DAQ-2025-000130

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DAQC-1244-24
Site ID 10273 (B1)

MEMORANDUM

TO: FILE – ASHDOWN BROTHERS CONSTRUCTION – Asphalt Plant Crusher
Concrete Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: December 18, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Iron County

INSPECTION DATE: September 6, 2023

SOURCE LOCATION: 1134 North Lund Highway, Cedar City, Iron County

Directions: Take I-15 Exit 59, 200 N and head west to Lund
Highway (3100 West), just west of the airport.

SOURCE CONTACT(S): Karen Hunter: 435-586-1138,
[e-mail]
Mark Ashdown, Manager: 435-586-1138
Kris Ashdown, Supervisor: 435-590-5100
[e-mail]

OPERATING STATUS: Operating.

PROCESS DESCRIPTION: Ashdown Brothers operates an aggregate processing plant and
asphalt plant in Cedar City. Aggregate material is loaded from
the pit walls into a feeder by a front-end loader. The material
then passes through a jaw crusher and is then conveyed to a
screen. Material that is too large to pass through the screen falls
into a cone crusher. Crushed rock then falls onto a conveyor
which routes it back to the screen. Material is classified in the
screen according to size and is stacked by conveyors by its size
classification onto storage piles. Water sprays and a vinyl
enclosure around the screen are used to control dust from the
aggregate operations. A water truck is used to control fugitive
dust from the haul roads, storage piles, and operational areas.
The aggregate material is then sold and shipped off site for
construction projects or is used in the asphalt plant.

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The material used at the asphalt plant is loaded into storage bins
according to size. The material is fed onto a conveyor where it is
then dropped into a drum dryer. The dried aggregate is then
dropped into a pugmill where asphalt and other materials are
added and mixed in. Asphalt material is loaded into a haul truck
then hauled to the paving project. A Venturi scrubber controls
stack emissions at the asphalt plant.

APPLICABLE REGULATIONS: Approval Order DAQE-AN0102730001-08, dated September
30, 2008

SOURCE INSPECTION
EVALUATION: General AO Conditions:

Condition 1. This Approval Order (AO) applies to the following company:

Site Office
Ashdown Brothers Construction
1134 North Lund Hwy.
Cedar City, Utah 84720
Phone Number: [phone]
Fax Number: [phone]

The equipment listed in this AO shall be operated at the following location:

PLANT LOCATION:
1134 North Lund Hwy.
Cedar City, Utah, Iron County

Universal Transverse Mercator (UTM) Coordinate System:
4,174.63 kilometers Northing, 316.96 kilometers Easting, Zone 12

Condition 2. All definitions of terms, abbreviations, and references used in this AO conform to those
used in the Utah administrative Code (UAC) Rule 307 (R307), and Title 40 of the Code
of Federal Regulations (40 CFR). Unless noted otherwise, references cited in these AO
conditions refer to those rules.

Condition 3. The limits set forth in this AO shall not be exceeded without prior approval in accordance
with R307-401.

Status: In Compliance. No limits were exceeded. See status of each condition for compliance
details.

Condition 4. Modifications to the equipment and processes approved by this AO that could affect the
emissions covered by this AO must be approved in accordance with R307-401-1.

Status: Not in Compliance. There are two generators that operate the conveyors for the
aggregate pit. These generators are not on the current AO. However, a Notice of
Intent was submitted to include the generators in a new AO, but has been in process
since 2021.

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Condition 5. All records referenced in this AO or in applicable NSPS, which are required to be kept by
the owner/operator, shall be made available to the Executive Secretary or Executive
Secretary’s representative upon request. Records shall be kept for the following minimum
periods:

A. Emissions inventories Five years from the date of each emissions statement
or until the next inventory is due, whichever is longer.

B. All other records Five years

Status: In Compliance. Records were reviewed on site and by email. Emission inventory has
been submitted to DAQ.

