DAQ-2024-010966

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DAQC-CI100210001-24
Site ID 10021 (B1)

MEMORANDUM

TO: FILE – GENEVA ROCK PRODUCTS – Perry Sand & Gravel Pit

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: October 8, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Box Elder County

INSPECTION DATE: July 31, 2024

SOURCE LOCATION: 600 West 3000 South
Perry, UT 84320

DIRECTIONS: From I-15 north bound, take exit 357. Take south highway 89 to
3000 South in Perry. The pit entrance is on the east side of 3000
South and Highway 89. Continue east bound past the small
electrical power substation.

SOURCE CONTACTS: Colt Powell, Site Maintenance Manager

Grant Ensign, Environmental Specialist
801-802-6954, [e-mail]

OPERATING STATUS: The aggregate equipment was operating. The concrete batch
plant was temporarily down. The wash plant has not operated
since 2017.

PROCESS DESCRIPTION: The Perry Pit includes dry batch concrete, a wash plant, and an
aggregate crushing plant. Face material is dropped into the feed
bin by a front-end loader. The material then drops to a transfer
belt and to a three-deck screen. The oversize drops from the top
of the screen to an attached cone crusher. Road base drops from
the screen chute to a transfer belt and then through three transfer
bins, transfer screen, and a stacker belt and storage pile. When
the plant is operating, some product will be routed to the wash
plant for additional processing. The concrete plant has two silos
with one silo having two separate internal bins. Cement powder
and fly ash from the pneumatically loaded silos is gravity fed
through the feed gate and into the transfer truck. Water is mixed
with the aggregate and cement powder in the truck drop chute
and the mixing is done in the transfer truck. The drop chute has a
three-sided enclosure and two vacuum ducts which feed a
ground level baghouse.

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All loading is done by the plant operator from the control room.
To control emissions, three bin vents utilizing fabric filter media
are installed at the cement and fly ash storage silos; a baghouse
controls emissions from loading haul trucks. To control fugitive
dust from roads and operational areas, the site has a paved
entrance road, an on-site water truck for the entire plant, and
several sprayers and sprinklers for the roadway and work areas.
The site also has a company sweeper that is used twice per week
on the main access road. All the permanent equipment is
currently operated with electrical power.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN100210008-24, dated
July 9, 2024

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

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Geneva Rock Products
Perry Sand & Gravel Pit

1565 West 400 North 600 West 3000 South
Orem, UT 84057 Perry, UT 84320

SIC Code: 1442: (Construction Sand & Gravel)

Section I: GENERAL PROVISIONS

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

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

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

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

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
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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 R307-150 Series. Inventories, Testing and Monitoring.
[R307-150]

I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

Status: In Compliance. No limits were exceeded based on the observations made during the
inspection and a review of the submitted records. The process and equipment were as
permitted on the current AO and the Temporary Relocation DAQC-607-23. The baghouse
gauge calibration occurred later than the 12-month requirement, but was performed on
October 8, 2024. The records for this AO were otherwise kept as required. An Emissions
Inventory was submitted for the 2023 activity year. No applicable breakdowns have
occurred.

Section II: SPECIAL PROVISIONS

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

II.A.1 Perry Sand & Gravel Pit

II.A.2 One (1) Concrete Batch Plant
Capacity: 250 cubic yards per hour

II.A.3 One (1) Cement Storage Silo
Control Device: Bin Vent

II.A.4 One (1) Fly Ash Storage Silo
Control Device: Bin Vent

II.A.5 One (1) Truck Loading Baghouse
Location: Concrete Truck Loading Station

II.A.6 One (1) 560-Horsepower Diesel Generator

II.A.7 One (1) Cone Crusher
Capacity: 150 tons per hour

II.A.8 One (1) Sizing Screen
Capacity: 300 tons per hour

II.A.9 One (1) Wash Screen

II.A.10 One (1) Sand Screw

II.A.11 Associated Conveyors and Stackers

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II.A.12 One (1) Diesel Storage Tank
Capacity: 8,000 gallons

II.A.13 One (1) Diesel Storage Tank
Capacity: 12,000 gallons

Status: In Compliance. No unpermitted equipment was observed during the inspection. A
jaw crusher permitted on the Temporary Relocation DAQC-607-23 dated June 20,
2023, was on site. This relocated equipment was reportedly started up on August 9,
2023, and then operated for a total of 136 days as of the date of this inspection. See
the attached emailed statement submitted with the aggregate production totals. The
560-hp diesel generator (II.A.6) and the 8,000-gallon diesel tank (II.A,12) were not
present and were removed at least two years prior to this inspection. All equipment
operating at this site is now powered by electricity.

