DAQ-2024-011860

DAQE-AN117680003-24

{{$d1 }}

Kamren Garfield
Geneva Rock Products, Inc.
730 North 1500 West
Orem, UT 84057
[e-mail]

Dear Mr. Garfield:

Re: Approval Order: Modification to Approval Order DAQE-AN117680002-18 to Reduce Diesel
Generator Operation Hours and Update Equipment
Project Number: N117680003

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on October
4, 2023. Geneva Rock Products, Inc. must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Dungan Adams, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well
as the DAQE number shown on the upper right-hand corner of this letter. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DA:jg

cc: Salt Lake County Health Department

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

November 26, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN117680003-24
Modification to Approval Order DAQE-AN117680002-18
to Reduce Diesel Generator Operation Hours
and Update Equipment

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
Geneva Rock Products, Inc. - Bacchus Pit

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality
November 26, 2024

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-AN117680003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Geneva Rock Products, Inc. Geneva Rock Products, Inc. - Bacchus Pit

Mailing Address Physical Address
730 North 1500 West 6852 West 6200 South
Orem, UT 84057 West Valley City, UT 84118

Source Contact UTM Coordinates
Name: Kamren Garfield 411,392 m Easting
Phone: [phone],499,251 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 1442 (Construction Sand & Gravel)

SOURCE INFORMATION
General Description
Geneva Rock Products, Inc. (GRP) owns and operates the Bacchus Pit in Kearns, Salt Lake County. The
pit includes an aggregate crushing and screening operation and a concrete batch plant. The plant produces
up to 2,000,000 tons of aggregates and 200,000 cubic yards of concrete per rolling 12-month period. Air
pollutants are primarily emitted from crushers, screens, fugitive dust sources, diesel generators, and a
boiler.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), JJJJJJ: National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers Area Sources
DAQE-AN117680003-24
Page 4

Project Description
The source has requested the following changes to the AO:

1. Reduce the hours of operation of the stationary diesel generators on site from 5,470 hours per year to
3,325 hours per year.
2. Remove operational limit of 3,700 hours per rolling 12-month period for the concrete batch plant.
3. Add five (5) 12,000 gallon above-ground diesel storage tanks.
4. Replace six (6) crushers, each rated at 600 tons per hour (tph), one (1) stacker, one (1) wash plant
screen, size 8' x 20', and two (2) dewatering screws, each rated at 300 tph.
5. Remove manufacturer descriptions from the approved equipment.
6. Remove the 350 tph aggregate production limit.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent -478.65 4891.35
Carbon Monoxide -7.37 11.27
Nitrogen Oxides -18.02 49.97
Particulate Matter - PM10 -1.12 29.11
Particulate Matter - PM2.5 -1.12 6.44
Sulfur Dioxide -0.42 6.27
Volatile Organic Compounds -3.85 2.27

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) -1500 80
Change (TPY) Total (TPY)
Total HAPs -0.75 0.04

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]
DAQE-AN117680003-24
Page 5

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 R307-150 Series. Inventories, Testing and Monitoring. [R307-150]
I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Bacchus Pit
II.A.2 One (1) Generator 3412 Rating: 757 hp (565 kW) Fuel: Diesel NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ II.A.3 One (1) Generator 3406 Rating: 335 hp (250 kW) Fuel: Diesel NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
II.A.4 Six (6) Crushers (New) Rating: 600 tph each II.A.5 Four (4) Triple Deck Screens
II.A.6 One (1) Wash Plant Screen (New) Size: 8' x 20'
DAQE-AN117680003-24
Page 6

II.A.7 One (1) Feeder Rating: 600 tph II.A.8 One (1) Sand Classifier Size: 10'x24'

II.A.9 One (1) Dewatering Plant II.A.10 Two (2) Dewatering Screws (New)
Rating: 300 tph each
II.A.11 Various Hoppers, Stackers, and Conveyors
II.A.12 One (1) Concrete Batch Plant
II.A.13 Two (2) Cement/Flyash Silos Control: Three (3) Bin Vents II.A.14 One (1) Baghouse
Rating: 6,500 CFM
Controls: Product loading at mixer
II.A.15 One (1) Boiler Rating: 4 MMBTU/hr Fuel: Diesel fuel, natural gas, or propane
II.A.16 One (1) Diesel Fuel Storage Tank
Capacity: 3,000 gallons
II.A.17 Five (5) Diesel Fuel Storage Tanks (New) Capacity: 12,000 gallons each

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-wide Limitations II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20% opacity. [R307-305-3]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3]
II.B.1.b The owner/operator shall not produce more than 2,000,000 tons of aggregates per rolling 12-month period. [R307-401-8]
DAQE-AN117680003-24
Page 7

II.B.1.b.1 The owner/operator shall: A. Determine production by an operations log B. Record production daily C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.2 Haul Roads and Fugitive Dust Sources
II.B.2.a The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic, mobile equipment in operational areas, and fugitive dust sources on site to exceed 20% opacity on site or 10% opacity at the property boundary at all times. [R307-309]
II.B.2.a.1 The owner/operator shall conduct visible emission observations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas using procedures similar to Method
9. The normal requirement for observations to be made at 15-second intervals over a six-minute
period, 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]

II.B.2.b The owner/operator shall water spray and/or chemically treat all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition or unless it is below freezing. The opacity shall not exceed the limits listed in this AO during all times the areas are in use. If chemical treatment is to be used, the plan must be approved by the Director. [R307-401-8] II.B.2.b.1 The owner/operator shall keep records of water or chemical treatment 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.

[R307-401-8]
II.B.2.c The owner/operator shall not exceed a haul road length of 0.5 miles. [R307-401-8]
II.B.2.c.1 Compliance with the haul road length shall be determined with GPS measurements or aerial
photographs. [R307-401-8]

II.B.2.d The owner/operator shall control disturbed or stripped areas at all times (24 hours per day every day) for the duration of the project/operation until the area is reclaimed. Records of treatment and/or reclamation shall be kept for all periods when the plant is in operation. [R307-401-8]
II.B.2.e The owner/operator shall water storage piles to prevent visible emissions from exceeding the
opacity limits listed in this AO. Records of water and/or chemical treatment shall be kept for all
periods when the plant is in operation. [R307-401-8]

DAQE-AN117680003-24
Page 8

II.B.3 Aggregate Processing Equipment II.B.3.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values: A. All crushers - 12% opacity
B. All screens - 7% opacity
C. All conveyor transfer points - 7% opacity D. All conveyor drop points - 20% opacity
E. All visible emissions at property boundary - 10% opacity
F. All other points - 20% opacity.
[40 CFR 60 Subpart OOO, R307-401-8]

