DAQ-2025-000479

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-041-25
Site ID 10639 (B1)

Tyler Hodson
Kilgore Companies, LLC
7057 West 2100 South
West Valley City, UT 84128

Dear Mr. Hodson:

Re: Kilgore Companies, LLC – Temporary Relocation/Operation, Notice of Intent – San Juan
County

Your Notice of Intent dated October 18, 2024, to relocate portable aggregate and asphalt equipment to
the temporary project for the old Legrand Johnson site, located from southbound Highway 191, then
east off West Trout Trail Road, near Moab, UT was received by the Utah Division of Air Quality
(DAQ) and has been reviewed.

The following equipment has been approved for operation for this temporary project:

Cedarapids jaw crusher
Cedarapids cone crusher
Cedarapids triple deck screen
Caterpillar 750 kW generator
Isuzu 100 kW generator
Cedarapids E400P drum mix asphalt plant
Caterpillar 750 kW generator
Cedarapids HMA burner

The referenced equipment has been permitted for operation in the State of Utah by the Kilgore
Contracting, LLC, portable Approval Order (AO) DAQE-AN129310019-18, dated April 12, 2018.
The above location is a permitted facility with established equipment hours of operation and
production limits. All equipment operating at this site must be in accordance with the current AO for
this site DAQE-AN106390008-14, dated May 27, 2014, as cited below:

The production of aggregate and hours of operation from the temporary equipment when combined
with the permanent equipment totals cannot exceed the 12-month rolling limit of 700,000 tons, or 10
hours of operation as per Conditions II.B.1.b.A and II.B.1.b.B.
+ 2 / 6 Ú à Û Ù Û Þ
DAQC-041-25
Page 2

The 750 kW generator used for the aggregate production shall be restricted to 2,800 hours as per
Condition II.B.7.a.B. The 100 kW generator shall be restricted to 3,276 hours of operation as per
Condition II.B.7.a.C. The 750 kW generator used for the drum mix asphalt plant shall be restricted to
1,500 hours of operation as per II.B.7.a.A.

As per Condition II.B.8.g., the production of asphalt and hours of the asphalt plant operation cannot
exceed 600,000 tons per rolling 12-month period and the asphalt plant cannot exceed 10 hours per day
from March 1 through November 30. The asphalt plant shall cease operations during the months of
December, January, and February. The asphalt plant operating at this location must have tested within
the last five years or have the ability to test within 180 days after the start up at this location. If a stack
test will be performed at this location, a stack testing protocol shall be submitted to the DAQ at least
30 days prior to performing the test. Testing shall be at no less than 90% of the production rate
achieved to date. If the test is passed, the new maximum allowable production rate shall be 110% of
the tested achieved rate. This new maximum allowable production rate shall be less than 90% of the
allowed maximum production rate. This new allowable maximum production rate shall remain in
effect until successfully tested at a higher rate.

Approval is granted to relocate and operate this equipment at the new location for a period not to
exceed 180 operational days. As per Utah Administrative Code (UAC) R307-401-17, the operation of
equipment at this temporary site may be for up to 180 working days in any calendar year not to exceed
365 consecutive days, starting from the initial relocation date. The operational days per site cannot be
extended beyond the stipulated 365 consecutive day period. A new Notice of Intent to permit this
equipment and update the current AO for this location will be submitted to the DAQ prior to the end
of this relocation period.

The owner/operator shall maintain records of the actual operation hours, days, and production rate of
the above referenced equipment at this relocation site and have the ability to submit the information to
the DAQ upon the request of representatives of the Director. Please make certain that the plant
operator is aware of all the location specific requirements for this site and the conditions of the
aforementioned AO.

Federal New Source Performance Standards Subpart OOO requires that initial Method 9 observations
be performed for all applicable portable crushers, screens, and attached conveyors. Subpart OOO also
mandates that all crushers constructed, modified, or reconstructed on or after April 22, 2008, which
are not enclosed, must install spray bars on the equipment and keep maintenance records to ensure
proper spray bar operations.

Utah Division of Water Quality Storm Water Permits and regulations may apply to this temporary
project. Please refer to Utah DEQ Water Quality’s current Storm Water Construction requirements for
additional information.

This approval for relocation in no way releases the owner or operator from any liability for compliance
with all other applicable federal, state, and local regulations including the UAC.

