 South after 0.8 mile. The entrance to the
pit is 1.3 miles directly west.

SOURCE CONTACTS: Christian Boudreau, Environmental Specialist, West Division
801-871-6704 [e-mail]
Cole Pinarelli, Site Superintendent

OPERATING STATUS: Operating Normally.

PROCESS DESCRIPTION: Keigley Quarry has a primary and secondary crushing circuit
using crushers and screens to produce a variety of rock and
aggregate products. Some of the products are used to produce
asphalt. Asphalt and aggregate are trucked off-site to customers.
Limestone Quarry Operations: Two types of limestone
(carbonate mineral - limestone and dolomite) are mined at the
quarry. Limestone, mined from the Lime Pit, is a rock containing
large amounts of calcium carbonate. Dolomite, mined from the
East and West Dolomite Pits, is a form of limestone in which a
good part of the calcium carbonate has been replaced with
magnesium carbonate. Both types are mined in the same manner.
Holes are drilled - 15' apart and - 26' back from the face of the
pit with large mobile drill machines. Water is injected through
the drill bits as the machines operate, loosening the rock and
suppressing any dust created during drilling. Explosive charges
are then packed into the holes and set off, blasting the rock face
into 2"-minus rock. Loading Building. In this building, the rock
is screened into two cuts: 7/S"-minus to 1/8"-plus, and 1/8"
minus to 0. Each cut is kept in a separate storage bin. The site
also has a Rock Dust Mill, a standard aggregate processing plant,
and an asphalt plant.

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APPLICABLE REGULATIONS:
Approval Order (AO) DAQE-AN124440009-18 dated October 1,
2018
NSPS (Part 60) - OOO: Standards of Performance for
Nonmetallic Mineral Processing Plants,
NSPS (Part 60) – I: Standards of Performance for Hot Mix
Asphalt Facilities, UAC R307-203 and R307-312.

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Staker Parson Companies - Keigley Quarry
89 West 13490 South, Suite 100 12370 South West Mountain Highway
Draper, UT 84020 Genola, UT

SIC Code: 1442: (Construction Sand & Gravel)

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

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I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

Status: In Compliance. No limits were exceeded based on the submitted documents and the
observations made during the inspection. No additional equipment or processes since the
previous July 27, 2022, inspection have occurred, however, a modified AO is in process to
include the operation of the old Rock Dust Mill and add fuel tanks. The required records
are kept for at least two years and were made available. No applicable Breakdowns have
occurred and Emission Inventories are submitted as required. A startup notification was
submitted on May 6, 2019, see DAQC-1326-21 for more information.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Keigley Quarry

II.A.2 Four (4) Tri-Deck Screens
Capacity: 700 tph (each)

II.A.3 Two (2) Screen Plants
Capacity: 700 tph (each)

II.A.4 Two (2) Cone Crushers
Capacity: 700 tph (each)

II.A.5 Two (2) Jaw Crushers
Capacity: 700 tph (each)

II.A.6 One (1) VSI Crusher
Capacity: 700 tph

II.A.7 Additional Crushing Equipment
Includes: Various Conveyors, Feeders, Loaders, and Stackers

II.A.8 One (1) Grizzly Feeder

II.A.9 One (1) Hot Drum Mix Asphalt Plant
Capacity: 500 tph

II.A.10 Three (3) Hot Mix Storage Silos
Capacity: 300 tons (each)

II.A.11 One (1) Asphalt Storage Silo
Capacity: 75 tons

II.A.12 One (1) Lime Silo
Capacity: 3,600 Cu. Ft.

