DAQ-2025-001748

1

DAQC-292-25
Site ID 15936 (B4)

MEMORANDUM

TO: STACK TEST FILE – STAKER PARSON COMPANIES – Spanish Valley
Aggregate and Hot Mix Asphalt Facility

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Paul Bushman, Environmental Scientist

DATE: March 19, 2025

SUBJECT: Source: 600 TPH Portable Hot Mix Asphalt Plant
Location: Four Miles South of White Mesa on South Side of Utah Highway 191,
San Juan County, UT
Contact: Chris Rose: 385-400-2119
Tester: Montrose Air Quality Services, LLC
Site ID #: 15936
Permit/AO #: Approval Order DAQE-AN159360002-20, dated October 21, 2020
Subject: Review of Pretest Protocol dated March 14, 2025

On March 14, 2025, DAQ received a protocol for testing of the Hot Mix Asphalt Plant at Four Miles
South of White Mesa on South Side of Utah Highway 191, San Juan County, UT. Testing will be
performed on May 13, 2025, to determine compliance with the emission limits found in conditions
II.B.5.h in Approval Order DAQE-AN159360002-20.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3 used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine moisture content: OK
5. RM 5 used to determine particulate matter emissions: OK
6. RM 9 used to determine visible emissions opacity: OK
7. RM 202 used to determine condensable particulate matter: OK

DEVIATIONS: None.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Staker Parson Companies’ Pretest Protocol

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

5/March 14, 2025
Subject: Compliance Test Plan, Astec 600 TPH Portable HMAP
Facility Name: Staker Parson Companies
Facility Location: Four Miles South of White Mesa on South Side of Utah
Highway 191, San Juan County, UT
Montrose Document No.: GP081AS-052897-PP-971
Enclosed please find the compliance test plan for the above-referenced facility and source.
The test plan documents the details of the testing that will be performed by Montrose Air
Quality Services, LLC (Montrose) at Staker Parson Companies on May 13, 2025.
The following distribution was provided for this project.
Name Company/Agency No. of
copies Electronic Copy
Jeffery Cowlishaw
Staker Parson
2350 South 1900 West
Ogden, Utah 84401
One (1)
Electronic
Copy
Emailed PDF, 3/14/2025
([e-mail])
Chad Gilgen
UDEQ, Division of Air
Quality
195 North 1950 West
Salt Lake City, UT 84116
None
Sent
Emailed PDF, 2/20/2025
([e-mail])
***COPIES HAVE NOT BEEN SENT TO ANY REGULATORY AGENCIES***
Please do not hesitate to contact our office at 801-372-7049 if you have any questions.
Sincerely,
Montrose Air Quality Services, LLC

Beckie Hawkins
District Manager
6823 S 3600 W
Spanish Fork, UT 84660

BH/jd

Source Test Plan for 2025 Compliance Testing
Astec 600 TPH Portable HMAP
Staker Parson Companies
Approximately Four Miles South of White Meas on
the South Side of Utah Highway 191
San Juan County, Utah
Prepared For:
Staker Parson Companies
2350 South 1900 West
Ogden, Utah 84401
Prepared By:
Montrose Air Quality Services, LLC
6823 South 3600 West
Spanish Fork, Utah 84660
For Submission To:
Utah Department of Environmental Quality, Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116
Document Number: GP081AS-052897-PP-971
Proposed Test Date: May 13, 2025
Test Plan Submittal Date: March 14, 2025

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Review and Certification
I certify that, to the best of my knowledge, the information contained in this document is
complete and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature: Date: March 14, 2025
Name: Beckie Hawkins Title: District Manager
I have reviewed, technically and editorially, details and other appropriate written materials
contained herein. I hereby certify that to the best of my knowledge the presented material
is authentic and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature: Date: March 14, 2025
Name: Joby Dunmire Title: Reporting QC Specialist IV

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Table of Contents
Section Page
1.0 Introduction ........................................................................................................ 5
1.1 Summary of Test Program ............................................................................. 5
1.2 Applicable Regulations and Emission Limits ...................................................... 6
1.3 Key Personnel .............................................................................................. 7
2.0 Plant and Sampling Location Descriptions................................................................ 8
2.1 Process Description, Operation, and Control Equipment ..................................... 8
2.2 Flue Gas Sampling Location ........................................................................... 8
2.3 Operating Conditions and Process Data ........................................................... 9
2.4 Plant Safety ............................................................................................... 10
2.4.1 Safety Responsibilities ........................................................................ 10
2.4.2 Safety Program and Requirements ....................................................... 11
3.0 Sampling and Analytical Procedures ..................................................................... 12
3.1 Test Methods ............................................................................................. 12
3.1.1 EPA Method 1 .................................................................................... 12
3.1.2 EPA Method 2 .................................................................................... 12
3.1.3 EPA Method 3 .................................................................................... 13
3.1.4 EPA Method 4 .................................................................................... 14
3.1.5 EPA Methods 5 and 202 ...................................................................... 15
3.1.6 EPA Method 9 .................................................................................... 17
3.2 Process Test Methods .................................................................................. 17
4.0 Quality Assurance and Reporting .......................................................................... 18
4.1 QA Audits .................................................................................................. 18
4.2 Quality Control Procedures .......................................................................... 18
4.2.1 Equipment Inspection and Maintenance ................................................ 18
4.2.2 Audit Samples ................................................................................... 18
4.3 Data Analysis and Validation ........................................................................ 18
4.4 Sample Identification and Custody ................................................................ 19
4.5 Quality Statement ...................................................................................... 19
4.6 Reporting .................................................................................................. 19
4.6.1 Example Report Format ...................................................................... 20
4.6.2 Example Presentation of Test Results ................................................... 20

