DAQ-2024-011405

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DAQC-CI120850001-24
Site ID 12085 (B1)
MEMORANDUM

TO: FILE – STAKER PARSON COMPANIES – Lehi-Peck Pit

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: October 22, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: July 25, 2024

SOURCE LOCATION: Approximately 5.6 miles west of Lehi on Highway 73
Lehi, UT 84043
DIRECTIONS: The entrance sign states "Staker Lehi-West". From I-15 take exit
282 to UT-194/W 2100 N, to UT-145/Mountainview/S Mountain
View to UT-73/W Cedarfort Road.

SOURCE CONTACTS: Mark Shaw, Site Aggregate Supervisor

Christopher Rose, Environmental Specialist West Division
385-400-2119 [e-mail]

OPERATING STATUS: The aggregate equipment was operating. The concrete batch
plant was not operating.

PROCESS DESCRIPTION: Staker & Parson operates a concrete batch plant and an aggregate
processing plant. The aggregate equipment consists of multiple
crushers, screens with associated feeders and conveyors. The
batch plant silos are controlled with dust collectors. All the
equipment is connected to electrical power.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN120850002-23, dated July 20,
2023
NSPS (Part 60) OOO: Standards of Performance for Nonmetallic
Mineral Processing Plants

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Staker Parson Companies- Lehi-Peck Pit
89 West 13490 South Suite 100 Approximately 5.6 miles west of Lehi on Hwy 73
Draper, UT 84020 Lehi, 84043

SIC Code: 1442: (Construction Sand & Gravel)
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Section I: GENERAL PROVISIONS

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

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

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

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

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

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

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

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

Status: In Compliance. No limits were exceeded based on the observations and the reviewed documents. No modifications to the equipment or process were found. Records are kept
and were submitted as required. An Emissions Inventory was submitted for the 2023
activity year and is attached to this memo. No applicable breakdowns are on record.

Section II: SPECIAL PROVISIONS

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

II.A.1 Lehi-Peck Pit
II.A.2 One (1) Jaw Crusher Federal Applicability: NSPS OOO Rating: 1200 tons/hour
II.A.3 Two (2) Cone Crushers Federal Applicability: NSPS OOO Rating: 1200 tons/hour each
II.A.4 One (1) Primary Screen Federal Applicability: NSPS OOO Rating: 1200 tons/hour
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II.A.5 Two (2) Screens Federal Applicability: NSPS OOO Rating: 1200 tons/hour each
II.A.6 One (1) 12 cubic yard Concrete Aggregate Batcher with Feeder Bin
II.A.7 One (1) Cement Silo with Dust Collector
II.A.8 One (1) Flyash Silo with Dust Collector
II.A.9 One (1) Water Heater Rating: 9.9 MMBtu/hr Fuel: Natural Gas
II.A.10 Other Associated Equipment Including: Conveyors, Loaders, Dozers
Status: In Compliance. The permitted equipment was observed on site. Equipment authorized by the Temporary Relocation DAQC-1374-23 dated January 9, 2024, was also seen on site with the exception that only one of the authorized track screens, and one of the authorized cone crushers, were on site, but were not operating. The relocated equipment reportedly only sporadically operates and is scheduled to be removed by the end of December of 2024. No other equipment was observed during this inspection.

II.B Requirements and Limitations
II.B.1 The Lehi-Peck Pit shall be subject to the following: II.B.1.a The owner/operator shall not produce more than the following: A. 3,000,000 tons of aggregate per rolling 12-month period. B. 400,000 cubic yards of concrete per rolling 12-month period. [R307-401-8] Status: In Compliance. The reported 12-month rolling total for aggregate production for the time period of July 2023 through June 2024, was 1,189,732.54. The rolling 12-month total for concrete production for the same time period was 96,620.25 tons and included the production resulting from the temporarily relocated equipment authorized by DAQC-1374-23. See the attached email statement and production spreadsheets. II.B.1.a.1 The owner/operator shall: A. Determine production with company and/or customer billing records B. Record aggregate and concrete production on a daily basis C. 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 D. Keep the production records for all periods the plant is in operation. [R307-401-8] Status: In Compliance. Totals are derived from daily weighed product loads exiting the facility. The totals are kept for all periods that the plants are in operation and are calculated as required.

