DAQ-2024-011811

1
DAQC-CI112340001-24
Site ID 11234 (B1)

MEMORANDUM

TO: FILE – STAKER & PARSON COMPANIES – Point of the Mountain Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: November 4, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: September 5, 2024

SOURCE LOCATION: 3.5 miles South of Bluffdale, Exit 291
Bluffdale, UT

DIRECTIONS: From I-15 South, take exit 288. Take Minuteman Drive to the Staker
Parson frontage road to the pit.

SOURCE CONTACTS: Samuel Miles, Supervisor

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

OPERATING STATUS: All aspects of the facility were temporarily down at the time of this
inspection due to a safety meeting and a personnel shift change.

PROCESS DESCRIPTION: Sand and gravel pit (east side) Lower Pit - Material is pushed off the
bank and taken by loader to the 3 Syntron feeders (weigh belt). The
material drops to a splitter and is screened by 2 Simplicity wet
screens. It is then transferred to a vertical impact crusher and
processed in an Eagle wet screen and screw. Upper Pit (east side) -
Material is dropped by front-end loader to a feeder, conveyed to a
splitter, and screened by El Jay and JCI screens. The material is then
transferred to a roller cone for further processing. Product produced is
l/2" rock and 7/8" minus rock.

Ross Central Mix Plant - aggregate is stored in 4 piles each with a
feed belt to a storage bin in an enclosed building. The storage bins
drop the material into a bottom weigh hopper and then dropped onto a
common belt and transferred to the mixing tank. Cement powder and
fly ash are stored in silos. The cement powder and fly ash are dropped
through weigh hoppers and gravity fed to the mixer through
ductwork.

Asphalt Plant - this plant uses aggregate material produced at this
facility. The crushed material is dumped into hoppers according to
size by a front-end loader. The material drops to a conveyor where it
is weighed and transferred to the pug mill along with lime.

2
The milled material is then transferred to a rotary kiln to remove
excess moisture. The heated material is transferred to a weigh hopper
and then into a pug mill where it is mixed with hot asphalt at -3500 C.
The asphaltic concrete is then transferred to a storage silo to be
loaded into haul trucks. The emissions from the rotary kiln, lime, and
cement storage bins are controlled by baghouses.

Concrete batch plant (south east side) - The concrete batch plant
includes one central mix concrete batch plant consisting of cement
silos, fly ash silo, a weight hopper, a boiler, a drum mixer, four
associated baghouses, conveyors and feed bins, and miscellaneous
diesel equipment. Concrete production is limited to 300,000 cubic
yards per 12-month period. Washed sand and gravel aggregate
materials are shipped to the plant in trucks and off-loaded to storage
piles. The aggregate is then scooped up with a front-end loader (FEL)
and dumped into a three-compartment feeder hopper. The aggregate
drops from the feeder hopper to a conveyor belt and is transported to
an enclosed shoot where it is measured as it exits the feeder hopper.
Cement and fly ash are shipped to the plant in trucks and
pneumatically blown into their respective storage silos. There are two
cement silos and one fly ash silo. Each is equipped with a 50-bag, bin
vent, pulsejet baghouse. The sand, gravel, cement, and fly ash are
measured into a weigh hopper, and from there they are fed through
the enclosed shoot into concrete mixer where they are mixed as water
is added. The mixer is controlled by a baghouse. The final wet
mixture is loaded into the transport trucks and transported off-site for
use.

West Side Pit consists of an aggregate wash plant.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN112340015-24, dated
August 5, 2024

NSPS (Part 60) I: Standards of Performance for Hot Mix Asphalt
Facilities

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Staker & Parson Companies
Point of the Mountain Facility

89 West 13490 South, Suite 100 3.5 miles South of Bluffdale, Exit 291
Draper, UT 84020 Bluffdale, UT

SIC Code: 1442: (Construction Sand & Gravel)

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]
3
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. The limits established by this AO were not exceeded based on the
review of the submitted documents. No process changes or additional equipment were
observed. Maintenance occurs and is recorded as required. No applicable breakdowns are
on record. An Emissions Inventory was submitted for the 2023 activity year and is attached
to this inspection memo. The construction status for the new asphalt plant and new fuel
tanks will be submitted to the NSR Engineer, Christine Bodell, as per the attached
November 6, 2024, email.

Section II: SPECIAL PROVISIONS

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

II.A.1 Point of the Mountain Facility

II.A.2 Aggregate Processing

II.A.3 Seventeen (17) Screens
Capacity: 700 tph (each)
NSPS Applicability: Subpart OOO

II.A.4 Two (2) Screens
4
Capacity: 500 tph (each)
NSPS Applicability: Subpart OOO

II.A.5 Two (2) Screens
Capacity: 300 tph (each)
NSPS Applicability: Subpart OOO

II.A.6 Four (4) VSI Crushers
Capacity: 700 tph (each)
NSPS Applicability: Subpart OOO

II.A.7 One (1) VSI Crusher
Capacity: 300 tph
NSPS Applicability: Subpart OOO

II.A.8 Two (2) Cone Crushers
Capacity: 700 tph (each)
NSPS Applicability: Subpart OOO

II.A.9 Two (2) Cone Crushers
Capacity: 500 tph (each)
NSPS Applicability: Subpart OOO

II.A.10 One (1) Cone Crusher
Capacity: 300 tph
NSPS Applicability: Subpart OOO

II.A.11 Two (2) Jaw Crushers
Capacity: 700 tph and 500 tph
NSPS Applicability: Subpart OOO

II.A.12 One (1) Jaw Crusher
Capacity: 500 tph
NSPS Applicability: Subpart OOO

II.A.13 Wet Aggregate Processing
Screens and material washing screws
*Listed for information purposes only*

II.A.14 Two (2) 12-yard Concrete Central Mix Plants
Equipped with handling bins and weigh Batchers

II.A.15 Eight (8) Cement/Flyash silos
Equipped with dust collectors
NSPS Applicability: Subpart I

II.A.16 Two (2) Water Heaters
Rating: 10 MMBtu (each)
Fuel: Natural Gas
NSPS Applicability: Subpart Dc

5
II.A.17 One (1) Drum Mix Asphalt Plant (New)
Drum Rated Capacity: 500 tph
Drum Burner Rating: 150 MMBtu/hr
Burner Fuel: Natural Gas
Control: Baghouse
NSPS Applicability: Subpart I
MACT Applicability: None

II.A.18 One (1) Lime Silo
Equipped with a dust collector
NSPS Applicability: Subpart I

II.A.19 One (1) Pugmill

II.A.20 Six (6) Asphalt Cement Tanks (3 New)
Capacity: 30,000 gallons (each)
NSPS Applicability: Subpart I

II.A.21 Six (6) Asphalt Storage Silos (New)
Capacity: 500 tons (each)
NSPS Applicability: Subpart I

II.A.22 Various Cold Feed Bins
NSPS Applicability: Subpart I

II.A.23 Various RAP Feed Bins
NSPS Applicability: Subpart I

II.A.24 Two (2) 10,000 Gallon Diesel Fuel Tanks

II.A.25 Two (2) 12,000 Gallon Diesel Fuel Tank (New)

II.A.26 One (1) 2,000 Gallon Gasoline Fuel Tank (New)

II.A.27 Associated Equipment
Includes: Front-end Loaders, Bulldozers, Conveyors, Feeders, etc.