II.A.13 Eight (8) Cold Feed Bins

II.A.14 Two (2) Recycled Asphalt Pavement Bins

II.A.15 One (1) Baghouse
Rating: 70,000 acfm

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II.A.16 Various Aggregate & Asphalt Equipment
Includes: Conveyors, Loaders, Bulldozers, Haul Trucks; Holding Tanks, Hot Oil Heaters and
Feeders

II.A.17 One (1) Wash Plant
Includes: Screens, Belts, and Feeders

Status: In Compliance. An existing Rock Dust Mill dating back to the 1940's is not listed on
the permitted equipment on this AO. A post-inspection discussion with the Minor
Source NSR Section engineer, working on a modified AO at the time of this
inspection, confirmed that a modified AO needs to include the Rock Dust Mill
equipment. Other equipment which may be added include a 1,000-gallon gasoline
tank and a 10,000-gallon diesel tank. Stacker Parson Companies current contact
personnel has been notified that this process will be included in the modification. The
equipment was otherwise present at the time of the inspection.

II.B Requirements and Limitations

II.B.1 Site Wide Requirements

II.B.1.a The following production limits shall not be exceeded:

A. 6,000,000 tons of processed aggregate material per rolling 12-month period

B. 500,000 tons of asphalt material per rolling 12-month period

C. 500 tons per hour of asphalt material produced

[R307-401-8]

Status: In Compliance. The reported 12-month rolling totals for the period of August 2022,
through July 2023, was reported as follows:

A - Aggregate total - 1,137.122 tons.
B. - Hot Mix Plant production total - 174,189 tons.
C - Asphalt production tons per hour - 182.15 tons per hour.

See the attached emailed production total statement.

II.B.1.a.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months.
Records of production shall be kept for all periods when the plant is in operation. Production
shall be determined by scale house records or vendor receipts. The records of production shall be
kept on a daily basis. Hours of operation shall be determined by supervisor monitoring and
maintaining of an operations log. [R307-401-8]

Status: In Compliance. Records are derived from scale house records for all periods when
the equipment is in production and appear to be tabulated as required.

II.B.1.b Visible emissions from the following emission points shall not exceed the following values:

A. Crushers - 12% opacity

B. Screens - 7% opacity

C. All Conveyor Transfer Points - 7% opacity

D. All Diesel Engines - 20% opacity

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E. Asphalt Plant Baghouse - 10% opacity

F. All Conveyor Drop Points - 20% opacity

G. All Other Points - 20% opacity.

[R307-312]

Status: In Compliance. Visual Emission Observations (VEOs) were taken for a conveyor
drop to the surge pile, the material-drop to the entrance of the double screen, and the
asphalt plant's silo mix stack. The surge pile drop point was observed operating with a six-
minute average of 4.79%, the double screen entrance was observed operating with a six-
minute average of 4.375%, and the asphalt plant's silo stack was observed with a six-
minute opacity average of 6.04%. No other significant sources of opacity were seen during
the site inspection.

II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of visible emissions from stationary
sources shall be conducted according to 40 CFR 60, Appendix A, Method 9.

Initial visible emission observations shall be conducted according to 40 CFR 60.11 and 40 CFR
60.674. A certified observer must be used for these observations. Emission points which are
subject to the initial observations are those as defined in 40 CFR 60.670.

[R307-305]

Status: In Compliance. The opacity observations were conducted as per 40 CFR 60,
Method 9 requirements. See the attached VEOs.

II.B.2 Asphalt Plant Requirements

II.B.2.a The asphalt plant baghouse shall control process streams from the asphalt plant drum mixer. This
baghouse shall be sized to handle at least 70,000 ACFM for the existing conditions. All exhaust
air from the drum mixer shall be routed through the baghouse before being vented to the
atmosphere. [R307-401-8]

Status: In Compliance. The asphalt plant baghouse is sized as described and no changes
have occurred since the baghouse description submitted on the initial NOI. All exhaust air
from the drum mixer is routed through the baghouse before being vented to the
atmosphere.

II.B.2.b The asphalt plant shall not operate with a stack exhaust flow rate in excess of 75,000 ACFM
without prior approval from the Director in accordance with R307-401. This will be verified
during stack testing. [R307-401-8]

Status: In Compliance. The most recent stack test performed on August 25-26, 2023,
indicated compliance with the baghouse ACFM specifications. See the Montrose Air
Quality Services consulting report that is attached to the electronic files of DAQC-936-23.

