DAQ-2024-010848

1

DAQC-970-24
Site ID 12894 (B4)
MEMORANDUM

TO: STACK TEST FILE – STAKER PARSON – Huntington Asphalt
and Aggregate Pit

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Paul Bushman, Environmental Scientist

DATE: September 26, 2024

SUBJECT: Source: One (1) Gencor 400 Drum Mix Hot Mix Asphalt Plant
Location: Approximately 2 miles North and West of Huntington, UT
Contact: Jeffery Cowlishaw: 385-405-4315
Tester: Montrose Air Quality Services, LLC
Site ID #: 12894
Permit/AO #: Approval Order (AO) DAQE-AN128940010-19, dated March 14, 2019
Subject: Review of Pretest Protocol received September 24, 2024

On September 24, 2024, DAQ received a test notification for the testing of one (1) Gencor 400 Drum Mix
Hot Mix Asphalt Plant located Approximately 2 miles North and West of Huntington on Highway 31 in
Emery County, UT. Testing will be performed October 8, 2024, to determine compliance with the
emission limits found in condition II.B.2.e of AO DAQE-AN128940010-19.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3 used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine the moisture content within the gas stream: OK
5. RM 5 used to determine total particulate emissions: OK
6. RM 202 used to determine condensable PM10 emissions: OK

DEVIATIONS: No deviations stated in the protocol.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Staker Parson pretest protocol and 30 day notification exemption
request.
Source Test Plan for 2024 Compliance Testing on
the Gencor 400 Drum Mix Hot Mix Asphalt Plant
Staker Parson
Approximately 2 miles North and West of
Huntington on Highway 31
Emery County, Utah
Prepared For:
Staker Parson
2350 South 1900 West
Ogden, Utah 84401
Prepared By:
Montrose Air Quality Services, LLC
6823 South 3600 West
Spanish Fork, Utah 84660
For Submission To:
State of Utah Department of Environmental Quality
Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84114-4820
Document Number: GP081AS-046104-PP-917
Proposed Test Date: October 8, 2024
Submittal Date: September 23, 2024
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2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah

Review and Certification
I certify that, to the best of my knowledge, the information contained in this document is
complete and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature: Date: September 24, 2024
Name: Joby Dunmire Title: Reporting/QC Specialist III
I have reviewed, technically and editorially, details and other appropriate written materials
contained herein. I hereby certify that to the best of my knowledge the presented material
is authentic and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature: Date: September 24, 2024
Name: Beckie Hawkins Title: District Manager

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2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah

Table of Contents
Section Page
1.0Introduction ........................................................................................................ 5 
1.1Summary of Test Program ............................................................................. 5 
1.2Applicable Regulations and Emission Limits ...................................................... 6 
1.3Key Personnel .............................................................................................. 7 
2.0Plant and Sampling Location Descriptions................................................................ 8 
2.1Process Description, Operation, and Control Equipment ..................................... 8 
2.2Flue Gas Sampling Location ........................................................................... 8 
2.3Operating Conditions and Process Data ........................................................... 9 
2.4Plant Safety ............................................................................................... 10
2.4.1Safety Responsibilities ........................................................................ 10
2.4.2Safety Program and Requirements ....................................................... 11 
3.0Sampling and Analytical Procedures ..................................................................... 12 
3.1Test Methods ............................................................................................. 12
3.1.1 EPA Method 1, Sample and Velocity Traverses for Stationary Sources ...... 12
3.1.2 EPA Method 2, Determination of Stack Gas Velocity and Volumetric Flow
Rate (Type S Pitot Tube) .................................................................... 12
3.1.3 EPA Method 3, Gas Analysis for the Determination of Dry Molecular Weight
13
3.1.4 EPA Method 4, Determination of Moisture Content in Stack Gas ............... 13 
3.1.5 EPA Methods 5 and 202, Determination of Particulate Matter from
Stationary Sources and Dry Impinger Method for Determining Condensable
Particulate Emissions from Stationary Sources ...................................... 14
3.1.6 EPA Method 9, Visual Determination of the Opacity of Emissions ............. 15 
4.0Quality Assurance and Reporting .......................................................................... 17 
4.1QA Audits .................................................................................................. 17
4.2Quality Control Procedures .......................................................................... 17 
4.2.1Equipment Inspection and Maintenance ................................................ 17 
4.2.2Audit Samples ................................................................................... 17
4.3Data Analysis and Validation ........................................................................ 17 
4.4Sample Identification and Custody ................................................................ 18 
4.5Quality Statement ...................................................................................... 18
4.6Reporting .................................................................................................. 18
4.6.1Example Report Format ...................................................................... 19
4.6.2Example Presentation of Test Results ................................................... 19 

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List of Appendices
A Supporting Information ...................................................................................... 21 
A.1 Units and Abbreviations.............................................................................. 22 
A.2 Accreditation Information/Certifications ........................................................ 30
A.3 AO DAQE-AN128940010-19 ........................................................................ 32 
“S” Field Work Safety Plan ....................................................................................... 46 
List of Tables
1-1 Summary of Test Program and Proposed Schedule .................................................. 5 
1-2 Reporting Units and Emission Limits ...................................................................... 6 
1-3 Test Personnel and Responsibilities ....................................................................... 7 
2-1 Sampling Location ............................................................................................... 9 
4-1 Example Emissions Results - Gencor 400 TPH HMA Plant, Huntington, Utah ............. 20 
List of Figures
3-1 EPA Methods 5/202 Sampling Train ..................................................................... 15 
4-1 Typical Report Format ....................................................................................... 19 

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1.0 Introduction
1.1 Summary of Test Program
Staker Parson contracted Montrose Air Quality Services, LLC (Montrose) to perform a total
suspended particulate matter (PM), particulate matter less than 10 microns in aerodynamic
diameter (PM10) and visible emissions of opacity (VEOs) compliance emissions test program
on the outlet of the Gencor 400 TPH Drum Mix Hot Mix Asphalt (HMA) Plant located at the
Huntington Asphalt and Aggregate facility located near Huntington, Utah.
The tests are being conducted to determine compliance with the emission limits listed in
Approval Order (AO) DAQE-AN128940010-19, issued by the State of Utah Department of
Environmental Quality, Division of Air Quality on March 14, 2019. A copy of the AO is
attached as Appendix A-3.
The specific objectives are to:
x Measure emissions of PM/PM10 at the outlet of the Gencor 400 TPH Drum Mix
HMA Plant, Drum Dryer, controlled by a baghouse.
x Determine the opacity of emissions (VEOs) at the outlet of the Gencor 400
TPH Drum Mix HMA Plant, Drum Dryer, controlled by a baghouse.
x Conduct the test program with a focus on safety.
Montrose will provide the test personnel and the necessary equipment to measure emissions
as outlined in this test plan. Facility personnel will provide the process and production data
to be included in the final report. A summary of the test program and proposed schedule is
presented in Table 1-1.
Table 1-1
Summary of Test Program and Proposed Schedule
Proposed
Test Date(s)
Unit ID/
Source Name Activity/Parameters Test Methods
No. of
Runs
Duration
(Minutes)
October 8,
2024
Gencor 400
TPH Drum Mix
HMA
Velocity/Volumetric
Flow Rate
EPA 1, 2, 3A,
4 3 ~60
O2, CO2 EPA 3A 3 ~60
Moisture EPA 4 3 ~60
PM/PM10 EPA 5/202 3 ~60
Opacity EPA 9 3 ~6

To simplify this test plan, a list of Units and Abbreviations is included in Appendix A.
Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not
defined. Please refer to the list for specific details.
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2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah

1.2 Applicable Regulations and Emission Limits
The results from this test program are presented in units consistent with those listed in the
applicable regulations or requirements. The reporting units and emission limits are
presented in Table 1-2.
Table 1-2
Reporting Units and Emission Limits
Unit ID/
Source Name Parameter Reporting Units Emission Limit
Emission Limit
Reference
Gencor 400
TPH Drum Mix
HMA
PM
lb/hr virgin & RAP material 10.07
AN128940010-
19, §II.B.2.e.
gr/dscf virgin & RAP material 0.020
PM10
lb/hr virgin & RAP material 8.05
gr/dscf virgin & RAP material 0.016
Opacity % 10 AN128940010-
19, §II.B.2.d.

