DAQ-2024-012137

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DAQC-CI129340001-24
Site ID 12934 (B1)

MEMORANDUM

TO: FILE – QUALITY EXCAVATION INC. – The Desert Canyon Pit – Fort Pierce
Industrial Park

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: September 19, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Washington County

INSPECTION DATE: August 15, 2024

SOURCE LOCATION: Approximately 1.4 miles southeast of the St. George Airport
St. George, UT 84790
DIRECTIONS: Head east on Southern Parkway (Route 7) and take exit 7,
Airport Parkway. Turn right on Airport Parkway the pit is
directly southeast.

SOURCE CONTACTS: Trevor Black, Manager
[e-mail]

OPERATING STATUS: The crushing circuit was temporarily down at the time of
inspection. Only loading was being conducted.

PROCESS DESCRIPTION: Quality Excavation Inc. uses crushers, screens, conveyors and
generators to produce aggregate materials. Materials are loaded
by frontloaders into trucks.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN129340008-23, dated
September 25, 2023
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,
MACT (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

0 0
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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Quality Excavation Inc. - The Desert Canyon Pit
- Fort Pierce Industrial Park

Approximately 1.4 miles southeast of the St.
1472 East 3950 South
St. George, UT 84790
George Airport
St. George, UT 84790

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 are kept and were made available for review at the time of inspection. Equipment is maintained. No reportable breakdowns have occurred. A
2023 emission inventory was submitted to DAQ.

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Section II: SPECIAL PROVISIONS

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

II.A.1 Desert Canyon Pit Aggregate processing operations
II.A.2 Jaw Crusher One (1) jaw crusher Capacity: 350 tons per hour Manufactured in 2006 NSPS Subpart OOO
II.A.3 Cone Crusher One (1) cone crusher Capacity: 400 tons per hour Manufactured in 2017 NSPS Subpart OOO equipment
II.A.4 Trackhoe Crusher One (1) trackhoe crusher - new equipment Capacity: 400 tons per hour NSPS Subpart OOO
II.A.5 Screen One (1) screen Capacity: 551 tons per hour Manufactured in 2017 NSPS Subpart OOO equipment
II.A.6 Conveyors and Stackers NSPS Subpart OOO
II.A.7 Generator Engine One (1) generator engine Rating: 261 kW (350 hp) Fuel: diesel fuel Manufactured: 2016 NSPS Subpart IIII MACT Subpart ZZZZ
II.A.8 Generator Engine One (1) generator engine Rating: 275 kW (369 hp) Fuel: diesel fuel Manufactured: April 30, 2006 MACT Subpart ZZZZ
II.A.9 Generator Engine One (1) generator engine Rating: 87 kW (117 hp) Fuel: diesel fuel Manufactured in 2000 MACT Subpart ZZZZ
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II.A.10 Generator Engine One (1) generator engine Rating 83 kW (111 hp) Fuel: diesel fuel Manufactured: 2017 NSPS Subpart IIII MACT Subpart ZZZZ
II.A.11 Drilling/Blasting Activity Control equipment: shroud attached to the drilling apparatus
II.A.12 Mobile Equipment - for information only Miscellaneous off-highway mobile equipment including loaders, dozers and aggregate moving equipment.
Status: In Compliance. Equipment observed on-site was consistent with that listed. Item II.A.4 was not yet installed and items II.A.9 and 10 are not currently on-site.

II.B Requirements and Limitations
II.B.1 Site-Wide Requirements and Limitations. II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any emission unit on site to exceed 20 percent opacity. [R307-401-8] II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. Only visible emissions from haul traffic and loading operations were observed during the inspection which were within the 20% opacity limit. II.B.2 Aggregate Production Plants II.B.2.a The owner/operator shall not produce more than 550,000 tons of processed aggregate material per rolling 12-month period. [R307-401-8] II.B.2.a.1 The owner/operator shall: A. Determine production using sales receipts or a belt scale. 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. Records reviewed at the time of inspection reported that 174,851.5 tons of aggregate was produced in the 12-month period of August 2023 through July 2024. II.B.2.b The owner/operator shall not allow visible emissions from the following crushers on site to exceed the following values: A. Installed before April 22, 2008 - 15% opacity B. Installed on or after April 22, 2008 - 12% opacity. [40 CFR 60 Subpart OOO, R307-401-8] Status: Not Observed. The crushing circuit was temporarily down during the inspection.
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II.B.2.c The owner/operator shall not allow visible emissions from the screens on site to exceed 7% opacity. [40 CFR 60 Subpart OOO, R307-401-8] Status: Not Observed. The crushing circuit was temporarily down during the inspection. II.B.2.d The owner/operator shall not allow visible emissions from any conveyor transfer point on site to exceed 10 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8] Status: Not Observed. The crushing circuit was temporarily down during the inspection. II.B.2.e The owner/operator shall not allow visible emissions from any conveyor drop point on site to exceed 20 percent opacity. [40 CFR 60 Subpart OOO, R307-401-8] Status: Not Observed. The crushing circuit was temporarily down during the inspection. II.B.2.f The owner/operator shall install water sprays at the following points to control fugitive emissions: A. All crushers B. All screens C. All conveyor transfer points. [R307-401-8] Status: In Compliance. Water sprays are installed as outlined. II.B.2.g The owner/operator shall perform monthly periodic inspections to check that water is flowing to discharge spray nozzles associated with each crusher, screen, and conveyor. If the owner/operator finds that water is not flowing properly during an inspection of the water spray nozzles, the owner/operator shall initiate corrective action within 24 hours and complete corrective action as expediently as practical. [40 CFR 60 Subpart OOO, R307-401-8] II.B.2.g.1 Records of the water sprays inspections shall be kept and maintained in a logbook for all periods when the plant is in operation. The records shall include the following items: A. Date the inspections were made B. Any corrective actions taken C. Control mechanism used if sprays are not operating. [40 CFR 60 Subpart OOO] Status: In Compliance. Monthly water spray records were provided for review at the time of inspection. II.B.3 Crushers, Screens, and Conveyor subject to NSPS Subpart OOO II.B.3.a The owner/operator shall conduct an initial performance test for all crushers, screens, 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.3.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR 60.675(c). The owner or operator may use methods and procedures specified in 40 CFR 60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c). [40 CFR 60 Subpart OOO]