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

List of Appendices
Appendix A Supporting Information ........................................................................... 22
Appendix A.1 Units and Abbreviations .................................................................. 23
Appendix A.2 Accreditation Information/Certifications ............................................ 32
Appendix A.3 UDEQ Approval Order DAQE-AN159360002-20 .................................. 34
Appendix A.4 Map of HMAP Location .................................................................... 50
Appendix “S” Field Work Safety Plan .......................................................................... 53
List of Tables
Table 1-1 Summary of Test Program and Proposed Schedule .......................................... 5
Table 1-2 Reporting Units and Emission Limits from UDEQ AO AN15936002-20 ................ 6
Table 1-3 Test Personnel and Responsibilities ............................................................... 7
Table 2-1 Sampling Location ....................................................................................... 8
Table 4-1 Example Emissions Results–Astec 600 TPH Portable HMAP, Near White Mesa, UT ....................................................................................................................... 21
List of Figures
Figure 3-1 EPA Methods 5/202 Sampling Train ............................................................. 16
Figure 4-1 Typical Report Format ............................................................................... 20

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

1.0 Introduction
1.1 Summary of Test Program
Staker Parson contracted Montrose Air Quality Services, LLC (Montrose) to perform a
compliance emissions test program on the following units at the facility to be located near
White Mesa, San Juan County, UT: Astec 600 TPH Portable HMAP. The tests are conducted
to determine the emissions of PM/PM10 and the opacity of emissions (VEs) from the exhaust
of the HMAP. Also, as this same portable HMAP is anticipated to be put in service at the
Spanish Valley Pit later in the year (past the test date proposed in this test plan), testing
will be conducted to determine the portable HMAP’s compliance status with Permit Condition
II.B.5 contained in Utah Department of Environmental Quality (UDEQ) Approval Order (AO)
DAQE-AN159360002-20, issued October 20, 2020. It is hoped that the test results from
this test program also demonstrate compliance with the emission limitations contained in
AO DAQE-AN159360002-20. The portable HMAP is also subject to 40 CFR Part 60, Subpart
I emission limits.
The specific objectives are to:
• Measure emissions of PM/PM10 at the outlet of the Astec 600 TPH Portable
HMA Plant, controlled by a baghouse.
• Determine the opacity of emissions (VEOs) at the outlet of the Astech 600
TPH Portable HMA Plant, controlled by a baghouse.
• Conduct the test program with a focus on safety.
Montrose will provide the test personnel and the necessary equipment to measure emissions
as outlined in this test plan. Facility personnel will provide the process and production data
to be included in the final report. A summary of the test program and proposed schedule is
presented in Table 1-1.
Table 1-1
Summary of Test Program and Proposed Schedule
Proposed Test Date(s) Unit ID/ Source Name Activity/Parameters Test Methods No. of Runs Duration (Minutes)
May 13, 2025 Astec 600 TPH Portable Mix HMAP
Velocity/Volumetric
Flow Rate EPA 1, 2, 3, 4 3 60
O2, CO2 EPA 3 3 60
Moisture Content EPA 4 3 60
PM/PM10/PM2.5 EPA 5/202 3 60
Opacity EPA 9 3 6

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

To simplify this test plan, a list of Units and Abbreviations is included in Appendix A.
Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not
defined. Please refer to the list for specific details.
1.2 Applicable Regulations and Emission Limits
The results from this test program are presented in units consistent with those listed in the
applicable regulations or requirements. The reporting units and emission limits are
presented in Tables 1-2.
Table 1-2
Reporting Units and Emission Limits from UDEQ AO AN15936002-20
Unit ID/
Source Name Parameter Reporting Units Emission Limit Emission Limit
Reference
Astec 600 TPH Portable Mix HMAP Exhaust Stack
PM
gr/dscf virgin and/or RAP material 0.04 40 CFR Part 60, Subpart I
gr/dscf virgin and/or RAP material 0.01
AN15936002-20,
§II.B.5.h.
lb/hr virgin and/or RAP material 5.6
PM10/PM2.5
gr/dscf virgin and/or RAP material 0.01
lb/hr virgin and/or RAP material 3.2
Opacity % 10 AN15936002-20, §II.B.5.e.

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

1.3 Key Personnel
A list of project participants is included below:
Facility Information
Source Location: Staker Parson
Astec 600 TPH Portable HMAP
Approximately Four (4) Miles South of White Mesa on the South Side
of Utah Highway 191
San Juan County, Utah
Project Contact: Jeffery Cowlishaw
Role: Environmental Specialist
Company: Staker Parson
Telephone: [phone]
Email: [e-mail]

Agency Information
Regulatory
Agency:
Utah Department of Environmental Quality, Division of Air Quality
Agency Contact: Chad Gilgen
Telephone: [phone]
Email: [e-mail]

Testing Company Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Beckie Hawkins Austin Tramell
Title: District Manager Field Project Manager
Telephone: [phone]
Email: [e-mail] [e-mail]

Table 1-3 details the roles and responsibilities of the test team.
Table 1-3
Test Personnel and Responsibilities
Role Primary Assignment Additional Responsibilities
Client Project Manager Coordinate Project Post-test follow up
Field Project Manager Operate mobile lab Facility interface, test crew coordination
Field Technician Execute stack platform
responsibilities Preparation, support PM

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

2.0 Plant and Sampling Location Descriptions
2.1 Process Description, Operation, and Control
Equipment
Asphaltic concrete paving is a mixture of well graded, high-quality aggregate and
liquid asphaltic cement which is heated and mixed in measured quantities to produce
bituminous pavement material. Aggregate constitutes 92 weight percent of the total
mixture. Aside from the amount and grade of asphalt used, mix characteristics are
determined by the relative amounts and types of aggregate used. A certain
percentage of fine aggregate (% less than 74 micrometers in physical diameter) is
required to produce good quality asphaltic concrete.