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2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah

1.3 Key Personnel
A list of project participants is included below:

Facility Information
Source Location: Staker Parson
Huntington Asphalt and Aggregate
Gencor 400 TPH Drum Mix HMA Plant
About 2 miles North and West of Huntington on Highway 31
Emery County, Utah 84528
Project Contact: Jeffery Cowlishaw
Role: Environmental Specialist
Company: Staker Parson
Telephone: [phone]
Email: [e-mail]

Agency Information
Regulatory
Agency:
State of Utah DEQ, Division of Air Quality
Agency Contact: Chad Gilgen, Minor Source Compliance
Telephone: [phone]
Email: [e-mail]

Testing Company Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Beckie Hawkins Austin Tramell
Title: District Manager Field Project Manager
Telephone: [phone]
Email: [e-mail] [e-mail]
Table 1-3 details the roles and responsibilities of the test team.
Table 1-3
Test Personnel and Responsibilities
Role Primary Assignment Additional Responsibilities
District Manager Coordinate Project Post-test follow up
Field Project Manager Operate mobile lab Facility interface, test crew coordination
Field Technician Execute stack platform
responsibilities Preparation, support PM

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2.0 Plant and Sampling Location Descriptions
2.1 Process Description, Operation, and Control
Equipment
Asphaltic concrete paving is a mixture of well graded, high-quality aggregate and
liquid asphaltic cement which is heated and mixed in measured quantities to produce
bituminous pavement material. Aggregate constitutes 92 weight percent of the total
mixture. Aside from the amount and grade of asphalt used, mix characteristics are
determined by the relative amounts and types of aggregate used. A certain
percentage of fine aggregate (% less than 74 micrometers in physical diameter) is
required to produce good quality asphaltic concrete.
The drum mix process simplifies the conventional process by using proportioning
feed controls in place of hot aggregate storage bins, vibration screens, and the
mixer. Aggregate is introduced near the burner end of the revolving drum mixer,
and the asphalt is injected midway along the drum. A variable flow asphalt pump is
linked electronically to the aggregate belt scales to control mix specifications. The
hot mix is discharged from the revolving drum mixer into surge bins or storage bins.
Emissions from the asphalt drum mixer are vented to a baghouse before being emitted to
the atmosphere. The pressure drop across the baghouse will be maintained between 2 and
6 inches of water column. The estimated removal efficiency for the baghouse is 99+ percent
for total suspended particulate material (and PM10).
The Gencor 400 TPH Drum Mix HMA is limited to 728,000 tons of aphalt production per
rolling 12-month period and 5,600 tons of asphalt per day. The static differential pressure
across the baghouse must be maintained between 2.0 to 5.0 inches of water column on the
pressure gauge.
2.2 Flue Gas Sampling Location
Actual stack measurements, number of traverse points, and location of traverse points will
be evaluated in the field as part of the test program. Table 2-1 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
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Table 2-1
Sampling Location
Sampling
Location
Stack Inside
Diameter
(in.)
Distance from Nearest Disturbance
Number of Traverse
Points
Downstream EPA
“B” (in./dia.)
Upstream EPA
“A” (in./dia.)
Gencor 400
TPH Drum Mix
HMA
42 84.0/2 24.0/0.50
Isokinetic: 24 (12/port)
Flow: 24 (12/port)
Gaseous: Single point or
3-point short line
The sample location is verified in the field to conform to EPA Method 1. Acceptable cyclonic
flow conditions are confirmed prior to testing using EPA Method 1, Section 11.4.
2.3 Operating Conditions and Process Data
Emission tests are performed while the source and air pollution control devices are
operating at the conditions required by the permit. As per UDEQ AO DAQE-AN128940010-
19, “…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. In all cases, when testing for PM10 emissions during manufacture of
recycled asphalt, recycled asphalt shall be introduced into the plant at a rate no less than
15% of the plant production (i.e., if the plant is producing 300 tons per hour of finished
product, then asphalt to be recycled shall be introduced into the plant at a rate no less than
45 TPH).”
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters:
x Asphalt production rate, in tons per hour, at least once every 15 minutes.
x The RAP percentage usage, at least once every 15 minutes.
x The type of fuel combusted in the asphalt drum mixer.
x The applicable emissions control device operating parameters at least once
every 15 minutes, including, at a minimum, baghouse pressure drop, typically
measured in inches of water (“ H2O).
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2.4 Plant Safety
Montrose will comply with all safety requirements at the facility. The facility Client Sponsor,
or designated point of contact, is responsible for ensuring routine compliance with plant
entry, health, and safety requirements. The Client Sponsor has the authority to impose or
waive facility restrictions. The Montrose test team leader has the authority to negotiate any
deviations from the facility restrictions with the Client Sponsor. Any deviations must be
documented.
2.4.1 Safety Responsibilities
Planning
x Montrose must complete a field review with the Client Sponsor prior to the
project date. The purpose of the review is to develop a scope of work that
identifies the conditions, equipment, methods, and physical locations that will
be utilized along with any policies or procedures that will affect our work.
x We must reach an agreement on the proper use of client emergency services
and ensure that proper response personnel are available, as needed.
x The potential for chemical exposure and actions to be taken in case of
exposure must be communicated to Montrose. This information must include
expected concentrations of the chemicals and the equipment used to identify
the substances.
x Montrose will provide a list of equipment being brought to the site, if required
by the client.
Project Day
x Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate.
x Our team will meet daily to review the Project Scope, Job Hazard Assessment,
and Work Permits. The Client Sponsor and Operations Team are invited to
participate.
x Montrose will provide equipment that can interface with the client utilities
previously identified in the planning phase and only work with equipment that
our client has made ready and prepared for connection.
x We will follow client direction regarding driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area.
x As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the
following provisions at each sample location:
o Sampling ports, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tight.
o Safe sampling platforms.
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o Safe access to the platforms and test ports, including any scaffolding or
man lifts.
o Sufficient utilities to perform all necessary testing.
x Montrose will use the client communication system, as directed, in case of
plant or project emergency.
x Any adverse conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
x Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site.
x Montrose will clean up our work area to the same condition as it was prior to
our arrival.
x We will ensure that all utilities, connection points or equipment have been
returned to the pre-project condition or as stated in the safe work permit. In
addition, we will walk out the job completion with Operations and the Client
Sponsor if required by the facility.
2.4.2 Safety Program and Requirements
Montrose has a comprehensive health and safety program that satisfies State and Federal
OSHA requirements. The program includes an Illness and Injury Prevention Program, site-
specific safety meetings, and training in safety awareness and procedures. The basic
elements include:
x All regulatory required policies/procedures and training for OSHA, EPA and
FMCSA
x Medical monitoring, as necessary
x Use of Personal Protective Equipment (PPE) and chemical detection equipment
x Hazard communication
x Pre-test and daily toolbox meetings
x Continued evaluation of work and potential hazards
x Near-miss and incident reporting procedures as required by Montrose and the
Client
Montrose will provide standard PPE to employees. The PPE will include but is not limited to;
hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand
protections, and fall protection. In addition, our trailers are equipped with four gas detectors
to ensure that workspace has no unexpected equipment leaks or other ambient hazards.
The detailed Site Safety Plan for this project is attached to this test plan in Appendix “S”.
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3.0 Sampling and Analytical Procedures
3.1 Test Methods
The test methods for this test program have been presented in Table 1-1. Additional
information regarding specific applications or modifications to standard procedures is
presented below.
3.1.1 EPA Method 1, Sample and Velocity Traverses for Stationary
Sources
EPA Method 1 is used to assure that representative measurements of volumetric flow rate
are obtained by dividing the cross-section of the stack or duct into equal areas, and then
locating a traverse point within each of the equal areas. Acceptable sample locations must
be located at least two stack or duct equivalent diameters downstream from a flow
disturbance and one-half equivalent diameter upstream from a flow disturbance.
3.1.2 EPA Method 2, Determination of Stack Gas Velocity and
Volumetric Flow Rate (Type S Pitot Tube)
EPA Method 2 is used to measure the gas velocity using an S-type pitot tube connected to a
pressure measurement device, and to measure the gas temperature using a calibrated
thermocouple connected to a thermocouple indicator. Typically, Type S (Stausscheibe) pitot
tubes conforming to the geometric specifications in the test method are used, along with an
inclined manometer. The measurements are made at traverse points specified by EPA
Method 1. The molecular weight of the gas stream is determined from independent
measurements of O2, CO2, and moisture. The stack gas volumetric flow rate is calculated
using the measured average velocity head, the area of the duct at the measurement plane,
the measured average temperature, the measured duct static pressure, the molecular
weight of the gas stream, and the measured moisture.
Pertinent information regarding the performance of the method is presented below:
x S-type pitot tube coefficient is 0.84.
x Shortridge multimeter may be used to measure velocity.
The typical sampling system is detailed as part of the EPA Method 5/202 sampling train in
Figure 3-1.
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2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah
3.1.3 EPA Method 3, Gas Analysis for the Determination of Dry
Molecular Weight
EPA Method 3 is used to calculate the dry molecular weight of the stack gas by measuring
the percent O2 and CO2 in the gas stream. A gas sample is extracted from the stack by one
of the following methods: (1) single-point, grab sampling; (2) single-point, integrated
sampling; or (3) multi-point, integrated sampling. The gas sample is analyzed for percent
CO2 and percent O2 using either an Orsat or a Fyrite analyzer.
Pertinent information regarding the performance of the method is presented below:
x Method Options:
o A Fyrite-type combustion gas analyzer is used to measure the analyte
concentrations
o An Orsat analyzer is used to measure the analyte concentrations
o Single-point grab sampling is performed
o Single-point integrated sampling is performed
o Less than 28 L (1.0 ft3) is collected
o Multi-point integrated sampling is performed
x Target and/or Minimum Required Sample Duration: 60 minutes
x Target and/or Minimum Recommended Sample Volume: 1.0 ft3
x Target Analytes: O2 and CO2
3.1.4 EPA Method 4, Determination of Moisture Content in Stack
Gas
EPA Method 4 is a manual method used to measure the moisture content of gas streams.
Gas is sampled at a constant sampling rate through a probe and impinger train. Moisture is
removed using a series of pre-weighed impingers containing methodology-specific liquids
and silica gel immersed in an ice water bath. The impingers are weighed after each run to