Condition 6. Ashdown Brothers Construction shall install and operate the vertical impact crusher and
two screens and shall conduct its operation of the aggregate, asphalt and concrete
production in accordance with the terms and conditions of this AO, which was written
pursuant to Ashdown Brothers Construction’s NOI submitted to the Division of Air
Quality (DAQ) on May 15, 2008, and additional information submitted to the DAQ on
June 26, 2008.

Status: In Compliance.

Condition 7. This AO shall replace the AO (DAQE-525-01) dated July 5, 2001.

Status: In Compliance. The compliance determination was based solely on the current AO.

Condition 8. The approved installations shall consist of the following equipment or equivalent*:

Aggregate Plant

A. One (1) El Jay jaw crusher, Model 1208 *

B. One (1) El Jay 45" cone crusher, Model 115 *

C. One (1) vertical impact crusher** rated at 100 tons/hour, manufactured in 1982

D. One (1) screen**, 3’x 8’, manufactured in 1957

E. One (1) screen**, 5’x 16’, manufactured in 1957

Asphalt Plant

F. One (1) Madsen 4000 asphalt plant, 150 ton/hour (design capacity), Mfg 1964*

G. One (1) wet Venturi scrubber

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Concrete Batch Plant

H. One (1) concrete batch plant with bin vent on associated cement silos

I. Miscellaneous plant-wide equipment including loaders, dozers, water and haul
trucks, conveyors, stackers, and small diesel fuel tanks

* Equivalency shall be determined by the Executive Secretary.
** Newly installed equipment

Status: Out of Compliance. There are two generators located at the Aggregate Plant, a
545-kW diesel generator and a 300-kW diesel generator. These generators run the
Aggregate Plant machinery. In a previous inspection memo, Mark Ashdown stated
that they have been there since approximately 2001. A Notice of Intent has been
submitted to include the generators in the AO. The above equipment is installed and
operable with the exception of the concrete batch plant which has been removed.

Condition 9. Ashdown Brothers Construction shall notify the Executive Secretary in writing when the
installation of the equipment listed in Condition 8.C., D. and E. has been completed and
is operational, as an initial compliance inspection is required. To insure proper credit
when notifying the Executive Secretary, send your correspondence to the Executive
Secretary, Attn: Compliance Section.

If installation has not been completed within eighteen months from the date of this AO,
the Executive Secretary shall be notified in writing on the status of the installation. At
that time, the Executive Secretary shall require documentation of the continuous
installation of the operation and may revoke the AO in accordance with R307-401-11.

Status: Not in compliance - No notification was in the file. According to the 2011 inspection
memo, an initial inspection was conducted in 2008 which observed the equipment in
Condition 8.C., D. and E. No action is recommended.

Limitations and Test Procedures

Condition 10. Emissions to the atmosphere at all times from the indicated emission point shall not
exceed the following rates and concentrations:

Source: Asphalt Plant Scrubber

Pollutant lb/hr grains/dscf
(68°F, 29.92 in Hg)

TSP ............................ 3.67.................................. 0.030
TSP (RAP) ................. 4.28.................................. 0.035
PM10 ........................... 2.94.................................. 0.024
PM10 (RAP) ................ 3.43.................................. 0.028

Status: In Compliance. Stack testing to determine compliance with the above listed
limitations at the asphalt plant was conducted May 5, 2022. The results of the stack
test for PM were 2.029 lb/hr and 0.011 grains/dscf. Results were reviewed and
excepted by DAQ (DAQC-776-22).

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Condition 11. Stack testing to show compliance with the emission limitations stated in the above
condition shall be performed as specified below:

A. Testing Test
Emissions Point Pollutant Status Frequency

Asphalt Plant PM10 * @
Scrubber (virgin and RAP)

B. Testing Status (To be applied above)

* The initial testing was performed for TSP and subsequent tests shall be
performed for PM10.

