DAQ-2024-011073

DAQE-GN128710006-24

{{$d1 }}

Trina Pace
Brown Brothers Construction
90 North 200 East
Loa, UT 84747
[e-mail]

Dear Ms. Pace:

RE: Revocation of Approval Order DAQE-AN2871003-06 dated June 6, 2006
Project Number: N128710006

The Division of Air Quality (DAQ) initiated a 10-Year Review for Approval Order (AO)
DAQE-AN2871003-06 for Brown Brothers Construction’s - Gravel Crushing & Washing facility. During
the review, it was determined no equipment is currently operating at the site. The DAQ received a request
to revoke AO DAQE-AN2871003-06 on September 3, 2024. All permitted equipment at the site has been
removed. There are no longer crushing and washing operations taking place at this site. Therefore, the
DAQ has revoked the AO referenced above as of the date of this letter.

As authorized by the Utah Legislature, the fee for revoking an AO is the actual time spent by the review
engineer and all other staff on the project. Payment should be made to the DAQ upon receipt of the
invoice.

If you have any questions, please contact Dylan Frederick, who can be reached at [phone] or
[e-mail].

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DF:jg

cc: EPA Region 8
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}}
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

September 11, 2024
DAQE-GN128710006-24
{{$d1 }}
Trina Pace Brown Brothers Construction
90 North 200 East Loa, UT 84747 [e-mail] Dear Trina Pace: RE: Revocation of Approval Order DAQE-AN2871003-06 dated June 6, 2006 Project Number: N128710006 The Division of Air Quality (DAQ) initiated a 10-Year Review for Approval Order (AO) DAQE-AN2871003-06 for Brown Brothers Construction’s Gravel Crushing & Washing facility. During the
review, it was determined no equipment is currently operating at the site. The DAQ received a request to revoke AO DAQE-AN2871003-06 on September 3, 2024. All permitted equipment at the site has been removed. There are no longer crushing and washing operations taking place at this site. Therefore, the
DAQ has revoked the AO referenced above as of the date of this letter. As authorized by the Utah Legislature, the fee for revoking an AO is the actual time spent by the review
engineer and all other staff on the project. Payment should be made to the DAQ upon receipt of the invoice. If you have any questions, please contact Dylan Frederick who can be reached at [phone] or [e-mail]. Sincerely, {{$s }}
Bryce C. Bird Director BCB:xx:jg
cc: , EPA Region 8
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}}
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
2/24/24, 6:37 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r470020882422188717&simpl=msg-a:r-301716883081113…1/6
Dylan Frederick <[e-mail]>
10-year review for Approval Order DAQE-AN2871003-06 Information Request
4 messages
Dylan Frederick <[e-mail]>Tue, Jan 30, 2024 at 1:36 PM
To: Pace <[e-mail]>
Good Afternoon,
I just got off the phone with you, my name is Dylan and I'm a permit writing engineer with the Utah Division of Air Quality. I
just wanted to confirm some information with you so I can administratively update your approval order on my end.
Per our phone conversation, is this the correct primary contact information?
Trina Pace
[phone]
[e-mail]
An inspection from 2011 indicated that most of the equipment listed on the approval order was sold at an auction. Can
you confirm what equipment is permanently on site?
And can you let me know the mailing address for the facility and the UTM coordinates of the facility?
Thank you so much for your help,
Dylan
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
[e-mail] <[e-mail]>Tue, Jan 30, 2024 at 2:55 PM
To: Dylan Frederick <[e-mail]>
Dylan,

We do road construction and excavation, so we are very mobile. What facility are you referring to?

2/24/24, 6:37 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r470020882422188717&simpl=msg-a:r-301716883081113…2/6

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 30, 2024 1:37 PM
To: Pace <[e-mail]>
Subject: 10-year review for Approval Order DAQE-AN2871003-06 Information Request

Good Afternoon,

I just got off the phone with you, my name is Dylan and I'm a permit writing engineer with the Utah Division of Air Quality. I
just wanted to confirm some information with you so I can administratively update your approval order on my end.

