DAQ-2024-011506

1
DAQC-CI106750001-24
Site ID 10675 (B1)
MEMORANDUM

TO: FILE – REDMOND MINERALS, INCORPORATED – Salt & Clay Mining and Salt
Production Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: October 29, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Sanpete County

INSPECTION DATE: July 29, 2024

SOURCE LOCATION: 6005 North 100 West Redmond
Sanpete County, UT 84652

DIRECTIONS: Highway 89 south to Axtell main street, go west to salt mine road
then west to Clairon Road (100 West). Follow truck route signs.

SOURCE CONTACTS: Mike Forbush, Engineer
435-657-3600, [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Mine - Clay is taken from a surface mine and piled for sale, mostly to
Western Clay. The Redmond clay processing plant is on a separate
AO. The salt and clay mixture is removed from an underground mine
by drilling, blasting, front end loader and truck, and dumped into the
primary system. High quality salt ore is taken to the food salt system.

Primary System - Ore from mine is dumped into a plate feeder,
processed by a Jaw crusher, then sent to the primary screen. Belts
take 4 inch plus rock to trophy rock bins; 0.5 to 4.5 rock is sent to the
primary cone crusher then back to the screen. 0.5 minus material
goes to the cone storage bin. Oversized material is run through the
primary screen again. Material from the cone storage bin is either
moved through the (agricultural) Milled Products System or through
the Road Salt System.

Road Salt System - Primary fines are treated with an anti-caking
additive and mixed in the pug mill. The material is stored in
uncovered piles.

Milled Products - Primary fines are dried in a rotary dryer/kiln and
sent to the Milled products screen. Oversized material is run through
a hammer mill and then back to Storage. Screened products are
stored in covered concrete bins. Emissions from the drier, hammer
mill, and elevator are treated by a baghouse. The screen is treated by
a separate baghouse.

2
Secondary system - Trophy rock is passed through a sorting room and
reject rock goes into the secondary apron feeder, jaw crusher, roll
crusher, then bins for use as agricultural or road salt.

Food Salt - Select material first goes through a Gleason Crusher,
elevator, and then a storage bin. Next, the material is transferred to a
hammer mill, to a bin, then to a set of screens. Three different
products are generated and stored in enclosed bins. Bins are emptied
into pallet bags for shipping to the Heber City packaging plant.
Emissions from the food salt system are controlled by a baghouse.

Agricultural salt clay - The dried and milled salt is stored for mixing
and bagging.

Warehouse - Ten-pound Trophy Rock is weighed and wrapped with
plastic. Smaller rope rock is weighed, drilled, and fitted with a rope.
Other products including small 1 inch minus trophy rock are bagged.
Emissions from warehouse activities and bagging system are
controlled by a small baghouse that vents to the inside of the
warehouse or a larger baghouse that vents to the atmosphere.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN106750009-19, dated
October 25, 2019

NSPS (Part 60) OOO: Standards of Performance for Nonmetallic
Mineral Processing Plants

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Redmond Minerals, Incorporated
Salt & Clay Mining and Salt Production Plant

6005 North 100 West, P.O. Box 219 6005 North 100 West Redmond
Redmond, UT 84652 Sanpete County, UT 84652

SIC Code: 1479: (Chemical & Fertilizer Mineral Mining, 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
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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. Unpermitted equipment was observed at the time of inspection.
See Section II for more details. The equipment appeared to be properly operated and
maintained according to manufacturer recommendations. Records are kept as required
and were made available after the inspection. No breakdowns have been reported since the
previous inspection. An emissions inventory was submitted for 2023, and emissions data
are reported below.

Section II: SPECIAL PROVISIONS

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

II.A.1 Salt & Clay Mining Operations & Salt Bagging Plant

II.A.2 One (1) Primary System Crusher
Capacity: 400 tph
NSPS Applicability: Subpart OOO

II.A.3 Primary System Screen
Size: 6' x 16'
NSPS Applicability: Subpart OOO

II.A.4 One (1) Primary System Cone Crusher
Capacity: 300 tph
NSPS Applicability: Subpart OOO

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II.A.5 One (1) Secondary System Apron Feeder
NSPS Applicability: Subpart OOO

II.A.6 One (1) Secondary System Jaw Crusher
Capacity: 200 tph
NSPS Applicability: Subpart OOO

II.A.7 One (1) Secondary System Screen
Size: 5' x 16'
NSPS Applicability: Subpart OOO

II.A.8 One (1) Secondary System Roll Crusher
Capacity: 100 tph
NSPS Applicability: Subpart OOO

II.A.9 One (1) Secondary System Baghouse
Flow rate: 9,465 ACFM
Controls: Secondary Salt System process streams
NSPS Applicability: Subpart OOO

II.A.10 One (1) R.S. System Cone Storage Bin
Capacity: 50 tons
NSPS Applicability: Subpart OOO