@ Test every five years. The Executive Secretary may require testing at any
time. Compliance testing shall not be required for both virgin and recycle
materials during the same testing period. Testing shall be performed for
the product being produced during the time of testing.

C. Notification

The Executive Secretary shall be notified at least 30 days prior to conducting any
required emission testing. A source test protocol shall be submitted to DAQ
when the testing notification is submitted to the Executive Secretary.

The source test protocol shall be approved by the Executive Secretary prior to
performing the tests. The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest
conference shall be held, if directed by the Executive Secretary.

D. Sample Location

The emission point shall be designed to conform to the requirements of 40 CFR
60, Appendix A, Method 1, or other methods as approved by the Executive
Secretary. An Occupational Safety and Health Administration (OSHA) or Mine
Safety and Health Administration (MSHA) approved access shall be provided to
the test location.

E. Volumetric Flow Rate

40 CFR 60, Appendix A, Method 2 or other testing methods approved by the
Executive Secretary

F. PM10

For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Methods 201, 201a, or other testing methods
approved by the Executive Secretary. The back half condensibles shall also be
tested using the method specified by the Executive Secretary. All particulate
captured shall be considered PM10.

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For stacks in which liquid drops are present, methods to eliminate the liquid
drops should be explored. If no reasonable method to eliminate the drops exists,
then the following methods shall be used: 40 CFR 60, Appendix A, Method 5,
5a, 5d, or 5e as appropriate, or other testing methods approved by the Executive
Secretary. The back half condensibles shall also be tested using the method
specified by the Executive Secretary. The portion of the front half of the catch
considered PM10 shall be based on information in Appendix B of the fifth edition
of the EPA document, AP-42, or other data acceptable to the Executive
Secretary.

The back half condensibles shall not be used for compliance demonstration but
shall be used for inventory purposes.

G. Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration, as
determined by the appropriate methods above, shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the
Executive Secretary to give the results in the specified units of the emission
limitation.

H. Existing Source Operation

For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the
previous three (3) years.

I. PM10

For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Methods 201, 201a, or other testing methods
approved by the Executive Secretary. The back half condensibles shall also be
tested using the method specified by the Executive Secretary. All particulate
captured shall be considered PM10.

For stacks in which liquid drops are present, methods to eliminate the liquid
drops should be explored. If no reasonable method to eliminate the drops exists,
then the following methods shall be used: 40 CFR 60, Appendix A, Method 5,
5a, 5d, or 5e as appropriate, or other testing methods approved by the Executive
Secretary. The back half condensibles shall also be tested using the method
specified by the Executive Secretary. The portion of the front half of the catch
considered PM10 shall be based on information in Appendix B of the fifth edition
of the EPA document, AP-42, or other data acceptable to the Executive
Secretary.

The back half condensibles shall not be used for compliance demonstration but
shall be used for inventory purposes.

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J. Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration, as
determined by the appropriate methods above, shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the
Executive Secretary to give the results in the specified units of the emission
limitation.

K. Existing Source Operation

For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the
previous three (3) years.

Status: In Compliance. Stack testing to determine compliance at the asphalt plant was
conducted in May 5, 2022, by Montrose Air Quality Services, LLC. Acceptance of
test protocol was documented in DAQC-459-22.

Condition 12. Visible emissions from the following emission points shall not exceed the following
values:

A. All crushers - 15% opacity
B. All screens - 10% opacity
C. All scrubbers - 15% opacity
D. All baghouses/bin vents - 10% opacity
E. All conveyor transfer points - 10% opacity
F. All diesel engines - 20% opacity
G. Conveyor drop points - 20% opacity
H. All other points - 20% opacity

Opacity observations of emissions from stationary sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9.

For equipment subject to NSPS, opacity shall be determined by conducting observations
in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9.

