DAQ-2025-000112

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DAQC-CI102400001-24
Site ID 10240 (B1)

MEMORANDUM

TO: FILE – CASTLE VALLEY MINING LLC – Bear Canyon Mine

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: December 19, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Emery County

INSPECTION DATE: July 10, 2024

SOURCE LOCATION: Eleven miles west of Huntington, Utah on state Highway 31
Huntington, UT
DIRECTIONS: From Huntington turn northwest onto State Route 31. Head up
Huntington Canyon, the road to the facility is approximately one
mile past the Huntington Power Plant. There is a Gentry
Mountain Mine sign at that point, follow Bear Canyon Road to
the facility.

SOURCE CONTACTS: Miles Stephens, Mine Engineer
435-687-2178 [e-mail]

Hyrum Peterson, Engineer Tech
435-687-5456 [e-mail]

OPERATING STATUS: Operating normally at time of inspection.

PROCESS DESCRIPTION: Coal is mined from a room and pillar mine. The coal is loaded
onto one of two conveyor belts. The belts go to a stage bin with a
bottom auger which drops the coal to a conveyor belt. This belt
goes to the upper crusher and picking line or the lower crushers.
The upper line has a crusher and single deck screen and then a
picking table for removal of rock and then a separator deck
screen to separate coal to different sizes as needed. The bottom
line has two crushers and screens to further separate all coal. All
the coal from both circuits go to a single line which conveys the
coal to a transfer point to one of four drop (stacker) tubes
depending on the type and grade of the coal. All piles have
underground feeders which feed the coal to a stage bin and drop
chute with elephant duct. The load out also has swinging tube
extenders to use for pickup loads. The loading operation is run
from the scale house. There are water sprays at all transfer points
and at all entrances and exits of crushers and screens. The drop
points at the stackers have rain bird sprinklers which spray the
transfer point, conveyor line, and stockpiles.
) $ ' $ '
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The coal transfer line from the first stage bin has a secondary
line, which can be used to transfer all the mine coal to the new
crushers and screens. The new system will replace the old line
while the older equipment is being refurbish and then both lines
will be used according to the type and grade of coal. The new
system exits all coal to the transfer line, which goes to the
stacker tubes. The company has opened a new mine several
hundred meters from this equipment. The new mine portal feeds
to a feeder and overland belt and then to the crusher circuit. The
belt is covered. The site has a water truck, which is used to spray
the access road and working area. The site also has two single
line crushers to crush oversize coal/rock material. These are both
located between the main crusher circuits and the stacker tubes.
The mine is in the process of installing a dry coal separator with
two cyclones and two baghouses that will separate rock and ash
from the coal.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN102400006-19, dated October
24, 2019
MACT (Part 63) CCCCCC: National Emission Standards for
Hazardous Air Pollutants for Source Category: Gasoline
Dispensing Facilities,

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Castle Valley Mining LLC - Bear Canyon Mine
P.O. Box 300
Eleven miles west of Huntington, Utah on state
Highway 31
Huntington, UT 84528 Huntington, UT

SIC Code: 1241: (Coal Mining Services)

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]

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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 set forth in this AO appear to have been exceeded. The source stated that there have been no modifications to the equipment or processes. The equipment appeared to be properly operated and maintained according to manufacturer recommendations. Records are kept as required and were made available after the inspection. No breakdowns have been reported since the previous inspection. An emissions inventory was submitted for 2023, and emissions data are reported below. The dry coal separator has not been installed and the source intends to sell it.

Section II: SPECIAL PROVISIONS

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

II.A.1 Bear Canyon Mine
Underground coal mining with surface loadout facility

II.A.2 South Crusher*
Hammer Mill Primary Crushing
Capacity: 450 tons per hour

II.A.3 Wildhorse Crusher*
Primary Crushing
Capacity: 900 tons per hour

II.A.4 Lump Crusher (high ash)
Granulator Primary Crushing
Capacity: 300 tons per hour

II.A.5 Lump Screenage Crusher Primary Crushing
Capacity: 50 tons per hour

II.A.6 Gundlach Crusher
Primary Crushing
Capacity: 700 tons per hour
II.A.7 Oversize Crusher
Secondary Crushing Capacity: 50 tons per hour

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II.A.8 Secondary Scalping Screen Capacity: 450 tons per hour
II.A.9 Wildhorse Screen Capacity: 900 tons per hour
II.A.10 Upper Screen Capacity: 900 tons per hour
II.A.11 Lower Screen Capacity: 900 tons per hour
II.A.12 Dry Coal Separator One (1) Coal Separator Attached equipment: two (2) cyclones with two (2) baghouses. Capacity: 16,480 cfm each
II.A.13 Storage Tank* One (1) vertical above-ground unleaded gasoline storage tank rated at 11,000 gallons
II.A.14 Storage Tank* One (1) above-ground diesel storage tank rated at 11,000 gallons
II.A.15 Storage Tank* One (1) above-ground diesel storage tank rated at 16,000 gallons
II.A.16 Storage Tanks* Two (2) above-ground stoker oil storage tanks rated at 14,000 gallons
II.A.17 Storage Tank* One (1) above-ground diesel storage tank rated at 1,000 gallons
II.A.18 Storage Tank* One (1) above-ground diesel storage tank rated at 8,000 gallons (installed in 1999)
II.A.19 Storage Tank* One (1) above-ground anti-freeze storage tank rated at 2,000 gallons
II.A.20 Space Heaters Four (4) space heaters located at shower house, scale house, shop building, and the coal stoker Capacity: <5.0 MMBtu/hr each Fuel: natural gas

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II.A.21 Miscellaneous Equipment Including conveyors*, diesel fired front-end loaders, oil burner/space heater and other mobile equipment necessary for facility management *Not subject to 40 CFR 60 Subparts OOO or Kb
Status: In Compliance. The storage tanks on site do not match the types listed above. However, no unapproved crushing equipment is on site. Since the total volumes of actual tanks are less than the permitted volumes, no compliance action is recommended at this time. Additional information gathered at the time of inspection: ·II.A.2: The South Crusher has been removed ·II.A.3: This is known as the bypass crusher ·II.A.4: The Lump Crusher has been removed ·II.A.6: This is known as the primary crusher ·II.A.7: The Oversize Crusher has been removed ·II.A.8: The Secondary Scalping Screen has been removed ·II.A.9: The Wildhorse Screen has been removed ·II.A.10: This is known as the upper vibrator ·II.A.11: This is known as the lower vibrator ·II.A.12: The dry coal separator is on site, but has never been installed. The source is trying to sell this equipment. ·II.A.13: This tank is not in use. A 1,000-gal horizontal gasoline tank is in use. ·II.A.14: This tank has a vertical orientation and is not in use. ·II.A.15: This tank is on site and in use. ·II.A.16: This tank has been removed. ·II.A.17: This tank has a horizontal orientation and is in use. ·II.A.18: This tank has been removed. ·II.A.19: This tank has been removed. ·II.A.20: The coal stoker was replaced with an electric furnace.

