DAQ-2025-001092

January 28, 2025
Attn: NSPS Contact & Mr. Chad Gilgen,
Minor Source Compliance, Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
RE: NSPS UUU 2024 2nd Semiannual Report
NSPS 000 2024 2nd Semiannual Report
40 CFR §60.735; UAC R307-210
Geofortis Utah, LLC (Ash Grove Tooele Plant)
DAQE-AN 160190001-20
New Modified Approval Order DAQE-AN160190002-25
DAQ NSPS Contact & Mr. Gilgen:
A CRH COMPANY
Geofortis Utah, LLC (now Ash Grove Tooele Plant) is submitting semiannual reporting to the Division
of Air Quality (DAQ) of the approved dryer, ball mill, and pozzolans processing facility in Tooele,
Project Number N160190001. The Division of Air Quality (DAQ) issued the Approval Order (AO}
DAQE-DAQE-AN160190001-20 for the Tooele Pozzolans Processing Plant on September 30, 2020.
Geofortis was purchased by Ash Grove Cement Company on September 3, 2024. A Minor
Modification at Minor Source was submitted on October 28, 2024. The modification was approved
and a new AO was issued on January 15, 2025. The modification included the change of owner and
operator to Ash Grove Tooele Plant.
The pozzolans dryer is an affected facility under Code of Federal Regulations Title 40 (40 CFR} Part
60 Subpart UUU -Standards of Performance for Calciners and Dryers in Mineral industries (NSPS
UUU). The pozzolans dryer is a rotary design controlled by a fabric filter baghouse. The ball mill
crusher is subject to 40 CFR, Part 60 Subpart 000 -Standards of Performance for Nonmetallic
Mineral Processing Plants (NSPS 000). The ball mill crusher is also controlled by a dedicated fabric
filter. Pursuant to NSPS UUU and NSPS 000, §60.735 and§ 60.676, Geofortis submits this
semiannual summary of control device operating parameters from July 1 to December 31, 2024, in
which no exceedances were visually observed.
Reportable exceedances for pozzolans dryer control device operating parameters are described in
NSPS UUU, §60.73S(c}(l}, and NSPS 000 § 60.676(d). The Geofortis Tooele Pozzolans Processing
Plant pozzolans dryer utilizes a dry control device; therefore, §60.735(c)(2} and (3) do not apply. For
semiannual reporting purposes, NSPS UUU requires the following:
NSPS UUU, §60.735(c):
(c)Each owner or operator shall submit written reports semiannually of exceedances of control
device operating parameters required to be monitored by§ 60. 734 of this subpart. For the
purpose of these reports, exceedances are defined as follows:
(1) All 6-minute periods during which the average opacity from dry control devices is greater than
10%;
NSPS 000, §60. 676(d):
1
REVIEWED
Initials: CG Date: 2-21-25
Compliance Status: NSPS OOO and UUUSemi-Annual Report
File # 16019 (B2)
Page 1 of 2
Geofortis NSPS UUU & NSPS 000 2024 2nd Semiannual Report
January 28, 2025
(d)After the initial performance test of a wet scrubber, the owner or operator shall submit
semiannual reports to the Administrator of occurrences when the measurements of the scrubber
pressure Joss and liquid flow rate decrease by more than 30 percent from the average
determined during the most recent performance test.
NSPS UUU §60.734(c) specifically exempts industrial rotary pozzolans dryers from requirements to
monitor opacity of emissions, due to the US EPA determination while developing NSPS UUU and
NSPS 000 that the potential particulate matter emission rate for such dryers is less than 0.01
gr/dscf. However, Geofortis (Ash Grove) has developed voluntary internal procedures to check
baghouse operating parameters and conduct a brief visual and auditory inspection to confirm
baghouses are operating properly once per shift. These observations are qualitative checks along
with required differential pressure drop readings per day. Based upon this information,
maintenance, and differential pressure drop readings, there were no exceedances to report from
January 1 to June 30, 2024, pursuant to opacity standards in NSPS UUU and NSPS 000.
It should be noted that AO DAQE-AN160190001-20, Conditions 11.B.2.f and 11.B.3.d, require that
Geofortis (Ash Grove) maintain the dryer and ball mill crusher baghouse differential pressures
between 2.0 and 6.0 inches of water column. Geofortis (Ash Grove) had eight occurrences of
differential pressure readings below the assessed AO range and 2 occurrences of differential
pressure readings above the assessed AO range. During these ten occurrences of low/high
differential pressure readings, and on a daily basis, the stacks were observed and determined to
have no emissions or zero percent opacity. Geofortis (Ash Grove will plan to submit an AO
modification and revision of Conditions 11.B.2.f and 11.B.3.d consistent with the manufacturer's
recommendations.
Should the DAQ have any questions regarding this semiannual report, please contact Andrew
McKane, Ash Grove Tooele PlantEHS Manager, at 385.454.4827 or
[e-mail].
Sincerely,
Kyle Fletcher,
Ash Grove Tooele Plant Manager
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2
Chad Gilgen <[e-mail]>
Geofortis/Ash Grove Tooele Semiannual Report H2 2024
Chad Gilgen <[e-mail]>Fri, Feb 21, 2025 at 3:21 PM
To: Andrew Mckane <[e-mail]>
Hello Andrew,
Thanks for submitting the 2nd semi-annual report for 2024. I'll get it added to the file.
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 Thu, Jan 30, 2025 at 3:10 PM Andrew Mckane <[e-mail]> wrote:
Chad,
For Geofors Utah, LLC, DAQE-AN160190001-20 and Ash Grove Tooele Plant, DAQE-AN160190002-25,
please find the aached NSPS UUU and OOO 2nd 2024 Semiannual Report for the one (1) pozzolans dryer
and one (1) ball mill operang on-site.
Geofors was purchased by Ash Grove Cement company on September 3rd 2024. A new modified
Approval Order, DAQE-AN160190002-25 was issued on January 15, 2025. The modificaon included the
ownership and name change.
If there are any quesons, please contact me at this email and/or phone below.
Thanks
Andrew McKane
Andrew McKane
EHS Manager
Ash Grove Tooele
385-454-4827
2/21/25, 3:22 PM State of Utah Mail - Geofortis/Ash Grove Tooele Semiannual Report H2 2024
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permmsgid=msg-a:r-4565582833654964921&dsqt=1&simpl=msg-a:r-4565582…1/1