DAQ-2024-010977

1
DAQC-CI124440001-24
Site ID 12444 (B1)
MEMORANDUM

TO: FILE – STAKER PARSON COMPANIES – Keigley Quarry

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: September 24, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: July 26, 2024

SOURCE LOCATION: 12370 South West Mountain Highway
Genola, UT 84651

DIRECTIONS: Directions from I-15 Southbound - Take Payson Exit 248 and turn
right onto 10900 South then turn left after 0.2 mile onto 1700 West.
Turn right onto 10950 South after 1.2 miles then turn right onto
120000 South after 0.8 mile. The entrance to the pit is 1.3 miles
directly west.

SOURCE CONTACTS: Christopher Rose, Environmental Specialist
385-400-2119, [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Keigley Quarry has a primary and secondary crushing circuit using
crushers and screens to produce a variety of rock and aggregate
products. Some of the products are used to produce asphalt. Asphalt
and aggregate are trucked off-site to customers.

Limestone Quarry Operations: Two types of limestone (carbonate
mineral - limestone and dolomite) are mined at the quarry. Limestone,
mined from the Lime Pit, is a rock containing large amounts of
calcium carbonate. Dolomite, mined from the East and West
Dolomite Pits, is a form of limestone in which a good part of the
calcium carbonate has been replaced with magnesium carbonate. Both
types are mined in the same manner. Holes are drilled - 15' apart and
26' back - from the face of the pit with large mobile drill machines.
Water is injected through the drill bits as the machines operate,
loosening the rock and suppressing any dust created during drilling.
Explosive charges are then packed into the holes and set off, blasting
the rock face into 2"-minus rock.

Loading Building: In this building, the rock is screened into two cuts:
7/S"-minus to 1/8"-plus, and 1/8" minus to 0. Each cut is kept in a
separate storage bin. The site also has a Rock Dust Mill, a standard
aggregate processing plant, and an asphalt plant.

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APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN124440009-18, dated
October 1, 2018

NSPS (Part 60) OOO: Standards of Performance for Nonmetallic
Mineral Processing Plants,
NSPS (Part 60) I: Standards of Performance for Hot Mix Asphalt
Facilities

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Staker Parson Companies
Keigley Quarry

89 West 13490 South, Suite 100 12370 South West Mountain Highway
Draper, UT 84020 Genola, UT 84651

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
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
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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: Out of Compliance. Unapproved equipment was observed on-site at the time of
inspection. See Section II for more details. No limits set forth in this AO appear to have
been exceeded. An emissions inventory was submitted for 2023, and emissions data are
reported below. No breakdowns have been reported since the previous inspection. A
startup notification was submitted on May 6, 2019, see DAQC-1326-21 for more
information.

Section II: SPECIAL PROVISIONS

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

II.A.1 Keigley Quarry

II.A.2 Four (4) Tri-Deck Screens
Capacity: 700 tph (each)

II.A.3 Two (2) Screen Plants
Capacity: 700 tph (each)

II.A.4 Two (2) Cone Crushers
Capacity: 700 tph (each)

II.A.5 Two (2) Jaw Crushers
Capacity: 700 tph (each)

II.A.6 One (1) VSI Crusher
Capacity: 700 tph

II.A.7 Additional Crushing Equipment
Includes: Various Conveyors, Feeders, Loaders, and Stackers

II.A.8 One (1) Grizzly Feeder

II.A.9 One (1) Hot Drum Mix Asphalt Plant
Capacity: 500 tph

II.A.10 Three (3) Hot Mix Storage Silos
Capacity: 300 tons (each)

II.A.11 One (1) Asphalt Storage Silo
Capacity: 75 tons

II.A.12 One (1) Lime Silo
Capacity: 3,600 Cu. Ft.

II.A.13 Eight (8) Cold Feed Bins

II.A.14 Two (2) Recycled Asphalt Pavement Bins

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II.A.15 One (1) Baghouse
Rating: 70,000 acfm

II.A.16 Various Aggregate & Asphalt Equipment
Includes: Conveyors, Loaders, Bulldozers, Haul Trucks; Holding Tanks, Hot Oil Heaters and
Feeders

II.A.17 One (1) Wash Plant
Includes: Screens, Belts, and Feeders

Status: Out of Compliance. An existing Rock Dust Mill dating back to the 1940's is not listed
on the permitted equipment on this AO. A 1,000-gallon gasoline tank, a 4,000-gallon
diesel tank, and a 10,000-gallon diesel tank are also on-site and unpermitted. A new
AO (DAQE-124440011-24) including this unpermitted equipment was issued on
August 13, 2024. No compliance action is recommended at this time.