II.B.3.b The owner/operator shall install water sprays on all crushers, screens, and conveyor transfer/drop points on site to control fugitive emissions. The sprays shall operate to meet the opacity limits above. [R307-401-8] II.B.3.c The owner/operator shall conduct an initial performance test for all crushers, screens, and
conveyor transfer points on site within 60 days after achieving maximum production rate but not
later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 of Subpart OOO. Records of initial performance tests shall be kept and maintained on
site for the lifetime of the equipment. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.3.c.1 Initial performance tests for fugitive emission limits shall be conducted according to 40 CFR 60.675(c). The owner/operator may use methods and procedures specified in 40 CFR 60.675(e) as an alternative. [40 CFR 60 Subpart OOO, R307-401-8] II.B.3.c.2 The owner/operator shall submit written reports of the results of all performance tests conducted
to demonstrate compliance with 40 CFR 60.672 to the Director, attn.: Compliance Section. The
submission shall be postmarked no later than 180 days from the date of this AO or no later than 180 days from equipment start-up, whichever is later. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.4 Concrete Batch Plant
II.B.4.a The owner/operator shall not allow visible emissions from the concrete batch plant on site to exceed 7% opacity. [R307-312-4]

II.B.4.b The owner/operator shall not produce more than 200,000 cubic yards of concrete per rolling 12-month period from the concrete batch plant. [R307-401-8]
II.B.4.b.1 The owner/operator shall:

A. Determine production by an operations log

B. Record production daily

C. Use the production data to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months

D. Keep the production records for all periods the plant is in operation.

[R307-401-8]

DAQE-AN117680003-24
Page 9

II.B.4.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across all baghouses in the concrete batch plant. The static pressure differential across each baghouse shall be between 2.0 and 5.0 inches of water column. [R307-401-8]
II.B.4.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8]
II.B.4.c.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8] II.B.4.c.3 The pressure gauge shall be calibrated according to the manufacturer's instructions at least once
every 12 months. [R307-401-8]
II.B.4.d The owner/operator shall not allow visible emissions from any baghouse exhaust point on site to exceed 10% opacity. [R307-401-8] II.B.5 Stationary Engines and Boilers
II.B.5.a The owner/operator shall not allow visible emissions from any stationary diesel engine on site to exceed 20% opacity. [R307-305] II.B.5.b The owner/operator shall not operate each generator on site for more than 3,325 hours per rolling
12-month period. [R307-401-8]

II.B.5.b.1 The owner/operator shall install a non-resettable hour meter for each generator on site. [R307-401-8]
II.B.5.b.2 The owner/operator shall:
A. Determine hours of operation from the non-resettable hour meter and by maintaining
an operations log
B. Record hours of operation monthly
C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months
D. Keep hours of operation records for all periods the plant is in operation.

[R307-401-8]
II.B.5.c The owner/operator shall only use #1 diesel fuel, #2 diesel fuel, natural gas, or propane for all boilers on site. [R307-401-8] II.B.5.d The owner/operator shall use only #1 or #2 diesel fuel for all generators on site. [R307-401-8]

II.B.5.e The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.e.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

DAQE-AN117680003-24
Page 10

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN117680002-18 dated January 25, 2018 Is Derived From NOI dated October 4, 2023 Incorporates Additional Information dated November 1, 2023 Incorporates Additional Information dated March 26, 2024 Incorporates Additional Information dated May 7, 2024 Incorporates Additional Information dated October 3, 2024

DAQE-AN117680003-24
Page 11

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN117680003-24

October 17, 2024

Kamren Garfield
Geneva Rock Products, Inc.
730 North 1500 West
Orem, UT 84057
[e-mail]

Dear Mr. Garfield:

Re: Intent to Approve: Modification to Approval Order DAQE-AN117680002-18 to Reduce Diesel
Generator Operation Hours and Update Equipment
Project Number: N117680003

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Dungan Adams, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Dungan Adams, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DA:jg

cc: Salt Lake County Health Department

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

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN117680003-24
Modification to Approval Order DAQE-AN117680002-18
to Reduce Diesel Generator Operation Hours
and Update Equipment

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
Geneva Rock Products - Bacchus Pit

Issued On
October 17, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-IN117680003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Geneva Rock Products, Inc. Geneva Rock Products, Inc. - Bacchus Pit

Mailing Address Physical Address
730 North 1500 West 6852 West 6200 South
Orem, UT 84057 West Valley City, UT 84118

Source Contact UTM Coordinates
Name: Kamren Garfield 411,392 m Easting
Phone: [phone],499,251 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 1442 (Construction Sand & Gravel)

SOURCE INFORMATION
General Description
Geneva Rock Products, Inc. (GRP) owns and operates the Bacchus Pit in Kearns, Salt Lake County. The
pit includes an aggregate crushing and screening operation and a concrete batch plant. The plant produces
up to 2,000,000 tons of aggregates and 200,000 cubic yards of concrete per rolling 12-month period. Air
pollutants are primarily emitted from crushers, screens, fugitive dust sources, diesel generators, and a
boiler.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), JJJJJJ: National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers Area Sources
DAQE-IN117680003-24
Page 4

Project Description
The source has requested the following changes to the AO:

1. Reduce the hours of operation of the stationary diesel generators on site from 5,470 hours per year to
3,325 hours per year.
2. Remove the operational limit of 3,700 hours per rolling 12-month period for the concrete batch plant.
3. Add five (5) 12,000 gallon above-ground diesel storage tanks.
4. Replace six (6) crushers, each rated at 600 tons per hour (tph), one (1) stacker, one (1) wash plant
screen, size 8' x 20', and two (2) dewatering screws, each rated at 300 tph.
5. Remove manufacturer descriptions from the approved equipment.
6. Remove the 350 tph aggregate production limit.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent -478.65 4891.35
Carbon Monoxide -7.37 11.27
Nitrogen Oxides -18.02 49.97
Particulate Matter - PM10 -1.12 29.11
Particulate Matter - PM2.5 -1.12 6.44
Sulfur Dioxide -0.42 6.27
Volatile Organic Compounds -3.85 2.27

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) -1500 80
Change (TPY) Total (TPY)
Total HAPs -0.75 0.04

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Salt Lake Tribune and Deseret News on October 20, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

DAQE-IN117680003-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

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 R307-150 Series. Inventories, Testing and Monitoring.
[R307-150]
I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT

II.A.1 Bacchus Pit
DAQE-IN117680003-24
Page 6

II.A.2 One (1) Generator 3412 Rating: 757 hp (565 kW) Fuel: Diesel NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
II.A.3 One (1) Generator 3406 Rating: 335 hp (250 kW) Fuel: Diesel
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
II.A.4 Six (6) Crushers (New) Rating: 600 tph each II.A.5 Four (4) Triple Deck Screens
II.A.6 One (1) Wash Plant Screen (New) Size: 8' x 20'
II.A.7 One (1) Feeder
Rating: 600 tph
II.A.8 One (1) Sand Classifier Size: 10'x24' II.A.9 One (1) Dewatering Plant