II.B.2.c The following operating parameters for the asphalt plant baghouse shall be maintained within the
indicated ranges:

A. The pressure drop shall not be less than 2.0 inches of water column or more than 7.0
inches of water column

B. The pressure drop reading shall be accurate within plus or minus 1.0 inches of water
column.

The pressure drop shall be monitored with equipment located such that an inspector/operator can
safely read the output any time.

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All instruments shall be calibrated according to the manufacturer's instructions at least once
every 12 months. Continuous recording for the monitoring device is not required; however,
recording of the reading is required every time the baghouse is operated.

[R307-401-8]

Status: In Compliance. The asphalt plant baghouse was observed operating at 2.2 inches of
water column on the day of the inspection. The pressure drop gauge is located on the main
panel in the operator shack and can be easily read. Records of readings for each day of
operation are kept in a log at the operator building. The gauge is calibrated every year. The
last calibration on record is dated May 8, 2023. See the attached email statement.

II.B.2.d For the asphalt plant the following operating parameters shall be maintained within the indicated
ranges:

A. Temperature of the gases exiting the baghouse shall be between 100ºF and 350ºF -
Plus or minus 10ºF

B. Asphalt mix temperature not to exceed 350ºF - Plus or minus 10ºF

They shall be monitored with equipment located such that an inspector can at any time safely
read the output.

All instruments shall be calibrated in accordance with manufacturer's instructions or
recommendations. A log of asphalt mix temperature shall be taken at 15-minute intervals or more
often, and a current year of data shall be available for evaluation by the Director upon request.

[R307-401-8]

Status: In Compliance. The temperature of the gases exiting the baghouse are continuously
monitored and recorded on a graph wheel for all periods that the plant is in operation.
Temperatures viewed during the inspection which are recorded on graph wheel logs
indicated that the temperature remained within the limits with the exception of occasional
spikes that resolved quickly and spikes that happened during the initial startup or the
shutdown of the plant. Recent temperature readings were submitted as an example.

II.B.2.e Emissions to the atmosphere from the Hot Mix Asphalt Plant Baghouse Exhaust Stack shall not
exceed the following rates and concentrations (standardized at 68 °F, 29.92 in Hg):

Pollutant lb/hr grain/dscf

TSP 5.80 0.030
TSP (RAP) 6.78 0.035
PM10 4.64 0.024
PM10 (RAP) 5.42 0.028
PM10 (Filterable) 4.64 0.024
PM2.5 (Filterable) (RAP) 4.64 0.024

[R307-401-8]

Status: In Compliance. A Method 5 stack test was performed for PM on August 25-26,
2023. The DAQ review of the test indicated particulate measured at 0.00870 gr/dscf and
2.05576 lb/hr (DAQC-936-23). See Condition Status of II.B.2.e.8 for more information.

II.B.2.e.1 Stack testing to show compliance with the emission limitations stated in the above condition
shall be performed as specified below:

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Emission Point: HMAP Baghouse Exhaust Stack

Pollutant Test Frequency

PM10 #
(virgin & RAP)

PM2.5 #
(virgin & RAP)

# Test every three years or sooner if directed by the Director. Tests may be required if
the source is suspected to be in violation with other conditions of this AO.
Compliance testing shall not be required for both virgin and recycled materials during
the same testing period. Testing shall be performed for the product being produced
during the time of testing.

[R307-165]

II.B.2.e.2 Notification:

At least 30 days prior to conducting any emission testing required under any part of UAC, R307,
the owner or operator shall notify the Director of the date, time and place of such testing and, if
determined necessary by the Director, the owner or operator shall attend a pretest conference.
The pretest conference shall include representation from the owner/operator, the tester, and the
Director. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The source test protocol shall be approved by the Director prior to
performing the test(s). The source test protocol shall outline the proposed test methodologies,
stack to be tested, and procedures to be used. The emission point shall be designed to conform to
the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the
Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

[R307-165]

II.B.2.e.3 PM10

For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51,
Appendix M, Methods 201 or 201a. The back half condensibles shall also be tested using the
method specified by the Director. All particulate captured shall be considered PM10 .