II.B Requirements and Limitations

II.B.1 The Perry Sand & Gravel Pit shall be subject to the following:

II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any source on site to exceed 20% opacity. [R307-401-8]

Status: In Compliance. No visible dust was observed from the crushing circuit during the
time of this inspection. Spray bars were operating and the materials were damp at the time
of processing.

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. [R307-401-8]

Status: In Compliance. No significant dust was observed from any point, including the
operating screens, crusher, or the associated conveyor drops and transfers. The
observations were conducted in a manner consistent with Method 9 requirements. See the
attached VEO.

II.B.1.b The owner/operator shall not produce more than the following:

A. 750,000 tons of aggregate processed through the crushing/screening plant per
rolling 12-month period

B. 200,000 tons of aggregate harvested from the bank run (in addition to item A
above) & directly transported off-site per rolling 12-month period. [R307-401-8]

Status: In Compliance. Totals for the rolling 12-month period of July 2023 through June
2024, were 141,660 tons of crushing/screening plant processed materials. This 12-month
total included the resulting production from the portable Cedarapids jaw crusher relocated
on the Temporary Relocation authorization letter DAQC-607-23. 17,276 tons were
reported for bank run harvesting for the same time period. See the attached submitted
email statement and graph totals. A copy of the letter has also been attached for reference.

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II.B.1.b.1 The owner/operator shall:

A. Determine production by weighing products as they exit/enter the site

B. Record the weight of each truck as it enters the site and the weight of the truck as it
leaves the site

C. Record production on a daily basis

D. Use the production data to calculate a new rolling 12-month total by the 20th data of
each month using data from the previous 12 months

E. Keep production records for all periods the plant is in operation. [R307-401-8]

Status: In Compliance. Records are determined by scale house weighs of product exiting
the site. Records are created daily for all periods that the plant is in operation and the
summaries are calculated as required.

II.B.1.c The owner/operator shall not operate the aggregate crushing/screening operations for more than
3,600 hours per rolling 12-month period. [R307-401-8]

Status: In Compliance. The aggregate crushing spread average was stated to be 172.74
tons per hour, resulting in approximately 820 hours for the reported 12-month period. See
the attached emailed statement under Condition II.B.1.c.

II.B.1.c.1 The owner/operator shall:

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

B. Use the hours of operation to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months. [R307-401-8]

Status: In Compliance. Hours of equipment operation were estimated from the associated
equipment ton per hour operation log.

II.B.2 The Concrete Batch Plant and Associated Equipment shall be subject to the following

II.B.2.a The owner/operator shall not allow visible emissions from the concrete batch plant to exceed 7%
opacity. [R307-312-4]

Status: Not Observed. The concrete batch plant was not operating at the time of this
inspection.

II.B.2.b The owner/operator shall not produce more than 100,000 cubic yards of concrete per rolling
12-month period. [R307-401-8]

Status: In Compliance. The batch plant produced 53,795 cubic yards of concrete for the
12-month period of July 2023 through June 2024. See the attached submitted production
graph for this condition.

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II.B.2.b.1 The owner/operator shall:

A. Determine production by weighing products as they exit/enter the site

B. Record the weight of each truck as it enters the site and the weight of each truck as it
leaves the site

C. Record production on a daily basis

D. Use the production data to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months

E. Keep production records of all periods the plant is in operation. [R307-401-8]

Status: In Compliance. The submitted totals are based on scale house weighs that occur for
all periods when the plant is in production. The monthly totals appear to be added to the
electronic office records as required.

II.B.2.c The owner/operator shall not operate the concrete batch plant for more than 2,000 hours per
rolling 12-month period. [R307-401-8]

Status: In Compliance. The concrete batch plant operation hours were reported at 375
hours for the 12-month period. See the attached graph for this condition .