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II.B.3.a.2 The owner/operator shall keep and maintain records of the initial performance test for each crusher, screen, and conveyor for the life of the equipment. [R307-401-8] Status: In Compliance. Initial OOO observations were conducted January 1, 2018. Records were provided for review at the time of inspection. The new trackhoe crusher has not been installed yet. II.B.4 Drilling and Blasting Requirements II.B.4.a The owner/operator shall not blast more than 49 tons of ANFO per rolling 12-month period. [R307-401-8] II.B.4.a.1 The owner/operator shall: A. Determine the amount of ANFO used in blasting with purchasing records or maintaining an operations log. B. Record the amount of ANFO used in blasting on a daily basis. C. Use the blasting data to calculate a new rolling 12-month total by the 20th day of each month from the previous 12 months. D. Keep the production records for all periods the plant is in operation. [R307-401-8] Status: Not Applicable. The source has not conducted any blasting at this site to date. II.B.4.b The owner/operator shall use shroud operation on all aggregate drilling equipment when drilling to control fugitive emissions. [R307-401-8] Status: Not Applicable. The source has not conducted any blasting at this site to date. II.B.5 Haul Roads and Fugitive Dust Sources II.B.5.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20 percent opacity on site. [R307-205-4, R307-401-8] II.B.5.a.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 vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-205-4, R307-401-8] Status: In Compliance. Visible emissions from haul traffic and loading operation was within limits. No other fugitive dust was observed during the inspection. II.B.5.b The haul roads shall not exceed the following lengths: A. Unpaved haul roads not to exceed 2,734 feet B. Loader operating area not to exceed 264 feet C. Trackhoe haul roads not to exceed 33 feet. [R307-401-8] II.B.5.b.1 Compliance shall be determined through Global Positioning System (GPS) measurements or aerial photographs. [R307-401-8] Status: In Compliance. The haul roads and operation areas have not changed since the AO was issued. If the haul roads and operation areas change the source will document the change in lengths. Aerial photographs were reviewed at the time of inspection.
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II.B.5.c The owner/operator shall cover the unpaved haul roads on with road base. [R307-401-8] Status: In Compliance. Haul roads were covered in road base. II.B.5.d The owner/operator shall not have the total area of storage piles exceeding three (3) acres. [R307-401-8] II.B.5.d.1 Compliance shall be determined through Global Positioning System (GPS) measurements or aerial photographs. [R307-401-8] Status: In Compliance. The total storage pile area was 1.89 acres. Aerial photograph was observed at the time of inspection. II.B.5.e The owner/operator shall apply water to fugitive dust sources to prevent visible emissions from exceeding the opacity limits listed in this AO. The owner/operator may stop applying water to fugitive dust sources when the temperature is below freezing, but shall apply other controls as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-205-4, R307-401-8] II.B.5.e.1 The owner/operator shall keep records of water application and fugitive dust control for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature is below freezing E. Records of any other controls used to reduce fugitive dust. [R307-205-4, R307-401-8] Status: In Compliance. Water records were made available at the time of inspection and contained the required information. II.B.6 Generator Engines II.B.6.a The owner/operator shall install the generator engines that are certified to meet the following emission rates: A. 261 kW generator engine NOx - 0.29 g/hpr-hr or less CO - 2.61 g/hp-hr or less B. 275 kW generator engine NOx - 3.59 g/hp-hr or less CO - 0.23 g/hp-hr or less C. 87 kW generator engine NOx - 6.86 g/hp-hr or less D. 83 kW generator engine NOx - 0.29 g/hp-hr or less CO - 2.61g/hp-hr or less. [R307-401-8]

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II.B.6.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] Status: Out of Compliance. The source submitted manufacturer's certifications by email following the inspection but the certification of emissions from the manufacturer indicated higher rates for the 261 kW and 275 kW engines than required above. See attachments. II.B.6.b The owner/operator shall not allow visible emissions from the generator engines to exceed 20 percent opacity on site. [R307-401-8] Status: Not Observed. None of the generators were operating at the time of inspection. II.B.6.c The owner/operator shall not operate: A. The 261 kW generator engines for more than 4,380 hours per rolling 12-month period. B. The 275 kW generator engines for more than 2,340 hours per rolling 12-month period. C. The 87 kW generator engine for more than 100 hours per rolling 12-month period. D. The 83 kW generator engines for more than 4,380 hours per rolling 12-month period. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.6.c.1 The owner/operator shall: A. Determine hours of operation with a non-resettable hour meter for each engine 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. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. The hours of operation for the generators for the 12-month period are as follows: 261 kW - 887 hours 275 kW - 1,036 hours 87 kW - 0 hours (not on site) 83 kW - 951 hours II.B.6.d The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in each engine. [R307-401-8] II.B.6.d.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. [R307-401-8] II.B.6.d.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. [R307-401-8] Status: In Compliance. The source purchases diesel fuel from Rhinehart Oil which is stated to be ultra-low sulfur on the invoice.

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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: In Compliance. IIII pertains to the 261 kW and the 83 kW generators. The source maintains
manufacturer's certification of emission rates. They operate on ultra-low sulfur diesel fuel. Regular
maintenance is conducted.

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

Status: In Compliance. Initial opacity readings were conducted on January 24, 2018. Monthly water
spray inspections are conducted and records are kept and were provided for review at the time of
inspection. No opacity exceedance was observed at the time of inspection.
MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. The source maintains manufacturer's certification of emission rates. The
generators operate on ultra-low sulfur diesel fuel. Regular maintenance is conducted. The generators
operate within the specified operation time limits.
AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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

Status: In Compliance. Fugitive emissions were only observed from hauling and loading activities. All
observed visible emissions were within set limits.
Stationary Sources [R307-210]

Status: In Compliance. See conditions IIII and OOO.

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

Status: In Compliance. See condition ZZZZ.

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EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Quality Excavation Inc. - The Desert
Canyon Pit - Fort Pierce Industrial Park. A comparison of the estimated total potential emissions (PTE)
on AO: DAQE-AN129340008-23, dated September 25, 2023, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 2527.00
Carbon Monoxide 31.70 3.502
Nitrogen Oxides 9.80 1.927
Particulate Matter - PM10 10.25 1.593
Particulate Matter - PM2.5 1.80 0.247
Sulfur Dioxide 0.60 1.383
Volatile Organic Compounds 2.90 1.351

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Generic HAPs (CAS #GHAPS) 120 37

PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN129340008-23,
dated September 25, 2023, the overall status is: Out of
Compliance with conditions II.B.6.a and II.B.6.a.1. Equipment
appeared to be properly maintained and operated properly.
Records were provided at the time of inspection with the
exception of generator certs which were emailed after the
inspection. A compliance advisory is being issued with ongoing
compliance action.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at an increased frequency.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, Generator Certs, Emails
10/13/23, 4:08 PM
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Engine Emissions Data
For Emissions / Certification feedback and questions, please submit a ticket via our ERC Request Portal
This emission data is Caterpillar's best estimate for this rating. If actual emissions are required then an emission test needs to be run on your
engine.
Serial Number (Machine)
Serial Number (Engine)JKT03541
Sales Model C4.4
Regulatory Build Date 15-FEB-2017
Engine ReRated
Engine Arrangement Number 4559407
Certification Arrangement
Test Spec Number
Regulatory Status CAT_Korea
Regulatory Status CAT_NR_EPA/CARB_MLIT_EU_R120_China Export
Labeled Model Year 2017
EPA Family Code HPKXL04.4MT1
EU Emissions Level IV
Japan Emissions Level STEP 4 FINAL
EU Type Approval e11*97/68RA*2012/46*3041*01
Korea Type Approval C4.4+4126/2200//15EN*PE*01
UN R120 Type Approval 120R-011138
CORR FL Power at RPM
Advertised Power
Total Displacement 4.40 L
10/13/23, 4:08 PM
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Caterpillar Confidential: Green
Content Owner: Commercial Processes Division
Web Master(s): PSG Web Based Systems Support
Current Date: 10/13/2023, 4:06:08 PM
© Caterpillar Inc. 2023 All Rights Reserved.
Data Privacy Statement.
Disclaimer: The information provided has been compiled from third party sources and is accurate to the best of Caterpillar's knowledge.
However, Caterpillar cannot guarantee the accuracy, completeness, or validity of the information and is not liable for any errors or omissions
contained therein. All information provided should be independently verified and confirmed, including by examining the emissions label located
on the engine.
Need emission replacement label? Click here!
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2017 MODEL YEAR
CERTIFICATE OF CONFORMITY
WITH THE CLEAN AIR ACT
OFFICE OF TRANSPORTATION
AND AIR QUALITY
ANN ARBOR, MICHIGAN 48105
Certificate Issued To:Scania CV AB
(U.S. Manufacturer or Importer)
Certificate Number: HY9XL09.3DAA-001
Effective Date:
12/12/2016
Expiration Date:
12/31/2017
_________________________
Byron J. Bunker, Division Director
Compliance Division
Issue Date:
12/12/2016
Revision Date:
N/A
Model Year: 2017
Manufacturer Type: Original Engine Manufacturer
Engine Family: HY9XL09.3DAA
Mobile/Stationary Indicator: Mobile
Emissions Power Category: 130<=kW<=560
Fuel Type: Diesel
After Treatment Devices: Diesel Oxidation Catalyst, Ammonia Slip Catalyst, Selective Catalytic
Reduction
Non-after Treatment Devices: Electronic Control, Smoke Puff Limiter, Electronic/Electric EGR -
Cooled
Pursuant to Section 213 of the Clean Air Act (42 U.S.C. section 7547) and 40 CFR Part 1039, and subject to the terms and conditions prescribed in those provisions, this certificate of conformity is hereby
issued with respect to the test engines which have been found to conform to applicable requirements and which represent the following engines, by engine family, more fully described in the documentation
required by 40 CFR Part 1039 and produced in the stated model year.
This certificate of conformity covers only those new compression-ignition engines which conform in all material respects to the design specifications that applied to those engines described in the
documentation required by 40 CFR Part 1039 and which are produced during the model year stated on this certificate of the said manufacturer, as defined in 40 CFR Part 1039.
It is a term of this certificate that the manufacturer shall consent to all inspections described in 40 CFR 1068 and authorized in a warrant or court order. Failure to comply with the requirements of such a
warrant or court order may lead to revocation or suspension of this certificate for reasons specified in 40 CFR Part 1039. It is also a term of this certificate that this certificate may be revoked or suspended or
rendered void ab initio for other reasons specified in 40 CFR Part 1039.
This certificate does not cover engines sold, offered for sale, or introduced, or delivered for introduction, into commerce in the U.S. prior to the effective date of the certificate.
2023 Emissions Inventory Report
Quality Excavation Inc. The Desert Canyon Pit - Fort Pierce Industrial Park (12934)
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)1.54515 0.04795 1.5931
PM10-FIL PM10 Filterable 1.54515 <.00001 1.54515
PM25-PRI PM2.5 Primary (Filt + Cond)0.20028 0.04651 0.2468
PM25-FIL PM2.5 Filterable 0.20028 <.00001 0.20028
PM-CON PM Condensible 0.02757 <.00001 0.02757
SO2 Sulfur Dioxide 1.38218 0.00037 1.38255
NOX Nitrogen Oxides 1.60778 0.31886 1.92664
VOC Volatile Organic Compounds 1.29024 0.06105 1.35129
CO Carbon Monoxide 3.20238 0.29966 3.50203

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
75070 Acetaldehyde (HAP)VOC 0.00362
107028 Acrolein (HAP)VOC 0.00044
71432 Benzene (HAP)VOC 0.0044
50000 Formaldehyde (HAP)VOC 0.00557
91203 Naphthalene (HAP)VOC 0.0004
130498292 PAH, total (HAP)PM 0.00079
108883 Toluene (HAP)VOC 0.00193
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.00135

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
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Jared James <[e-mail]>
Generator emission rate certs
4 messages
Stephanie <[e-mail]>Thu, Aug 15, 2024 at 2:36 PM
To: "[e-mail]" <[e-mail]>
Cc: "Trevor Black ([e-mail])" <[e-mail]>
Good afternoon.

Attached are the generator certs as you requested from Trevor today.

Thanks,

Stephanie Gledhill
Quality Excavation, Inc.
1472 East 3950 South   
St. George, Utah 84790
[phone] Phone

5 attachments
quality lt106 engine info.pdf
108K
u-r-024-0029.pdf
129K
Cert_HY9XL09.3DAA-001.pdf
155K
MBD02248.pdf
279K
JKT03541 cerificate.pdf
109K
Stephanie <[e-mail]>Thu, Aug 15, 2024 at 2:37 PM
To: "[e-mail]" <[e-mail]>
Cc: "Trevor Black ([e-mail])" <[e-mail]>
1 more.
9/19/24, 9:27 AM State of Utah Mail - Generator emission rate certs
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1807487278499368200&simpl=msg-f:180748727849936820…1/2

Thanks,

Stephanie Gledhill
Quality Excavation, Inc.
1472 East 3950 South
St. George, Utah 84790
[phone] Phone

[Quoted text hidden]
SQUALITY EX24081515040.pdf
4415K
Jared James <[e-mail]>Mon, Aug 19, 2024 at 9:09 AM
To: Stephanie <[e-mail]>
Thank you. Can you give me the generator operation hours for the last 12 months (August '23 - July '24) as well?
[Quoted text hidden]
--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
195 North 1950 West, Salt Lake City, UT 84116
Jared James <[e-mail]>Mon, Aug 19, 2024 at 10:02 AM
To: Stephanie <[e-mail]>
Oh sorry, Trevor already sent them to me. Thanks!
[Quoted text hidden]
9/19/24, 9:27 AM State of Utah Mail - Generator emission rate certs
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1807487278499368200&simpl=msg-f:180748727849936820…2/2
Jared James <[e-mail]>
Fwd: FW: Air Quality issue
4 messages
Trevor <[e-mail]>Fri, Nov 22, 2024 at 9:17 AM
To: Jared James <[e-mail]>
Jared
Looking at the issues we are having hopefully these emails will answer your questions. If not please let me know.
Thanks Trevor Black
Quality excavation
---------- Forwarded message ---------
From: Stephanie <[e-mail]>
Date: Fri, Nov 22, 2024, 9:02 AM
Subject: FW: Air Quality issue
To: Trevor Black ([e-mail]) <[e-mail]>
Trevor,

Do you want to send the attached emails from Stantec to Air Quality? Hopefully it helps.

