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AS}I EROVE
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A CRH COMPANY
DATE: April3,2024
VIA Certified Mail
Office of Emergency Management
1200 Pennsylvania Ave NW
Washington, DC 20460
Mail Code 5104A
Attn: Continuous Release Report
Subject: Ash Grove Cement Company - Leamington, UT plant Continuous Release, lnitialWritten
Notification (CR-ERNS #1 393034)
Dear Sir or Madam,
On behalf of Ash Grove Cement Company, I am writing to provide additional information about the
above-referenced continuous release of ammonia from the main kiln stack at our cement plant
located in Leamington, Utah. This follows the initialtelephone notification of this release made
previously. Enclosed with this report is a copy of the initial written notification report of the
continuous release, as specifled in 40 CFR 302.8(e).
Please let me know if you have questions about the enclosure
Sincerely,
nggs
Corporate Environmental Manager - West
Division of Environmental Response and Remediation
P.O. Box 144840
Salt Lake City, UT 84114-4840
RE: lncident #16937
Juab County Sheriff's Office
PO Box 133
Nephi, UT 84648
Ash Grove
11011CodyStreet
Overland Park
KS 66210
Ph:406 4914444
Jeff . [e-mail]
www.ashgrove.com
Continuous Release Form
Form Approved OMB No. 2050-00E6
Expiration Date: 11-30-2022
1 393034
I: GENERAL
INFORMATION CR-ERNS Number:
0310412024Date of Initial Release:0310412024 Date of Initial Call to NRC:
Type of Report: Select from the drop-down list,
the type of report that you
are submitting
lnitial Written Notification
Signed Statement: I certifu that the hazardous substance releases desuibed herein are continuous and stable in quantity
and rate under the definitions in 40 CFR 302.8(a) or 355.32 and that all submitted information is accurate and current to the
04t0312024 Jeff Briggs - Corporate Environmental MangerName and Posilion
,
Date Signature
best of my lmowledge.
Part A. Facility or Vessel Information
Name of Facility or Vessel Ash Grove Cement Company - Leamington, UT Plant
Person in Charge Name
of Facility or
Vessel phone Number
Josh Nelson Position Plant Manager
435-857-1211 Alt Phone No.
Facility Address
or Vessel Port of
Registration
Street Hwy 132 County Juab
City Leamington State
Dun and Bradstreet Number for Facility 00-712-3698
Facility/Vessel
Location
Latitude Deg 39 Min 33 Sec 48
Longitude oeg 112 Min Sec 4911
NOTE: Latilude/Longitude information can be obtained at the following websites: http://www.satsig.net/maps/lat-long-finder.htm, htp://earth.google.com/,
and http://www.census.gov/geo/landview/. Do not use P.O. Box, Rural Route or Mailing Address. Use physical location only.
Vessel LORAN Coordinates
Part B. Population Information
Population
Density
Sensitive
Populations and
Ecosystems within
One-Mile Radius
Select from the drop-down list, the range that
describes the population density within a one-
mile radius of your facility or vessel.
0-50 Persons
Sensitive Populations or Ecosystems
(e.g., elementary schools, hospitals, retirement communities,
retlands)
Estimated Distance and Direction from
Facility, if Known
None
EPA Form 6100-10, Continuous Release Reporting Form Page I of 3
E,ocoa"l84638_l
ON II: SOURCE
INFORMATION
Part A: Basis for Asserting the Release is Continuous and Stable in Ouantitv and Rate.
For EACH source of a release of a hazardous substance or mixturefromyourfaciltty or vessel, provide
thefollowing information on a SEPARATE sheet.
Name of Source:Cement Kiln
1. Indicate whether the release from this source is either:
Continuous without intemrption OR routine, anticipated, intermittent & incidental to
Note that unonttcipated events, such as spills, pipe ruptures, equipmentfailures, emergency shutdowns, or
accidents, do not qualifufor reduced reporting under CERCLA section 103(fl(2). (Jnanticipated events are
not incidental to normal operations and, by definition, are not continuous or anticipated, and are not
sfficiently predictable or regular to be considered stable in quantity and rate.
3. Identify below how you established the pattern or release and calculated release estimates.
I Release data llfuowledge of Operating Procedures ! Engineering estimate I Best Professional judgment
USEPA Reference Method Source Testing
Other
1 393034CR-ERNS Number:
2 Provide a briefstatement describing the basis for stating that the release is continuous and stable in quantity and rate.
If malfunction, describe the malfunction and explain why the release from the malfunction should be considered
continuous and stable in quantity and rate given the note above.
Facility was required to perform source testing for this chemical as part of a Section 114
request by USEPA in conjunction with the Portland Cement NESHAP Risk and Technology
Review. Testing was done under normal conditions. Based on the source testing, it was
determined that the emission rate exceeded CERCLA reporting thresholds. No previous
emission data was available.
Continuous Release Form
Form Approved OMB No. 2050-0086
Expiration Date: I l-30-2022
Form 6100-10, Continuous Form Page Z or f
E
Continuous Release Re Form Form Approved OMB No. 2050-0086
Expiration Date: 1 l-30-2022
SECTION II: SOURCE
INFORMATION
contin
CR-ERNS Number:1 393034
Part B: Specific Information on the Source
For the source identiJied above, provide thefollowing informatton. Please provide a SEPARATE sheetfor
EACH source.