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II.B.1.b Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions to exceed the following values at the following emission points: 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. The concrete batch plant - 7% opacity F. All Silo vents - 10% opacity G. All other sources - 20% opacity. [R307-309-5, R307-312-4, R307-401-8] Status: In Compliance. No visible emissions were observed from any point on the operating aggregate screens, cones, or conveyors. The batch plant had stopped operating for the day at the time of the inspection. II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-305-3] Status: In Compliance. The VEO was performed in a manner consistent with Method 9. See the attached VEO. II.B.1.c The owner/operator shall not operate the Lehi-Peck Pit before 6:00 AM and after 10:00 PM each day. [R307-401-8] Status: In Compliance. The plant operator and the Staker Environmental Specialist stated that the equipment permitted on site does not operate prior to 6:00 am or after 10:00 pm. See the attached email statement. II.B.1.c.1 The owner/operator shall keep and maintain the following records of operation for all periods the Lehi-Peck Pit is in operation: A. Time operations begin each day B. Time operations end each day. [R307-401-8] Status: In Compliance. On-site employee records indicate that scheduled shifts start at 6:00 am, with the equipment feed beginning at 7:00 am. The scheduled equipment feed stops at 5:00 pm and the employee shift ends at 6:00. These hours were also verified by screen shots of the onsite shift records attached to the inspection memo DAQC-1269-23. II.B.2 All Haul Roads and Fugitive Dust Sources shall be subject to the following: 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 Lehi-Peck Pit. [R307-309-6] Status: In Compliance. A Fugitive Dust Control Plan dated October 13, 2023, is on record for this facility. The facility appears to comply with the plan in terms of water truck and spray bar operations.

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II.B.2.b The owner/operator: A. Shall not exceed 0.39 miles of unpaved haul roads for all operations B. Shall pave at minimum 0.27 miles of haul roads for the aggregate plant. [R307-401-8] Status: In Compliance. The unpaved haul road length is reported as 0.3563 miles. The current paved portion of the haul road is reported as 0.4764 miles. II.B.2.b.1 Compliance shall be determined through GPS measurements or aerial photographs. The owner/operator shall record new measurements on an annual basis with no less than four months between new measurements. [R307-401-8] Status: In Compliance. The above lengths are based on aerial photographs measured in October of 2024. See the attached October 19, 2024, corrected email statement with aerial photographs. II.B.2.b.2 The owner/operator shall keep records of the following: A. The date measurements of the haul roads were taken B. The measured length of the unpaved haul roads C. The measured length of the paved haul road. [R307-401-8] Status: In Compliance. The haul road length measurements have reportedly been taken in October of 2024, are denoted in photographs, and are now recorded on a spreadsheet. See the attached spreadsheet for haul road lengths. II.B.2.c Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed 20% opacity. [R307-309-5] Status: In Compliance. No visible dust was observed from haul-road vehicles or mobile equipment in the operation areas during this inspection. II.B.2.c.1 Visible emissions determinations for traffic sources shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-309-5] Status: In Compliance. The observations were performed in a manner consistent with Method 9. II.B.2.d Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions: A. All crushers B. All screens C. All conveyor transfer points The sprays shall operate as needed in order to maintain the opacity limits in this AO. [R307-401-8] Status: In Compliance. Water sprays have been installed at all the required points on the aggregate processing circuit.
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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 storage piles and bulldozing operation areas. The owner/operator shall use chemical suppressants and water application on unpaved haul roads. The chemical suppressant shall be applied according to manufacturer recommendations. Controls shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-309-5, R307-401-8] Status: In Compliance. Water applications are made as required to suppress fugitive emissions as necessary at all operation areas, roads, and process points. No fugitive dust was observed during this inspection. II.B.2.e.1 The owner/operator shall keep records of water application and fugitive dust control 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 is below freezing E. Records of any other controls used to reduce fugitive dust. [R307-401-8] Status: In Compliance. Paper records of water application are kept on site in the watering truck and are then transferred to records kept at the main Staker Parson Companies office. Paper watering records for the year were reviewed for this inspection. II.B.2.f The owner/operator shall perform monthly periodic inspections to check that water is flowing to discharge spray nozzles associated with each crusher, screen, and conveyor. If the owner/operator finds that water is not flowing properly during an inspection of the water spray nozzles, the owner/operator shall initiate corrective action within 24 hours and complete corrective action as expediently as practical. [R307-401-8] Status: In Compliance. Daily spray bar nozzle checks are performed prior to starting the aggregate processing equipment. II.B.2.f.1 Records of the water sprays inspections shall be kept and maintained in a logbook for all periods when the plant is in operation. The records shall include the following items: A. Date the inspections were made B. Any corrective actions taken C. Control mechanism used if sprays are not operating. [R307-401-8] Status: In Compliance. The spray bar inspections include the date, and the corrective action taken to fix the nozzle in the event of a malfunction. The spray nozzle is corrected prior to starting the equipment. See the attached spray bar records. II.B.2.g The owner/operator shall not exceed: A. 7 acres of combined area occupied by all storage piles B. 23 acres of disturbed ground. [R307-401-8] Status: In Compliance. The reported stockpile acreage was measured at 4.177. The combined disturbed area acreage was measured at 11.499.
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II.B.2.g.1 To determine compliance with the total acres of the storage piles, the owner/operator shall measure the total area of the storage piles at least once every six months and shall maintain a record of the total acres of the storage piles. To determine the acres of the storage piles on site, the owner/operator shall use a handheld GPS unit and travel around the base of each storage pile on site to calculate the area of each storage pile on site or any method approved by the Director. The area of each storage pile shall be added together to obtain the total area of all the storage piles on site. Records of the total acres of the storage piles shall contain the following: A. Date of measurements B. Size of each storage pile on site or active disturbed area C. Total acres of all storage piles combined or disturbed area combined. [R307-401-8] Status: In Compliance. The measurements were taken on August 29, 2024, and included a breakdown of each product line measurement. See the attached stockpile and disturbed area acreage spreadsheet. The road lengths reported were updated on October 19, 2024. II.B.3 Crushers, Screens, and Conveyors Subject to NSPS OOO II.B.3.a The owner/operator shall conduct an initial performance test for all crushers subject to NSPS OOO. Performance tests shall meet the limitations specified in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO] II.B.3.a.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.3.a.2 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. The record of the initial performance test must be made available to the Director or the Director's representative upon request. [40 CFR 60 Subpart OOO] Status: In Compliance. The initial performance test per NSPS OOO were conducted on August 14, 2015. These records were included as an attachment to the inspection memo DAQC-1269-23. The aggregate equipment has not been changed since that time. The 2023 AO was issued to modify the production hours and remove the Hot Mix Asphalt plant. II.B.4 Bulldozing Requirements II.B.4.a The owner/operator shall not operate all bulldozers on site for more than 4,500 hours combined per rolling 12-month period. [R307-401-8]