determine the percent moisture.
Pertinent information regarding the performance of the method is presented below:
x Condensed water is measured gravimetrically
x Moisture sampling is performed as part of the EPA Method 5/202 sample trains
x Since it is theoretically impossible for measured moisture to be higher than
psychrometric moisture, the psychrometric moisture is also calculated, and the lower
moisture value is used in the calculations
x Target Sample Duration: 60 minutes
x Minimum Required Sample Volume: 31.8 scf
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As the EPA Method 5/202 sampling train will be used to collect moisture, sampling will not
be constant; rather, sampling will be isokinetic as per the criteria set forth in EPA Methods
5/202.
The typical sampling system is detailed as part of the EPA Method 5/202 sampling train in
Figure 3-1.
3.1.5 EPA Methods 5 and 202, Determination of Particulate Matter
from Stationary Sources and Dry Impinger Method for
Determining Condensable Particulate Emissions from
Stationary Sources
EPA Methods 5 and 202 are manual, isokinetic methods used to measure FPM and CPM
emissions. The methods are performed in conjunction with EPA Methods 1, 2, 3, and 4. The
stack gas is sampled through a nozzle, probe, heated filter, unheated CPM filter, condenser,
and impinger train. FPM is collected from the probe and heater filter. CPM is collected from
the unheated CPM filter and the impinger train. The samples are analyzed gravimetrically.
The sum of FPM and CPM represents TPM. The FPM, CPM, and TPM results are reported in
emission concentration and emission rate units. Pertinent information regarding the
performance of the method is presented below:
x Glass sample nozzles and probe liners are used.
x Condensed water is measured gravimetrically.
x As an alternative to baking glassware, a field train proof blank sample may be
recovered.
x If no water is collected before the CPM filter, the post-test nitrogen purge will be
omitted.
x The post-test nitrogen purge may be performed using the sampling system meter
box and vacuum pump.
x The post-test nitrogen purge may be performed by passing nitrogen through the
train under pressure.
x Method 5/202 total PM results will be used to demonstrate compliance with the
individual PM and PM10 emission limits.
x Target Sample Duration: 60 minutes
x Minimum Required Sample Volume: 31.8 dscf (0.90 dscm)
x Method Options:
o EPA Approved Alternative Method 009 (ALT-009) is used as an alternative to
a two-point post-test meter box calibration. This procedure uses a calculation
to check the meter box calibration factor rather than requiring a physical
post-test meter box calibration using a standard dry gas meter. The average
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calculated meter box percent (%) error must result in a percent error within
±5% of Y. If not, a full calibration is performed, and the results are presented
using the Y factor that yields the highest emissions.
The typical sampling system is detailed in Figure 3-1.
Figure 3-1
EPA Methods 5/202 Sampling Train
3.1.6 EPA Method 9, Visual Determination of the Opacity of
Emissions
EPA Method 9 is used to observe the visual opacity of emissions (opacity). The observer
stands at a distance sufficient to provide a clear view of the emissions with the sun oriented
in the 140° sector to their back. The line of vision is perpendicular to the plume direction
and does not include more than one plume diameter. Observations are recorded at 15-
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second intervals and are made to the nearest 5% opacity. The qualified observer is certified
according to the requirements of EPA Method 9, section 3.1.
x Observations are attempted to be made during each concurrent particulate run,
unless weather conditions are unfavorable.
x Total Observation Period Duration: 6 minutes (40 CFR Part 60, Subpart I)
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2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah
4.0 Quality Assurance and Reporting
4.1 QA Audits
Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality
assurance audits are performed as part of the test program to ensure that the results are
calculated using the highest quality data available. This program ensures that the emissions
data we report are as accurate as possible. The procedures included in the cited reference
methods are followed during preparation, sampling, calibration, and analysis. Montrose is
responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose
will also perform the sampling, sample recovery, storage, and shipping. Approved contract
laboratories may perform some of the preparation and sample analyses, as needed.
4.2 Quality Control Procedures
Montrose calibrates and maintains equipment as required by the methods performed and
applicable regulatory guidance. Montrose follows internal procedures to prevent the use of
malfunctioning or inoperable equipment in test programs. All equipment is operated by
trained personnel. Any incidence of nonconforming work encountered during testing is
reported and addressed through the corrective action system.
4.2.1 Equipment Inspection and Maintenance
Each piece of field equipment that requires calibration is assigned a unique identification
number to allow tracking of its calibration history. All field equipment is visually inspected
prior to testing and includes pre-test calibration checks as required by the test method or
regulatory agency.
4.2.2 Audit Samples
When required by the test method and available, Montrose obtains EPA TNI SSAS audit
samples from an accredited provider for analysis along with the samples. Currently, the
SSAS program has been suspended pending the availability of a second accredited audit
sample provider. If the program is reinstated, the audit samples will be ordered. If required
as part of the test program, the audit samples are stored, shipped, and analyzed along with
the emissions samples collected during the test program. The audit sample results are
reported along with the emissions sample results.
4.3 Data Analysis and Validation
Montrose converts the raw field, laboratory, and process data to reporting units consistent
with the permit or subpart. Calculations are made using proprietary computer spreadsheets
or data acquisition systems. One run of each test method is also verified using a separate
example calculation. The example calculations are checked against the spreadsheet results
and are included in the final report. The “Standard Conditions” for this project are 29.92
inches of mercury and 68 °F.
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4.4 Sample Identification and Custody
The on-site Field Project Manager will assume or assign the role of sample and data
custodian until relinquishing custody. The sample custodian will follow proper custody
procedures before departing from the test site including:
x Assign the unique sample identification number to each sample.
x Attach sample labels and integrity seals to all samples.
x Complete COC form(s), ensuring that the sample identification numbers on
the samples match the sample identification numbers on the COC.
x Pack and store samples in accordance with the test method requirements in
appropriate transport containers for protection from breakage, contamination,
or loss.
x Keep samples in a secure locked area if not in the direct presence of Montrose
staff.
The sample custodian will follow proper custody procedures upon arriving at the Montrose
office including:
x Remove samples and COC documents from vehicles and check into
designated secure sample holding areas.
x Store samples requiring additional measures such as refrigeration or dry ice
appropriately.
4.5 Quality Statement
Montrose is qualified to conduct this test program and has established a quality
management system that led to accreditation with ASTM Standard D7036-04 (Standard
Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual
functional assessments for conformance with D7036-04 which are conducted by the
American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose
is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04
Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the
documented limits in the test methods are met by using approved test protocols for each
project as defined in D7036-04 Sections 7.2.1 and 12.10. Additional quality assurance
information is included in the appendices. The content of this test plan is modeled after the
EPA Emission Measurement Center Guideline Document (GD-042).
4.6 Reporting
Montrose will prepare a final report to present the test data, calculations/equations,
descriptions, and results. Prior to release by Montrose, each report is reviewed and certified
by the project manager and their supervisor, or a peer. Source test reports will be
submitted to the facility or appropriate regulatory agency (upon customer approval) within
30 days of the completion of the field work. The report will include a series of appendices to
19 of 61 GP081AS-046104-PP-917
Staker Parson, Huntington Asphalt and Aggregate Pit
2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah
present copies of the intermediate calculations and example calculations, raw field data,
laboratory analysis data, process data, and equipment calibration data.
4.6.1 Example Report Format
The report is divided into various sections describing the different aspects of the source
testing program. Figure 4-1 presents a typical Table of Contents for the final report.
Figure 4-1
Typical Report Format
Cover Page
Certification of Report
Table of Contents
Section
1.0 Introduction
2.0 Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
4.0 Test Discussion and Results
5.0 Internal QA/QC Activities
Appendices
A Field Data and Calculations
B Facility Process Data
C Laboratory Analysis Data
D Quality Assurance/Quality Control
E Regulatory Information
4.6.2 Example Presentation of Test Results
Table 4-1 presents the typical tabular format that is used to summarize the results in the
final source test report. Separate tables will outline the results for each target analyte and
compare them to their respective emissions limits.
20 of 61 GP081AS-046104-PP-917
Staker Parson, Huntington Asphalt and Aggregate Pit
2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah
Table 4-1
Example Emissions Results -
Gencor 400 TPH HMA Plant, Huntington, Utah
Parameter/Units Run 1 Run 2 Run 3 Average
Date XX XX XX
Time XX XX XX
Process Data
Throughput, ton/hr XX XX XX XX
Hot Mix Temperature, °F
Baghouse Static Pressure, “ H2O XX XX XX XX
Sampling & Flue Gas Parameters
O2, % volume dry XX XX XX XX
CO2, % volume dry XX XX XX XX
flue gas temperature, °F XX XX XX XX
moisture content, % volume XX XX XX XX
volumetric flow rate, dscfm XX XX XX XX
PM/PM10
Concentration, gr/dscf XX XX XX XX
Emission rate, lb/hr XX XX XX XX
Opacity of Emissions Results
Opacity, %XX XX XX XX
21 of 61 GP081AS-046104-PP-917
Staker Parson, Huntington Asphalt and Aggregate Pit
2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah
Appendix A
Supporting Information
22 of 61 GP081AS-046104-PP-917
Staker Parson, Huntington Asphalt and Aggregate Pit
2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah
Appendix A.1
Units and Abbreviations
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30 of 61 GP081AS-046104-PP-917
Staker Parson, Huntington Asphalt and Aggregate Pit
2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah
Appendix A.2
Accreditation Information/Certifications
31 of 61 GP081AS-046104-PP-917
Accredited Air Emission Testing Body
A2LA has accredited
MONTROSE AIR QUALITY SERVICES
In recognition of the successful completion of the joint A2LA and Stack Testing Accreditation Council (STAC)
evaluation process, this laboratory is accredited to perform testing activities in compliance with
ASTM D7036:2004 - Standard Practice for Competence of Air Emission Testing Bodies.
Presented this 27th day of February 2024.
_______________________
Vice President, Accreditation Services
For the Accreditation Council
Certificate Number 3925.01
Valid to February 28, 2026
This accreditation program is not included under the A2LA ILAC Mutual Recognition Arrangement.
American Association for Laboratory Accreditation
32 of 61 GP081AS-046104-PP-917
Staker Parson, Huntington Asphalt and Aggregate Pit
2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah
Appendix A.3
AO DAQE-AN128940010-19
33 of 61 GP081AS-046104-PP-917

