DAQ-2024-004566

1
DAQC-CI148470001-23
Site ID 14847 (B1)

MEMORANDUM

TO: FILE – GRANITE CONSTRUCTION COMPANY – Talons Cove Hot Mix Asphalt
Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: October 31, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: July 19, 2023

SOURCE LOCATION: 4288 East Ranches Parkway
Eagle Mountain, UT 84005
DIRECTIONS: From intersection of Redwood Road and Mountain View
Corridor, head west on Mountain View Corridor for about 2.5
miles, turn right onto W 8800 N, continue west on this road until
it turns into Spring Run Parkway. The plant will be on the left in
about 1 mile.

SOURCE CONTACTS: Quin Bingham, Environmental Manager
801-526-6050 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Granite Construction Company (GCC) operates a 400 ton per
hour asphalt plant with associated equipment at the Talons Cove
property shared with the TM Crushing aggregate operations. The
asphalt plant is situated north of the aggregate pit and can be
accessed by following the main TM haul road as it curves north
bound. Raw dry materials are kept in storage piles that can be
dropped by a front-end loader into a screen feed belt. The
material is blended with asphalt oils, mixed and then conveyed
to storage silos which then load through chutes into haul trucks.
Emissions are controlled with a baghouse. GCC runs its own
watering truck independent of TM Crushing's operations. A
modeling analysis for formaldehyde was required for this
operation. The modeling statement DAQE-MN148470001-13
documented emissions comply with the UDAQ-TSL (toxic
screening level).

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APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN148470001-14, dated January
22, 2014
NSPS (Part 60) -OOO : Standards of Performance for Nonmetallic
Mineral Processing Plants,

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

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Granite Construction Company
Talons Cove Hot Mix Asphalt Plant

1000 North Warm Springs Road 4288 East Ranches Parkway
Salt Lake City, UT 84116 Eagle Mountain, UT 84005

SIC Code: 2951: (Asphalt Paving Mixtures & Blocks)

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]

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

Status: Out of Compliance. Unpermitted equipment was observed on site at the time of
inspection. See Section II for more information.

No limits set forth in this AO appear to have been exceeded. The equipment appeared to be
properly operated and maintained according to manufacturer recommendations. Records
are kept as required and were made available after the inspection. No breakdowns have
been reported since the previous inspection. An emissions inventory was submitted for
2020, and emissions data are reported below.

Section II: SPECIAL PROVISIONS

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

II.A.1 Talons Cove Asphalt site
Hot Mix Asphalt Plant

II.A.2 CMI 400 T Drum Asphalt Plant
Company equipment ID # 35.320801, drum mix

II.A.3 One scalping screen
3 feet x 8 feet RAP scalping screen

II.A.4 Equipment company ID # 80.3209
30 inches x 58 feet RAP conveyor

II.A.5 Equipment company ID # 85.5009
Lime Silo/Pugmill/Screw

II.A.6 Equipment company ID #82.5003
CMI Cold Feed Screen

II.A.7 Company equipment ID 80.5008
CMI 30 inches x 47 feet Conveyor

II.A.8 Company equipment ID # 87.5002
CMI Reverse Air Baghouse

II.A.9 Company equipment ID 80.5011
24 inches x 24 feet RAP conveyor

II.A.10 Company equipment ID #80.1788
30 inches x 30 feet Conveyor

II.A.11 No company ID number
24 inches x 40 feet conveyor

II.A.12 Company equipment ID # 86.088
CEI 1800A Hot Oil Heater

II.A.13 Company equipment ID # 86.5011
CEI 30K AC Tank

II.A.14 Company equipment ID # 86.373
Burke 25K AC Tank

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II.A.15 Company equipment ID #86.718
Hyway 25K AC Tank

II.A.16 No company equipment ID
Six (6) Astec AC Silos, 200 tons capacity each

Status: Out of Compliance. All of the above equipment was observed on site. A fourth,
unpermitted AC tank is also operational at the site. A CA was issued on October 3,
2023 (see DAQC-1060-23). The source responded on October 5, 2023. The
compliance action was closed with an ESA issued on October 27, 2023 (see DAQC-
1154-23). Five of the Astec silos in Condition II.A.16 are on the main property, and
the sixth is on the hill above Kilgore's property.

