DAQ-2024-012136

1
DAQC-CI129110001-24
Site ID 12911 (B1)

MEMORANDUM

TO: FILE – MEL CLARK CONSTRUCTION – Cedar City Aggregate Processing Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: December 18, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Iron County

INSPECTION DATE: July 11, 2024

SOURCE LOCATION: 2333 North Bulldog Road
Cedar City, UT 84721

SOURCE CONTACTS: Tenesha Robinson, Compliance Officer
435-592-6579, [e-mail]

OPERATING STATUS: Only loading operations were being conducted.

PROCESS DESCRIPTION: Mel Clark Construction operates an aggregate processing plant in
Cedar City, UT. The aggregate is mined by bulldozer and loaded into
a feeder by a front-end loader. The aggregate is conveyed to a screen.
The screen separates the aggregate which is then mostly conveyed to
storage piles. The larger aggregate is conveyed to a cone crusher.
Crushed material is then conveyed back to the screen. Power for the
plant is provided by one diesel generator.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN129110005-22, dated
June 7, 2022

NSPS (Part 60) IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
NSPS (Part 60) OOO: Standards of Performance for Nonmetallic
Mineral Processing Plants,
NESHAP (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines.

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Mel Clark Construction
Cedar City Aggregate Processing Plant

2333 North Bulldog Road 2333 North Bulldog Road
Cedar City, UT 84721 Cedar City, UT 84721

0 0
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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]

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

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

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

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

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

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

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

Status: In Compliance. No limits appear to have been exceeded. No modifications have
been made to equipment or process. Records were supplied during the inspection or by
email afterward. Equipment is maintained. No reportable breakdowns have occurred since
the previous inspection. A 2023 emission inventory was submitted to DAQ. New screen and
crusher are installed.

Section II: SPECIAL PROVISIONS

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

II.A.1 Cedar City Aggregate Processing Plant

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II.A.2 One (1) Kolman Scalper Screen
Capacity: 4 ft x 10 ft
NSPS Applicability: Subpart OOO
Manufactured before 2008

II.A.3 One (1) Mark II Power Screen
Capacity: 4 ft x 8 ft
NSPS Applicability: Subpart OOO
Manufactured before 2008

II.A.4 One (1) El Jay Screen
Capacity: 5 ft x 16 ft
NSPS Applicability: Subpart OOO
Manufactured before 2008

II.A.5 One (1) El Jay Screen 1320/1140 (NEW)
Capacity: 6 ft x 20 ft
Triple Deck
NSPS Applicability: Subpart OOO
Manufactured before 2008

II.A.6 One (1) Terex Crusher (NEW)
Capacity: 400 tph
NSPS Applicability: Subpart OOO
Manufactured before 2008

II.A.7 Kohlberg Crusher
400 tph
NSPS Applicability: Subpart OOO
Manufactured before 2008

II.A.8 Three (3) Generator Engines*
Fuel: Diesel
Rating: 435 hp, 600 hp, 1475 hp*
MACT Applicability: Subpart ZZZZ

*NEW, NSPS Applicability: Subpart IIII

II.A.9 Associated Conveyors
NSPS Applicability: Subpart OOO
Manufactured before 2008

Status: In Compliance. Equipment observed on site was consistent with that listed except
that the 435 hp and 600 hp generator engines have been removed from the site.

II.B Requirements and Limitations

II.B.1 Site Wide Requirement

II.B.1.a The owner/operator shall not exceed the following production limits:

A. 600,000 tons of processed aggregate material per rolling 12-month period
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B. 400,000 tons of unprocessed bank run material per rolling 12-month period.
[R307-401-8]

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

A. Determine production using scale house records or vendor receipts.

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 production records for all periods the plant is in operation. [R307-401-8]

Status: In Compliance. The source produced 76,449 tons of processed aggregate, and zero
tons of unprocessed bank run material during the 12-month period.

II.B.1.b The owner/operator shall not operate before 6 am or after 10 pm each day. [R307-401-8]

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

A. Determine hours of operation by monitoring and maintaining an operations log.

B. Record hours of start and end times each day

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months.

D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]

Status: In Compliance. The source operates from 6:30 AM - 9:30 PM during warmer
months and 7:00 AM - 5:00 PM during cold months.

II.B.1.c The owner/operator shall not allow visible emissions to exceed the following limits:

A. All screens - 10%

B. All crushers - 15% opacity

C. All conveyor transfer points -10% opacity

D. All conveyor drop points - 20% opacity

E. All diesel engines - 20% opacity

F. All other points - 20% opacity. [40 CFR 60 Subpart OOO, R307-201-3, R307-401-8]

II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]

Status: Not Observed. The crushing circuit was down at the time of inspection.