II.A.11 R.S. System Pug Mill
NSPS Applicability: Subpart OOO

II.A.12 One (1) Salt Rotary Dryer
Capacity: 12 MMBTU/hr
Fuel: Natural Gas

II.A.13 Milled Products System Hammer Mill
Capacity: 20 tph
NSPS Applicability: Subpart OOO

II.A.14 Milled Products System Screen (new)
Size: 6' x 18'
NSPS Applicability: Subpart OOO

II.A.15 Milled Products System Baghouse
Flow Rate: 7,875 ACFM
Controls: Milled Products System Screen process streams

II.A.16 Milled Products System Screen Baghouse (new)
Flow Rate: 3,015 ACFM
Controls: Milled Product System process streams

II.A.17 Food Salt System Gleason Crusher
Capacity: 5 tph
NSPS Applicability: Subpart OOO

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II.A.18 Food Salt System Storage Bin
Capacity: 15 ton
NSPS Applicability: Subpart OOO

II.A.19 Two (2) Food Salt System Hammer Mills
Capacity: 2 tph each
NSPS Applicability: Subpart OOO

II.A.20 Two (2) Food Salt System Fines Screens
Size: 60" diameter each
NSPS Applicability: Subpart OOO

II.A.21 One (1) Food Salt System Baghouse
Flow Rate: 3,375 ACFM
Controls: Food Salt System process streams

II.A.22 Enclosed Mixing System
Control: Baghouse
NSPS Applicability: Subpart OOO

II.A.23 Mixing System Baghouse
Flow Rate: 1,500 ACFM
Controls: Enclosed Mixing System process streams
- vents inside the warehouse -
NSPS Applicability: Subpart OOO

II.A.24 Enclosed Bagging System
Control: Baghouse
NSPS Applicability: Subpart OOO

II.A.25 One (1) Bagging System Baghouse
Flow Rate: 2,200 ACFM
Controls: Enclosed Bagging System process streams

II.A.26 Various Conveyors
NSPS Applicability: Subpart OOO

II.A.27 Various Storage Bins
NSPS Applicability: Subpart OOO

II.A.28 Various Space Heaters
Rating: <5 MMbtu/hr Each

Status: Out of Compliance. Unapproved equipment was observed at the time of inspection
including a new primary system cone crusher, a new salt rotary dryer, and two new
food salt system fine screens. A Compliance Advisory (DAQC-804-24) for the
unpermitted equipment was issued on August 9, 2024. The source responded on
August 13, 2024. An Early Settlement Agreement (DAQC-888-24) was issued on
September 9, 2024. A Signed Early Settlement Agreement (DAQC-1030-24) was
issued on October 11, 2024.

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II.B Requirements and Limitations

II.B.1 Site-wide Requirements

II.B.1.a The owner/operator shall not process more than 750,000 tons of salt per rolling 12-month period
in the salt processing plant. [R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
of processing shall be kept for all periods when the plant is in operation. Processing shall be
determined by sales records and/or volumetric survey. The records of processing shall be kept
on a daily basis. [R307-401-8]

Status: In Compliance. For the rolling 12-month period from July 2023 – June 2024, a
total of 667,431 tons of salt were produced. See the attached spreadsheet.

II.B.1.b Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any stationary source on site to exceed 10 percent opacity. [R307-401-8]

II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources
shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3]

Status: Out of Compliance. A VEO was performed where a conveyor drops onto the
primary system screen. Average opacity was 11.875 percent over six minutes. A
Compliance Advisory (DAQC-804-24) for the opacity exceedance was issued on August 9,
2024. The source stated they would install rubber wind strips to help control emissions.
No further action is recommended at this time.

II.B.2 Salt & Clay Surface Mining Requirements

II.B.2.a The owner/operator shall not exceed the following mine outputs per rolling 12-month total:
A. 100,000 tons of salt from the salt surface mine
B. 100,000 tons of clay from the clay surface mine. [R307-401-8]

II.B.2.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 salt surface and clay surface mining shall be kept for all periods when the plant is in operation.
Mining shall be determined by sales records and/or volumetric survey. The records of salt
surface and clay surface mining shall be kept on a daily basis. [R307-401-8]

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

A) 0 tons of salt from the salt surface mine
B) 20,000 tons of clay from the clay surface mine.

II.B.2.b The clay haul trucks shall not exceed 1,433 miles of travel combined per rolling 12-month period
between the clay mining location and the site entrance or clay processing plant. [R307-401-8]

II.B.2.b.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 vehicle miles traveled shall be kept for all periods when the plant is in operation. Vehicle
miles traveled shall be determined by maintaining of an operations log for each clay haul truck.
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The records of vehicle miles traveled shall be kept on a daily basis. [R307-401-8]

Status: In Compliance. For the rolling 12-month period from July 2023 – June 2024, the
clay haul trucks traveled 394 miles.

II.B.2.c The owner/operator shall not conduct more than 94 blasts of explosives within the surface mine
per rolling 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. Number
of blasts shall be determined by supervisor monitoring and maintaining of an operations log.
[R307-401-8]

Status: In Compliance. Salt is mined underground, and clay is surface mined. Explosives
are not required to mine the clay. No surface blasts have occurred in the past twelve
months.