II.B.2.c.1 The owner/operator shall:

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

B. Use the hours of operation to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months. [R307-401-8]

Status: In Compliance. Operation hours are based on equipment logs associated with the
scale house weighs.

II.B.2.d The owner/operator shall control particulate emissions from the cement storage silo and the fly
ash storage silo with two (2) bin vents that utilize fabric filter media. [R307-401-8]

Status: In Compliance. The two bin vents have been installed for the storage silos and the
fabric filter operates in the truck loading baghouse.

II.B.2.e The owner/operator shall use a loading shroud at the truck loading station to further prevent
particulate emissions from this area. [R307-401-8]

Status: In Compliance. A truck loading shroud is reportedly used when the loading station
is operating. The previous inspection noted observing the shroud operating. See
CI100210001-23.

II.B.3 Baghouse Conditions

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II.B.3.a The owner/operator shall control particulate emissions from the concrete truck loading station
with a baghouse. [R307-401-8]

Status: In Compliance. A baghouse has been installed to control the emissions from the
dry/truck mix loading station.

II.B.3.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across the baghouse. [R307-401-8]

Status: In Compliance. A manometer has been installed to measure the static pressure
drop across the baghouse.

II.B.3.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

Status: In Compliance. The manometer has been installed in the operator shack for the
batch plant and can easily be read during truck loads.

II.B.3.b.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]

Status: In Compliance. The gauge measures the pressure drop in at least 1-inch water
column increments.

II.B.3.c During operation of the baghouse, the owner/operator shall maintain the static pressure drop
across the baghouse between two (2) and six (6) inches of water column. [R307-401-8]

Status: In Compliance. The batch plant was not operating during the time of this
inspection, however, the submitted manometer truck readings for the months of July and
August indicated a pressure drop between 4 and 5.25 inches. See the attached record
examples for this condition.

II.B.3.c.1 The owner/operator shall record the pressure drop at least once per operating day while the
baghouse is operating. [R307-401-8]

Status: In Compliance. The pressure drop is electronically recorded once a day for the
days that the plant is in operation.

II.B.3.c.2 The owner/operator shall maintain the following records of the pressure drop readings:

A. Unit identification;
B. Date of reading;
C. Daily static pressure drop readings. [R307-401-8]

Status: In Compliance. The electronic record includes the unit identification, date of the
reading, and the actual pressure drop reading.

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II.B.3.d At least once every 12 months, the owner/operator shall calibrate the pressure gauge against a
primary standard. [R307-401-8]

Status: Not in Compliance. The annual pressure gauge calibration originally submitted for
this gauge was dated June 14, 2023. The Clyde Companies Environmental Specialist
resubmitted a new calibration record dated October 8, 2024. See the attached record screen
shot for the updated calibration. No further action recommended.

II.B.3.e The owner/operator shall not allow visible emissions from the baghouse to exceed 7% opacity.
[R307-312-4]

Status: Not Observed. The batch plant was not operating at the time of this inspection.

II.B.4 The Diesel Generator shall be subject to the following:

II.B.4.a The owner/operator shall not operate the 560-Horsepower Diesel Generator for more than 3,600
hours per rolling 12-month period. [R307-401]

Status: Not Applicable. The 560-hp diesel generator has been removed and the equipment
is now powered on the electrical grid.

II.B.4.a.1 The owner/operator shall:

A. Determine the hours of operation by supervisor monitoring and maintaining of an
operations log
B. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months. [R307-401-8]

Status: Not Applicable. This generator was removed a few years ago and the removal was
noted on the previous inspection DAQC-CI100210001-23.

II.B.4.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. [40 CFR 63 Subpart ZZZZ,
R307-401-8]

Status: In Compliance. Only ULSD is used in the off-road equipment. The purchased fuel
is certified by Bridge Source. See the attached June 26, 2024, fuel invoice.

II.B.4.b.1 The sulfur content of any fuel oil or diesel fuel shall be determined by ASTM Methods
D4294-89 or approved equivalent. Certification of fuels shall be either by the owner/operator's
own testing or by test reports from the fuel oil or diesel fuel marketer. Records of fuel supplier's
test report on sulfur content shall be available on-site for each load delivered. [R307-203]

Status: In Compliance. See the attached ULSD invoice.

