DAQ-2024-010965

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DAQC-CI100420002-24
Site ID 10042 (B1)

MEMORANDUM

TO: FILE – STAKER PARSON MATERIALS AND CONSTRUCTION – McGuire Pit

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: October 10, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Box Elder County

INSPECTION DATE: July 31, 2024

SOURCE LOCATION: 8211 South U.S. Highway 89
Willard, UT 84340

DIRECTIONS: Take exit 351 from I-15 north bound. Drive to Highway 89.

SOURCE CONTACTS: Boe Couch, Site Supervisor
385-239-8402

Jeffery Cowlishaw, Environmental Specialist North Wasatch
385-405-4315

OPERATING STATUS: Normal operation.

PROCESS DESCRIPTION: McGuire aggregate pit. Bank material is pushed for processing in
the main circuit. A power screen and jaw crusher operate above
the main plant for specialty processing. The area formerly known
as the "north pit" is no longer operating.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN100420012-23, dated
December 11, 2023
NSPS (Part 60) OOO: Standards of Performance for Nonmetallic
Mineral Processing Plants

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Staker Parson Materials and Construction
McGuire Pit

89 West 13490 South, Suite 100 8211 South U.S. Highway 89
Draper, UT 84020 Willard, UT 84340

SIC Code: 1442: (Construction Sand & Gravel)

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Section I: GENERAL PROVISIONS

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

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

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

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

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

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

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

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

Status: In Compliance. No limits were exceeded based on the inspection observations and
review of the submitted documents. No changes in equipment or processes were found.
Maintenance is appropriate and records are kept as required. No UAC R307-107
applicable breakdowns have occurred. An Emissions Inventory was submitted for the 2023
activity year and is attached to this inspection memo. The notification for the new Astec
Screen was made on October 11, 2023, as part of the NOI process to add the equipment to
the current AO.

Section II: SPECIAL PROVISIONS

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

II.A.1 McGuire Pit
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II.A.2 One (1) Jaw Crusher
Rated Capacity: 500 tph
Manufacturer: Telsmith
Manufacture Date 1997

II.A.3 One (1) 7 x 20 Screen
Rated Capacity: 700 tph
Manufacturer: El Jay
Manufacture Date 1998

II.A.4 One (1) Jaw Crusher
Rated Capacity: 500 tph
Manufacturer: Cedarapids
Manufacture Date 2005

II.A.5 One (1) Cone Crusher
Rated Capacity: 500 tph
Manufacturer: Terex
Manufacture Date 2019

II.A.6 One (1) Cone Crusher
Rated Capacity: 500 tph
Manufacturer: MVP 450
Manufacture Date 1993

II.A.7 Two (2) 8 x 20 Screens
Rated Capacity: 600 tph
Manufacturer: Terex
Manufacture Date 2019

II.A.8 One (1) 8 x 20 Screen - new equipment
Rated Capacity: 600 tph
Manufacturer: ASTEC
Manufacture Date 2023

II.A.9 One (1) 6 x 20 Screen
Rated Capacity: 600 tph
Manufacturer: El Jay
Manufacture Date 1999

II.A.10 One (1) Power Screen
Rated Capacity: 250 tph
Manufacture Date 1992
Fuel: Diesel

II.A.11 Two (2) Diesel Storage Tanks
Rated Capacity: 10,000 Gallons each

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II.A.12 Associated Conveyors & Other Support Equipment

Status: In Compliance. The listed permitted equipment has been installed and is operating
with the exception of II.A.10, the 250 tph diesel-fueled Power Screen which has been
decommissioned since at least 2022. No other equipment was observed at the time of
this inspection.

II.B Requirements and Limitations

II.B.1 The McGuire Pit shall be subject to the following:

II.B.1.a The owner/operator shall not produce more than 2,500,000 tons of aggregate materials per
rolling 12-month period. [R307-401-8]

Status: In Compliance. The reported aggregate production totals for the 12-month rolling
period of July 2023 through June 2024 was reported as 1,325,616.59 tons. See the attached
McGuire rolling 12 spreadsheet.