The drum mix process simplifies the conventional process by using proportioning
feed controls in place of hot aggregate storage bins, vibration screens, and the
mixer. Aggregate is introduced near the burner end of the revolving drum mixer,
and the asphalt is injected midway along the drum. A variable flow asphalt pump is
linked electronically to the aggregate belt scales to control mix specifications. The
hot mix is discharged from the revolving drum mixer into surge bins or storage bins.
Emissions from the asphalt drum mixer are vented to a baghouse before being emitted to
the atmosphere. The pressure drop across the baghouse will be maintained between 2 and
6 inches of water column. The estimated removal efficiency for the baghouse is 99+ percent
for total suspended particulate material (and PM10).
2.2 Flue Gas Sampling Location
Actual stack measurements, number of traverse points, and location of traverse points will
be evaluated in the field as part of the test program. Table 2-1 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
Table 2-1
Sampling Location
Sampling
Location
Stack Inside
Diameter
(in.)
Distance from Nearest Disturbance
Number of Traverse
Points
Downstream EPA
“B” (in./dia.)
Upstream EPA
“A” (in./dia.)
Astec 600
TPH Portable
Mix HMAP
Exhaust Stack
TBD TBD/TBD TBD/TBD Isokinetic: TBD
Flow: TBD

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

The sample locations is verified in the field to conform to EPA Method 1. Acceptable cyclonic
flow conditions are confirmed prior to testing using EPA Method 1, Section 11.4.
2.3 Operating Conditions and Process Data
Emission tests are performed while the source and air pollution control devices are
operating at the conditions required by the permit. As per UDEQ AO DAQE-AN159360002-20, §II.B.5.i.6, “The owner/operator shall conduct all tests while the source is operating at
the maximum production or combustion rate at which the source will be operated unless
otherwise specified in the approved source test protocol. During the tests, the owner/operator shall burn fuels or combinations of fuels, use raw materials, and maintain process conditions representative of normal operations.”
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters:
• Asphalt production rate, in tons per hour, at least once every 15 minutes.
• The RAP production rate, in tons per hour, at least once every 15 minutes.
• The type of fuel combusted in the asphalt drum mixer and the fuel
consumption rate, in MMBtu/hr, at least once every 15 minutes.
• Asphalt mix temperature, in degrees Fahrenheit, at least once every 15
minutes.
• The applicable emissions control device operating parameters at least once
every 15 minutes, including, at a minimum, baghouse pressure drop, typically
measured in inches of water (“ H2O).

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

2.4 Plant Safety
Montrose will comply with all safety requirements at the facility. The facility Client Sponsor,
or designated point of contact, is responsible for ensuring routine compliance with plant
entry, health, and safety requirements. The Client Sponsor has the authority to impose or
waive facility restrictions. The Montrose test team leader has the authority to negotiate any
deviations from the facility restrictions with the Client Sponsor. Any deviations must be
documented.
2.4.1 Safety Responsibilities
Planning
• Montrose must complete a field review with the Client Sponsor prior to the
project date. The purpose of the review is to develop a scope of work that
identifies the conditions, equipment, methods, and physical locations that will
be utilized along with any policies or procedures that will affect our work.
• We must reach an agreement on the proper use of client emergency services
and ensure that proper response personnel are available, as needed.
• The potential for chemical exposure and actions to be taken in case of
exposure must be communicated to Montrose. This information must include
expected concentrations of the chemicals and the equipment used to identify
the substances.
• Montrose will provide a list of equipment being brought to the site, if required
by the client.
Project Day
• Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate.
• Our team will meet daily to review the Project Scope, Job Hazard Assessment,
and Work Permits. The Client Sponsor and Operations Team are invited to
participate.
• Montrose will provide equipment that can interface with the client utilities
previously identified in the planning phase and only work with equipment that
our client has made ready and prepared for connection.
• We will follow client direction regarding driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area.
• As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the
following provisions at each sample location:
o Sampling ports, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tight.
o Safe sampling platforms.

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

o Safe access to the platforms and test ports, including any scaffolding or
man lifts.
o Sufficient utilities to perform all necessary testing.
• Montrose will use the client communication system, as directed, in case of
plant or project emergency.
• Any adverse conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
• Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site.
• Montrose will clean up our work area to the same condition as it was prior to
our arrival.
• We will ensure that all utilities, connection points or equipment have been
returned to the pre-project condition or as stated in the safe work permit. In
addition, we will walk out the job completion with Operations and the Client
Sponsor if required by the facility.
2.4.2 Safety Program and Requirements
Montrose has a comprehensive health and safety program that satisfies State and Federal
OSHA requirements. The program includes an Illness and Injury Prevention Program, site-
specific safety meetings, and training in safety awareness and procedures. The basic
elements include:
• All regulatory required policies/procedures and training for OSHA, EPA,
FMCSA, and MSHA
• Medical monitoring, as necessary
• Use of Personal Protective Equipment (PPE) and chemical detection equipment
• Hazard communication
• Pre-test and daily toolbox meetings
• Continued evaluation of work and potential hazards
• Near-miss and incident reporting procedures as required by Montrose and the
Client
Montrose will provide standard PPE to employees. The PPE will include but is not limited to;
hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand
protections, and fall protection. In addition, our trailers are equipped with four gas detectors
to ensure that workspace has no unexpected equipment leaks or other ambient hazards.
The detailed Site Safety Plan for this project is attached to this test plan in Appendix “S”.