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II.B.4.a.1 The owner/operator shall: A. Determine hours of operation with a supervisor monitoring and maintaining an operations log. The hours of operation of each bulldozer shall be added together to determine the total hours. B. Record hours of each bulldozer operation each day C. 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 D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8] Status: In Compliance. The total bulldozer hours for the 12-month rolling period of July 2023 through June of 2024, were reported as 3,015 with 1,798 hours associated with dozer 1018, and 1,217 hours associated with dozer 1621. Hours of operation are calculated from daily employee hours reported per shift and the individual dozer hours are recorded as required. See the attached dozer hour spreadsheet. II.B.5 Concrete Batch Plant Requirements II.B.5.a The owner/operator shall control the PM10 emissions from the concrete batch plant with a baghouse. [R307-401-8] Status: In Compliance. This batch plant's particulate emissions are controlled by dust collectors on both the cement and fly ash silos. II.B.5.b The owner/operator shall pass all displaced air from the pneumatically loaded silos through a fabric filter device before being vented to the atmosphere. [R307-401-8] Status: In Compliance. The displaced air from the batching process passes through the installed fabric filters prior to being vented to the atmosphere. II.B.6 Water Heater Requirements II.B.6.a The owner/operator shall only use natural gas as fuel for the 9.9MMBtu/hr water heater. [R307-401-8] Status: In Compliance. The permitted water heater associated with the batch plant only operates on natural gas. II.B.6.b The owner/operator shall not operate the natural gas water heater for more than 2,000 hours per rolling 12-month period. [R307-401-8]

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II.B.6.b.1 The owner/operator shall: A. Determine hours of operation with a supervisor monitoring and maintaining an operations log. The hours of operation for the water heater shall be added together to determine the total hours. B. Record hours of operation for the water heater each day C. 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 D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8] Status: In Compliance. The reported hot water heater use hours for the 12-month rolling totals for the period of July 2023 through June 2024, were reported as 153.5. Records are based on equipment use for the batch plant when required for colder weather periods. See the attached water heater hour spreadsheet.