II.B.2.d The owner/operator shall not use more than 70.5 tons of explosives within the surface mine per
rolling 12-month period. [R307-401-8]

II.B.2.d.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. Amount
of explosives used shall be determined by purchasing records or maintaining an operations log.
[R307-401-8]

Status: In Compliance. No explosives have been used within the surface mine in the past
twelve months.

II.B.3 Baghouse and Enclosure Requirements

II.B.3.a The owner/operator shall not allow visible emissions from any building or baghouse on site to
exceed 7 percent opacity. [R307-401-8]

Status: Out of Compliance. A VEO was performed where a conveyor drops onto the
primary system screen. Average opacity was 11.875 percent over six minutes. A
Compliance Advisory (DAQC-804-24) for the opacity exceedance was issued on August 9,
2024. The source stated they would install rubber wind strips to help control emissions.
No further action is recommended at this time.

II.B.3.b The owner/operator shall maintain the manometer or magnehelic pressure gauges on each
baghouse on site to measure the differential pressure drop. The static pressure differential across
each baghouse shall be maintained according to the manufactures' specifications. The pressure
gauge shall be located such that an inspector/operator can safely read the indicator at any time.
The reading shall be accurate to within plus or minus 0.5 inches water column. The instrument
shall be calibrated according to the manufactures' instructions annually. The differential pressure
drop shall be recorded on a monthly basis. [R307-401-8]

Status: In Compliance. All of the baghouse manometers are replaced each year. The
gauges are located in areas were inspectors can easily read them. See attached for
replacement records and some examples of magnehelic readings.

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II.B.3.c The owner/operator shall route all emissions from the Secondary System to the Secondary
System Baghouse before venting to the atmosphere. [R307-401-8]

Status: In Compliance. All emissions from the secondary system are routed through the
baghouse accordingly.

II.B.3.d The owner/operator shall route all emissions from the rotary dryer, hammer mill, and elevator in
the Milled Products System to the Milled Products System Baghouse before venting to the
atmosphere. [R307-401-8]

Status: In Compliance. All emissions from the rotary dryer, hammer mill, and elevator are
routed through the baghouse accordingly.

II.B.3.e The owner/operator shall route all the emissions from the Milled Product System Screen to the
Milled Products System Screen Baghouse before venting to the atmosphere. [R307-401-8]

Status: In Compliance. All emissions from the milled product system screen are routed
through the baghouse accordingly.

II.B.3.f The owner/operator shall route all emissions from the Food Salt System to the Food Salt System
Baghouse before venting to the atmosphere. [R307-401-8]

Status: In Compliance. All emissions from the food salt system are routed through the
baghouse accordingly.

II.B.3.g The owner/operator shall route all emissions from the Enclosed Mixing System to the Mixing
System Baghouse before venting to the atmosphere. [R307-401-8]

Status: In Compliance. All emissions from the enclosed mixing system are routed through
the baghouse accordingly.

II.B.3.h The owner/operator shall route all emissions from the Enclosed Bagging System to the Bagging
System Baghouse before venting to the atmosphere. [R307-401-8]

Status: In Compliance. All emissions from the enclosed bagging system are routed through
the baghouse accordingly.

II.B.4 Haul Roads and Fugitive Dust Sources Requirements

II.B.4.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources
on site to exceed 20 percent opacity. [R307-205-4]

II.B.4.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile
equipment in operational areas shall use procedures similar to Method 9. The normal
requirement for observations to be made at 15-second intervals over a six-minute period,
however, shall not apply. Visible emissions shall be measured at the densest point of the plume
but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height
of the vehicle. [R307-205-4]

Status: In Compliance. There were no visible fugitive dust emissions observed at the time
of inspection. The source takes steps to minimize fugitive dust by watering roads and
restricting the speed of vehicles involved in the operation.

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II.B.4.b The owner/operator shall treat all unpaved haul roads and operational areas on site with salt brine
to maintain opacity limits listed in this AO. The owner/operator may stop treatment when the
temperature is below freezing. [R307-401-8]

II.B.4.b.1 Records of haul road treatment 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, dilution ratio, and quantity of water or brine applied
C. Rainfall amount received, if any
D. Records of temperature, if the temperature is below freezing. [R307-401-8]

Status: In Compliance. The source applies water and brine regularly. Records of
treatments are kept in the water truck. See the attached watering logs for 2024.

II.B.4.c The owner/operator shall apply water to clay storage piles as needed to form crusts to minimize
generation of fugitive dusts and to maintain opacity limits listed in this AO. [R307-401-8]

Status: In Compliance. Clay storage piles appeared to have a crust to minimize fugitive
dust.

II.B.4.d The owner/operator shall work (disked and/or piled) the clay drying pads only when the wind
velocity is less than 15 mph. [R307-401-8]

Status: In Compliance. Source contacts stated that no disking or piling of the clay takes
place at this time.

