DAQ-2024-010983

1
DAQC-CI144460002-24
Site ID 14446 (B1)

MEMORANDUM

TO: FILE – TM CRUSHING, LLC – Talons Cove Aggregate Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: September 24, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: August 14, 2024

SOURCE LOCATION: The Intersection of Mount Airey Drive and SR 73
Eagle Mountain, UT 84005

DIRECTIONS: Check in at the scale house located on the east side of Mount
Airey Drive.

SOURCE CONTACTS: Nicki Coates, Scale Manager
801-425-2539, [e-mail]

OPERATING STATUS: The south operation (TC-1) was down for maintenance. The
north operation (TC-2) was operating.

PROCESS DESCRIPTION: TM Crushing, LLC operates an aggregate processing plant in
Eagle Mountain, Utah County. TM Crushing, LLC has primary
plant equipment, secondary plant equipment, independent plant
equipment, and mobile plant equipment. The primary plant,
secondary plant, independent plant, and mobile plant equipment
use jaw crushers, an impact crusher, cone crushers, screens,
wash plant, a trommel, and off-highway mobile equipment. TM
Crushing, LLC also conducts occasional blasting to generate the
aggregate for their plant.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN144460004-19, dated
August 5, 2019

NSPS (Part 60) IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
NSPS (Part 60) OOO: Standards of Performance for Nonmetallic
Mineral Processing Plants,
MACT (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

TM Crushing, LLC
Talons Cove Aggregate Plant

P.O. Box 437 The Intersection of Mount Airey Drive and SR 73
Lehi, UT 84043 Eagle Mountain, UT 84005

SIC Code: 1429: (Stone, Crushed & Broken, NEC)

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: Out of Compliance with Conditions I.2 and I.3. One unpermitted generator engine
was observed powering operations at TC-2 (north operation). This was discovered and
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addressed with a Compliance Advisory (DAQC-1271-23) during a previous inspection.
Some of the limits in the current AO appeared to be out of compliance. The source has
submitted a Notice-of-Intent (NOI) to include the unpermitted equipment and updated
limitations on the new AO. The remaining conditions were reviewed with the source and
appeared to be in compliance. The 2023 Emission Inventory was submitted by the required
date.

Section II: SPECIAL PROVISIONS

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

II.A.1 Talons Cove Facility
An aggregate processing plant

II.A.2 Jaw Crushers
One (1) jaw crusher rated at 600 tph, manufactured 1977, not subject to NSPS Subpart OOO *
One (1) jaw crusher rated at 600 tph, manufactured 1998, subject to NSPS Subpart OOO ** (new)

* Within the primary plant.
** Within the secondary plant.

II.A.3 Impact Crusher
One (1) impact crusher rated at 600 tph, manufactured 2018, subject to NSPS Subpart OOO * (new)

* Within the primary or secondary plant

II.A.4 Cone Crushers
One (1) cone crusher rated at 400 tph, manufactured in 2000 *
One (1) cone crusher rated at 350 tph, manufactured in 1996 *
One (1) cone crusher rated at 350 tph, manufactured in 2005 ** (new)
All cone crushers are subject to NSPS Subpart OOO

* Within the primary plant
**Within the secondary plant

II.A.5 Screens
Two (2) 6' x 20', manufactured in 2002 *
Two (2) 8' x 20',manufactured in 2002 ** (new)
All screens are subject to NSPS Subpart OOO

* Within the primary plant
**Within the secondary plant

II.A.6 Wash Plant
One (1) Wash Plant rated at 450 tph ** (new)

**Within the secondary plant

II.A.7 Mobile Crushers/Screeners
One (1) 400 tph track mounted jaw crusher
One (1) 400 tph portable impactor/screen plant
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One (1) 300 tph track mounted trommel plant
One (1) 250 tph track mounted screen plant

All this equipment is subject to NSPS Subpart OOO
These are located in the independent production plant.

II.A.8 Combination Crusher/Screener
One (1) 400 tph closed-circuit combination impact crusher and screening plant
NSPS Subpart OOO

This is located in the portable production plant.

