DAQ-2025-000969

1
DAQC-CI155530002-25
Site ID 15553 (B1)

MEMORANDUM

TO: FILE – RULON HARPER CONSTRUCTION, INC. – Pit No. 12

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: January 16, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Tooele County

INSPECTION DATE: May 25, 2023

SOURCE LOCATION: S11 T4S R5W
Tooele County, UT

DIRECTIONS: Take 1-80 westbound to Exit 99 to State Highway 36 past
Stansbury. Remain on 36 until Bauer Road. The pit is north west
of the Tooele County landfill. The site is marked with a Rulon
Harper Pit #12 sign.

SOURCE CONTACTS: Carlos Almarol, Site Foreman

Dennis Sortor, Risk Manager
801-326-1016, [e-mail]

OPERATING STATUS: Operating.

PROCESS DESCRIPTION: Rulon Harper operates an aggregate processing plant that
includes crushing, screening, washing, and hauling. Material is
pulled from surrounding banks, processed, and then sorted into
various storage piles. The equipment is powered by two
generators. A watering truck is stationed on site.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN155530001-16, dated
April 14, 2016

NSPS (Part 60) IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
NSPS (Part 60) OOO: Standards of Performance for Nonmetallic
Mineral Processing Plants,
NESHAP (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines.

0 . ) $ . ) - "
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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Rulon Harper Construction, Inc.
Pit No. 12

8201 West 5400 South S11 T4S R5W
Salt Lake City, UT 84118 Tooele County, UT

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: Out of Compliance. On the day of this inspection, Rulon Harper's site operator
discussed a possible discrepancy with the 100-kW generator and a recently added 400-kW
generator. One crusher and one screen that were not listed on the current AO were
observed on site, but not operating. The haul road exceeded the established length as per
Condition II.B.3.d. These issues were resolved with a combined ESA dated January 7, 2025
(C-1255-24). No further action is required at this time. No applicable breakdowns are on
record. Emission Inventories are submitted as required. The most recent Inventory for the
2023 activity year was submitted following this inspection and is attached to this memo.
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Section II: SPECIAL PROVISIONS

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

II.A.1 Rulon Harper Construction, Inc. - Pit No. 12

II.A.2 One (1) Jaw Crusher
Capacity: 400 tph
Manufacture Date: 2012
NSPS Applicable: Subpart OOO

II.A.3 One (1) Cone Crusher
Capacity: 400 tph
Manufacture Date: 2012
NSPS Applicable: Subpart OOO

II.A.4 One (1) Triple Deck Screen
Size: 8'x20'
Capacity: 400 tph
Manufacture Date: 2011
NSPS Applicable: Subpart OOO

II.A.5 One (1) Wash Plant
Size: 8'x20'
Capacity: 400 tph
Fuel: Diesel
Manufacture Date: 2012
NSPS Applicable: Subpart OOO

II.A.6 Various Conveyors and Stackers

II.A.7 Generator
Rating: 400 KW (approximately 536 hp)
Fuel: Diesel Fuel
Manufacture Date: 2013
NSPS Applicable: Subpart IIII
MACT Applicable: Subpart ZZZZ

II.A.8 Generator
Rating: 100 KW (approximately 134 hp)
Fuel: Diesel Fuel
Manufacture Date: 2014
NSPS Applicable: Subpart IIII
MACT Applicable: Subpart ZZZZ

Status: Out of Compliance. The listed equipment was present with the following exceptions:
The 100-kW generator described by II.A.8 had reportedly been replaced by a second
400-kW generator. Two additional crushers not listed on this AO were situated next
to the existing circuit line, but were not operating. The issue of the non-permitted
equipment was documented by a Compliance Advisory (CA), DAQC-618-23, dated
June 27, 2023. This CA was resolved by a combined joint Early Settlement
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Agreement (DAQC-1196-24) dated December 3, 2024. No further action is required
at this time.

II.B Requirements and Limitations

II.B.1 Site-Wide Limitations and Requirement

II.B.1.a The owner/operator shall notify the Director in writing when the equipment listed in this AO has
been installed and is operational. To ensure proper credit when notifying the Director, send your
correspondence to the Director, attn: Compliance Section.

