DAQ-2024-011467

1
DAQC-1076-24
Site ID 12898 (Bl)

MEMORANDUM

TO: FILE – PROGRESSIVE CONTRACTING, INC.

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: October 21, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Washington County

INSPECTION DATE: August 6, 2024

SOURCE LOCATION: 1700 East 3500 South, St. George, UT Washington County

Take River Road South to 3850 South, then tum onto 1700 East.
Progressive Contracting, Inc. (PCI) is at the end of the road.
Check in at the weigh station.

SOURCE CONTACTS: John Slack, Pit Manager
[e-mail]

OPERATING STATUS: Not operating at the time of inspection

PROCESS DESCRIPTION: Progressive Contracting operates an aggregate processing
operation (Gypsum Mine) in the Fort Pierce, Washington
area of St. George. Raw aggregate bank run materials are
loaded by front end loader into the impactor crusher. The
feeder drops the material onto a conveyor where it is moved
to the primary screen and sorted. Material is shipped off site
by haul trucks, which are loaded by front end loaders. Water
sprays are used to control dust from the product processing
operations. A water truck is used to control dust from
roadways and operational areas. A water tank has been
installed at the northern end of the source. Permitted
equipment is often temporarily relocated to other locations
for specific jobs.

APPLICABLE REGULATIONS: Approval Order AN128980002-07 dated February 22, 2007

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SOURCE EVALUATION:

Condition 1. This Approval Order (AO) applies to the following company:

Corporate Office Location
Progressive Contracting, Inc.
297 West Hilton Dr., Suite #3
St. George, Utah 84770
Phone Number [phone]
Fax Number [phone]

The equipment listed in this AO shall be operated at the following location:

1700 East 3500 South Near Bloomington Hills, St. George, Utah, Washington County
Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27
4,104.1 kilometers Northing, 269.1 kilometers Easting, Zone 12
Condition 2.

All definitions, terms, abbreviations, and references used in this AO conform to those
used in the Utah Administrative Code (UAC) Rule 307 (R307) and Title 40 of the Code
of Federal Regulations (40 CFR). Unless noted otherwise, references cited in these AO
conditions refer to those rules.
Condition 3.

The limits set forth in this AO shall not be exceeded without prior approval in accordance
with R307-401.
Status:

In compliance. No limits were exceeded at the time of inspection.
Condition 4.

Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved in accordance with
R307- 401-1.
Status:

In compliance. No additional equipment was observed during the inspection.
Some of the listed equipment is no longer operational. The source ceased
operations on June 8, 2023, returned intermittently on December 18, 2023, and
shut down operations again on July 4, 2024. Source is currently in process of
receiving a new AO.

3
Condition 5.

All records referenced in this AO or in applicable NSPS standards, which are required
to be kept by the owner/operator, shall be made available to the Executive Secretary or
Executive Secretary's representative upon request, and the records shall include the
two- year period prior to the date of the request. Records shall be kept for the
following minimum periods:

A. Emission inventories: Five years from the due date of each emission statement or
until the next inventory is due, whichever is longer.

B. All other records: Two years

Status:

Condition 6.
In compliance. All necessary records were made available upon request.

Progressive Contracting, Inc., shall install and operate the Screen Plant and Rip Rap
Plant and shall conduct its operations of the aggregate plant in accordance with the
terms and conditions of this AO, which was written pursuant to Progressive Contacting,
Inc's Notice of Intent submitted to the Divisions of Air Quality (DAQ) on October 10,
2006 and additional information submitted on December 13, 2006.
Status: In compliance. The Rip Rap plant and the Screen plant have been
combined into one plant with two sets of screens.

Condition 7. This AO shall replace the AO (DAQE-AN2898001-03) dated September 23, 2003.

Status: In compliance. The observed equipment and process is consistent with the AO
AN12898002-7 dated February 22, 2007, and only this AO was used for this
inspection. Much of the equipment on the 2007 AO is no longer on site and/or in
operation on site.