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

3.0 Sampling and Analytical Procedures
3.1 Test Methods
The test methods for this test program have been presented in Table 1-1. Additional
information regarding specific applications or modifications to standard procedures is
presented below.
3.1.1 EPA Method 1, Sample and Velocity Traverses for Stationary
Sources
EPA Method 1 is used to assure that representative measurements of volumetric flow rate
are obtained by dividing the cross-section of the stack or duct into equal areas, and then
locating a traverse point within each of the equal areas. Acceptable sample locations must
be located at least two stack or duct equivalent diameters downstream from a flow
disturbance and one-half equivalent diameter upstream from a flow disturbance.
3.1.2 EPA Method 2, Determination of Stack Gas Velocity and
Volumetric Flow Rate (Type S Pitot Tube)
EPA Method 2 is used to measure the gas velocity using an S-type pitot tube connected to a
pressure measurement device, and to measure the gas temperature using a calibrated
thermocouple connected to a thermocouple indicator. Typically, Type S (Stausscheibe) pitot
tubes conforming to the geometric specifications in the test method are used, along with an
inclined manometer. The measurements are made at traverse points specified by EPA
Method 1. The molecular weight of the gas stream is determined from independent
measurements of O2, CO2, and moisture content. The stack gas volumetric flow rate is
calculated using the measured average velocity head, the area of the duct at the
measurement plane, the measured average temperature, the measured duct static
pressure, the molecular weight of the gas stream, and the measured moisture.

Pertinent information regarding the performance of the method is presented below:

o S-type pitot tube coefficient is 0.84.
o Shortridge multimeter may be used to measure velocity.

The typical sampling system is detailed as part of the EPA Method 5/202 sampling train in
Figure 3-1.

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

3.1.3 EPA Method 3, Gas Analysis for the Determination of Dry
Molecular Weight
EPA Method 3 is used to calculate the dry molecular weight of the stack via measurement of
the percent O2 and CO2 in the gas stream. A gas sample is extracted from a stack by multi-
point, integrated sampling. The gas sample is analyzed for percent CO2 and percent O2
using either an Orsat or a Fyrite analyzer. Alternatively, an assigned value of 30.0 lb/lb-mol,
in lieu of actual measurements, is used for processes burning natural gas, coal, or oil.
Pertinent information regarding the performance of the method is presented below:
• Method Options:
o An Orsat analyzer is used to measure the analyte concentrations.
o Multi-point integrated sampling is performed.
• Method Exceptions:
o A value of 30.0 is assigned for dry molecular weight, in lieu of actual
measurements, for processes burning natural gas, coal, or oil.
• Target and/or Minimum Required Sample Duration: 60 minutes
• Target and/or Minimum Recommended Sample Volume: 1.0 ft3
• Target Analytes: O2 and CO2

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

3.1.4 EPA Method 4, Determination of Moisture Content in Stack
Gas
EPA Method 4 is a manual method used to measure the moisture content of gas streams.
Gas is sampled at a constant sampling rate through a probe and impinger train. Moisture is
removed using a series of pre-weighed impingers containing methodology-specific liquids
and silica gel immersed in an ice water bath. The impingers are weighed after each run to
determine the percent moisture.
Pertinent information regarding the performance of the method is presented below:
o Condensed water is measured gravimetrically.
o Since it is theoretically impossible for measured moisture to be higher
than psychrometric moisture, the psychrometric moisture is also
calculated, and the lower moisture value is used in the calculations.
o Minimum Required Sample Volume: 21 scf
o Moisture content is determined from the EPA Methods 5 and 202
sampling training. In this case, gas is sampled at an isokinetic rate,
not constant.
o Method Options:
o EPA Approved Alternative Method 009 (ALT-009) is used as an
alternative to a two-point post-test meter box calibration. This
procedure uses a calculation to check the meter box calibration
factor rather than requiring a physical post-test meter box
calibration using a standard dry gas meter. The average calculated
meter box percent (%) error must result in a percent error within
±5% of Y. If not, a full calibration is performed, and the results are
presented using the Y factor that yields the highest emissions.
o EPA Approved Alternative Method 011 (ALT-011) is used as an
alternative to the EPA Method 2 two-point thermocouple
calibration. This procedure involves a single-point in-field check
using a reference thermometer to confirm that the thermocouple
system is operating properly. The temperatures of the
thermocouple and reference thermometers shall agree to within ±2
°F.
The typical sampling system is detailed in Figure 3-1 as part of the EPA Method 2 and 4
sampling train.

