DAQ-2025-000162

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DAQC-CI109070001-24
Site ID 10907 (B1)

MEMORANDUM

TO: FILE – WESTERN ROCK PRODUCTS CORPORATION – Sorenson Pit

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jared James, Environmental Scientist

DATE: October 21, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Washington County

INSPECTION DATE: August 16, 2024

SOURCE LOCATION: Five miles East of Washington City on Telegraph Road One mile
East of the Washington County Landfill
St. George, Utah 84780
DIRECTIONS: Five miles east of Washington City on Telegraph Road. At the
intersection at the county landfill take a right and then a quick
left onto Smelter Drive. The pit is at the end of the road.

SOURCE CONTACTS: Anthony Robinson, Superintendent

Chris Rose, Records
[e-mail]

OPERATING STATUS: The crushing circuit and concrete batch plant were operating
normally. The wash plant was down for repair.

PROCESS DESCRIPTION: Western Rock Products operates an aggregate and concrete
plant. Aggregate is crushed in the lower pit and stored in piles.
Materials needed for concrete are moved to the wash plant for
cleaning. Washed material is used in the concrete batch plant.
Other aggregate materials are trucked off site.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN109070001-22, dated March
31, 2022
NSPS (Part 60) OOO: Standards of Performance for Nonmetallic
Mineral Processing Plants,
NSPS (Part 60) I: Standards of Performance for Hot Mix Asphalt
Facilities,
NESHAP (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines.,

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Western Rock Products Corporation- Sorenson Pit
89 West 13490 South Suite 100
Draper, UT 84020
Five miles East of Washington City on Telegraph
Road one mile East of the Washington County
Landfill
St. George, Utah 84780

SIC Code: 1442: (Construction Sand & Gravel)

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the
owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a
minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
Status: In Compliance. No limits appear to have been exceeded. No modifications have been
made to equipment or process. Equipment appears to be adequately maintained and operated
properly. No reportable breakdowns have occurred since the previous inspection. A 2023 emission inventory was submitted to DAQ.

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Section II: SPECIAL PROVISIONS

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

II.A.1 Sorenson Pit
II.A.2 Two (2) Jaw Crushers Capacity: 600 tons per hour (tph) Each
II.A.3 Four (4) Cone Crushers Capacity: 600 tph Each
II.A.4 Two (2) Vertical Shaft Crushers Capacity: 600 tph Each
II.A.5 Six (6) Screens Capacity: 600 tph Each
II.A.6 One (1) Hot Mix Asphalt Plant Capacity: 400 tph
II.A.7 One (1) Drum Mixer/Dryer
II.A.8 One (1) Pugmill
II.A.9 One (1) Baghouse
II.A.10 One (1) Lime Silo
II.A.11 Associated Feed Bins and Asphalt Silos
II.A.12 One (1) Concrete Batch Plant Capacity: 100 Cubic Yards/Hour
II.A.13 Three (3) Engines Capacity: 600 hp Each Fuel: Diesel Fuel
II.A.14 Miscellaneous Equipment Loaders, Dozers, Trac-hoes, Haul and Water trucks, Hot Oil Heaters and Asphalt Storage Tanks Status: In Compliance. No unapproved equipment was observed on site. The asphalt plant was removed from the site more than two years ago with no plans of moving it back. The three engines listed are not on-site. The 600 TPH crusher and 2250 hp generator are on temporary relocation (DAQC-708-24).

II.B Requirements and Limitations
II.B.1 Limitations and Procedure II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All crushers - 15% opacity B. All screens - 10% opacity
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C. All conveyor transfer points - 10% opacity
D. All baghouse emission points - 10% opacity
E. All diesel engines - 20% opacity

F. All conveyor drop points - 20% opacity
G. All other points - 20% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to
40 CFR 60, Appendix A, Method 9. [R307-401-8]
Status: In Compliance. Emissions observed during the inspection were within the set
limits. Only minimal dust was observed from the crushing circuit and haul traffic.