II.B Requirements and Limitations

II.B.1 Site Wide Requirements

II.B.1.a The following production limits shall not be exceeded:

A. 6,000,000 tons of processed aggregate material per rolling 12-month period

B. 500,000 tons of asphalt material per rolling 12-month period

C. 500 tons per hour of asphalt material produced

[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months.
Records of production shall be kept for all periods when the plant is in operation. Production
shall be determined by scale house records or vendor receipts. The records of production shall
be kept on a daily basis. Hours of operation shall be determined by supervisor monitoring and
maintaining of an operations log. [R307-401-8]

Status: In Compliance. For the rolling 12-month period from July 2023 – June 2024,
production records are as follows:

A) 1,056,537.45 tons of aggregate
B) 39, 315.45 tons of asphalt
C) According to the source, the plant's absolute max production capacity is 400 TPH. Due
to production constraints, the plant only produces 350-370 TPH at the most. Typical
production is close to 275-300 TPH.

See the attached email correspondence for more information.

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

A. Crushers - 12% opacity

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B. Screens - 7% opacity

C. All Conveyor Transfer Points - 7% opacity

D. All Diesel Engines - 20% opacity

E. Asphalt Plant Baghouse - 10% opacity

F. All Conveyor Drop Points - 20% opacity

G. All Other Points - 20% opacity.

[R307-312]

II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of visible emissions from stationary
sources shall be conducted according to 40 CFR 60, Appendix A, Method 9.

Initial visible emission observations shall be conducted according to 40 CFR 60.11 and 40 CFR
60.674. A certified observer must be used for these observations. Emission points which are
subject to the initial observations are those as defined in 40 CFR 60.670.

[R307-305]

Status: In Compliance. A VEO was performed at a conveyor transfer to a screen. Average
opacity at this point was 2.08%. The opacity observations were conducted as per 40 CFR
60, Appendix A, Method 9 requirements. See the attached VEO form.

II.B.2 Asphalt Plant Requirements

II.B.2.a The asphalt plant baghouse shall control process streams from the asphalt plant drum mixer. This
baghouse shall be sized to handle at least 70,000 ACFM for the existing conditions. All exhaust
air from the drum mixer shall be routed through the baghouse before being vented to the
atmosphere. [R307-401-8]

Status: In Compliance. The asphalt plant baghouse is sized as required. All exhaust air
from the drum mixer is routed through the baghouse before being vented to the
atmosphere.

II.B.2.b The asphalt plant shall not operate with a stack exhaust flow rate in excess of 75,000 ACFM
without prior approval from the Director in accordance with R307-401. This will be verified
during stack testing. [R307-401-8]

Status: In Compliance. The most recent stack test performed on August 25-26, 2023,
indicated compliance with the baghouse ACFM specifications. See the Montrose Air
Quality Services consulting report that is attached to the electronic files of DAQC-936-23.

II.B.2.c The following operating parameters for the asphalt plant baghouse shall be maintained within the indicated ranges: A. The pressure drop shall not be less than 2.0 inches of water column or more than 7.0 inches of water column B. The pressure drop reading shall be accurate within plus or minus 1.0 inches of water column.
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The pressure drop shall be monitored with equipment located such that an inspector/operator can safely read the output any time. All instruments shall be calibrated according to the manufacturer's instructions at least once every 12 months. Continuous recording for the monitoring device is not required; however, recording of the reading is required every time the baghouse is operated. [R307-401-8] Status: In Compliance. The pressure reading is read at least once per day of operation. The reading was 3.2 at the time of inspection. The manometer was last calibrated on
May 8, 2023. The source stated they would calibrate again soon for 2024. See the attached
records and email correspondence.

II.B.2.d For the asphalt plant the following operating parameters shall be maintained within the indicated
ranges:

A. Temperature of the gases exiting the baghouse shall be between 100ºF and 350ºF -
Plus or minus 10ºF

B. Asphalt mix temperature not to exceed 350ºF - Plus or minus 10ºF

They shall be monitored with equipment located such that an inspector can at any time safely
read the output.