II.A.9 Associated Conveyors/Stackers
Conveyor transfer/drop points
NSPS Subpart OOO

II.A.10 Off-Highway Mobile Equipment
Associated loaders, dozers, drills, etc. (for information only)

Status: Out of Compliance. One unpermitted 1,150hp generator engine was powering
operations at TC-2. This was discovered and initially addressed during a previous
inspection. No other unapproved equipment was observed.

Additional Information:
II.A.3: The impact crusher is still on site but not operating.
II.A.7: The mobile crushing equipment is currently not on site.

II.B Requirements and Limitations

II.B.1 Site-Wide Requirements and Limitations
II.B.1.a The following production limits shall not be exceeded: A. 1,500,000 tons of aggregate processed through the primary plant per rolling 12-month period B. 1,500,000 tons of aggregate processed through the secondary plant per rolling 12-month period C. 100,000 tons of aggregate processed through the track mounted jaw crusher per rolling 12-month period D. 150,000 tons of aggregate processed through the track mounted screen plant per rolling 12-month period E. 150,000 tons of aggregate processed through the track mounted trommel plant per rolling 12-month period F. 400,000 tons of aggregate processed through the portable impactor/screen plant per rolling 12-month period G. 350,000 tons of bank run materials loaded per rolling 12-month period. [R307-401-8]
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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 20th day of each month using data from the previous 12 months. Records
of production shall be kept for all periods when the plant is in operation. Production shall be
determined by belt scale records, scale house records, or bucket scale records. The records of
production shall be kept on a daily basis. [R307-401-8]

Status: In Compliance. Calculations are made according to this condition. Refer to the
attachments for more details. The rolling 12-month totals from August 2023 – July 2024
are as follows:
A. 348,688 tons
B. 444,843 tons
C. 0 tons
D. 0 tons
E. 0 tons
F. 0 tons
G. 104,659 tons

II.B.1.b The owner/operator shall not allow visible emissions to 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
E. All other points - 20% opacity. [40 CFR 60 Subpart OOO, R307-312, R307-401-8]

II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [40 CFR 60 Subpart OOO]

Status: In Compliance. Minimal visible emissions from TC-2 were observed. TC-1 was
down for maintenance. Observations were taken according to EPA Method 9. Refer to the
VEO form in the attachments for more details.

II.B.1.c The owner/operator shall conduct an initial performance test for all crushers, screens, and
conveyor transfer points listed as new in this AO and subject to 40 CFR 60 Subpart OOO within
60 days after achieving the maximum production rate but not later than 180 days after initial
start-up. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO.
Records of initial performance tests shall be kept and maintained with the equipment for the life
of the equipment. [40 CFR 60 Subpart OOO]

II.B.1.c.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner/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.c.2 The owner/operator shall submit written reports to the Director of the results of all
performance tests conducted to demonstrate compliance with the standards set forth in 40 CFR
60.672. [40 CFR 60 Subpart OOO]

Status: In Compliance. Initial performance tests were conducted for the new equipment.
This was determined during a previous inspection (DAQC-1321-21). No applicable
equipment has changed.
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II.B.2 Conditions on Fugitive Dust Emissions.

II.B.2.a Within 30 days of the date of this AO, the owner/operator shall submit a FDCP in electronic or
written format. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan
Permit Application Website. If a written FDCP is completed, it shall be submitted to the
Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the
FDCP for control of all fugitive dust sources associated with the Talons Cove pit. [R307-309-6]

Status: In Compliance. A FDCP was submitted October 17, 2013. The source maintains a
copy of this plan and controls fugitive dust according to the requirements set forth in the
plan.

II.B.2.b 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.b.1 Visible emission determinations 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. [R307-401-8]

Status: In Compliance. Visible emissions from the haul roads and fugitive dust sources did
not exceed the limits in this condition. Refer to the VEO form in the attachments for more
details.

II.B.2.c The owner/operator shall not exceed 2,808 hours of bulldozing per 12-month period.
[R307-401-8]

II.B.2.c.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
of hours of operation shall be kept for all periods when the plant is in operation. Hours of
operation shall be determined by supervisor monitoring of the operation and recorded in a log
book. [R307-401-8]

Status: In Compliance. The bulldozer operating hours are calculated according to this
condition. The rolling 12-month total operating hours were 627 hours. Refer to the
attachments for more details.