If the owner/operator has not notified the Director in writing within 18 months from the date of
this AO on the status of the construction and/or installation, the Director shall require
documentation of the continuous construction and/or installation of the operation. If a
continuous program of construction and/or installation is not proceeding, the Director may
revoke the AO. [R307-401-18]

Status: In Compliance. Dennis Sortor emailed a notification on November 22, 2019. See the
inspector memo DAQC-545-21 for more information.

II.B.1.b The following production limits shall not be exceeded:

A. 850,000 tons of processed aggregate, asphalt, and concrete products per
rolling 12-month period

B. 4,000 hours of plant operation per rolling 12-month period.

C. From March 22 to December 20 each year, the owner/operator shall not
operate more than 10 hours per day and six days a week.

D. From December 21 to March 21, the owner/operator shall not operate
more than 8 hours per day, five days a week. [R307-401-8]

Status: In Compliance. The rolling 12-month aggregate production totals for the time
period of May 2022 through April 2023 were reported as follows:

A. 426,193.92 tons of processed aggregate were produced. No asphalt or concrete
equipment are on site.

B. Plant equipment operation periods are derived from the generator hours and were
reported as 1,329 hours for the equipment running from the 400-kW generator.
251 hours were reported for the 100-kW generator for a total of 1,580 hours,
assuming that the generators were not operated simultaneously.

C. Daily operation totals are also derived from the generator operation logs. The week
totals are recorded for all periods that the equipment operated. For the seasonal
period of March 22 to December 20, the highest recorded weekly totals were 42
hours for the 400-kW generator which occurred on the week beginning on August
20 and the week beginning on December 10 which resulted in a daily average of 8.4
hours. The use of the 100-kW generator for the same weeks were reported as 9
5
hours for the week beginning on August 20 and 6 hours for the week beginning
December 20, resulting in an average daily use of 1.8 hours and 1.2 hours,
respectively.

D. For the seasonal period of December 21 to March 21, the highest number of 400-
kW generator hours were reported as 38 for the week beginning on December 24,
resulting in a daily average of 7.6 hours. The 100-kW generator was operated for a
total of 5 hours, with a daily operation average of 1 hour for the same week.

II.B.1.b.1 To determine compliance with 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. Production
shall be determined by belt scale records or vendor receipts. 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. [R307-401-8]

Status: In Compliance. Totals are recorded each month and the previous month's totals
are available by the 20th day of each month.

II.B.1.c Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any stationary source on site to exceed 20 percent opacity. [R307-401-8]

Status: In Compliance. Only the wash plant was operating during the time of this
inspection. No significant dust was observed from any other point including the generators.
See the attached VEO.

II.B.1.c.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources
shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-309-5]

II.B.2 All Aggregate Processing Equipment on site shall be subject to the following

II.B.2.a The owner/operator shall not allow visible emissions from any crusher on site to exceed 12
percent opacity on site and 10% at the property boundary. [R307-312]

Status: Not Observed. The crusher was down for repairs. Only the wash plant was
operating during this inspection.

II.B.2.b The owner/operator shall not allow visible emissions from any screen on site to exceed 7 percent
opacity. [R307-312]

Status: Not Observed. Only the wash plant screen was operating during this inspection.
The permitted triple screen was not being used due to the connected crusher being down
for repairs.

II.B.2.c The owner/operator shall not allow visible emissions from any conveyor transfer point subject on
site to exceed 7 percent opacity. [R307-312]

Status: In Compliance. Only the conveyor transfer points connected to the wet processing
of the wash plant were operating. No visible emissions were observed from these transfer
points.

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II.B.2.d The owner/operator shall not allow visible emissions from any conveyor drop point on site to
exceed 20 percent opacity. [R307-309]

Status: In Compliance. Conveyor drop points were connected to the wash plant and were
observed operating without visible emissions.

II.B.2.e The owner/operator shall install water sprays on all crushers, all screens, and all unenclosed
conveyor transfer points on site to control fugitive emissions. Sprays shall operate as required to
ensure the opacity limits listed in this AO are not exceeded. [R307-401-8]

Status: In Compliance. The plant foreman provided a tour of the equipment. Water sprays
appeared to have been installed at all the appropriate aggregate processing points.