II.B.4.e The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive
Emission and Fugitive Dust sources on site. [R307-205]

Status: In Compliance. There were no visible fugitive dust emissions observed at the time
of inspection. The source operates according to a FDCP.

II.B.5 Crusher, Screens, and Conveyors Subject to NSPS Subpart OOO Requirements

II.B.5.a The owner/operator shall conduct an initial performance test for all baghouses, crushers, screens,
and conveyor transfer points subject to this AO that are subject to NSPS OOO. Performance tests
shall meet the limitations specified in Table 2 to Subpart OOO for stack emissions and Table 3 to
Subpart OOO for fugitive emissions. Records of initial performance tests shall be kept and
maintained on site for the life of the equipment. [40 CFR 60 Subpart OOO]

II.B.5.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(b) for stack emission limits and 40 CFR 60.675(c) for fugitive emission limits. 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(b) and 40 CFR 60.675(c).
[40 CFR 60 Subpart OOO]

II.B.5.a.2 The owner/operator shall keep and maintain records of the initial performance test for each
baghouse, crusher, screen, and conveyor for the life of the equipment. The owner/operator shall
submit written reports of the results of all performance tests to the Director.
[40 CFR 60 Subpart OOO]

Status: In Compliance. See attached for initial performance tests for the new cone crusher
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and the food salt screens. All other initial performance tests were included with previous
inspections from the DAQ.

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: Out of Compliance. The source has not been performing monthly inspections of nozzle sprays.
They have tracked the amount of liquid per ton that is added to the material for each shift. Compliance
assistance was provided, and the source stated that going forward they would perform monthly nozzle
inspections. See the attached liquid addition records and email correspondence.

See attached for initial performance tests for the new cone crusher and the food salt screens. All other
initial performance tests were included with previous inspections from the DAQ.

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. Ultra-low sulfur diesel fuel is utilized. See the attached fuel invoices.

Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

Status: In Compliance. There were no visible fugitive dust emissions observed at the time of
inspection. The source takes steps to minimize fugitive dust by watering roads and restricting the
speed of vehicles involved in the operation.

Stationary Sources [R307-210]

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

EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Redmond Minerals, Incorporated – Salt &
Clay Mining and Salt Production Plant for the 2023 emissions year. A comparison of the estimated total
potential emissions (PTE) on AO: DAQE-AN106750009-19, dated October 25, 2019, is provided. PTE are
supplied for supplemental purposes only.

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Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 2000.00 N/A
Carbon Monoxide 6.69 0.26754
Nitrogen Oxides 5.76 0.3185
Particulate Matter - PM10 27.43 11.14984
Particulate Matter - PM2.5 6.88 0.40136
Sulfur Dioxide 0.14 0.00191
Volatile Organic Compounds 0.28 0.01752

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN106750009-19, dated
October 25, 2019, the overall status is: Out of Compliance. A
Compliance Advisory (DAQC-804-24) for unpermitted equipment
was issued on August 9, 2024. The source responded on August 13,
2024. An Early Settlement Agreement (DAQC-888-24) was issued
on September 9, 2024. A Signed Early Settlement Agreement
(DAQC-1030-24) was issued on October 11, 2024.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Check to see if new AO has been issued or is in progress. The source
indicated that they would submit a NOI by the end of 2024. Ensure
that monthly nozzle spray inspections are being recorded as required
by 40 CFR Part 60 Subpart OOO.

NSR RECOMMENDATIONS: Look for NOI for unpermitted equipment.

ATTACHMENTS: VEO form, email correspondence, rolling 12 sheets, ULSD invoices,
OOO initial performance tests, liquid added per shift, additional email
correspondence
Daniel Riddle <[e-mail]>
(no subject)
1 message
Daniel Riddle <[e-mail]>Wed, Jul 31, 2024 at 8:31 AM
To: "[e-mail]" <[e-mail]>
Mike,
Thanks for taking the time to meet with me Monday for your air quality inspection. As discussed, here are the records I require to complete my
inspection report:
From AO DAQE-AN106750009-19:
Condition II.B.1.a - tonnage of solt production (July 2023 - June 2024)
Condition II.B.2.a - tonnage of clay mined (July 2023 - June 2024)
Condition II.B.2.b - miles of travel by clay haul trucks (July 2023 - June 2024)
Condition II.B.3.b - record of annual magnehelic gauge calibration for all baghouses
Condition II.B.4.b - record of haul road treatment with salt brine
Condition II.B.5.a - OOO initial performance evaluation for the new cone crusher installed in January 2024
Please provide these records by August 7, 2024. Thanks and let me know if you have any questions.
Best,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
AN106750009-19.rtf
137K
9/18/24, 9:30 AM State of Utah Mail - (no subject)
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-6666863735045787263&simpl=msg-a:r-85754826921295…1/1
Daniel Riddle <[e-mail]>
2024 Inspection follow up
7 messages
Mike Forbush <[e-mail]>Tue, Aug 6, 2024 at 9:50 AM
To: Daniel Riddle <[e-mail]>
Hello Daniel,

The information you requested is below:

Condition II.B.1.a - tonnage of salt production (July 2023 - June 2024)
We have produced 667,431 tons of salt during the time frame listed above.