All instruments shall be calibrated in accordance with manufacturer's instructions or
recommendations. A log of asphalt mix temperature shall be taken at 15-minute intervals or
more often, and a current year of data shall be available for evaluation by the Director upon
request.

[R307-401-8]

Status: In Compliance. The temperature of the gases exiting the baghouse are continuously
monitored and recorded on a graph wheel for all periods that the plant is in operation.
Temperatures observed at the time of inspection were within limits. See the attached
example graph wheels.

II.B.2.e Emissions to the atmosphere from the Hot Mix Asphalt Plant Baghouse Exhaust Stack shall not
exceed the following rates and concentrations (standardized at 68 °F, 29.92 in Hg):

Pollutant lb/hr grain/dscf

TSP 5.80 0.030
TSP (RAP) 6.78 0.035
PM10 4.64 0.024
PM10 (RAP) 5.42 0.028
PM10 (Filterable) 4.64 0.024
PM2.5 (Filterable) (RAP) 4.64 0.024

[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:
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Emission Point: HMAP Baghouse Exhaust Stack Pollutant Test Frequency PM10 # (virgin & RAP) PM2.5 # (virgin & RAP) # Test every three years or sooner if directed by the Director. Tests may be required if the source is suspected to be in violation with other conditions of this AO. Compliance testing shall not be required for both virgin and recycled materials during the same testing period. Testing shall be performed for the product being produced during the time of testing. [R307-165] Status: In Compliance. A Method 5 stack test was performed for PM on August 25-26, 2023. The DAQ review of the test indicated particulate matter measured at 0.00870 gr/dscf and 2.05576 lb/hr (DAQC-936-23). See Condition Status of II.B.2.e.8 for more information.

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.
The pretest conference shall include representation from the owner/operator, the tester, and the
Director. 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. The emission point shall be designed to conform to
the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the
Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and
Health Administration (MSHA) approved access shall be provided to the test location.

[R307-165]

II.B.2.e.3 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 condensibles shall also be tested using the
method specified by the Director. All particulate captured shall be considered PM10 .

For stacks in which liquid drops are present, methods to eliminate the liquid drops should be
explored. If no reasonable method to eliminate the drops exists, then the following methods shall
be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The condensable
particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other
EPA-approved testing method, acceptable to 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 the
EPA document, AP-42, or other data acceptable to the Director. The condensable particulate
emissions shall not be used for compliance demonstration, but shall be used for inventory
purposes.

[R307-401]

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II.B.2.e.4 PM2.5

The following methods shall be used to measure filterable particulate emissions: 40 CFR 51,
Appendix M, Method 201A, or other EPA-approved testing method, as acceptable to the
Director. All particulate captured shall be considered PM2.5. The portion of the filterable
particulate emissions considered PM2.5 shall be based on information in Appendix B of the fifth
edition of the EPA document, AP-42, or other data acceptable to the Director. The filterable
particulate emissions shall be used for compliance demonstration.

The following methods shall be used to measure condensable particulate emissions: 40 CFR 51,
Appendix M, Method 202, or other EPA-approved testing method, as acceptable to the Director.
The condensable particulate emissions shall not be used for compliance demonstration, but shall
be used for inventory purposes.

[R307-401]

II.B.2.e.5 Volumetric Flow Rate

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

[R307-401]

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]

II.B.2.e.7 New Source Operation

For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the production rate listed in this AO. If the maximum AO allowable production
rate has not been achieved at the time of the test, the following procedure shall be followed:

A. Testing shall be at no less than 90% of the production rate achieved to date.

B. If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This
new allowable maximum production rate shall remain in effect until successfully tested
at a higher rate.

C. The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate
(110% of the new rate) will then be allowed if the test is successful. This process may be
repeated until the maximum AO production rate is achieved.

[R307-401]

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II.B.2.e.8 Existing Source Operation

For an existing source/emission point, the production rate during all compliance testing shall be
no less than 90% of the maximum production achieved in the previous three (3) years.

[R307-401]

Status: In Compliance. The stack test was performed by Montrose Air Quality Services
and the test was submitted on September 28, 2022. The AO requirements for testing were
deemed compliant as per the DAQ memo DAQC-936-23. The testing protocol was
submitted in April of 2022. The next stack test will be due during the calendar year of 2025.