II.B.1.d The owner/operator shall not operate more than two screens concurrently. [R307-401-8]
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II.B.1.d.1 The owner/operator shall:

A. Determine hours of operation for each screen by maintaining an operations log

B. Record start and end times each day. [R307-401-8]

Status: In Compliance. Only two screens were in the crushing circuit configuration.

II.B.2 Haul Roads and Fugitive Dust Requirement

II.B.2.a The owner/operator shall not allow visible fugitive dust emissions from haul-roads and mobile
equipment in operational area to exceed 20% opacity. [R307-205-4, R307-401-8]

Status: In Compliance. Only minimal emissions were observed from haul traffic.

II.B.2.b.1 Visible emission determinations for fugitive dust from haul roads and 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 one-half the height of the
vehicle. [R307-205]

Status: In Compliance. Regular watering is conducted and water records are kept.

II.B.2.b The owner/operator shall use water application or other control options contained in R307-205 to
minimize emissions from fugitive dust and fugitive emissions sources, including haul roads,
storage piles, and disturbed areas. Controls shall be applied to ensure the opacity limits in this
AO are not exceeded. [R307-205, R307-401-8]

II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. All crusher inlet and outlet points

B. All dry screens

C. All conveyor transfer and stacker drop points

The sprays shall operate whenever conditions warrant to meet the opacity requirements of this
AO. [R307-205-5, R307-401-8]

Status: In Compliance. Water sprays are installed as required. Sprays were not in
operation at the time of inspection due to the crushing circuit being down.

II.B.2.d The owner/operator shall not allow storage piles area to exceed 8 acres. [R307-401-8]

II.B.2.d.1 The storage pile area shall be determined through source records, GPS measurements, or another
method acceptable to the Director. [R307-401-8]

Status: In Compliance. Provided records indicated storage piles to occupy 1.65 acres.

II.B.2.e The owner/operator shall not allow the amount of disturbed ground to exceed 12 acres.
[R307-401-8]

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II.B.2.e.1 The disturbed ground area shall be determined through source records, GPS measurements, or
another method acceptable to the Director. [R307-401-8]

Status: In Compliance. Provided records indicated disturbed area equated to 8 acres.

II.B.3 Generator Engine Requirement

II.B.3.a The owner/operator shall not operate the stationary generator engines for more than the
following hours:

A. 435 hp - 3,500 hours per rolling 12-month period

B. 600 hp - 3,500 hours per rolling 12-month period

C. 1,475 hp - 2,000 hours per rolling 12-month period. [R307-401-8]

II.B.3.a.1 The owner/operator shall:

A. Determine hours of operation by monitoring and maintaining an operations log

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. [R307-401-8]

II.B.3.a.2 Records of hours of operation shall be determined by installing a non-resettable hour meter for
each stationary generator engine. [R307-401-8]

Status: In Compliance. Only the 1,475 hp engine is on site, which operated for 827 hours
during the 12-month period. It is equipped with a non-resettable hour meter.

II.B.3.b The owner/operator shall only use diesel fuel as fuel in the generator engine. [R307-401-8]

II.B.3.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ,
R307-401-8]

II.B.3.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the
ULSD requirements. [R307-203]

Status: In Compliance. The source uses ultra-low sulfur diesel fuel purchased through
Jenkins.

II.B.3.c The owner/operator shall complete stack testing and/or other reporting requirements to ensure
compliance with all applicable requirements of MACT 40 CFR 63 Subpart ZZZZ for all three
engines. [40 CFR 63 Subpart ZZZZ, R307-401-8]

Status: Out of Compliance. The source had not stack tested the 1,475 hp engine (only
engine on site) and could not provide reporting documentation.

II.B.3.d The owner/operator shall complete stack testing and/or reporting requirements to ensure
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compliance with all applicable requirements of NSPS 40 CFR 60 Subpart IIII for the 1,475 hp
engine. [40 CFR 60 Subpart IIII, R307-401-8]

Status: Out of Compliance. The source had not stack tested the 1,475 hp engine (only
engine on site) and could not provide reporting documentation.