AFFECTED MEDIUM. Identifu the environmental medium (i.e., air, surface water, soil, or ground water) that is affected
by the release from this source. If your source releases hazardous substances to more than one medium (e.g., a wastepile releasing
to air and ground water), treat the release to EACH medium as a separate source and complete Section II, Parts A, B, and C, of this
format for EACH medium affected.
o soIL oR GROUND WATER
Ifthe release is on or under the location of water wells within two miles.
Cement KilnName of Source:
O AIR Ifthe medium affected is air, please also specifu whether the source is a stack or a ground-based area source.
fi Stack Indicate stack height in feet or meters 295
O SURFACE WATER
Ifthe release affects any surface water body, give the name of the water body
Surface
Water Body
! Stream Ifthe release affects a stream, give the stream order or average flow rate, in cubic feet per second.
Stream Order OR Average Flow Rate (cubic feet/second)
! Lake Surface area oflake (in acres Average depth of lake (in meters)
Ifthe release affects a lake, give the surface area ofthe lake in acres and the average depth in meters.
Ootional Information
The following information is not required to comply with the rtgulation, however, such information will assist EPA in evaluating the risks
associated with the continuous release. If this informetion is not providcd, EPA will meke conservative assumptions rbout the appropriste
velues. Please note that the units specified below are suggested units. You may use other units; however, be certain that the units are clearly
identified.
For a stack release to air, provide the following information, ifavailable:
Gas Temp (degrees Fahrenheit, Kelvin, or Celsius)
available:
Inside diameter (feet or meters)Gas Exit Velocity (ft or meters/sec)
Average velocity of surface water (feet/second)
For a release to water,
EPA Form 6100-10, Continuous Release Reporting Form Pase 3 of 5
Continuous Release Form Form Approved OMB No. 2050-0086
Expiration D^te: ll-30-2022
ON II: SOURCE INFORMATION
(continued)CR-ERNS Number:1 393034
Part C: Identity and Ouantity of Each Hazardous Substance or Mixture Released From Each Source
Please provide a SEPARATE sheetfor EACH source.
Name of Source:Cement Kiln
Litt ..ch hrardout lrt trncc rrlctt d fmm the .ourc. idcrtlfld .bovc rrd prcvidc thc followiry irform.tior Irlud. uii! *r@ qrrop.iat . R..ti@ti.h! in ti.r (ci).
Name of Hazardous Substance CASRN #
Normal Range
(in lbs., kg, or Ci per day)
Upper Bound Lower Bound
Number of Days
Release Occurs
(per year)
Total Quantity
Released in Previous Year
(in lbs.. kg. or Ci)
Period of the
Release
Hydrogen Cyanide )1. 7 lo h'350 3 osD
List each mixture released from the source identified above and provide the following information. Include units where appropriate. Radionuclides in curies (Ci).
Normal Range of
Components
Normal Range of
Mixture Total Quantity of
Mixture Released
in Previous Year
(in lbs., kg or Ci)Name of Mixture
Name of Hazardous
Substance
Components CASRN #
(in lbs., kg, or Ci per day) (in lbs., kg, or Ci per day) Number of DaysWeight Upper Lower Upper Lower Release Occurs
Percentage Bound Bound Bound Bound (peryear)
Period of
the
Release
IEPA Form 6100-10, Continuous Release Reporting Form
W|z+eo€
ON III: SUBSTANCE
INFORMATION
Calculation of the SSI Trigger
For EACH hazardous substance component of a mixture indicated in Section II, Parr C,list the names of
the releasing soutces and their upper bounds. Please use a sEPARATE sheerfor EACH hazardous
substance.
* This methodfor calculating the SSI triggerfor the hazardous substance assumes that all releases of the
same hazardous substance or mixture occur simultaneousty. To the extent that q hazardous substanie is
releasedfrom yourfacilityfrom dffirent sources and at dffirentfrequencies, you mqy adjust the SSI trigger
as appropriate so that it more occurately reflects the frequency and quantity of the release. The SSI trtgger
in the final analysis must reflect the upper bound of the normal range of the release, taking into
consideration all sources of the release at the facility or vessel. The normal range of the ielease includes all
releases previously reported or occurring over a 24-hour period during the preiious year.
1 393034CR-ERNS Number:
Hydrogen CyanideName of Hazardous Substance:
calculate the SSI trigger (i.e.,upper bound ofthe normal range ofa release)the hazardous substance identified
aggregate the upper bounds ofthe normal range ofthe identified hazardous substance across all sources identified in
II,Part C.If the hazardous substance ls also component of a mixture,be certain to include the upper bound of the
component AS calculated ln Section II,Part C,ln your calculation of the S SI trigger,
Name of Source(s)
Upper Bound of the Normal Range of
the Release (specift lbs.. kg.. or Ci)
lCement Kiln l1,a
TOTAL - SSI trigger for this hazardous substance release*:)q.)
Continuous Release Form Form Approved OMB No. 2050-0086
Expiration Date. 11-30-2022
)
EPA Form 6100-10, Continuous Release Reporting Form
Page of 5
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