Initial visible emission observations shall consist of 30 observations of six minutes each
in accordance with 40 CFR 60.11(b). Equipment subject to NSPS Subpart OOO shall
comply with 40 CFR 60.675(3) or 40 CFR 60.675(4). All visible emission observations
must be conducted in accordance with 40 CFR 60, Appendix A, Method 9. A certified
observer must be used for these observations. Emission points which are subject to the
initial observations are:

A. The impact crusher in Condition #8.C.
B. The screen in Condition #8.D.
C. The screen in Condition #8.E.

Status: Not observed. The crushing circuit was down for repair and the asphalt plant had
shutdown for the day.

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Condition 13. The following production limits shall not be exceeded:

A. 400,000 tons of processed aggregate material per rolling 12-month period.
B. 3,000 hours of aggregate plant equipment operation per rolling 12-month period.
C. 10,000 cubic yards of concrete production per rolling 12-month period.
D. 100,000 tons of asphalt production per rolling 12-month period.
E. 3,000 hours of asphalt plant equipment operation per rolling 12-month period.
F. 85 ton per hour - maximum production rate of the Madsen 4000 asphalt plant

Compliance with the limitations shall be determined on a rolling 12-month total. The
owner/operator shall calculate a new 12-month total by the twentieth 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. Records of production, including rolling 12-month
totals, shall be made available to the Executive Secretary or Executive Secretary’s
representative upon request and the records shall include the two-year period prior to the
date of the request. Production shall be determined by vendor receipts or weigh scale
records. The records of production shall be kept on a daily basis. Hours of operation shall
be determined by supervisor monitoring and maintaining of an operations log.

Status: In Compliance. Plant production and hours of operation listed below are for the
12-month period ending at the end of August 2023 and are as follows:

A. The total aggregate material processed through the plant was 34,037 tons for the
12-months prior to the inspection.

B. The total hours of operation for the 12-months prior to the inspection were
562.5 hours for the crushing/screening operations.

C. The concrete batch plant has been removed.

D. The total tons of asphalt produced were 32,950 tons for the 12-month period
prior to the inspection.

E. The total hours of operation of the asphalt plant for the 12 months prior to the
inspection were 752 hours.

F. The 85 ton/hour limit on the asphalt plant is a design criteria.

Condition 14. Visible fugitive dust emissions from haul-road traffic and mobile equipment in
operational areas shall not exceed 20% opacity from any point. 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 ½ vehicle length behind the vehicle and not less than ½ the height of
the vehicle.

Status: In Compliance. The unpaved roads and operational areas were well maintained and
a water truck was available. Watering records are kept by the office manager and
were reviewed on site.

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Condition 15. Ashdown Brothers Construction shall abide by all applicable requirements of R307-205
for Fugitive Emission and Fugitive Dust sources.

Status: In Compliance. Ashdown Brothers Construction appear to be abiding with the
requirements of R307-205.

Condition 16. All unpaved roads and other unpaved operational areas that are used by mobile
equipment shall be water sprayed and/or chemically treated to control fugitive dust. The
application of water or chemical treatment shall be used. Treatment shall be of sufficient
frequency and quantity to maintain the surface material in a damp/moist condition or
unless it is below freezing. The opacity shall not exceed 20% during all times the areas
are in use. If chemical treatment is to be used, the plan must be approved by the
Executive Secretary. Records of water and/or chemical treatment shall be kept for all
periods when the plant is in operation. The records shall include the following items:

A. Date
B. Number of treatments made, dilution ratio, and quantity
C. Rainfall received, if any, and approximate amount
D. Time of day treatments were made
E. Records of temperature if the temperature is below freezing

Status: In Compliance. Records were reviewed on site. Dates and number of treatments are
recorded.

Condition 17. The haul road limitations shall be:

A. ½ mile in length
B. 15 miles per hour

The haul road speed shall be posted, at a minimum, on site at the beginning of the haul
road so that it is clearly visible from the haul road.

Status: In Compliance. The haul road appeared to be approximately ½ mile in length and
speed limit is posted at 10 mph at the entrance to facility.