II.A.10 Two (2) Dewatering Screws (New) Rating: 300 tph each
II.A.11 Various Hoppers, Stackers, and Conveyors

II.A.12 One (1) Concrete Batch Plant
II.A.13 Two (2) Cement/Flyash Silos
Control: Three (3) Bin Vents
II.A.14 One (1) Baghouse Rating: 6,500 CFM Controls: Product loading at mixer
II.A.15 One (1) Boiler
Rating: 4 MMBTU/hr Fuel: Diesel fuel, natural gas, or propane

II.A.16 One (1) Diesel Fuel Storage Tank Capacity: 3,000 gallons
II.A.17 Five (5) Diesel Fuel Storage Tanks (New)
Capacity: 12,000 gallons each

DAQE-IN117680003-24
Page 7

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-wide Limitations
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20% opacity. [R307-305-3] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3]
II.B.1.b The owner/operator shall not produce more than 2,000,000 tons of aggregates per rolling 12-month period. [R307-401-8] II.B.1.b.1 The owner/operator shall: A. Determine production by an operations log. B. Record production daily. C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the production records for all periods the plant is in operation. [R307-401-8]
II.B.2 Haul Roads and Fugitive Dust Sources II.B.2.a The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic, mobile equipment in operational areas, and fugitive dust sources on site to exceed 20% opacity on site or 10% opacity at the property boundary at all times. [R307-309]
II.B.2.a.1 The owner/operator shall conduct visible emission observations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas using procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, 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] II.B.2.b The owner/operator shall water spray and/or chemically treat all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition or unless it is below freezing. The opacity shall not exceed the limits listed in this AO during all times the areas are in use. If chemical treatment is to be used, the plan must be approved by the Director. [R307-401-8]
DAQE-IN117680003-24
Page 8

II.B.2.b.1 The owner/operator shall keep records of water or chemical treatment 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. [R307-401-8] II.B.2.c The owner/operator shall not exceed a haul road length of 0.5 miles. [R307-401-8]

II.B.2.c.1 Compliance with the haul road length shall be determined with Global Positioning System (GPS) measurements or aerial photographs. [R307-401-8]
II.B.2.d The owner/operator shall control disturbed or stripped areas at all times (24-hours per day every day) for the duration of the project/operation until the area is reclaimed. Records of treatment
and/or reclamation shall be kept for all periods when the plant is in operation. [R307-401-8]

II.B.2.e The owner/operator shall water storage piles to prevent visible emissions from exceeding the opacity limits listed in this AO. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. [R307-401-8] II.B.3 Aggregate Processing Equipment
II.B.3.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All crushers - 12% opacity. B. All screens - 7% opacity. C. All conveyor transfer points - 7% opacity. D. All conveyor drop points - 20% opacity. E. All visible emissions at property boundary - 10% opacity. F. All other points - 20% opacity. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.3.b The owner/operator shall install water sprays on all crushers, screens, and conveyor transfer/drop
points on site to control fugitive emissions. The sprays shall operate to meet the opacity limits
above. [R307-401-8]

II.B.3.c The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving maximum production rate but not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 of Subpart OOO. Records of initial performance tests shall be kept and maintained on site for the lifetime of the equipment. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.3.c.1 Initial performance tests for fugitive emission limits shall be conducted according to 40 CFR
60.675(c). The owner/operator may use methods and procedures specified in 40 CFR 60.675(e)
as an alternative. [40 CFR 60 Subpart OOO, R307-401-8]

DAQE-IN117680003-24
Page 9

II.B.3.c.2 The owner/operator shall submit written reports of the results of all performance tests conducted to demonstrate compliance with 40 CFR 60.672 to the Director, attn.: Compliance Section. The submission shall be postmarked no later than 180 days from the date of this AO or no later than 180 days from equipment start-up, whichever is later. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.4 Concrete Batch Plant
II.B.4.a The owner/operator shall not allow visible emissions from the concrete batch plant on site to exceed 7% opacity. [R307-312-4]
II.B.4.b The owner/operator shall not produce more than 200,000 cubic yards of concrete per rolling 12-month period from the concrete batch plant. [R307-401-8]
II.B.4.b.1 The owner/operator shall: A. Determine production by an operations log. B. Record production daily. C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the production records for all periods the plant is in operation. [R307-401-8]
II.B.4.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across all baghouses in the concrete batch plant. The static pressure
differential across each baghouse shall be between 2.0 and 5.0 inches of water column.
[R307-401-8]
II.B.4.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.4.c.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]

II.B.4.c.3 The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. [R307-401-8]
II.B.4.d The owner/operator shall not allow visible emissions from any baghouse exhaust point on site to exceed 10% opacity. [R307-401-8]

II.B.5 Stationary Engines and Boilers
II.B.5.a The owner/operator shall not allow visible emissions from any stationary diesel engine on site to exceed 20% opacity. [R307-305]

II.B.5.b The owner/operator shall not operate each generator on site for more than 3,325 hours per rolling 12-month period. [R307-401-8]
II.B.5.b.1 The owner/operator shall install a non-resettable hour meter for each generator on site.
[R307-401-8]

DAQE-IN117680003-24
Page 10

II.B.5.b.2 The owner/operator shall: A. Determine hours of operation from the non-resettable hour meter and by maintaining an operations log. B. Record hours of operation monthly. C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]
II.B.5.c The owner/operator shall only use #1 diesel fuel, #2 diesel fuel, natural gas, or propane for all boilers on site. [R307-401-8]

II.B.5.d The owner/operator shall use only #1 or #2 diesel fuel for all generators on site. [R307-401-8] II.B.5.e The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less.
[40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.e.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN117680002-18 dated January 25, 2018 Is Derived From NOI dated October 4, 2023 Incorporates Additional Information dated November 1, 2023 Incorporates Additional Information dated March 26, 2024 Incorporates Additional Information dated May 7, 2024 Incorporates Additional Information dated October 3, 2024

DAQE-IN117680003-24
Page 11

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

THANK YOU for your business.
This is your confirmation that your order has been changed. Below are the details of your transaction. Please save this
confirmation for your records.
Job Details
Order Number:
SLT0029898
Classification:
Other Notices
Package:
Legals
Order Cost:
$199.40
Referral Code:
DAQE-NN117680003-24
Account Details
ANDREA RIDDLE
PO BOX 144820
SALT LAKE CITY, UT � 84114
801-536-4000
[e-mail]
UTAH DIVISION OF AIR QUALITY
Schedule for ad number SLT00298980
Sat Oct 19, 2024
The Salt Lake Tribune E-Edition
All Zones
Sun Oct 20, 2024
The Salt Lake Tribune Legals
All Zones