II.B.1.b The owner/operator shall not allow visible emissions from any fugitive dust source to exceed
20% opacity on site. [R307-401-8]

II.B.1.b.1 Opacity observations of fugitive dust from intermittent sources shall be conducted according to
40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at
15-second intervals over a six-minute period shall not apply. Six (6) points, distributed along the
length of the haul road or in the operational area, shall be chosen by the Director or the Director's
representative. For fugitive dust generated by mobile sources, visible emissions shall be
measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind
the vehicle and not less than 1/2 the height of the vehicle. The accumulated six (6) readings shall
be averaged for the compliance value. [R307-401-8]

Status: In Compliance. Emissions observed during the inspection were within the set
limits. Only minimal dust was observed from the crushing circuit and haul traffic.

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

A. 1,000,000 tons of processed aggregate material per rolling 12-month period

B. 375,000 tons of asphalt production per rolling 12-month period

C. 200,000 cubic yards of concrete production per rolling 12-month period. [R307-401-8]

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

A. Determine production with scale house records or vendor receipts

B. Record production on a daily basis

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

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

Status: In Compliance. The 12-month rolling totals for production were:

764,817 tons of processed aggregate
Zero tons of produced asphalt
56,015 cubic yards of produced concrete.

II.B.1.d The owner/operator shall not exceed 2,900 combined total hours of operation for the three 600 hp
diesel generators per rolling 12-month period. [R307-401-8]
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II.B.1.d.1 The owner/operator shall determine hours of operation by supervisor monitoring and maintaining of an operations log. [R307-401-8]

Status: Out of Compliance. The generators listed on the permit are not on site. The source has a 2250 hp generator on a temporary relocation permit (DAQC-708-24) which has
operated 2,346 hours. The source reported having accrued generator hours before the
temporary relocation was issued to DAQ. The source is working on a NOI application and will submit a KPI report when the generator is removed from the pit.

II.B.2 Fuel Requirement
II.B.2.a The owner/operator shall use natural gas, liquefied petroleum gas, or #1 through #6 fuel oil as
primary fuel in on-site equipment. The asphalt plant shall burn natural gas, liquefied petroleum gas, #1 through #6 fuel oil, or on-specification used oil as defined in R315-15, as fuel.
[R307-401-8]

Status: In Compliance. Fuel is used as outlined. The asphalt plant has not been on-site for
more than two years.

II.B.2.b The owner/operator shall only combust fuel oil or diesel that has a maximum sulfur content of
15 ppm. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.2.b.1 The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of used oil shall be either by the owner/operator's own testing or test reports from
the used oil fuel marketer. Certification of other fuels shall be either by the owner/operator's own
testing or test reports from the fuel marketer. [R307-401-8]

Status: In Compliance. Ultra-low sulfur diesel fuel is purchased through Rhinehart Oil.

II.B.2.c The owner/operator shall:

A. Provide test certification for each load of used oil fuel received. Certification shall be either

B. Record used oil fuel consumption and test reports on a daily basis

C. Keep usage and test records for all periods when the plant is in operation. [R307-401-8]

Status: Not Applicable. Used Oil was only applicable to the asphalt plant which was moved
from the site more than two years ago.

II.B.3 Asphalt Plant Baghouse Condition

II.B.3.a The owner/operator shall use a baghouse to control particulate emissions from the drum dryer.
[R307-401-8]

II.B.3.b The baghouse shall be sized to handle at least 60,000 ACFM for the existing conditions.
[R307-401-8]

II.B.3.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure differential across the baghouse. [R307-401-8]

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

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

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II.B.3.d During operation of the baghouse, the owner/operator shall maintain the static pressure differential across the baghouse between 2 and 6 inches of water column. [R307-401-8]

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

Status: Not Applicable. The asphalt plant was moved from the site more than two years ago with no plans of bringing it back.

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) OOO: Standards of Performance for Nonmetallic Mineral Processing Plants

Status: In Compliance. The source has sprays installed at the required points and performs monthly
spray inspections and maintains those records.
NSPS (Part 60) I: Standards of Performance for Hot Mix Asphalt Facilities

Status: Not Applicable. The asphalt plant was removed from the site over two years ago with no plans
to bring it back.
NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines.

