DAQ-2024-010059

State of Utah
SPENCER J. COX
Goventor
DEIDRE HENDERSON
Lieulenant Goventor
Department of
Environmental Quality
Kimberly D. Sheltey
Executive Director
DryISION OF AIR QUALITY
Bryce C. Bird
Direclor
No. 70 1 907000002083 47266
DAQC-879-24
Site ID 15972 (81)
August 28,2024
Sent Via Certified Mail
Justin Robb
CKC Operations, LLC
P.O. Box 184
Altamont, UT 84007
Dear Mr. Robb:
Re: Compliance Advisory - CKC Operations, LLC, Utah Administrative Code (UAC)
R307-401, Approval Order (AO) DAQE-ANI59720001-19, Duchesne County
On August 26,2024, a representative of the Utah Division of Air Quality (DAQ) reviewed 2023
Emission lnventory information related to CKC Operations, LLC in Duchesne County, Utah.
Information reviewed indicates CKC Operations, LLC has been operating a Hot Mix Asphalt
Plant without conducting performance testing. Additional information was also reviewed which
indicates equipment operations have not been authorized under a Notice of Temporary Relocation
and that the equipment appears to be operating at a stationary location at the Moon Pit (UTM
Coordinates 12 T 571359.90 Easting 4442499.72 Northing) in Myton, Utah since, at least, 2022.
These may be violations of UAC R307-401-5, New Source Performance Standards (NSPS) 40
Code of Federal Regulations (CFR) Subpart I, and conditions ILB.1.a, ILB.3.a, and II.B.9.g.l of
AO DAQE-AN 1 s972000 1 - I 9.
CKC Operations, LLC is required to comply with the above regulations. A written response to this
letter is required within ten (10) business days of receipt of this letter.
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144820 . Salt Lake City, UT 841144820
Telephone [phone]. Fax [phone]'T.D.D. [phone]
ww.deq.utah.gov
Printed on 100% rccycled paper
DAQC-879-24
Page2
Additional details about the above observations and regulations are affached to this letter. Please
contact me at 385-306-6500 or [e-mail] if you have any questions about this letter.
Sincerely,
4,Or-E;
Chad Gilgen, Manager
Minor Source Compliance Section
CG:rh
cc: TriCounty Health Deparhnent
Alan Humpherys, Manager, MinorNSR Section
DAQC-879-24
Page 3
Potential Violation(s)
On August 26,2024, a representative of the Utah Division of Air Quality (DAQ) reviewed
2023 Emission Inventory information related to CKC Operations, LLC in Duchesne County,
Utah. Information reviewed indicates CKC Operations, LLC has been operating a Hot Mix
Asphalt Plant without conducting performance testing. Additional information was also
reviewed which indicates equipment operations have not been authorized under a Notice of
Temporary Relocation and that the equipment appears to be operating at a stationary location
at the Moon Pit (UTM Coordinates 12 T 571359.90 Easting 4442499.72 Northing) in Myton,
Utah since, at least, 2022.
AO Conditions/Rules
Utah Administrative Code R307-401. Permit: New and Modified Sources
R307401-5. Notice of Intent.
(1) Except as provided in Sections R307-401-9 through R307-401-l7,any person subjectto Rule
R307-401 shall submit a notice of intent to the director and receive an approval order precedent to
the construction, modification, installation, establishment, or relocation of an air pollutant source
or indirect source. The notice of intent shall be in a format specified by the director.
NSPS 40 CFR 60 Subpart I
$60.92 Standard for particulate matter.
(a) On and after the date on which the performance test required to be conducted by $60.8 is
completed, no owner or operator subject to the provisions of this subpart shall discharge or
cause the discharge into the atmosphere from any affected facility any gases which:
(l) Contain particulate matter in excess of 90 mg/dscm (0.04 grldscf).
(2) Exhibit 20 percent opacity, or greater.
Condition II.B.1.a of AO DAQE-ANI59720001-19:
The owner/operator shall submit a Notice of Temporary Relocation and obtain a Temporary
Relocation Approval Letter prior to operating a portable source at any location. [R307401-8]
DAQC-879-24
Page 4
Condition II.B.3.a of AO DAQE-AN159720001-19:
The owner/operator may temporarily relocate this portable source to any temporary location.
The temporary relocation shall not exceed 180 working days and shall not exceed 365
consecutive days. If a temporary relocation is expected to exceed 180 working days, the
owner/operator shall submit an NOI in accordance with R307-401 for a permanent source and
obtain a valid AO prior to the end of the 180 working days. [R307-401-17]
Condition II.B.9.g.1 of AO DAQE-ANI59720001-19:
Stack testing to show compliance with the emission limitations stated in the above
condition shall be performed as specified below:
Emission Point: Drum Mixer exhaust passing through the baghouse
Pollutant Testing Status Test Frequency
TSP*#
PMro 'l"l' @
PMz.s 'r'F @
* Initial compliance testing is required for each plant. The initial test date shall be
performed as soon as possible and in no case later than 180 days after the
start-up of a new or modified emission source. A compliance test is required on
a modified emission point that has an emission rate limit.
'r{' Initial test is not required unless specified by the Director.
# Initial test is required. Subsequent tests shall only be performed for PMro.
@ Test every third calendar year, or sooner if required by the Director, not
exceeding 42 months between tests. Tests may be required if the source is
suspected to be in violation with other conditions of this AO.
[R307-40 I -8, R307-1 65]
The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ. You
are responsible for complying with the Utah Air Conservation Rules. There are possible
administrative and civil penalties for failing to do so. Section l9-2-ll5 of the Utah Code
Annotated provides that violators of the Utah Air Conservation Act and/or any order issued there
under may be subject to a civil penalty of up to $10,000 per day for each violation.
The written response to this CA will be considered in resolving the deficiencies documented in
this letter. It may include information demonstrating compliance with the regulations or a
schedule to bring your company back into compliance with the applicable regulations.
DAQC-879-24
Page 5
The DAQ will review your response and this CA may be revised as a result of that review. Failure
to respond in writing within ten (10) business days of receipt of this CA will be considered in any
subsequent enforcement action and the assessment of penalties.
Possible DAQ actions to resolve a CA include: No Further Action Letter, Warning Letter, Early
Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or
Notice of Violation and Order to Comply.
This CA does not limit or preclude the DAQ from pursuing enforcement options concerning this
inspection. Also, this CA does not constitute a bar to enforcement action for conditions that the
DAQ did not observe or evaluate, or any other conditions found during future inspections.
A meeting may be requested to discuss this CA. Please contact Chad Gilgen at 385-306-6500 or
[e-mail] if you would like to request a meeting or if you have any questions about this
letter.
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CKC OPERATIONS, LLC
P.O. BOX 184
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