The Salt Lake Tribune
Publication Name:
The Salt Lake Tribune
Publication URL:
Publication City and State:
Salt Lake City, UT
Publication County:
Salt Lake
Notice Popular Keyword Category:
Notice Keywords:
geneva rock
Notice Authentication Number:
202410221028083755593
1761527914
Notice URL:
Back
Notice Publish Date:
Sunday, October 20, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Geneva Rock Products, Inc. Location: Geneva Rock Products, Inc. - Bacchus Pit –
6852 West 6200 South, West Valley City, UT Project Description: Geneva Rock Products, Inc. (GRP) owns and operates the Bacchus Pit in
Kearns, Salt Lake County. The pit includes an aggregate crushing and screening operation and a concrete batch plant. The plant produces up
to 2,000,000 tons of aggregates and 200,000 cubic yards of concrete per rolling 12-month period. Air pollutants are primarily emitted from
crushers, screens, fugitive dust sources, a diesel generator, and a boiler. GRP has requested the following modifications to the Approval
Order: 1. Reduce the hours of operation of the stationary diesel generators on site from 5,470 hours per year to 3,325 hours per year. 2.
Remove the operational limit of 3,700 hours per rolling 12-month period for the concrete batch plant. 3. Add five (5) 12,000 gallon above-
ground diesel storage tanks. 4. Replace various crushers, stackers, screens, and dewatering screws. 5. Remove all manufacturer descriptions
from the approved equipment. 6. Remove the 350 tph aggregate production limit. The completed engineering evaluation and air quality
impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The
Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air
quality, and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West,
Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before November 19, 2024, will be
considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at
[e-mail]. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in
accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information
or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: October 20, 2024
SLT0029898
Back

DAQE-NN117680003-24

October 17, 2024

Salt Lake Tribune and Deseret News
Legal Advertising Dept.
P.O. Box 704055
West Valley City, UT 84170
Acct #9001399880

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on October 20, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Salt Lake County
cc: Wasatch Front Regional Council

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

DAQE-NN117680003-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Geneva Rock Products, Inc.
Location: Geneva Rock Products, Inc. - Bacchus Pit – 6852 West 6200 South, West Valley
City, UT
Project Description: Geneva Rock Products, Inc. (GRP) owns and operates the Bacchus Pit in Kearns,
Salt Lake County. The pit includes an aggregate crushing and screening
operation and a concrete batch plant. The plant produces up to 2,000,000 tons of
aggregates and 200,000 cubic yards of concrete per rolling 12-month period. Air
pollutants are primarily emitted from crushers, screens, fugitive dust sources, a
diesel generator, and a boiler.

GRP has requested the following modifications to the Approval Order: 1. Reduce
the hours of operation of the stationary diesel generators on site from 5,470 hours
per year to 3,325 hours per year. 2. Remove the operational limit of 3,700 hours
per rolling 12-month period for the concrete batch plant. 3. Add five (5) 12,000
gallon above-ground diesel storage tanks. 4. Replace various crushers, stackers,
screens, and dewatering screws. 5. Remove all manufacturer descriptions from
the approved equipment. 6. Remove the 350 tph aggregate production limit.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before November 19, 2024, will be considered in
making the final decision on the approval/disapproval of the proposed project. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: October 20, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN117680003 October 11, 2024 Kamren Garfield Geneva Rock Products, Inc. 730 North 1500 West Orem, UT 84057
[e-mail] Dear Kamren Garfield,
Re: Engineer Review: Modification to DAQE-AN117680002-18 to Reduce Diesel Generator Operation Hours and
Update Equipment Project Number: N117680003
The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Geneva Rock Products, Inc. should complete this review within 10 business days of receipt.
Geneva Rock Products, Inc. should contact Dungan Adams at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dungan Adams at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director.
If Geneva Rock Products, Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Geneva Rock Products, Inc. has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction.
Approval Signature _____________________________________________________________ (Signature & Date)

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
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N117680003 Owner Name Geneva Rock Products, Inc. Mailing Address 730 North 1500 West Orem, UT, 84057 Source Name Geneva Rock Products - Bacchus Pit Source Location 6852 West 6200 South West Valley City, UT 84118
UTM Projection 411,392 m Easting, 4,499,251 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12
SIC Code 1442 (Construction Sand & Gravel) Source Contact Kamren Garfield
Phone Number [phone] Email [e-mail]
Billing Contact Kamren Garfield Phone Number 801-802-6933 Email [e-mail] Project Engineer Dungan Adams, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted October 4, 2023 Date of Accepted Application March 27, 2024

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 2
SOURCE DESCRIPTION General Description
Geneva Rock Products, Inc. (GRP) owns and operates the Bacchus Pit in Kearns, Salt Lake County. The pit includes an aggregate crushing and screening operation and a concrete batch plant. The plant produces up to 2,000,000 tons of aggregates and 200,000 cubic yards of concrete
per rolling 12-month period. Air pollutants are primarily emitted from crushers, screens, fugitive dust sources, diesel generators, and a boiler.
NSR Classification: Minor Modification at Minor Source
Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA
Salt Lake County Airs Source Size: SM Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines MACT (Part 63), JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources
Project Proposal Modification to DAQE-AN117680002-18 to Reduce Diesel Generator Operation Hours and
Update Equipment Project Description
The source has requested the following changes to the AO: 1. Reduce the hours of operation of the stationary diesel generators on site from 5,470 hours per year to 3,325 hours per year.
2. Remove operational limit of 3,700 hours per rolling 12-month period for the concrete batch plant. 3. Add five (5) 12,000 gallon above-ground diesel storage tanks. 4. Replace six (6) crushers, each rated at 600 tons per hour (tph), one (1) stacker, one (1) wash plant screen, size 8' x 20', and two (2) dewatering screws, each rated at 300 tph. 5. Remove manufacturer descriptions from the approved equipment. 6. Remove the 350 tph aggregate production limit. EMISSION IMPACT ANALYSIS All criteria pollutant and HAP emissions are decreasing. All criteria pollutants are below the modeling thresholds contained in R307-410-4. All HAP emissions are below their respective emission threshold values in R307-410-5. Therefore, no modeling is required for this modification. [Last updated April 4, 2024]