Status: Out of Compliance. The 2250 hp temporary relocation engine operates on ultra-low sulfur
diesel fuel, has regular maintenance and has operated 2,346 within the 12-month period. See condition
II.B.1.d.1 for additional information.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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

Status: In Compliance. Observed emissions were within the standards set.

Stationary Sources [R307-210]

Status: In Compliance. See status for OOO.

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

Status: In Compliance. See status for ZZZZ.

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EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Western Rock Products Corporation,
Sorenson Pit. A comparison of the estimated total potential emissions (PTE) on Approval Order:
DAQE-AN109070001-22, dated March 31, 2022, is provided. PTE are supplied for supplemental
purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 19750.00
Carbon Monoxide 32.10 21.764
Nitrogen Oxides 39.14 83.441
Particulate Matter - PM10 17.49 16.663
Particulate Matter - PM2.5 17.49 7.139
Sulfur Dioxide 15.11 4.438
Volatile Organic Compounds 7.25 6.495

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 140 28
Formaldehyde (CAS #50000) 1160 36
Generic HAPs (CAS #GHAPS) 1280
Naphthalene (CAS #91203) 240 2
Toluene (CAS #108883) 1100 12

PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN109070001-22,
dated March 31, 2022, the overall status is: Out of Compliance.
Out of compliance with condition II.B.1.d.1 and ZZZZ, the
source self-reported generator hour use to DAQ, see condition
II.B.1.d.1 for additional information. No further action is
recommended at this time. The source appeared to be
adequately maintained and operated properly. The majority of
records were provided at the time of inspection with the
remainder emailed after.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal.

NSR RECOMMENDATIONS: Remove asphalt plant from the next AO modification.

ATTACHMENTS: VEO Form, Concrete Production Email.
Jared James <[e-mail]>
Air Quality Inspection
Johnson, Elliott (Staker & Parson Companies) <[e-mail]>Fri, Oct 11, 2024 at 1:23 PM
To: "[e-mail]" <[e-mail]>
Cc: "Rose, Chris (Staker & Parson Companies)" <[e-mail]>, "Cobbley, Greg (Staker & Parson
Companies)" <[e-mail]>
James,

I’m responding to your inquiry below with the following information regarding the rolling 12-month production
totals at our Sorenson Ready mix facility. This total is for September 2023 to August 2024.

As an FYI Chris Rose has replaced Christian Boudreau and will be your point of contact moving forward.
Thank you for reaching out and have a great day!

Elliott Johnson
Region Environmental Manager
Mountain West Region

CRH Americas Materials, Inc.
89 W 13490 S
Draper, UT 84020

C [phone]
E [e-mail]
10/21/24, 11:55 AM State of Utah Mail - Air Quality Inspection
https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permmsgid=msg-f:1812646735196713092&simpl=msg-f:1812646735196713092 1/3
You don't often get email from [e-mail]. Learn why this is important

www.crhamericasmaterials.com

From: Cobbley, Greg (Staker & Parson Companies) <[e-mail]>
Sent: Thursday, October 10, 2024 12:25 PM
To: Rose, Chris (Staker & Parson Companies) <[e-mail]>
Subject: FW: [EXT] Fwd: Air Quality Inspecon

Chris,

This was emailed to the plant closer out to Sorenson. Can you help out with this.

Thanks

From: Andy Swearingen <[e-mail]>
Sent: Thursday, October 10, 2024 12:20 PM
To: Cobbley, Greg (Staker & Parson Companies) <[e-mail]>
Subject: [EXT] Fwd: Air Quality Inspecon

CAUTION: This email originated from outside of the organizaon. Do not click links or open aachments unless you are
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Report Phish buon.

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Begin forwarded message:
From: Jared James <[e-mail]>
Date: October 10, 2024 at 10:41:21 AM MDT
To: [e-mail]
Subject: Air Quality Inspection
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