II.B Requirements and Limitations
II.B.1 Production Limitations II.B.1.a The owner operator shall not produce more than five (5) million tons of coal per rolling 12-month period. [R307-401-8] II.B.1.a.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records of production shall be kept for all periods when the plant is in operation. Production shall be determined by belt scale records, scale house records, or bucket scale records. The records of production shall be kept on a daily basis. [R307-401-8] Status: In Compliance. For the rolling 12-month period from July 2023 - June 2024, a total of 344,200 tons of coal were produced. II.B.2 Requirements on Fugitive Dust Sources. II.B.2.a Within 30 days of the date of this AO, the owner/operator shall submit a FDCP in electronic or written format. An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the FDCP for control of all fugitive dust sources associated with the Bear Canyon Mine. [R307-205] Status: In Compliance. The source submitted a FDCP on December 16, 2020.

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II.B.2.b The facility shall comply with all applicable requirements of R307-205 for fugitive emission and fugitive dust sources. [R307-205] Status: In Compliance. There were no visible fugitive dust emissions observed at the time of inspection. The source takes steps to minimize fugitive dust by watering roads and restricting the speed of vehicles involved in the operation. II.B.2.c The owner/operator shall not allow visible emissions from roads and other fugitive dust sources to exceed 20% opacity on site. [R307-205] II.B.2.c.1 Visible emission determinations shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-205, R307-401-8] Status: In Compliance. No visible emissions were noted during the inspection. The source has a water truck. See the attached VEO form. II.B.2.d The following haul road lengths shall not exceed: A. 1.40 miles in length for unpaved access roads B. 0.24 miles in length for paved haul roads. [R307-401-8] II.B.2.d.1 Compliance shall be determined through GPS measurements or aerial photographs. [R307-401-8] Status: In Compliance. The unpaved haul road has a length of 1.1 miles and the paved haul road has a length of 0.24 miles. See the attached images. II.B.2.e The owner/operator shall cover all unpaved haul roads and wheeled-vehicle operational areas with road base material. [R307-401-8] Status: In Compliance. Road base is applied to the unpaved haul roads as needed to keep dust down. II.B.2.f 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. [R307-401-8] II.B.2.f.1 Records of water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature was above freezing. [R307-401-8] Status: In Compliance. Watering records are maintained as required and were reviewed at the time of inspection.

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II.B.2.g Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive dust emissions: A. All crushers B. All screens C. All conveyor transfer points The sprays shall operate to meet the opacity limits listed in this AO. [R307-205-5, R307-401-8] Status: In Compliance. Water sprays are present at the beginning of the process, the crushers and screens, and all conveyor transfer points. In addition, all conveyors are completely covered, including transfer points, and drop points. II.B.2.h The owner/operator shall pass emissions from the dry coal separator through a cyclone and a baghouse before being emitted into the air. [R307-401-8] Status: Not Applicable. The dry coal separator has not been installed and the source has no plans to ever install it. II.B.3 Limitations on Fuels. II.B.3.a The owner/operator shall only use diesel fuel (e.g. fuel oil #1, or #2) or gasoline as fuel in the stationary equipment on site. [R307-401-8] II.B.3.a.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.3.a.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. Only ULSD is used at this source. See the attached fuel invoice from Pierce Oil Company, Inc.

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) Y: Standards of Performance for Coal Preparation and Processing Plants

Status: Out of Compliance. The source has not been performing annual performance tests as
required. A Compliance Advisory (DAQC-1126-24) was issued on November 12, 2024. The source
responded on December 3, 2024, by submitting a NSPS Part Y performance test (attached below).
A No Further Action letter (DAQC-1241-24) was issued on December 19, 2024, to resolve this
compliance action.

The source processes more than 200 tons of coal per day. Initial opacity observations for the
equipment were submitted on June 30, 2010 (DAQC-952-17). The source operates according to a
FDCP. See attached for the latest update to the plan.

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

Status: Not applicable. Only coal is processed in crushing, screening, and conveying equipment.
These processes are subject to NSPS (Part 60) Subpart Y. Coal is not a mineral and not subject to
this federal subpart.

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

Status: In Compliance. The source has a throughput of less than 10,000 gallons per month. The source
handles gasoline in a manner to prevent vapor releases to the atmosphere for extended periods of time.
The gasoline tank appeared to be well maintained an operated. The source keeps records of gasoline
throughput. See attached gasoline throughput records.

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. Only ULSD is used at this source. See the attached fuel invoice from Pierce
Oil Company, Inc.
Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

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

Standards of Performance for New Stationary Sources [R307-210]

Status: Compliance with this area source rule is satisfied by compliance with Federal Requirements
NSPS (Part 60) Subparts OOO and Y. See Section III above for more information.
National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirement MACT (Part 63) Subpart CCCCCC. See Section III above for more information.

9
EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Castle Valley Mining LLC - Bear
Canyon Mine for the 2023 Emissions Reporting Year. A comparison of the estimated total potential
emissions (PTE) on AO: DAQE-AN102400006-19, dated October 24, 2019, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 1.00 N/A
Carbon Monoxide 0.36 0.00001
Nitrogen Oxides 0.31 0.00001
Particulate Matter - PM10 (Fugitives) 16.45 070177
Particulate Matter - PM2.5 (Fugitives) 2.73 0.06144
Sulfur Dioxide 0.61 0.00001
Volatile Organic Compounds 2.44 0.05797

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN102400006-19,
dated October 24, 2019, the overall status is: Out of Compliance
at the time of inspection. A Compliance Advisory
(DAQC-1126-24) was issued on November 12, 2024. The source
responded on December 3, 2024, by submitting a NSPS Part Y
performance test (attached below). A No Further Action letter
(DAQC-1241-24) was issued on December 19, 2024, to resolve
this compliance action.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at typical frequency for this type of source. Ensure the
source has notified Minor NSR of their name change. Ensure
that annual Subpart Y performance tests are being submitted as
required.

NSR RECOMMENDATIONS: Equipment list in Section II has been updated. Adjust for
changes, removals, etc. Watch for submission from source for
name change. Remove evaluation of 40 CFR Part 60 Subparts
OOO and Kb from equipment list. Add evaluation of 40 CFR
Part 60 Subpart Y.