For stacks in which liquid drops are present, methods to eliminate the liquid drops should be
explored. If no reasonable method to eliminate the drops exists, then the following methods shall
be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The condensable
particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other
EPA-approved testing method, acceptable to the Director. The portion of the front half of the
catch considered PM10 shall be based on information in Appendix B of the fifth addition of the
EPA document, AP-42, or other data acceptable to the Director. The condensable particulate
emissions shall not be used for compliance demonstration, but shall be used for inventory
purposes.

[R307-401]

II.B.2.e.4 PM2.5

The following methods shall be used to measure filterable particulate emissions: 40 CFR 51,
Appendix M, Method 201A, or other EPA-approved testing method, as acceptable to the
Director. All particulate captured shall be considered PM2.5. The portion of the filterable
particulate emissions considered PM2.5 shall be based on information in Appendix B of the fifth
edition of the EPA document, AP-42, or other data acceptable to the Director. The filterable
particulate emissions shall be used for compliance demonstration.
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The following methods shall be used to measure condensable particulate emissions: 40 CFR 51,
Appendix M, Method 202, or other EPA-approved testing method, as acceptable to the Director.
The condensable particulate emissions shall not be used for compliance demonstration, but shall
be used for inventory purposes.

[R307-401]

II.B.2.e.5 Volumetric Flow Rate

40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods approved by the
Director.

[R307-401]

II.B.2.e.6 Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation.

[R307-401]

II.B.2.e.7 New Source Operation

For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the production rate listed in this AO. If the maximum AO allowable production
rate has not been achieved at the time of the test, the following procedure shall be followed:

A. Testing shall be at no less than 90% of the production rate achieved to date.

B. If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This
new allowable maximum production rate shall remain in effect until successfully tested
at a higher rate.

C. The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate
(110% of the new rate) will then be allowed if the test is successful. This process may be
repeated until the maximum AO production rate is achieved.

[R307-401]

II.B.2.e.8 Existing Source Operation

For an existing source/emission point, the production rate during all compliance testing shall be
no less than 90% of the maximum production achieved in the previous three (3) years.

[R307-401]

Status: In Compliance. The stack test was performed by Montrose Air Quality Services
and the test was submitted on September 28, 2022. The AO requirements for testing were
deemed compliant as per the DAQ memo DAQC-936-23. The testing protocol was
submitted in April of 2022. The next stack test will be due during the calendar year of 2025.

II.B.3 Haul Road and Fugitive Dust Requirements

II.B.3.a All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
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water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below
freezing. The opacity shall not exceed 20% on site and 10% at the property boundary during
all times the areas are in use. If chemical treatment is to be used, the plan must be approved
by the Director. [R307-401-8]

Status: In compliance. No visible emissions were observed coming from the unpaved
roads and operational areas. A watering truck was observed operating during the site
inspection.

II.B.3.a.1 Records of water or chemical treatment shall be kept for all periods when the plant is in
operation. The records shall include the following items:

A. Date

B. Number of treatments made, dilution ratio, and quantity

C. Rainfall received, if any, and approximate amount

D. Records of temperature if the temperature is below freezing.
[R307-401-8]

Status: In compliance. Watering records are maintained on site and include the
required information.

II.B.3.b The haul road speed limit of 15 mph shall be posted, at a minimum, at the beginning of
the haul road where it is clearly visible. [R307-401-8]

Status: In compliance. There is a 10 mph sign at the entrance to the pit.

II.B.3.c Control of fugitive dust emissions from disturbed or stripped areas shall be required at all
times for the duration of the project/operation. [R307-309]

Status: In compliance. No visible emissions were observed from the disturbed and
stripped areas during the inspection. A Fugitive Dust Control Plan for this facility
was submitted on May 7, 2021.