Thanks,

Stephanie Gledhill
Quality Excavation, Inc.
1472 East 3950 South
St. George, Utah 84790
[phone] Phone

From: Clark, Eric <[e-mail]>
Sent: Friday, November 22, 2024 8:44 AM
To: Stephanie <[e-mail]>
Subject: RE: Air Quality issue

Stephanie –

12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:18164401268759101…1/23
Please see the attached email sent to Tim of UDAQ permit back at the beginning of 2023. One has a pdf (Appendix H).
It clearly shows the following:

A: 261 – Tier 4 – Tier 4 – Appendix H page 26

B: 275 – Tier 3 – Appendix H Page 13
C: 87 – Tier 1 - Appendix H Page 21
D: 83 – Tier 4 - Appendix H Page 10 (Family HPKXL04.4MT1) then the second email shows that the family is EPA
certified and I have a communication with Tim stating that EU4 for all intents and purposes equates to EPA Tier 4
If necessary, the 425 hp trackhoe (318 kw) – Tier 4 – Appendix H Page 3

Hopefully that helps??

Eric Clark, P.E.
Senior Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
---------- Forwarded message ----------
From: "Clark, Eric" <[e-mail]>
To: "'Tim Dejulis'" <[e-mail]>
Cc: "'Stephanie'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Alan
Humpherys'" <[e-mail]>, Dave Prey <[e-mail]>, "'Jason Krebs'" <[e-mail]>
Bcc:
Date: Fri, 27 Jan 2023 18:32:38 +0000
Subject: RE: Quality Excavation NOI Resubmittal
Tim –
Two of these three engines are definitely EPA Tier 4 certified as shown in Appendix H of the NOI For the 425 hp please
see page 3. The 350 hp is on page 26. The model years are 2015 and 2017, respectively which all can be Tier 4 as
shown in the link below. Regarding the 111 hp, as shown on page 10 has the EU emission level of 4. I am working with
CAT to confirm the certification. That said, I believe that the NOx is equivalent to EPA Tier 4 (0.4 g/kwh), but the CO
may be 5.0 for smaller units than the applied 3.5. See the second link below.
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100OA05.pdf
https://dieselnet.com/standards/eu/nonroad.php#s3
Eric Clark, P.E.
Project Engineer
[e-mail]
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:18164401268759101…2/23
From: Tim Dejulis <[e-mail]>
Sent: Friday, January 27, 2023 10:18 AM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
We have gone through the NOI sent to us on 01/06/23. Thank you.
We have a problem with the list of generator engines on site, we hope you'll clarify for us. The 111 hp, the 350 hp, and the
425 hp generator engines have exactly the same NOx and CO emission factors in Quality Excavations (QE) calculations.
The information presented to us shows that each generator engine has an emission factor for NOx at ~0.3 g/hp-hr and
CO at 2.61 g/hp-hr. This isn't possible given the years of manufacture and the differing sizes for each generator engine.
We don't have specification sheets for each engine and AP-42 emission factors weren't used for these three engines.
We searched the internet for the specification sheets for all three engines unsuccessfully. If QE could, we need one of the
following two options from QE: the specification sheets for the 111 hp, the 350 hp, and the 425 hp engines to verify the
emissions factors used in the calculations already submitted or alternately, QE should use the AP-42 emission factors for
these three engines in their revised emission estimate calculations. Please contact me if you have any questions. Thank
you.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 6, 2023 at 6:32 PM Clark, Eric <[e-mail]> wrote:
Tim –
Per our teleconference a couple of weeks ago, Stantec and Quality Excavation is resubmitting a NOI application per
your request for the Desert Canyon Pit. Please see the attached pdf. I have also included a resigned Form 2 in case
it was needed. I have also included a link to the modeling files. Please let me know if you have any access issues. I
have included Dave in this email so he has access to the files as well. Thanks
Folder iconQuality Excavation
Eric Clark, P.E.
Project Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:18164401268759101…3/23
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
---------- Forwarded message ----------
From: "Clark, Eric" <[e-mail]>
To: "'Tim Dejulis'" <[e-mail]>
Cc: "'Stephanie'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Alan
Humpherys'" <[e-mail]>, Dave Prey <[e-mail]>, "'Jason Krebs'" <[e-mail]>
Bcc:
Date: Thu, 2 Feb 2023 17:01:59 +0000
Subject: RE: Quality Excavation NOI Resubmittal
Tim –
Following our telephone call on Monday, it was determined that EPA-420-B-16-022 is identical to the first of the two
links I sent last week. Therefore, the 350 hp and 425 hp are definitely Tier 4 certified units. The 111 hp unit is EU Level
4. Unfortunately, I could not fully substantiate the EU4 standards beyond the link I sent you earlier other than the
attached EPA certificate for based on the family name. That said, it is my understanding that you recommended using
Tier 4 as an equivalent. Assuming that remains appropriate, the previously submitted EI spreadsheet applies the most
appropriate Tier 4 factors for those three engines. However, the CO for the 111 hp should have been 5.0 g/kw-hr, not
3.5 as previously submitted. Following this minor change, Stantec and QE believe the emission estimates to be
representative. For further detail see below.
425 hp (~317kW)
Per EPA-420-B-16-022
225 ≤ kW < 450; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 3.5 g/kW-hr
350 hp (~261kW)
Per EPA-420-B-16-022
225 ≤ kW < 450; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 3.5 g/kW-hr
111 hp (~83kW)
Per EPA-420-B-16-022
75 ≤ kW < 130; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 5.0 g/kW-hr
UDAQ spreadsheet is in g/hp-hr
HP = 1.34 kW or KW = 0.7457hp
0.4 g/kw-hr / 1.34 kw/hp (or *0.7457) = 0.29 g/hp-hr
3.5 g/kw-hr / 1.34 kw/hp (or *0.7457) = 2.61 g/hp-hr
5.0 g/kw-hr / 1.34 kw/hp (or *0.7457) = 3.73 g/hp-hr
https://archive.epa.gov/international/air/web/pdf/stds-eng.pdf (see bottom righthand column of the first page for
conversion reference)
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:18164401268759101…4/23
Eric Clark, P.E.
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Monday, January 30, 2023 1:50 PM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
It looks like Quality Excavation used a more liberal emission factor based on the EPA standards for the 111 hp, 350 hp,
and 425 hp generator engines; therefore the emissions from these engines were underestimated. This is based on the
"EPA's nonroad CI engines: Exhaust Emission standards, EPA-420-B-16-022". Please take a look at this reference and let
me know what you think.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 27, 2023 at 11:32 AM Clark, Eric <[e-mail]> wrote:
Tim –
Two of these three engines are definitely EPA Tier 4 certified as shown in Appendix H of the NOI For the 425 hp