ATTACHMENTS: VEO form, Email correspondence, ULSD verification, Aerial
measurements, FDCP, Subpart Y performance test
Daniel Riddle <[e-mail]>
10240 - Follow up to air quality inspection
Daniel Riddle <[e-mail]>To: Miles Stephens <[e-mail]>
Cc: Mark Reynolds <[e-mail]>, Hyrum Peterson <[e-mail]>, Shain Stoddard <[e-mail]>
Thanks for sending this! I'll discuss with my manager the next step in compliance action. Since you promptly addressed the issue, there will likely be either no or very little penalty, but I'll have
On Tue, Dec 3, 2024 at 11:26 PM Miles Stephens <[e-mail]> wrote:Hello Daniel,
Please see the aached response to the Compliance Advisory you referenced.
Thanks!
Miles Stephens
Mine Engineer Ph.: [phone]
Direct: [phone] PO Box 300
5550 West Bear Canyon Rd. Hunngton, UT 84528

CONFIDENTIALITY:
This message and any attachments may contain legally privileged and/or sensitive information. Any unapproved disclosure, use or dissemination of this e-mail message or its contents, either in whole or in part, is not permitted. If y
sender and then securely dispose of it.

From: Daniel Riddle <[e-mail]>
Sent: Monday, December 2, 2024 9:17 AM
To: Miles Stephens <[e-mail]>
Cc: Mark Reynolds <[e-mail]>; Hyrum Peterson <[e-mail]>
Subject: Re: 10240 - Follow up to air quality inspecon

[CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.]
Okay thank you.
On Tue, Nov 26, 2024 at 2:13 PM Miles Stephens <[e-mail]> wrote:Hi Daniel,
Thanks for the follow up.
I did receive a copy of that cerfied leer on 11/20. Also, the test has been performed, just working on the report write-up. I should be able to get the response to y
Thanks!
Miles Stephens Mine Engineer
Ph.: [phone] Direct: [phone]
PO Box 300 5550 West Bear Canyon Rd.
Hunngton, UT 84528

CONFIDENTIALITY:
This message and any attachments may contain legally privileged and/or sensitive information. Any unapproved disclosure, use or dissemination of this e-mail message or its contents, either in whole or in part, is not permitted.
sender and then securely dispose of it.

12/19/24, 9:44 AM State of Utah Mail - 10240 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permmsgid=msg-a:r2383061274628866030&simpl=msg-a:r238306127462886…1/7
From: Daniel Riddle <[e-mail]>
Sent: Monday, November 25, 2024 3:20 PM
To: Miles Stephens <[e-mail]>; Mark Reynolds <[e-mail]>; Hyrum Peterson <[e-mail]>
Subject: Re: 10240 - Follow up to air quality inspecon

[CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.]
Hi - just wanted to check whether that performance test was performed? Also, you should have received a compliance advisory through certified mail from the Division of Air Quality, datedreceipt. When you respond to that, you can email the response to me. Let me know if you haven't received it.
On Thu, Nov 7, 2024 at 10:11 AM Daniel Riddle <[e-mail]> wrote:
Great, keep me posted.
On Wed, Oct 30, 2024 at 9:33 AM Miles Stephens <[e-mail]> wrote:Thanks Daniel,
I'll try to get that completed during the next couple of weeks, but for sure by the end of November.
Thanks!
Miles Stephens Mine Engineer
Ph.: [phone] Direct: [phone]
PO Box 300 5550 West Bear Canyon Rd.
Hunngton, UT 84528

CONFIDENTIALITY:
This message and any attachments may contain legally privileged and/or sensitive information. Any unapproved disclosure, use or dissemination of this e-mail message or its contents, either in whole or in part, is not perm
notify the sender and then securely dispose of it.

From: Daniel Riddle <[e-mail]>
Sent: Wednesday, October 23, 2024 4:45 PM
To: Miles Stephens <[e-mail]>
Cc: Hyrum Peterson <[e-mail]>; Mark Reynolds <[e-mail]>
Subject: Re: 10240 - Follow up to air quality inspecon

[CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.]
Miles - after further explanation from my manager, it appears that Subpart Y (not OOO) is indeed the federal subpart we need to consider here, but there are some additional complia
Section 60.255(b)(2) of Subpart Y states:
(2) For each affected facility subject to an opacity standard, an initial performance test must be performed. Thereafter, a new performance test must be conducted according to th
section, as applicable, except as provided for in paragraphs (e) and (f) of this section. Performance test and other compliance requirements for coal truck dump operations are sp
(i) If any 6-minute average opacity reading in the most recent performance test exceeds half the applicable opacity limit, a new performance test must be conducted within 90 owas required to be completed.
(ii) If all 6-minute average opacity readings in the most recent performance test are equal to or less than half the applicable opacity limit, a new performance test must be condu
performance test was required to be completed.
(iii) An owner or operator of an affected facility continuously monitoring scrubber parameters as specified in § 60.256(b)(2) is exempt from the requirements in paragraphs (b)(2concurrently with (or within a 60-minute period of) PM performance tests.
Thus, according to (ii), performance tests should be performed at least every 12 months. These performance tests should be performed by someone who is Method 9 certified ("smok
Observation. This is probably the easiest way to satisfy this requirement, but 60.255 (f) and 60.255 (g) offer alternatives.
I'm attaching an example of an annual report from another coal mine for you to use to better understand the requirements here. I'd recommend you complete this annual emissions retime frame for when you could complete that?
On Tue, Oct 15, 2024 at 10:40 AM Daniel Riddle <[e-mail]> wrote:
Thanks for sending that updated FDCP
On Fri, Oct 11, 2024 at 1:01 PM Miles Stephens <[e-mail]> wrote:Hi Daniel,
We were able to find a more recent version of the FDCP.
Thanks!
Miles Stephens Mine Engineer
Ph.: [phone] Direct: [phone]
12/19/24, 9:44 AM State of Utah Mail - 10240 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permmsgid=msg-a:r2383061274628866030&simpl=msg-a:r238306127462886…2/7
PO Box 300 5550 West Bear Canyon Rd.
Hunngton, UT 84528

CONFIDENTIALITY:
This message and any attachments may contain legally privileged and/or sensitive information. Any unapproved disclosure, use or dissemination of this e-mail message or its contents, either in whole or in part, is not
notify the sender and then securely dispose of it.