II.B.2.d The following unpaved haul road lengths shall not exceed

A. 0.50 mile in length for unpaved haul road
B. 0.10 miles in length for loader operating area

The owner/operator shall pave the main haul road at the beginning of the property. The paved
haul road shall be at least 0.33 mile in length. [R307-401-8]

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II.B.2.d.1 Compliance shall be determined through GPS measurements or aerial photographs.
[R307-401-8]

Status: Out of Compliance. The unpaved haul road lengths exceed the limitations set forth
in the current AO. A previous inspection memo indicated that these length limitations were
meant to be averages that NSR mistook for limits. The NOI submitted by the source
includes updated road length limitations. Records provided by the source after the
inspection show the current unpaved haul road lengths do not exceed the limitations that
will be in the new AO. Refer to the attachments for haul road lengths. No action
recommended.

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

II.B.2.e.1 Records of water application shall be kept for all periods when the plant is in operation. The
records shall include the following items:

A. Date and time treatments were made
B. Number of treatments made and quantity of water applied
C. Rainfall amount received, if any
D. Records of temperature, if the temperature was above freezing. [R307-401-8]

Status: In Compliance. Water is applied as necessary to control fugitive dust from the haul
roads, storage piles, and disturbed areas. The area was wet upon arrival and a water truck
was actively spraying during the inspection. Watering records are kept according to this
condition and were viewed during the site visit.

II.B.2.f Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive dust emissions:

A. All crushers
B. All screens
C. All conveyor transfer points

The sprays shall operate to meet the opacity limits listed in this AO. [R307-401-8]

Status: In Compliance. Water sprays are installed at the required points and operate as
needed to meet the opacity limits in this AO.

II.B.2.g The owner/operator shall periodically sweep or spray clean any section of paved roads on site to
ensure the opacity limits in this AO are not exceeded. The owner/operator shall use a chemical
suppressant and water application on the unpaved haul roads to ensure the opacity limits in this
AO are not exceeded. The owner/operator shall apply gravel to the unpaved haul roads.
[R307-401-8]

Status: In Compliance. Paved roads are periodically cleaned and swept to ensure the
opacity limits are not exceeded. Gravel has been applied to the unpaved haul roads and
water is applied as needed to reduce dust.

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II.B.2.h The owner/operator shall not exceed the following limits:
A. 52 blasting episodes per 12-month period
B. 3.7 tons of ANFO per blasting episode. [R307-401-8]

II.B.2.h.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. The
number of blasting episodes and the amount of ANFO per blasting episode shall be determined
by supervisor monitoring of the operation and recorded in a log book. [R307-401-8]

Status: Out of Compliance. The source used more than the permitted tons of ANFO per
blasting episode. A previous inspection memo indicated that these values were meant to be
averages that NSR mistook for limits. The NOI submitted by the source includes updated
limitations. The number of blasting episodes did not exceed 52 for the rolling 12-month
period. Refer to the attachments for more details. No action recommended.

II.B.2.i The owner/operator shall not exceed the following limits:

A. 10 acres of storage piles
B. 27 acres of disturbed areas. [R307-401-8]

II.B.2.i.1 The owner/operator shall measure the total storage piles and the disturbed areas at least once
every six months and shall maintain a record of the total acres of the storage piles and the total
acres of disturbed areas. To determine the acres of the storage piles and disturbed areas on site,
the owner/operator shall use a handheld GPS unit and travel around the base of each storage piles
and disturbed area on site to calculate the area of each storage piles and disturbed area on site.
Records of the total acres of the storage piles and disturbed areas shall contain the following:

A. Date of measurements
B. Size of each storage pile and disturbed area on site
C. Total acres of all storage piles
D. Total acres of all disturbed areas. [R307-401-8]

Status: Out of Compliance. The current stockpile acreage and disturbed area acreage
exceed the limitations in the current AO. The NOI submitted by the source includes
updated limitations. Refer to the attachments for more details. The last measurement was
taken October 19, 2023. The source was notified that measurements shall be taken every six
months according to this condition. No action is recommended at this time.