II.B Requirements and Limitations

II.B.1.a The baghouse shall control process streams from the CMI drum mix asphalt plant. All exhaust
air from the asphalt-mixing drum shall be routed through its dedicated baghouse before being
vented to the atmosphere. [R307-401-8]

Status: In Compliance. All exhaust air from the asphalt mixing drum is routed through its
dedicated baghouse before being vented to the atmosphere.

II.B.1.b A manometer or magnehelic pressure gauge shall be installed on the asphalt plant baghouse to
measure the differential pressure across the fabric filters. Static pressure differential across the
fabric filters shall be between 4.0 to 7.0 inches of water column. The pressure gauge shall be
located such that an inspector/operator can safely read the indicator at any time. The readings
shall be accurate to within plus or minus one (1.0) inch of water column. Intermittent recording
of the readings are required on a once-per-operational-day basis. [R307-401-8]

Status: In Compliance. A magnehelic gauge for the baghouse is installed in the plant
operations trailer. The gauge read 4 inches of water column at the time of inspection. This
is within the specified range of this condition. Readings are recorded on a daily basis and
kept in a log book sorted by month. The readings for the past year were within the range
specified in this condition.

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

1. All screens - 10% opacity

2. All conveyor transfer points - 10% opacity

3. Baghouse exhaust stack - 20% opacity

4. Conveyor drop points - 20% opacity

5. All other points - 20% opacity

[R307-401-8]

II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. For sources that are subject to NSPS, opacity shall be
determined by conducting observations in accordance with 40 CFR 60.11(b) and 40 CFR 60,
Appendix A, Method 9. [R307-401-8]

Status: In Compliance. No conveyors were running at the time of inspection. No emissions
were observed as a result. The water truck was running. See the attached VEO Form.

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II.B.1.d The owner/operator shall not allow visible emissions from all paved in-plant haul roads to exceed
10 percent opacity and shall not allow visible emissions from all unpaved haul roads and fugitive
dust sources on site to exceed 20 percent opacity. [R307-401-8]

II.B.1.d.1 Visible emissions determinations for traffic sources 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 the vehicle length behind the vehicle and not less than 1/2
the height of the vehicle. [R307-309-5]

Status: In Compliance. No dust was observed from paved haul roads. No significant
fugitive dust was observed on the haul roads or surrounding operational areas. See the
attached VEO Form for additional information.

II.B.1.e Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

1. All dry screens

2. All conveyor transfer and stacker drop points

The sprays shall operate whenever conditions warrant to meet the opacity requirements of this
AO.

[R307-401-8]

Status: In Compliance. Water sprays have been installed at screens, conveyor transfer,
and drop points control fugitive emissions.

II.B.1.f The source shall not exceed the following limits:

1. 500,000 tons per rolling 12-month period of asphalt production

2. 3,840 hours per rolling 12-month period for HMA plant operation

3. 141,000 tons of recycled asphalt produced per rolling 12-month period

[R307-401-8]

II.B.1.f.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 of
the various products shall be determined by maintaining a production log for each material. 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. The source determines compliance from daily production records
when the plant is in operation, and maintains an operations log. For the rolling 12-month
period from July 2022 - June 2023, the following records have been reported:

1. 117,043 tons of asphalt production
2. 675 hours of HMA plant operation
3. 34,181 tons of recycled asphalt production

See the attached email correspondence.

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II.B.1.g Emissions to the atmosphere at all times from the indicated emission point shall not exceed the
following rates and concentrations:

Source: (Drum Asphalt Plant Stack)

Pollutant lb/hr grains/dscf (68 degrees F, 29.92 in Hg)

PM10 (virgin) 9.53 0.024
PM10 (recycle) 11.12 0.028

[R307-401-8]

Status: In Compliance. Stack Testing was performed on August 19, 2022. DAQ results for
the drum asphalt plant stack were 3.581 lb/hr, and 0.0211 gr/dscf for PM10. See
DAQC-1303-22 for more information.