II.A.28 Hot Oil Heater
Capacity: 2.8 MMBtu/hr
Fuel: Natural Gas

Status: In Compliance. The permitted equipment has been installed and is operational with
the following exceptions: There are currently only nine of the seventeen screens
installed as per II.A.3. There are currently only three of the VSI Crushers installed
as per II.A.6. There are currently only one of the two cone crushers installed as per
II.A.8. The crushing equipment referenced by II.A.9, II.A.10, II.A.11, and II.A.12 are
not currently on site. There are only 4 of the 8 cement/flyash silos installed at the two
concrete central mix plants. The drum mix asphalt plant permitted by II.A.17 was
not fully operational on the day of this inspection. A Temporary Relocation
Authorization (TRP) dated June 25, 2024 (DAQC-584-24), for two cone crushers, two
screens, and a 745 kW generator was used from May 28, 2024, through August 31,
2024, for a recycling project. This equipment had been removed and was not present
on the day of this inspection. A TRP dated July 18, 2024 (DAQC-716-24), for a 1,000
6
kW generator was approved as a temporary power source to be used until Rocky
Mountain Power can fully install the equipment needed to transfer this site to 100
percent electrical power. This generator project should be completed by the end of
the winter of 2025.

II.B Requirements and Limitations

II.B.1 Site-Wide Requirements

II.B.1.a The owner/operator shall not produce more than the following:

A. 7,800,000 tons of aggregate material per rolling 12-month period

B. 800,000 tons of hot mix asphalt per rolling 12-month period

C. 1,075,000 cubic yards of concrete per rolling 12-month period.

[R307-401-8]

Status: In Compliance. The total rolling 12-month aggregate production for the time
period of August 2023 through July 2024 was reported as 1,387,9936.17 tons. The 12-month
rolling total for this period for Ready Mix concrete production was reported as 192,991.33
tons. The total for the asphalt plant production for this period was reported as 174,949.60
tons. The 12-month rolling aggregate records are the combined totals from the Point East,
Point West, and the recycled material production created by the Temporary Relocation
Equipment permitted on DAQC-584-24. The temporary equipment produced 4,850 tons of
a recycled product that is only used in the concrete batch process. The total 12-month
rolling aggregate production when not including this product, was 1,289,301.17 tons. The
concrete production includes the product from both the Point South and Point West plants.
The asphalt production is based primarily from the older Point East plant, as the new Point
West asphalt plant did not begin operating until the middle of September of 2024. See the
attached email correspondence and product spreadsheets.

II.B.1.a.1 The owner/operator shall:

A. Determine production by scale house records, belt scale records or manifest
statements

B. Record 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. The production totals are derived from weighed product exiting
the facility, with the exception of the recycled material product used as an additive to the
concrete batching process. The weighed totals are from all periods that the respective
processes are in operation. The records are electronically entered into spreadsheets as
required for the monthly totals.
7
II.B.1.b The owner/operator shall not conduct bulldozing operations for more than 4,500 hours total per
rolling 12-month period. [R307-401-8]

Status: In Compliance. The reported bulldozer hours for the 13-month period of August
2023 through August 2024 was 2,462 hours. See the email statement and the "In Field
Equipment Summary."

II.B.1.b.1 The owner/operator shall:

A. Determine hours of operation by monitoring and maintaining an operations log.
The hours of operation of each bulldozer shall be added together to determine the
total hours of bulldozing.

B. Record hours of 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. Hours of operation are based on individual dozer logs and
employee timesheet hours.

II.B.1.c Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions to
exceed the following limits:

A. Crushers - 12% opacity

B. Screens - 7% opacity

C. All Conveyor Transfer Points - 7% opacity

D. Concrete Batch Plants - 7% opacity,

E. All Conveyor Drop Points - 20% opacity

F. Hot Oil Heater, Dryer, Conveyors, Silos, Tanks, and Load Out Areas
Associated with the Hot Mix Asphalt Plant - 10% opacity

G. All Other Points - 20% opacity

[40 CFR 60 Subpart OOO, R307-312, R307-401-8]

II.B.1.c.1 Opacity observations of visible emissions from stationary sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9. [40 CFR 60 Subpart OOO, R307-401-8]

Status: Not Observed. This facility was temporarily down at the time of this inspection due
to an employee safety meeting and a routine shift change.

8
II.B.1.d The owner/operator shall only use natural gas as fuel in the 150 MMBtu/hr asphalt plant drum
mixer burner and in the asphalt plant 2.8 MMBtu/hr hot oil heater. [R307-401-8]

Status: In Compliance. The 500 TPH drum mix asphalt plant permitted by this Approval
Order is designed to use only natural gas.

II.B.2 Haul Roads and Fugitive Dust Requirements

II.B.2.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources
on site to exceed 20% opacity on site and 10% opacity at the property boundary. [R307-309-5,
R307-401-8]

Status: Not Observed. This facility was down at the time of this inspection due to a safety
meeting and staff shift change.

II.B.2.a.1 Opacity observations of fugitive dust from intermittent sources shall be conducted according to
40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at
15-second intervals over a six-minute period shall not apply. The number of observations and the
time period shall be determined by the length of the intermittent source. For fugitive dust
generated by mobile sources, 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. [R307-401-8]

Status: Not Observed. This facility was not operating at the time of this inspection due to a
safety meeting and staff shift change.

II.B.2.b The owner/operator shall control particulate emissions from storage piles, exposed areas, and
other fugitive dust sources using water application. The owner/operator shall apply water as
required to ensure the opacity limits in this AO are not exceeded. [R307-401-8]

Status: In Compliance. No visible dust was observed from the storage piles, exposed areas,
or the operation areas during this inspection.

II.B.2.b.1 Records of treatments to the storage piles, exposed areas, and other fugitive dust sources shall
include:

A. The date, time, and location of applications.

B. The volume of water applied.

[R307-401-8]

Status: In Compliance. Watering records indicate date and time of the applications, the
location of the treatments, and the number of truck loads. See the attached example
records.

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

A. 44 acres combined occupied by all storage piles on site

B. 31 acres combined occupied by all disturbed area on site

[R307-401-8]
9
II.B.2.c.1 To determine compliance with the above limits, the owner/operator shall measure the total area
of the storage piles and/or disturbed areas at least once every twelve (12) months and shall
maintain a record of the total acres of the storage piles and/or disturbed areas. Compliance shall
be determined through GPS measurements or aerial photographs. The area of each storage pile
and/or disturbed areas shall be added together to obtain the total area of all the storage piles and
disturbed areas on site. Records of the total acres of the storage piles and/or disturbed areas shall
contain the following:

A. Date of measurements

B. Size of each storage pile on site and each disturbed area on site

C. Total acres of all storage piles combined and all disturbed areas combined.

[R307-401-8]

Status: In Compliance. The reported total Point of the Mountain storage pile acreage, as
measured on September 3, 2024, and September 27, 2024, was 35.278. The total combines
all product line piles from the Point East, Point South, and Point West stocks. The total
disturbed area acreage was 26.152. The total combines the disturbed areas from the Point
South Ready Mix Concrete operations, the Point East crusher operation, the Point East
south of the old Hot Mix Asphalt Plant, and the Point West area north of the new Hot Mix
Asphalt Plant. See the attached spreadsheet records.