II.B.5 All Haul Roads and Fugitive Dust Sources shall be subject to the following:

II.B.5.a The owner/operator shall comply with a fugitive dust control plan (FDCP) acceptable to the
Director for control of all dust sources on site. This plan shall contain sufficient controls to
prevent an increase in PM10 emissions above those modeled for this AO. The limitations and
conditions in the fugitive dust control plan shall not be changed without prior approval in
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accordance with R307-401. [R307-309-6]

Status: In Compliance. A Fugitive Dust Control Plan was submitted to the DAQ on August
17, 2021, and the basic dust control measures, including watering and spray bar
considerations, are followed accordingly.

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

Status: In Compliance. No significant dust was observed from the haul roads or other dust
sources. No visible dust could be viewed at the property boundaries.

II.B.5.b.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; however, the
requirement for observations to be made at 15-second intervals over a six-minute period shall not
apply. Visible emissions shall be measured at a point not less than 1/2 vehicle length behind the
vehicle and not less than 1/2 the height of the vehicle. [R307-309-5, R307-401-8]

Status: In Compliance. No significant fugitive dust was observed from the haul road traffic
or the operational areas on the day of the inspection.

II.B.5.c The owner/operator shall use water application and/or chemical treatment on all unpaved haul
roads and other unpaved operational areas that are used by mobile equipment to maintain opacity
limits listed in this AO. If the temperature is below freezing, the owner/operator may stop
applying water and/or chemical treatment to the unpaved haul roads and other unpaved
operational areas that are used by mobile equipment. The owner/operator shall resume applying
water and/or chemical treatment to the unpaved haul roads and other unpaved operational areas
that are used by mobile equipment when the temperature is above freezing. If chemical treatment
is to be used, the plan must be approved by the Director. [R307-401-8]

Status: In Compliance. Geneva Rock Products relies on water treatment applications for
dust control. A watering truck and water tank are maintained on site.

II.B.5.c.1 The owner/operator shall keep records of treatment 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, chemical dilution ratio used, and quantity of water applied
C. Rainfall amount received, if any, and approximate amount
D. Temperature, if the temperature is below freezing. [R307-401-8]

Status: In Compliance. Records are compiled electronically and are kept for a minimum of
two years. The date of the application and the water truck employee are noted for each day
of the application. The site's maintenance operator stated that applications occur as
necessary. See the submitted watering records.

II.B.5.d The owner/operator shall not exceed a haul road length of 0.6 miles. [R307-401-8]

Status: In Compliance. Previous inspections have noted that the haul road length is 0.5
mile. The site manager stated that no changes to the pit dimensions have occurred in the
last five years or more.
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II.B.5.e The owner/operator shall not exceed a haul road speed limit of 25 miles per hour. The haul road
speed shall be posted, at a minimum, on site at the beginning of the haul road so that it is clearly
visible from the haul road. [R307-401-8]

Status: In Compliance. The speed limit is posted as 15 miles per hour. The sign is located
at the beginning of the entrance to the pit.

II.B.5.f The access haul road(s) to State Highway 89 & effected areas of State Highway 89 that are paved
shall be periodically swept or sprayed clean as dry conditions warrant or as determined necessary
by the Director. [R307-309]

Status: In Compliance. Sweeping for this pit has historically included State Highway 89.
See DAQC-CI100210001-23 for more information.

II.B.5.f.1 The owner/operator shall keep records of cleaning paved roads. [R307-401]

Status: In Compliance. Sweeping and watering records are compiled into electronic sheets.

II.B.5.g The owner/operator shall use water application for all storage piles to minimize fugitive dust, as
dry conditions warrant or as determined necessary by the Director. [R307-401-8]

Status: In Compliance. Water applications are used to minimize fugitive dust. The site
maintenance manager reported that the watering truck is used as necessary to control dust.
The truck and a watering tank are maintained on site. Bank run materials are typically
damp when processed.

II.B.5.g.1 The owner/operator shall keep records of water and/or chemical treatment. [R307-401-8]

Status: In Compliance. This facility relies on water applications for dust control. Records
are kept electronically. See the attached example records.

II.B.5.h The owner/operator shall control all disturbed or stripped areas on site at all times for the
duration of the project/operation. [R307-309]

Status: In Compliance. Disturbed areas are controlled by use of a water side spray located
on the truck. Bank areas are typically damp from natural water runoff and seepage.