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 Observed. The source has submitted a NOI to include this engine as stationary equipment on an updated AO. This requirement was not evaluated during the inspection. The diesel generator engine was manufactured in 2013.
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NSPS (Part 60) OOO: Standards of Performance for Nonmetallic Mineral Processing Plants

Status: In Compliance. Compliance with this subpart is satisfied by compliance with conditions II.B.1.c,
II.B.1.c.1, II.B.1.c.2, and II.B.2.f of the AO.

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

Status: Not Observed. The source has submitted a NOI to include this engine as stationary equipment
on an updated AO. This requirement was not evaluated during the inspection. The source confirmed
that only ultra-low sulfur diesel is used in the generator engine. This was determined by a fuel purchase
invoice provided by the supplier.

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. The source confirmed that only ultra-low sulfur diesel is used in the
generator engine. This was determined by a fuel purchase invoice provided by the supplier.

Stationary Sources [R307-210]

Status: In Compliance. This area source rule is applicable per 40 CFR 60 Subpart OOO. Subpart
IIII was not evaluated at the time of the inspection.

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

Status: Not Observed. The generator engine applicable to 40 CFR 63 Subpart ZZZZ was not
evaluated at the time of inspection. Refer to the Applicable Federal Requirements section for more
details.

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

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with AO
condition II.B.1.b.

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

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with AO
condition II.B.1.b and maintaining a Fugitive Dust Control Plan.

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

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with AO
condition II.B.1.b.

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EMISSION INVENTORY:
Listed below are the 2023 Actual Emissions Inventory provided from TM Crushing, LLC – Talons Cove
Aggregate Plant. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN144460004-19, dated August 5, 2019, is provided. PTE are supplied for supplemental
purposes only.
Criteria Pollutant PTE tons/yr Actuals tons/yr
Carbon Monoxide 6.46 1.99
Nitrogen Oxides 1.64 7.51
Particulate Matter - PM10 59.86 23.03
Particulate Matter - PM10 (Fugitives) 53.07 4.598
Particulate Matter - PM2.5 7.96 2.47
Particulate Matter - PM2.5 (Fugitives) 6.64 0.98
Sulfur Dioxide 0.19 1.36