please see page 3. The 350 hp is on page 26. The model years are 2015 and 2017, respectively which all can be
Tier 4 as shown in the link below. Regarding the 111 hp, as shown on page 10 has the EU emission level of 4. I am
working with CAT to confirm the certification. That said, I believe that the NOx is equivalent to EPA Tier 4 (0.4
g/kwh), but the CO may be 5.0 for smaller units than the applied 3.5. See the second link below.
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100OA05.pdf
https://dieselnet.com/standards/eu/nonroad.php#s3
Eric Clark, P.E.
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Friday, January 27, 2023 10:18 AM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:18164401268759101…5/23
We have gone through the NOI sent to us on 01/06/23. Thank you.
We have a problem with the list of generator engines on site, we hope you'll clarify for us. The 111 hp, the 350 hp, and
the 425 hp generator engines have exactly the same NOx and CO emission factors in Quality Excavations (QE)
calculations. The information presented to us shows that each generator engine has an emission factor for NOx at ~0.3
g/hp-hr and CO at 2.61 g/hp-hr. This isn't possible given the years of manufacture and the differing sizes for each
generator engine. We don't have specification sheets for each engine and AP-42 emission factors weren't used for
these three engines.
We searched the internet for the specification sheets for all three engines unsuccessfully. If QE could, we need one of
the following two options from QE: the specification sheets for the 111 hp, the 350 hp, and the 425 hp engines to verify
the emissions factors used in the calculations already submitted or alternately, QE should use the AP-42 emission
factors for these three engines in their revised emission estimate calculations. Please contact me if you have any
questions. Thank you.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 6, 2023 at 6:32 PM Clark, Eric <[e-mail]> wrote:
Tim –
Per our teleconference a couple of weeks ago, Stantec and Quality Excavation is resubmitting a NOI application
per your request for the Desert Canyon Pit. Please see the attached pdf. I have also included a resigned Form 2
in case it was needed. I have also included a link to the modeling files. Please let me know if you have any
access issues. I have included Dave in this email so he has access to the files as well. Thanks
Folder iconQuality Excavation
Eric Clark, P.E.
Project Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
Caution: This email originated from outside of Stantec. Please take extra precaution.
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:18164401268759101…6/23
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
---------- Forwarded message ----------
From: "Clark, Eric" <[e-mail]>
To: "'Tim Dejulis'" <[e-mail]>
Cc: "'Stephanie'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Alan
Humpherys'" <[e-mail]>, Dave Prey <[e-mail]>, "'Jason Krebs'" <[e-mail]>
Bcc:
Date: Fri, 27 Jan 2023 18:32:38 +0000
Subject: RE: Quality Excavation NOI Resubmittal
Tim –
Two of these three engines are definitely EPA Tier 4 certified as shown in Appendix H of the NOI For the 425 hp please
see page 3. The 350 hp is on page 26. The model years are 2015 and 2017, respectively which all can be Tier 4 as
shown in the link below. Regarding the 111 hp, as shown on page 10 has the EU emission level of 4. I am working with
CAT to confirm the certification. That said, I believe that the NOx is equivalent to EPA Tier 4 (0.4 g/kwh), but the CO
may be 5.0 for smaller units than the applied 3.5. See the second link below.
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100OA05.pdf
https://dieselnet.com/standards/eu/nonroad.php#s3
Eric Clark, P.E.
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Friday, January 27, 2023 10:18 AM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
We have gone through the NOI sent to us on 01/06/23. Thank you.
We have a problem with the list of generator engines on site, we hope you'll clarify for us. The 111 hp, the 350 hp, and the
425 hp generator engines have exactly the same NOx and CO emission factors in Quality Excavations (QE) calculations.
The information presented to us shows that each generator engine has an emission factor for NOx at ~0.3 g/hp-hr and
CO at 2.61 g/hp-hr. This isn't possible given the years of manufacture and the differing sizes for each generator engine.
We don't have specification sheets for each engine and AP-42 emission factors weren't used for these three engines.
We searched the internet for the specification sheets for all three engines unsuccessfully. If QE could, we need one of the
following two options from QE: the specification sheets for the 111 hp, the 350 hp, and the 425 hp engines to verify the
emissions factors used in the calculations already submitted or alternately, QE should use the AP-42 emission factors for
these three engines in their revised emission estimate calculations. Please contact me if you have any questions. Thank
you.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:18164401268759101…7/23
P: [phone]
airquality.utah.gov
On Fri, Jan 6, 2023 at 6:32 PM Clark, Eric <[e-mail]> wrote:
Tim –
Per our teleconference a couple of weeks ago, Stantec and Quality Excavation is resubmitting a NOI application per
your request for the Desert Canyon Pit. Please see the attached pdf. I have also included a resigned Form 2 in case
it was needed. I have also included a link to the modeling files. Please let me know if you have any access issues. I
have included Dave in this email so he has access to the files as well. Thanks
Folder iconQuality Excavation
Eric Clark, P.E.
Project Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
---------- Forwarded message ----------
From: "Clark, Eric" <[e-mail]>
To: "'Tim Dejulis'" <[e-mail]>
Cc: "'Stephanie'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Alan
Humpherys'" <[e-mail]>, Dave Prey <[e-mail]>, "'Jason Krebs'" <[e-mail]>
Bcc:
Date: Thu, 2 Feb 2023 17:01:59 +0000
Subject: RE: Quality Excavation NOI Resubmittal
Tim –
Following our telephone call on Monday, it was determined that EPA-420-B-16-022 is identical to the first of the two
links I sent last week. Therefore, the 350 hp and 425 hp are definitely Tier 4 certified units. The 111 hp unit is EU Level
4. Unfortunately, I could not fully substantiate the EU4 standards beyond the link I sent you earlier other than the
attached EPA certificate for based on the family name. That said, it is my understanding that you recommended using
Tier 4 as an equivalent. Assuming that remains appropriate, the previously submitted EI spreadsheet applies the most
appropriate Tier 4 factors for those three engines. However, the CO for the 111 hp should have been 5.0 g/kw-hr, not
3.5 as previously submitted. Following this minor change, Stantec and QE believe the emission estimates to be
