DAQ-2025-000572

STAKER PARSON
MATERIALS & CONSTRUCTION
A CRH COMPANY
BURDICK
MATERIALS
A CRH COMPANY

HALES
SAND & GRAVEL
A CRH COMPANY

IDAHO MATERIALS
& CONSTRUCTION

JACK B. PARSON
READY MIX CONCRETE
A CRH COMPANY
NIELSON
CONSTRUCTION & MATERIALS

REYNOLDS EXCAVATION
DEMOLITION & UTILITIES
A.CRHCOMPANY

STAKER PARSON
LANDSCAPE CENTERS

WESTERN ROCK
PRODUCTS

The Preferred Source
SAND A ROCK A LANDSCAPE PRODUCTS A READY MIX CONCRETE A ASPHALT A PAVING A CONSTRUCT ION SERVICES
Christopher Rose
Staker Parson Companies
Environmental Specialist
89 West 13490 South, Suite 100
Draper, Utah 84020

12/15/24

Chad Gilgen
Utah Department of Environmental Quality- Division of Air Quality
Manager- Minor Source Compliance Section

Re: Compliance Advisory Response – Staker Parson Companies dba Western Rock Products,
Approval Order (AO) DAQE-AN102780003-19, Iron County

Dear Mr. Gilgen,

This letter is a response to Compliance Advisory DAQC-1192-24 for site 10278 which was received
on Monday, December 9th, 2024. Staker Parson Companies acknowledges some deficiencies to
conditions I.2, II.B.2.b, II.B.2.b.1, II.B.3.b, II.B.3.b.1 and II.B.4.a recorded as part of the DAQ’s
inspection on June 4th, 2024.

Staker Parson Companies requests that UDAQ considers the attached operations log for aggregate
processing starting November 1st, 2024 as proof of compliance to conditions II.B.2.b and II.B.2.b.1 in
response to the UDAQ inspection this past summer. Actual equipment operation times are listed in the
third and fourth columns.

Staker Parson Companies understands that proof of compliance to conditions II.B.2.b and II.B.3.b is
dependent on proper documentation of operation schedules. Any documentation deficiencies as part
of conditions II.B.2.b.1 and II.B.3.b.1 may carry suspicion of non-compliance to seasonal scheduling
limitations.

Due to recent turnover on Staker Parson Companies’ environmental team, no environmental
employees were aware of any recordkeeping deficiencies at Western Rock Products’ Cedar City site
until the response to the inspection. As a result, Staker Parson environmental created a full
recordkeeping log and AO quick reference guide for operators and managers of the Cedar City site.
These guides were distributed on July 11th, 2024 in response to suspected recordkeeping deficiencies.
A representative from Staker Parson Environmental has since been in regular communication with
Cedar City employees to ensure ongoing permit compliance.

Deficiencies to condition II.B.4.a are understood and Staker Parson Companies will amend AO
DAQE-AN102780003-19 to address any issues in a timely manner. A reasonable timeline for
compliance would be to have an updated AO in hand in 12 months’ time. Staker Parson Companies
would likely utilize the expertise of Trinity Consulting to amend the AO, and any timeline for
compliance would vary based on the workload of Trinity’s modeling team.

Staker Parson Companies strives to remain compliant to any and all state and federal regulations.
UDEQ inspections are welcomed as a way to improve our stewardship to the environment and our
community.

Sincerely,

Christopher Rose
(C): [phone]
[e-mail]
REVIEWED
Initials: DDR Date: 29.Jan.2025
Compliance status: response to CA
File#: 10278