II.B.3 Haul Road and Fugitive Dust Requirements

II.B.3.a All unpaved roads and other unpaved operational areas that are used by mobile equipment shall
be water sprayed and/or chemically treated to control fugitive dust. The application of water or
chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to
maintain the surface material in a damp/moist condition unless it is below freezing. The opacity
shall not exceed 20% on site and 10% at the property boundary during all times the areas are in
use. If chemical treatment is to be used, the plan must be approved by the Director. [R307-401-8]

II.B.3.a.1 Records of water or chemical treatment shall be kept for all periods when the plant is in
operation. The records shall include the following items:

A. Date

B. Number of treatments made, dilution ratio, and quantity

C. Rainfall received, if any, and approximate amount

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

[R307-401-8]

Status: In Compliance. No visible emissions were observed coming from the unpaved
roads and operational areas. A watering truck was observed operating during the site
inspection. Watering records are maintained on site and were viewed at the time of
inspection to contain the required information.

II.B.3.b The haul road speed limit of 15 mph shall be posted, at a minimum, at the beginning of the haul
road where it is clearly visible. [R307-401-8]

Status: In Compliance. There is a 10 mph sign at the entrance to the pit.

II.B.3.c Control of fugitive dust emissions from disturbed or stripped areas shall be required at all times
for the duration of the project/operation. [R307-309]

Status: In Compliance. No visible emissions were observed from the disturbed and
stripped areas during the inspection. A Fugitive Dust Control Plan for this facility was
submitted on May 7, 2021.

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II.B.3.d Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas
shall not exceed 20% opacity on site and 10% opacity at the property boundary. [R307-309]

II.B.3.d.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-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.
[R307-309]

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

II.B.3.e The haul road shall be paved and shall be periodically swept or sprayed clean as dry conditions
warrant or as determined necessary by the Director. [R307-401-8]

II.B.3.e.1 Records of cleaning paved roads shall be made available to the Director or the Director's
representative upon request. [R307-401-8]

Status: In Compliance. Jacketta, a third-party sweeping service, sweeps the paved roads
on a weekly basis. See the attached sweeping logs.

II.B.3.f The storage piles shall be watered to minimize generation of fugitive dusts, as dry conditions
warrant or as determined necessary by the Director. [R307-401-8]

Status: In Compliance. No fugitive dust was observed coming from the storage piles.
Source contacts stated that these are watered if fugitive dust is observed.

II.B.4 Fuel Requirements

II.B.4.a The owner/operator shall use only #1 or #2 fuel oil as a primary fuel for aggregate processing
equipment and propane, natural gas, fuel oil or on-specification used oil as fuel in the asphalt
plant. [R307-401-8]

Status: In Compliance. ULSD fuel is used for off-road equipment. Aggregate equipment is
operated on line power. The HMA plant is operated on line power and natural gas.

II.B.4.b The sulfur content of any fuel oil or diesel burned shall not exceed:

A. 0.50 percent by weight for fuels used in the asphalt plant.

B. 15 ppm by weight for diesel fuels consumed in all other equipment.

[R307-401-8]

II.B.4.b.1 The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of used oil shall be either by the owner/operators own testing or test reports from
the used oil fuel marketer. Certification of other fuels shall be either by the owner/operators own
testing or test reports from the fuel marketer. [R307-203]

Status: Not Applicable for A, as the plant is not run on any diesel fuel. In Compliance for
B, as ULSD fuel used for the miscellaneous off-road equipment is provided by Chevron
Products Co. and Phillips 66. See the attached delivery tickets.
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II.B.4.c Sources burning used oil for energy recovery shall comply with the following:

The concentrations/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight

2) Cadmium 2 ppm by weight

3) Chromium 10 ppm by weight

4) Lead 100 ppm by weight

5) Total halogens 1,000 ppm by weight

6) Flash Point shall not be less than 100°F

[R307-401-14]

II.B.4.c.1 The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation. Records shall be made available to the Director or the Director's
representative upon request. The records shall include the three-year period prior to the date of
the request. [R307-401-8]

II.B.4.c.2 Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis. [R307-401-8]

II.B.4.c.3 Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the boiler. The oil shall be tested for
halogen content by ASTM Method D-808-81, EPA Method 8240 or Method 8260 before used oil
fuel is transferred to the boiler tank and burned. [R307-401-8]

Status: Not Applicable for II.B.4.c through II.B.4.c.3. The asphalt plant no longer burns
used oil.