representative. For further detail see below.
425 hp (~317kW)
Per EPA-420-B-16-022
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:18164401268759101…8/23
225 ≤ kW < 450; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 3.5 g/kW-hr
350 hp (~261kW)
Per EPA-420-B-16-022
225 ≤ kW < 450; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 3.5 g/kW-hr
111 hp (~83kW)
Per EPA-420-B-16-022
75 ≤ kW < 130; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 5.0 g/kW-hr
UDAQ spreadsheet is in g/hp-hr
HP = 1.34 kW or KW = 0.7457hp
0.4 g/kw-hr / 1.34 kw/hp (or *0.7457) = 0.29 g/hp-hr
3.5 g/kw-hr / 1.34 kw/hp (or *0.7457) = 2.61 g/hp-hr
5.0 g/kw-hr / 1.34 kw/hp (or *0.7457) = 3.73 g/hp-hr
https://archive.epa.gov/international/air/web/pdf/stds-eng.pdf (see bottom righthand column of the first page for
conversion reference)
Eric Clark, P.E.
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Monday, January 30, 2023 1:50 PM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
It looks like Quality Excavation used a more liberal emission factor based on the EPA standards for the 111 hp, 350 hp,
and 425 hp generator engines; therefore the emissions from these engines were underestimated. This is based on the
"EPA's nonroad CI engines: Exhaust Emission standards, EPA-420-B-16-022". Please take a look at this reference and let
me know what you think.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:18164401268759101…9/23
On Fri, Jan 27, 2023 at 11:32 AM Clark, Eric <[e-mail]> wrote:
Tim –
Two of these three engines are definitely EPA Tier 4 certified as shown in Appendix H of the NOI For the 425 hp
please see page 3. The 350 hp is on page 26. The model years are 2015 and 2017, respectively which all can be
Tier 4 as shown in the link below. Regarding the 111 hp, as shown on page 10 has the EU emission level of 4. I am
working with CAT to confirm the certification. That said, I believe that the NOx is equivalent to EPA Tier 4 (0.4
g/kwh), but the CO may be 5.0 for smaller units than the applied 3.5. See the second link below.
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100OA05.pdf
https://dieselnet.com/standards/eu/nonroad.php#s3
Eric Clark, P.E.
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Friday, January 27, 2023 10:18 AM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
We have gone through the NOI sent to us on 01/06/23. Thank you.
We have a problem with the list of generator engines on site, we hope you'll clarify for us. The 111 hp, the 350 hp, and
the 425 hp generator engines have exactly the same NOx and CO emission factors in Quality Excavations (QE)
calculations. The information presented to us shows that each generator engine has an emission factor for NOx at ~0.3
g/hp-hr and CO at 2.61 g/hp-hr. This isn't possible given the years of manufacture and the differing sizes for each
generator engine. We don't have specification sheets for each engine and AP-42 emission factors weren't used for
these three engines.
We searched the internet for the specification sheets for all three engines unsuccessfully. If QE could, we need one of
the following two options from QE: the specification sheets for the 111 hp, the 350 hp, and the 425 hp engines to verify
the emissions factors used in the calculations already submitted or alternately, QE should use the AP-42 emission
factors for these three engines in their revised emission estimate calculations. Please contact me if you have any
questions. Thank you.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 6, 2023 at 6:32 PM Clark, Eric <[e-mail]> wrote:
Tim –
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…10/23
Per our teleconference a couple of weeks ago, Stantec and Quality Excavation is resubmitting a NOI application
per your request for the Desert Canyon Pit. Please see the attached pdf. I have also included a resigned Form 2
in case it was needed. I have also included a link to the modeling files. Please let me know if you have any
access issues. I have included Dave in this email so he has access to the files as well. Thanks
Folder iconQuality Excavation
Eric Clark, P.E.
Project Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
---------- Forwarded message ----------
From: "Clark, Eric" <[e-mail]>
To: "'Tim Dejulis'" <[e-mail]>
Cc: "'Stephanie'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Alan
Humpherys'" <[e-mail]>, Dave Prey <[e-mail]>, "'Jason Krebs'" <[e-mail]>
Bcc:
Date: Fri, 27 Jan 2023 18:32:38 +0000
Subject: RE: Quality Excavation NOI Resubmittal
Tim –
Two of these three engines are definitely EPA Tier 4 certified as shown in Appendix H of the NOI For the 425 hp please
see page 3. The 350 hp is on page 26. The model years are 2015 and 2017, respectively which all can be Tier 4 as
shown in the link below. Regarding the 111 hp, as shown on page 10 has the EU emission level of 4. I am working with
CAT to confirm the certification. That said, I believe that the NOx is equivalent to EPA Tier 4 (0.4 g/kwh), but the CO
may be 5.0 for smaller units than the applied 3.5. See the second link below.
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100OA05.pdf
https://dieselnet.com/standards/eu/nonroad.php#s3
Eric Clark, P.E.
Project Engineer
[e-mail]
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…11/23
From: Tim Dejulis <[e-mail]>
Sent: Friday, January 27, 2023 10:18 AM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
We have gone through the NOI sent to us on 01/06/23. Thank you.
We have a problem with the list of generator engines on site, we hope you'll clarify for us. The 111 hp, the 350 hp, and the
425 hp generator engines have exactly the same NOx and CO emission factors in Quality Excavations (QE) calculations.
The information presented to us shows that each generator engine has an emission factor for NOx at ~0.3 g/hp-hr and
CO at 2.61 g/hp-hr. This isn't possible given the years of manufacture and the differing sizes for each generator engine.
We don't have specification sheets for each engine and AP-42 emission factors weren't used for these three engines.
We searched the internet for the specification sheets for all three engines unsuccessfully. If QE could, we need one of the
following two options from QE: the specification sheets for the 111 hp, the 350 hp, and the 425 hp engines to verify the
emissions factors used in the calculations already submitted or alternately, QE should use the AP-42 emission factors for
these three engines in their revised emission estimate calculations. Please contact me if you have any questions. Thank
you.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 6, 2023 at 6:32 PM Clark, Eric <[e-mail]> wrote:
Tim –
Per our teleconference a couple of weeks ago, Stantec and Quality Excavation is resubmitting a NOI application per
your request for the Desert Canyon Pit. Please see the attached pdf. I have also included a resigned Form 2 in case