Condition II.B.2.a - tonnage of clay mined (July 2023 - June 2024)
We have mined 20,000 tons of clay during the time frame listed above.

Condition II.B.2.b – miles of travel by clay haul trucks (July 2023 – June 2024)
The clay haul trucks traveled 394 miles during the time frame listed above.

Condition II.B.3.b - record of annual magnehelic gauge calibration for all baghouses
All magnahelics were replaced on 8-1-24. The records are attached.

Condition II.B.4.b - record of haul road treatment with salt brine
The water records are attached.

Condition II.B.5.a - OOO initial performance evaluation for the new cone crusher installed in January 2024
We will complete the OOO evaluation this week, I will send it to you as soon as it is completed.

Thanks
Mike Forbush
(43)979-4629
2 attachments
9/18/24, 9:31 AM State of Utah Mail - 2024 Inspection follow up
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1806653921531075551&simpl=msg-f:18066539215310755…1/3
Watering Records.pdf
1017K
Mill Magnahelic Records.pdf
2746K
Daniel Riddle <[e-mail]>Tue, Aug 6, 2024 at 11:10 AM
To: Mike Forbush <[e-mail]>
Thanks Mike. I'll let you know if I have any questions. I'll look for the OOO evaluation from you later.
[Quoted text hidden]
Mike Forbush <[e-mail]>Tue, Aug 13, 2024 at 9:29 AM
To: Daniel Riddle <[e-mail]>
Hello Daniel,
We have completed the necessary opacity observations in order to comply with 40 CFR 60 Subpart OOO.
The results of these observations are attached as well as certification documents for the observer.
Let me know if you have any questions…
Thanks
Mike Forbush
[Quoted text hidden]
Cone Crusher OOO.pdf
787K
Daniel Riddle <[e-mail]>Wed, Aug 14, 2024 at 2:23 PM
To: Mike Forbush <[e-mail]>
Thank you for sending this!
[Quoted text hidden]
Daniel Riddle <[e-mail]>Tue, Sep 10, 2024 at 5:12 PM
To: Mike Forbush <[e-mail]>
Mike - I had a few questions after reviewing your records:
Do you use any diesel fuel in mobile equipment? If so, could you send me verification that the diesel purchased is
Ultra Low Sulfur Diesel fuel?
Were OOO initial performance tests performed for the tw new food salt system fines screens that were installed
after the issuance of the 2019 AO? If so, could you send those to me? Condition II.A.20 says these are subject to
Subpart OOO.
Could you send spreadsheets that verify the rolling 12-month totals listed above? At least with the monthly total for
each month from July 2023 - June 2024. I need to verify that the maximum tonnage was never exceeded during
that period. (Conditions II.B.1.a for tonnage of salt, II.B.2.a for tonnage of clay mined, and II.B.2.b for
Please provide these by September 17, 2024 if possible. Thanks and let me know if you have any questions.
Best,
Daniel
[Quoted text hidden]
Mike Forbush <[e-mail]>Wed, Sep 11, 2024 at 11:51 AM
9/18/24, 9:31 AM State of Utah Mail - 2024 Inspection follow up
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1806653921531075551&simpl=msg-f:18066539215310755…2/3
To: Daniel Riddle <[e-mail]>
Hi Daniel,
I was just going to reach out, I have not seen a letter regarding or ESA that you mentioned earlier. Just
wondering if you can send this to me electronically?

As for your questions:

1. We do use Ultra Low Sulfur Diesel fuel, our supplier is sending me a certificate. I will forward it today.
2. We have not completed a OOO performance test for the food salt screens. We can do it this week?
3. We use paper records for the clay mining, they are attached. The salt production numbers are
attached.

Thanks
Mike

From: Daniel Riddle <[e-mail]>
Sent: Tuesday, September 10, 2024 5:12 PM
To: Mike Forbush <[e-mail]>
Subject: Re: 2024 Inspecon follow up

Mike - I had a few questions after reviewing your records: Do you use any diesel fuel in mobile equipment? If so, could you send me verification that the diesel purchased is Ultra Low Sulfur Diesel fuel? Were OOO initial performance tests performed
[Quoted text hidden]
2 attachments
Rolling 12 Month Clay Production.pdf
736K
Rolling 12 Month Salt Production .xlsx
17K
Daniel Riddle <[e-mail]>Mon, Sep 16, 2024 at 11:30 AM
To: Mike Forbush <[e-mail]>
Mike - thank you for sending these as well as the ULSD verification. Please send the performance tests once your
employee has completed them.
[Quoted text hidden]
9/18/24, 9:31 AM State of Utah Mail - 2024 Inspection follow up
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1806653921531075551&simpl=msg-f:18066539215310755…3/3
Daniel Riddle <[e-mail]>
FW: Low Sulfur Diesel Certificate
1 message
Mike Forbush <[e-mail]>Wed, Sep 11, 2024 at 2:56 PM
To: Daniel Riddle <[e-mail]>
Daniel,
This is the information on the ultra low sulfur content diesel fuel we are using at Redmond Minerals….
Thanks
Mike