From: Miles Stephens <[e-mail]>
Sent: Thursday, October 10, 2024 4:43 PM
To: Daniel Riddle <[e-mail]>
Cc: Hyrum Peterson <[e-mail]>; Mark Reynolds <[e-mail]>
Subject: Re: 10240 - Follow up to air quality inspecon
Hi Daniel,
I apologize for the delayed response. Hyrum Peterson had been managing all of our air quality records, etc. but shortly aer your site visit he moved to a pos
rotaon than me.
I have aached what I have been able to find regarding the Fugive dust plan and the 2023 emissions report.
The FDCP is the only thing that I could find, but Hyrum said he will look for one as well. It looks like we may just need to update it, but I may need some assis
Also, it appears to me that subpart OOO is applicable to nonmetallic minerals processing, but not coal.
Thanks!
Miles Stephens Mine Engineer
Ph.: [phone] Direct: [phone]
PO Box 300 5550 West Bear Canyon Rd.
Hunngton, UT 84528

CONFIDENTIALITY:
This message and any attachments may contain legally privileged and/or sensitive information. Any unapproved disclosure, use or dissemination of this e-mail message or its contents, either in whole or in part, is not
notify the sender and then securely dispose of it.

From: Daniel Riddle <[e-mail]>
Sent: Tuesday, October 8, 2024 10:12 AM
To: Miles Stephens <[e-mail]>
Cc: Hyrum Peterson <[e-mail]>; Mark Reynolds <[e-mail]>
Subject: Re: 10240 - Follow up to air quality inspecon

[CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.]
Checking in to see if this email was received and if you could show compliance with these federal subparts OOO and Y?
On Wed, Sep 25, 2024 at 12:22 PM Daniel Riddle <[e-mail]> wrote:
Miles and Hyrum,
After review from my manager, I had a few additional questions/comments to determine compliance for this site.
1) https://deq.utah.gov/air-quality/permitting-forms-air-quality - the current name for this site is still Castle Valley Mining, LLC. You'll need to apply for a name change to
Please work with Minor New Source Review to do this.
2) The equipment in Conditions II.A.5, II.A.6, II.A.10, and II.A.11 are still on site and may be subject to 40 CFR Part 60 Subpart OOO ( https://www.ecfr.gov/current/title-40/charequirements here could include initial performance tests (Method 9 Visible Emission Observations) to determine opacity coming from this equipment, the use of nozzle sprays
sprays. Check Table 3 at the bottom of the link as well as 60.6074 (b)3) Even though the coal separator is not in use, you may still be subject to aspects of 40 CFR Part 60 Subpart Y ( https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/p
initial performance tests you could send me required by 60.255 (b) (2)? and also a Fugitve Coal Dust Emissions Control Plan (FDCP) as required by 60.254 (c)?
Let's determine the applicability and compliance status of these federal requirements. Please reach out with questions.
12/19/24, 9:44 AM State of Utah Mail - 10240 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permmsgid=msg-a:r2383061274628866030&simpl=msg-a:r238306127462886…3/7
Daniel
On Wed, Sep 4, 2024 at 11:35 AM Daniel Riddle <[e-mail]> wrote:
Thank you!
On Tue, Sep 3, 2024 at 2:55 PM Miles Stephens <[e-mail]> wrote: Monthly Cumulave
2023July 38,715 38,715
2023August 37,120 75,835
2023September 29,480 105,315
2023October 17,417 122,732
2023November 21,400 144,132
2023December 20,426 164,558
2024January 21,020 185,578
2024February 28,474 214,052
2024March 39,377 253,429
2024April 27,744 281,173
2024May 34,488 315,661
2024June 28,539 344,200
Miles Stephens Mine Engineer
Ph.: [phone] Direct: [phone]
PO Box 300 5550 West Bear Canyon Rd.
Hunngton, UT 84528

CONFIDENTIALITY:
This message and any attachments may contain legally privileged and/or sensitive information. Any unapproved disclosure, use or dissemination of this e-mail message or its contents, either in whole or in pa
message, kindly notify the sender and then securely dispose of it.

From: Daniel Riddle <[e-mail]>
Sent: Tuesday, September 3, 2024 2:03 PM
To: Hyrum Peterson <[e-mail]>
Cc: Mark Reynolds <[e-mail]>; Miles Stephens <[e-mail]>
Subject: Re: 10240 - Follow up to air quality inspecon

[CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.]
Hyrum - Could you send me a table of production from July 2023 - June 2024 that includes every individual month's rolling total?
On Thu, Jul 18, 2024 at 4:13 PM Daniel Riddle <[e-mail]> wrote:
Thanks for sending this. I'll look it over and let you know if I have any questions.
On Thu, Jul 18, 2024 at 2:51 PM Hyrum Peterson <[e-mail]> wrote:Daniel,
Here is the informaon requested:
From AO DAQE-AN102400006-19:Condion II.B.1.a - coal producon - July 2023 to June 2024 (344,200 Tons)
Condion II.B.2.d - proof taken from aerial photographs or GPS measurements that the unpaved haul road is less than 1.40 miles in length anlength - See Image Aachments 1 and 2
Condion II.B.3.a - invoice or proof of purchase for ULSD fuel - See PDF Aachment
Please provide me with a list of all diesel and gasoline tanks on site with their volumes and orientaons.
Fuel Type Volume Tank Type Status
Gasoline 1,000 (Gal)Horizontal Operang
Diesel 16,000 (Gal)Vercal Operang
Diesel 3,000 (Gal)Horizontal Operang
Gasoline 11,000 (Gal)Vercal Not In Use
Diesel 11,000 (Gal)Vercal Not In Use
12/19/24, 9:44 AM State of Utah Mail - 10240 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permmsgid=msg-a:r2383061274628866030&simpl=msg-a:r238306127462886…4/7
Addionally, what is the throughput of gasoline per month at your facility? Previous inspecons showed it was less than 10,000 gallons per month.requirements from 40 CFR Part 63 Subpart CCCCCC: (https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-63/subpart-CCCCCC)
2023 Fuel Consumpon
Invoice No Invoice Date Gasoline (Gallons)
137113 1/4/2023 951.10
137228 1/18/2023 697.00
137372 2/2/2023 500.00
137586 2/28/2023 550.00
137620 3/3/2023 500.00
137744 3/20/2023 550.00
138126 4/27/2023 550.00
137914 4/6/2023 500.00
138425 6/1/2023 850.00
138562 6/16/2023 500.00
138743 7/10/2023 944.00
139016 8/7/2023 992.60
139113 8/15/2023 384.70
139430 9/19/2023 999.00
139674 10/16/2023 1,000.00
139898 11/8/2023 977.00
140076 12/1/2023 495.00
140231 12/22/2023 993.00
Total (Annual)12,933.40
Average (Monthly)1,077.78
Are these measures implemented at your facility? - Yes, the 63.11115 Requirements (above) are implemented.
Thanks,
Hyrum Peterson Engineer Tech
Ph. Direct: [phone] PO Box 300
5550 West Bear Canyon Rd. Hunngton, UT 84528

