DAQ-2024-011291

State
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenanl Goventor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DTVISION OF AIR QUALITY
Bryce C. Bird
Direclor
September 10,2024
Sent Via Certified Mail No. 70022030000044115427
DAQC-906-24
site ID 10273 (Bl)
Kris Ashdown
Ashdown Brothers Construction
I134 North Lund Highway
Cedar City, UT 84720
Dear Mr. Ashdown:
Re: Compliance Advisory - Ashdown Brothers Construction, Utah Administrative Code (UAC)
R307-401, Approval Order (AO) DAQE-AN0102730001-08, Iron County
On July 10,2024, a representative of the Utah Division of Air Quality (DAQ) conducted an
inspection of Ashdown Brothers Construction, located at ll34 North Lund Highway, Cedar City, UT.
The DAQ observed the source operating two unapproved generator engines which are not listed on the
current AO, which may be a violation of UAC R307-401-5 and Conditions 4 and 8 of AO
DAQE-AN0102730001-08. These are repeat violations found during a compliance inspectionin2023
for which the DAQ issued a separate Compliance Advisory @AQC-1039-23\.
Ashdown Brothers Construction is required to comply with the above regulations. A written response
to this letter is required within ten (10) business days of receipt of this letter.
Additional details about the above observations and regulations are attached to this letter. Please
contact Connor Kijowski at 385-245-6720 or [e-mail] if you have any questions about this
letter.
Sincerely,
L4,4r-q;
Chad Gilgen, Manager
Minor Source Compliance Section
CG:CKjl
cc: Southwest Utah Public Health Department
Alan Humpherys, Manager, MinorNSR Section
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144820. Salt Lake Ciry, UT 841144820
Telephone (80 I ) 5364000 . Fax (80 I ) 5364099 . T.D.D. (80 I ) 903-3978
ww.deq.utah.gov
Printed on 100% rccyclcd paper
DAQC-906-24
Page 2
Potential Violations
On July 10,2024, an inspector from the DAQ observed Ashdown Brothers Construction at I134
North Lund Highway, Cedar City, in Iron County, UT.
At the time of the inspection the DAQ documented the following potential violations:
. UAC R307-401-5
Ashdown Brothers Construction submitted a Notice of Intent in2023 to include the two
additional diesel generator engines (545-kW and 300-kW) but failed to receive an AO
prior to installation and operation of the equipment.
o Conditions 4 and 8 of Approval Order DAQE-AN0102730001-08
Ashdown Brothers Construction installed and operates two diesel generator engines which
are not listed on the approved equipment list of the AO and may affect the emissions
covered by this AO.
AO Conditions/Rules
Utah Administrative Code R307-401. Permit: New and Modified Sources
UAC R307-401-5: ( I ) Except as provided in Sections R307-40 1-9 through R307-40 1- I 7 , any
person subject to Rule R307-401 shall submit a notice of intent to the director and receive an
approval order precedent to the construction, modification, installation, establishment, or
relocation of an air pollutant source or indirect source. The notice of intent shall be in a format
specified by the director.
DAQE-AN0102730001-08, dated September 30, 2008
Condition 4. Modifications to the equipment or processes approved by this AO that could affect
the emissions covered by this AO must be approved with R301-401-1.
Condition 8. The approved installations shall consist of the following equipment or equivalent*:
Aggregate Plant
A. One (l) El Jay jaw crusher, Model 1208*
B. One (1) El Jay 45" cone crusher, Model 115*
C. One (1) vertical impact crusher** rated at 100 tons/hour, manufactured in 1982
D. One (1) screen**,3'x 8', manufactured in 1957
E. One (l) screen**, 5' x 16', manufactured in 1957
Asphalt Plant
F. One (l) Madsen 4000 asphalt plant, 150 ton/hour (design capacity), Mfg 1964*
G. One (l) wet Venturi Scrubber
DAQC-906-24
Page 3
Concrete Batch Plant
H. One (l) concrete batch plant with bin vent on associated cement silos
L Miscellaneous plant-wide equipment including loaders, dozers, water and haul trucks,
conveyors, stackers, and small diesel fuel tanks
*Equivalency shall be determined by the Executive Secretary
t*Newly installed equipment
The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ. You are
responsible for complying with the Utah Air Conservation Rules. There are possible administrative
and civil penalties for failing to do so. Section l9-2-l l5 of the Utah Code Annotated provides that
violators of the Utah Air Conservation Act and/or any order issued there under may be subject to a
civil penalty of up to $10,000 per day for each violation.
The written response to this CA will be considered in resolving the deficiencies documented in this
letter. It may include information demonstrating compliance with the regulations or a schedule to
bring your company back into compliance with the applicable regulations. The DAQ will review your
response and this CA may be revised as a result of that review. Failure to respond in writing within ten
(10) business days of receipt of this CA will be considered in any subsequent enforcement action and
the assessment of penalties.
Possible DAQ actions to resolve a CA include: No Further Action Letter, Warning Letter, Early
Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or
Notice of Violation and Order to Comply.
This CA does not limit or preclude the DAQ from pursuing enforcement options concerning this
inspection. Also, this CA does not constitute a bar to enforcement action for conditions that the DAQ
did not observe or evaluate, or any other conditions found during future inspections.
A meeting may be requested to discuss this CA. Please contact Connor Kijowski at385-245-6720 or
[e-mail] if you would like to request a meeting or if you have any questions about this
letter.
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Jazmine Lopez <[e-mail]>
Returned Mail DAQC-906-24
Connor Kijowski <[e-mail]>
To: Jazmine Lopez <[e-mail]>
Mon, Sep 23,2024 at 5:00 PM
HiJazmine,
Apparently we have had trouble with this mailing address in the past and have just sent it via email. ljust forwarded the
letter to Ashdown Brothers via email and no hard copy needs to be sent.
Thanks,
Connor
On Mon, Sep 23, 2024 at 3:01 PM Jazmine Lopez <[e-mail]> wrote:
Hello,
The letter for DAQC-906-24 (Ashdown Brothers Compliance Advisory) was returned to us in the mail as "Attempted -j Not Known, Unable to Forward." The address it was sent to was:
I Kris Ashdown
i rra+ N Lund Hwy
: Cedar City, UT 84720
ls there another address for us to re-mail this to? Thank you!
Jazmine
Jazmine Lopez
Office Technician
Phone: (8or) Sg6-+o5o Fax: [phone]
airquality.utah.gov
AIR OUALITY
C,.Gonnor Kijowski
Environmental Scientist I Minor Source Compliance
M: [phone]
airquality.utah.gov
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