From: Jackson Jenkins <[e-mail]>
Sent: Wednesday, September 11, 2024 1:36 PM
To: Mike Forbush <[e-mail]>
Cc: Jordan <[e-mail]>; Jake Albrecht <[e-mail]>
Subject: Low Sulfur Diesel Certificate

Hello Mike, I have attached documentation for the sulfur content of the diesel we have been supplying to your Redmond mine. The first document states that the Sulfur in these diesel batches ranges from 7.2-12.0 ppm, which is well below the
Hello Mike,

I have attached documentation for the sulfur content of the diesel we have been supplying to your Redmond mine. The
first document states that the Sulfur in these diesel batches ranges from 7.2-12.0 ppm, which is well below the 15ppm
threshold. The second document is the latest Bill of Lading we delivered which states the dyed diesel fuel is described
as a 15 ppm sulfur maximum.

Please let me know if this is adequate or whether you need additional information. Thank you again and have a nice
day!

Thanks,

Jackson Jenkins
Business Manager
O: (435)-586-6931
9/16/24, 11:19 AM State of Utah Mail - FW: Low Sulfur Diesel Certificate
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1809934649982469662&simpl=msg-f:1809934649982469662 1/2

2 attachments
090924 TK532 PP Corrected.pdf
66K
BOL# 114648.pdf
860K
9/16/24, 11:19 AM State of Utah Mail - FW: Low Sulfur Diesel Certificate
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1809934649982469662&simpl=msg-f:1809934649982469662 2/2
Daniel Riddle <[e-mail]>
Food Salt Screen Performance Test
2 messages
Mike Forbush <[e-mail]>Wed, Sep 18, 2024 at 8:28 AM
To: Daniel Riddle <[e-mail]>
Hey Daniel,
The opacity test results are attached for the Food Salt Screens. Let me know if you have any questions…
Thanks
Mike
Food Salt Screen OOO.pdf
837K
Daniel Riddle <[e-mail]>Wed, Sep 18, 2024 at 9:29 AM
To: Mike Forbush <[e-mail]>
Thank you for sending this!
[Quoted text hidden]
9/18/24, 9:29 AM State of Utah Mail - Food Salt Screen Performance Test
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-f:1810544405590555089&simpl=msg-f:18105444055905550…1/1
July 2015 43,135 QTR #1 550,252
August 2015 43,769 QTR #2 549,696
September 2015 46,487 2015 QTR #3 547,964
October 2015 48,969 QTR #4 537,503 546,354 Average
November 2015 37,524
December 2015 36,707
January 2016 40,451
February 2016 42,275
March 2016 56,160
April 2016 33,814
May 2016 45,722 QTR #1 546,743
June 2016 54,420 529,433 2016 QTR #2 540,128
July 2016 43,671 529,969 QTR #3 556,449
August 2016 57,629 543,829 QTR #4 558,339 550,415 Average
September 2016 48,191 545,533
October 2016 50,499 547,063
November 2016 45,934 555,473
December 2016 34,821 553,587
January 2017 53,043 566,179
February 2017 53,986 577,890
March 2017 50,697 572,427
April 2017 47,675 586,288 QTR #1 572,683
May 2017 50,028 590,594 2017 QTR #2 581,543
June 2017 44,779 580,953 QTR #3 580,800
July 2017 44,498 581,780 QTR #4 575,370 577,599 Average
August 2017 58,639 582,790
September 2017 45,506 580,105
October 2017 42,590 572,196
November 2017 42,974 569,236
December 2017 40,367 574,782
January 2018 58,386 580,125
February 2018 48,332 574,471
March 2018 57,594 581,368
April 2018 56,407 590,100 QTR #1 581,964
May 2018 46,514 586,586 2018 QTR #2 589,675
June 2018 47,622 589,429 QTR #3 598,584
July 2018 50,014 594,945 QTR #4 606,667 594,223 Average
August 2018 57,140 593,446
September 2018 50,639 598,579
Total Mill Production #'s
12 Month Rolling Monthly 12 Month Rolling Quarterly
October 2018 54,951 610,940
November 2018 45,696 613,662
December 2018 31,404 604,699
January 2019 28,864 575,177
February 2019 43,780 570,625
March 2019 41,088 554,119
April 2019 40,612 538,324
May 2019 41,905 533,715 QTR #1 556,041
June 2019 39,777 525,870 2019 QTR #2 527,809
July 2019 43,023 518,879 QTR #3 500,661
August 2019 45,307 549,363 QTR #4 523,400 526,978 Average
September 2019 42,317 498,724
October 2019 51,414 495,187
November 2019 43,472 492,963
December 2019 61,832 523,391
January 2020 67,975 562,502
February 2020 64,815 583,537
March 2020 66,985 609,434
April 2020 70,088 638,910
May 2020 54,731 651,736
June 2020 54,985 666,944 QTR #1 609,433
July 2020 47,669 671,590 2020 QTR #2 666,964
August 2020 47,009 673,292 QTR #3 680,910
September 2020 49,830 680,805 QTR #4 657,611 653,730 Average
October 2020 51,228 680,619
November 2020 37,602 674,749
December 2020 44,637 657,554
January 2021 50,340 639,918
February 2021 47,957 623,060
March 2021 57,100 613,175
April 2021 48,404 591,491
May 2021 41,773 578,533
June 2021 51,515 575,063 QTR #1 613,591
July 2021 43,710 571,104 2021 QTR #2 575,457
August 2021 53,635 577,730 QTR #3 578,846
September 2021 50,173 578,073 QTR #4 580,942 587,209 no drone ad
October 2021 48,131 574,976
November 2021 51,929 589,303
December 2021 34,900 579,566
January 2022 37,057 566,284
February 2022 43,468 561,795
March 2022 46,705 551,400
April 2022 35,221 538,217
May 2022 33,744 530,188 QTR #1 552,184
June 2022 45,002 523,675 2022 QTR #2 524,459
July 2022 33,789 513,754 QTR #3 491,106
August 2022 44,348 504,467 QTR #4 468,210 508,990
September 2022 36,457 490,752
October 2022 36,282 478,903
November 2022 36,565 463,539
December 2022 39,806 468,445
January 2023 46,297 477,685
February 2023 53,047 487,263
March 2023 49,058 489,616
April 2023 59,990 514,385 QTR #1 489,616
May 2023 62,287 542,928 2023 QTR #2 548,886
June 2023 50,962 548,889 QTR #3 612,368
July 2023 48,800 563,900 QTR #4 665,262
August 2023 66,049 585,600
September 2023 63,226 612,369
October 2023 65,439 641,527
November 2023 49,747 654,709
December 2023 50,362 665,265
January 2024 55,132 674,100 not including drone
February 2024 57,836 678,889
March 2024 49,737 679,567
April 2024 42,162 661,739 QTR #1 679,564
May 2024 60,772 660,225 2024 QTR #2 667,428
June 2024 58,168 667,431 QTR #3 489,354
July 2024 70,672 689,303 QTR #4 323,807
August 2024 623,254
September 2024 560,028
October 2024 494,588
November 2024 444,841
December 2024 394,479
January 2024 339,347 not including drone
February 2024 281,511
March 2024 231,774
April 2024 189,612 QTR #1 604,752
May 2024 128,840 2025 QTR #2 555,900
June 2024 70,672 QTR #3 445,927
July 2024 - QTR #4 274,146
August 2024 -
September 2024 -
October 2024 -
November 2024 -
December 2024 -