CONFIDENTIALITY:
This message and any attachments may contain legally privileged and/or sensitive information. Any unapproved disclosure, use or dissemination of this e-mail message or its contents, either in whole or
12/19/24, 9:44 AM State of Utah Mail - 10240 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permmsgid=msg-a:r2383061274628866030&simpl=msg-a:r238306127462886…5/7
message, kindly notify the sender and then securely dispose of it.
From: Miles Stephens <[e-mail]>
Sent: Thursday, July 18, 2024 9:42 AM
To: Daniel Riddle <[e-mail]>; Hyrum Peterson <[e-mail]>
Subject: Re: 10240 - Follow up to air quality inspecon
Hi Daniel.
Hyrum has been working on it. We'll have the informaon back to you a lile later today.
Thanks for following up.
Miles Stephens Mine Engineer
Ph.: [phone] Direct: [phone]
PO Box 300 5550 West Bear Canyon Rd.
Hunngton, UT 84528

CONFIDENTIALITY:
This message and any attachments may contain legally privileged and/or sensitive information. Any unapproved disclosure, use or dissemination of this e-mail message or its contents, either in whole or
message, kindly notify the sender and then securely dispose of it.

From: Daniel Riddle <[e-mail]>
Sent: Thursday, July 18, 2024 9:35 AM
To: Miles Stephens <[e-mail]>; Hyrum Peterson <[e-mail]>
Subject: Re: 10240 - Follow up to air quality inspecon

[CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.]
Hello - have you compiled these records to send me?
On Thu, Jul 11, 2024, 9:04 AM Daniel Riddle <[e-mail]> wrote:Miles and Hyrum,
Thank you for taking the time to meet with me yesterday for your air quality inspection. As discussed, here are the records I require to complete my inspection repo
From AO DAQE-AN102400006-19:
Condition II.B.1.a - coal production (June 2023 - May 2024)Condition II.B.2.d - proof taken from aerial photographs or GPS measurements that the unpaved haul road is less than 1.40 miles in length and that paved haul roa
Condition II.B.3.a - invoice or proof of purchase for ULSD fuel
Please provide me with a list of all diesel and gasoline tanks on site with their volumes and orientations. Additionally, what is the throughput of gasoline per month 10,000 gallons per month. If that is still the case you are subject to these requirements from 40 CFR Part 63 Subpart CCCCCC: (https://www.ecfr.gov/current/title-4
Are these measures implemented at your facility?
Please provide these records by July 18, 2024. Thanks and let me know if you have any questions.
Best,Daniel
2019 ao.pdf
--
12/19/24, 9:44 AM State of Utah Mail - 10240 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permmsgid=msg-a:r2383061274628866030&simpl=msg-a:r238306127462886…6/7
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
4 attachments
image.png182K
Outlook-ykoxbl1f.png23K
image.png195K
Outlook-xiy0ombn.png23K
12/19/24, 9:44 AM State of Utah Mail - 10240 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permmsgid=msg-a:r2383061274628866030&simpl=msg-a:r238306127462886…7/7
12/16/2020 https://appengine.egov.com/apps/ut/dust
https://appengine.egov.com/apps/ut/dust 1/17
DEQ DUSTA SERVICE FROM UTAH.GOV
Review Plan
Applicant Information
Applicant Type Facility/Project Manager
Name Bear Canyon Mine
Mailing Address PO Box 475
City Huntington
State Utah
Zip 84528
Phone [phone]
Email [e-mail]
Project Information
Project Name Bear Canyon Mine
Address 5550 West Bear Canyon Road
City Huntington
State Utah
Zip 84528
County Emery
Acreage 10912.7
EDIT
EDIT
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Point of Contact
Name Miles Stephens
Company Gentry Mountain Mining LLC
Address 5550 W Bear Canyon Road
City Huntington
State Utah
Zip 84528
Phone [phone]
Cell 435-609-0284
Dust Suppressants
Magnesium Chloride Magnesium Chloride
Calcium Chloride false
Clay Additives false
Lime (calcium oxide)false
Synthetic Polymers (for
example; polyvinyl
acetate and vinyl
acrylic).
false
Organic Non-
Petroleum Products,
(ligninsulfonate, tall
(pine) oil, and
vegetable derivatives).
false
BMP 01 Selections
01-01. Water backll
material to maintain
01-01. Water backll material to maintain moisture
or to form crust.
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EDIT
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moisture or to form
crust.
01-02. Apply and
maintain a chemical
stabilizer to backll
material to form crust.
false
01-03. Cover (natural
or synthetic) or enclose
backll material when
not actively handling.
false
01-04. Empty loader
bucket slowly and
minimize drop height
from loader bucket.
01-04. Empty loader bucket slowly and minimize
drop height from loader bucket.
01-05. Dedicate water
truck or large hose to
backlling equipment
and apply water as
needed.
01-05. Dedicate water truck or large hose to
backlling equipment and apply water as needed.
01-06. Mix moist soil
with dry soil until the
optimum moisture is
reached.
false
01-07. Apply and mix
water into the backll
material until optimum
moisture is reached.
false
01-08. Apply and mix
water and chemical
solution into the
backll material until
optimum moisture is
reached.
false
01-09. Apply water and
maintain disturbed
soils in a stable
condition.
01-09. Apply water and maintain disturbed soils in
a stable condition.
01-10. Apply and
maintain a chemical
stabilizer on disturbed
soils to form a crust.
false
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01-11. Mix moist soil
with dry soil until the
optimum moisture is
reached.
false
01-12. Dedicate water
truck or large hose to
equipment and apply
water as needed.
false
01-13. Not applicable 01-13. Not applicable
BMP 02 Selections
02-01. Pre-water and
maintain surface soils
in a stabilized
condition.
02-01. Pre-water and maintain surface soils in a
stabilized condition.
02-02. Apply and
maintain a chemical
stabilizer on surface
soils.
false
02-03. Limit the blast
footprint area to no
larger than what can
be practically
stabilized immediately
following the blast.
02-03. Limit the blast footprint area to no larger
than what can be practically stabilized immediately
following the blast.
02-04. Maintain surface
rock and vegetation
where possible to
reduce exposure of
disturbed soil to wind.
false
02-05. Water disturbed
soils to form crust
immediately following
blast and safety
clearance.
02-05. Water disturbed soils to form crust
immediately following blast and safety clearance.
02-06. Apply and
maintain a chemical
stabilizer to form crust
immediately following
false
EDIT
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blast and safety
clearance.
BMP 03 Selections
03-01. Pre-water and
maintain surface soils
in a stabilized
condition.
03-01. Pre-water and maintain surface soils in a
stabilized condition.
03-02. Apply and
maintain a chemical
stabilizer on surface
soils.
false
03-03. Water disturbed
soils to form crust.
03-03. Water disturbed soils to form crust.
03-04. Apply and
maintain a chemical
stabilizer on disturbed
soils to form crust.
false
03-05. Stabilize sloping
surfaces using soil
binders until
vegetation or ground
cover can eectively
stabilize the slope.
03-05. Stabilize sloping surfaces using soil binders
until vegetation or ground cover can eectively
stabilize the slope.
03-06. Apply water and
maintain sloping
surfaces/wind breaks
in a crusted condition.
false
BMP 04 Selections
04-01. Use water spray
to clear forms,
foundations and slabs.
04-01. Use water spray to clear forms, foundations
and slabs.
04-02. Use sweeping
and water spray to
false
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clear forms,
foundations and slabs.
04-03. Use industrial
vacuum to clear forms,
foundations and slabs
prior to the use of high
pressure air to blow
soil and debris.
false
04-04. Use industrial
vacuum to clear forms,
foundations and slabs.
false
BMP 05 Selections
05-01. Pre-water and
maintain surface soils
in a stabilized
condition.
05-01. Pre-water and maintain surface soils in a
stabilized condition.
05-02. Apply and
maintain a chemical
stabilizer to surface
soils.
false
05-03. Pave
operational area(s).
false
05-04. Pre-water
material.
05-04. Pre-water material.
05-05. Test material to
determine moisture
content and silt
loading, crush only
material that is at
optimum moisture
content.
false
05-06. Apply water to
stabilize material so as
to maintain
compliance with
opacity standards and
permit conditions.
05-06. Apply water to stabilize material so as to
maintain compliance with opacity standards and
permit conditions. *
EDIT
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05-07. Make
adjustments to
maintain compliance
with opacity standards
and permit conditions.
05-07. Make adjustments to maintain compliance
with opacity standards and permit conditions.
05-08. Install wind
break or use
enclosure.
05-08. Install wind break or use enclosure.
05-09. Water crushed
material immediately
following crushing.
05-09. Water crushed material immediately
following crushing.
05-10. Apply and
maintain a chemical
stabilizer to crushed
material.
false
05-11. Maintain in
enclosure.
false
05-12. Minimize height
of stockpile.
false
05-13. Minimize vehicle
miles.
false
05-14. Reduce truck
trac.
false
05-15. Reduce truck
speed.
05-15. Reduce truck speed.
05-16. Minimize
transfer and drop
point height.
05-16. Minimize transfer and drop point height. *
BMP 09 Selections
09-01. Limit
disturbance of soils
with the use of fencing,
barriers, barricades,
and/or wind barriers.
09-01. Limit disturbance of soils with the use of
fencing, barriers, barricades, and/or wind barriers.
09-02. Limit vehicle
mileage and reduce
false
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speed.
09-03. Apply water to
stabilize disturbed
soils. Soil moisture
must be maintained
such that soils can be
worked without
generating fugitive
dust.
09-03. Apply water to stabilize disturbed soils. Soil
moisture must be maintained such that soils can