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

3.1.5 EPA Methods 5 and 202, Determination of Particulate Matter
from Stationary Sources and Dry Impinger Method for
Determining Condensable Particulate Emissions from
Stationary Sources
EPA Methods 5 and 202 are manual, isokinetic methods used to measure FPM and CPM
emissions. The methods are performed in conjunction with EPA Methods 1, 2, 3, and 4. The
stack gas is sampled through a nozzle, probe, heated filter, unheated CPM filter, condenser,
and impinger train. FPM is collected from the probe and heater filter. CPM is collected from
the unheated CPM filter and the impinger train. The samples are analyzed gravimetrically.
The sum of FPM and CPM represents TPM. The FPM, CPM, and TPM results are reported in
emission concentration and emission rate units.
Pertinent information regarding the performance of the method is presented below:
• Method Options:
o Glass sample nozzles and probe liners are used.
o Stainless steel sample nozzles and glass probe liners are used.
o As an alternative to baking glassware, a field train proof blank sample
is recovered.
o The post-test nitrogen purge is performed using the sampling system
meter box and vacuum pump.
o The post-test nitrogen purge is performed by passing nitrogen
through the train under pressure.
• Method Exceptions:
o Stainless steel probe liners are used.
o A heated flexible probe extension is used to connect the sample probe
to the impinger box.
o Single-point isokinetic sampling is performed at this stack due to
space restrictions.
o The sum of the filterable PM (via Method 5) and CPM (via Method
202) are used as a surrogate for PM10 and/or PM2.5.
• Target and/or Minimum Required Sample Duration: 60 minutes
• Analytical Laboratory: MAQS, Spanish Fork, Utah
The typical sampling system is detailed in Figure 3-1.

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Figure 3-1
EPA Methods 5/202 Sampling Train

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

3.1.6 EPA Method 9, Visual Determination of the Opacity of
Emissions
EPA Method 9 is used to observe the visual opacity of emissions (opacity). The observer
stands at a distance sufficient to provide a clear view of the emissions with the sun oriented
in the 140° sector to their back. The line of vision is perpendicular to the plume direction
and does not include more than one plume diameter. Observations are recorded at 15-
second intervals and are made to the nearest 5% opacity. The qualified observer is certified
according to the requirements of EPA Method 9, section 3.1.
Pertinent information regarding the performance of the method is presented below:
• Method Options:
o Averaging period is 6 minutes (40 CFR Part 60, Subpart I).
Observations are attempted to be made 30 minutes before, during, or within 30 minutes
after each concurrent particulate run, unless weather conditions are unfavorable.
3.2 Process Test Methods
The applicable regulations do not require process samples to be collected during this test
program.

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

4.0 Quality Assurance and Reporting
4.1 QA Audits
Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality
assurance audits are performed as part of the test program to ensure that the results are
calculated using the highest quality data available. This program ensures that the emissions
data we report are as accurate as possible. The procedures included in the cited reference
methods are followed during preparation, sampling, calibration, and analysis. Montrose is
responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose
will also perform the sampling, sample recovery, storage, and shipping. Approved contract
laboratories may perform some of the preparation and sample analyses, as needed.
4.2 Quality Control Procedures
Montrose calibrates and maintains equipment as required by the methods performed and
applicable regulatory guidance. Montrose follows internal procedures to prevent the use of
malfunctioning or inoperable equipment in test programs. All equipment is operated by
trained personnel. Any incidence of nonconforming work encountered during testing is
reported and addressed through the corrective action system.
4.2.1 Equipment Inspection and Maintenance
Each piece of field equipment that requires calibration is assigned a unique identification
number to allow tracking of its calibration history. All field equipment is visually inspected
prior to testing and includes pre-test calibration checks as required by the test method or
regulatory agency.
4.2.2 Audit Samples
When required by the test method and available, Montrose obtains EPA TNI SSAS audit
samples from an accredited provider for analysis along with the samples. Currently, the
SSAS program has been suspended pending the availability of a second accredited audit
sample provider. If the program is reinstated, the audit samples will be ordered. If required
as part of the test program, the audit samples are stored, shipped, and analyzed along with
the emissions samples collected during the test program. The audit sample results are
reported along with the emissions sample results.
4.3 Data Analysis and Validation
Montrose converts the raw field, laboratory, and process data to reporting units consistent
with the permit or subpart. Calculations are made using proprietary computer spreadsheets
or data acquisition systems. One run of each test method is also verified using a separate
example calculation. The example calculations are checked against the spreadsheet results
and are included in the final report. The “Standard Conditions” for this project are 29.92
inches of mercury and 68 °F.

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

4.4 Sample Identification and Custody
The on-site Field Project Manager will assume or assign the role of sample and data
custodian until relinquishing custody. The sample custodian will follow proper custody
procedures before departing from the test site including:
• Assign the unique sample identification number to each sample
• Attach sample labels and integrity seals to all samples
• Complete COC form(s), ensuring that the sample identification numbers on
the samples match the sample identification numbers on the COC
• Pack and store samples in accordance with the test method requirements in
appropriate transport containers for protection from breakage, contamination,
or loss
• Keep samples in a secure locked area if not in the direct presence of Montrose
staff
The sample custodian will follow proper custody procedures upon arriving at the Montrose
office including:
• Remove samples and COC documents from vehicles and check into
designated secure sample holding areas
• Store samples requiring additional measures such as refrigeration or dry ice
appropriately
4.5 Quality Statement
Montrose is qualified to conduct this test program and has established a quality
management system that led to accreditation with ASTM Standard D7036-04 (Standard
Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual
functional assessments for conformance with D7036-04 which are conducted by the
American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose
is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04
Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the
documented limits in the test methods are met by using approved test protocols for each
project as defined in D7036-04 Sections 7.2.1 and 12.10. Additional quality assurance
information is included in the appendices. The content of this test plan is modeled after the
EPA Emission Measurement Center Guideline Document (GD-042).
4.6 Reporting
Montrose will prepare a final report to present the test data, calculations/equations,
descriptions, and results. Prior to release by Montrose, each report is reviewed and certified
by the project manager and their supervisor, or a peer. Source test reports will be
submitted to the facility or appropriate regulatory agency (upon customer approval) within