DAQC-041-25
Page 3

If you have any questions regarding this relocation authorization or the temporary relocation process
please contact Susan Weisenberg at [phone].

Sincerely,

Jay P. Morris
Assistant Director

JPM:SPW:jl

Enclosure: Submitted Temporary Relocation Form

cc: Southeast Utah Health Department
4 * - - $ . — ) @ D v A ? A D @ E w @ B ˜
Susan Weisenberg <[e-mail]>
Portable/Temporary Relocation Form
1 message
[e-mail] <[e-mail]>Fri, Oct 18, 2024 at 1:57 PM
Reply-To: [e-mail]
To: [e-mail]
Susan/Chad:
Site # -- Kilgore Companies has requested a Temporary Relocation. Please see the information below. Any attachments
can be access by clicking on the links.

Recipient Data:
Time Finished: 2024-10-18 13:57:01 MDT
IP: 165.225.11.1
ResponseID: R_65fxlVZlzog5i93
Link to View Results: Click Here
URL to View Results: https://utahgov.iad1.qualtrics.com/apps/single-response-reports/reports/
hD2RnusmxWEegVWxlvPyIXRpXHUGKrvr8w-GRmNI-tbc5cOXR-21Xyx302rSdgclXzT1jLWpNt1YnXMm
TZF7113Wr4sYQP6s-qKBDeLAbS4-uEIBUF1bnoPv6VGH5Vjlw2iqWFoOI4LtBg9mtN5MMqrJcJMxg580sxX3gQLb
j9rkBzDCpJb6EQUlK0HKKkZidVc0P32CpdMdUudoSriMWsUplg1kKxXmL68Z%2Etu2euZJG6QeIrEj9TnuewuserGgV0x-
uZeEe4Xxyt-BGbC8rPShf5pv2zZNVAAfzqCL4T2eg2qTO7ImpbEvwHQfTasjy4ukErPRiLSNXywWFl7Adg
Response Summary:
Please fill out the information below:
Contact Person: Tyler Hodson
Company Name: Kilgore Companies
Mailing Address: 7057 W 2100 S
City: West Valley City
Zip: 84128
Phone Number: 3852283653
Email: [e-mail]
Is the site located within a PM2.5 non-attainment and maintenance plan areas on cleared land grea...
No
All temporary relocation projects are required to submit a Fugitive Dust Control Plan (FDCP). Lo...
D20EDF16FD
Briefly give directions to the site and/or physical address:
Heading south from Moab city along highway 191 turn east onto West trout trail road. Proceed 1/2 mile along W trout
trail then turn south to drive onto site.
Proposed Relocation Information:
Closest City Moab
County San Juan
UTM X Coordinates 635460.15 m E
UTM Y Coordinates 4259646.36 m N
Approximate distance to the nearest house/business 1300 feet
UTM X Coordinates to nearest house/business 634980.46 m E
UTM Y Coordinates to nearest house/business 4259790.51 m N
Does this site currently have a permit with DAQ?
10/28/24, 2:55 PM State of Utah Mail - Portable/Temporary Relocation Form
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1813283004359711249%7Cmsg-f:1813283004359711249&s…1/3
No
Please provide the permit ID for the equipment? (DAQE-XXXXXXXXX-XX)
DAQE-AN129310019-18
Please list all the Equipment on Site:Note: It is important to identify ALL diesel powered engine...
1
Equipment Type Jaw Crusher
Make/Model Cedar Rapids 2450
Serial or ID# 0460
Manufactured Date 2016
Design Capacity 500 tph
2
Equipment Type Cone Crusher
Make/Model Cedarapids MV550X
Serial or ID# TRX550KOKGF0870
Manufactured Date 2016
Design Capacity 500 tph
3
Equipment Type Triple Deck Screen
Make/Model Cedar Rapids T6203
Serial or ID# TRXV6203KDUGD2249
Manufactured Date 2016
Design Capacity 500 tph
4
Equipment Type Triple Deck Screen
Make/Model Cedarapids 6203
Serial or ID# P62032406
Manufactured Date 2007
Design Capacity 500 tph
5
Equipment Type Generator
Make/Model Caterpillar C27
Serial or ID# TAZ00307
Manufactured Date 2013
Design Capacity 750 kW
6
Equipment Type Generator
Make/Model Isuzu
Serial or ID# 7510986
Manufactured Date 2013
Design Capacity 100 kW
7
Equipment Type Drum mix asphalt plant
Make/Model Cedarapids E400P
Serial or ID# CX2109
Manufactured Date 1996
Design Capacity 400 tph
8
Equipment Type Generator
Make/Model Caterpillar C27
Manufactured Date 2013
Design Capacity 750 kW
9
Equipment Type Generator
Make/Model Caterpillar C27
Manufactured Date 2013
Design Capacity 750 kW
10
Equipment Type HMA Burner
Make/Model Cedarapids 130
Serial or ID# DA-130-100
Manufactured Date 1996
Design Capacity 100 MMBtu
10/28/24, 2:55 PM State of Utah Mail - Portable/Temporary Relocation Form
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1813283004359711249%7Cmsg-f:1813283004359711249&s…2/3
Please attach a site diagram showing the equipment layout and general site dimensions for this re...
https://utahgov.co1.qualtrics.com/WRQualtricsControlPanel/File.php?F=F_1IaVhsI8PEnWlj6
Have any other state or local regulatory agencies issued any other "Conditional Use Permits" for...
No
Operational Information: (Please note: Operating time over 16 hours in a 24 hour period will re...
Total Hours of operation per 24 hr period 18
Starting time of operation (am/pm) 4 am
Ending time of operation (am/pm) 10 pm
Maximum hourly production rate for project 1000 tph
Expected startup date 10/25/2024
Expected completion date 10/25/2025
What type of application is this for?
New Application
In accordance with the fee schedule approved by the Utah State Legislature, the Division of Air Q...
https://utahgov.co1.qualtrics.com/WRQualtricsControlPanel/File.php?F=F_2s55EJBxpnkYGVz
Owner/Operator Representative:
https://utahgov.co1.qualtrics.com/WRQualtricsControlPanel/File.php?F=F_1kIfNPBaRDUpu7H
10/28/24, 2:55 PM State of Utah Mail - Portable/Temporary Relocation Form
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1813283004359711249%7Cmsg-f:1813283004359711249&s…3/3
Susan Weisenberg <[e-mail]>
RE: proposed Moab relocation
1 message
Tyler Hodson <[e-mail]>Fri, Nov 1, 2024 at 2:53 PM
To: Alan Humpherys <[e-mail]>
Cc: Susan Weisenberg <[e-mail]>, Chad Gilgen <[e-mail]>, Bryan Jorgensen
<[e-mail]>
Hello Alan,