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. Monthly nozzle spray inspections were reviewed at the time of inspection. The
initial Method 9 observations were performed on September 6, 2012. Copies of the observations were
attached to the inspection memo DAQC-1326-21.

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

Status: In Compliance. This subpart is satisfied by compliance with Condition II.B.1.b for opacity
limits and Conditions II.B.2.e through II.B.2.e.8 for stack testing requirements.

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. ULSD fuel used for the miscellaneous off-road equipment is provided by
Chevron Products Co. and Phillips 66. See the attached delivery tickets.

Stationary Sources [R307-210]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirements NSPS (Part 60) Subparts OOO and I. See Section III above for more information.

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

Status: In Compliance. Minimal emissions were observed from a conveyor transfer point at the time
of inspection. See attached VEO Form for additional information.

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

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

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

Status: In Compliance. Minimal emissions were observed from a conveyor transfer point at the time
of inspection. See attached VEO Form for additional information.

EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Staker Parson Companies – Keigley Quarry.
A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN124440009-18, dated October 1, 2018, is provided. PTE are supplied for supplemental purposes
only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Carbon Monoxide 32.55 N/A
Nitrogen Oxides 13.95 2.97725
Particulate Matter - PM10 73.75 18.74309
Particulate Matter - PM2.5 29.05 2.43396
Sulfur Dioxide 15.21 0.38933
Volatile Organic Compounds 8.00 3.6643

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Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Acetaldehyde (CAS #75070) 660 N/A
Acrolein (CAS #107028) 20 N/A
Benzene (Including Benzene From Gasoline) (CAS #71432) 200 89.32
Ethyl Benzene (CAS #100414) 120 N/A
Formaldehyde (CAS #50000) 1560 709.96
Generic HAPs (CAS #GHAPS) 300 N/A
Hexane (CAS #110543) 460 N/A
Naphthalene (CAS #91203) 320 N/A
Toluene (CAS #108883) 1460 N/A
Xylenes (Isomers And Mixture) (CAS #1330207) 100 N/A

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN124440009-18, dated
October 1, 2018, the overall status is: Out of Compliance. See
Section II for more details. No compliance action is recommended at
this time.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: New AO DAQE-AN124440011-24 issued on August 13, 2024.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO form, email correspondence, aggregate production, asphalt
production, magnehelic checks, magnehelic calibration, HMA
temperature wheels, sweeping records, ULSD delivery tickets
Daniel Riddle <[e-mail]>
12444 - Follow up to air quality inspection
6 messages
Daniel Riddle <[e-mail]>Fri, Jul 26, 2024 at 11:34 AM
To: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>,
[e-mail]
Jeffrey and Elliott,
Today I met with Cole at the Genola Staker Parson facility for an air quality inspection. Here are the records I require to
complete my inspection report:
From AO DAQE-AN124440009-18:
Condition II.B.1.a - production totals from July 2023 - June 2024
A) tonnage of aggregate
B) tonnage of asphalt
C) verification that no more than 500 tons of asphalt was produced in any hour
Condition II.B.2.c - pressure drop readings from the baghouse on the asphalt plant as well as record of an annual
calibration of the gauge
Condition II.B.2.d - record showing that asphalt mix temperature is monitored at least every 15 minutes
Condition II.B.3.e - record of sweeping paved haul roads
Please provide these records by August 2, 2024. Thanks and let me know if you have any questions.
Best,
Daniel
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9/10/24, 10:54 AM State of Utah Mail - 12444 - Follow up to air quality inspection
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---------- Forwarded message ----------
From: Daniel Riddle <[e-mail]>
To: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>,
[e-mail]
Cc:
Bcc:
Date: Fri, 26 Jul 2024 11:34:39 -0600
Subject: 12444 - Follow up to air quality inspection
Jeffrey and Elliott,
Today I met with Cole at the Genola Staker Parson facility for an air quality inspection. Here are the records I require to
complete my inspection report:
From AO DAQE-AN124440009-18:
Condition II.B.1.a - production totals from July 2023 - June 2024
A) tonnage of aggregate
B) tonnage of asphalt
C) verification that no more than 500 tons of asphalt was produced in any hour
Condition II.B.2.c - pressure drop readings from the baghouse on the asphalt plant as well as record of an annual
calibration of the gauge
Condition II.B.2.d - record showing that asphalt mix temperature is monitored at least every 15 minutes
Condition II.B.3.e - record of sweeping paved haul roads
Please provide these records by August 2, 2024. Thanks and let me know if you have any questions.
Best,
Daniel
Daniel Riddle <[e-mail]>Tue, Aug 6, 2024 at 12:02 PM
To: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
Elliott - Do you have these records available?
[Quoted text hidden]
Johnson, Elliott (Staker & Parson Companies) <[e-mail]>Wed, Aug 7, 2024 at 1:29
PM
To: Daniel Riddle <[e-mail]>
MY apologies for the delayed response. I just got back from vacation last night. Do you have an address for
the facility and I will begin to gather the data you’re requesting?