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. No opacity was observed from the operating aggregate equipment. The initial
performance observations were performed and spray bar nozzles are inspected daily prior to each shift
and appropriate records are kept.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Stationary Sources [R307-210]

Status: In Compliance. This rule incorporates NSPS OOO for the federal requirements for aggregate
equipment. See the above federal reference for more information.
Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. No visible opacity was observed at this site or the property boundaries at the
time of the inspection.
Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. A Fugitive Dust Control Plan dated October 13, 2023, is available on site.
Fugitive dust was well controlled with a water truck and spray bars.
Aggregate Processing Operations for PM2.5 Nonattainment Areas [R307-312]

Status: In Compliance. No visible emissions were observed from the applicable equipment during this
inspection.
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EMISSION INVENTORY:
An Emissions Inventory for the 2023 activity year were submitted and are attached to this inspection.
Listed below are the Actual Emissions Inventory provided from Staker Parson Companies - Lehi-Peck
Pit. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN120850002-23,
dated July 20, 2023, is provided. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 1171.00
Carbon Monoxide 0.82
Nitrogen Oxides 0.97
Particulate Matter - PM10 23.47
Particulate Matter - PM2.5 4.10
Sulfur Dioxide 0.01
Volatile Organic Compounds 0.05

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Hexane (CAS #110543) 35

PREVIOUS ENFORCEMENT
ACTIONS: A Compliance Advisory was issued on July 27, 2021,
DAQC-986-21, for exceeding the production limit of II.B.1.a.
The issue was resolved by the company submitting a NOI. A
Warning Letter dated September 3, 2021, DAQC-1176-21, was
issued to document the resolution.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN120850002-23,
dated July 20, 2023, the overall status is: In Compliance. In
compliance with the AO AN120850002-23 dated July 20, 2023,
and NSPS Subpart OOO at the time of this inspection.

HPV STATUS: Not Applicable.

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

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO, email correspondence, production records, haul road,
storage piles, disturbed area totals with photographs, water
heater operation hour record, and spray bar inspection records.
Susan Weisenberg <[e-mail]>
RE: [EXT] Lehi Peck disregard stockpile acreage and water heater hour request
1 message
Rose, Chris (Staker & Parson Companies) <[e-mail]>Sat, Oct 19, 2024 at 7:42 PM
To: Susan Weisenberg <[e-mail]>
Hello Susan,

Thanks for clarifying. I reattached the rolling 12 month production totals for both aggregate processing and
ready mix concrete as requested in your last email.

Regarding the haul roads- The measurements I sent you before are incorrect. I was counting a section of
concrete road in the landscape yard as dirt; it’s hard to tell from an overhead view. The correct
measurements are attached as screenshots. In one of the last emails I believed that we hadn’t yet paved
the section of road required in II.B.2.b, but this is incorrect. Unbeknownst to me, we repaved the entrance to
the mine and exits for the mixer trucks and haul trucks between November and December of 2023. The
before and after photos are attached.

Using the attached measurements from after the paving was complete, we can see that the current paved
haul road lengths total 0.4764 miles. The unpaved haul road length is 0.3563 miles, see attachment. The
rest of the roads onsite are loader operation areas, mining roads, equipment trails, access roads, etc.

I can confirm that the aggregate processing (crushers, screens, conveyors, etc.) does not operate before 6
AM or after 10 PM.

I hope this helps you close out your inspection. Please let me know if you need anything else from me.

Christopher Rose
Environmental Specialist
West Division

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

C [phone]
10/22/24, 5:59 PM State of Utah Mail - RE: [EXT] Lehi Peck disregard stockpile acreage and water heater hour request
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1399294283395650849%7Cmsg-f:1813395312740531099…1/3
E [e-mail]

From: Susan Weisenberg <[e-mail]>
Sent: Thursday, October 17, 2024 4:44 PM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Subject: [EXT] Lehi Peck disregard stockpile acreage and water heater hour request