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr

PREVIOUS ENFORCEMENT
ACTIONS: Compliance Advisory (DAQC-1271-23) for an unpermitted
generator engine operating at TC-2. An Early Settlement
Agreement will soon be issued to resolve the listed Compliance
Advisory.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN144460004-19,
dated August 5, 2019, the overall status is: Out of Compliance.
An unpermitted generator engine still operates at TC-2. This was
observed during the previous inspection and a Compliance
Advisory was issued. An Early Settlement Agreement will be
issued to resolve the listed Compliance Advisory. The haul road
length limitations, disturbed area acreage limitations, and
blasting limitations were all out of compliance with the current
AO. TM Crushing, LLC has submitted a NOI to NSR to receive
an updated AO and resolve the compliance issues. For these
reasons, no action is currently recommended. The remaining
conditions appeared to be in compliance. Records were current
and available for review during the inspection and via email.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect once the new AO has been issued. Evaluate 40 CFR 60
Subpart IIII and 40 CFR 63 Subpart ZZZZ. Verify stockpile and
disturbed areas are measured every six months according to
Condition II.B.2.i.1.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, Email Correspondence
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
Page_of_
EPA METHOD 9 -VISIBLE EMISSION OBSERVATION FORM
Source Name:
Street Address: C\S
City/County: Sa~ V«< {YlouJ}tqi 11 1/ UM Vl
Phone: o()\-L\2-5= ·z..S~
Site ID: \ l\v\~ lo
Facility: A~~ e¥:k Pa'J.
Equipment/Process: (rurhcS r Sc/U/1 s I LQl)Yo..(orS
Control Equipment: UJ(tt,/ C,\.,.eM\cq\ A-?f>lacob'c/)
Emission Point: 6'.,,lv<.
Sky Conditions: Clear fl(] Partly Cloudy [ ] Overcast [ ]
Precipitation: No [t\] Yes [ ] _____ _
Wind: Direction: ___ Speed: ___ mph
Ambient Temp: ___ °F RH: ___ %
Height Relative to Observer: ---
Distance From Observer: ---
Condensed Water Vapor Present: No [ ] Yes [ ]
Attached [ ] Detached [ ]
Length of Condensed Water Vapor Plume: ______ _
Background: ________________ _
Sketch process unit: indicate observer position relative to
source; indicate potential emission points and/or actual
emission points.
0
Dr•wnonharrow
• observer
~
Sun ♦ Wind
Observer Position X
Emission Point with Plume ( ...... )...___,(
Observer's Signature:
Distrib: white-file; canary-inspector; -owner/operator
OBSERVATION DATE: 4IJJi}JI!, 'f;) /4 /Z'i
\ \', 0--1 Sta rt time: __.__ a...._;J...J;;..;;;__ Stop time: \ t.'$b
sec 0 15 30 45 min
1
2 ,/ '-;;,.. ~ 1..,..,--"
3 /,/ --V ~
A_/
I 4
5 /
6
I 7 -n:-\ U\-C,-;, ~h.nbl
' I
8
9
10
1 1
12
COMMENTS:
'Tc..-\ \..vv, cb~vo ~r Mci ,"kl)CV)c.e... •
,c.--z.. )>~,CV\ ~er<"'!Hq u?Y' c1rr-,vq I CY1t{
I have received a copy of these observations:
SIGNATURE: zn-d ~'':!,
Printed Name: /11,ch.oe..( flufc~y-S
Title: S c/rerv/-s-or-
Connor Kijowski <[e-mail]>
Air Quality Inspection - Records Request for TM Crushing Talons Cove
5 messages
Connor Kijowski <[e-mail]>Wed, Aug 14, 2024 at 3:28 PM
To: Nicki Coates <[e-mail]>
Good Afternoon Nicki,
It was great to meet with you and Mike to show me around the site. To complete the inspection, there are some records required. From the Approval Order (attached for your reference):
II.B.1.a: Rolling 12-month (August 2023 - July 2024) production totals for the primary plant, secondary plant, track mounted jaw crusher, track mounted screen, track mountain trommel,
portable impactor/screen, bank run material
II.B.2.c: Bulldozer operating hours for the rolling 12-month period
II.B.2.d: Unpaved haul road length and loader operating area length
II.B.2.h: Blasting episodes and tons of ANFO per blasting period for the 12-month period
II.B.2.i: Storage pile and disturbed acreage area -- record of the last measurement
Please provide these records by no later than August 26, 2024. Let me know if you have any questions.
Thank you,
--Connor Kijowski
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
DAQE-AN144460004-19.pdf
119K
Nicki Coates <[e-mail]>Wed, Aug 21, 202
To: Connor Kijowski <[e-mail]>Cc: Joe Johnson <[e-mail]>
Connor,

Below you will find the records you requested to complete the Talons Cove inspections. I will be out of the office until August 28th, but I have added Joe Johnson to the email if you have questneed to be addressed before I return.

Thanks
Nicki Coates

II.B.1.a: Rolling 12-month (August 2023 - July 2024) production totals for the primary plant, secondary plant, track mounted jaw crusher, track mounted screen, track mountain trommel, portab
impactor/screen, bank run material

23-Aug 23-Sep 23-Oct 23-Nov 23-Dec 24-Jan 24-Feb 24-Mar 24-Apr 24-May 24-Jun 24-Jul TO
Qty Qty Qty Qty Qty Qty Qty Qty Qty Qty Qty Qty Qty
Bank Run 8,839.74 3,230.1 35,320.72 22,879.98 711.00 5,619.95 8,486.97 7,191.19 5,518.21 861.99 526.20 5,473.38 10
TC2 66,771.31 34,101.95 37,439.74 32,922.85 24,287.61 20,844.05 42,793.76 38,126.33 43,908.25 44,807.26 31,550.19 27,290.1 44
TC1 36,077.62 39,298.06 44,273.38 19,041.76 15,057.98 13,441.22 14,512.51 20,201.00 42,328.5 32,730.15 36,592.48 35,133.37 34
Track Jaw 0 0 0 0 0 0 0 0 0 0 0 0
Track Screen 0 0 0 0 0 0 0 0 0 0 0 0
9/26/24, 1:29 PM State of Utah Mail - Air Quality Inspection - Records Request for TM Crushing Talons Cove
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-a:r-5873668217613352270&simpl=msg-a:r-32682033233404…1/3
Track Trommel 0 0 0 0 0 0 0 0 0 0 0 0
Portable 0 0 0 0 0 0 0 0 0 0 0 0