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 3
SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent -478.65 4891.35
Carbon Monoxide -7.37 11.27
Nitrogen Oxides -18.02 49.97
Particulate Matter - PM10 -1.12 29.11
Particulate Matter - PM2.5 -1.12 6.44
Sulfur Dioxide -0.42 6.27 Volatile Organic Compounds -3.85 2.27 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) -1500 80
Change (TPY) Total (TPY)
Total HAPs -0.75 0.04
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding New Diesel Storage Tanks
VOC Emissions The source has proposed to add five (5) 12,000-gallon diesel storage tanks. VOC emissions from storage tanks result from working and breathing losses. Available control options include vapor
control systems, submerged fill pipes, and best management practices. Vapor control systems capture vapors produced from storage tank filling. Submerged fill pipes consist of hard pipes installed to the inlet of the storage tank that extend to no more than six inches above the bottom of
the tank, or six inches above the maximum drain level of the tank. Submerged fill pipes extend below the liquid surface level, which reduces vapor generation
The addition of the five (5) storage tanks will result in a VOC emission increase of 0.02 tpy. Vapor control systems are not a cost-effective control option because of the minimal VOC emissions associated with the storage tanks. The source has estimated that it would cost $1,800 to add
submerged fill pipes to each storage tank. The EPA's guideline document, Control of Volatile Organic Emissions from Bulk Gasoline Plants, suggests that submerged filling reduces VOC emissions by 22% during loading. Conservatively assuming all VOC emission are produced from tank loading, implementing submerged fill pipes would reduce VOC emissions by 0.0044 tons per year. Because of the small reduction in VOC emissions, submerged fill pipes are not considered a cost-effective control option. Therefore, BACT for VOC emissions is best management practices, which include regular
inspection and minimizing vapor space in the tanks. [Last updated October 3, 2024] 2. BACT review regarding Replacement Crushers, Screen, Stacker, and Dewatering Screws
PM10 and PM2.5 Emissions The source has proposed to replace six (6) existing crushers with six (6) new crushers rated 600 tph each, one (1) existing wet plant screen with one (1) new wash plant screen, one (1) existing
stacker with one (1) new stacker, and two (2) existing dewatering screws with two (2) new dewatering screws rated 300 tph each. While these replacements will not increase the site-wide potential to emit (PTE), BACT is required for new emission units. PM10 and PM2.5 emissions result
from crushing, screening, and conveying operations at an aggregate processing plant. Available control options from crushers, screens, stackers, and dewatering screws include water application, enclosures, and add-on control devices such as baghouses, wet scrubbers, cyclones, and
electrostatic precipitators. Due to the cost of control and prohibitive temperature-variable outdoor environment, enclosures, baghouses, wet scrubbers, cyclones, and electrostatic precipitators are eliminated as BACT.
Therefore, BACT for PM10 and PM2.5 emissions is the use of water application for all crushing,
screening, and conveying operations. Additionally, BACT is meeting the following opacity limitations: Crushers - 12% Screens - 7%
Conveyor Transfer Points - 7% Conveyor Drop Points - 20% [Last updated April 9, 2024]

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 5
SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
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 R307-150 Series. Inventories, Testing and Monitoring.
[R307-150] I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 6
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Bacchus Pit
II.A.2 One (1) Generator 3412 Rating: 757 hp (565 kW) Fuel: Diesel
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ II.A.3 One (1) Generator 3406 Rating: 335 hp (250 kW)
Fuel: Diesel NSPS/MACT Applicability: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ
II.A.4 NEW Six (6) Crushers (New) Rating: 600 tph each
II.A.5 Four (4) Triple Deck Screens II.A.6 NEW One (1) Wash Plant Screen (New) Size: 8' x 20'

II.A.7 One (1) Feeder Rating: 600 tph
II.A.8 One (1) Sand Classifier Size: 10'x24'

II.A.9 One (1) Dewatering Plant II.A.10 NEW Two (2) Dewatering Screws (New) Rating: 300 tph each
II.A.11 Various Hoppers, Stackers, and Conveyors

II.A.12 One (1) Concrete Batch Plant
II.A.13 Two (2) Cement/Flyash Silos Control: Three (3) Bin Vents
II.A.14 One (1) Baghouse
Rating: 6,500 CFM Controls: Product loading at mixer

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 7
II.A.15 One (1) Boiler Rating: 4 MMBTU/hr Fuel: Diesel fuel, natural gas, or propane
II.A.16 One (1) Diesel Fuel Storage Tank
Capacity: 3,000 gallons II.A.17 NEW Five (5) Diesel Fuel Storage Tanks (New) Capacity: 12,000 gallons each

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 NEW Site-wide Limitations
II.B.1.a NEW Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20% opacity. [R307-305-3]

II.B.1.a.1
NEW
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-305-3] II.B.1.b NEW The owner/operator shall not produce more than 2,000,000 tons of aggregates per rolling 12-month period. [R307-401-8]

II.B.1.b.1 NEW The owner/operator shall: A. Determine production by an operations log
B. Record production daily
C. Use the production data to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months.
D. Keep the production records for all periods the plant is in operation. [R307-401-8]

II.B.2 NEW Haul Roads and Fugitive Dust Sources
II.B.2.a NEW The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic, mobile equipment in operational areas, and fugitive dust sources on site to exceed 20% opacity on site or 10% opacity at the property boundary at all times. [R307-309]

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 8
II.B.2.a.1 NEW The owner/operator shall conduct visible emission observations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas using procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, 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]

II.B.2.b
NEW
The owner/operator shall water spray and/or chemically treat all unpaved roads and other
unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition or unless it is below freezing. The opacity shall not exceed the limits listed in this AO during all times the areas are in use. If chemical treatment is to be used, the plan must be approved by the Director. [R307-401-8]
II.B.2.b.1
NEW
The owner/operator shall keep records of water or chemical treatment 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. [R307-401-8]
II.B.2.c
NEW
The owner/operator shall not exceed a haul road length of 0.5 miles. [R307-401-8]

II.B.2.c.1
NEW
Compliance with the haul road length shall be determined with GPS measurements or aerial
photographs. [R307-401-8] II.B.2.d NEW The owner/operator shall control disturbed or stripped areas at all times (24-hours per day every day) for the duration of the project/operation until the area is reclaimed. Records of
treatment and/or reclamation shall be kept for all periods when the plant is in operation. [R307-401-8]
II.B.2.e
NEW
The owner/operator shall water storage piles to prevent visible emissions from exceeding the
opacity limits listed in this AO. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. [R307-401-8]
II.B.3 NEW Aggregate Processing Equipment

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 9
II.B.3.a NEW The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All crushers - 12% opacity B. All screens - 7% opacity
C. All conveyor transfer points - 7% opacity
D. All conveyor drop points - 20% opacity
E. All visible emissions at property boundary - 10% opacity F. All other points - 20% opacity. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.3.b NEW The owner/operator shall install water sprays on all crushers, screens, and conveyor transfer/drop points on site to control fugitive emissions. The sprays shall operate to meet the opacity limits above. [R307-401-8] II.B.3.c NEW The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving maximum production rate but
not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 of Subpart OOO. Records of initial performance tests shall be kept and maintained on site for the lifetime of the equipment. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.3.c.1 NEW Initial performance tests for fugitive emission limits shall be conducted according to 40 CFR 60.675(c). The owner/operator may use methods and procedures specified in 40 CFR 60.675(e) as an alternative. [40 CFR 60 Subpart OOO, R307-401-8]