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

30 days of the completion of the field work. The report will include a series of appendices to
present copies of the intermediate calculations and example calculations, raw field data,
laboratory analysis data, process data, and equipment calibration data.
4.6.1 Example Report Format
The report is divided into various sections describing the different aspects of the source
testing program. Figure 4-1 presents a typical Table of Contents for the final report.
Figure 4-1
Typical Report Format
Cover Page
Certification of Report
Table of Contents
Section
1.0 Introduction
2.0 Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
4.0 Test Discussion and Results
5.0 Internal QA/QC Activities
Appendices
A Field Data and Calculations
B Facility Process Data
C Laboratory Analysis Data
D Quality Assurance/Quality Control
E Regulatory Information

4.6.2 Example Presentation of Test Results
Table 4-1 presents the typical tabular format that is used to summarize the results in the
final source test report. Separate tables will outline the results for each target analyte and
compare them to their respective emissions limits.

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Table 4-1
Example Emissions Results – Astec 600 TPH Portable HMAP, Near White Mesa, UT
Parameter/Units Run 1 Run 2 Run 3 Average
Date XX XX XX
Time XX XX XX
Process Data
throughput, ton/hr XX XX XX XX
baghouse diff. pressure, in.
wc XX XX XX XX
Sampling & Flue Gas Parameters
O2, % volume dry XX XX XX XX
CO2, % volume dry XX XX XX XX
flue gas temperature, °F XX XX XX XX
moisture content, % volume XX XX XX XX
volumetric flow rate, dscfm XX XX XX XX
PM/PM10/PM2.5 Results (Virgin and/or RAP)
concentration, gr/dscf XX XX XX XX
emission rate, lb/hr XX XX XX XX
emission rate, lb/ton HMA XX XX XX XX
Opacity of Emissions Results
opacity, % XX XX XX XX

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Appendix A
Supporting Information

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Appendix A.1
Units and Abbreviations

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

UNITS OF MEASUREMENT
@ X% O2 corrected to X% oxygen (corrected for dilution air)
|CC| absolute value of the confidence coefficient
|d| absolute value of the mean differences
ºC degrees Celsius
ºF degrees Fahrenheit
ºR degrees Rankine
" H2O inches of water column
13.6 specific gravity of mercury
ΔH pressure drop across orifice meter, inches H2O
ΔP velocity head of stack gas, inches H2O
θ total sampling time, minutes
µg microgram
ρa density of acetone, mg/ml
ρw density of water, 0.9982 g/ml or 0.002201 lb/ml
acfm actual cubic feet of gas per minute at stack conditions
An cross-sectional area of nozzle, ft2
As cross-sectional area of stack, square feet (ft2)
Btu British thermal unit
Bws proportion by volume of water vapor in gas stream
Ca particulate matter concentration in stack gas, gr/acf
CAvg average unadjusted gas concentration, ppmv
CDir measured concentration of calibration gas, ppmv
cf or ft3 cubic feet
cfm cubic feet per minute
CGas average gas concentration adjusted for bias, ppmv
CM average of initial and final system bias check responses from upscale
calibration gas, ppmv
cm or m3 cubic meters CMA actual concentration of the upscale calibration gas, ppmv
CO average of initial and final system bias check responses from low-level
calibration gas, ppmv
Cp pitot tube coefficient
Cs particulate matter concentration in stack gas, gr/dscf
CS calibration span, % or ppmv
CS measured concentration of calibration gas, ppmv
CV manufactured certified concentration of calibration gas, ppmv
D drift assessment, % of span
dcf dry cubic feet
dcm dry cubic meters
Dn diameter of nozzle, inches
Ds diameter of stack, inches
dscf dry standard cubic feet
dscfm dry standard cubic feet per minute
dscm dry standard cubic meters
Fd F-factor, dscf/MMBtu of heat input
fpm feet per minute
fps feet per second
ft feet
ft2 square feet
g gram
gal gallons

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

gr grains (7000 grains per pound)
gr/dscf grains per dry standard cubic feet
hr hour
I percent of isokinetic sampling
in inch
k kilo or thousand (metric units, multiply by 103)
K kelvin (temperature)
K3 conversion factor 0.0154 gr/mg
K4 conversion factor 0.002668 ((in. Hg)(ft3))/((ml)(°R))
kg kilogram
Kp pitot tube constant (85.49 ft/sec)
kwscfh thousand wet standard cubic feet per hour
l liters
lb/hr pounds per hour
lb/MMBtu pounds per million Btu
lpm liters per minute
m meter or milli
M thousand (English units) or mega (million, metric units)
m3 cubic meters
ma mass of residue of acetone after evaporation, mg
Md molecular weight of stack gas; dry basis, lb/lb-mole
meq milliequivalent
mg milligram
Mg megagram (106 grams)
min minute
ml or mL milliliter
mm millimeter
MM million (English units)
MMBtu/hr million Btu per hour
mn total amount of particulate matter collected, mg
mol mole
mol. wt. or MW molecular weight
Ms molecular weight of stack gas; wet basis, lb/lb-mole
MW molecular weight or megawatt
n number of data points
ng nanogram
nm nanometer
Nm3 normal cubic meter
Pbar barometric pressure, inches Hg
pg picogram
Pg stack static pressure, inches H2O
Pm barometric pressure of dry gas meter, inches Hg
ppb parts per billion
ppbv parts per billion, by volume
ppbvd parts per billion by volume, dry basis
ppm parts per million
ppmv parts per million, by volume
ppmvd parts per million by volume, dry basis
ppmvw parts per million by volume, wet basis
Ps absolute stack gas pressure, inches Hg
psi pounds per square inch
psia pounds per square inch absolute