II.B.2.f The owner/operator shall conduct an initial performance test for all crushers, screens, and
conveyor transfer points on site. Performance tests shall meet the limitations specified in Table 3
to Subpart OOO. [ 40 CFR 60 Subpart OOO]

Status: In Compliance. Initial Method 9 performance observations were performed on the
equipment on December 10, 2019, and March 9, 2020. See the previous inspection memos
DAQC-545-21 and DAQC-799-22 for more information.

II.B.2.f.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner or operator may use methods and procedures specified in 40 CFR
60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c).
[ 40 CFR 60 Subpart OOO]

Status: In Compliance. The initial performance observations were reviewed and appear to
be compliant with Subpart OOO requirements. Copies of the March 9, 2020, observation
form are attached to the memos DAQC-545-21 and DAQC-799-22.

II.B.3 All Fugitive Dust Sources, including haul roads and operational areas, on site shall be
subject to the following

II.B.3.a The owner/operator shall comply with a FDCP acceptable to the Director for control of all dust
sources associated with this site. The owner/operator shall submit a FDCP to the Director,
attention: Compliance Section, for approval within 30 days of the date of this AO. [R307-309-6]

Status: In Compliance. A Fugitive Dust Control Plan was submitted to the DAQ on
November 4, 2015. See memo DAQC-799-22 for more information.

II.B.3.b Visible fugitive dust emissions, including visible dust emissions from haul-road traffic and
mobile equipment in operational areas, shall not exceed 20% opacity on site and 10% opacity at
the property boundary. [R307-309-5]

Status: In Compliance. No significant emissions were observed from the haul-road traffic
or the operation areas. A watering truck was observed operating throughout the site
during the inspection.

II.B.3.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile
equipment in operational areas shall use procedures similar to Method 9. The normal
requirement for observations to be made at 15-second intervals over a six-minute period,
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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. [R307-309-5]

Status: In Compliance. No significant visible emissions were observed. The observations
performed were consistent with Method 9 requirements.

II.B.3.c 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 emissions unless the
temperature is below freezing. Treatment shall be of sufficient frequency and quantity to meet
the opacity limit above. If chemical treatment is to be used, the plan must be approved by the
Director. [R307-401-8]

Status: In Compliance. A watering truck is present at all times of the plant operation. A
watering tank has been permanently installed. Application of all areas, including the roads
and operation areas, occur with each application. No opacities were observed from the
referenced areas at the time of this inspection.

II.B.3.c.1 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 of treatment

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 was below freezing. [R307-401-8]

Status: In Compliance. Daily watering records are kept in a log in the watering truck and
were reviewed during the inspection. The log is then entered as weekly applications on a
spreadsheet. The spreadsheet includes weekly dates, application amounts, and weather
comments. Additional watering records were emailed following the inspection. See the
attached watering log.

II.B.3.d The haul road shall not exceed 900 feet in length. [R307-401-8]

Status: Out of Compliance. The haul road, starting from the point of entry to this pit to the
installed permitted aggregate processing equipment, exceeded 900 feet. A Notice of Intent
consultation with Minor Source NSR has been required to obtain an accurate haul road
length distance. The haul road length will be addressed on the next modified AO to be
issued in 2025. No additional compliance action is recommended at this time.

II.B.4 Limitations and Requirements on the 400 kw and 100 kw Generator Engines

II.B.4.a The 400-kW diesel generator shall not exceed 4,000 hours of operation per rolling 12-month
period. [R307-401-8]

Status: In Compliance. 1,329 hours were reported for the 400-kW generator for the time
period of May 7, 2022, through April 29, 2023.
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II.B.4.a.1 To determine compliance with 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.
Hours of operation shall be determined by supervisor monitoring and maintaining of an
operations log. [R307-401-8]

Status: In Compliance. The rolling 12-month totals are derived from an operation log for
all weeks that the generators are operated. See the attached Weekly Hours of Operation
Report.

II.B.4.b The 100-kW diesel generator shall not exceed 500 hours of operation per rolling 12-month
period. [R307-401-8]

Status: Out of Compliance. The total hours of operation reported for the 100-kW
generator for the 12-month rolling time period was recorded as 251. While this reported
number is within the established limit, there was a question regarding if the 100-kW
generator had been operating for the full time period reported. The plant manager at the
time of this inspection reported that the 100-kW generator had recently been replaced with
an additional 400-kW generator. The discrepancy regarding the generator size was
addressed on the Compliance Advisory dated June 27, 2023 (DAQC-618-23). The existing
generator discrepancy was also noted on an additional inspection conducted on July 18,
2024, and documented on a Compliance Advisory dated August 23, 2024. Both issues of
generator size non-compliance were resolved with the ESA dated December 3, 2024
(DAQC-1196-24). See the attached weekly generator operation log.