Thank you for this clarification. We were not aware of the 3-mile radius stipulation and so that will be very
helpful in the NOI that is currently in process for the Moab site.

The reason I am writing to you is in reference to the following statement: “Since the AO only has one asphalt
plant, they couldn't operate an asphalt plant at the pit and the Airport Road address at the same time”

I am attaching a permit dated October 12, 1993 (DAQE-0908-93). It is for a Stansteel Model RM-200 Hot
Mix Asphalt with an address of 5101 East Old Airport Road, Moab, Utah. It is our understanding that this AO
is current and has never been superseded by any other AO, and was active at the time the 2014 permit was
modeled. There is also another permit dated July 13, 1994 (DAQE-560-94) for a Concrete Plant at the same
address, 5101 East Old Airport Road. I will attach that permit also.

We fully intend to submit an NOI for the crushing and asphalt equipment at the Trust Lands Site soon, but
just wanted to make sure we’re all on the same page.

Thank you,

Tyler Hodson
Administrative Environmental Manager
[phone]
[e-mail]

11/19/24, 1:18 PM State of Utah Mail - RE: proposed Moab relocation
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-3436151581266553021%7Cmsg-f:1814554950655914880…1/3
From: Susan Weisenberg <[e-mail]>
Sent: Wednesday, October 30, 2024 10:52 AM
To: Tyler Hodson <[e-mail]>
Cc: Alan Humpherys <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: proposed Moab relocaon

Hello, your proposed relocation to the Moab site has been reviewed by the NSR Minor Source Section Manager, Alan
Humpherys. As discussed during this morning's phone conversation, this TRP currently appears to be covered by an
existing AO originally issued to Legrand Johnson. In addition to the below requirements stated by Alan, it is important to
emphasize that only one asphalt plant may operate within this modeled area at any one time. The asphalt plant located on
Old Airport Road site cannot be operating if the proposed relocated Cedarapids plant is operating.