it was needed. I have also included a link to the modeling files. Please let me know if you have any access issues. I
have included Dave in this email so he has access to the files as well. Thanks
Quality Excavation
Eric Clark, P.E.
Project Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…12/23
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
---------- Forwarded message ----------
From: "Clark, Eric" <[e-mail]>
To: "'Tim Dejulis'" <[e-mail]>
Cc: "'Stephanie'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Alan
Humpherys'" <[e-mail]>, Dave Prey <[e-mail]>, "'Jason Krebs'" <[e-mail]>
Bcc:
Date: Thu, 2 Feb 2023 17:01:59 +0000
Subject: RE: Quality Excavation NOI Resubmittal
Tim –
Following our telephone call on Monday, it was determined that EPA-420-B-16-022 is identical to the first of the two
links I sent last week. Therefore, the 350 hp and 425 hp are definitely Tier 4 certified units. The 111 hp unit is EU Level
4. Unfortunately, I could not fully substantiate the EU4 standards beyond the link I sent you earlier other than the
attached EPA certificate for based on the family name. That said, it is my understanding that you recommended using
Tier 4 as an equivalent. Assuming that remains appropriate, the previously submitted EI spreadsheet applies the most
appropriate Tier 4 factors for those three engines. However, the CO for the 111 hp should have been 5.0 g/kw-hr, not
3.5 as previously submitted. Following this minor change, Stantec and QE believe the emission estimates to be
representative. For further detail see below.
425 hp (~317kW)
Per EPA-420-B-16-022
225 ≤ kW < 450; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 3.5 g/kW-hr
350 hp (~261kW)
Per EPA-420-B-16-022
225 ≤ kW < 450; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 3.5 g/kW-hr
111 hp (~83kW)
Per EPA-420-B-16-022
75 ≤ kW < 130; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 5.0 g/kW-hr
UDAQ spreadsheet is in g/hp-hr
HP = 1.34 kW or KW = 0.7457hp
0.4 g/kw-hr / 1.34 kw/hp (or *0.7457) = 0.29 g/hp-hr
3.5 g/kw-hr / 1.34 kw/hp (or *0.7457) = 2.61 g/hp-hr
5.0 g/kw-hr / 1.34 kw/hp (or *0.7457) = 3.73 g/hp-hr
https://archive.epa.gov/international/air/web/pdf/stds-eng.pdf (see bottom righthand column of the first page for
conversion reference)
Eric Clark, P.E.
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…13/23
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Monday, January 30, 2023 1:50 PM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
It looks like Quality Excavation used a more liberal emission factor based on the EPA standards for the 111 hp, 350 hp,
and 425 hp generator engines; therefore the emissions from these engines were underestimated. This is based on the
"EPA's nonroad CI engines: Exhaust Emission standards, EPA-420-B-16-022". Please take a look at this reference and let
me know what you think.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 27, 2023 at 11:32 AM Clark, Eric <[e-mail]> wrote:
Tim –
Two of these three engines are definitely EPA Tier 4 certified as shown in Appendix H of the NOI For the 425 hp
please see page 3. The 350 hp is on page 26. The model years are 2015 and 2017, respectively which all can be
Tier 4 as shown in the link below. Regarding the 111 hp, as shown on page 10 has the EU emission level of 4. I am
working with CAT to confirm the certification. That said, I believe that the NOx is equivalent to EPA Tier 4 (0.4
g/kwh), but the CO may be 5.0 for smaller units than the applied 3.5. See the second link below.
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100OA05.pdf
https://dieselnet.com/standards/eu/nonroad.php#s3
Eric Clark, P.E.
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Friday, January 27, 2023 10:18 AM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
We have gone through the NOI sent to us on 01/06/23. Thank you.
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…14/23
We have a problem with the list of generator engines on site, we hope you'll clarify for us. The 111 hp, the 350 hp, and
the 425 hp generator engines have exactly the same NOx and CO emission factors in Quality Excavations (QE)
calculations. The information presented to us shows that each generator engine has an emission factor for NOx at ~0.3
g/hp-hr and CO at 2.61 g/hp-hr. This isn't possible given the years of manufacture and the differing sizes for each
generator engine. We don't have specification sheets for each engine and AP-42 emission factors weren't used for
these three engines.
We searched the internet for the specification sheets for all three engines unsuccessfully. If QE could, we need one of
the following two options from QE: the specification sheets for the 111 hp, the 350 hp, and the 425 hp engines to verify
the emissions factors used in the calculations already submitted or alternately, QE should use the AP-42 emission
factors for these three engines in their revised emission estimate calculations. Please contact me if you have any
questions. Thank you.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 6, 2023 at 6:32 PM Clark, Eric <[e-mail]> wrote:
Tim –
Per our teleconference a couple of weeks ago, Stantec and Quality Excavation is resubmitting a NOI application
per your request for the Desert Canyon Pit. Please see the attached pdf. I have also included a resigned Form 2
in case it was needed. I have also included a link to the modeling files. Please let me know if you have any
access issues. I have included Dave in this email so he has access to the files as well. Thanks
Quality Excavation
Eric Clark, P.E.
Project Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…15/23
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
9 attachments
image002.gif
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image001.png
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image001.png
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Appendix H.pdf
2400K
RE: Quality Excavation NOI Resubmittal.eml
3308K
HPKXL04_4MT1-011 (1).pdf
156K
JKT03541.pdf
75K
QE EI Update 020223.xlsx
164K
RE: Quality Excavation NOI Resubmittal.eml
597K
Jared James <[e-mail]>Mon, Nov 25, 2024 at 1:38 PM
To: Chad Gilgen <[e-mail]>
Hi Chad,
This was sent to me from Quality Excavation in answer to your question concerning:
II.B.6.a The owner/operator shall install the generator engines that are certified to meet the followingemission rates:
A. 261 kW generator engine NOx - 0.29 g/hpr-hr or less CO - 2.61 g/hp-hr or less
B. 275 kW generator engine NOx - 3.59 g/hp-hr or less
CO - 0.23 g/hp-hr or less
C. 87 kW generator engine
NOx - 6.86 g/hp-hr or less
D. 83 kW generator engine
NOx - 0.29 g/hp-hr or less CO - 2.61g/hp-hr or less. [R307-401-8]
II.B.6.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record ofthe manufacturer's certification of the emission rate. The record shall be kept for the life of theequipment. [R307-401-8]