CAUTION: This email originated from outside of the organizaon. Do not click links or open aachments unless you are
expecng this email and know the contents are safe. If you believe this email may be phishing or malicious, please use the
Report Phish buon.
Hello Chris - please disregard my reference to the need to get the stock pile , disturbed area, haul road measurements,
and the water heater hours. I found the information on a separate email communication dated September 5, 2024. I would
still need to get an estimated date for the completion of paving the remaining 0.1 mile of haul road. Thanks, let me know if
you have any questions.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

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6 attachments
Rolling 12 aggs- includes portables.jpg
59K
Rolling 12 RMC.jpg
67K
10/22/24, 5:59 PM State of Utah Mail - RE: [EXT] Lehi Peck disregard stockpile acreage and water heater hour request
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1399294283395650849%7Cmsg-f:1813395312740531099…2/3
Lehi Peck entrance after paving.jpg
432K
Lehi Peck entrance before paving.jpg
0K
Lehi Peck unpaved haul road length.jpg
468K
Lehi Peck paved haul road lengths.xlsx
11K
10/22/24, 5:59 PM State of Utah Mail - RE: [EXT] Lehi Peck disregard stockpile acreage and water heater hour request
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1399294283395650849%7Cmsg-f:1813395312740531099…3/3
Lehi Peck/Cedar Pass RMC paved haul road lengths
Haul Road Length (Miles)
Haul/Mixer Entrance (purple line)0.0964
Mixer Exit (green line)0.1924
Haul Exit (yellow line)0.1876
Total:0.4764
Aggregate stockpile areas
Type Acreage Total stockpile acreage (8/29/24):4.177
2" structural embankment 0.375
6" rock 0.03
1" crushed rock 0.122
1" crushed rock- pile 2 0.995
1.5" crushed rock 0.74
3-0" rock 0.104
4" crushed minus borrow 0.599
3/8" natural sand 0.164
3/8" natural sand- pile 2 0.098
4" screened rock 0.022
1" road base 0.326
RMC stockpile areas
Type Acreage Combined disturbed area acreage: 11.499
#8 pea gravel 0.078
#57 rock 0.157
#98 squeegee 0.056
B sand 0.258
PE sand 0.053
Paved haul road lengths
Road Length 0.3641
Site entrance road 0.0938
Site exit road 0.1199
Scalehouse access road 0.1504
Susan Weisenberg <[e-mail]>
RE: [EXT] Records for Lehi Peck Facility
1 message
Rose, Chris (Staker & Parson Companies) <[e-mail]>
To: Susan Weisenberg <[e-mail]>Cc: "Johnson, Elliott (Staker & Parson Companies)" <[e-mail]>
Susan,

Here are copies of recent daily spray nozzle inspections.

Thank you,

Christopher Rose
Environmental Specialist
West Division

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

C [phone]
E [e-mail]

From: Rose, Chris (Staker & Parson Companies)
Sent: Thursday, September 5, 2024 6:53 PM
To: Susan Weisenberg <[e-mail]>
Cc: Johnson, Ellio (Staker & Parson Companies) <[e-mail]>
Subject: RE: [EXT] Records for Lehi Peck Facility

Susan,

I’ve put more info together for you. I’ve attached our water heater operation hours for the year- we’re permitted for 2000 and we did about 153. In addition, I’ve attached cdisturbed area for the pit, total stockpile acreage, and paved haul road lengths. Unfortunately, it looks like since the 2023 issuance of this AO we haven’t yet paved far enunpaved haul road max length below the required threshold. I’ll work with our operations to make sure this happens in a timely manner.

I also wanted to follow up to see how you would like the dust suppression inspections. Since we inspect spray nozzles and dust suppression daily as part of our pre-shift like to see a few recent examples of those?

Let me know what you think,

Christopher Rose
Environmental Specialist
West Division

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

10/22/24, 6:09 PM State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:180972910687610656…1/10
C [phone]
E [e-mail]

From: Rose, Chris (Staker & Parson Companies)
Sent: Friday, August 30, 2024 1:15 PM
To: 'Susan Weisenberg' <[e-mail]>
Cc: Johnson, Ellio (Staker & Parson Companies) <[e-mail]>
Subject: RE: [EXT] Records for Lehi Peck Facility

Susan,

Thanks for your patience on this. I know we’ve been working on other projects together, but I hate to make you wait a month for info.