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall:

A. Determine the aggregate production by sales records of final products shipped
B. Keep the records of production on a daily basis
C. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months
D. Keep records of production for all periods when the plant is in operation. [R307-401-8]

Status: In Compliance. The reported totals are based on scale house weighs for all periods
when the site is in production. The monthly totals are entered into an electronic
spreadsheet and are maintained as required.

II.B.1.b The owner/operator shall not operate the equipment listed in II.A.5 through II.A.9 more than 20
hours per day. [R307-401-8]

II.B.1.b.1 To determine compliance with hours of operations, the owner/operator shall:

A. Determine hours of operations by monitoring and maintaining of an operations log

B. Keep record of hours of operations on a daily basis

C. Keep records of hours of operation for all periods when the plant is in operation.
[R307-401-8]

Status: In Compliance. This facility only operates a single 12-hour shift a day. Operation
logs are kept on site. No changes to employee shifts have happened during the last several
years. A log of total hours operated, per process, for the 12-month period was also
submitted as additional information.

II.B.1.c The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:
A. All crushers - 12% opacity
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B. All screens - 7% opacity
C. All conveyor transfer points - 7% opacity
D. All diesel engines - 20% opacity
E. All conveyor drop points - 20% opacity
F. All storage piles - 10% opacity
G. All other points - 20% opacity. [R307-312-4, 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. [R307-201-3]

Status: In Compliance. No visible dust was observed from either the upper or lower
aggregate processing units during this inspection. The materials were damp and the spray
bars were operating. The observations were done in accordance with Method 9. See the
attached VEO.

II.B.1.d The owner/operator shall install water sprays on all crushers, all screens, all conveyor transfer
points, and all conveyor drop points to control emissions. Sprays shall operate as required to
ensure the opacity limits in this AO are not exceeded. [R307-401-8]

Status: In Compliance. Spray bars were installed and were operating at the appropriate
points.

II.B.1.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. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.1.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]

Status: In Compliance. The paper form daily checklist includes the date of the safety and
equipment function inspection, notations of corrections, and an indication if parts have
been ordered.

II.B.1.f The owner/operator shall conduct an initial performance test for all new crushers, screens, and
conveyor transfer points subject to NSPS Subpart OOO. Performance tests shall meet the
limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO]

II.B.1.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]
II.B.1.f.2 The owner/operator shall keep and maintain records of the initial performance test for each
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crusher, screen, and conveyor for the life of the equipment. The record of the initial performance
test must be made available to the Director or the Director's representative upon request.
[40 CFR 60 Subpart OOO]

Status: In Compliance. Initial NSPS Method 9 observations were performed for the
originally installed aggregate equipment on May 9, 2007. The observations for
Replacement-in-Kind Astec screen were performed in August of 2022. See the inspection
memos DAQC-1131-22 and DAQC-CI100420001-23 for more information.

II.B.2 All Haul Roads and Fugitive Dust Sources shall be subject to the following:

II.B.2.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to
exceed 20 percent opacity on site and 10 percent at the property boundary. [R307-309-5,
R307-401-8]

II.B.2.a.1 Visible emission determinations for fugitive dust from haul roads and operational areas shall use
procedures similar to Method 9. The normal requirement for observations to be made at 15-
second intervals over a six-minute period, however, shall not apply. Visible emissions shall be
measured at the densest point of the plume but at a point not less than one-half vehicle length
behind the vehicle and not less than one-half the height of the vehicle. [R307-309-5,
R307-401-8]

Status: In Compliance. No significant dust was observed from the haul road or off-road
operational areas during this inspection.