from what I see looking at the attachments (appendix H especially) all the engines are certified Tier IV. Please review this
email train and let me know what you think. Thanks!
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…16/23
[Quoted text hidden]
--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
195 North 1950 West, Salt Lake City, UT 84116
---------- Forwarded message ----------
From: "Clark, Eric" <[e-mail]>
To: "'Tim Dejulis'" <[e-mail]>
Cc: "'Stephanie'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Alan
Humpherys'" <[e-mail]>, Dave Prey <[e-mail]>, "'Jason Krebs'" <[e-mail]>
Bcc:
Date: Fri, 27 Jan 2023 18:32:38 +0000
Subject: RE: Quality Excavation NOI Resubmittal
Tim –
Two of these three engines are definitely EPA Tier 4 certified as shown in Appendix H of the NOI For the 425 hp please
see page 3. The 350 hp is on page 26. The model years are 2015 and 2017, respectively which all can be Tier 4 as
shown in the link below. Regarding the 111 hp, as shown on page 10 has the EU emission level of 4. I am working with
CAT to confirm the certification. That said, I believe that the NOx is equivalent to EPA Tier 4 (0.4 g/kwh), but the CO
may be 5.0 for smaller units than the applied 3.5. See the second link below.
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100OA05.pdf
https://dieselnet.com/standards/eu/nonroad.php#s3
Eric Clark, P.E.
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Friday, January 27, 2023 10:18 AM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
We have gone through the NOI sent to us on 01/06/23. Thank you.
We have a problem with the list of generator engines on site, we hope you'll clarify for us. The 111 hp, the 350 hp, and the
425 hp generator engines have exactly the same NOx and CO emission factors in Quality Excavations (QE) calculations.
The information presented to us shows that each generator engine has an emission factor for NOx at ~0.3 g/hp-hr and
CO at 2.61 g/hp-hr. This isn't possible given the years of manufacture and the differing sizes for each generator engine.
We don't have specification sheets for each engine and AP-42 emission factors weren't used for these three engines.
We searched the internet for the specification sheets for all three engines unsuccessfully. If QE could, we need one of the
following two options from QE: the specification sheets for the 111 hp, the 350 hp, and the 425 hp engines to verify the
emissions factors used in the calculations already submitted or alternately, QE should use the AP-42 emission factors for
these three engines in their revised emission estimate calculations. Please contact me if you have any questions. Thank
you.
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…17/23
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 6, 2023 at 6:32 PM Clark, Eric <[e-mail]> wrote:
Tim –
Per our teleconference a couple of weeks ago, Stantec and Quality Excavation is resubmitting a NOI application per
your request for the Desert Canyon Pit. Please see the attached pdf. I have also included a resigned Form 2 in case
it was needed. I have also included a link to the modeling files. Please let me know if you have any access issues. I
have included Dave in this email so he has access to the files as well. Thanks
Quality Excavation
Eric Clark, P.E.
Project Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
---------- Forwarded message ----------
From: "Clark, Eric" <[e-mail]>
To: "'Tim Dejulis'" <[e-mail]>
Cc: "'Stephanie'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'Alan
Humpherys'" <[e-mail]>, Dave Prey <[e-mail]>, "'Jason Krebs'" <[e-mail]>
Bcc:
Date: Thu, 2 Feb 2023 17:01:59 +0000
Subject: RE: Quality Excavation NOI Resubmittal
Tim –
Following our telephone call on Monday, it was determined that EPA-420-B-16-022 is identical to the first of the two
links I sent last week. Therefore, the 350 hp and 425 hp are definitely Tier 4 certified units. The 111 hp unit is EU Level
4. Unfortunately, I could not fully substantiate the EU4 standards beyond the link I sent you earlier other than the
attached EPA certificate for based on the family name. That said, it is my understanding that you recommended using
Tier 4 as an equivalent. Assuming that remains appropriate, the previously submitted EI spreadsheet applies the most
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…18/23
appropriate Tier 4 factors for those three engines. However, the CO for the 111 hp should have been 5.0 g/kw-hr, not
3.5 as previously submitted. Following this minor change, Stantec and QE believe the emission estimates to be
representative. For further detail see below.
425 hp (~317kW)
Per EPA-420-B-16-022
225 ≤ kW < 450; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 3.5 g/kW-hr
350 hp (~261kW)
Per EPA-420-B-16-022
225 ≤ kW < 450; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 3.5 g/kW-hr
111 hp (~83kW)
Per EPA-420-B-16-022
75 ≤ kW < 130; 2014+ model year
NOX = 0.4 g/kw-hr; CO = 5.0 g/kW-hr
UDAQ spreadsheet is in g/hp-hr
HP = 1.34 kW or KW = 0.7457hp
0.4 g/kw-hr / 1.34 kw/hp (or *0.7457) = 0.29 g/hp-hr
3.5 g/kw-hr / 1.34 kw/hp (or *0.7457) = 2.61 g/hp-hr
5.0 g/kw-hr / 1.34 kw/hp (or *0.7457) = 3.73 g/hp-hr
https://archive.epa.gov/international/air/web/pdf/stds-eng.pdf (see bottom righthand column of the first page for
conversion reference)
Eric Clark, P.E.
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Monday, January 30, 2023 1:50 PM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
It looks like Quality Excavation used a more liberal emission factor based on the EPA standards for the 111 hp, 350 hp,
and 425 hp generator engines; therefore the emissions from these engines were underestimated. This is based on the
"EPA's nonroad CI engines: Exhaust Emission standards, EPA-420-B-16-022". Please take a look at this reference and let
me know what you think.
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…19/23
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 27, 2023 at 11:32 AM Clark, Eric <[e-mail]> wrote:
Tim –
Two of these three engines are definitely EPA Tier 4 certified as shown in Appendix H of the NOI For the 425 hp
please see page 3. The 350 hp is on page 26. The model years are 2015 and 2017, respectively which all can be
Tier 4 as shown in the link below. Regarding the 111 hp, as shown on page 10 has the EU emission level of 4. I am
working with CAT to confirm the certification. That said, I believe that the NOx is equivalent to EPA Tier 4 (0.4
g/kwh), but the CO may be 5.0 for smaller units than the applied 3.5. See the second link below.
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100OA05.pdf
https://dieselnet.com/standards/eu/nonroad.php#s3
Eric Clark, P.E.
Project Engineer
[e-mail]
From: Tim Dejulis <[e-mail]>
Sent: Friday, January 27, 2023 10:18 AM
To: Clark, Eric <[e-mail]>
Cc: Stephanie <[e-mail]>; [e-mail]; Alan Humpherys
<[e-mail]>; Dave Prey <[e-mail]>; Jason Krebs <[e-mail]>
Subject: Re: Quality Excavation NOI Resubmittal
Eric,
We have gone through the NOI sent to us on 01/06/23. Thank you.
We have a problem with the list of generator engines on site, we hope you'll clarify for us. The 111 hp, the 350 hp, and
the 425 hp generator engines have exactly the same NOx and CO emission factors in Quality Excavations (QE)
calculations. The information presented to us shows that each generator engine has an emission factor for NOx at ~0.3
g/hp-hr and CO at 2.61 g/hp-hr. This isn't possible given the years of manufacture and the differing sizes for each
generator engine. We don't have specification sheets for each engine and AP-42 emission factors weren't used for
these three engines.
We searched the internet for the specification sheets for all three engines unsuccessfully. If QE could, we need one of
the following two options from QE: the specification sheets for the 111 hp, the 350 hp, and the 425 hp engines to verify
the emissions factors used in the calculations already submitted or alternately, QE should use the AP-42 emission
factors for these three engines in their revised emission estimate calculations. Please contact me if you have any
questions. Thank you.
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…20/23
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Jan 6, 2023 at 6:32 PM Clark, Eric <[e-mail]> wrote:
Tim –
Per our teleconference a couple of weeks ago, Stantec and Quality Excavation is resubmitting a NOI application
per your request for the Desert Canyon Pit. Please see the attached pdf. I have also included a resigned Form 2
in case it was needed. I have also included a link to the modeling files. Please let me know if you have any
access issues. I have included Dave in this email so he has access to the files as well. Thanks
Quality Excavation
Eric Clark, P.E.
Project Engineer
727 East Riverpark Lane, Suite 150
Boise, Idaho 83706
Ph: 208-388-4324
Cell: 208-861-7182
[e-mail]
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
Caution: This email originated from outside of Stantec. Please take extra precaution.
Attention: Ce courriel provient de l'extérieur de Stantec. Veuillez prendre des précautions supplémentaires.
Atención: Este correo electrónico proviene de fuera de Stantec. Por favor, tome precauciones adicionales.
9 attachments
image001.png
1K
image002.gif
1K
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…21/23
image001.png
1K
Appendix H.pdf
2400K
RE: Quality Excavation NOI Resubmittal.eml
3308K
HPKXL04_4MT1-011 (1).pdf
156K
JKT03541.pdf
75K
QE EI Update 020223.xlsx
164K
RE: Quality Excavation NOI Resubmittal.eml
597K
Chad Gilgen <[e-mail]>Fri, Dec 6, 2024 at 11:47 AM
To: Jared James <[e-mail]>
Jared,
Have you reviewed what they submitted? Does it answer the questions I had on the memo? If so, please clarify and
point out which certification applies to each engine.
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.
[Quoted text hidden]
Chad Gilgen <[e-mail]>Thu, Dec 12, 2024 at 10:40 AM
To: Jared James <[e-mail]>
Hey Jared,
Based on our conversation today, I think a Compliance Advisory is the best way to go since you indicated the exhaust
emission statements provided indicate NOx and CO emission rates are higher than those allowed by AO condition
II.B.6.a. Once the CA is issued, you can wrap up your memo noting the CA has been issued and recommend this one for
a follow-up inspection/additional compliance action once their CA response is received.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…22/23
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Mon, Nov 25, 2024 at 1:38 PM Jared James <[e-mail]> wrote:
[Quoted text hidden]
12/12/24, 3:17 PM State of Utah Mail - Fwd: FW: Air Quality issue
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1816440126875910141&simpl=msg-f:1816440126875910…23/23