II.B.3.d Visible fugitive dust emissions from haul-road traffic and mobile equipment in
operational areas shall not exceed 20% opacity on site and 10% opacity at the property
boundary. [R307-309]

II.B.3.d.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and
mobile equipment in operational areas shall use procedures similar to Method 9. The
normal requirement for observations to be made at 15-second intervals over a six-minute
period, however, shall not apply. Visible emissions shall be measured at the densest point
of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less
than 1/2 the height of the vehicle. [R307-309]

Status: In compliance. No significant visible emissions were observed associated
with haul-road traffic or mobile equipment in operational areas at the time of
inspection.

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II.B.3.e The haul road shall be paved and shall be periodically swept or sprayed clean as dry
conditions warrant or as determined necessary by the Director. [R307-401-8]

II.B.3.e.1 Records of cleaning paved roads shall be made available to the Director or the Director's
representative upon request. [R307-401-8]

Status: In compliance. The haul road was paved and clean at the time of inspection.
Sweeping is conducted regularly. Sweeper receipts were provided on a September 8,
2023, email statement with the production totals.

II.B.3.f The storage piles shall be watered to minimize generation of fugitive dusts, as dry
conditions warrant or as determined necessary by the Director. [R307-401-8]

Status: In compliance. No visible dust was observed emanating from the storage
piles during the inspection. The storage piles are reportedly watered at the same
time the operation areas are watered.

II.B.4 Fuel Requirements

II.B.4.a The owner/operator shall use only #1 or #2 fuel oil as a primary fuel for aggregate
processing equipment and propane, natural gas, fuel oil or on-specification used oil as
fuel in the asphalt plant. [R307-401-8]

Status: In compliance. Only #2 Ultra Low Sulfur fuel is used for the off-road
equipment. The aggregate equipment is operated on line power and the asphalt
plant is powered by natural gas.

II.B.4.b The sulfur content of any fuel oil or diesel burned shall not exceed:

A. 0.50 percent by weight for fuels used in the asphalt plant.

B. 15 ppm by weight for diesel fuels consumed in all other equipment.

[R307-401-8]

II.B.4.b.1 The sulfur content shall be determined by ASTM Method D-4294-89 or approved
equivalent. Certification of used oil shall be either by the owner/operators own testing or
test reports from the used oil fuel marketer. Certification of other fuels shall be either by
the owner/operators own testing or test reports from the fuel marketer. [R307-203]

Status: Not applicable for A as the plant was running on natural gas. Diesel fuel
used for the miscellaneous off-road equipment is provided by Chevron fuels which
certifies the product as #2 Ultra Low.

II.B.4.c Sources burning used oil for energy recovery shall comply with the following:

The concentrations/parameters of contaminants in any used oil fuel shall not exceed the following levels:

1) Arsenic 5 ppm by weight

2) Cadmium 2 ppm by weight

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3) Chromium 10 ppm by weight

4) Lead 100 ppm by weight

5) Total halogens 1,000 ppm by weight

6) Flash Point shall not be less than 100°F

[R307-401-14]

II.B.4.c.1 The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation. Records shall be made available to the Director or
the Director's representative upon request. The records shall include the three-year period
prior to the date of the request. [R307-401-8]

II.B.4.c.2 Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis. [R307-401-8]

II.B.4.c.3 Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the boiler. The oil shall be tested
for halogen content by ASTM Method D-808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the boiler tank and burned. [R307-401-8]

Status: Not applicable for II.B.4.c through II.B.4.c.3. The asphalt plant no longer
burns used oil.

Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

NSPS (Part 60) -OOO: Standards of Performance for Nonmetallic Mineral Processing Plants

Status: In Compliance. All opacities viewed on the day of this inspection were under the standards for
the applicable aggregate equipment. Monthly spray bar records were viewed on site. The records
covered a two-year period and included the dates and repair indicators. The initial Method 9
observations were performed on September 6, 2012. Copies of the observations were attached to the
inspection memo DAQC-1326-21.

NSPS (Part 60) – I: Standards of Performance for Hot Mix Asphalt Facilities

Status: In Compliance. This subpart is satisfied by compliance with Condition II.b.1.b.E for opacity
limits, and Conditions II.B.2.e through II.B.2.e.8 for stack testing requirements.