DAQE-AN128940010-19

March 14, 2019

Nakeasha Scovill
Nielson Construction Company
825 North Loop Road
P.O. Box 620
Huntington, UT 84528

Dear Ms. Scovill:

Re: Approval Order: Modification to Approval Order DAQE-AN128940008-12 Dated July 13, 2012
to Update Equipment
Project Number: N12894-0010

The attached document is the Approval Order for the above-referenced project. Future correspondence
on this Approval Order should include the engineer's name as well as the DAQE number as shown on the
upper right-hand corner of this letter. The project engineer for this action is Sarah Foran, who may be
reached at [phone].

Sincerely,

Signed by Bryce C. Bird on March 14, 2019

Bryce C. Bird
Director

BCB:SF:sa

cc: Southeastern Utah District Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

GARY R. HERBERT
Governor

SPENCER J. COX
Lieutenant Governor

Department of
Environmental Quality

Alan Matheson
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director
34 of 61 GP081AS-046104-PP-917

STATE OF UTAH

Department of Environmental Quality

Division of Air Quality

APPROVAL ORDER: Modification to Approval Order
DAQE-AN128940008-12 Dated July 13, 2012
to Update Equipment

Prepared By: Sarah Foran, Engineer
Phone: [phone]
Email: [e-mail]

APPROVAL ORDER NUMBER

DAQE-AN128940010-19

Date: March 14, 2019

Nielson Construction Company
Huntington Asphalt and Aggregate Pit
Source Contact:
Nakeasha Scovill
Phone: [phone]
Email: [e-mail]

Signed by Bryce C. Bird on March 14, 2019

Bryce C. Bird
Director

35 of 61 GP081AS-046104-PP-917

Abstract

Nielson Construction Company has requested a modification to AO DAQE-AN128940008-12 dated July
13, 2012, to update on-site equipment, equipment use, and the name of the site. Existing production
limits are not changing. The existing generator use was reduced to emergency use only.