Condition 8. The approved installations shall consist of the following equipment or equivalent*:

A. One (1) Austin Western Jaw Crusher, Model 3640, 200 ton per hour
(tph)*
B. One (1) El Jay Cone Crusher w/Double Deck Screen, 54", 200 tph*
C. One (1) Telesmith Double Deck Screen, 200 tph*
D. One (1) 343 KW Diesel Generator
E. One (1) 100 KW Diesel Generator
F. One (1) Eagle Horizontal Impactor, Model 12/4817, 200 tph*
G. One (1) Norberg Impactor, Model 3055, 200 tph*
H. One (1) JCI Triple Deck Screen, 300 tph*
I. One (1) 250 KW Diesel Generator
J. One (1) Kolberg/Pioneer Screening Plant Model 401712, 6' x 20' **
K. One (1) Rip Rap Plant 62' x24 ' SN 205-071000-6224**
L. One (10 163 KW Generator - SN 530886884**
M. One (1) Hewitt Robbins Jaw crusher SN 17807, 30" x 42" **
N. One (1) Cedar Rapids Jaw Crusher - SN 17807, 1O" x 36"**One (1)
O. One (1) Cedar Rapids Roll Crusher SN 31490, 41" x 36"**
P. One (1) 2 Deck Screen, 5' x 16" **
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Q. All Plants will have miscellaneous Loaders, Excavators, Conveyors,
Stackers, Feed Hoppers, and Haul Trucks, which can be shared
between plants.

*Equivalency shall be determined by the Executive Secretary.

**New equipment

Status: In compliance. As previously noted, only items H, I, K, and Q were the
only equipment onsite. That information remains true, as that was the
only equipment observed at the time of inspection. Information carried
over from the previous inspection include:

Item I has an actual maximum KW of 180. This diesel generator
powers the Rip Rap plant and the Triple Deck Screen. These were not
running during the time of inspection.

Condition 9. Progressive Contracting, Inc. shall notify the Executive Secretary in writing when the
installation of the equipment listed in Condition #8.J through #8.L has been
completed and is operational, as an initial compliance inspection is required.
To insure proper credit when notifying the Executive Secretary, send your
correspondence to the Executive Secretary, Attn: Compliance Section.

If construction and/or installation have not been completed within eighteen
months from the date of this AO, the Executive Secretary shall be notified in
writing on the status of the construction and/or installation. At that time, the
Executive Secretary shall require documentation of the continuous construction
and/or installation of the operation and may revoke the AO in accordance with
R307-401-11 .

Status: In compliance. Progressive Contracting Inc. notified the Executive
Secretary in writing that the equipment listed in Condition 8 J through
8 L had been installed and was operational. The letter was received by
the DAQ on May 21, 2007.

5
Condition 10. Visible emissions from the following emission points shall not exceed the following values:
A. All crushers - 15% opacity
B. All screens - 10% opacity
C. All conveyor transfer points - 10% opacity
D. All diesel engines - 20% opacity
E. Conveyor drop points - 20% opacity
F. All other points - 20% opacity

Opacity observations of emissions from stationary sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9. For sources that are subject to NSPS, opacity shall
be determined by conducting observations in accordance with 40 CFR 60.1 l(b) and 40
CFR 60, Appendix A, Method 9.

Status: In compliance. No visible emissions were observed at the time of inspection. See
the attached VEO form for additional information.
Condition 11. The following operating limits shall not be exceeded:

A. 650,000 tons of processed aggregate material per rolling 12-month period

B. 4,160 hours of diesel generator operation (combined total of all on-site diesel
generators) per rolling 12-month period

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.