II.B.3.c.2 NEW The owner/operator shall submit written reports of the results of all performance tests conducted to demonstrate compliance with 40 CFR 60.672 to the Director, attn.: Compliance Section. The submission shall be postmarked no later than 180 days from the date of this AO
or no later than 180 days from equipment start-up, whichever is later. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.4 NEW Concrete Batch Plant
II.B.4.a
NEW
The owner/operator shall not allow visible emissions from the concrete batch plant on site to
exceed 7% opacity. [R307-312-4] II.B.4.b NEW The owner/operator shall not produce more than 200,000 cubic yards of concrete per rolling 12-month period from the concrete batch plant. [R307-401-8]

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 10
II.B.4.b.1 NEW The owner/operator shall:
A. Determine production by an operations log
B. Record production daily C. Use the production data to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months
D. Keep the production records for all periods the plant is in operation. [R307-401-8]

II.B.4.c
NEW
The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
differential pressure across all baghouses in the concrete batch plant. The static pressure differential across each baghouse shall be between 2.0 and 5.0 inches of water column. [R307-401-8]
II.B.4.c.1 NEW The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8]
II.B.4.c.2
NEW
The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]
II.B.4.c.3 NEW The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. [R307-401-8]
II.B.4.d
NEW
The owner/operator shall not allow visible emissions from any baghouse exhaust point on site
to exceed 10% opacity. [R307-401-8] II.B.5 NEW Stationary Engines and Boilers
II.B.5.a NEW The owner/operator shall not allow visible emissions from any stationary diesel engine on site to exceed 20% opacity. [R307-305]

II.B.5.b NEW The owner/operator shall not operate each generator on site for more than 3,325 hours per rolling 12-month period. [R307-401-8]
II.B.5.b.1 NEW The owner/operator shall install a non-resettable hour meter for each generator on site. [R307-401-8]
II.B.5.b.2 NEW The owner/operator shall: A. Determine hours of operation from the non-resettable hour meter and by maintaining
an operations log B. Record hours of operation monthly C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 11
II.B.5.c NEW The owner/operator shall only use #1 diesel fuel, #2 diesel fuel, natural gas, or propane for all boilers on site. [R307-401-8] II.B.5.d NEW The owner/operator shall use only #1 or #2 diesel fuel for all generators on site. [R307-401-8]
II.B.5.e
NEW
The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.e.1 NEW To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 12
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN117680002-18 dated January 25, 2018
Is Derived From NOI dated October 4, 2023 Incorporates Additional Information dated November 1, 2023 Incorporates Additional Information dated March 26, 2024
Incorporates Additional Information dated May 7, 2024 Incorporates Additional Information dated October 3, 2024
REVIEWER COMMENTS 1. Comment regarding Diesel Generators: In the previous AO (DAQE-AN117680002-18), the diesel generators were incorrectly rated. The
generators were listed as 250 hp and 565 hp. The correct ratings are 250 kW (335 hp) and 565 kW (757 hp) respectively. These ratings were listed in the previous AO (DAQE-AN0117680001-09). The source has not replaced or changed these generated since at least 1999. The incorrect generator ratings led to inaccurate side-wide PTE calculations in the previous AO. There are three (3) combustion devices on site which produce non-PM emissions: one (1) 250 kW (335 hp) diesel generator, one (1) 565 kW (757 hp) generator, and one (1) 4 MMBtu/hr diesel boiler. The remaining approved equipment produces only PM emissions. The boiler PTE was calculated
under the continued assumption of constant operation (8760 hours per year). The PTE of the generators was recalculated using the correct ratings and limit of 3325 hours of annual operation. This results in a site-wide NOx PTE of 49.97 TPY.
The reduction in generator operation also leads to a minor reduction of PM10 and PM2.5 emissions.
This reduction was calculated by subtracting the correctly rated generator PM emissions at current operation (5470 hours per year) from the correctly rated generator PM emissions at proposed operation (3325 hours per year). [Last updated June 21, 2024]
2. Comment regarding Concrete Batch Plant Annual Operation Limit: The source has requested to remove the annual 3,700-hour concrete batch plant (CBP) operation
limit. Annual PM10 and PM2.5 emissions from the CBP are calculated using only the annual production of concrete, the type of plant, and the control technology used. Therefore, the annual operation limit on the CBP does not affect the annual site-wide PTE and can be removed. [Last
updated April 5, 2024] 3. Comment regarding Aggregate Processing Equipment Replacement: The source has proposed to replace six (6) existing crushers with six (6) new crushers rated 600 tph each, one (1) existing wet plant screen with one (1) new wash plant screen, one (1) existing stacker
with one (1) new stacker, and two (2) existing dewatering screws with two (2) new dewatering screws rated 300 tph each. The existing crushers and dewatering screws are rated at lower tons per hour (tph) than the new replacement equipment. However, since the aggregate processing equipment
emission calculations are calculated from the total annual tons of aggregate produced and the maximum hourly tons of aggregate produced (Condition II.B.1.b), the individual rating increase of a crusher or dewatering screw does not impact site-wide PTE. [Last updated April 5, 2024]

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 13

4. Comment regarding Removal of Hourly Aggregate Production Limit: Approval Order (AO) DAQE-AN117680002-18 requires annual and hourly production limits on aggregate production. The source has requested to remove the 350 tons per hour (tph) aggregate production limit from the AO. The hourly production limit restricts the source's hourly Particulate Matter (PM) emission rate, but it has been determined that a possible increase in hourly PM emissions is not a concern from a modeling standpoint. Annual PM emissions from aggregate
production are calculated based on annual production and not on hourly production. Therefore, the removal of the hourly production limit will not affect site-wide PTE or cause any annual emission increases. [Last updated June 21, 2024]
5. Comment regarding Aggregate Equipment Operation: The aggregate equipment (Conditions II.A.1-II.A.16) has not been on-site or operational at the
Bacchus Pit for several years. Before Geneva Rock Products (GRP) brings this equipment back on site and resumes operation, GRP will need to notify the DAQ compliance section. GRP will also be required to conduct Subpart OOO observations for the applicable equipment and CO emission
testing for any Subpart ZZZZ-applicable generator engines. [Last updated June 11, 2024] 6. Comment regarding Federal Subpart Applicability: NSPS (40 CFR 60) 40 CFR 60 Subpart Dc (Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units) applies to owners and operators of small industrial-commercial-institutional steam generating units between 100 MMBtu/hr and 10 MMBtu/hr. The boiler on site is less than 10 MMBtu/hr; therefore, NSPS Subpart Dc does not apply to this source.
40 CFR 60 Subpart Kb (Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984) applies vessels with a design capacity greater than or equal to 75 m3 (19,813 gallons) used for volatile organic liquids. The largest storage tank on site has a capacity of 15,000 gallons (56.78 m3). Therefore, NSPS Subpart Kb does not apply to the source because each of the diesel storage tanks has a capacity of less than 75 m3. 40 CFR Part 60 Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants) applies to select equipment at nonmetallic mineral processing plants that commenced construction, modification, or reconstruction after August 31, 1983. The screens, crushers, and
transfer/drop points (conveyors, stackers, feed bins) at this facility are subject to 40 CFR Part 60 Subpart OOO. 40 CFR 60 Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE)) applies to owners and operators of stationary CI ICE that
commenced construction after July 11, 2005, where the stationary CI ICE are manufactured are manufactured after April 1, 2006. The two diesel engines commenced construction prior to October 4, 1999. Therefore, NSPS Subpart IIII does not apply to this source. [Last updated June 25, 2024]
MACT (40 CFR 63)
40 CFR 63 Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) applies to owners and operators of stationary internal combustion engines (RICE) at an area source of HAP emissions. Therefore, MACT Subpart