The site is located in Emery County. Emery County is an attainment area of the NAAQS for all
pollutants. NSPS 40 CFR 60 Subpart A, Subpart I, Subpart OOO, Subpart IIII; and MACT 40 CFR 63
Subpart A, and Subpart ZZZZ regulations apply to this source. NESHAP 40 CFR 61 regulations do not
apply to this source. Title V of the 1990 CAA applies to this source, and this source is considered a Title
V area source.

The PTE, in TPY, will change as follows: PM10 = +1.57, PM2.5= -0.47, NOx = -6.97, SO2 = -0.07,
CO = -1.08, VOC = +0.31, HAPs = +0.87, GHG = +854.

The PTE, in TPY, will be: PM10 = 27.93, PM2.5 = 10.85, NOx = 20.47, SO2 = 21.12, CO = 48.84,
VOC = 18.07, HAPs = 4.86, CO2e = 13,304.

This air quality AO authorizes the project with the following conditions and failure to comply with any of
the conditions may constitute a violation of this order. This AO is issued to, and applies to the following:

Name of Permittee:
Nielson Construction Company
825 North Loop Road
P.O. Box 620
Huntington, UT 84528
Permitted Location:
Huntington Asphalt and Aggregate Pit
About 2 miles North and West
of Huntington on Highway 31
Emery County, UT

UTM coordinates: 499,460 m Easting, 4,356,380 m Northing, UTM Zone 12
UTM Datum: NAD83
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 (2)-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 start-up, 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

36 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 3

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]

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]

Section II: SPECIAL PROVISIONS

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

II.A.1 Huntington Pit

II.A.2 One (1) Gencor Drum Mix Asphalt Plant
Rated Capacity: 400 tons per hour (TPH)
Control Device: Baghouse
NSPS Applicability: Subpart I

II.A.3 One (1) Gencor Baghouse
Type: Reverse Air
Maximum Flow Rate: 89,217 ACFM
Average Flow Rate: 49,133 ACFM
NSPS Applicability: Subpart I

II.A.4 Two (2) Asphalt Storage Silos
Capacity: 150 Tons Each

II.A.5 Liquid Asphalt Storage Tanks*
One (1) Tank
Capacity: 30,000 Gallons

One (1) Split tank
Capacity: 10,000 and 20,000 Gallons
NSPS Applicability: Subpart I

II.A.6 Hot Oil Heater
Rating: 1.4 MMBtu/hr
Fuel: Waste Oil
NSPS Applicability: Subpart I

II.A.7 One (1) 4-Bin Feeder*
Capacity: 400 TPH
NSPS Applicability: Subpart OOO

II.A.8 One (1) 2-Bin Feeder*
Capacity: 400 TPH
NSPS Applicability: Subpart OOO
37 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 4

II.A.9 One (1) Lime Silo*
Capacity: 45 Tons
Control: Bin Vent
NSPS Applicability: Subpart I

II.A.10 2-Bin RAP Feeder*
Capacity: 400 TPH
NSPS Applicability: Subpart OOO

II.A.11 Fly Ash Silo*
Capacity: 150 Tons
Control: Bin Vent
NSPS Applicability: Subpart I

II.A.12 One (1) Jaw Crusher*
Capacity: 500 TPH
NSPS Applicability: Subpart OOO

II.A.13 Three (3) Cone Crushers*
Capacity: 400 TPH
NSPS Applicability: Subpart OOO

II.A.14 Five (5) Triple-deck Screens*
Size: 8' X 20' Each
NSPS Applicability: Subpart OOO

II.A.15 One (1) Scalper Screen*
Size: 5' x 12' Each
NSPS Applicability: Subpart OOO

II.A.16 One (1) Hopper*
Capacity: 400 TPH
NSPS Applicability: Subpart OOO

II.A.17 Two (2) Impact Crushers*
Capacity: 400 TPH
NSPS Applicability: Subpart OOO

II.A.18 Associated Equipment
Both aggregate and asphalt production equipment include:
conveyors, drag elevator, weigh conveyors, stackers, loaders, and dozer, haul and water
trucks

II.A.19 One (1) Emergency Generator
Rating: 800 kW
Fuel: Diesel
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

*Indicates new equipment

38 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 5

II.B Requirements and Limitations

II.B.1 Site-wide Requirements

II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions
from any installation of this AO to exceed 20% opacity. [R307-201-3]

II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary
sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.2 HMA Plant Requirements:

II.B.2.a The owner/operator shall not produce more than 728,000 tons of asphalt per rolling 12-month
period, and 5,600 tons of asphalt per day. [R307-401-8]

II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 20th 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. [R307-401-8]

II.B.2.a.2 The owner/operator shall weigh and account for all hot mix asphalt prior to the hot mix asphalt
leaving the site. [R307-401-8]

II.B.2.b The owner/operator shall only operate the asphalt plant for 16 hours per day from March
through November. The owner/operator shall not operate the asphalt plant from December
through February. [R307-401-8]

II.B.2.b.1 Hours of operation shall be determined by supervisor monitoring and maintaining of an
operations log. The records of operation shall be kept on a daily basis and shall include the
time the asphalt plant starts operation, the time the asphalt plant ceases operation, and the total
hours of operation for the day. [R307-401-8]

II.B.2.c The owner/operator shall use a baghouse to control particulate emissions from the hot mix
asphalt plant. All exhaust air from the drum mixer shall be routed through the baghouse
before being vented to the atmosphere. [R307-401-8]

II.B.2.c.1 The owner/operator shall maintain the static pressure differential across the baghouse between
2.0 to 5.0 inches of water column on the pressure gauge. [R307-401-8]

II.B.2.c.2 The pressure gauge shall be located such that an inspector/operator can safely read the
indicator at any time. The pressure gauge shall measure the pressure drop in one (1)-inch
water column increments or less. The pressure gauge shall be calibrated according to the
manufacturer's instructions at least once every 12 months. [R307-401-8]

II.B.2.d The owner/operator shall not allow visible emissions from the baghouse on site to exceed 10%
opacity. [R307-401-8]

39 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 6

II.B.2.e Emissions to the atmosphere from the indicated emission point shall not exceed the following
rates and concentrations:

Source: Gencor 400 TPH Hot Mix Asphalt Plant Baghouse Exhaust Stack

Pollutant lb/hr grain/dscf
(68oF, 29.92 in Hg)

TSP (virgin & RAP) 10.07 0.020
PM10 (virgin & RAP) 8.05 0.016

[R307-401-8]

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:

Emission Point: Hot Mix Asphalt Plant Baghouse Exhaust Stack

TSP (virgin & RAP): Initial Test Completed: 9/21/2011

PM10 (virgin & RAP): Test every five (5) 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. 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. A pretest conference shall be held, if directed by
the Director. The pretest conference shall include representation from the owner/operator, the
tester, and the Director.

[R307-165]

II.B.2.e.3 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.

[R307-401-8]

II.B.2.e.4 Volumetric Flow Rate:

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

[R307-401-8]
40 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 7

II.B.2.e.5 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 condensables 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
condensables 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 Appendix B of the
fifth addition of AP-42 or other data acceptable to the Director.

The back half condensables shall not be used for compliance demonstration but shall be used
for inventory purposes.

[R307-401-8]

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.

[R307-401-8]

II.B.2.e.7 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.

In all cases, when testing for PM10 emissions during manufacture of recycled asphalt, recycled
asphalt shall be introduced into the plant at a rate no less than 15% of the plant production (i.e.
if the plant is producing 300 tons per hour of finished product, then asphalt to be recycled shall
be introduced into the plant at a rate no less than 45 TPH).