II.B.4.b.1 To determine compliance with 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
Hours of operation shall be determined by supervisor monitoring and maintaining of an
operations log. [R307-401-8]

Status: Out of Compliance. See the above description of the question of the size of the
generator installed during the full reporting period.

II.B.4.c Visible emissions from the generator engine stacks shall not exceed 20% opacity. [R307-401-8]

Status: In Compliance. No visible emissions were observed from the generator stacks
during this inspection.

II.B.4.d The sulfur content of any diesel burned shall not exceed 15 ppm by weight. [40 CFR 63 Subpart
ZZZZ, R307-401-8]

Status: In Compliance. Invoices are present on site. Rhinehart Oil certifies their product
as ULSD that meets the federal standards for sulfur.

II.B.4.d.1 The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of fuels shall be either by owner/operator's own testing or test reports from the fuel
marketer. [R307-401-8]

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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) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines.

Status: In Compliance. The emissions for the two non-emergency engines are restricted by the 12-
month rolling total hour of operation limits of II.B.4.a and II.B.4.b. Maintenance is routinely performed
by the contracted engine manufacturer and are available at the operations shack on site. The sulfur
content for the diesel fuel is ULSD and certified by Rhinehart Oil.

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

Status: In Compliance. Only the wash plant was operating at the time of this inspection. Spray bar
inspections are performed and recorded as required. The initial Method 9 observations were performed
by Opacitek on December 10, 2019, and March 9, 2020, and are attached to the April 27, 2022,
inspection memo C-799-22.

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

Status: In Compliance. MACT ZZZZ requirements for the engines on site are met with compliance
with NSPS Subpart IIII.

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. See the status of Conditions II.B.4.d and II.B.4.d.1.

Stationary Sources [R307-210]

Status: In Compliance. This Area Source Rule incorporates the federal NSPS standards for Subpart
OOO for Nonmetallic Mineral Processing Plants and Subpart IIII for Stationary Compression
Ignition Internal Combustion Engines. See the above Federal Requirements statement.

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

Status: In Compliance. This Area Source Rule incorporates the federal MACT standards for
Subpart ZZZZ for Stationary Reciprocating Internal Combustion Engines. See the above federal
requirements statement.

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Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. Only the wash plant was operating during this inspection. A Fugitive Dust
Control Plan was submitted to the DAQ on November 4, 2015.

Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. No visible fugitive dust was observed from the haul roads, operation areas,
property boundaries, or any other point at the time of this inspection.

Aggregate Processing Operations for PM2.5 Nonattainment Areas [R307-312]

Status: Not Observed. Only the wash plant was operating during this inspection. No aggregate
mining equipment was observed operating.

EMISSION INVENTORY:
An Emissions Inventory was submitted for the 2023 activity year and a Summary Emission Report is
attached to this memo. Listed below are the Actual Emissions Inventory provided from Rulon Harper
Construction, Inc. – Pit No. 12. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN155530001-16, dated April 14, 2016, is provided. PTE are supplied for supplemental
purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Carbon Monoxide 5.62
Nitrogen Oxides 17.79
Particulate Matter - PM10 7.57
Particulate Matter - PM10 (Fugitives) 6.01
Particulate Matter - PM2.5 2.83
Sulfur Dioxide 2.27
Volatile Organic Compounds 0.27

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
1,3-Butadiene (CAS #106990) 1
Acetaldehyde (CAS #75070) 14
Acrolein (CAS #107028) 2
Benzene (Including Benzene From Gasoline) (CAS #71432) 18
Formaldehyde (CAS #50000) 1
Naphthalene (CAS #91203) 2
Toluene (CAS #108883) 8
Xylenes (Isomers And Mixture) (CAS #1330207) 5