Elliott Johnson
Region Environmental Manager
Mountain West Region

CRH Americas Materials, Inc.
89 W 13490 S
Draper, UT 84020
9/10/24, 10:54 AM State of Utah Mail - 12444 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r5294037041237201222&simpl=msg-a:r-95059602171370…2/3

C [phone]
E [e-mail]

www.crhamericasmaterials.com

From: Daniel Riddle <[e-mail]>
Sent: Tuesday, August 6, 2024 12:02 PM
To: Johnson, Ellio (Staker & Parson Companies) <[e-mail]>
Subject: [EXT] Re: 12444 - Follow up to air quality inspecon

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.
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moins que vous ne connaissiez l'expéditeur du courriel et savez que le contenu est sécuritaire. Si vous pensez qu’il s’agit d’un
courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
Daniel Riddle <[e-mail]>Thu, Aug 22, 2024 at 10:23 AM
To: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
No worries - I've also been a bit behind. I thought I had responded to this message. This is for your facility at 1270 South
West Mountain Highway in Genola, Utah. The Keigler Quarry.
[Quoted text hidden]
Daniel Riddle <[e-mail]>Thu, Aug 29, 2024 at 9:16 AM
To: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
Elliott - any updates on the status of these records?
[Quoted text hidden]
9/10/24, 10:54 AM State of Utah Mail - 12444 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r5294037041237201222&simpl=msg-a:r-95059602171370…3/3
Daniel Riddle <[e-mail]>
Keigley inspection documents
9 messages
Rose, Chris (Staker & Parson Companies) <[e-mail]>Fri, Aug 30, 2024 at 4:32 PM
To: Daniel Riddle <[e-mail]>
Cc: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
Hello Daniel,

I wanted to let you know that I’m the main environmental representative for the Keigley site in Genola, UT that you
inspected on 7/26/24. I apologize for the delay in this response, it’s our internal audit season so I only get a couple days a
week in front of my desk. In addition, I’ve been several DAQ info requests across the state. I’ve included our rolling 12
production info for Keigley in this email to show that I’m still going on this. I have requests for info out to our plant
managers, I should hear back very soon.

Let me know if you have any questions,

Christopher Rose
Environmental Specialist
West Division

Staker Parson
A CRH COMPANY
89 West 13490 South
Draper, Utah 84020

C [phone]
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Daniel Riddle <[e-mail]>Wed, Sep 4, 2024 at 11:50 AM
To: "Rose, Chris (Staker & Parson Companies)" <[e-mail]>
Cc: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
No problem, thank you for the update. Keep me posted as you receive more records. I've not always been sure whom to
contact at Staker-Parson for records requests, but I'll cc you on all future emails.
[Quoted text hidden]
Rose, Chris (Staker & Parson Companies) <[e-mail]>Thu, Sep 5, 2024 at 7:46 PM
To: Daniel Riddle <[e-mail]>
Cc: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
Daniel,

Thanks for your patience, I’ve compiled most of the info you requested.

We measure magnahelic gauge pressure drops on every shift, and I’ve attached a recent record of our shift
readings. I’ve also attached our latest magnahelic gauge calibration- we calibrate the gauge annually, and it
looks like we’re a couple months overdue (last reading was May 2023). That being said, I’ve scheduled a
time to calibrate it very soon, and I’ve attached the last few year’s calibrations so you can see that we’ve
historically stuck to it.

Next, we track temperature constantly on a daily basis using a compass-type temp graph. Each day we file
the temp graph along with the day’s production information. Since it’s much more complicated to pull up the
temp info digitally, I’ve attached some photos I took on site of recent daily temperature charts as an example
of how we keep track of temperature.