Condition 18. Silos for Concrete Batching: All pneumatically loaded silos shall have the displaced air
pass through a fabric filter device before being vented to the atmosphere.

Status: Not applicable. The concrete batch plant has been removed from the site.

Condition 19. Control of disturbed or stripped areas shall be required at all times for the duration of the
project/operation per R307-205.

Status: In Compliance. Stripped or disturbed areas are watered as required.

Condition 20. The in-plant haul road shall be paved and shall be periodically swept or sprayed clean as
dry conditions warrant or as determined necessary by the Executive Secretary. Records of
cleaning paved roads shall be maintained.

Status: In Compliance. Ashdown Brothers Construction stated that they water the haul
road as needed. Records of watering are kept in the main office.

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Condition 21. Water sprays or chemical dust suppression sprays shall be installed at the following
points to control fugitive emissions:

A. All crushers
B. All screens
C. All conveyor transfer points

The sprays shall operate whenever dry conditions warrant or as determined necessary by
the Executive Secretary.

Status: In Compliance. Water sprays have been installed and are operational as needed.

Condition 22, The storage piles shall be watered to minimize generation of fugitive dusts, as dry
conditions warrant or as determined necessary by the Executive Secretary. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in
operation.

Status: In Compliance. The storage piles are watered as needed by the water truck.

Condition 23. The owner/operator shall use only #1 or #2 fuel oil as a fuel source. The asphalt plant
shall use natural gas, propane or fuel oil as fuel.

Status: In Compliance. Ashdown Brothers Construction uses #2 diesel for fuel.

Condition 24. The sulfur content of any fuel oil or diesel burned shall not exceed 0.5 percent by weight.
Sulfur content shall be decided by ASTM Method D2880-71 or D-4294-89, or approved
equivalent. The sulfur content shall be tested if directed by the Executive Secretary. The
percent by weight of the sulfur contained in the fuel can be obtained from the fuel oil
certifications. Certification of fuels shall be either by Ashdown Brothers Construction’s
own testing or test reports from the fuel marketer. Records of fuel supplier's test report on
sulfur content shall be available on-site for each load delivered.

Status: In Compliance. The sulfur content of the diesel fuel used is less than 0.5% by
weight.

Condition 25. In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, NSPS
Subpart A, 40 CFR 60.1 to 60.18 and Subpart OOO, 40 CFR 60.670 to 60.676 (Standards
of Performance for Nonmetallic Mineral Processing Plants) apply to this installation.

Status: In Compliance. Ashdown Brothers Construction is abiding by the applicable
provisions of 40 CFR 60, NSPS Subparts A and OOO. The applicable provisions of
Subpart OOO are covered in other conditions of the AO.

Condition 26. The following operating parameters shall be maintained within the indicated ranges:

A. Asphalt Plant Scrubber

The liquid flow rate (including make-up water) shall not be less than 420 gallons
per minute (gpm) or more than 480 gpm.

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They shall be monitored with equipment located such that an inspector/operator
can safely read the output any time. The readings shall be accurate to within the
following ranges:

B. Liquid flow rate - Plus or minus 5 gallons per minute

All instruments shall be calibrated on an annual basis according to the manufacturer's
instructions. Continuous recording for the monitoring device is not required.

Status: Not observed. The asphalt plant was finished for the day. The magnehelic is
replaced annually.

Condition 27. 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 the information available to the Executive Secretary 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 the equipment authorized by this AO shall be recorded.

Status: In Compliance. All maintenance is performed on an as-needed basis.

Condition 28. The owner/operator shall comply with R307-150 Series. Inventories, Testing and
Monitoring.

Status: In Compliance. An Emission Inventory was submitted for the 2023 operating year.

Condition 29. The owner/operator shall comply with R307-107. General Requirements: Unavoidable
Breakdowns.

Status: In Compliance. There have been no reportable breakdowns at this facility as of the
date of the inspection.