II.B.2.d The owner/operator: A. Shall not have more than 29,700 feet (5.6 miles) of total haul roads (including paved and unpaved haul roads) on site B. Shall not pave less than 9,000 feet (1.7 miles) of haul roads on site [R307-401-8]
II.B.2.d.1 To determine compliance with the above limits, the owner/operator shall measure the paved and
unpaved haul road lengths at least once every twelve (12) months and shall maintain a record of
the lengths of the paved and unpaved haul roads. Compliance shall be determined through GPS
measurements or aerial photographs. [R307-401-8]

Status: In Compliance. The total paved and unpaved haul roads still active for the
combined operations at this facility as measured on September 3, 2024, and September 27,
2024, was reported as 17,531.9 feet. The total paved haul road for this facility as measured
on the same dates was measured at 10,220.6 feet. The measurements were derived from
adding the haul road from each operation and site area. See the attached spreadsheet
records.

II.B.2.e An operational vacuum sweeper and water truck shall be made available during each operating
day. The owner/operator shall vacuum sweep and flush with water all the paved haul roads on
site to maintain opacity limits listed in this AO. If the temperature is below freezing, the
owner/operator shall continue to vacuum sweep the road but may stop flushing the paved haul
roads with water. Flushing the paved haul road with water shall resume when the temperature is
above freezing. If the haul roads are covered with snow or ice, the owner/operator may stop
vacuum sweeping the paved haul roads. Vacuum sweeping the paved haul roads shall resume
when the haul roads are cleared from snow and ice. [R307-401-8]

Status: In Compliance. Staker Parson Companies has a standing contract with Jacketta
Sweeping Service which will bring in a sweeper to each area as needed.
10
II.B.2.e.1 Records of vacuum sweeping and water application shall be kept for all periods when the plant is
in operation. The records shall include the following items:

A. Date and time treatments were made

B. Number of treatments made and quantity of water applied

C. Rainfall amount received, if any

D. Records of temperature, if the temperature is below freezing

E. Records shall note if the paved haul roads are covered with snow or ice.

[R307-401-8]

II.B.2.f The owner/operator shall cover all unpaved haul roads and wheeled-vehicle operational areas
with road base material, and an operational water truck shall be made available during each
operating day. The owner/operator shall use chemical suppressant and water application to
maintain opacity limits listed in this AO. If the temperature is below freezing, the owner/operator
may stop applying chemical suppressant and water to the unpaved haul roads and wheeled-
vehicle operational areas. The owner/operator shall resume applying chemical suppressant and
water to the unpaved haul roads and wheeled-vehicle operational areas when the temperature is
above freezing. [R307-401-8]

Status: In Compliance. Road base gravel has been laid down on all unpaved haul roads
and operational areas. A water truck is on site and available during each day. No opacity
was observed from the applicable areas during this inspection.

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

A. Date and time treatments were made

B. Number of treatments made, quantity of water applied, and chemical dilution ratio
used

C. Rainfall amount received, if any

D. Records of temperature, if the temperature is below freezing.

[R307-401-8]

Status: In Compliance. Water truck logs are kept for all periods when the plant is in
operation. The log includes the date, the areas maintained, and the number of truck loads.
A "weather conditions" check box list has also been incorporated into the log. See the
attached log examples.

II.B.2.g The owner/operator shall comply with a fugitive dust control plan (FDCP) consistent with R307-
309-6. [R307-309-6]

Status: In Compliance. A Fugitive Dust Control Plan was submitted to the DAQ in 2015
and is available in the main POM office.

11
II.B.2.h The owner/operator shall comply with all applicable requirements of R307-309 for Fugitive
Emission and Fugitive Dust sources on site. [R307-309]

Status: In Compliance. The dust control measures are adhered to with regular water
applications and sweeping. No opacities were observed on the day of this inspection.

II.B.2.i The owner/operator shall not exceed a haul road speed limit of 15 miles per hour. The haul road
speed shall be posted, at a minimum, on site at the beginning of the haul road so that it is clearly
visible from the haul road. [R307-401-8]

Status: In Compliance. A 10 miles per hour sign has been posted at the entrance.

II.B.3 Hot Mix Asphalt Plant Requirement
II.B.3.a The owner or operator shall install emission capture and control systems in compliance with UAC R307-313 (VOC and Blue Smoke Controls for Hot Mix Asphalt Plants) that capture and reduce blue smoke emissions from the dryer, conveyors, silos, and load out areas associated with the hot mix asphalt plant. [R307-313, R307-401-8] Status: Not Observed. The new West asphalt plant permitted by Condition II.A.17 was not operating on the day of this inspection. The plant manufacturing specifications are reportedly designed to meet R307-313 for asphalt plants.
II.B.3.b The owner or operator shall operate emission capture and control systems in compliance with
UAC R307-313 (VOC and Blue Smoke Controls for Hot Mix Asphalt Plants) at all times during
the production of asphalt products. [R307-313, R307-401-8]

Status: Not Observed. This plant's installation was not yet completed at the time of this
inspection. The new plant has been manufactured to meet the required controls for all
periods of production.

II.B.3.c The owner/operator shall install a fabric filter on each storage silo associated with the hot mix
asphalt plant to control particulate emissions generated during the filling of the silos. Displaced
air from each silo shall pass through a fabric filter before being vented to the atmosphere.
[R307-401-8]

Status: Not Observed. This plant's installation was not yet completed at the time of this
inspection. An associated baghouse with filters will reportedly be used to control
particulate emissions during all periods when the plant is in operation.

II.B.3.d The HMAP baghouse shall control process streams from the asphalt plant drum mixer. This
baghouse shall be sized to handle at least 75,000 acfm for the existing conditions. All exhaust air
from the HMAP drum mixer shall be routed through the baghouse before being vented to the
atmosphere. [R307-401-8]

Status: Not Observed. This plant's installation was not yet completed at the time of this
inspection. As per the NOI submitted for the current AO modification, the baghouse design
is manufactured to be at least 75,000 acfm.
II.B.3.e The owner/operator shall install a baghouse on the HMAP with a control efficiency of no less than 99.9%. [R307-401-8] Status: Not Observed. This plant's installation was not yet completed at the time of this inspection. As per the NOI submitted for the current AO modification, the baghouse is designed to have an efficiency rating of 99.9%.
12
II.B.3.e.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's control efficiency guarantee for the installed baghouse. [R307-401-8]

Status: In Compliance. Records of the manufacturer's control efficiency guarantee is kept
at the Staker Parson Company offices. A copy of the design specifications are also kept in
the DAQ electronic NOI files for this AO.

II.B.3.f The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across the hot mix asphalt plant baghouse. [R307-401-8]

Status: Not Observed. The referenced asphalt plant was not yet fully installed at the time
of this inspection. The pressure gauge will reportedly operate as required during
production.

II.B.3.f.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

Status: Not Observed. The referenced asphalt plant was not yet fully installed at the time
of this inspection. The pressure gauge will reportedly operate as required during
production.

II.B.3.f.2 The pressure gauge shall measure the static pressure differential in 1-inch water column
increments or less. [R307-401-8]

Status: Not Observed. The referenced asphalt plant was not yet fully installed at the time
of this inspection. The pressure gauge will reportedly operate as required during
production.

II.B.3.g During operation of the baghouse, the owner/operator shall maintain the static pressure
differential across the baghouse between 3 and 7 inches of water column. [R307-401-8]

Status: Not Observed. The referenced asphalt plant was not yet fully installed at the time
of this inspection. The pressure gauge will reportedly operate as required during
production.