II.B.2.b The owner/operator shall use water sprays and/or chemical treatment to control fugitive dust
emissions from all unpaved roads and other unpaved operational areas that are used by mobile
equipment. Treatment shall be of sufficient frequency and quantity to maintain the surface
material in a damp/moist condition unless it is below freezing. If chemical treatment is to be
used, the plan must be approved by the Director. [R307-401-8]

Status: In Compliance. Watering records are maintained in binders in the watering truck
that remains on site.

II.B.2.b.1 Records of water and/or chemical treatment shall be kept for all periods when the plant is in
operation. The records shall include the following items:

A. Date of treatment
B. Number of treatments made, dilution ratio, and quantity
C. Rainfall received, if any, and approximate amount
D. Time of day treatments were made
E. Records of temperature if the temperature is below freezing. [R307-401-8]

Status: In Compliance. The paper binder records include the date of treatments, number
of treatments, the time of day, and weather notations. The daily inspection checklist form
also indicates dust control provisions performed each day. On site records indicate that the
most recent Magnesium Chloride treatment was performed on May 24, 2024. The site
supervisor stated that these chemical treatments typically occur during the spring of each
year.

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II.B.2.c The total haul roads shall not exceed 0.4 miles in length. [R307-401-8]

Status: In Compliance. The haul road lengths have not changed since the pit began
operating and reportedly remains under 0.4 miles in length.

II.B.2.d The owner/operator shall use water application or other control options contained in R307-309 to
minimize emissions from fugitive dust emissions from storage piles. Controls shall be applied to
ensure the opacity limits in this AO are not exceeded. [R307-309-5, R307-401-8]

Status: In Compliance. Water applications are used to control storage piles. No opacity
was observed resulting from the piles during this inspection.

II.B.2.e The owner/operator shall comply with a FDCP consistent with R307-309-6, Fugitive Dust
Control Plan. The FDCP shall address the control of all fugitive dust sources at the plant.
[R307-309-6, R307-401-8]

Status: In Compliance. A Fugitive Dust Control Plan was submitted to the DAQ on June
12, 2006.

II.B.3 Diesel fuel the power screen engine consumes shall be subject to the following

II.B.3.a The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the power screen engine. [R307-401-8]

Status: Not Applicable. The diesel fueled power screen is no longer in service.

II.B.3.b The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.3.b.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the
ULSD requirements. [R307-401-8]

Status: In Compliance. This facility purchases #2 ULSD certified as 15 ppm. See the
attached Delivery Ticket from Phillips 66 sold to Pilot Thomas Logistics, LLC.

Section III: APPLICABLE FEDERAL REQUIREMENTS

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

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

Status: In Compliance. See Condition II.B.1.c through II.B.1.f.2 for more information.

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AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]

Status: In Compliance. See Condition II.B.3.b and II.B.3.b.1 for more details.

Stationary Sources [R307-210]

Status: In Compliance. This Rule incorporates the federal standards for NSPS Subpart OOO for
aggregate mining which is satisfied by Conditions II.B.1.c through II.B.1.f.2.

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

Status: In Compliance. This Rule is satisfied by compliance with Conditions II.B.2.a, II.B.2.a.1,
II.B.2.d, and II.B.2.e.

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

Status: In Compliance. The observed opacities were under the specified aggregate equipment limits
at the time of this inspection.

EMISSION INVENTORY:
An Emissions Inventory for the 2023 activity year was submitted to the DAQ and the Summary Report is
attached to this memo. Listed below are the Actual Emissions Inventory provided from Staker Parson
Materials and Construction – McGuire Pit. A comparison of the estimated total potential emissions
(PTE) on AO: DAQE-AN100420012-23, dated December 11, 2023, is provided. PTE are supplied for
supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 79.00
Carbon Monoxide 0.46
Nitrogen Oxides 2.11
Particulate Matter - PM10 17.36
Particulate Matter - PM2.5 3.58
Sulfur Dioxide 0.14
Volatile Organic Compounds 0.17

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr

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PREVIOUS ENFORCEMENT
ACTIONS: A Compliance Advisory DAQC-1088-23 was issued to
document that the facility replaced a screen without prior
notification. A Replacement-In-Kind was then submitted as part
of a Notice of Intent to modify the existing AO. A Warning
Letter DAQC-1363-23 was then issued to document the
occurrence and the resolution of the issue.