"It looks like this site is part of 10639. Back in 2014, the site was modeled with equipment operating in this location
instead of the location on Airport Road. The source should be able to comply with the AO that was issued for this site,
DAQE-AN106390008-14. The requirements of this site based on the model should include the following:
· Aggregate operations shall not exceed 10 hours per day.
· Aggregate production shall not be more than 400 tons per hour (4,000 tons per day)
· Asphalt production shall not exceed 10 hours per day, except asphalt shall not be produced during the
months of December, January, or February.
· Asphalt production shall not be more than 400 tons per hour (4,000 tons per day)".
With regards to the stated address on the above referenced AO:

"the UTM Coordinates on pages 21-23 of our modeling memo. In addition, if you look at the site layout on page 47 (the
source's modeling analysis), it shows that the site is the same one that the source is requesting to relocate at.

If you look at previously issued AO's, the abstract indicates that the source was allowed to operate any pit within a 3-mile
radius of the Airport Road address. I am not sure why that was removed with the 2014 AO, but I'm guessing that it was
assumed that operations would be at the location indicated instead of the Airport Road address. Because the old AOs
covered both locations, it was assumed that they could operate at either. Since the AO only has one asphalt plant, they
couldn't operate an asphalt plant at the pit and the Airport Road address at the same time (along with the other
equipment). I'm not sure what the source has at the Airport Road address. It would probably be good for the source to
submit a NOI for both locations so we can clear this up."

Given the above situation - Kilgore Companies may proceed with the submitted relocation with the first paragraph's
operation restrictions if:

1 - a stack test for this specific Cedarapids asphalt plant has occurred, or will be scheduled within the relocation period.
2. - a new NOI for this area that includes both the existing Old Airport Road and the proposed relocation site's actual
equipment and operation.
3. - Only one asphalt plant can operate within this area.

Please contact Alan Humpherys if you have additional information or if you have any questions. Thanks.

11/19/24, 1:18 PM State of Utah Mail - RE: proposed Moab relocation
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-3436151581266553021%7Cmsg-f:1814554950655914880…2/3
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

2 attachments
E-560-94 Concrete Batch AO.pdf
147K
E-0908-9 Asphalt Plant AO.pdf
63K
11/19/24, 1:18 PM State of Utah Mail - RE: proposed Moab relocation
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-3436151581266553021%7Cmsg-f:1814554950655914880…3/3
Susan Weisenberg <[e-mail]>
Re: draft for Kilgore TRP to Moab
1 message
Daniel Riddle <[e-mail]>Wed, Jan 15, 2025 at 10:01 AM
To: Chad Gilgen <[e-mail]>
Cc: Susan Weisenberg <[e-mail]>
Susan - yes, from what I understand you can issue this TRP as is.
On Tue, Jan 14, 2025 at 1:48 PM Chad Gilgen <[e-mail]> wrote:
Hi Susan,
I thought everything was good with this one.
Daniel - Can you please let us know your thoughts on if this one, based on the equipment lists you have reviewed, is
OK to proceed with getting a Temporary Relocation letter?
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Fri, Jan 10, 2025 at 11:00 AM Susan Weisenberg <[e-mail]> wrote:
I apologise for still not being certain where the Temporary relocation stands for this - should I issue the most recent
TRP draft as a final or am I waiting for a new equipment list with the corrected AO references?

Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
On Fri, Jan 10, 2025 at 10:17 AM Chad Gilgen <[e-mail]> wrote:
Hi Daniel,
That sounds good. I think we also determined how to address the ESA during our meeting on Wednesday. Let me
know if we need to discuss any further.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
1/15/25, 10:47 AM State of Utah Mail - Re: draft for Kilgore TRP to Moab
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-4642420861317160609%7Cmsg-f:1821335111252474025…1/3
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Mon, Jan 6, 2025 at 10:52 AM Daniel Riddle <[e-mail]> wrote:
I just sent a message asking for further clarification on this from Bryan, but I think they are struggling with this as
much as we are. The items on the TRP vs the items on the AO vs the items in the three
Chad - can I issue a more generic ESA to close out this compliance action and memo so that we can move
forward? We can ask Kilgore to have the 2 AOs for this site completed (or at the very least NOIs submitted and
new AOs in progress) by the time this site is inspected again, and I'll tell Jordan about the way this site is moving
forward before he inspects them this year.
On Mon, Dec 30, 2024 at 2:30 PM Susan Weisenberg <[e-mail]> wrote:
Thanks - everything going on with this site - and with temporary relocations in general can be confusing. I
thought I had taken the equipment list referenced on the relocation letter from the initial electronically
submitted request which I thought had indicated that the equipment had come from the generic list on their
portable AO. Did they ask for additional equipment?
Just as background, usually, when a company is requesting a "temporary" operation at a permanent site, I try
to match up the permanent site's operating conditions, rather than the existing equipment. That only works
however, when there's an apple to apple comparison. For example, a new asphalt plant would have to operate
in the same way, with the same production rate and hours as the permanent site's modeled plant. The same
considerations are given to aggregate equipment. The number of crushers in these cases do not necessarily
have to be the same in number, provided that the total equipment does not exceed the production limit, or
otherwise create a situation that indicates that the permanent site's modeled emissions will be exceeded.
Generators are always difficult to get a good emissions match. Chad, can you take a look at the conditions I
referenced for the generators to see if we can allow the TRP using this language? Unfortunately, I think back
in 2014, we didn't always permit fuel tanks. I'm not certain if this is an issue for this operation. Thanks! Let me
know if anyone needs more information. A lot of time has passed since we first started analyzing this project. I
may have forgotten certain details.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
On Mon, Dec 30, 2024 at 10:37 AM Daniel Riddle <[e-mail]> wrote:
Thanks for sending this Susan. While waiting for a response from Bryan in the other thread, I have
compared equipment lists. The document they sent us had three tables. All of the equipment in Table 3 is
permitted under the 2014 AO. It appears that this TRP covers much of the equipment in Table 1 - including
the jaw crusher, the cone crusher, the triple deck screen, and the HMA plant. However, when comparing the
2 lists, it seems that the VSI crusher, HSI crusher, 3 725 kW generators, 80 kW backup generator, and 125
kW generator all listed from Table 1 are not permitted on any AO nor on this TRP. Additionally, storage
tanks in Tables 1 & 2 are not on any permits or TRP.
Chad - for the ESA, should I include all of the pieces of equipment as individual "events"? Or is there a
simpler way to group everything together? With all the old permits and lists, I feel that it might be easiest to
issue a more generic ESA with the expectation that they should strive to have the 2 new AOs for the sites
with equipment lists accurate within a time frame of one year.
Sorry if my message here is somewhat confusing. It's been difficult to determine what equipment is
compliant and what isn't at this site.
On Thu, Dec 26, 2024 at 11:00 AM Susan Weisenberg <[e-mail]> wrote:
1/15/25, 10:47 AM State of Utah Mail - Re: draft for Kilgore TRP to Moab
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-4642420861317160609%7Cmsg-f:1821335111252474025…2/3
I see that Kilgore has submitted a list of their current AOs for the Moab area as requested. Back in
November, I submitted a draft TRP for this requested relocation. It appears that the relocation should still
reference the AN106390008-14 AO as the regulating permit as originally suggested by Alan Humpherys.
Can you review the attached draft Moab relocation and supporting documents? Please let me know if one
of their other AOs is a better fit, or what other edits need to be made. I believe that the relocated asphalt
plant will still need to stack test. Thanks.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
---------- Forwarded message ---------
From: Susan Weisenberg <[e-mail]>
Date: Tue, Nov 19, 2024 at 5:11 PM
Subject: draft for Kilgore TRP to Moab
To: Chad Gilgen <[e-mail]>
See the enclosed draft for the Kilgore Moab TRP. This relocation may not provide Kilgore with what they
were looking for as Condition II.B.8.g of the 2014 AO prohibits the operation of an asphalt plant during the
winter months of December, January, and February. I cited this restriction on the first paragraph of page
two. All other specific equipment restrictions are also referenced. Let me know what edits need to occur or
if a different approach is necessary. Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
1/15/25, 10:47 AM State of Utah Mail - Re: draft for Kilgore TRP to Moab
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-4642420861317160609%7Cmsg-f:1821335111252474025…3/3