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AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. The observed opacities were under the limits established by this Rule for the
property boundaries and at all on site points. The most recent Fugitive Dust Control Plan is dated
May 7, 2021, and can be viewed on site.

Aggregate Processing Operations for PM2.5 Nonattainment Areas [R307-312]

Status: In Compliance. The opacities observed from the applicable equipment were under the limits
established by this rule. See Conditions II.B.1.b.A through II.B.1.b.G for more information.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Staker Parson Companies - Keigley
Quarry. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN124440009-18,
dated October 1, 2018. (PTE) are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Carbon Monoxide 32.55
Nitrogen Oxides 13.95
Particulate Matter - PM10 73.75
Particulate Matter - PM2.5 29.05
Sulfur Dioxide 15.21
Volatile Organic Compounds 8.00

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Acetaldehyde (CAS #75070) 660
Acrolein (CAS #107028) 20
Benzene (Including Benzene From Gasoline) (CAS #71432) 200
Ethyl Benzene (CAS #100414) 120
Formaldehyde (CAS #50000) 1560
Generic HAPs (CAS #GHAPS) 300
Hexane (CAS #110543) 460
Naphthalene (CAS #91203) 320
Toluene (CAS #108883) 1460
Xylenes (Isomers And Mixture) (CAS #1330207) 100

EMISSION INVENTORY data can be collected from SLEIS. See attached 2020 Emissions Inventory
Report for Staker & Parson Companies 2020 activity at the Keigley Quarry.

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions on record for the past five years.
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COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with the conditions of AO DAQE-AN124440009-18 dated
October 1, 2018, NSPS I, OOO, UAC R307-309, and R307-312 at the
time of this inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Schedule for the next inspection cycle. Check for a new AO that adds the
Rock Dust Mill and the fuel tanks.

NSR RECOMMENDATIONS: Consider removing Conditions II.B.4.c through II.B.4.c.3 as the asphalt
plant no longer uses used fuel oil.

ATTACHMENTS: VEOs, emailed production statement with attached asphalt temperature
graphs, sweeper records, and SLEIS 2020 Emission Inventory
10/16/23, 6:22 PM State of Utah Mail - RE: [EXT] Records to complete the Keigly Pit inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-6646107751994061276%7Cmsg-f:177651201595152370…1/4
Susan Weisenberg <[e-mail]>
RE: [EXT] Records to complete the Keigly Pit inspection
1 message
Scovill, Nakeasha (Staker Parson) <[e-mail]>Fri, Sep 8, 2023 at 4:57 PM
To: Susan Weisenberg <[e-mail]>
Cc: "Boudreau, Christian (Staker & Parson)" <[e-mail]>
Hey Susan,

II.B.1.a.A R12 Aggs: 1,137,122 Tons
II.B.1.a.B R12 HMA: 174,189 Tons
II.B.1.a.C 182.15 Tons Per Hour

II.B.2.c We are still working on finding out if the magnehelic has been calibrated in the last year. If not, then we will make
sure to get this done and sent to you as soon as possible.

II.B.2.d Attached are a recent week of temperature reading. Let me know if you need more.

II.B.3.e Attached are a few copies of sweeper receipts. Let me know if you need more.

The date of the most recent FDCP is 05/07/2021. If you need a copy of the email confirmation, I have that as well.

Let me know what else you need.

Thank you!

From: Susan Weisenberg <[e-mail]>
Sent: Thursday, August 31, 2023 3:53 PM
To: Scovill, Nakeasha (Staker Parson) <[e-mail]>
Subject: [EXT] Records to complete the Keigly Pit inspection

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
are expecting this email and know the contents are safe. If you believe this email may be phishing or malicious,
please use the Report Phish button.
10/16/23, 6:22 PM State of Utah Mail - RE: [EXT] Records to complete the Keigly Pit inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-6646107751994061276%7Cmsg-f:177651201595152370…2/4
Hello, I inspected the Keigly facility, located at 12370 South West Mountain Road, Geneva, yesterday. In order to
complete the inspection I will need documents to demonstrate compliance with with the following AO AN124440009-18
Conditions:

II.B.1.a. for the 12-month rolling period of August 2022 to July 2023 for A - total processed aggregate material, B - total
tons of asphalt material, and C. the tons per hour of asphalt produced.