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PREVIOUS ENFORCEMENT
ACTIONS: A Compliance Advisory (DAQC-1609-19) was issued on
December 5, 2019, for exceeding generator operation limits. An
Early Settlement Agreement (DAQC-1690-19) was issued on
December 18, 2019. A Compliance Advisory (DAQC-523-21)
was issued on April 27, 2021, for excess fugitive dust emissions.
A Warning (DAQC-734-21) was issued on May 28, 2021, to
resolve the 2021 Advisory.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN155530001-16,
dated April 14, 2016, the overall status is: Out of Compliance
with the permitted equipment list Section II.A of the AO DAQE-
AN155530001-16. Following this inspection, a Compliance
Advisory was issued on June 6, 2023 (DAQC-618-23), for
unpermitted equipment. An additional inspection was performed
on July 18, 2024. A second Compliance Advisory resulting from
that inspection was issued on August 23, 2024 (DAQC-862-24),
for unpermitted equipment and excessive fugitive dust. Both
C-618-23 and C-862-24 Advisories were resolved with an Early
Settlement Agreement dated December 3, 2024 (C-1196-24),
and signed January 7, 2025 (C-1255-24).

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: The issue of noncompliance was resolved with the combined
ESA C-1196-24 for a penalty of $7,153.00.

NSR RECOMMENDATIONS: Ensure that the list of permitted equipment corresponds with this
facility's actual operating equipment.

ATTACHMENTS: VEO, email correspondence, production records, pit hours,
weekly hours, water log, sprinkler inspection records, and SLEIS
2023 Summary Report.
Susan Weisenberg <[e-mail]>
RE: routine inspection of Pit 12 in Tooele County
1 message
Dennis Sortor <[e-mail]>Wed, May 31, 2023 at 10:17 AM
To: Susan Weisenberg <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Attached are the records pertaining to Pit 12 (Bauer, Utah).

Thank you,

   Dennis Sortor
DENNIS SORTOR — C.D.S.
Risk Manager
Office: 801 / 326-1016
Fax: 801 / 326-1019
Mobile: 801 / 381-9923
Email: [e-mail]
Rulon Harper Construction Inc.
8201 West 5400 South
P.O. Box 18549
Kearns, Utah 84118
www.harpercompaniesinc.com

This email and any files transmitted with it are confidential and intended solely for the use of the individual to whom they are addressed. If you have received this
email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the
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1/13/25, 7:15 PM State of Utah Mail - RE: routine inspection of Pit 12 in Tooele County
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-2273376143224752928%7Cmsg-f:1767427171246325881…1/3

From: Susan Weisenberg <[e-mail]>
Sent: Friday, May 26, 2023 10:08 AM
To: Dennis Sortor <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Subject: routine inspection of Pit 12 in Tooele County

Hello, my name is Susan Weisenberg and I work with the Division of Air Quality for the State of Utah. A routine inspection
was performed yesterday for the aggregate pit located north west of the Tooele County landfill. The pit and haul roads
appeared to be well maintained and a watering truck was observed making the required applications. Only the wash plant
and the generators were operating during my observations.

In order to complete the inspection, I will need the following records for the time period of May 2022 through April 2023:
As per II.B.1.b.A - the 12-month rolling production total for processed aggregate.
As per II.B.1.b.B - documentation of plant operation hours.
As per II.B.1.b.C - documentation that the daily operation did not exceed 10 hours per day and did not exceed six days
per week.
As per II.B.3.c and II.B.3.c.1 - recent watering/road treatment records.
As per II.B.4.a - the 12-month total operation hours for the generators

In terms of equipment, it was noted that your permitted 100 kW generator had been replaced with a second 400 kW
generator. An additional cone crusher and triple deck screen also appeared to be on site, although neither was operating
at the time of this inspection. It is likely that your current Approval Order (AO) AN155530001-16 dated April 14, 2016
should be modified to include the larger sized generator and add the above referenced aggregate equipment. In addition,
Condition II.B.3.d of your current AO states that the haul road shall not exceed 900 feet in length. Given that the pit
operations have been moved to a new area, the total haul road length and exposed operation areas should probably be
analysed by a new New Source Review analysis. Please let me know if your company has current plans to submit a
Notice of intent to the DAQ in order to reflect the above changes on a new AO.