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

Emissions Point Pollutant Testing Status Test Frequency

Asphalt Plant Stack PM10 * @

Testing Status (To be applied above)

* Initial compliance testing has already been performed.

@ 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.1.i Methods for pollutant PM10

For stack 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 back half
condensibles shall also be tested using the method specified by the Director. The portion of the
front half of the catch considered PM10 shall be based on information in AP-42, Appendix C or
other data acceptable to the Director.

The back half condensibles shall not be used for compliance demonstration but shall be used for
inventory purposes. [R307-165]

II.B.1.j Sample Location

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]
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II.B.1.k Volumetric flow rate

40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director.
[R307-165]

II.B.1.l Calculation

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. [R307-165]

II.B.1.m Notification

The Director shall be notified at least 30 days prior to conducting any required emission testing.
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
tests. The source test protocol shall outline the proposed test methodologies, stack to be tested,
and procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.n 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.
[R307-165]

Status: In Compliance. All requirements with testing, reporting, and approval were
followed. See DAQC-1303-22 for more information.

II.B.1.o 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 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. The opacity shall not exceed 20%
during all times the areas are in use or unless it is below freezing. Records of water and 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. Time of day treatments were made

Records of treatment shall be made available to the Director upon request. [R307-309-5]

Status: In Compliance. All unpaved roads and other unpaved operational areas are water
sprayed to control fugitive dust. Watering records were reviewed on site. These records
include the date of treatment, number of treatments, moisture received and time of day
treatments were made.

II.B.1.p The storage piles shall be watered to minimize generation of fugitive dusts, as dry conditions
warrant or as determined necessary by the Director. Records of water and/or chemical treatment
shall be kept for all periods when the plant is in operation. Records of water and/or chemical
treatment shall be made available to the Director or Director's representative upon request.
[R307-401-8]

Status: In Compliance. The water truck has the capability to water the storage piles and
the piles are watered when necessary. Records are maintained with the haul road records.
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II.B.1.q Granite Construction Company shall comply with a FDCP acceptable to the Director for control
of all dust sources associated with the Talons Cove site. Granite Construction Company shall
comply with the most current FDCP approved by the Director. The haul road speed shall be
posted. [R307-309-6]

Status: In Compliance. The most current Fugitive Dust Control Plan is dated May 22,
2013. The haul road speed is posted and clearly visible.

II.B.1.r The facility shall comply with all applicable requirements of R307-309 for PM10 and PM2.5
nonattainment areas for Fugitive Emission and Fugitive Dust sources. [R307-309]

Status: In Compliance. No visible emissions were observed from any point at the time of
inspection. See attached VEO Form for additional information.

II.B.1.s The owner/operator shall use natural gas as fuel in the asphalt plant. [R307-401-8]

Status: In Compliance. Natural gas is the only fuel used in the asphalt plant.

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: Not Applicable. A scalping screen and a cold feed screen are used to convey materials to the
asphalt mixing containers but do not process aggregate product as per Subpart OOO.

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

Status: In Compliance. An initial stack test was performed for this previously portable plant on
September 21, 2013. The most recent stack test was performed on August 19, 2022 (see DAQC-1303-22).
An initial VEO for the plant was performed on September 18, 2013, and the results were submitted to the
DAQ with the stack testing results. This plant operates on natural gas.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. No visible emissions were observed from any point at the time of inspection.
See attached VEO Form for additional information.

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

Status: In Compliance. No significant fugitive dust was observed on the haul roads or surrounding
operational areas. See the attached VEO Form for additional information.
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Aggregate Processing Operations for PM2.5 Nonattainment Areas [R307-312]

Status: In Compliance. No visible emissions were observed from any point at the time of inspection.
See attached VEO Form for additional information.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Granite Construction Company – Talons
Cove Hot Mix Asphalt Plant. A comparison of the estimated total potential emissions (PTE) on AO
DAQE-AN148470001-14, dated January 22, 2014, is provided. PTE are supplied for supplemental
purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Carbon Monoxide 33.18 13.17854
Nitrogen Dioxide 6.50 2.51154
Particulate Matter - PM10 5.75 2.05841
Particulate Matter - PM10 (Fugitives) 3.93 0.20715
Particulate Matter - PM2.5 1.39 2.49974
Sulfur Dioxide 0.85 0.46212
Volatile Organic Compounds 11.84 2.3438