II.B.3.g.1 The owner/operator shall maintain the following records of the static pressure differential:

A. Unit identification;

B. Weekly static pressure differential readings;

C. Date of reading.

[R307-401-8]

Status: Not Observed. Records of the static pressure will reportedly be kept as required
when the plant is operating.

II.B.3.h At least once every 12 months, the owner/operator shall calibrate the pressure gauges in
accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]

Status: Not Applicable. The pressure gauge will be calibrated at the correct intervals when
the plant becomes operational.
13
II.B.3.h.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

Status: Not Observed. Staker Parson shall maintain records of the pressure gauge
calibration and replacements when the equipment is operating.

II.B.3.i The owner/operator shall not emit more than the following rates and concentrations from the
Asphalt Plant Baghouse:

Pollutant grains/dscf lb/hr

Filterable PM10 0.015 0.52

Filterable PM2.5 0.015 0.12

The owner/operator shall also test for condensable PM; however, the condensable particulate
emissions shall not be used for compliance demonstration, but shall be used for inventory
purposes.

[R307-401-8]

Status: Not Observed. Staker Parson Companies will test this plant during April – May of
2025. See the attached November 6, 2024, email.

II.B.3.i.1 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]

Status: Not Observed. See the above status line for more information.

II.B.3.i.2 Test Frequency
The owner/operator shall conduct a stack test on the emission unit within three (3) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

II.B.3.j The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.3.j.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.3.j.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.3.j.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

14
II.B.3.j.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.3.j.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.3.k Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.3.k.1 Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K)

B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.3.k.2 Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10. [R307-401-8]

II.B.3.k.3 Filterable PM2.5
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-
approved testing method as acceptable to the Director. If other approved testing methods are
used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the
filterable particulate emissions shall be considered PM2.5. [R307-401-8]

II.B.3.k.4 Condensable PM
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to
the Director. [R307-401-8]

Status: Not Observed. Staker Parson Companies will performed the required stack test
during April – May of 2025.

II.B.4 Fuel Tank Requirements

II.B.4.a The owner/operator shall load the diesel and gasoline fuel tanks on site by the use of submerged
loading. [R307-401-8]

Status: In Compliance. The site supervisor, Samuel Miles, stated that the fuel tanks are
filled by the use of submerged loading. Mr. Miles also stated that the new gasoline tank
(2,000 gallon capacity) has a monthly throughput of under 10,000 gallons. All spills will be
immediately minimized and the tank has gasket seals as required by MACT CCCCCC for
gasoline dispensing equipment of this size.
15
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) I: Standards of Performance for Hot Mix Asphalt Facilities

Status: Not Observed. The asphalt plant permitted by this AO was not yet operating on the day of this
inspection. Staker and Parson Companies will stack test this new plant during April – May of 2025 as
per the attached November 6, 2024, email.

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

Status: In Compliance. Initial Method 9 observations were performed on May 9, 2006, and July 15,
2017. Spray bar nozzle inspections are performed as required. None of the applicable aggregate
equipment was operating on the day of this inspection.

MACT (Part 63) CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category:
Gasoline Dispensing Facilities

Status: In Compliance. This subpart refers to the 2,000-gallon gasoline fuel tank used for miscellaneous
vehicles at this site. The monthly throughput for this tank is under 10,000 gallons per month as the tank
is only sporadically filled throughout the year. Spills are minimized and promptly cleaned up as
required. The tank is loaded as required and has a sealed gasket system.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Stationary Sources [R307-210]

Status: In Compliance. This rule incorporates the NSPS Federal Requirements for Subpart I for
asphalt plants and Subpart OOO for aggregate equipment. See the above references to the federal
requirements for more information.

R307-214. National Emission Standards for Hazardous Air Pollutants

Status: In Compliance. This rule incorporates the Federal Requirements for MACT CCCCCC for
Gasoline Dispensing Facilities. See the above federal reference for this standard.

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

Status: In Compliance. No opacities were observed during this inspection. A Fugitive Dust Control
Plan was submitted in 2015 and is followed accordingly.

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

Status: Not Observed. No opacity was observed from any point of the property boundaries. The
applicable equipment was not operating at the time of this inspection.

16
EMISSION INVENTORY:
An Emission Inventory was submitted for the 2023 Activity Year and the Summary Report has been
attached to this memo. Listed below are the Actual Emissions Inventory provided from Staker & Parson
Companies – Point of the Mountain Facility. A comparison of the estimated total potential emissions (PTE)
on AO: DAQE-AN112340015-24, dated August 5, 2024, is provided. PTE are supplied for supplemental
purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 21761.00
Carbon Monoxide 33.32
Nitrogen Oxides 9.92
Particulate Matter - PM10 112.80
Particulate Matter - PM2.5 26.13
Sulfur Dioxide 1.39
Volatile Organic Compounds 17.22

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 318
Ethyl Benzene (CAS #100414) 204
Formaldehyde (CAS #50000) 2524
Generic HAPs (CAS #GHAPS) 350
Hexane (CAS #110543) 920
PAH, Total (CAS #234) 282
Toluene (CAS #108883) 132

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions on record for the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In Compliance with the AO DAQE-AN112340015-24, dated August
5, 2024, NSPS I, OOO, and MACT CCCCCC at the time of this
inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Check for the completion of the required initial stack test for the new
plant. Also check to be certain that the notification of the construction
for this plant and the new fuel tanks was submitted to the NSR
contact. Otherwise, inspect as usual maintaining the same targeting
frequency.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO, general site clarification correspondence, production records,
site measurements, watering and sweeping records, spray bar nozzle
records, November 6, 2024, correspondence, and 2023 SLEIS
Summary Report.
Susan Weisenberg <[e-mail]>
RE: [EXT] POM site inspection records
1 message
Rose, Chris (Staker & Parson Companies) <[e-mail]>Wed, Oct 23, 2024 at 5:58 PM
To: Susan Weisenberg <[e-mail]>
Hello Susan,

Deep apologies, it took me longer than I thought to compile everything. Here is everything you’ll need.

Since POTM is a conglomerate of multiple sites, I’ve attached several different rolling 12-month production
totals but combined they’re still under the permitted limits. Point East and Point West aggs are separate, but
combined the number is 1,289,301.17. Adding the TRP production (attached) brings the total to
1,387,936.17. The TRP crusher was crushing recycled concrete and asphalt, which goes back into our
mixes, thus not adding to the total. It’s also tracked differently, which is why the tally is in a different format.

Rolling 12-month production for RMC is split between Point South and Point West. The total is 192,991.33
for the requested period.

Rolling 12-month production for HMA is split between the former Point East plant and the new Point West
plant. Note that the records say both Point East and Point West; the new plant wasn’t really operational
during the requested period (Aug 23-July 24), so almost all production was at the old Point East plant.

Bulldozer hours, examples of warm weather water logs, and NSPS subpart OOO spray inspections were
pulled by Sam Miles and mailed to me, I included scans of the pages he sent. Dozer hours total 2,462. He
accidentally added an extra month, but the total is still under our permitted limit.

I’ve attached an excel sheet that calculates both the stockpile and disturbed area acreage as well as the
paved and unpaved haul road total lengths. I only calculated the lengths of the active haul roads- we have
access roads and equipment paths throughout Point East, and both Point East and Point West have
recently decommissioned paved and unpaved haul roads.