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 14
ZZZZ applies to this facility. 40 CFR 63 Subpart JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources) applies to owners and operators of industrial, commercial, or institutional boilers located at an area source of HAP emissions. The facility is an area source of HAP emissions and uses an industrial boiler that runs on diesel fuel. Therefore, MACT Subpart JJJJJJ applies to the facility. [Last updated June 25, 2024] 7. Comment regarding Title V Applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source.
This facility is not a major source and is not a Title IV source. This facility is subject to 40 CFR 60 (NSPS Subpart OOO) regulations that do not specifically exempt it from Title V. Therefore, Title V applies to this facility as an area source. [Last updated June 11, 2024]

Engineer Review N117680003: Geneva Rock Products - Bacchus Pit August 2, 2024 Page 15
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations
CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard
NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
Geneva Rock Products - West Valley Bacchus Pit Emission Calculations
Revision to Air Quality Approval Order DAQE-AN117680002-18
Source
Rated Capacity Units Proposed Annual
Operation (hours)
Generator 3406 335 hp 3325
Generator 3412 757 hp 3325
Boiler 4 MMBTU/hr 8760
Source NOx VOC CO PM10 PM2.5 SO2 CO2eGenerator 3406 0.031 0.00251 0.00668 0.0022 0.0022 0.00205 1.15
Generator 3412 0.024 0.000642 0.0055 0.000401 0.000401 0.00405 1.16
Source NOx VOC CO PM10 PM2.5 SO2 CO2e HAPs
Generator 3406 17.265 1.398 3.720 1.225 1.225 1.142 640.478 2.00E-02
Generator 3412 30.204 0.808 6.922 0.505 0.505 5.097 1459.875 1.00E-02
Boiler 2.500 0.040 0.630 0.300 0.270 0.030 2791.000 0.010
Total 49.969 2.246 11.272 2.030 2.000 6.269 4891.353 0.040
*Emission factors obtained from AP-42, Chapters 3.3-1 & 3.4-1
*Conversion from lb/MMBTU to lb/hp-hr based on 7,000 BTU/hp-hr per AP-42
HAP Annual Emissions Annual Emissions
2.00E-02 1.00E-02
*See detailed HAP emissions at bottom of page
Source # of Tanks NOx VOC CO PM10 SO2
Tank 5 0.0000 0.0201 0 0 0
*Emissions based on AP-42 Section 7.1: Organic Liquid Storage Tanks
*See attached Storage Tank Calculation Tool Printout on following page
Source NOx VOC CO PM10 PM2.5 SO2 HAP CO2e
Current AO PTE (tpy)67.99 6.12 18.64 30.23 7.56 6.69 0.79 5370
Emissions PTE 49.969 2.246 11.272 2.030 2.000 6.269 0.040 4891.353
Addition 0.000 0.020 0.000 0.000 0.000 0.000 0.000 0.000
proposed NOI -18.021 -3.854 -7.368 -1.120 -1.120 -0.421 -0.750 -478.647Proposed Updated Sitewide 49.969 2.266 11.272 29.110 6.440 6.269 0.040 4891.353
757 HP Generator HAP Emissions Detail 335 HP Generator HAP Emissions Detail
Sitewide Emissions Summary
Criteria Pollutants from Combustion Sources
Emission Factors (lb/hp-hr)
Criteria Pollutant Annual Emissions (tpy)
HAP Emissions (tpy)
Generator 3412Generator 3406
Total
Emission Increase from Diesel Storage Tanks
Potential to Emit (tpy)
Actual
Rating (hp)
Current
Operation
(hrs)
New
Operation
(hrs)
335 5470 3325 ***If you want sitewide PTE to be below 50 TPY of
757 5470 3325
NOx CO VOC PM SO2 CO2e
0.031 0.00668 0.00251 0.0022 0.00205 1.15
0.024 0.0055 0.000642 0.000401 0.00405 1.16
NOx CO VOC PM10 PM2.5 SO2 CO2e HAP
78.09 17.51 3.63 2.85 2.85 10.26 3455.32 0.04
NOx CO VOC PM10 PM2.5 SO2 CO2e HAP
2.50 0.63 0.04 0.30 0.27 0.03 2791 0.01
NOx CO VOC PM10 PM2.5 SO2 CO2e HAP
80.59 18.14 3.67 3.15 3.12 10.29 6246.32 0.05
NOx CO VOC PM10 PM2.5 SO2 CO2e HAP
47.47 10.64 2.21 1.73 1.73 6.24 2100.35 0.03
NOx CO VOC PM10 PM2.5 SO2 CO2e HAP
NOx and SO2 e
335 hp and 75
PTE from Boiler (TPY)
Total Combustion PTE at current operation (TPY)
PTE from correctly rated engines at new operation (TPY)
Generator 3406
Generator 3412
Engine Emission factors (lb/hp-hr)
< 600 hp
> 600 hp
PTE from correctly rated engines at current operation (TPY)
PTE from Boiler (TPY)
2.50 0.63 0.04 0.30 0.27 0.03 2791 0.01
NOx CO VOC PM10 PM2.5 SO2 CO2e HAP
49.97 11.27 2.25 2.03 2.00 6.27 4891.35 0.04
NOx CO VOC PM10 PM2.5 SO2 CO2e HAP
67.99 18.64 6.12 30.23 7.56 6.69 5370 0.79
PM10 PM2.5
-1.12 -1.12
VOC
0.02
NOx CO VOC PM10 PM2.5 SO2 CO2e HAP
49.97 11.27 2.27 29.11 6.44 6.27 4891.35 0.04
Difference in PM PTE
(TPY)
New Proposed Site-wide PTE (TPY)
Storage Tank VOC
Increase (TPY)
Total Combustion PTE at new operation (TPY)
Current PTE in AO (TPY)
f NOx then you need to set hours of operation to 3325 hrs
emissions are above the PTE in the active Approval Order for the
7 hp engines at 5470 hours of operation
Dungan Adams <[e-mail]>
Fw: Submerged Fill Pipe
1 message
Kamren Garfield <[e-mail]>Wed, Oct 2, 2024 at 2:03 PM
To: Dungan Adams <[e-mail]>
Dungan,
See cost estimate below.
Thanks,
Kamren
Get Outlook for iOS
From: Ted Soffe <[e-mail]>
Sent: Wednesday, October 2, 2024 1:55 PM
To: Kamren Garfield <[e-mail]>
Cc: Taber Westech <[e-mail]>
Subject: Re: Submerged Fill Pipe