dded into these figures
HF Sinclair Parco Refining LLC ⦁Laboratory Services ⦁Sinclair, WYCertificate of Analysis, Pioneer Pipeline#2 ULSD Diesel Fuel
Transferor:HF Sinclair Parco Refining LLC100 E. Lincoln Highway ⦁ PO Box 277Sinclair, WY 82334EPA Company ID: 5053, Facility ID: 23521
Transferee:ConocoPhillipsPioneer Pipeline600 N. Dairy Ashford RoadHouston, TX 77079-1175EPA Company ID: 4528, Facility ID: 82245
Sample Date: 9/9/2024 Tester(s): Madison Praytor, Allison Ritschard
Tank Number: Tank 532 Sampler: C. Roberts
LIMS ID: 837432 EPA Batch Number: 5053-23521-24-500241
Tender:
Available BBLS:
Approved By: Date: 9/10/2024
Allison Ritschard
#2 Diesel 15ppm w/w Sulfur Motor Vehicle Diesel Fuel.
15 ppm sulfur (maximum) Undyed Ultra-Low Sulfur Diesel Fuel. For use in all diesel vehicles and engines.
Lubricity/conductivity additives may need to be added at the terminal in order for the fuel to meet ASTM D975
requirements.
SPECIFICATIONSTestMETHODRESULT
MINIMUM MAXIMUM
Gravity, API @ 60°F ASTM D4052 37.1 30.0
Flash Point (PMCC), °F ASTM D93 151.0 135.0
Haze @ 70°F ASTM D4176, Proc. 2 1 2
Bright & Clear ASTM D4176 Pass PASS
Color ASTM D1500 <0.5 2.5
Ash, wt%ASTM D482 <0.001 0.010
Distillation @ 760mmHg, °F ASTM D86
IBP 335.6 REPORT
10 vol.% Recovered 406.2 REPORT
50 vol.% Recovered 507.8 REPORT
90 vol.% Recovered 612.9 540.0 640.0
FBP 661.2 698.0
% Total Recovered 99.6 REPORT
% Residue 1.4 REPORT
BS&W, vol%ASTM D2709 0.025 0.050
Sulfur, ppm ASTM D7039 7.2 12.0
Copper Strip Corrosion, 3hr @ 122°F ASTM D130 1a 1b
CR, Ramsbottom, wt%ASTM D524 0.04 0.35
Thermal Stability, Y Filter ASTM D6468 99 82
Cetane Index, 4V ASTM D4737, Proc. A 49.8 40.0
Cetane Index, 2V ASTM D976 50.2 40.0
Cloud Point, °F ASTM D5773 7.4 10.0
Pour Point, °F ASTM D5949 5 0
Conductivity, pS/m @ T, °C ASTM D2624 0 @ 22.7 10
Viscosity @ 104°F, cSt ASTM D445 2.650 1.9 3.4
NACE Rust Test, Rating TM0172-2001 A B+
Daniel Riddle <[e-mail]>
Monthly nozzle inspections
5 messages
Daniel Riddle <[e-mail]>Wed, Oct 9, 2024 at 10:51 AM
To: Mike Forbush <[e-mail]>
Mike,
You use wet suppression systems to control emissions on your equipment, correct? Are monthly (or more often) nozzle inspections performed? This
is required by 40 CFR Part 60 Subpart OOO (https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-60/subpart-OOO)
(b) The owner or operator of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that
uses wet suppression to control emissions from the affected facility must perform monthly periodic inspections to check that water is flowing to
discharge spray nozzles in the wet suppression system. The owner or operator must initiate corrective action within 24 hours and complete corrective
action as expediently as practical if the owner or operator finds that water is not flowing properly during an inspection of the water spray nozzles. The
owner or operator must record each inspection of the water spray nozzles, including the date of each inspection and any corrective actions taken, in
the logbook required under § 60.676(b).
Let me know how you perform these inspections at least once a month.
Thanks,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Mike Forbush <[e-mail]>Mon, Oct 14, 2024 at 11:25 AM
To: Daniel Riddle <[e-mail]>
Hi Daniel,
Sorry, I was away on vacation last week. I was not aware of this requirement. We do track how many gallons of liquid per ton is
added to the material each shift. These records are available if they will satisfy this requirement? Let me know…
Thanks
Mike