Status:

In compliance. Monthly logs of aggregate production and diesel fuel operation were
reviewed at the time of inspection. Review of records showed the following totals:

A. Total material produced from this pit in the 12-month period of August
2023 through July 2024, was 15,165.62 tons.

B. The total hours of diesel operation from August 2023 through July 2024,
were 376.50 hours.

Condition 12. Visible fugitive dust emissions from haul-road traffic and mobile equipment in
operational areas shall not exceed 20% opacity. Visible emissions determinations for
traffic sources shall use procedures similar to Method 9. Normal requirements for
observations to be made at 15-second intervals over a six-minute period, however, shall
not apply. Six points, distributed along the length of the haul road or in operational
areas, shall be chosen by the Executive Secretary of the Executive Secretary' s
representative. An opacity reading shall be made ½ vehicle length or greater behind the
vehicle and at approximately ½ the height of the vehicle or greater. The accumulated six
readings shall be averaged for the compliance value.
'-
Status: In compliance. No fugitive dust was observed at the time of inspection, as
operations were ceased.
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Condition 13.

Progressive Contracting, Inc. shall abide by all applicable requirements of R307-205 for
Fugitive Emission and Fugitive Dust sources.
Status:

In compliance. Fugitive emissions from sources did not exceed 20% opacity at time
of inspection. The source uses water to mitigate fugitive dust onsite. The paved road
at entrance to source was clear of fugitive dust.
Condition 14. The owner/operator shall use #2 diesel fuel in the various power generator engines.
Status: In compliance. The source obtains #2 diesel fuel from Rhinehart Oil.
Condition 15.

The sulfur content of any fuel oil or diesel burned shall not exceed 0.50 percent by
weight for all fuels used. The sulfur content shall be determined by ASTM Method D-
4294-89 or approved equivalent. Certification of fuels shall be either by Progressive
Contracting's own testing or test reports from the fuel marketer.
Status:

In compliance. The diesel fuel from Rhinehart Oil is classified as ULSD according
to a recent fuel invoice. A copy of the invoice can be seen in the attachments section.
Condition 16.

In addition to the requirements of this AO, all applicable provisions of 40 CPR 60, New
Source Performance Standards (NSPS) Subpart A, 40 CPR 60.1 to 60.18 and Subpart
OOO, 40 CPR 60.670 to 60.676 (Standards of Performance for Nonmetallic Mineral
Processing Plants) apply to this installation.
Status:

In compliance. An inspection report dated September 14, 2006, stated that NSPS
observations were performed in 2002 for all of the equipment listed on the
September 23, 2003, AO and that the observations are available for review in the
company's main office. Most of the equipment applicable to 40 CPR 60, NSPS
Subpart A is no longer operational on site.
Condition 17.

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 Approval Order 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 Executive Secretary 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.
Status:

In compliance. The source is following best practices to minimize emissions.

Condition 18.

The owner/operator shall comply with R307-150 Series. Inventories, Testing and
Monitoring.
Status:

Out of compliance. The 2023 Emission Inventory was submitted late but has
been reviewed and accepted. A copy can be found in the attachments section
below. No further action is recommended.

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Condition 19. The owner/operator shall comply with R307-107. General Requirements: Unavoidable
Breakdowns.

Status: In compliance. There have been no reportable breakdowns at this source
since the previous inspection.

AREA SOURCE RULES EVALUATION:

UAC R307-203 Emission Standards: Sulfur Content of Fuels

Status: In compliance. Ultra-low sulfur fuel is utilized at this source, see condition #15.

UAC R307-205: Fugitive Emission and Fugitive Dust sources

Status: In compliance. See condition #13 above.

EMISSION INVENTORY:

EMISSION INVENTORY can be collected from SLEIS. Progressive Contracting, Inc.
Emissions Inventory data for the 2023 activity year are recorded as follows:

Pollutant Tons/Year
Acetaldehyde 0
Acrolein 0
Benzene 0.00005
Carbon Monoxide 4.23
NOx 11.02
PM10 4.21
PM2.5 0.93
SO2 0.01
Toluene 0
VOC 0.86
Xylene 0

PREVIOUS ENFORCEMENT
ACTIONS:

COMPLIANCE STATUS &
RECOMMENDATIONS:

RECOMMENDATION
FOR NEXT INSPECTION:

No compliance action within the past five years.