I’ve attached files showing the rolling 12-month Aggs and RMC production data along with hours of operation data. Unfortunately I can’t provide proof of schedule compli

For the bulldozer hours, we’ve tallied the hours between the two dozers we’ve used onsite for the requested time period. Dozer 1018 ran a total of 1,798 hours from July In that same period, dozer 1621 ran a total of 1,217 hours. The total dozer operation hours are 3,015, bringing us under the 4,500 hour limit.

I wanted to ask- our company policy dictates that spray nozzles are inspected before each load shift. For convenience sake, could we provide a month’s pre-shift logs aspulling a year’s worth of daily paperwork?

Lastly, I’m still pulling RMC water heater hours and mapping ground acres and road lengths. I wanted to give you the rest of the info to show that I’m actively working on to you very soon.

Thanks for your patience,

Christopher Rose
Environmental Specialist
West Division

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

C [phone]
E [e-mail]

From: Rose, Chris (Staker & Parson Companies)
Sent: Friday, July 26, 2024 10:14 AM
To: Susan Weisenberg <[e-mail]>
Cc: Johnson, Ellio (Staker & Parson Companies) <[e-mail]>
Subject: RE: [EXT] Records for Lehi Peck Facility

Good morning Susan,

Thanks for reaching out. I’ll start compiling this list and I’ll send it over when I have everything.

Chris Rose
Environmental Specialist
10/22/24, 6:09 PM State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:180972910687610656…2/10
West Division

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

C [phone]
E [e-mail]

From: Susan Weisenberg <[e-mail]>
Sent: Friday, July 26, 2024 8:02 AM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Subject: [EXT] Records for Lehi Peck Facility

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
use the Report Phish buon.
Hello, I performed a routine inspection for the Lehi-Peck operation yesterday. I order to complete the compliance evaluation I will need the following as per the current AO AN120850002-23, d

II.B.1.a.A - 12-month rolling aggregate production totals (please include the temporary equipment production) for the time period of July 2023 through June 2024
II.B.1.a.B - the 12-month rolling concrete production for the same time period.

II.B.1.c - documentation of operation hours between 6:00 am to 10:00 pm

II.B.2.b - II.B.2.b.1- recent GPS measurements or aerial photographs documenting length of unpaved and paved haul roads. II.B.2.g - recent measurements of operation acres and disturbed g

II.B.2.f - monthly spray nozzle records

II.B.4.a - 12-month rolling total for bulldozer operation hours.

II.B.6.b - batch plant water heater operation hours

Watering records were reviewed on site. I've attached a copy of the current AO for reference. Let me know if you have any questions. Thanks

Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

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
qu’il s’agit d’un courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
---------- Forwarded message ----------From: "Shaw, Mark (Staker Parson)" <[e-mail]>
To: "Shaw, Mark (Staker Parson)" <[e-mail]>Cc:
Bcc: Date: Fri, 6 Sep 2024 11:37:30 +0000
Subject:
10/22/24, 6:09 PM State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:180972910687610656…3/10
Mark Shaw
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10/22/24, 6:09 PM
State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:180972910687610656…
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---------- Forwarded message ----------
From: "Shaw, Mark (Staker Parson)" <[e-mail]>To: "Shaw, Mark (Staker Parson)" <[e-mail]>
Cc: Bcc:
Date: Fri, 6 Sep 2024 11:36:43 +0000Subject:

Mark Shaw
Aggregate Manager Reynolds Excavation, Demolition & Utilities
A CRH COMPANY
89 West 13490 South
Draper, UT 84020

M [phone]
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10/22/24, 6:09 PM State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:180972910687610656…5/10
---------- Forwarded message ----------
From: "Shaw, Mark (Staker Parson)" <[e-mail]>To: "Shaw, Mark (Staker Parson)" <[e-mail]>
Cc: Bcc:
Date: Fri, 6 Sep 2024 11:37:08 +0000Subject:

Mark Shaw
Aggregate Manager Reynolds Excavation, Demolition & Utilities
A CRH COMPANY
89 West 13490 South
Draper, UT 84020

M [phone]
E [e-mail]

---------- Forwarded message ----------
From: "Shaw, Mark (Staker Parson)" <[e-mail]>To: "Shaw, Mark (Staker Parson)" <[e-mail]>
Cc: Bcc:
Date: Fri, 6 Sep 2024 11:37:52 +0000
10/22/24, 6:09 PM State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:180972910687610656…6/10
Subject:

Mark Shaw
Aggregate Manager Reynolds Excavation, Demolition & Utilities
A CRH COMPANY
89 West 13490 South
Draper, UT 84020

M [phone]
E [e-mail]

---------- Forwarded message ----------
From: "Shaw, Mark (Staker Parson)" <[e-mail]>To: "Shaw, Mark (Staker Parson)" <[e-mail]>
Cc: Bcc:
Date: Fri, 6 Sep 2024 11:38:13 +0000Subject:
10/22/24, 6:09 PM State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:180972910687610656…7/10

Mark Shaw
Aggregate Manager Reynolds Excavation, Demolition & Utilities
A CRH COMPANY
89 West 13490 South
Draper, UT 84020

M [phone]
E [e-mail]

---------- Forwarded message ----------From: "Shaw, Mark (Staker Parson)" <[e-mail]>
To: "Shaw, Mark (Staker Parson)" <[e-mail]>Cc:
Bcc: Date: Fri, 6 Sep 2024 11:38:36 +0000
Subject:
10/22/24, 6:09 PM State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:180972910687610656…8/10
Mark Shaw
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10/22/24, 6:09 PM
State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:180972910687610656…
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10/22/24, 6:09 PM State of Utah Mail - RE: [EXT] Records for Lehi Peck Facility
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-1078168152989898042%7Cmsg-f:18097291068761065…10/10
Cedar Pass water heater operation hours
Date Hours Fired
11/1/2023 1
11/6/2023 2
11/7/2023 4.5
11/15/2023 2
11/30/2023 2
12/5/2023 2.5
12/6/2023 2
12/7/2023 2
12/11/2023 4
12/12/2023 2
12/13/2023 4
12/14/2023 5
12/15/2023 2
12/18/2023 3
12/19/2023 4.5
12/20/2023 5
12/21/2023 2
12/22/2023 4
12/28/2023 3.5
12/29/2023 3
1/3/2024 4.5
1/4/2024 3
1/5/2024 5
1/9/2024 2
1/10/2024 5.5
1/25/2024 1
1/26/2024 2
1/29/2024 4
2/1/2024 2
2/5/2024 3
2/6/2024 2
2/7/2024 2.5
2/9/2024 4
2/13/2024 3
2/14/2024 4
2/15/2024 6
2/16/2024 3
2/20/2024 2
2/21/2024 4
2/22/2024 3.5
2/23/2024 4.5
2/26/2024 4
2/27/2024 4.5
2/28/2024 5.5
2/29/2024 4
3/1/2024 1
3/4/2024 2
3/5/2024 2
Total hours:153.5
2023 Emissions Inventory Report
Staker & Parson Companies- Lehi-Peck Pit (12085)
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)20.99373 0.87882 21.87255
PM10-FIL PM10 Filterable 20.97806 <.00001 20.97806
PM25-PRI PM2.5 Primary (Filt + Cond)2.43404 0.85245 3.2865
PM25-FIL PM2.5 Filterable 2.41837 <.00001 2.41837
PM-CON PM Condensible 0.01568 <.00001 0.01568
SO2 Sulfur Dioxide 0.00165 0.01812 0.01977
NOX Nitrogen Oxides 0.275 13.48768 13.76268
VOC Volatile Organic Compounds 0.01513 0.98192 0.99705
CO Carbon Monoxide 0.231 5.80007 6.03107
7439921 Lead 0.00002 <.00001 0.00002
NH3 Ammonia 0.0088 <.00001 0.0088

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
75070 Acetaldehyde (HAP)VOC 0.00004
107028 Acrolein (HAP)VOC 0.00005
7440382 Arsenic (HAP)PM 0.00002
71432 Benzene (HAP)VOC 0.00001
7440417 Beryllium (HAP)PM <.00001
7440439 Cadmium (HAP)PM 0.00001
7440473 Chromium (HAP)PM 0.00007
7440484 Cobalt (HAP)PM <.00001
50000 Formaldehyde (HAP)VOC 0.00021
110543 Hexane (HAP)VOC 0.00495
7439965 Manganese (HAP)PM 0.00399
7439976 Mercury (HAP)- <.00001
91203 Naphthalene (HAP)VOC <.00001
7440020 Nickel (HAP)PM 0.00026
7723140 Phosphorus (HAP)- 0.00098
7782492 Selenium (HAP)PM <.00001
108883 Toluene (HAP)VOC 0.00001
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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