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

psig pounds per square inch gauge
Pstd standard absolute pressure, 29.92 inches Hg
Qa volumetric flow rate, actual conditions, acfm
Qs volumetric flow rate, standard conditions, scfm
Qstd volumetric flow rate, dry standard conditions, dscfm
R ideal gas constant 21.85 ((in. Hg) (ft3))/((°R) (lbmole))
SBfinal post-run system bias check, % of span
SBi pre-run system bias check, % of span
scf standard cubic feet
scfh standard cubic feet per hour
scfm standard cubic feet per minute
scm standard cubic meters
scmh standard cubic meters per hour
sec second
sf, sq. ft., or ft2 square feet
std standard
t metric ton (1000 kg)
T 0.975 t-value
Ta absolute average ambient temperature, ºR (+459.67 for English)
Tm absolute average dry gas meter temperature, ºR (+459.67 for English)
ton or t ton = 2000 pounds
tph or tons/hr tons per hour
tpy or tons/yr tons per year
Ts absolute average stack gas meter temperature, ºR (+459.67 for English)
Tstd absolute temperature at standard conditions
V volt
Va volume of acetone blank, ml
Vaw volume of acetone used in wash, ml
Vlc total volume H2O collected in impingers and silica gel, grams
Vm volume of gas sampled through dry gas meter, ft3
Vm(std) volume of gas measured by the dry gas meter, corrected to standard conditions, dscf
Vma stack gas volume sampled, acf
Vn volume collected at stack conditions through nozzle, acf
Vs average stack gas velocity, feet per second
Vwc(std) volume of water vapor condensed, corrected to standard conditions, scf
Vwi(std) volume of water vapor in gas sampled from impingers, scf
Vwsg(std) volume of water vapor in gas sampled from silica gel, scf
W watt
Wa weight of residue in acetone wash, mg
Wimp total weight of impingers, grams
Wsg total weight of silica gel, grams
Y dry gas meter calibration factor, dimensionless

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

ABBREVIATIONS
AAS atomic absorption spectroscopy ACDP air contaminant discharge permit
ACE analyzer calibration error, percent of span
AD absolute difference
ADL above detection limit
AETB Air Emissions Testing Body
AS applicable standard (emission limit)
ASTM American Society for Testing and Materials
BACT best achievable control technology
BDL below detection limit
BHP brake horsepower
BIF boiler and industrial furnace
BLS black liquor solids
CC confidence coefficient
CD calibration drift
CE calibration error
CEM continuous emissions monitor
CEMS continuous emissions monitoring system
CERMS continuous emissions rate monitoring system
CET calibration error test
CFR Code of Federal Regulations
CGA cylinder gas audit
CHNOS elemental analysis for determination of C, H, N, O, and S content in fuels
CNCG concentrated non-condensable gas
CO catalytic oxidizer
COC chain of custody
COMS continuous opacity monitoring system
CPM condensable particulate matter
CPMS continuous parameter monitoring system
CT combustion turbine
CTM conditional test method
CTO catalytic thermal oxidizer
CVAAS cold vapor atomic absorption spectroscopy
De equivalent diameter
DE destruction efficiency
Dioxins polychlorinated dibenzo-p-dioxins (PCDDs)
DLL detection level limited
DNCG dilute non-condensable gas
ECD electron capture detector
EIT Engineer in Training
ELCD electrolytic conductivity detector (hall detector)
EMPC estimated maximum possible concentration
EPA US Environmental Protection Agency
EPRI Electric Power Research Institute
ES emission standard (applicable limit)
ESP electrostatic precipitator
EU emission unit
FCCU fluid catalytic cracking unit
FGD flue gas desulfurization

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

FI flame ionization
FIA flame ionization analyzer
FID flame ionization detector
FPD flame photometric detector
FPM filterable particulate matter
FTIR Fourier-transform infrared spectroscopy
FTPB field train proof blank
FTRB field train recovery blank
Furans polychlorinated dibenzofurans (PCDFs)
GC gas chromatography
GC/MS gas chromatography/mass spectroscopy
GFAAS graphite furnace atomic absorption spectroscopy
GFC gas filter correlation
GHG greenhouse gas
HAP hazardous air pollutant
HC hydrocarbons
HHV higher heating value
HPLC high performance liquid chromatography
HRGC/HRMS high-resolution gas chromatography/high-resolution mass spectroscopy
HRSG heat recovery steam generator
IC ion chromatography
ICAP inductively-coupled argon plasma emission spectroscopy
ICPCR ion chromatography with a post-column reactor
ICP-MS inductively coupled plasma-mass spectroscopy
IR infrared radiation
ISO International Standards Organization
kW kilowatts
LFG landfill gas
LHV lower heating value
LPG liquified petroleum gas
MACT maximum achievable control technology
MDI methylene diphenyl diisocyanate
MDL method detection limit
MNOC maximum normal operating conditions
MRL method reporting limit
MS mass spectrometry
NA not applicable or not available
NCASI National Council for Air and Steam Improvement
NCG non-condensable gases
ND not detected
NDIR non-dispersive infrared
NESHAP National Emissions Standards for Hazardous Air Pollutants
NG natural gas
NIOSH National Institute for Occupational Safety and Health
NIST National Institute of Standards and Technology
NMC non-methane cutter
NMOC non-methane organic compounds
NMVOC non-methane volatile organic compounds
NPD nitrogen phosphorus detector
NSPS New Source Performance Standards