COMPLIANCE STATUS &
RECOMMENDATIONS: In Compliance with the AO DAQE-AN1004020012-23, dated
December 11, 2023, and NSPS OOO.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual using the same targeting frequency.

NSR RECOMMENDATIONS: Consider removing the 250 TPH Power Screen referenced by
II.A.10 on the next AO modification as this equipment was
decommissioned several years ago and will no longer be used at
this site.

ATTACHMENTS: VEO, email correspondence, 12-month rolling production total
spreadsheet, total hours by process spreadsheet, copy of ULSD
invoice, and 2023 Emissions Inventory Summary Report.
Susan Weisenberg <[e-mail]>
RE: [EXT] inspection records for the Willard City McGuire Pit
1 message
Cowlishaw, Jeffery (Staker & Parson Companies) <[e-mail]>Mon, Aug 19, 2024 at 9:36
AM
To: Susan Weisenberg <[e-mail]>
Susan,

Attached are files showing the operating hours for equipment on the AO, A Bill of Lading showing ultra-low
sulfur diesel, and our rolling 12 production in tons.

Please let me know if you need anything else.

Thanks,

Jeffery (J) Cowlishaw
Environmental Specialist
North Wasatch

C [phone]
E [e-mail]

www.crhamericasmaterials.com

From: Susan Weisenberg <[e-mail]>
Sent: Friday, August 2, 2024 1:06 PM
To: Cowlishaw, Jeffery (Staker & Parson Companies) <[e-mail]>
Subject: [EXT] inspecon records for the Willard City McGuire Pit

CAUTION: This email originated from outside of the organizaon. Do not click links or open aachments unless you are
expecng this email and know the contents are safe. If you believe this email may be phishing or malicious, please use the
Report Phish buon.
Hello, on Wednesday July 31, 2024. I inspected the McGuire Pit located at 8211 South US Hwy 89, Willard, Box Elder
County. In order to complete this inspection I will need the following as per the AO AN100420012-23:
10/10/24, 11:00 AM State of Utah Mail - RE: [EXT] inspection records for the Willard City McGuire Pit
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r8346387654134024741%7Cmsg-f:1807830760298315583…1/2

II.B.1.a - 12-month rolling totals for the time period of July 2023 through June 2024 for aggregate production.
II.B.1.b - aggregate hours of operation for the equipment listed in Conditions II.A.5 through II.A.9.
II.B.3.b - a recent diesel fuel invoice indicating the purchase of ULSD.

Watering/chemical treatment records, and the daily spray bar/nozzle inspections, were reviewed on site.

Thanks, let me know if you have any questions.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

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3 attachments
Maguire op Hours.JPG
45K
Maguire Rolling 12 Jul 23-Jun 24.png
38K
Maquire Fuel Bill of Lading.pdf
125K
10/10/24, 11:00 AM State of Utah Mail - RE: [EXT] inspection records for the Willard City McGuire Pit
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r8346387654134024741%7Cmsg-f:1807830760298315583…2/2
2023 Emissions Inventory Report
Staker & Parson Companies- McGuire Pit Crushing Operation (10042)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)12.70374 0.44199 13.14573
PM10-FIL PM10 Filterable 12.70374 <.00001 12.70374
PM25-PRI PM2.5 Primary (Filt + Cond)1.76598 0.42873 2.19471
PM25-FIL PM2.5 Filterable 1.76598 <.00001 1.76598
SO2 Sulfur Dioxide <.00001 0.00949 0.00949
NOX Nitrogen Oxides <.00001 6.74097 6.74097
VOC Volatile Organic Compounds <.00001 0.49842 0.49842
CO Carbon Monoxide <.00001 2.84103 2.84103

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*

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