II.B.6 All Crushers, Screens, and Conveyors shall be subject to the following:

II.B.6.a Visible emissions from the following emission points shall not exceed the following values:

A. All crushers - 12% opacity
B. All screens - 7% opacity
C. All conveyor transfer points - 7% opacity
D. All conveyor drop points - 20% opacity. [R307-312-4, R307-401-8]

Status: In Compliance. No visible dust was observed from the crusher, screen, and
associated conveyor circuit during this inspection. See the attached VEO.

II.B.6.b The owner/operator shall install water sprays on all crushers, screens, and conveyor transfer
points on site to control fugitive emissions. Sprays shall operate whenever dry conditions warrant
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or as determined necessary by the Director. [R307-401-8]

Status: In Compliance. Water sprays had been installed and were operating at the
appropriate points.

II.B.6.c The owner/operator shall conduct an initial performance test for each crusher, screen, and
conveyor transfer point on site. Performance tests shall demonstrate compliance with the
limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO]

II.B.6.c.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.6.d The owner/operator shall keep and maintain records of the initial performance test for each
crusher, screen, and conveyor for the life of the equipment. [40 CFR 60 Subpart OOO,
R307-401-8]

Status: In Compliance. The inspection memo DAQC-651-10 states that the initial visible
Method 9 observations were conducted on September 14, 2000, and can be found in the
hard copy case files. The electronic file records for this site only go back to 2005. The site
manager for this facility stated that the equipment permanently installed at this site has not
changed for many years. The AO DAQE-AN0100210007-09 was an Administrative
Amendment to update formatting. AO DAQE-AN100210008-24 is an Administrative
Amendment for a 10-year Review. The initial Method 9 observations for the portable jaw
crusher were performed on September 29, 2020, and can be viewed as an attachment to the
inspection memo DAQC-CI100210001-23.

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) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: Not Applicable. The permitted diesel engine has been removed from this site.

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

Status: In Compliance. The applicable equipment was operating without visible emissions. The initial
VEOs for the permanent equipment were reportedly performed on September 14, 2000, and September
29, 2020, for the relocated portable jaw crusher. Spray bar inspection records are kept for the months
that the equipment is in operation. See the attached water nozzle inspection record.

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NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines.

Status: Not Applicable. The permitted diesel engine has been removed from this site.

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 the attached ULSD invoice for reference.

Stationary Sources [R307-210]

Status: In Compliance. This Rule incorporates the Federal NSPS Standards for Subpart IIII and
OOO. Subpart IIII for diesel engines no longer applies due to the removal of the generator. Subpart
OOO for aggregate mining has been met by the above referenced Federal Requirements and the
applicable AO Conditions referencing aggregate equipment opacities, initial Method 9 requirements,
and spray bar maintenance.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: Not Applicable. This Rule incorporated the MACT Standards Subpart ZZZZ for diesel
generators, but no longer applies as the permitted diesel fueled engine has been removed.

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

Status: In Compliance. No significant fugitive dust was observed from any point.

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

Status: In Compliance. No significant fugitive dust or visible emissions were observed during this
inspection. Water is applied as necessary. A Fugitive Dust Plan has been submitted to the DAQ.

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

Status: In Compliance. The aggregate processing equipment was observed operating with opacities
under the established limits.

EMISSION INVENTORY:
An Emissions Inventory was submitted for the 2023 activity year and has been attached to this inspection
memo. Listed below are the Actual Emissions Inventory provided from Geneva Rock Products – Perry
Sand & Gravel Pit. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN100210008-24, dated July 9, 2024, is provided. PTE are supplied for supplemental purposes
only.

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Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 1159.00
Carbon Monoxide 7.61
Nitrogen Oxides 29.83
Particulate Matter - PM10 10.17
Particulate Matter - PM2.5 10.17
Sulfur Dioxide 2.29

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Generic HAPs (CAS #GHAPS) 560

PREVIOUS ENFORCEMENT
ACTIONS: No compliance actions are on record for the last five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: The annual calibration for the baghouse pressure gauge was
performed later than the 12-month requirement of Condition
II.B.3.d. The Clyde Companies Specialist was contacted and an
updated calibration record dated October 8, 2024, was submitted.
No additional compliance action is recommended. This facility
should otherwise be considered to be in compliance with the AO
DAQE-AN100210008-24, dated July 9, 2024, and NSPS Subpart
OOO at the time of this inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Check for a current annual calibration for the baghouse pressure
gauge during the next inspection. Otherwise inspect as usual
maintaining the same inspection frequency.