Feel free to contact me if you have any comments or questions. Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

6 attachments
Production Report-Pit 12-for months 712 5-2022 thru 4-2023.pdf
20K
1/13/25, 7:15 PM State of Utah Mail - RE: routine inspection of Pit 12 in Tooele County
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-2273376143224752928%7Cmsg-f:1767427171246325881…2/3
EQ hours Pit 12 4-2022 thru 4-2023.pdf
61K
Weekly hours of Operation Pit 12 5-2022 thru 4-2023.pdf
74K
Water log for dust control 4-30-22 to 4-29-23.pdf
101K
Sprinkler inspection - maintenance log 4-2022 through 5-2023.pdf
88K
Tonage for 2022-2023.pdf
310K
1/13/25, 7:15 PM State of Utah Mail - RE: routine inspection of Pit 12 in Tooele County
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r-2273376143224752928%7Cmsg-f:1767427171246325881…3/3
Harper Sand & Gravel - 5/22 to 4/23
Pit 12 Rolling #
Tons 419,955.49
05/22 Total 16,632.62 419,814.87
06/22 Total 15,884.95 419,103.66
07/22 Total 16,278.51 421,857.88
08/22 Total 15,341.07 426,173.86
09/22 Total 16,538.65 428,780.61
10/22 Total 13,323.89 423,921.94
11/22 Total 12,322.65 422,210.94
12/22 Total 23,988.20 434,639.69
1/23 Total 7,003.36 432,097.38
2/23 Total 7,455.31 430,696.10
3/23 Total 10,904.31 431,099.33
4/23 Total 9,211.81 426,193.92
164,885.33
Crusher generator hours were 1361 for calendar year.
Generator for the well pump was 248 for calendar year.
Total miles driven in pit were 1917.26 (estimated using amount of tonages
hauled out divided by average load times length of travel inside pit).
850,000 ton twelve-month limit
MONTHLY EQUIPMENT HOUR REPORT PIT 12 2022 - 2023 RULON HARPER CONSTRUCTION MATERIALS
MONTH 400 KW Gen Set 100 KW Gen Set
MAY-22 149 24
JUN-22 143 25
JUL-22 147 33
AUG-22 141 28
SEP-22 148 35
OCT-22 110 19
NOV-22 94 16
DEC-22 160 22
JAN-23 51 10
FEB-23 56 12
MAR-23 69 11
APR-23 61 16
Total Hrs 1329 251
Notes
WEEKLY HOURS OF OPERATION REPORT
May 2022 thru April 2023
Pit 12 Bauer RULON HARPER CONSTRUCTION MATERIALS
Week Ending 400 KW Gen Set 100 KW Gen Set
5/7/2022 32 6
5/14/2022 38 6
5/21/2022 40 6
5/28/2022 39 6
6/4/2022 35 6
6/11/2022 33 6
6/18/2022 39 7
6/25/2022 36 6
7/2/2022 24 7
7/9/2022 40 8
7/16/2022 26 6
7/23/2022 30 6
7/30/2022 27 6
8/6/2022 40 7
8/13/2022 36 6
8/20/2022 42 9
8/27/2022 23 6
9/3/2022 41 8
9/10/2022 28 6
9/17/2022 39 12
9/24/2022 40 9
10/1/2022 12 0
10/8/2022 36 7
10/15/2022 8 2
10/22/2022 22 5
10/29/2022 32 5
11/5/2022 30 5
11/12/2022 26 4
11/19/2022 22 4
11/26/2022 16 3
12/3/2022 40 6
12/10/2022 42 6
12/17/2022 40 5
12/24/2022 38 5
12/31/2022 0 0
1/7/2023 0 0
1/14/2023 18 3
1/21/2023 24 5
1/28/2023 9 2
2/4/2023 5 0
2/11/2023 16 4
2/18/2023 15 3
2/25/2023 20 5
3/4/2023 8 1
3/11/2023 16 3
3/18/2023 20 3
3/25/2023 25 4
4/1/2023 10 2
4/8/2023 12 4
4/15/2023 9 2
4/22/2023 7 2
4/29/2023 23 6
Totals 1329 251
NOTES
Weekly Sprinkler Log 4/2021 through 4/2022
MONTH/YEAR ISSUES NOTICED REPAIRS PERFORMED
APRIL/2022 Low pressure spray blow out lines and clean sprayers
MAY/2022 2 sprayers plugged replaced sprayers
JUNE/2022 spray pressure getting low blow out lines and clean sprayers
JULY/2022 None