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

OSHA Occupational Safety and Health Administration
PAH polycyclic aromatic hydrocarbons
PCB polychlorinated biphenyl compounds
PCWP plywood and composite wood products
PE Professional Engineer
PFAS per- and polyfluoroalkyl substances (PFAS)
PI photoionization
PID photoionization detector
PM particulate matter
PM10 particulate matter less than 10 microns in aerodynamic diameter
PM2.5 particulate matter less than 2.5 microns in aerodynamic diameter
POM polycyclic organic matter
PS performance specification
PSD particle size distribution
PSEL plant site emission limits
PST performance specification test
PTE permanent total enclosure
PTM performance test method
QA/QC quality assurance and quality control
QI Qualified Individual
QSTI Qualified Source Testing Individual
RA relative accuracy
RAA relative accuracy audit
RACT reasonably available control technology
RATA relative accuracy test audit
RCTO rotary concentrator thermal oxidizer
RICE stationary reciprocating internal combustion engine
RM reference method
RTO regenerative thermal oxidizer
SAM sulfuric acid mist
SCD sulfur chemiluminescent detector
SCR selective catalytic reduction system
SD standard deviation
Semi-VOST semi-volatile organic compounds sample train
SRM standard reference material
TAP toxic air pollutant
TBD to be determined
TCA thermal conductivity analyzer
TCD thermal conductivity detector
TGNENMOC total gaseous non-ethane non-methane organic compounds
TGNMOC total gaseous non-methane organic compounds
TGOC total gaseous organic compounds
THC total hydrocarbons
TIC tentatively identified compound
TO thermal oxidizer
TO toxic organic (as in EPA Method TO-15)
TPM total particulate matter
TSP total suspended particulate matter
TTE temporary total enclosure
ULSD ultra-low sulfur diesel

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

UV ultraviolet radiation range
VE visible emissions
VOC volatile organic compounds
VOST volatile organic sample train
WC water column
WWTP waste water treatment plant

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

CHEMICAL NOMENCLATURE
Ag silver NOx nitrogen oxides
As arsenic O2 oxygen
Ba barium P phosphorus
Be beryllium Pb lead
C carbon PCDD polychlorinated dibenzo-p-dioxins
Cd cadmium PCDF polychlorinated dibenzofurans
CdS cadmium sulfide Sb antimony
CH2O formaldehyde SO2 sulfur dioxide
CH3CHO acetaldehyde SO3 sulfur trioxide
CH3OH methanol SOx sulfur oxides
CH4 methane TCDD tetrachlorodibenzodioxin
C2H4O ethylene oxide TCDF tetrachlorodibenzofuran
C2H6 ethane TGOC total gaseous organic concentration
C3H4O acrolein THC total hydrocarbons
C3H6O propionaldehyde Tl thallium
C3H8 propane TRS total reduced sulfur compounds
C6H5OH phenol Zn zinc
Cl2 chlorine
ClO2 chlorine dioxide
CO carbon monoxide
Co cobalt
CO2 carbon dioxide
Cr chromium
Cu copper
EtO ethylene oxide
EtOH ethyl alcohol (ethanol)
H2 hydrogen
H2O water
H2O2 hydrogen peroxide
H2S hydrogen sulfide
H2SO4 sulfuric acid
HCl hydrogen chloride
Hg mercury
IPA isopropyl alcohol
MDI methylene diphenyl diisocyanate
MeCl2 methylene chloride
MEK methyl ethyl ketone
MeOH methanol
Mn manganese
N2 nitrogen
NH3 ammonia
Ni nickel
NO nitric oxide
NO2 nitrogen dioxide

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Appendix A.2
Accreditation Information/Certifications

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Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Appendix A.3
UDEQ Approval Order DAQE-AN159360002-20

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Appendix A.4
Map of HMAP Location

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

Appendix “S”
Field Work Safety Plan

Staker Parson Companies
2025 Compliance Source Test Plan, Astech 600 TPH Portable HMA Plant, Near White Mesa, Utah

This is the Last Page of This Document
If you have any questions, please contact one of the following
individuals by email or phone.

Name: Beckie Hawkins
Title: District Manager
Region: USA - Stack - Great Plains - Operations
Email: [e-mail]
Phone: [phone]

Name: Cheyney Guymon
Title: Client Project Manager
Region: Great Plains Region, Utah Office
Email: [e-mail]
Phone: [phone]

The permit for the temporary relocation of this plant has not been issued as of the submission
of this test plan. The plant will be tested according to the Spanish Valley Approval Order which
should be more stringent then the temporary relocation permit.

Please call if there are any questions or concerns.

J Cowlishaw
Environmental Specialist
385-405-4315