NSR RECOMMENDATIONS: Consider removing the 560 hp diesel generator (II.A.6) and the
8000-gallon diesel fuel tank (II.A.12) during the next AO
modification as this equipment has been removed.

ATTACHMENTS: VEO, Temporary Relocation Letter DAQC-607-23 with
electrical power statement email, submitted production,
manometer readings, watering, sweeping, spray nozzle monthly
records, ULSD fuel invoice, updated manometer calibration
record, and the 2023 activity year Emissions Inventory.
Susan Weisenberg <[e-mail]>
Re: records for the Perry S & G site inspection
1 message
Grant Ensign <[e-mail]>Tue, Aug 6, 2024 at 11:46 AM
To: Susan Weisenberg <[e-mail]>
Hi Susan,
Thanks for reaching out.
Here are the records you requested:
II.B.1.b.A - 12-month rolling producon total for aggregate crushing/screening producon for the me period of July 2023 through June of 2024.
(Please include the producon created by the TRP DAQC-607-23 for the temporary Cedar Rapids Jaw Crusher. I will also need the startup and
esmated compleon date for this temporary equipment).

141,660tons
The Cedar Rapids Jaw Crusher on
TRP 507-23 was used to helpprocess ALL the aggregates. All141,660 tons produced over the
past 12 months were generated
with the help of the Cedar RapidsJaw Crusher. Operations began8/9/23 and continued until
12/15/23. Operations ceased for
the winter months and started upagain in June 2024 until today. Intotal, the Cedar Rapids Jaw
Crusher was used 136 days.  
II.B.1.b.B - total tons for the same me period for the bank run.
17,276 tons
II.B.1.c - total hours of aggregate crushing/screening operaons.
The agg/crushing spread averages 172.74 tons/hour. At this rate, the total hours is 820 hours (141,660 tons/172.74 tons/hr =820 hours)
II.B.2.b - 12-month rolling total for concrete cubic producon.
10/7/24, 10:28 AM State of Utah Mail - Re: records for the Perry S & G site inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r3627319156955081954%7Cmsg-f:1806661183332915043&…1/5
53,795 CY
II.B.2.c - 12-month rolling total hours of batch plant producon.
375 hours
II.B.3.c.1 - recent daily pressure drop reading records for batch plant operaon.
II.B.3.d - the most recent annual pressure gauge calibraon.
10/7/24, 10:28 AM State of Utah Mail - Re: records for the Perry S & G site inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r3627319156955081954%7Cmsg-f:1806661183332915043&…2/5
II.B.4.b - recent diesel fuel invoice indicang ULSD.
ULSD = Ultra Low Sulphur Diesel (<15 ppm)
II.B.5.c and II.B.5.c.1 - recent watering records
II.B.5.f.1 - recent sweeping records.
10/7/24, 10:28 AM State of Utah Mail - Re: records for the Perry S & G site inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r3627319156955081954%7Cmsg-f:1806661183332915043&…3/5
II,B.5.g.1 - most recent chemical treatment if used.
None.
NSPS OOO - recent monthly water nozzle inspecons.
Grant Ensign
ENVIRONMENTAL SPECIALIST
O [phone] 
C [phone]
WWW.CLYDEINC.COM

From: Susan Weisenberg <[e-mail]>
Sent: Friday, August 2, 2024 12:42 PM
To: Grant Ensign <[e-mail]>
Subject: records for the Perry S & G site inspecon