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN148470001-14,
dated January 22, 2014: Not in compliance at the time of
inspection due to an unpermitted AC tank. A CA was issued on
October 3, 2023 (see DAQC-1060-23). The source responded
on October 5, 2023. The compliance action was closed with an
ESA issued on October 27, 2023 (see DAQC-1154-23). Source
contacts believed that the unpermitted AC tank would not
contribute to emissions, and they should receive only a warning.
Compliance assistance was provided to explain the VOC, HAP,
and NOx emissions of AC tanks. See the attached
correspondence.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect again next year, ideally wait until the new AO that has
the 4th AC tank permitted.

NSR RECOMMENDATIONS: 4th AC tank needs to be put in equipment list

ATTACHMENTS: VEO form, email correspondence
10/31/23, 11:49 AM State of Utah Mail - (no subject)
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-25528822648005969&simpl=msg-a:r1203546897422276…1/3
Daniel Riddle <[e-mail]>
(no subject)
5 messages
Daniel Riddle <[e-mail]>Mon, Jul 31, 2023 at 10:05 AM
To: "Bingham, Quin" <[e-mail]>
Quin,
This email got left in my drafts folder, so I'm sending it to you a bit later than I had intended.
On July 19, 2023 I went to inspect site ID 12727 - Granite Construction Company's hot mix asphalt plant in Eagle
Mountain. Here are the records I'll need to complete my inspection report:
From AO DAQE-AN148470001-14:
Condition II.B.1.b - reading on magnehelic (daily)
Condition II.B.1.f - records of production of asphalt and recycled asphalt, as well as hours of HMA operation (July 2022 -
June 2023)
Condition II.B.1.o - record of watering roads
Finally, I counted 4 AC tanks on site, although the permit has 3 listed in Conditions II.A.13-II.A.15. They are numbered 1 -
4. If this is unpermitted equipment, then we may need to issue a compliance advisory.
Please provide these records to me by August 10, 2023. Let me know if you have any questions.
Best,
Daniel Riddle
Bingham, Quin <[e-mail]>Thu, Aug 3, 2023 at 12:29 PM
To: Daniel Riddle <[e-mail]>
Daniel,

Please find attached a copy of the daily magnehelic reading for the hot plant baghouse. Note they recorded the
magnehelic results under the opacity column?

Production records for asphalt (tons): 117,043 tons
Hours of operation for the hot mix plant: 675 hours
Production records of recycled asphalt (tons): 34,181 tons

Regarding the 4th AC tank, I am in the process of submitting a NOI for a minor modification to our AO.

Please let me know if you have any questions.

Regards,
Quin

10/31/23, 11:49 AM State of Utah Mail - (no subject)
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-25528822648005969&simpl=msg-a:r1203546897422276…2/3
Quinten G. Bingham
Utah Region Environmental Manager
1000 N Warm Springs Rd
Salt Lake City,UT 84116
Direct: 801-526-6050
Mobile: [phone]
Email: [e-mail]

From: Daniel Riddle <[e-mail]>
Sent: Monday, July 31, 2023 10:06 AM
To: Bingham, Quin <[e-mail]>
Subject:

CAUTION: This email originated from outside of Granite
[Quoted text hidden]
Talon Cove Magnehelic Reports 2023.pdf
1508K
Daniel Riddle <[e-mail]>Mon, Sep 25, 2023 at 10:27 AM
To: "Bingham, Quin" <[e-mail]>
Quin,
Did you submit that NOI? I have not seen anything in our system yet. The 4th tank should have been permitted before it
was on site and operational anyway. I will likely be sending a Compliance Advisory, but the best way to get back into
compliance is to submit that NOI asap.
Best,
Daniel
[Quoted text hidden]
2 attachments
10/31/23, 11:49 AM State of Utah Mail - (no subject)
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-25528822648005969&simpl=msg-a:r1203546897422276…3/3
image001.png
15K
image001.png
15K
Bingham, Quin <[e-mail]>Tue, Sep 26, 2023 at 8:16 AM
To: Daniel Riddle <[e-mail]>
Daniel,

I’ll be submitting the NOI this week.