II.B.4 NSPS Subpart OOO Requirement

II.B.4.a The owner/operator shall conduct an initial performance test for newly installed crushers and
conveyor transfer points on site within 60 days after achieving the maximum production rate but
not later than 180 days after initial startup. Performance tests shall meet the limitations specified
in Table 3 to Subpart OOO. [40 CFR 60 Subpart OOO]

II.B.4.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner or operator may use methods and procedures specified in 40 CFR
60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c).
[40 CFR 60 Subpart OOO]

II.B.4.a.2 The owner/operator shall keep and maintain records of the initial performance test for each
newly installed crusher, screen, and conveyor for the life of the equipment. [40 CFR 60 Subpart
OOO]

Status: Out of Compliance. The source had not done initial OOO observations on the new
equipment at the time of inspection. Initial OOO observations were conducted afterward.
See attached. No further action is recommended for this condition.

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) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: Out of Compliance. The source was not able to produce reporting documentation and had not
conducted a stack test.

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

Status: Out of Compliance. The source had not conducted the initial OOO observations on the new
equipment at the time of inspection. Initial observations were conducted afterward. See attached. No
further action is recommended for this condition.

NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines.

Status: In Compliance. The engine is equipped with an hour meter, is regularly maintained, and
operates on ultra-low sulfur diesel fuel.

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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. This rule is satisfied by compliance with II.B.3.b.

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

Status: In Compliance. Only minimal emissions were observed from haul traffic.

Stationary Sources [R307-210]

Status: Out of Compliance. The source had not conducted the initial OOO observations on the new
equipment at the time of inspection. Initial observations were conducted afterward. See attached. No
further action is recommended for this condition. The source was not able to produce reporting
documentation and had not conducted a stack test.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. This rule is satisfied by compliance with ZZZZ.

EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Mel Clark Construction – Cedar City
Aggregate Processing Plant. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN129110005-22, dated June 7, 2022, is provided. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 3796.00
Carbon Monoxide 16.00 0.7206
Nitrogen Oxides 45.21 2.4101
Particulate Matter - PM10 13.15 4.2053
Particulate Matter - PM2.5 4.80 0.6685
Sulfur Dioxide 6.72 0.0261
Volatile Organic Compounds 2.25 0.1175

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Acetaldehyde (CAS #75070) 22
Benzene (Including Benzene From Gasoline) (CAS #71432) 40
Formaldehyde (CAS #50000) 36
Generic HAPs (CAS #GHAPS) 280

PREVIOUS ENFORCEMENT
ACTIONS: January 11, 2019 - NOV (DAQC-0016-19) - Failure to conduct initial
stack test.
January 20, 2020 - ESA (DAQC-1716-19) - To resolve above.

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COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN129110005-22, dated
June 7, 2022, the overall status is: Out of Compliance. The source
failed to stack test or provide reporting requirements for the 1475 hp
generator engine. The source had recently fired the pit supervisor for
poor work practices and were working to correct known issues. The
source otherwise appeared to be adequately maintained and operated
properly. A compliance advisory was issued (DAQC-975-24)
followed by a Warning (DAQC-1129-24).

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at increased frequency. Check to make sure records are being
kept as required and that the 1,475 hp generator engine has been stack
tested.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, New Equipment Initial OOO Observations, Emails
Jared James <[e-mail]>
Mel Clark Inc
9 messages
[e-mail] <[e-mail]>Thu, Aug 8, 2024 at 9:55 AM
To: [e-mail]
Good morning,

I have located the 600HP generator that is on our permit, it is not located in the pit and has not been in use for 4+ years. I
am not sure if that still requires me to get it tested where it is not operational? Would I be allowed to leave it on the permit
although there are no future plans to have it placed in the operation with the requirement for initial performance testing
within 90 days of startup? Is that something that will be sufficient for you or is there another route that you would like to
take?

Also, are there any other testing requirements that you can think of that I am missing?

Thanks,

Tenesha Robinson
2333 N. Bulldog Rd.
Cedar City, UT 84721
[phone]

Air Quality Inspections.pdf
586K
Jared James <[e-mail]>Thu, Aug 8, 2024 at 11:40 AM
To: [e-mail]
Hi Tenesha,
You don't need to worry about the 600 hp engine, unless you bring it back on site, then you will need to get it stack tested.
Is the 1475 hp engine a tier IV? Can you send me verification of it's tier rating? Also, for your initial OOO readings you've
12/17/24, 3:36 PM State of Utah Mail - Mel Clark Inc
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1806835445803715510&simpl=msg-f:180683544580371551…1/4
got a good start but you need to do 6 - 6 minute readings for both the crusher and the screen. If you can get those to me
by next week I think you will be in good shape for this inspection. Thanks!
[Quoted text hidden]
--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
195 North 1950 West, Salt Lake City, UT 84116
[e-mail] <[e-mail]>Thu, Aug 8, 2024 at 11:54 AM
To: Jared James <[e-mail]>
Ok I will try to find it! Would it be on the faceplate or is that a document that I need to track down?