Hello, on Wednesday July 31, 2024, I inspected the Perry Pit located at 600 West 3000 South. In order to complete the inspection, I will need the
following as per the Approval Order AN100210008-24 (10-year Administrative Review update):
II.B.1.b.A - 12-month rolling production total for aggregate crushing/screening production for the time period of July 2023 through June of 2024. (Please
include the production created by the TRP DAQC-607-23 for the temporary Cedar Rapids Jaw Crusher. I will also need the startup and estimated
completion date for this temporary equipment).
II.B.1.b.B - total tons for the same time period for the bank run.
II.B.1.c - total hours of aggregate crushing/screening operations.
10/7/24, 10:28 AM State of Utah Mail - Re: records for the Perry S & G site inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r3627319156955081954%7Cmsg-f:1806661183332915043&…4/5
II.B.2.b - 12-month rolling total for concrete cubic production.
II.B.2.c - 12-month rolling total hours of batch plant production.
II.B.3.c.1 - recent daily pressure drop reading records for batch plant operation.
II.B.3.d - the most recent annual pressure gauge calibration.
II.B.4.b - recent diesel fuel invoice indicating ULSD.
II.B.5.c and II.B.5.c.1 - recent watering records
II.B.5.f.1 - recent sweeping records.
II,B.5.g.1 - most recent chemical treatment if used.
NSPS OOO - recent monthly water nozzle inspections.
Thanks, let me know if you have any questions.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
10/7/24, 10:28 AM State of Utah Mail - Re: records for the Perry S & G site inspection
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r3627319156955081954%7Cmsg-f:1806661183332915043&…5/5
Susan Weisenberg <[e-mail]>
Re: Perry Pit annual calibration for the batch plant manometer
1 message
Grant Ensign <[e-mail]>Tue, Oct 8, 2024 at 11:41 AM
To: Susan Weisenberg <[e-mail]>
Hi Susan,
They are doing the calibration today! I’ll send you the confirmation when it comes through.
—————
Grant Ensign
Clyde Companies
ENVIRONMENTAL SPECIALIST
O [phone]
C [phone]
WWW.CLYDEINC.COM
From: Susan Weisenberg <[e-mail]>
Sent: Tuesday, October 8, 2024 10:17:36 AM
To: Grant Ensign <[e-mail]>
Subject: Perry Pit annual calibraon for the batch plant manometer

Hello, I apologise for the late review comment, but I have a backlog of inspection memos that are now being completed.
The documents that were submitted for the Perry Sand and Gravel Pit on August 6, included a June 14, 2023 record as
the most recent calibration for the dry/truck mix batch plant manometer. Has a more recent calibration happened since
that time? If not, can you give me the scheduled date for this calibration? Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
10/8/24, 6:10 PM State of Utah Mail - Re: Perry Pit annual calibration for the batch plant manometer
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-2710704385465441058%7Cmsg-f:1812368488006855068…1/1
10/8/24, 6:14 PM Photo - Google Photos
https://photos.google.com/search/_tra_/photo/AF1QipPZgiNA5ZXCXmL0fWF5fbiOEfjGPRAFYgAwjSJN 1/1
2023 Emissions Inventory Report
Geneva Rock Products- Perry Sand & Gravel Pit (10021)
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)2.03358 0.14625 2.17982
PM10-FIL PM10 Filterable 2.0329 <.00001 2.0329
PM25-PRI PM2.5 Primary (Filt + Cond)0.26749 0.14186 0.40935
PM25-FIL PM2.5 Filterable 0.26682 <.00001 0.26682
PM-CON PM Condensible 0.00068 <.00001 0.00068
SO2 Sulfur Dioxide 0.00007 0.0031 0.00317
NOX Nitrogen Oxides 0.00593 2.2328 2.23873
VOC Volatile Organic Compounds 0.00165 0.16411 0.16577
CO Carbon Monoxide 0.00995 0.95187 0.96183
7439921 Lead <.00001 <.00001 <.00001
NH3 Ammonia 0.00038 <.00001 0.00038

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
7440382 Arsenic (HAP)PM <.00001
71432 Benzene (HAP)VOC <.00001
7440417 Beryllium (HAP)PM <.00001
7440439 Cadmium (HAP)PM <.00001
7440473 Chromium (HAP)PM <.00001
7440484 Cobalt (HAP)PM <.00001
50000 Formaldehyde (HAP)VOC 0.00001
110543 Hexane (HAP)VOC 0.00021
7439965 Manganese (HAP)PM <.00001
7439976 Mercury (HAP)- <.00001
91203 Naphthalene (HAP)VOC <.00001
7440020 Nickel (HAP)PM <.00001
7782492 Selenium (HAP)PM <.00001
108883 Toluene (HAP)VOC <.00001
91576 2-Methylnaphthalene (HAP)PM <.00001

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