II.B.2.c. - the pressure drop and on-site wheel recordings were reviewed during the inspection, I just need the most recent
calibration date for the asphalt plant's magnehelic gauge.

II.B.2.d - Please submit a recent week of asphalt mix temperature readings as an example of the typical hot mix
temperature range.

II.B.3.e - While watering records were reviewed on site, this referenced condition requires records of paved road
cleanings. Dennis Cole Pinarelli, stated that you probably have them. Please send me a recent road cleaning record and
a statement of how often the paved roads are cleaned.

R307-305 - requires the submission of a Fugitive Dust Control Plan. I couldn't find a record for the Keigly Pit's plan. Can
you give me the date of the current FDCP.

Thanks - let me know if you have any questions.

Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

ATTENTION: Ce courriel vient de l'exterieur de l'entreprise. Ne cliquez pas sur les liens, et n'ouvrez pas les pièces
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6 attachments
10/16/23, 6:22 PM State of Utah Mail - RE: [EXT] Records to complete the Keigly Pit inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-6646107751994061276%7Cmsg-f:177651201595152370…3/4
HMA Temp Readings 1.jpg
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HMA Temp Readings 2.jpg
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HMA Temp Readings 3.jpg
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HMA Temp Readings 4.jpg
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HMA Temp Readings.jpg
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10/16/23, 6:22 PM State of Utah Mail - RE: [EXT] Records to complete the Keigly Pit inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-6646107751994061276%7Cmsg-f:177651201595152370…4/4
image0000.JPG
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10/16/23, 6:20 PM State of Utah Mail - RE: [EXT] Records to complete the Keigly Pit inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-6646107751994061276%7Cmsg-f:177965730377382167…1/4
Susan Weisenberg <[e-mail]>
RE: [EXT] Records to complete the Keigly Pit inspection
1 message
Boudreau, Christian (Staker & Parson) <[e-mail]>Fri, Oct 13, 2023 at 10:10
AM
To: Susan Weisenberg <[e-mail]>
Susan,
Sorry for the late reply, the magnehelic gauge was last calibrated on 05/08/2023.
Thanks,
Christian Boudreau
Environmental Specialist
West Division
Staker Parson
A CRH COMPANY
89 West 13490 South
Draper, Utah 84020
O [phone]
C [phone]
E [e-mail]
From: Susan Weisenberg <[e-mail]>
Sent: Friday, October 6, 2023 11:34 AM
To: Scovill, Nakeasha (Staker Parson) <[e-mail]>
Cc: Boudreau, Christian (Staker & Parson) <[e-mail]>
Subject: Re: [EXT] Records to complete the Keigly Pit inspection
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
are expecting this email and know the contents are safe. If you believe this email may be phishing or malicious,
10/16/23, 6:20 PM State of Utah Mail - RE: [EXT] Records to complete the Keigly Pit inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-6646107751994061276%7Cmsg-f:177965730377382167…2/4
please use the Report Phish button.
Hello, were you able to get the date of the most recent asphalt plant's magnehelic calibration? Thanks!
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
On Fri, Sep 8, 2023 at 4:58 PM Scovill, Nakeasha (Staker Parson) <[e-mail]> wrote:
Hey Susan,
II.B.1.a.A R12 Aggs: 1,137,122 Tons
II.B.1.a.B R12 HMA: 174,189 Tons
II.B.1.a.C 182.15 Tons Per Hour
II.B.2.c We are still working on finding out if the magnehelic has been calibrated in the last year. If not, then we will
make sure to get this done and sent to you as soon as possible.
II.B.2.d Attached are a recent week of temperature reading. Let me know if you need more.
II.B.3.e Attached are a few copies of sweeper receipts. Let me know if you need more.
The date of the most recent FDCP is 05/07/2021. If you need a copy of the email confirmation, I have that as well.
Let me know what else you need.
Thank you!
From: Susan Weisenberg <[e-mail]>
Sent: Thursday, August 31, 2023 3:53 PM
To: Scovill, Nakeasha (Staker Parson) <[e-mail]>
Subject: [EXT] Records to complete the Keigly Pit inspection
10/16/23, 6:20 PM State of Utah Mail - RE: [EXT] Records to complete the Keigly Pit inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-6646107751994061276%7Cmsg-f:177965730377382167…3/4