I will send a separate email to you stating that the equipment authorized in the new AO is being constructed.

Since the plant isn’t in full production quite yet, I have contacted Christine Bodell and Chad Gilgen to
petition to have the initial stack test extended to April or May 2025, since that will be when we anticipate full
production starting. Our justification for this is that the plant will experience a season shutdown from roughly
mid-November to around the end of March. We won’t see high enough production rates to be able to stack
test until then. Christine Bodell couldn’t give me an answer, we are both awaiting Chad’s response.

11/4/24, 12:54 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1813751204423617972…1/7
I hope this answers all your questions. Please let me know if you need clarification anywhere.

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: Susan Weisenberg <[e-mail]>
Sent: Thursday, October 17, 2024 4:49 PM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Subject: Fwd: [EXT] POM site inspecon records

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, I'm also looking for the information requested in this email chain regarding the East Point of the Mountain
inspection dated September 5, 2024. Can you review the below and let me know if you have already submitted this? If so,
let me know what date it was sent. Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

11/4/24, 12:54 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1813751204423617972…2/7

---------- Forwarded message ---------
From: Susan Weisenberg <[e-mail]>
Date: Tue, Sep 10, 2024 at 8:54 AM
Subject: Re: [EXT] POM site inspection records
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>

You are correct - any requirements that are essentially the same as the previous AO requirements should be as before.
For example, any 12-month rolling totals should still be for that time period. Any new requirements, such as those
associated with the new asphalt plant, just go back to the time of the startup of the plant. The site measurements should
be the most recent on record, even if they occurred before the AO was issued as long as the measurements are not older
than one year. Let me know if this doesn't address your question.

I forgot to ask you for the records related to the TRPs that are associated with this site. Can you give me the startup date,
total days of operation, and production rate for the aggregate equipment authorized on DAQC-584-24? Also please give
me the startup date for the generator authorized on DAQC-716-24. It is understood that this generator will operate until
the electrical grid is available at that location.

I appreciate the submission of the Lehi-Peck documents. The DAQ inspection year ends on September 30th so I am
working on completing my inspections before that date and unfortunately haven't yet had a chance to review everything.
I'll definitely reach out if I have any questions.

Thanks for your time with this.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

On Mon, Sep 9, 2024 at 3:58 PM Rose, Chris (Staker & Parson Companies) <[e-mail]> wrote:
Susan,

Great to hear from you. I’ll get right on this project.

As a quick clarification- if we have requirements new to the 2024 AO, should I just send proof of
compliance to those requirements going back to the issuance of the 2024 AO?

11/4/24, 12:54 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1813751204423617972…3/7
Also, I’ve sent you pretty much everything you requested for the Lehi Peck inspection- please reach out
with any questions.

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: Susan Weisenberg <[e-mail]>
Sent: Monday, September 9, 2024 10:06 AM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Subject: [EXT] POM site inspecon records

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, I was at the main POM site last Thursday for a routine assigned inspection. Unfortunately, I came at around 2:30
when the site was down for a shift change and I wasn't able to see the equipment operating. However, the haul roads
and operation areas looked well maintained. I am requesting the following records as per the new AO for this site
AN112340015-24, dated August 5, 2024.

Condition I.8 - Just as a FYI - because this is a new AO, the permit requires a statement of the installation of new
equipment. In this case, this applies to the equipment associated with the asphalt plant and a fuel tank replacement.
The AO states that Staker Parson Companies has 18 months from the issuance of the new AO to make the
construction status statement. The status statement can be handled as an email to me or to Chad Gilgen.

11/4/24, 12:54 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1813751204423617972…4/7
II.B.1.a - 12-month rolling production totals for the time period of August 2023 through July 2024 for: A. - aggregate, B.
- hot mix asphalt, and C. - concrete.

II.B.1.b - bulldozer hours of operation for the same time period.

II.B.2.b and II.B.2.e.1 - recent warm weather months of watering and sweeping records for storage piles, exposed
areas, haul roads, and other operation areas.

II.B.2.c through II.B.2.d.1 - these AO conditions require that Staker measure the total storage piles, disturbed areas,
unpaved haul roads, and paved haul roads on site, using GPS or aerial photographs. The measurements should occur
at least once every 12 months and that the records of the measurement be kept. Please submit the most recent
measurements for the listed areas.

Hot Mix Asphalt Plant requirements
The asphalt plant was not yet operational on the day I was at the site, but I wanted to go over the Blue Smoke Controls
for Hot Mix Asphalt Plants as per the recently promulgated Rule R307-313. Among other requirements, This Rule
states that the related asphalt production opacity can not exceed 10%. The VOC capture must have an efficiency
established by the HMAP baghouse manufacturer, which in this case has been set at no less than 99.9%.as per
condition II.B.3.e. I've attached this Rule for reference. The static pressure differential requirements (II.B.3.f - II.B.3.h1)
will be documented during the next inspection when the plant is in full production.

II.B.3.i - II.B.3.k.4 - An initial stack test will be required within 180 days after the startup of the plant. The test will follow
the requirements of the referenced AO conditions. A stack testing protocol should be submitted at least 30 days prior to
the performance of the test.

Gasoline dispensing - II.B.4.a and MACT CCCCCC - the diesel and gasoline fuel tanks shall be loaded by the use of
submerged loading.Please provide a statement that the tanks are loaded as established by this requirement.

Aggregate spray bar requirements II.B.5.a - II.B.5.b, NSPS OOO - please provide recent months of spray bar nozzle
inspections and repairs.

DAQ records indicate that the initial Method 9 observations for your applicable aggregate equipment were performed
on May 9, 2006 and July 15, 2017. Please be aware new initial observations will be required if the aggregate
equipment is replaced or significantly modified as defined by Subpart OOO.

It was reported by your site manager, Samuel Miles, that the temporary equipment ( 2 crushers, 2 screens, and one
745 kW generator) authorized by the TRP DAQC-584-24 has been removed. Please be certain to add the production
from this temporary project to your site's overall production totals. Mr. Miles also stated that the generator authorized by
the TRP C-716-24, will be operating until an electrical connection can be installed in this area. The estimated time for
the generator to be removed is sometime during the winter of 2025.

Thanks, let me know if you have any questions or comments.