[R307-401-8]

II.B.3 Aggregate Pit Requirements:

II.B.3.a The owner/operator shall not produce more than 624,000 tons of processed aggregate material
and processed rotomill material combined per rolling 12-month period. [R307-401-8]

II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 20th 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. [R307-401-8]

II.B.3.a.2 The owner/operator shall weigh and account for all aggregate material prior to the aggregate
material leaving the site. [R307-401-8]

41 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 8

II.B.3.b The owner/operator shall not operate the Aggregate Plant (including haul road use and storage
pile loading or unloading) more than the allotted times for the following months:

A. March through October: 16 hours per day

B. November: 12 hours per day

C. December through February: 8 hours per day

[R307-401-8]

II.B.3.b.1 Hours of operation shall be determined by supervisor monitoring and maintaining of an
operations log. The records of operation shall be kept on a daily basis and shall include the
time the aggregate processing plant starts operation, the time the aggregate processing plant
ceases operation, and the total hours of operation for the day. [R307-401-8]

II.B.3.c The owner/operator shall not allow visible emissions to exceed the following:

A. Crushers - 12%

B. Screens - 7%

C. Conveyors - 7%

[40 CFR 60 Subpart OOO, R307-401-8]

II.B.3.d The owner/operator shall install water sprays on all crushers, all screens, all conveyor transfer
points, and all conveyor drop points at each location to control emissions. Sprays shall operate
as required to ensure the opacity limits in this AO are not exceeded. [R307-401-8]

II.B.3.e The owner/operator shall perform monthly periodic inspections to check that water is flowing
to discharge spray nozzles associated with each crusher, screen, and conveyor. If the owner/
operator finds that water is not flowing properly during an inspection of the water spray
nozzles, the owner/operator shall initiate corrective action within 24 hours and complete
corrective action as expediently as practical. [R307-401-8]

II.B.3.e.1 Records of the water sprays inspections shall be kept and maintained in a logbook for all
periods when the plant is in operation. The records shall include the following items:

A. Date the inspections were made

B. Any corrective actions taken

C. Control mechanism used if sprays are not operating

[40 CFR 60 Subpart OOO, R307-401-8]

II.B.3.f The owner/operator shall conduct an initial performance test for all crushers, screens, and
conveyor transfer points on site within 60 days after achieving the maximum production rate
but not later than 180 days after initial start-up. Performance tests shall meet the limitations
specified in Table 3 to Subpart OOO. Records of initial performance tests shall be kept and
maintained on site for the life of the equipment. [40 CFR 60 Subpart OOO, R307-401-8]

42 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 9

II.B.3.f.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner or operator may use methods and procedures specified in 40 CFR
60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR
60.675(c). [40 CFR 60 Subpart OOO, R307-401-8]

II.B.3.f.2 The owner/operator shall submit written reports to the Director of the results of all
performance tests conducted to demonstrate compliance with the standards set forth in 40 CFR
60.672. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.4 Emergency Generator Engine Requirements:

II.B.4.a The owner/operator shall not operate the emergency engine on site for more than 100 hours
per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 20th day of each month using data from the previous 12 months.
Records documenting the operation of the emergency engine shall be kept in a log and shall
include the following:

A. The date the emergency engine was used

B. The duration of operation in hours

C. The reason for the emergency engine usage

[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter on the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.5 All Haul Roads and Fugitive Dust Sources Requirements:

II.B.5.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources
on site to exceed 20% opacity at all times. [R307-205-4]

II.B.5.a.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 (6)-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. [R307-205-4]

II.B.5.b The owner/operator shall comply with the following to maintain the opacities listed in this
AO:
A. Paved Haul Roads: Sweep and flush with water.

B. Unpaved Haul Roads and Operational Areas: Apply water applications and cover
with road-base material.

The owner/operator may stop applying water to haul roads and operational areas when the
temperature is below freezing and may stop sweeping the paved haul roads when the haul
roads are covered with snow or ice.

[R307-401-8]

43 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 10

II.B.5.b.1 Records of sweeping and water application to all roads shall be kept for all periods when the
plant is in operation. The records shall include the following items:

A. Date and time treatments were made

B. Number of treatments made and quantity of water applied

C. Rainfall amount received, if any

D. Records of temperature, if the temperature is below freezing

E. Records shall note if the paved haul roads are covered with snow or ice.

[R307-401-8]

II.B.5.c The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive
Emission and Fugitive Dust sources on site. [R307-205]

II.B.6 Fuel Requirements:

II.B.6.a The owner/operator shall use natural gas, propane, fuel oil, on-specification used oil as defined
in R315-15, or any combination thereof as fuel in the hot mix asphalt plants. [R307-401-8]

II.B.6.b The sulfur content of any used fuel oil, fuel oil or diesel burned in the asphalt plant shall not
exceed 0.5 percent by weight. The sulfur content of any diesel fuel consumed in any
stationary engine on site shall not exceed 15 ppm. [R307-401-8, 40 CFR 63 Subpart ZZZZ,
R307-401-8]

II.B.6.b.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved
equivalent. Certification of used oil or diesel fuel shall be either by the owner/operator's own
testing or by test reports from the diesel fuel marketer. [R307-401-8]

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), A: General Provisions
NSPS (Part 60), I: Standards of Performance for Hot Mix Asphalt Facilities
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: NESHAP for Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

44 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 11
PERMIT HISTORY

This AO is based on the following documents:

Supersedes AO DAQE-AN128940008-12 dated July 13, 2012
Is Derived From NOI dated August 8, 2018
Incorporates Additional information dated September 11, 2018
Incorporates Additional Information dated September 26, 2018
Incorporates Additional Information dated November 5, 2018
Incorporates Additional Information dated January 3, 2019

ADMINISTRATIVE CODING

The following information is for UDAQ internal classification use only:

Emery County
CDS B
MACT (Part 63), Title V (Part 70) Area Source, Attainment Area, NSPS (Part 60)
45 of 61 GP081AS-046104-PP-917
DAQE-AN128940010-19
Page 12
ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

46 of 61 GP081AS-046104-PP-917
Staker Parson, Huntington Asphalt and Aggregate Pit
2024 Compliance Source Test Plan, Gencor 400 TPH Drum Mix HMA Plant, Near Huntington, Utah
Appendix “S”
Field Work Safety Plan
47 of 61 GP081AS-046104-PP-917
SITE SAFETY PLAN BOOKLET
Project: _____________________
Customer: ___________________
Location: ____________________
Units: _______________________
Client Project Manager: ______________________
Revision Date:June 29th, 2023
48 of 61 GP081AS-046104-PP-917
PROJ-046061
Mountain Cement Co.
Laramie, Wyoming
Kiln 1 & Kiln 2 PM, VEs and D/Fs
Jeff Goldfine/Chris Wall
Page 1 of 2