be worked without generating fugitive dust.
09-04. Apply and
maintain a chemical
stabilizer.
false
09-05. Use wind
breaks.
false
09-06. Apply cover
(natural or synthetic).
false
BMP 10 Selections
10-01. Prevent access
by fencing, ditches,
vegetation, berms or
other suitable barrier.
10-01. Prevent access by fencing, ditches,
vegetation, berms or other suitable barrier. *
10-02. Apply and
maintain a chemical
stabilizer on disturbed
soils.
false
10-03. Stabilize
disturbed soil with
vegetation.
10-03. Stabilize disturbed soil with vegetation.
10-04. Pave or apply
surface rock.
false
10-05. Use wind
breaks.
false
10-06. Apply water and
maintain soil moisture
sucient to avoid
generating fugitive
dust.
10-06. Apply water and maintain soil moisture
sucient to avoid generating fugitive dust.
EDIT
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BMP 11 Selections
11-01. Apply and
maintain
water/chemical
suppressant to
operational areas and
haul routes.
11-01. Apply and maintain water/chemical
suppressant to operational areas and haul routes.
11-02. Limit vehicle
mileage and speed.
11-02. Limit vehicle mileage and speed.
11-03. Use tarps or
other suitable
enclosures on haul
trucks.
11-03. Use tarps or other suitable enclosures on
haul trucks.
11-04. Apply water
prior to transport
11-04. Apply water prior to transport
11-05. Clean wheels.false
11-06. Sweep or water
haul road.
11-06. Sweep or water haul road.
BMP 14 Selections
14-01. Pre-water and
maintain surface soils
in a stabilized
condition.
14-01. Pre-water and maintain surface soils in a
stabilized condition.
14-02. Apply and
maintain a chemical
stabilizer on surface
soils.
false
14-03. Pave
operational area(s).
false
14-04. Apply a dust
suppressant to
material.
14-04. Apply a dust suppressant to material. *
EDIT
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14-05. Dedicate water
source to screening
operation and apply
water as needed to
prevent dust.
14-05. Dedicate water source to screening
operation and apply water as needed to prevent
dust.
14-06. Install wind
barrier upwind of
screen as high as the
drop point.
14-06. Install wind barrier upwind of screen as high
as the drop point.
14-07. Apply water to
stabilize screened
material and
surrounding area.
14-07. Apply water to stabilize screened material
and surrounding area.
14-08. Apply and
maintain a chemical
stabilizer to stabilize
screened material and
surrounding area.
false
14-09. Minimize
storage pile height.
false
14-10. Drop material
through the screen
slowly and minimize
drop height.
14-10. Drop material through the screen slowly and
minimize drop height. *
BMP 15 Selections
15-01. Limit vehicle
mileage and speed
limit.
15-01. Limit vehicle mileage and speed limit.
15-02. Apply water on
all vehicle trac areas
in the staging areas
and unpaved access
routes.
15-02. Apply water on all vehicle trac areas in the
staging areas and unpaved access routes.
15-03. Pre-water and
maintain surface soils
in a stabilized
condition.
15-03. Pre-water and maintain surface soils in a
stabilized condition.
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15-04. Apply and
maintain a chemical
stabilizer to surface
soils.
15-04. Apply and maintain a chemical stabilizer to
surface soils.
15-05. Apply a chemical
stabilizer.
false
15-06. Apply screened
or washed aggregate.
false
15-07. Use wind
breaks.
false
15-08. Pave.false
15-09. Completed
project will cover
staging area with
buildings, paving,
and/or landscaping.
false
15-10. Apply water to
form adequate crust
and prevent access.
15-10. Apply water to form adequate crust and
prevent access.
BMP 16 Selections
16-01. Pre-water and
maintain surface soils
in a stabilized
condition.
16-01. Pre-water and maintain surface soils in a
stabilized condition.
16-02. Apply and
maintain a chemical
stabilizer on surface
soils.
16-02. Apply and maintain a chemical stabilizer on
surface soils.
16-03. Pave area.false
16-04. Remove
material from the
downwind side of the
stockpile, when safe to
do so.
false
16-05. Reduce height.16-05. Reduce height.
EDIT
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16-06. Create wind
screen
false
16-07. Water stockpiles
to form a crust
immediately.
16-07. Water stockpiles to form a crust
immediately.
16-08. Apply and
maintain a chemical
stabilizer to all outer
surfaces of the
stockpiles.
false
16-09. Provide and
maintain wind barriers
on 3 sides of the pile.
false
16-10. Apply a cover
(natural or synthetic)
false
16-11. Wind screen.false
16-12. Avoid steep
sides to prevent
material sloughing.
false
16-13. Reduce height.false
BMP 17 Selections
17-01. Pre-water and
maintain surface soils
in a stabilized
condition.
17-01. Pre-water and maintain surface soils in a
stabilized condition.
17-02. Apply and
maintain a chemical
stabilizer on surface
soils
false
17-03. Install cover
(natural or synthetic).
false
17-04. Apply wind
break.
false
17-05. Avoid steep
sides or faces
false
EDIT
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17-06. Minimizing the
area of disturbed
tailings.
false
17-07. Restriction the
speed of vehicles in
and around the tailings
operation.
false
BMP 18 Selections
18-01. Clean trackout
at the end of the work
shift from paved
surfaces to maintain
dust control
18-01. Clean trackout at the end of the work shift
from paved surfaces to maintain dust control
18-02. Maintain dust
control during working
hours and clean
trackout from paved
surfaces at the end of
the work shift/day.
18-02. Maintain dust control during working hours
and clean trackout from paved surfaces at the end
of the work shift/day.
18-03. Install gravel
pad(s), clean, well-
graded gravel or
crushed rock.
Minimum dimensions
must be 30 feet wide
by 3 inches deep, and,
at minimum, 50' or the
length of the longest
haul truck, whichever
is greater. Re-screen,
wash or apply
additional rock in
gravel pad to maintain
eectiveness.
false
18-04. Install wheel
shakers. Clean wheel
shakers on a regular
basis to maintain
eectiveness.
false
EDIT
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18-05. Install wheel
washers. Maintain
wheel washers on a
regular basis to
maintain eectiveness.
false
18-06. Motorized
vehicles will only
operate on paved
surfaces.
false
18-07. Install cattle
guard before paved
road entrance.
false
18-08. Clearly establish
and enforce trac
patterns to route
trac over selected
trackout control
device(s).
18-08. Clearly establish and enforce trac patterns
to route trac over selected trackout control
device(s).
18-09. Limit site
accessibility to routes
with trackout control
devices in place by
installing eective
barriers on
unprotected routes.
false
BMP 19 Selections
19-01. Limit vehicle
mileage and speeds.
19-01. Limit vehicle mileage and speeds.
19-02. Apply and
maintain water on
surface soils.
19-02. Apply and maintain water on surface soils.
19-03. Apply and
maintain chemical
stabilizers on surface
soils.
false
19-04. Apply and
maintain gravel on
surface soils.
19-04. Apply and maintain gravel on surface soils.
EDIT
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19-05. Supplement
chemical stabilizers,
water or aggregate
applications as
necessary.
19-05. Supplement chemical stabilizers, water or
aggregate applications as necessary.
19-06. Apply recycled
asphalt (RAP) to
surface soils.
false
BMP 20 Selections
20-01. Pre-water
surface.
20-01. Pre-water surface. *
20-02. Pre-water and
maintain surface soils
in a stabilized
condition.
20-02. Pre-water and maintain surface soils in a
stabilized condition.
20-03. Apply and
maintain a chemical
stabilizer to surface
soils.
false
20-04. Limit mileage
and speed.
20-04. Limit mileage and speed.
20-05. Apply and
maintain water on
excavated soil.
20-05. Apply and maintain water on excavated soil.
20-06. Apply and
maintain chemical
stabilizer on excavated
soil.
false
BMP 21 Selections
21-01. Pre-water and
maintain surface soils
in a stabilized
condition where
loaders, support
21-01. Pre-water and maintain surface soils in a
stabilized condition where loaders, support
equipment and vehicles will operate.
EDIT
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equipment and
vehicles will operate.
21-02. Apply and
maintain a chemical
stabilizer on surface
soils where loaders,
support equipment
and vehicles will
operate.
false
21-03. Empty loader
bucket slowly and keep
loader bucket close to
the truck to minimize
the drop height while
dumping.
21-03. Empty loader bucket slowly and keep loader
bucket close to the truck to minimize the drop
height while dumping.