Best,
Quin
[Quoted text hidden]
Daniel Riddle <[e-mail]>Tue, Sep 26, 2023 at 10:39 AM
To: "Bingham, Quin" <[e-mail]>
Okay, thanks for getting on that
[Quoted text hidden]
11/2/23, 11:54 AM State of Utah Mail - Response to Compliance Advisory Letter DAQC-1060-23
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1778944038881923927&simpl=msg-f:17789440388819239…1/6
Daniel Riddle <[e-mail]>
Response to Compliance Advisory Letter DAQC-1060-23
11 messages
Bingham, Quin <[e-mail]>Thu, Oct 5, 2023 at 1:13 PM
To: Chad Gilgen <[e-mail]>, Daniel Riddle <[e-mail]>
Chad and Daniel,

Please find attached Granite Construction Company’s response letter to the UDAQ Compliance Letter DAQC-1060-3
written on October 3, 2023.

As of September 28, 2023, I have submitted an NOI to modify our AO and have meeting to discuss this modification with
John Persons tomorrow morning.

I plan to keep you both apprised of the modifications progress.

Please advise if additional corrective actions are required.

Best,
Quin

Quinten G. Bingham
Regional Environmental Manager
1000 N Warm Springs Rd
Salt Lake City,UT 84116
Direct: 801-526-6050
Mobile: [phone]
Email: [e-mail]

11/2/23, 11:54 AM State of Utah Mail - Response to Compliance Advisory Letter DAQC-1060-23
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1778944038881923927&simpl=msg-f:17789440388819239…2/6
GCC_TalonsCove_CA_ResponseLetter_10052023.pdf
217K
Chad Gilgen <[e-mail]>Fri, Oct 13, 2023 at 2:05 PM
To: Daniel Riddle <[e-mail]>
Hi Daniel,
Based on Quin's response, go ahead and put together an ESA for this one. I'll let Quin know we've received his response
and he can expect to see that settlement agreement soon.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Chad Gilgen <[e-mail]>Fri, Oct 13, 2023 at 2:09 PM
To: "Bingham, Quin" <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
Hello Quin,
Thanks for submitting your response to the Compliance Advisory. Based on the information provided, and the steps taken
to submit an NOI, no further corrective action is needed on your part at this time. We will move forward with closing this
compliance action out with an Early Settlement Agreement that will be sent to your attention within the next 10-14
business days.
Let me know if you have any questions or would like to discuss anything here further.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Thu, Oct 5, 2023 at 1:14 PM Bingham, Quin <[e-mail]> wrote:
[Quoted text hidden]
Bingham, Quin <[e-mail]>Fri, Oct 13, 2023 at 2:11 PM
To: Chad Gilgen <[e-mail]>
11/2/23, 11:54 AM State of Utah Mail - Response to Compliance Advisory Letter DAQC-1060-23
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1778944038881923927&simpl=msg-f:17789440388819239…3/6
Cc: Daniel Riddle <[e-mail]>
Chad,

Thank you for the notification.

Have a great weekend.

-Quin

From: Chad Gilgen <[e-mail]>
Sent: Friday, October 13, 2023 2:10 PM
To: Bingham, Quin <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
Subject: Re: Response to Compliance Advisory Letter DAQC-1060-23

CAUTION: External Email: Be Cyber-Alert
[Quoted text hidden]
Bingham, Quin <[e-mail]>Mon, Oct 30, 2023 at 2:04 PM
To: Chad Gilgen <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
Hi Chad,

I hope you had a great weekend.

I am emailing you as I received a certified letter from UDEQ today indicating that we are to pay a fine based on the finding
of this Compliance Advisory.