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), A: General Provisions

Status: Compliance with NSPS (Part 60), A is determined by applicability of NSPS conditions at the
source location. See status of NSPS (Part 60) conditions for additional information.

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

Status: In compliance. NSPS Subpart OOO was addressed in condition 25 and other conditions of the
AO.

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MACT (Part 63), A: General Provisions

Status: Compliance with NSPS (Part 63) A is determined by applicability of NSPS conditions at the
source location. See status of NSPS (Part 63) conditions for additional information.

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

Status: Out of Compliance. There are two generators in the aggregate plant. The generators were
installed in 2001 and are maintained by site personnel according to manufacturer’s specifications. A
non-resettable hour meter is required (66.6625(f)). Table 2d requires to change oil and filter every 500
hours of operation or annually (which ever first), inspect air cleaner every 1000 hours of operation or
annually (which ever first), and inspect hoses and belts every 500 hours or annually (which ever first).
Compliance assistance was provided for stack testing both generators. A stack test is required on both
generators.

EMISSION INVENTORY:

The emissions listed below are an estimate of the total potential emissions from Ashdown Brothers
Construction - Asphalt Plant Crusher Concrete Plant on the Approval Order DAQE-AN0102730001-08,
dated September 30, 2008. The following information was supplied for supplemental purposes only.

Estimated Criteria Pollutant Potential Emissions
Particulate Matter - PM10 4.96 tons/yr
Nitrogen Oxides 39.09 tons/yr
Sulfur Dioxide 8.03 tons/yr
Carbon Monoxide 10.65 tons/yr
Volatile Organic Compounds 5.21 tons/yr

Estimated Hazardous Air Pollutant Potential Emissions
Generic HAPs (CAS #GHAPS) 0.62 tons/yr

Ashdown Brothers Construction- Asphalt Plant Crusher Concrete Plant Emissions Inventory data for the
2023 activity year are recorded as follows:

Pollutant Tons/yr
Particulate Matter - PM10 3.553
Particulate Matter – PM2.5 1.405
Sulfur Dioxide 0.637
Nitrogen Oxides 5.643
Volatile Organic Compounds 0.444
Carbon Monoxide 7.562
Lead 0.002

Hazardous Air Pollutant Tons/yr
PAH, total 0.00032

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PREVIOUS ENFORCEMENT
ACTIONS: CAN (DAQC-1186-17) issued on August 31, 2017, for failure to
monitor flow rate from the asphalt plant and failure to submit the
emission inventory.

A Compliance Advisory was sent out on April 29, 2020, and a
response was received on May 8, 2020, stating that they will
modify their AO to include the two generators for the aggregate
pit.

Warning (DAQC-976-22) issued July 26, 2022, for unapproved
equipment (generators).

COMPLIANCE STATUS &
RECOMMENDATIONS: Out of compliance. The source has had two generators on site
that are not included in the AO. A Notice of Intent has been
submitted to include the generators to the AO. Compliance
assistance was provided to stack test the generators. A CA was
issued for this inspection (DAQC-1039-23) as well as a CA for
an inspection conducted in 2024 (DAQC-906-24). An ESA is
anticipated to be issued in the near future.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at an increased frequency. Check for a new AO that
includes the generators that operate the aggregate pit. Also,
check that stack test have been conducted on the asphalt plant,
and the two generators at the aggregate operations.

RECOMMENDATION FOR
NSR PERMITTING REVIEW: The site has a 545-kW (1999 manufacture date) generator and a
300-kW (1986 manufacture date) generator as part of the
Aggregate Plant that are not on the Approval Order.

ATTACHMENTS: VEO Form, Emails
Jared James <[e-mail]>
Ashdown Brothers Operation Hours
7 messages
Karen Hunter <[e-mail]>Thu, Oct 12, 2023 at 11:39 AM
To: "[e-mail]" <[e-mail]>

Good morning Jared,

I am so sorry I am just getting these to you.