Spray bar records
11/4/24, 12:54 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1813751204423617972…5/7
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 est sécuritaire. Si vous pensez qu’il s’agit d’un
courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
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 est sécuritaire. Si vous pensez qu’il s’agit d’un
courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
10 attachments
Point East Aggs rolling 12.jpg
62K
Point West Aggs rolling 12.jpg
29K
TRP rolling 12 at PW-98,635.jpg
10K
Point South RMC rolling 12.jpg
65K
Point West RMC rolling 12.jpg
40K
Point East & Point West Asphalt rolling 12.jpg
59K
POTM dozer hours SCAN.pdf
52K
POTM daily water log example SCANS.pdf
2248K
11/4/24, 12:54 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1813751204423617972…6/7
POTM stockpile and disturbed area, haul road calcs.xlsx
18K
POTM subpartOOO inspections SCANS.pdf
3516K
11/4/24, 12:54 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1813751204423617972…7/7
POTM Stockpile & Disturbed Area Calculations
Point East/Point South- Inventory taken 9/3/24 Point West- Inventory taken 9/27/24
Stockpile Acreage Stockpile Acreage
3/8" rock 0.089 1/2" rock- crushed 0.12
Asphalt 1/2" X #4 0.148 3/4" rock 0.081
Asphalt 3/4" rock- crushed 0.152 3/8" rock- crushed 0.089
Crusher fines pile 1 0.131 Beck crusher fines 0.169
RAP pile 1 0.285 Beef Hollow crusher fines 0.245
RAP pile 2 0.655 Pea gravel 0.139
RAP pile 3 0.743 Pond sand 0.147
RAP pile 4 0.228 RAP 0.304
#4 X #8 squeegie- washed 5.538 Squeegie 0.137
#4 X #8 squeegie- excess 3.301 Road base 1.373
3/4" rock- washed pile 1 1.486
3/4" rock- washed pile 2 0.879
3/4" rock- washed pile 3 0.298
3/4" rock- washed pile 4 2.09
3/8" rock- washed pile 1 0.425
3/8" rock- washed pile 2 0.113
3/8" rock- washed pile 3 0.057
3/8" rock- washed pile 4 0.092
Concrete sand- washed pile 1 1.611
Concrete sand- washed pile 2 0.063
Concrete sand- washed pile 3 0.552
Surge Pile 0.201
Crusher fines pile 2 0.109
Granular borrow 0.331
MSE backfill 0.12
Pond Sand- excess 11.874
3/8" rock 0.383
Crusher fines pile 3 0.52
Total PE/PS stockpile acreage:32.474
Total PW stockpile acreage:2.804
Total POTM stockpile acreage:35.278
Total POTM disturbed area acreage:26.152
Point East/Point South disturbed areas (9/3/24) and Point West disturbed areas (9/27/24)
Disturbed Area Acreage
PS leased RMC area 3.131
PE area Northeast of crusher 7.149
PE area South of old HMA 2.702
PW area north of new HMA 13.17
POTM haul road calculations (excludes inactive haul roads, paved or
PE/PS unpaved haul road lengths (9/3/24)
Haul Road Length in feet
PE Aggregate loading loop 1749.8
PS railway easement mixer road 4708.2
PE/PS unpaved haul road total:6458
PW unpaved haul road total:853.3
POTM total unpaved haul road:7311.3
PE/PS paved haul road total:2975.1
PW paved haul road total:7245.5
POTM total paved haul road lengths:10220.6
POTM total haul road lengths:17531.9
unpaved)
PW unpaved haul road lengths (9/27/24)
Haul Road Length in feet
Fuel island access to RMC 213
RMC pad exit to new paved haul road 204.8
HMA pull around 435.5
PE/PS paved haul road lengths (9/3/24)
Haul Road Length in feet
PE entrance past scales to loading loop 1370.7
PE exit from loading loop over scales 1079
PS wash pond and loadout lane 525.4
PW paved haul road lengths (9/27/24)
Haul Road Length in feet
Gentle grade entrance to HMA 3323.1
Gentle grade exit to frontage road 3500.1
RMC loadout loop 422.3
Susan Weisenberg <[e-mail]>
RE: [EXT] POM site inspection records
1 message
Rose, Chris (Staker & Parson Companies) <[e-mail]>Fri, Nov 1, 2024 at 1:13 PM
To: Susan Weisenberg <[e-mail]>
I believe our current schedule with Jacketta is sweeping paved roads eight times a month, or biweekly.

Thanks,

Christopher Rose
Environmental Specialist
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, November 1, 2024 11:48 AM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Subject: Re: [EXT] POM site inspecon records

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.
Thanks! Would it be accurate to report that you sweep at least twice a month?
11/4/24, 1:01 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1814548650179911014…1/8
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

On Fri, Nov 1, 2024 at 9:52 AM Rose, Chris (Staker & Parson Companies) <[e-mail]> wrote:
Susan, here’s the latest sweeping invoice if it gives you an idea of frequency.

Let me know if you need anything else,

Christopher Rose
Environmental Specialist
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: Thursday, October 31, 2024 4:57 PM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Subject: Re: [EXT] POM site inspecon records

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
11/4/24, 1:01 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1814548650179911014…2/8
Report Phish buon.
Thanks for your Point of the Mountain records. I have the watering records, but just caught that I'm missing an
example of sweeping records as per Conditions II.B.2.e and II.B.2.e.1. Samuel Miles let me know that you have a
contract with Jacketta Service for this. Do you have an example record or a copy of an invoice that indicates dates of
service? Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

On Wed, Oct 23, 2024 at 5:58 PM Rose, Chris (Staker & Parson Companies) <[e-mail]> wrote:
Hello Susan,

Deep apologies, it took me longer than I thought to compile everything. Here is everything you’ll need.

Since POTM is a conglomerate of multiple sites, I’ve attached several different rolling 12-month
production totals but combined they’re still under the permitted limits. Point East and Point West aggs
are separate, but combined the number is 1,289,301.17. Adding the TRP production (attached) brings
the total to 1,387,936.17. The TRP crusher was crushing recycled concrete and asphalt, which goes
back into our mixes, thus not adding to the total. It’s also tracked differently, which is why the tally is in
a different format.

Rolling 12-month production for RMC is split between Point South and Point West. The total is
192,991.33 for the requested period.

Rolling 12-month production for HMA is split between the former Point East plant and the new Point
West plant. Note that the records say both Point East and Point West; the new plant wasn’t really
operational during the requested period (Aug 23-July 24), so almost all production was at the old Point
East plant.

Bulldozer hours, examples of warm weather water logs, and NSPS subpart OOO spray inspections
were pulled by Sam Miles and mailed to me, I included scans of the pages he sent. Dozer hours total
2,462. He accidentally added an extra month, but the total is still under our permitted limit.

I’ve attached an excel sheet that calculates both the stockpile and disturbed area acreage as well as
the paved and unpaved haul road total lengths. I only calculated the lengths of the active haul roads-
we have access roads and equipment paths throughout Point East, and both Point East and Point
West have recently decommissioned paved and unpaved haul roads.
11/4/24, 1:01 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1814548650179911014…3/8

I will send a separate email to you stating that the equipment authorized in the new AO is being
constructed.

Since the plant isn’t in full production quite yet, I have contacted Christine Bodell and Chad Gilgen to
petition to have the initial stack test extended to April or May 2025, since that will be when we
anticipate full production starting. Our justification for this is that the plant will experience a season
shutdown from roughly mid-November to around the end of March. We won’t see high enough
production rates to be able to stack test until then. Christine Bodell couldn’t give me an answer, we are
both awaiting Chad’s response.

I hope this answers all your questions. Please let me know if you need clarification anywhere.

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: Susan Weisenberg <[e-mail]>
Sent: Thursday, October 17, 2024 4:49 PM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Subject: Fwd: [EXT] POM site inspecon records

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.
11/4/24, 1:01 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1814548650179911014…4/8
Hello Chris, I'm also looking for the information requested in this email chain regarding the East Point of the
Mountain inspection dated September 5, 2024. Can you review the below and let me know if you have already
submitted this? If so, let me know what date it was sent. Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

---------- Forwarded message ---------
From: Susan Weisenberg <[e-mail]>
Date: Tue, Sep 10, 2024 at 8:54 AM
Subject: Re: [EXT] POM site inspection records
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>

You are correct - any requirements that are essentially the same as the previous AO requirements should be as
before. For example, any 12-month rolling totals should still be for that time period. Any new requirements, such as
those associated with the new asphalt plant, just go back to the time of the startup of the plant. The site
measurements should be the most recent on record, even if they occurred before the AO was issued as long as the
measurements are not older than one year. Let me know if this doesn't address your question.