In compliance with the conditions of AO DAQE-AN128980002-07
dated February 22, 2007, at the time of the inspection. The facility
appears to be well maintained and operated. Required records were
current and made available after the inspection. Source did not submit
their 2023 Emission Inventory on time, but it has been submitted,
reviewed, and accepted. No further action is recommended.

Currently, the source has ceased operations. They are currently in the
process of receiving a new AO from a 10-Year Administrative Review.
Contact source before the next inspection once that new AO is
approved to see if the source is operating.
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RECCOMENDATION FOR
NSR PERMITTING REVIEW:

No recommendations at this time.

ATTACHMENTS: VEO form, email of aggregate material processed and diesel usage,
notice of closures and recommencement of operations, water
application logs

2023 Emissions Inventory Report
Progressive Contracting Incorporated- Aggregate Mining (12898)
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)3.55472 0.65934 4.21406
PM10-FIL PM10 Filterable 3.53098 <.00001 3.53098
PM25-PRI PM2.5 Primary (Filt + Cond)0.29867 0.63956 0.93823
PM25-FIL PM2.5 Filterable 0.28744 <.00001 0.28744
PM-CON PM Condensible 0.0059 <.00001 0.0059
SO2 Sulfur Dioxide 0.00124 0.01598 0.01722
NOX Nitrogen Oxides 0.72169 10.30231 11.02399
VOC Volatile Organic Compounds 0.00034 0.80412 0.80446
CO Carbon Monoxide 0.00271 4.23424 4.23695
7439921 Lead 0.00001 <.00001 0.00001

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
7440382 Arsenic (HAP)PM 0.00001
71432 Benzene (HAP)VOC 0.00005
7440417 Beryllium (HAP)PM <.00001
106990 1,3-Butadiene (HAP)VOC 0.00001
7440439 Cadmium (HAP)PM <.00001
7440473 Chromium (HAP)PM 0.00001
50000 Formaldehyde (HAP)VOC 0.00023
7439965 Manganese (HAP)PM 0.00065
7439976 Mercury (HAP)- <.00001
91203 Naphthalene (HAP)VOC 0.00003
7440020 Nickel (HAP)PM <.00001
130498292 PAH, total (HAP)PM 0.00003
7782492 Selenium (HAP)PM 0.00002

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
Jordan Garahana <[e-mail]>
8/6/2024 Inspection Requests Email 4 of 4
3 messages
John Slack <[e-mail]>Wed, Aug 21, 2024 at 3:30 PM
To: Jordan Garahana <[e-mail]>
Cc: [e-mail], Josh Button <[e-mail]>
Jordan,

Attached are the items you requested.

I received a due to size nondelivery notice back from the email I previously sent. So I am sending the attachments in 4
emails this time.

Thank you,

John W Slack
Progressive Contracting, Inc.
[e-mail]
Phone: [phone]
Fax: [phone]

Work Place Examinations December 2023 to May 2024.pdf
7600K
Jordan Garahana <[e-mail]>Wed, Aug 21, 2024 at 4:00 PM
To: John Slack <[e-mail]>
Cc: [e-mail], Josh Button <[e-mail]>
10/21/24, 1:57 PM State of Utah Mail - 8/6/2024 Inspection Requests Email 4 of 4
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1808034877558635805&simpl=msg-f:180803487755863580…1/2
Hey John,
Thank you for getting back to me with the records I requested. I will let you know if there is anything else I need from you
to help complete my inspection.
Thanks,
Jordan
[Quoted text hidden]
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
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10/21/24, 1:57 PM State of Utah Mail - 8/6/2024 Inspection Requests Email 4 of 4
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1808034877558635805&simpl=msg-f:180803487755863580…2/2