AUGUST/2022 Several sprayers plugging up took of sprayers and cleaned
SEPTEMBER/2022 no issues
OCTOBER/2022 3 Sprayers not working correctly Replaced sprayers
NOVEMBER/2022 Low pressure spray blow out lines and clean sprayers
DECEMBER/2022 Freezing Shut down crushing operation until warmer weather
JANUARY/2023 Freezing Shut down crushing operation until warmer weather
FEBRUARY/2023 Freezing Shut down crushing operation until warmer weather
MARCH/2023 Freezing Shut down crushing operation until warmer weather
APRIL/2023 Start up maintenance Blow out all lines / Inspect all sprayers and replace bad ones.
MAY/2023 Low pressure Blow out all lines / Inspect all sprayers and replace bad ones.
Bauer Pit # 12 Weekly water load - gallon count 4/2021 through 4/2022
WEEK ENDING LOAD COUNT GALLONS DOWNTIME
4/30/2022 4 16000
5/7/2022 6 24000
5/14/2022 7 28000
5/21/2022 9 36000
5/28/2022 7 28000
6/4/2022 5 20000
6/11/2022 6 24000
6/18/2022 7 28000
6/25/2022 6 24000
7/2/2022 4 16000
7/9/2022 9 36000
7/16/2022 12 48000
7/23/2022 14 56000
7/30/2022 16 64000
8/6/2022 12 48000
8/13/2022 9 36000
8/20/2022 8 32000
8/27/2022 8 32000
9/3/2022 8 32000
9/10/2022 6 24000
9/17/2022 6 24000
9/24/2022 9 36000
10/1/2022 5 20000
10/8/2022 7 28000
10/15/2022 3 12000
10/22/2022 5 20000
10/29/2022 5 20000
11/5/2022 6 24000 Not hauling
11/12/2022 3 12000 Not hauling
11/19/2022 4 16000
11/26/2022 3 12000
12/3/2022 3 12000
12/10/2022 2 8000
12/17/2022 0 0 Too cold
12/24/2022 0 0 Too cold
12/31/2022 0 0 Too cold
1/7/2023 0 0 Too cold
1/14/2023 0 0 Too cold
1/21/2023 0 0 Too cold
1/28/2023 0 0 Too cold
2/4/2023 0 0 Too cold
2/11/2023 0 0 Too cold
2/18/2023 0 0 Too cold
2/25/2023 0 0 Too cold
3/4/2023 0 0 Too cold
Bauer Pit # 12 Weekly water load - gallon count 4/2021 through 4/2022
3/11/2023 0 0 Too cold
3/18/2023 0 0 Too cold
3/25/2023 0 0 Too wet
4/1/2023 0 0 Too wet
4/8/2023 0 0 Too wet
4/15/2023 0 0 Too wet
4/22/2023 6 24000 Maintenance work / Load trucks
4/29/2023 8 32000 Maintenance work / Load trucks
TOTALS 952000
2023 Emissions Inventory Report
Rulon Harper Construction, Inc.- Pit No. 12 (15553)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons,
excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)6.00973 0.07346 6.08319
PM10-FIL PM10 Filterable 6.00973 <.00001 6.00973
PM25-PRI PM2.5 Primary (Filt + Cond)1.83235 0.07125 1.9036
PM25-FIL PM2.5 Filterable 1.83235 <.00001 1.83235
PM-CON PM Condensible 0.01421 <.00001 0.01421
SO2 Sulfur Dioxide 0.54047 0.00163 0.5421
NOX Nitrogen Oxides 4.20623 1.11499 5.32122
VOC Volatile Organic Compounds 0.07314 0.0836 0.15674
CO Carbon Monoxide 1.32799 0.4599 1.78788
NH3 Ammonia 0.03907 <.00001 0.03907

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
75070 Acetaldehyde (HAP)VOC 0.00142
107028 Acrolein (HAP)VOC 0.00017
71432 Benzene (HAP)VOC 0.00172
106990 1,3-Butadiene (HAP)VOC 0.00007
50000 Formaldehyde (HAP)VOC 0.00218
91203 Naphthalene (HAP)VOC 0.00016
130498292 PAH, total (HAP)PM 0.00039
108883 Toluene (HAP)VOC 0.00075
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.00053

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
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