Print this page for your records or save it as a PDF as specied by your browser
or operating system.
By submitting this plan I agree to the following terms:
A. I am authorized, on behalf of the individual or company listed in Section 1, as
Applicant, to apply for a Fugitive Dust Control Plan and to commit to all of the terms
and conditions of the requested plan.
B. Construction activities will be limited to lands that the applicant either owns or is
authorized to use for construction activities.
C. The applicant accepts responsibility for assuring that all contractors,
subcontractors, and all other persons on the construction site covered by this plan,
comply with the terms and conditions of the Fugitive Dust Control Plan.
D. I understand that any false material statement, representation or certication
made in this application may invalidate the plan or cause me to be subject to
enforcement action pursuant to Utah Code Ann. 19-2-115. E. Failure to comply with
fugitive dust rules may result in compliance action and penalties up to $10,000 per
violation/day.
My plan is ready to be submitted. *
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GENTRY MOUNTAIN MINING, LLC
P.O. BOX 300 Office [phone]
Huntington, UT 84528
December 3, 2024
Chad Gilgen, Manager
Utah Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Re: Compliance Advisory DAQC-1126-24
Dear Mr. Gilgen:
Enclosed is the response to the Compliance Advisory dated November 12, 2024, which I
received on November 20, 2024. The enclosed response is a report of a performance test
conducted in accordance with Section 60.255(b)(2) as referenced in the Compliance Advisory.
If you have any questions regarding this matter, please contact me.
Sincerely,
Miles Stephens
Mine Engineer
Office: 435-687-2178
Mobile: [phone]
[e-mail]
Enclosure(s)
Cc: COP Development Company, LLC
REVIEWED
Initials:DDR Date:12/4/2024 Compliance Status: Response to CA File #: 10240 (B1)
OPACITY MONITORING AT THE BEAR CANYON MINE
AO - DAQE-AN102400006-19
NOVEMBER 2024
This report presents the results of visible emissions observations performed at the Bear Canyon Mine located
at 5550 W. Bear Canyon Road, Huntington, UT 84528. This facility is operated by Gentry Mountain Mining,
LLC. The observations were performed in compliance with the minor source Approval Order
DAQE-AN102400006-19 (AO) issued by the Utah Division of Air Quality. The observations were performed by
Miles Stephens of Gentry Mountain Mining, LLC, an EPA Method 9 Certified reader (See Attachment 3). The
opacity readings were conducted intermittently between 11/11/24 and 11/22/24.
The Bear Canyon Mine is subject to Section 60.255(b)(2) of Subpart Y of the Environmental Protection
Agency’s New Source Performance Standards (NSPS) for new and modified stationary sources of air
pollutants, which applies to facilities that commenced construction, reconstruction, or modification after April,
2008. This Section requires that performance tests be conducted periodically during normal operation of the
mine to demonstrate compliance with the applicable emissions standard stated in the AO, with the frequency of
the tests dependent on the results of the most recent performance test.
The AO for Bear Canyon was modified to include additional equipment (Dry Coal Separator) and was
approved on October 24, 2019. The dry coal separator has yet to be commissioned, and therefore was not
included in this observation. Method 9 visible emissions observations were performed according to the test
method and procedures outlined in Section 60.257(a)(1)-(3) and the approved AO.
Bear Canyon Mine Emissions Observation Performance Method
The mine facilities include transporting the coal from underground via 4 surface conveyor belts that deliver
run-of-mine (ROM) coal through a tipple processing facility which includes sorting into multiple stockpiles
before being loaded into haul trucks.
Conveyor Belt #4 transports the coal from underground to the surface and into a fully enclosed storage bin
after which the ROM is fed onto Conveyor belt #3. Since this transfer point is fully enclosed, it meets
compliance per Section 60.255(c). The coal is transported down the canyon from the storage bin via
Conveyors 3, 2, and 1, after which point processing begins. The coal can be crushed and sorted into 4 distinct
piles: High Ash (Pile 4), Low Ash (Pile 1), slack coal, or lump coal. Under normal operations, the coal is most
commonly only sorted between Pile 4 and Pile 1, and only occasionally sorted into slack or lump piles. During
this observation, only Pile 4, Pile 1 and slack coal were being produced. Although no lump coal was being
produced, the lump coal screenage crusher was turned on long enough to perform an emissions evaluation.
There were a total of 14 observation points observed. These emission sources observed (identified as A thru
N) as well as the locations where each observation was conducted (identified as 1 thru 14) are shown on
Figures 1-3. A summary table comparing the results with opacity limits per the approved AO are given in Table
1 and a more detailed tabulation of the field observations is given in Table 2. The observation field sheets are
included in Attachment 1, and the observer’s Method 9 certificate is included in Attachment 2.
FIGURE 1 - Conveyor Transfer Points from Underground to Surface Processing (Observed 11/11/24)
FIGURE 2 - Coal Processing, Coal Storage, Truck Loading (Observed 11/15, 11/19, 11/21, 11/22)
FIGURE 3 - Coal Truck Haul Roads (Observed 11/21/24).
Table 1 - Bear Canyon Mine Opacity Limits and Highest Average Observed Opacity
Conveyor
Transfer Points
20 0 1 Conveyor 3 to 2 transfer point.
20 0 2 Conveyor 2 to 1 transfer point
20 0 3 Conveyor 1 to Upper Screen
Tipple
Processing
20 0 4 Upper Screen
20 0 5 Gundlach Crusher
20 0 6 Lower Screen
20 2.29 12 Lump Screenage Crusher
Coal Storage
Pad
20 0 7 ROM Conveyor drop to Pile #4
20 0 8 ROM Conveyor drop to Slack Pile
20 0 9 ROM Conveyor drop to Pile #1
Truck Loading
Points
20 0.21 10 Coal loadout #4
20 0.21 11 Coal loadout #1
Haul Roads 20 0 13 Haul road location #1
20 0 14 Haul road location #2
Emission
Sources
Opacity Limits
per AO
DAQE-AN1024
00006-19 (%)
Observed
Opacity,
Highest
Average (%)
Observation
Point Notes
Table 2 - Tabulation Summary of Field Sheet Observations and Average Opacity.
Facility Observation
Point Location
Date Minutes
Interval
Average
Opacity (%)
Notes
Bear Canyon Mine
Conveyor 3-2
Transfer 11/11/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
A 7-12 0
13-18 0
19-24 0
25-30 0
B
Conveyor 2-1
Transfer 11/11/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
C
Conveyor 1
Transfer to
Upper
Screen
11/11/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
D
Upper
Screen 11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
E
Gundlach
Crusher 11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
F
Lower
Screen 11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
G
Conveyor
drop to Pile
#4
11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
H
Conveyor
drop to Slack
Pile
11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
I
Conveyor
drop to Pile
#1
11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
L
Lump
Screenage
Crusher
11/19/24
1-6 2.08 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 1.67
13-18 2.29
19-24 1.88
25-30 1.46
K
Truck
Loadout #1 11/21/24 1-6 0
Observed 2 trucks being loaded
(total of 4 trailers) during two
separate 6-minute intervals.7-12 0.21
J
Truck
Loadout #4 11/22/24 1-6 0.21
Observed 2 trucks being loaded
(total of 4 trailers) during two
separate 6-minute intervals.7-12 0.21
M
Haul Road
Location #1 11/21/24
1 0 Observed 6 passes after the
truck left Loadout #1.2 0
3 0
4 0
5 0
0
N
Haul Road
Location #2 11/21/24
1 0 Observed 6 passes after the
truck left the scales.2 0
3 0
4 0
5 0
0
Pass #
6
Pass #
6
Conclusions and Recommendations
Observed visible emissions from a viewed sources were less than the applicable limit and the Bear Canyon
Mine is in compliance with applicable opacity limits. Based on the requirements given in Section 60.255(b)(2)
of Subpart Y, the next performance test is due within 12 calendar months of the date that this performance test
was completed.
ATTACHMENT 1
Opacity Observation Field Sheets
ATTACHMENT 2
Method 9 Certification
Mi
l
e
s

S
t
e
p
h
e
n
s
Is
s
u
e
d
:

0
9
/
3
0
/
2
0
2
4

Ex
p
i
r
e
s
:

0
3
/
3
0
/
2
0
2
5

Miles Stephens
Certification Date: September 30, 2024
Expiration Date: March 30, 2025 AeroMet Instructor: Steve Mumma