Next, item II.B.3.e of the referenced AO states “The haul road shall be paved and shall be periodically swept
or sprayed clean as dry conditions
warrant or as determined necessary by the Director.” We don’t use a sweeper truck at Keigley, as the paved
haul road is watered clean as the permit allows.

Lastly, I’ll have to calculate the constant TPH of the plant and get back to you. It’s not a metric we typically
track, so it’ll take a longer to find that. However, the plant’s max production capacity is only 400 TPH and
due to production constraints, the plant can’t produce any more than around 350-370 TPH. Typical
production is closer to 275-300 TPH.

Again, thanks for your patience on this. I hope this can help both of us close out the inspection. Please let
me know if you have any comments or questions that I can help clarify.

9/10/24, 10:54 AM State of Utah Mail - Keigley inspection documents
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1808853551754361217&simpl=msg-f:18088535517543612…2/7
Sincerely,

Christopher Rose
Environmental Specialist
West Division

Staker Parson
A CRH COMPANY
89 West 13490 South
Draper, Utah 84020

C [phone]
E [e-mail]

From: Daniel Riddle <[e-mail]>
Sent: Wednesday, September 4, 2024 11:50 AM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Cc: Johnson, Ellio (Staker & Parson Companies) <[e-mail]>
Subject: [EXT] Re: Keigley inspecon documents

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.
[Quoted text hidden]
ATTENTION: Ce courriel vient de l'exterieur de l'entreprise. Ne cliquez pas sur les liens, et n'ouvrez pas les pièces jointes, à
moins que vous ne connaissiez l'expéditeur du courriel et savez que le contenu est sécuritaire. Si vous pensez qu’il s’agit d’un
courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
7 attachments
9/10/24, 10:54 AM State of Utah Mail - Keigley inspection documents
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Rose, Chris (Staker & Parson Companies) <[e-mail]>Fri, Sep 6, 2024 at 4:16 PM
To: Daniel Riddle <[e-mail]>
Cc: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
Daniel- a correction to my previous email: after a site visit today, I confirmed that we do in fact sweep our
paved roads, it’s just through Jacketta, a third party sweeping service. We sweep the paved roads on a
weekly basis. I’ve attached photos of examples of some Jacketta receipts going back several months.

Sorry for the initial confusion.
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Daniel Riddle <[e-mail]>Mon, Sep 9, 2024 at 11:59 AM
To: "Rose, Chris (Staker & Parson Companies)" <[e-mail]>
Cc: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
Chris - thanks for sending all of these records.
Just to confirm over email, the HMA plant is only run by line power and natural gas? None of the alternative fuels
(propane, diesel, used oil) listed in Condition II.B.4.a are utilized?
Diesel fuel is used for off-road equipment. Could you send me a fuel invoice showing verification of ULSD?
[Quoted text hidden]
Rose, Chris (Staker & Parson Companies) <[e-mail]>Mon, Sep 9, 2024 at 4:06 PM
To: Daniel Riddle <[e-mail]>
Cc: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
Daniel,

Yes, our HMA is only run off lined in power and natural gas. I have our procurement manager pulling the last
few fuel receipts for our equipment fueling station. This receipt will show that we only use ULSD in our
equipment.

Also, I wanted to make sure you saw my follow up email about the sweeping logs.

Let me know if you have any questions,

Christopher Rose
Environmental Specialist
West Division

Staker Parson
A CRH COMPANY
89 West 13490 South
Draper, Utah 84020

9/10/24, 10:54 AM State of Utah Mail - Keigley inspection documents
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1808853551754361217&simpl=msg-f:18088535517543612…6/7
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Daniel Riddle <[e-mail]>Mon, Sep 9, 2024 at 5:39 PM
To: "Rose, Chris (Staker & Parson Companies)" <[e-mail]>
Thank you, send that over when you can. I got the sweeping email and everything looks good with that requirement.
[Quoted text hidden]
Rose, Chris (Staker & Parson Companies) <[e-mail]>Tue, Sep 10, 2024 at 7:48 AM
To: Daniel Riddle <[e-mail]>
Daniel,

Here are our last three fuel receipts showing ULSD.

Let me know if you need anything else.
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Daniel Riddle <[e-mail]>Tue, Sep 10, 2024 at 10:53 AM
To: "Rose, Chris (Staker & Parson Companies)" <[e-mail]>
Got it, thank you!
[Quoted text hidden]
9/10/24, 10:54 AM State of Utah Mail - Keigley inspection documents
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