Based on our email correspondence below, (1) Granite submitting an NOI on 9/28 to mod our AO based on the
compliance advisory and (2) your response indicating that UDA was closing this compliance action out with an early
agreement, I was under the impression that this compliance advisory was closed out based on our corrective actions.

Can you please help me understand whether we are to pay this fine or if this letter was sent out prior to closing this
compliance action?

Thanks,
Quin

11/2/23, 11:54 AM State of Utah Mail - Response to Compliance Advisory Letter DAQC-1060-23
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1778944038881923927&simpl=msg-f:17789440388819239…4/6
From: Chad Gilgen <[e-mail]>
Sent: Friday, October 13, 2023 2:10 PM
To: Bingham, Quin <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
Subject: Re: Response to Compliance Advisory Letter DAQC-1060-23

CAUTION: External Email: Be Cyber-Alert
[Quoted text hidden]
Chad Gilgen <[e-mail]>Tue, Oct 31, 2023 at 9:47 AM
To: "Bingham, Quin" <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
Hi Quin,
Yes, per my previous email, I indicated we would be sending out an Early Settlement Agreement (ESA) to close this one
out. An ESA with a reduced penalty is pretty standard for closing out compliance actions where unapproved equipment is
found as part of a compliance inspection. The ESA was sent since an NOI was submitted to add this equipment to the
Approval Order (AO).
I hope this answers your questions. Please let me know if you would like to discuss further.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Bingham, Quin <[e-mail]>Tue, Oct 31, 2023 at 9:57 AM
To: Chad Gilgen <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
Hey Chad,

Thanks for the additional clarification.

It was very helpful as this was a first for me.
11/2/23, 11:54 AM State of Utah Mail - Response to Compliance Advisory Letter DAQC-1060-23
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1778944038881923927&simpl=msg-f:17789440388819239…5/6

Best,
[Quoted text hidden]
Chad Gilgen <[e-mail]>Tue, Oct 31, 2023 at 2:43 PM
To: "Bingham, Quin" <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
Hi Quin,
You're welcome. Let me know if you have any other questions.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Bingham, Quin <[e-mail]>Tue, Oct 31, 2023 at 3:36 PM
To: Chad Gilgen <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
Dear Chad,

I hope you have a great Halloween. I attempted to reach you by phone earlier, but unfortunately, I was able to connect
with you. I will attempt to connect with you again tomorrow.

My primary concern pertains to the ESA fine is regarding our overall AC tank emissions. While I understand that our
current number of AC tanks on-site does not match our AO equipment list, it's essential to note that, from an emissions
standpoint, there has been virtually no change in our overall VOC emissions. This is because our annual AC throughput
remains consistent and is based on our annual HMA production.

I would like to explore the possibility of having this violation dropped, considering the absence of any significant change in
emissions. It appears to be more of an oversight in our equipment inventory.

Best regards,
[Quoted text hidden]
Chad Gilgen <[e-mail]>Wed, Nov 1, 2023 at 2:06 PM
To: "Bingham, Quin" <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
11/2/23, 11:54 AM State of Utah Mail - Response to Compliance Advisory Letter DAQC-1060-23
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1778944038881923927&simpl=msg-f:17789440388819239…6/6
Hello Quin,
Sorry I missed your call yesterday. AC storage tanks are considered potential sources of VOCs and HAPs that are taken
into account as part of a source's overall potential to emit. There are also NOx emission considerations associated with
the heater combustion for maintaining the temperature of each AC tank. Due to these factors, the penalty amount will
stand as is.
As a note - I received notification from our office staff that the penalty was paid this morning but the signed Acceptance of
Early Settlement Agreement page was not included. Do you know if that form was signed and submitted? If not, can you
please forward a copy to us?
Thanks and please let me know if you have any questions.
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Chad Gilgen <[e-mail]>Wed, Nov 1, 2023 at 2:07 PM
To: John Persons <[e-mail]>
Cc: Daniel Riddle <[e-mail]>
Hello John,
Please see the following exchange with Granite Construction on the Talons Cove Pit. I see you are working on an AO
modification with them and wanted to make sure you were aware of the correspondence.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]