Site Safety Plan and JHA Purpose and Instructions

Purpose
Employee safety is the top priority of Montrose Environmental Group. All employees must be
trained to assess and mitigate hazards. The District Manager and Project Manager are
responsible to ensure all hazards have been properly identified and managed. All employees
have Stop Work Authority in all situations where an employee feels they or their co-worker
cannot perform a job safely or if there is a task for which they have not been adequately trained.
The Site Safety Plan (SSP) has been developed to help assist Montrose test crews with
identifying physical and health hazards and determining how the hazards will be managed.
Additionally, the SSP will help each crew manage the safety of the employees by providing
emergency procedures and information. The booklet contains a several safety forms that may
be required in the field.
Instructions
The SSP consists of the following:

communicated to all employees, signed, and posted.
Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed,
CPM will maintain a roster and be responsible for accounting for all employees. The Job
to work commencing. In the event of an emergency situation/ evacuation, the Job Supervisor/
emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior
the Emergency Action Plan form and ensure that all employees are familiar with the facility
4. Emergency Action Plan -The Job Supervisor/ Client Project Manager (CPM) will complete
observed plus applicable PPE that may be required.
administrative controls that a crew can use to reduce or eliminate the hazards they have
3. Hazard Control Matrix - contains useful information on both engineering and
with the toolbox topic and signatures can be added to the SSP packet.
the hazard analysis is required daily for the duration of the test. An additional sheet of paper
modified when conditions change. A toolbox meeting with a daily topic in addition to a review of
sign on the Job Hazard Analysis form in agreement and sign in Section 10. The JHA is to be
Each team member has the option to discuss making changes or adding to the JHA and must
Section 9 will require at least three tasks, hazards and controls be identified for the project.
form for accuracy, making any corrections required and complete the remainder of the JHA.
complete the JHA form through section 8. Upon arrival at the test site, the team will review the
daily hazard review with sign off by the team.The client Project Manager is responsible to
task/site’s particular hazards and controls. The form also includes a daily toolbox topic and
2. A Job Hazard Analysis is a standardized, two-page, fillable form that is used to evaluated the
prior to the test.
1. A Pre-Mobilization Test Plan – To be completed in it’s entirety by the client project Manager
AQS-FRM-1.13R1
Extended Hours Formc.
Heat Stress Prevention Form Based on Heat Indexb.
MEWP Lift Inspection Forma.
Additional Forms, as applicable5.
49 of 61 GP081AS-046104-PP-917
Page 2 of 2

Site Safety Plan and JHA Purpose and Instructions

The SSP is a living document. The Project Manager should continually update their SSPs as
new information and conditions change or if new hazards are presented.
Each completed SSP should be maintained with the Test Plan in the office for a period of 3
years. There will be an audit process developed for the Site Safety Plans.

AQS-FRM-1.13R1
50 of 61 GP081AS-046104-PP-917
Page 1 of 2
PRE-MOBILIZATION TEST INFORMATION

Source Type: New Source: ____ Revisit: ____ Prj#/Date/Tech: __________________________
Coal Fired Electric Utility: ____ Ethanol Plant: ____ Chemical Mfg. of _________________________
Cement/Lime Kiln Plant: ____ Specialty Mfg. of: ___________ Other: _______________

Anticipated Effluent Composition – check all that apply and fill in expected concentration in ppm/%

CO NOX SO2 VOC other
If other, explain: _______________________________________________________

Flammable: _______ Toxic: ________ Corrosive: _______ Dust: __________
Engineering Controls to be Implemented:
______________________________________________________________________________________
__________________________________________________________________________________
Additional Safety Equipment Required:
Personal gas monitors: ____
Respiratory Protection:
Half Face____ Full Face____ HEPA Filters____ Supplied Air: _____ (Safety Dept. Approval)
Approximate Flue Gas Temperatures, (F)

below 210 210 to 450 450 to 950 above 950 other
If other, explain: _______________________________________________________
Approximate Duct Pressure, (iwg):

below -3 -3 to +3 +3 to +7 above +7 other
If other, explain: _______________________________________________________

PROJECT NAME/LOCATION: ______________________ PROJECT #: ____________________
TEST DATE: ______________________ PROJECT MANAGER: ___________________
TEST SCOPE: _________________________________________________________________
SITE CONTACT: Name: _____________________ Contact Phone: _________________________
AQS-FRM-1.17
51 of 61 GP081AS-046104-PP-917
X PROJ-04061/12-24/JG or CW
X
Mountain Cement Company PROJ-046061
Dec. 9 through 13, 2024 Jeff Goldfine/Chris Wall
PM, VEs, and PCDD/PCDF Testing on two Cement Kiln Exhausts
Aaron Hoese 307-745-2640
Page 2 of 2
PRE-MOBILIZATION TEST INFORMATION

Sampling Location: Stack Port ____ Duct Port ____
Approximate Sampling Platform Height, (ft)

Effluent Chemical Regulatory Limits

Gas Name Chemical
Formula
Cal OSHA PEL1
(ppm)
Cal OSHA
STEL2
(ppm)
NIOSH REL
TWA3 (ppm)
Cal OSHA
Ceiling
(ppm)
IDLH4
(ppm)
Carbon Monoxide CO 25 200 35 200 1,200
Nitric Oxide NOx 25 ND5 25 ND 100
Sulfur Dioxide SO2 2 5 2 ND 100
Hydrogen Chloride HCl 0.3 2 ND 2 50
Hydrogen Sulfide H2S 10 15 10 (10 min.)C 50 100
California Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) based on an 8 -hour shift;
2: Cal OSHA Short-term Exposure Limit (STEL) based on a 15-minute period;
3: National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) Time-weighted Average (TWA) based
on an 8-hour shift;
4: Immediately Dangerous to Life or Health (IDLH);
5: Not Defined (ND);
C: Ceiling Limit - Maximum allowable human exposure limit for an airborne or gaseous substance, which is not to be exceeded, even
momentarily.

Prepared by: Date:
Reviewed by: Date:

______________________________________________________________________________
______________________________________________________________________________
Additional Information:
______________________________________________________________________________
______________________________________________________________________________
Describe how equipment will be mobilized to the sampling location:
Other:_____________________________________________________________________________
Guardrails: ____ Toe plate: ____ Engineered Tie Off Points: ____ Heat Shield: ____
Elevators: ____ Ladders: ____ MEWP Lift: ____ Scaffold: ____ Equipment Hoist: ____
Access and Protection:
If other, explain: _______________________________________________________
below 6 6 to 50 50 to 100 above 100 other
AQS-FRM-1.17
52 of 61 GP081AS-046104-PP-917
X
X
Hoisted or hand carried
Joby Dunmire September 20, 2024
Job Hazard Analysis 1 of 3
1.
Client Rep
Job Preparation
Job Site Walk Through Completed Site Specific Training Complete
Safe Work Permit Received from Client
2.Facility Information/Emergency Preparedness
If non-emergency medical attention is needed, call: AXIOM #: 877-502-9466.
Plant Emergency # Certified First Aid Person:
EMS Location Evacuation Routes Rally Point
Severe Weather Shelter Location Eye Wash & Safety Shower Location
Operational: Yes No
Source Information: (list type):
Stack Gas Temp. (oF)Stack Gas Press. ("H2O)Stack Gas Components:
Stack Gas Inhalation Potential?Yes No If yes, see List of Hazard Chemicals.
3.Error Risk
Time Pressure Remote Work Location > 12 hr shift Working > 8 consecutive days
Lack of procedures Extreme temps, wind >30mph Personal illness/fatigue Vague work guidance
Monotonous Activity First day back after time off Multiple job locations Other:
4.Physical Hazards Hazard Controls
Dust Hazards Dust Mask Goggles Other:
Thermal Burn Hot Gloves Heat Shields Other Protective Clothing:
Electrical Hazards Connections Protected from Elements External GFCI Other:
XP Rating Requirement Intrinsically Safe Requirement
Inadequate Lighting Install Temporary Lighting Headlamps
Slip and Trip Housekeeping Barricade Area Other:
Hand Protection Cut Resistant Gloves Pinch Pts. General Electrical Impact Resistant
Other:
Potential Hazards for Consideration
Secondary Permits Hot Work Confined Space
Excavation
Working from Heights Falling objects Fall protection Drop zone protection Platform load ratings
See also Sect. 7 Scaffold inspection Ladder inspection Barricades for equipment
Electrical Exposed wire/connector Verify equipment grounding Arc Flash
Lifting Crane lift plan Rigging inspection Tag lines used Hoists in place
Respiratory Unexpected exposure Chemical Dust (combustible) PEL provided
See also Sect. 8 Cartridges or supplied air available Gas detection equipment
5.Required PPE Hard Hats Safety Glasses Safety Toe Shoe/Boot Hearing Protection Safety Spotter
Hi-Vis Vests Harness/Lanyard*Goggles Personal Monitor Type:
Metatarsal Guards Hot Gloves Face Shield Respirator Type:
Nomex/FRC Other PPE:
Client Contact Name Date
Facility SSP Writer PM
If the heat index is expected to be above 91°, fill out the Heat Stress Prevention Form.
All hazards and mitigation steps must be documented.
If this JHA does not cover all the hazards identified,
use Section 9 to document that information.
AQS-FRM-1.18
53 of 61 GP081AS-046104-PP-917
Mountain Cement Company Aaron Hoese
December 19, 2024
Laramie, Wyoming
Job Hazard Analysis 2 of 3
Additional Work Place Hazards
6.Critical Procedures – check all that apply – *indicates additional form must be completed or collected from client
Heat Stress Prevention* Confined Space* Roof Work Scaffold
Cold Weather Work Hazardous Energy Control* Other:
7.Working From Heights
Fall Protection Fixed Guardrails/Toe boards Fall Prevention PPE Warning Line System
Falling Objects Protection Barricading Netting House Keeping Tethered Tools Catch Blanket or Tarp
Fall Hazard Communication Adjacent/Overhead Workers Contractor Contact Client Contact
8.Other Considerations
Environmental Hazards - Weather Forecast
Heat/Cold Lightning Rain Snow Ice Tornado Wind Speed
Steps for Mitigation:
Electrical Safety Planning
Plant Hook up:110V 220/240V 480V Generator Hard wired into panel
Electrical Classified Area: Yes No Trailer Grounded: Yes No Plug Type
Electrical Hook Up Responsibility:
List of Hazardous Chemicals Other Chemicals:
Acetone Nitric Acid Hydrogen Peroxide Compressed Gases
Hexane Sulfuric Acid Isopropyl Alcohol Flammable Gas
Toluene Hydrochloric Acid Liquid Nitrogen Non-Flammable Gas
H2S Carbon Monoxide
Steps for Mitigation:
Wildlife/Fauna in Area
Poison Ivy Poison Oak Insects: Wildlife:
Personnel w/ known allergies to bees stings or other allergens?Yes No
9.Observed Hazards and Mitigation Steps
Task Potential Hazard(s) Steps for Mitigation
● 11
22
33
● 11
22
33
● 11
22
33
● 11
22
33
Exposure Monitoring
MEWP*
AQS-FRM-1.18
54 of 61 GP081AS-046104-PP-917
Job Hazard Analysis 3 of 3
10.JHA REVIEW: Crew Names & Signatures
11.Daily JHA Meeting & Review
Items to review:
● Change in conditions ● Extended work hours ● Daily Safety Topic
● New workers or contractors ● Occurrence of near misses or injuries
Printed Name Signature
2
Discussion TopicDay
Initialing demonstrates that site conditions and hazards have not changed from the original SSP. If changes did occur, make the
necessary updates to this JHA and add notes as applicable in Section 9.
Initials
9
8
7
6
3
Date Printed Name Signature Date
5
4
11
10
AQS-FRM-1.18
55 of 61 GP081AS-046104-PP-917
1
2
3
4
5
6 Local Hospital/ Clinic Telephone Number:
7
8
9
10
11
12
13
14
15
16
17
MEG Job Supervisor/ CPM's Telephone Number:
Plant's #1 Contact Person's Name:
Plant's #1 Contact Person's Telephone Number:
MEG Job Safety Supervisor's Telephone Number:
Plant's Emergency Telephone Number:
Emergency Ops Radio Channel:
The Fire Extinguisher is Located:
Eye Wash and Safety Shower Location:
The First Aid Kit is Located:
Page 1 of 2
The Job Supervisor/ Client Project Manager (CPM) will ensure that all employees are familiar with the facility emergency and evacuation
procedures, assembly/ rally points, alert systems, and signals prior to work commencing. In the event of an emergency situation/
evacuation, the Job Supervisor/ CPM will maintain a roster and be responsible for accounting for all employees. The Job Supervisor/
CPM will ensure that this Emergency Action Plan Form is completed, communicated to all employees, and posted.
• You must follow the client’s emergency action plan first, and notify your Supervisor immediately.
•If incident is life threatening, CALL 911 IMMEDIATELLY
• If non-emergency medical attention is needed, call AXIOM Medical number: 877-502-9466.
EMERGENCY ACTION PLAN FORM
MEG Job Supervisor/ CPM's Name:
MEG Job Safety Supervisor (if applicable):
Evacuation Routes:
Severe Weather Shelter Location:
Plant's #2 Contact Person's Name:
Plant's #2 Contact Person's Telephone Number:
Designated Assembly Point Location:
AQS-FRM-1.11
56 of 61 GP081AS-046104-PP-917
1
2
4
5
Signature: Date: Printed Name: Signature: Date:
EVACUATE:____________________________________;
OTHER:_______________________________________;
Alarm Tones:
EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBLY MAP REVIEW: Crew Names and Signatures
Printed Name:
Draw the evacuation and assembly map here
Page 2 of 2
EMERGENCY EVACUATION AND ASSEMBLY MAP
3
Designated Shelter(s) Description:
Designated Assembly Point(s) Description:
YES or NO
Facility Name:
Facility Alarm (Circle):
FIRE:_________________________________________;
CHEMICAL/ GAS:_______________________________;
SHELTER-IN-PLACE:_____________________________;
AQS-FRM-1.11
57 of 61 GP081AS-046104-PP-917

Serial Number:
Make: Rented or Owned:

x Check “Yes” if an item is adequate, operational, and safe.
x Check “No” to indicate that a repair or other corrective action is required prior to use.
x Check “N/A” to indicate “Not Applicable.”
Yes No N/A

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2. Hydraulic fluid level is sufficient, with the platform fully lowered ܆ ܆ ܆
3. Hydraulic system pressure (see manufacturer specs) is acceptable.
If the pressure is low, determine cause and repair in accordance with accepted procedures
as outlined in service manual.
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4. Tires and wheel lug nuts (for tightness) ܆ ܆ ܆
5. Hoses and cables (i.e. worn areas or chafing) ܆ ܆ ܆
6. Platform rails and safety gate (no damage present) ܆ ܆ ܆
7. Pivot pins secure ܆ ܆ ܆
8. Welds are not cracked and structural members are not bent or broken ܆ ܆ ܆
9. Warning and instructional labels are legible and secure, and load capacity is clearly marked. ܆ ܆ ܆
10. Manufacturer’s Instruction Manual is present inside the bucket ܆ ܆ ܆
11. Base controls (switches and push buttons) can be properly operated ܆ ܆ ܆
12. Platform conditions are safe (i.e. not slippery) ܆ ܆ ܆
13. Fire extinguisher is present, mounted and fully charged, located inside the bucket ܆ ܆ ܆
14. Headlights, safety strobe light and back-up alarm are functional ܆ ܆ ܆
15. Workplace is free of hazards (overhead powerlines, obstructions, level surface, high winds,
etc.) *Do not operate if winds are 20 mph, unless otherwise specified by manufacturer
recommendations.
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Operator Name & Signature Location Date

Ground Control Name & Signature Location Date

Harness Inspections:

Printed Name Signature Date

Printed Name Signature Date

Printed Name Signature Date
Daily MEWP Lift Inspection Form
Page 1 of 1
atthe beginning of each shift or following 6 to 8 hours of use.
All checks must be completed prior to each work shift, before operation of the MEWP lift. This checklist must be used
MEWP Lift Model #:
loose hoses, etc.) – if something can be easily loosened by hand then it is not sufficient.
1.All MEWP lift components are in working condition (i.e. no loose or missing parts, torn or
Items to be Inspected
AQS-FRM-1.16
58 of 61 GP081AS-046104-PP-917