Per our phone conversation, is this the correct primary contact information?

Trina Pace
[phone]
[e-mail]

An inspection from 2011 indicated that most of the equipment listed on the approval order was sold at an auction. Can
you confirm what equipment is permanently on site?

And can you let me know the mailing address for the facility and the UTM coordinates of the facility?

Thank you so much for your help,

Dylan
--
2/24/24, 6:37 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r470020882422188717&simpl=msg-a:r-301716883081113…3/6
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

Dylan Frederick <[e-mail]>Tue, Jan 30, 2024 at 3:41 PM
To: [e-mail]
This permit was for a gravel crushing and washing site permitted in 2006, located North East of Loa in Wayne County,
Utah.
[Quoted text hidden]
[e-mail] <[e-mail]>Wed, Jan 31, 2024 at 2:38 PM
To: Dylan Frederick <[e-mail]>
There is no crusher set up in that pit anymore. Hasn’t been for about 5 years.

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 30, 2024 3:41 PM
To: [e-mail]
Subject: Re: 10-year review for Approval Order DAQE-AN2871003-06 Information Request

2/24/24, 6:37 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r470020882422188717&simpl=msg-a:r-301716883081113…4/6
This permit was for a gravel crushing and washing site permitted in 2006, located North East of Loa in Wayne County,
Utah.

On Tue, Jan 30, 2024 at 2:55 PM <[e-mail]> wrote:
Dylan,

We do road construction and excavation, so we are very mobile. What facility are you referring to?

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 30, 2024 1:37 PM
To: Pace <[e-mail]>
Subject: 10-year review for Approval Order DAQE-AN2871003-06 Information Request

Good Afternoon,

I just got off the phone with you, my name is Dylan and I'm a permit writing engineer with the Utah Division of Air
Quality. I just wanted to confirm some information with you so I can administratively update your approval order on my
end.

Per our phone conversation, is this the correct primary contact information?

Trina Pace
[phone]
[e-mail]

An inspection from 2011 indicated that most of the equipment listed on the approval order was sold at an auction. Can
you confirm what equipment is permanently on site?

And can you let me know the mailing address for the facility and the UTM coordinates of the facility?

2/24/24, 6:37 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r470020882422188717&simpl=msg-a:r-301716883081113…5/6
Thank you so much for your help,

Dylan
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
2/24/24, 6:37 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r470020882422188717&simpl=msg-a:r-301716883081113…6/6

Dylan Frederick <[e-mail]>
10-year review for Approval Order DAQE-AN2871003-06 Information Request
Trina Pace <[e-mail]>Wed, Aug 28, 2024 at 12:31 PM
To: Dylan Frederick <[e-mail]>
Oh good. This all makes me feel a lot better. All we’ll ever have is one crusher, so we should be good. I’ll fill out that
revocation request.

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, August 27, 2024 10:29 AM
To: Trina Pace <[e-mail]>
Subject: Re: 10-year review for Approval Order DAQE-AN2871003-06 Informaon Request

Trina,

You would only get an approval order if you will have equipment on site for more than one year. I think the kind of
operation you're describing falls under a portable or temporary relocation permit. And if the operation is just one crusher, it
may be small enough that it just falls under a small source exemption.

On Tue, Aug 27, 2024 at 10:22 AM Trina Pace <[e-mail]> wrote:
Dylan,

Would we apply for a new permit if we’re setting up another permanent operation? I don’t see that happening anytime
in the near future, but there is a possibility we’ll move a crusher in for a few weeks to a month and then move it back
out on occasion.

9/4/24, 1:58 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1808657060446662675&simpl=msg-f:1808657060446662675 1/8

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, August 27, 2024 10:12 AM
To: Trina Pace <[e-mail]>
Subject: Re: 10-year review for Approval Order DAQE-AN2871003-06 Informaon Request

Trina,

When you move new equipment onto the site, you can schedule a pre-noi meeting with us on our website to go over
the requirements for a permit application. Essentially, you will need a list of equipment that produce emissions,
estimates of emissions, an an analysis of the best available control technology, which is essentially looking at all
possible control options and selecting the best control that is economically feasible. I can explain more when you need
a permit. I've included a link to the revocation request form on our website here, and a link to the pre-NOI request form
here.