From: Daniel Riddle <[e-mail]>
Sent: Wednesday, October 9, 2024 10:52 AM
To: Mike Forbush <[e-mail]>
Subject: Monthly nozzle inspecons

Mike, You use wet suppression systems to control emissions on your equipment, correct? Are monthly (or more often) nozzle inspections performed? This is required by 40 CFR Part 60 Subpart OOO (https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-60/subpart-OOO
Mike,

You use wet suppression systems to control emissions on your equipment, correct? Are monthly (or more often) nozzle inspections performed? This
is required by 40 CFR Part 60 Subpart OOO (https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-60/subpart-OOO)
10/29/24, 10:19 AM State of Utah Mail - Monthly nozzle inspections
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r2347903370087999649&simpl=msg-a:r-37627627093563…1/2

(b) The owner or operator of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that
uses wet suppression to control emissions from the affected facility must perform monthly periodic inspections to check that water is flowing to
discharge spray nozzles in the wet suppression system. The owner or operator must initiate corrective action within 24 hours and complete
corrective action as expediently as practical if the owner or operator finds that water is not flowing properly during an inspection of the water spray
nozzles. The owner or operator must record each inspection of the water spray nozzles, including the date of each inspection and any corrective
actions taken, in the logbook required under § 60.676(b).

Let me know how you perform these inspections at least once a month.

Thanks,
Daniel

--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov

Daniel Riddle <[e-mail]>Tue, Oct 15, 2024 at 11:32 AM
To: Mike Forbush <[e-mail]>
Send that record please, but this would not satisfy the requirement. The purpose of this requirement is to ensure that sprays are functioning properly
and do not need any maintenance to keep the dust down. If you will add this to your monthly tasks going forward, I will make a note of that in your
memo for the next inspection. Can you add this to your SOP? Many sites simply have a check for each nozzle on whether it is properly spraying or
not.
[Quoted text hidden]
Mike Forbush <[e-mail]>Tue, Oct 29, 2024 at 9:16 AM
To: Daniel Riddle <[e-mail]>
Hi Daniel,
Sorry for the delay. Our production sheets are attached, showing the amount of liquid per ton of product. We have updated our
systems to include a monthly nozzle check.
[Quoted text hidden]
image10-29-2024-091406.pdf
2904K
Daniel Riddle <[e-mail]>Tue, Oct 29, 2024 at 10:19 AM
To: Mike Forbush <[e-mail]>
Sounds good - thank you for sending this.
[Quoted text hidden]
10/29/24, 10:19 AM State of Utah Mail - Monthly nozzle inspections
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r2347903370087999649&simpl=msg-a:r-37627627093563…2/2