Plant Operation Hours for July 2022-Aug 2023

Agg. Plant Operation Hours 562.50

Asphalt Plant Operation Hours 752.00

Thank You,
Karen Hunter
Office Manager
Ashdown Brothers Const.
Ph: 435-586-1138
Fax: [phone]

Jared James <[e-mail]>Thu, Oct 12, 2023 at 12:00 PM
To: Karen Hunter <[e-mail]>
Thank you.
[Quoted text hidden]
--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
12/18/24, 3:23 PM State of Utah Mail - Ashdown Brothers Operation Hours
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1779572279718105726&simpl=msg-f:177957227971810572…1/4
195 North 1950 West, Salt Lake City, UT 84116
Karen Hunter <[e-mail]>Thu, Oct 12, 2023 at 12:01 PM
To: Jared James <[e-mail]>
You're welcome.

From: Jared James <[e-mail]>
Sent: Thursday, October 12, 2023 12:00 PM
To: Karen Hunter <[e-mail]>
Subject: Re: Ashdown Brothers Operation Hours

Thank you.

On Thu, Oct 12, 2023 at 11:39 AM Karen Hunter <[e-mail]> wrote:

Good morning Jared,

I am so sorry I am just getting these to you.

Plant Operation Hours for July 2022-Aug 2023

Agg. Plant Operation Hours 562.50

Asphalt Plant Operation Hours 752.00

Thank You,
Karen Hunter
Office Manager
Ashdown Brothers Const.
Ph: 435-586-1138
Fax: [phone]

12/18/24, 3:23 PM State of Utah Mail - Ashdown Brothers Operation Hours
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1779572279718105726&simpl=msg-f:177957227971810572…2/4

--
Jared James | Environmental Scientist | Minor Source Compliance
Phone:[phone] email: [e-mail]
[Quoted text hidden]
Jared James <[e-mail]>Tue, Oct 17, 2023 at 3:52 PM
To: Karen Hunter <[e-mail]>
Hi Karen
Do you know if Ashdown Brothers has received the Compliance Advisory letter (DAQC-1039-23) yet? It would have been
addressed to Kris. If not I can send it by email. Please let me know either way.
Thanks!
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
Karen Hunter <[e-mail]>Tue, Oct 17, 2023 at 3:56 PM
To: Jared James <[e-mail]>
HI Jared,

I have not seen it yet!

Thank You,
Karen Hunter
Office Manager
Ashdown Brothers Const.
Ph: 435-586-1138
Fax: [phone]
12/18/24, 3:23 PM State of Utah Mail - Ashdown Brothers Operation Hours
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1779572279718105726&simpl=msg-f:177957227971810572…3/4

[Quoted text hidden]
Jared James <[e-mail]>Tue, Oct 17, 2023 at 4:11 PM
To: Karen Hunter <[e-mail]>
Karen
Attached is the compliance advisory letter. Don't worry about conditions 8 and 13 concerning records, the information you
gave me last week addressed those concerns. As for the conditions concerning unapproved equipment and equipment
modification, make sure you provide dates and evidence of when Ashdown initially submitted the Notice of Intent (whether
that was in June of this year or if you submitted an NOI last year) and any correspondence you have had with the permit
writer. Please provide a response to the compliance advisory by October 31, 2023.
Thanks!
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C-1039-23.pdf
412K
Jared James <[e-mail]>Tue, Nov 21, 2023 at 10:35 AM
To: Karen Hunter <[e-mail]>
Hi Karen
I haven't seen a response to the compliance advisory from you guys yet. So I'm just verifying that you guys received it and
to get an idea of when I can expect a response. Please, let me know if the compliance advisory has been passed on to
Kris and if I can expect a response soon. I wouldn't want this to elevate to a notice of violation. Thanks for your
assistance.
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12/18/24, 3:23 PM State of Utah Mail - Ashdown Brothers Operation Hours
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1779572279718105726&simpl=msg-f:177957227971810572…4/4