Do the observations need to be done on separate days or can I do it over the course of a few hours?
[Quoted text hidden]
[Quoted text hidden]
195 North 1950 West, Salt Lake City, UT 84116
Teach InfoWest Spam Trap if this mail is spam:
Spam
Not spam
Forget previous vote
REMEMBER: Never give out your account information, password, or other personal
information over e-mail.
Jared James <[e-mail]>Thu, Aug 8, 2024 at 11:58 AM
To: [e-mail]
For the engine it would be documentation specs. For the OOO readings they can be sequential all on the same day, there
just needs to be 6 different readings for each piece of equipment.
[Quoted text hidden]
[Quoted text hidden]
12/17/24, 3:36 PM State of Utah Mail - Mel Clark Inc
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1806835445803715510&simpl=msg-f:180683544580371551…2/4
[Quoted text hidden]
[e-mail] <[e-mail]>Tue, Aug 20, 2024 at 2:09 PM
To: Jared James <[e-mail]>
Jared,
I have discovered that my engine will fall under the speciificaons requiring a stack test. I am in the process
of geng a catalyst ordered and installed on it but I'm not sure how long that process will take. Is there a
meline that I need to shoot for?
Thanks,

Tenesha Robinson
Safety Director
2333 N Bulldog Road
Cedar City, Utah 84721
[phone]
From: Jared James <[e-mail]>
Sent: Thursday, August 8, 2024 11:58 AM
To: [e-mail] <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
REMEMBER: Never give out your account information, password, or other personal information over e-mail.
[Quoted text hidden]
Jared James <[e-mail]>Tue, Aug 20, 2024 at 2:27 PM
To: "[e-mail]" <[e-mail]>
The sooner the better, but there is no hard date. I may need to issue the compliance advisory but if you just keep me
informed with dates that demonstrate you are working to solve the issue, we might be able to close out the inspection with
just a warning once you get the stack test completed.
[Quoted text hidden]
[e-mail] <[e-mail]>Tue, Aug 20, 2024 at 2:46 PM
To: Jared James <[e-mail]>
Ok, I appreciate your paence! I am trying to get this resolved as quickly as possible. I will keep you
updated on when CAT will be able to get the catalyst in.
Tenesha Robinson
12/17/24, 3:36 PM State of Utah Mail - Mel Clark Inc
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1806835445803715510&simpl=msg-f:180683544580371551…3/4
Safety Director
2333 N Bulldog Road
Cedar City, Utah 84721
[phone]
From: Jared James <[e-mail]>
Sent: Tuesday, August 20, 2024 2:27 PM
[Quoted text hidden]

[Quoted text hidden]
Jared James <[e-mail]>Tue, Aug 20, 2024 at 3:32 PM
To: "[e-mail]" <[e-mail]>
Sounds good, thank you.
[Quoted text hidden]
[e-mail] <[e-mail]>Thu, Aug 22, 2024 at 8:55 AM
To: Jared James <[e-mail]>
I just got off the phone with the CAT rep who does the exhaust systems for my area. He has iniated the
process of geng what I need put together.
Tenesha Robinson
Safety Director
2333 N Bulldog Road
Cedar City, Utah 84721
[phone]
From: Jared James <[e-mail]>
Sent: Tuesday, August 20, 2024 3:32 PM
[Quoted text hidden]

[Quoted text hidden]
12/17/24, 3:36 PM State of Utah Mail - Mel Clark Inc
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1806835445803715510&simpl=msg-f:180683544580371551…4/4
Jared James <[e-mail]>
OOO Observations
2 messages
[e-mail] <[e-mail]>Wed, Sep 18, 2024 at 1:44 PM
To: Jared James <[e-mail]>
I am not sure why these never got aached.
Sll waing on CAT regarding our catalyst.
Tenesha Robinson
Safety Director
2333 N Bulldog Road
Cedar City, Utah 84721
[phone]
Opacity Observations for 7160 7159 2024.pdf
483K
Jared James <[e-mail]>Wed, Sep 18, 2024 at 3:05 PM
To: "[e-mail]" <[e-mail]>
No problem, thank you!
[Quoted text hidden]
--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
195 North 1950 West, Salt Lake City, UT 84116
12/17/24, 3:32 PM State of Utah Mail - OOO Observations
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1810564287435266564&simpl=msg-f:181056428743526656…1/1