On Mon, Aug 26, 2024 at 5:02 PM Trina Pace <[e-mail]> wrote:
Dylan,

There aren’t any operations at the pit still, so I guess revoking the approval order is the only option. What will it look
like if / when we need to apply for coverage again?

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, August 6, 2024 3:51 PM
To: Trina Pace <[e-mail]>
Subject: Re: 10-year review for Approval Order DAQE-AN2871003-06 Informaon Request

Trina,

I'm looking to get this project started again. I last contacted you in February, and from the emails sent on this chain,
it looks like there currently aren't any operations at the site. This is for an air quality permit. My recommendation
would be to revoke this approval order if there currently are no operations at the site. If you plan on continuing
operations at the facility, you would need to send an application in to update the equipment and emissions, unless
the equipment and operations are equivalent to what was permitted in 2006. I've attached a copy of the old
approval order here for your reference.

9/4/24, 1:58 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1808657060446662675&simpl=msg-f:1808657060446662675 2/8
On Mon, Feb 26, 2024 at 10:14 AM Trina Pace <[e-mail]> wrote:
No operations going on at the site today, and won’t be for the foreseeable future. It seems reasonable to revoke
the permit for the time being, however we will likely be bringing a crushing operation into the pit again at some
point in the future. With that being said, is it easier to just leave the permit in place and keep it active? Or does it
make more sense to just reapply for a permit when we actually move an operation in? Exactly what permit would
I need to re-apply for?

From: Dylan Frederick <[e-mail]>
Sent: Saturday, February 24, 2024 6:48 PM
To: [e-mail]
Subject: Re: 10-year review for Approval Order DAQE-AN2871003-06 Information Request

Trina,

Are there any operations going on at that location today? Or would it make sense to revoke the permit?

On Wed, Jan 31, 2024 at 2:38 PM <[e-mail]> wrote:
There is no crusher set up in that pit anymore. Hasn’t been for about 5 years.

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 30, 2024 3:41 PM
To: [e-mail]
Subject: Re: 10-year review for Approval Order DAQE-AN2871003-06 Information Request
9/4/24, 1:58 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1808657060446662675&simpl=msg-f:1808657060446662675 3/8

This permit was for a gravel crushing and washing site permitted in 2006, located North East of Loa in Wayne
County, Utah.

On Tue, Jan 30, 2024 at 2:55 PM <[e-mail]> wrote:
Dylan,

We do road construction and excavation, so we are very mobile. What facility are you referring to?

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 30, 2024 1:37 PM
To: Pace <[e-mail]>
Subject: 10-year review for Approval Order DAQE-AN2871003-06 Information Request

Good Afternoon,

I just got off the phone with you, my name is Dylan and I'm a permit writing engineer with the Utah Division
of Air Quality. I just wanted to confirm some information with you so I can administratively update your
approval order on my end.

Per our phone conversation, is this the correct primary contact information?

Trina Pace
[phone]
[e-mail]

An inspection from 2011 indicated that most of the equipment listed on the approval order was sold at an
auction. Can you confirm what equipment is permanently on site?

And can you let me know the mailing address for the facility and the UTM coordinates of the facility?
9/4/24, 1:58 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1808657060446662675&simpl=msg-f:1808657060446662675 4/8

Thank you so much for your help,

Dylan
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

9/4/24, 1:58 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1808657060446662675&simpl=msg-f:1808657060446662675 5/8
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
9/4/24, 1:58 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1808657060446662675&simpl=msg-f:1808657060446662675 6/8

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
9/4/24, 1:58 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1808657060446662675&simpl=msg-f:1808657060446662675 7/8
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

9/4/24, 1:58 PM State of Utah Mail - 10-year review for Approval Order DAQE-AN2871003-06 Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1808657060446662675&simpl=msg-f:1808657060446662675 8/8