I forgot to ask you for the records related to the TRPs that are associated with this site. Can you give me the startup
date, total days of operation, and production rate for the aggregate equipment authorized on DAQC-584-24? Also
please give me the startup date for the generator authorized on DAQC-716-24. It is understood that this generator
will operate until the electrical grid is available at that location.

I appreciate the submission of the Lehi-Peck documents. The DAQ inspection year ends on September 30th so I am
working on completing my inspections before that date and unfortunately haven't yet had a chance to review
everything. I'll definitely reach out if I have any questions.

Thanks for your time with this.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

11/4/24, 1:01 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1814548650179911014…5/8

On Mon, Sep 9, 2024 at 3:58 PM Rose, Chris (Staker & Parson Companies) <[e-mail]> wrote:
Susan,

Great to hear from you. I’ll get right on this project.

As a quick clarification- if we have requirements new to the 2024 AO, should I just send proof of
compliance to those requirements going back to the issuance of the 2024 AO?

Also, I’ve sent you pretty much everything you requested for the Lehi Peck inspection- please reach
out with any questions.

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: Susan Weisenberg <[e-mail]>
Sent: Monday, September 9, 2024 10:06 AM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Subject: [EXT] POM site inspecon records

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
11/4/24, 1:01 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1814548650179911014…6/8
the Report Phish buon.
Hello, I was at the main POM site last Thursday for a routine assigned inspection. Unfortunately, I came at around
2:30 when the site was down for a shift change and I wasn't able to see the equipment operating. However, the
haul roads and operation areas looked well maintained. I am requesting the following records as per the new AO
for this site AN112340015-24, dated August 5, 2024.

Condition I.8 - Just as a FYI - because this is a new AO, the permit requires a statement of the installation of new
equipment. In this case, this applies to the equipment associated with the asphalt plant and a fuel tank
replacement. The AO states that Staker Parson Companies has 18 months from the issuance of the new AO to
make the construction status statement. The status statement can be handled as an email to me or to Chad
Gilgen.

II.B.1.a - 12-month rolling production totals for the time period of August 2023 through July 2024 for: A. -
aggregate, B. - hot mix asphalt, and C. - concrete.

II.B.1.b - bulldozer hours of operation for the same time period.

II.B.2.b and II.B.2.e.1 - recent warm weather months of watering and sweeping records for storage piles, exposed
areas, haul roads, and other operation areas.

II.B.2.c through II.B.2.d.1 - these AO conditions require that Staker measure the total storage piles,
disturbed areas, unpaved haul roads, and paved haul roads on site, using GPS or aerial photographs. The
measurements should occur at least once every 12 months and that the records of the measurement be kept.
Please submit the most recent measurements for the listed areas.

Hot Mix Asphalt Plant requirements
The asphalt plant was not yet operational on the day I was at the site, but I wanted to go over the Blue Smoke
Controls for Hot Mix Asphalt Plants as per the recently promulgated Rule R307-313. Among other requirements,
This Rule states that the related asphalt production opacity can not exceed 10%. The VOC capture must have an
efficiency established by the HMAP baghouse manufacturer, which in this case has been set at no less than
99.9%.as per condition II.B.3.e. I've attached this Rule for reference. The static pressure differential requirements
(II.B.3.f - II.B.3.h1) will be documented during the next inspection when the plant is in full production.

II.B.3.i - II.B.3.k.4 - An initial stack test will be required within 180 days after the startup of the plant. The test will
follow the requirements of the referenced AO conditions. A stack testing protocol should be submitted at least 30
days prior to the performance of the test.

Gasoline dispensing - II.B.4.a and MACT CCCCCC - the diesel and gasoline fuel tanks shall be loaded by the use
of submerged loading.Please provide a statement that the tanks are loaded as established by this requirement.

Aggregate spray bar requirements II.B.5.a - II.B.5.b, NSPS OOO - please provide recent months of spray bar
nozzle inspections and repairs.

DAQ records indicate that the initial Method 9 observations for your applicable aggregate equipment were
performed on May 9, 2006 and July 15, 2017. Please be aware new initial observations will be required if the
11/4/24, 1:01 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1814548650179911014…7/8
aggregate equipment is replaced or significantly modified as defined by Subpart OOO.

It was reported by your site manager, Samuel Miles, that the temporary equipment ( 2 crushers, 2 screens, and
one 745 kW generator) authorized by the TRP DAQC-584-24 has been removed. Please be certain to add the
production from this temporary project to your site's overall production totals. Mr. Miles also stated that the
generator authorized by the TRP C-716-24, will be operating until an electrical connection can be installed in this
area. The estimated time for the generator to be removed is sometime during the winter of 2025.

Thanks, let me know if you have any questions or comments.

Spray bar records
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 est sécuritaire. Si vous pensez
qu’il s’agit d’un courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave
d’hameçonnage.
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 est sécuritaire. Si vous pensez qu’il s’agit
d’un courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
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 est sécuritaire. Si vous pensez qu’il s’agit d’un
courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
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 est sécuritaire. Si vous pensez qu’il s’agit d’un
courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
11/4/24, 1:01 PM State of Utah Mail - RE: [EXT] POM site inspection records
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-7679507106268163554%7Cmsg-f:1814548650179911014…8/8
Invoice
DATE
10/25/24
INVOICE #
971124
BILL TO
STAKER & PARSONS COMPANY
ACCOUNTS PAYABLE DEPTPO BOX 3429OGDEN, UT 84409
SHIP TO
STAKER PIT
POINT EAST15589 S 500 WestDraper, UT
P.O. NO.
100-512085
TERMS
Net 30
Total
Balance Due
Payments/CreditsWe appreciate your business!
PO Box 25656
SLC, UT 84125www.jackettasweeping.comPh 801-973-6976Fax [phone]
DATEDESCRIPTIONUNITRATE AMOUNT
10/22/24Power Sweeping 1 340.00 340.00
10/24/24Power Sweeping 1 340.00 340.00
$680.00
$680.00
$0.00
10/31/2024
2023 Emissions Inventory Report
Staker & Parson Companies- Point of the Mountain Facilities (11234)
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)24.31799 1.87982 26.19781
PM10-FIL PM10 Filterable 22.56856 <.00001 22.56856
PM25-PRI PM2.5 Primary (Filt + Cond)5.93225 1.82342 7.75567
PM25-FIL PM2.5 Filterable 4.15751 <.00001 4.15751
PM-CON PM Condensible 0.13819 <.00001 0.13819
SO2 Sulfur Dioxide 0.30136 0.03283 0.33419
NOX Nitrogen Oxides 4.61771 26.25848 30.87619
VOC Volatile Organic Compounds 15.98932 2.12044 18.10977
CO Carbon Monoxide 13.21646 12.76009 25.97655
7439921 Lead 0.00013 <.00001 0.00013
NH3 Ammonia 0.06772 <.00001 0.06772