II.B.2.c: Bulldozer operating hours for the rolling 12-month period
Aug-23 116 hrs
Sep-23 87 hrs
Oct-23 94 hrs
Nov-23 61 hrs
Dec-23 34 hrs
Jan-24 53 hrs
Feb-24 13 hrs
Mar-24 22 hrs
Apr-24 43 hrs
May-24 15 hrs
Jun-24 37 hrs
Jul-24 52 hrs
12 month total = 627 hours

II.B.2.d: Unpaved haul road length and loader operating area length

Haul Road A (TC1 Road) = 2,400 feet one-way
Haul Road B (TC2 Road) = 4,700 feet one-way
Haul Road C (mobile Roads) 3,500 feet one-way
Haul Road D (Bank Run Roads) = 4,400 feet one-way
Loader Roads = 500 feet one-way

II.B.2.h: Blasting episodes and tons of ANFO per blasting period for the 12-month period
Date Client Location ANFO TONS ANFO LBS
9/29/2023 TM Crushing Talons Cove 22.5 45,000
11/13/2023 TM Cruching Talons Cove 14.75 29,500
11/29/2023 TM Cruching Talons Cove 25 50,000
12/27/2023 TM Crushing Talons Cove 25 50,000
1/24/2024 TM Crushing Talons Cove 24 48,000
3/13/2024 TM Crushing Talons Cove 17.9 35,800
4/25/2024 TM Crushing Talons Cove 19.95 39,900
5/15/2024 TM Crushing Talons Cove 20.7 41,400
9/26/24, 1:29 PM State of Utah Mail - Air Quality Inspection - Records Request for TM Crushing Talons Cove
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-a:r-5873668217613352270&simpl=msg-a:r-32682033233404…2/3
7/11/2024 TM Crushing Talons Cove 16.6 33,200

II.B.2.i: Storage pile and disturbed acreage area -- record of the last measurement

Stockpile Areas = 20 Acres
Disturbed Areas = 50 Acres
[Quoted text hidden]
Connor Kijowski <[e-mail]>Tue, Sep 24, 2024 at 3:34 PM
To: Nicki Coates <[e-mail]>
Hi Nicki,
I have one follow up question with the records you provided. Can you tell me when the last stockpile and disturbed area acreage measurement was taken?
Thanks,
Connor
[Quoted text hidden]
Nicki Coates <[e-mail]>Thu, Sep 26, 2024 at 12:26 PM
To: Connor Kijowski <[e-mail]>
Connor,

We had a consultant survey and measure site on October 19th 2023. We do fly and survey our stockpiles each month but that does not account for our disturbedacreage.

Thanks
Nicki
[Quoted text hidden]
Connor Kijowski <[e-mail]>Thu, Sep 26, 2024 at 1:24 PM
To: Nicki Coates <[e-mail]>
Thanks, Nicki. Measurements of the storage piles and disturbed acreage should take place every six months according to AO Condition II.B.2.i.1 (AO attached for your reference). Since
the new AO will be issued soon to resolve the previous compliance advisory, I will not be issuing an additional compliance advisory for this. However, I will make a note of it for the nextinspector to ensure this condition is met during the next inspection cycle. Let me know if you have any questions.
Best,
Connor
[Quoted text hidden]
DAQE-AN144460004-19.pdf119K
9/26/24, 1:29 PM State of Utah Mail - Air Quality Inspection - Records Request for TM Crushing Talons Cove
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-a:r-5873668217613352270&simpl=msg-a:r-32682033233404…3/3