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless
you are expecting this email and know the contents are safe. If you believe this email may be phishing or
malicious, please use the Report Phish button.
Hello, I inspected the Keigly facility, located at 12370 South West Mountain Road, Geneva, yesterday. In order to
complete the inspection I will need documents to demonstrate compliance with with the following AO AN124440009-18
Conditions:

II.B.1.a. for the 12-month rolling period of August 2022 to July 2023 for A - total processed aggregate material, B - total
tons of asphalt material, and C. the tons per hour of asphalt produced.

II.B.2.c. - the pressure drop and on-site wheel recordings were reviewed during the inspection, I just need the most
recent calibration date for the asphalt plant's magnehelic gauge.

II.B.2.d - Please submit a recent week of asphalt mix temperature readings as an example of the typical hot mix
temperature range.

II.B.3.e - While watering records were reviewed on site, this referenced condition requires records of paved road
cleanings. Dennis Cole Pinarelli, stated that you probably have them. Please send me a recent road cleaning record
and a statement of how often the paved roads are cleaned.

R307-305 - requires the submission of a Fugitive Dust Control Plan. I couldn't find a record for the Keigly Pit's plan.
Can you give me the date of the current FDCP.

Thanks - let me know if you have any questions.

Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

ATTENTION: Ce courriel vient de l'exterieur de l'entreprise. Ne cliquez pas sur les liens, et n'ouvrez pas les pièces
jointes, à moins que vous ne connaissiez l'expéditeur du courriel et savez que le contenu est sécuritaire. Si vous
pensez qu’il s’agit d’un courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentative
d’hameçonnage.
ATTENTION: Ce courriel vient de l'exterieur de l'entreprise. Ne cliquez pas sur les liens, et n'ouvrez pas les pièces
jointes, à moins que vous ne connaissiez l'expéditeur du courriel et savez que le contenu est sécuritaire. Si vous
10/16/23, 6:20 PM State of Utah Mail - RE: [EXT] Records to complete the Keigly Pit inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-6646107751994061276%7Cmsg-f:177965730377382167…4/4
pensez qu’il s’agit d’un courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentative
d’hameçonnage.
2020 Emissions Inventory Report
Emissions Summary for Staker & Parson Companies- Keigley Quarry (12444)
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)23.78752 0.2897 24.07722
PM10-FIL PM10 Filterable 21.3015 <.00001 21.3015
PM25-PRI PM2.5 Primary (Filt + Cond)3.10426 0.28101 3.38527
PM25-FIL PM2.5 Filterable 3.07823 <.00001 3.07823
SO2 Sulfur Dioxide 0.44254 0.00382 0.44636
NOX Nitrogen Oxides 3.38412 2.73354 6.11766
VOC Volatile Organic Compounds 4.16507 0.35416 4.51923
CO Carbon Monoxide 16.92061 1.82307 18.74368
7439921 Lead 0.00008 <.00001 0.00008

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
71432 Benzene (HAP)VOC 0.05076
7440439 Cadmium (HAP)PM 0.00005
50000 Formaldehyde (HAP)VOC 0.40349
7723140 Phosphorus (HAP)- 0.00364
540841 2,2,4-Trimethylpentane (HAP)VOC 0.00521
246 Polycyclic Organic Matter (HAP)VOC 0.01302

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
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