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 0.00006
71432 Benzene (HAP)VOC 0.0336
7440417 Beryllium (HAP)PM <.00001
7440439 Cadmium (HAP)PM 0.00006
75150 Carbon Disulfide (HAP)VOC 0.00034
7440473 Chromium (HAP)PM 0.00026
7440484 Cobalt (HAP)PM <.00001
100414 Ethyl Benzene (HAP)VOC 0.00078
75003 Ethyl Chloride (HAP)VOC 0.00008
50000 Formaldehyde (HAP)VOC 0.2775
110543 Hexane (HAP)VOC 0.04012
7439965 Manganese (HAP)PM 0.01139
7439976 Mercury (HAP)- 0.00001
74839 Methyl Bromide (HAP)VOC 0.0001
74873 Methyl Chloride (HAP)VOC 0.00047
75092 Methylene Chloride (HAP)- 0.00001
91203 Naphthalene (HAP)VOC 0.00079
7440020 Nickel (HAP)PM 0.00072
7723140 Phosphorus (HAP)- 0.00568
7782492 Selenium (HAP)PM <.00001
100425 Styrene (HAP)VOC 0.00011
108883 Toluene (HAP)VOC 0.00135
540841 2,2,4-Trimethylpentane (HAP)VOC 0.00338
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.00405
95476 o-Xylene (HAP)VOC 0.00118
91576 2-Methylnaphthalene (HAP)PM 0.00219
246 Polycyclic Organic Matter (HAP)VOC 0.00844

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2
Susan Weisenberg <[e-mail]>
Re: [EXT] Staker Parson POTM Inquiry
1 message
Chad Gilgen <[e-mail]>Wed, Nov 6, 2024 at 9:41 AM
To: "Rose, Chris (Staker & Parson Companies)" <[e-mail]>
Cc: Christine Bodell <[e-mail]>, Susan Weisenberg <[e-mail]>
Chris,
Yes, you can email that notification to us and Christine can get it added to the file per AO condition I.8 requiring it to be
sent to the attention of the NSR Section.
We can also work with you on the stack testing schedule since the start of the 180 operating days will be pretty close to
when the plant will start up at full production in April-May. Please respond back to this email confirming receipt of this
email.
Also send an email letting us know when this plant will be shut down for the season and another when it is being started
back up in Spring 2025.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Wed, Oct 30, 2024 at 3:04 PM Rose, Chris (Staker & Parson Companies) <[e-mail]> wrote:
Chad,

You’re correct, I have yet to submit notification of status. I can send that to you unless you have an
alternative preferred method of notification. If not, I’ll send you a statement on company letterhead.

The plant started firing some test loads here and there during construction at the end of September, and
we started minimal production on a semi-regular basis around the beginning of this month. I am told the
plant won’t see anything close to its rated capacity until regular production starts in April-May. If we’re
basing the 180 calendar day threshold on the very first test fire, we would need to stack test by mid to late
March, when the plant won’t yet be up and running for the season.

As a reminder, due to reasons such as decreased asphalt demand and the colder weather negatively
impacting the mix, the plant will typically be shut down between Nov-Dec and April-May. Due to the early
freezing temperatures this year, we will probably stop all production in the next couple weeks. If item
II.B.3.i.1 in DAQE-AN112340015-24 referred to calendar days during operational periods, we would have
until around August 2025 to test the plant, but I’m told that is intended to mean calendar days regardless
of the plant’s operation status.
11/6/24, 1:46 PM State of Utah Mail - Re: [EXT] Staker Parson POTM Inquiry
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1814992102622936882%7Cmsg-f:1814992102622936882&s…1/6

Please let me know if you would like additional information on this.

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: Chad Gilgen <[e-mail]>
Sent: Wednesday, October 30, 2024 12:32 PM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Cc: Chrisne Bodell <[e-mail]>
Subject: Re: [EXT] Staker Parson POTM Inquiry

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,

When did the plant begin operating? It doesn't look like notification, per AO condition I.8 of DAQE-AN112340015-24,
has been submitted to the DAQ. Do you anticipate submitting that startup notification sometime soon?

If the plant started up recently, you should still be within that 180 days if you test sometime in March or April. Does that
sound about right? If you are concerned about being outside of the 180 days, you can submit a letter to me (a
response to this email is fine) letting me know the details and we should be able to address it using compliance
discretion as long as the test takes place within a reasonable amount of time once operations resume in the spring.
11/6/24, 1:46 PM State of Utah Mail - Re: [EXT] Staker Parson POTM Inquiry
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1814992102622936882%7Cmsg-f:1814992102622936882&s…2/6

Thanks and let me know if you have any additional questions.

Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Wed, Oct 30, 2024 at 11:00 AM Rose, Chris (Staker & Parson Companies) <[e-mail]> wrote:
Christine and Chad,

I just wanted to follow up on this. Have you had a chance to review or discuss this issue? Let me know
what you think,

Thanks,

Christopher Rose
Environmental Specialist
West Division

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

C [phone]
E [e-mail]

11/6/24, 1:46 PM State of Utah Mail - Re: [EXT] Staker Parson POTM Inquiry
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1814992102622936882%7Cmsg-f:1814992102622936882&s…3/6

From: Rose, Chris (Staker & Parson Companies)
Sent: Friday, October 18, 2024 7:31 AM
To: Chrisne Bodell <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: RE: [EXT] Staker Parson POTM Inquiry

Hello Christine and Chad,

The plant is not necessarily running strictly at half capacity right now, we simply anticipate that the first
chance we’ll have to run the plant at the proposed testing rate is after the plant restarts production after
the seasonal shutdown between roughly mid-November and late March or April.

Please let me know how you would like us to proceed.

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: Chrisne Bodell <[e-mail]>
Sent: Wednesday, October 16, 2024 11:07 AM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: [EXT] Staker Parson POTM Inquiry

11/6/24, 1:46 PM State of Utah Mail - Re: [EXT] Staker Parson POTM Inquiry
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1814992102622936882%7Cmsg-f:1814992102622936882&s…4/6
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.
Good Morning Chad and Chris,

Chad, earlier this week I received a phone call from Chris Rose (Staker Parson) regarding Condition II.B.3.i.1 of
Approval Order DAQE-AN112340015-24:

Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit.

He shared that the unit had been started up recently, but the plant is only operating at half capacity and will continue
to do so in the next few months before shutting down for the season. Upon startup in the spring, the plant plans to
move to full capacity.

The issue is that this might result in an exceedance of the 180 day timeframe. Is there a precedent for this? I know
DAQ rules indicate that stack testing has to be conducted at a rate no less than 90% of the maximum production
rate.

Chris, please let me know if I misrepresented anything or if you have anything to add.

Thank you,
Christine

--

Christine Bodell
Environmental Engineer
Email | [e-mail]
Phone| [phone]
Emails to and from this email address may be considered public records and
thus subject to Utah GRAMA requirements
11/6/24, 1:46 PM State of Utah Mail - Re: [EXT] Staker Parson POTM Inquiry
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1814992102622936882%7Cmsg-f:1814992102622936882&s…5/6
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 est sécuritaire. Si vous pensez qu’il s’agit
d’un courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
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 est sécuritaire. Si vous pensez qu’il s’agit d’un
courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentave d’hameçonnage.
11/6/24, 1:46 PM State of Utah Mail - Re: [EXT] Staker Parson POTM Inquiry
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1814992102622936882%7Cmsg-f:1814992102622936882&s…6/6