Roughly $1,800.00 plus installaon and freight
Ted Soffe
Westech Equipment
195 West 3900 South
Salt Lake City Utah 84157
801-266-2545/Office
801-910-7456/Cell
From: Kamren Garfield <[e-mail]>
Sent: Wednesday, October 2, 2024 1:53 PM
To: Ted Soffe <[e-mail]>
Cc: Taber Westech <[e-mail]>
Subject: Re: Submerged Fill Pipe

AST. Division of air quality is looking at requiring these for diesel tanks and I’m putting together a cost vs emissions
analysis. Thanks
Get Outlook for iOS
From: Ted Soffe <[e-mail]>
Sent: Wednesday, October 2, 2024 1:34:12 PM
To: Kamren Garfield <[e-mail]>
Cc: Taber Westech <[e-mail]>
Subject: Re: Submerged Fill Pipe

Kamren,
Is this for a AST or a UST?
Ted Soffe
Westech Equipment
195 West 3900 South
10/3/24, 11:08 AM State of Utah Mail - Fw: Submerged Fill Pipe
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1811833834332223919&simpl=msg-f:1811833834332223919 1/2
Salt Lake City Utah 84157
801-266-2545/Office
801-910-7456/Cell
From: taber westechfuel.com <[e-mail]>
Sent: Wednesday, October 2, 2024 10:49 AM
To: Ted Soffe <[e-mail]>
Subject: FW: Submerged Fill Pipe

Approximate cost????

Taber DeHart, PG
Westech Environmental
195 West 3900 South
Salt Lake City, Utah 84157
Phone: [phone]
Cell: 801-910-7471
E-mail: [e-mail]

From: Kamren Garfield <[e-mail]>
Sent: Wednesday, October 2, 2024 10:47 AM
To: taber westechfuel.com <[e-mail]>
Subject: Submerged Fill Pipe

Taber,
Do you have an approximate cost to install a submerged fill drop pipe on a diesel fuel tank?

Thanks,

Kamren Garfield
ENVIRONMENTAL SPECIALIST
O [phone] 
C [phone]
WWW.CLYDEINC.COM

10/3/24, 11:08 AM State of Utah Mail - Fw: Submerged Fill Pipe
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1811833834332223919&simpl=msg-f:1811833834332223919 2/2
Dungan Adams <[e-mail]>
Minor Modification to Geneva Rock Bacchus Pit
51 messages
Dungan Adams <[e-mail]>Tue, Oct 10, 2023 at 2:26 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
My name is Dungan and I am working on processing the requested modifications to the Geneva Rock Products Bacchus
Pit. Everything looks good so far.
You have requested that the manufacturer be removed from the crushers in the approved equipment section. I think it
would be a good idea to remove the manufacturer from conditions II.A.15, II.A.16, II.A.17, and II.A.18 (Shown below). I'm
not sure why they were included in the first place.
II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron
II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
Manufacturer: El Jay
II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay
II.A.18 One (1) Sand Classifier
Size: 10'x24'
Manufacturer: Eagle Iron Autospec
Let me know if you would like to include this modification.
Thanks,
Dungan
--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
Kamren Garfield <[e-mail]>Tue, Oct 10, 2023 at 3:20 PM
To: Dungan Adams <[e-mail]>
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-3941150200946…1/238
Hi Dungan,
Look forward to working with you on this. Yes, I think that’s a good idea.

Thanks,
Kamren
[Quoted text hidden]
Dungan Adams <[e-mail]>Mon, Oct 23, 2023 at 10:51 AM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
Could you please provide emission calculations and state the emission reductions for PM2.5 and CO2e? Both of these
emissions were included in the previous AO but were not specified in the minor modification NOI.
Here's a link to the DAQs emission calculation spreadsheets. The diesel engine and boiler spreadsheets should help with
the CO2e calculation. Let me know if you have any questions.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Wed, Nov 1, 2023 at 9:58 AM
To: Dungan Adams <[e-mail]>
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West Valley to include PM2.5 and CO2e. Let me know if you have
any questions.

Thanks,
Kamren
[Quoted text hidden]
GRP West Valley Updated Emission calcs 11.1.23.pdf
203K
Dungan Adams <[e-mail]>Thu, Nov 2, 2023 at 12:23 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
In the provided calculations and modification request, Generators 3406 and 3412 are listed as 335 hp and 757 hp
respectively. In your current AO (DAQE-AN117680002-18) the generators are listed as 250 hp and 565 hp. Can you
please clarify if you are changing generators as part of the modification?
The discrepancy generator has caused issues with the emission calculations. You have calculated the reduction of annual
emissions assuming the original generators were 335 hp and 757 hp, but this is not the case. The annual NOx emissions
for 4200 hours of operation for the 335 hp and 757 hp generators is 59.96 TPY. The annual NOx emissions for 5470
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-3941150200946…2/238
hours of operation for the 335 hp and 757 hp generators is 78.09 TPY, which is above the limit set in the AO. It's fine to
change the generators in the modification, but you will need to update your emissions calculations to accurately reflect the
change.
I hope this makes sense. Let me know if you have any questions.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Fri, Nov 10, 2023 at 12:11 PM
To: Dungan Adams <[e-mail]>
Hi Dungan,

That is a great question, here is what I found while digging through some prior records.

Approval Order DAQE-AN0117680001-09 (Dated July 28, 2009) listed the generators as 250 KW and 565 KW. In
November 2017 a reduction in emissions was submitted to DAQ. In those calculations, both the KW and the equivalent hp
(as converted from kw) were expressed in the emission calculations (i.e. 250 KW = 335 hp & 565 KW = 757 hp). It looks
like the subsequent (current) AO was then written to show the generator size reflected as hp but used the KW number, if
that makes sense. So now the current AO erroneously shows the sizes as 250 hp and 565 hp when it should be in KW,
which would make them the same as 335 hp and 757 hp. This is something that should have been caught during the ER
review but nobody did. Hopefully this makes sense and we can get it corrected in this revision. I will be out most of next
week but can hop on a call next Friday if you want to discuss.
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Nov 14, 2023 at 2:10 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
Thanks for bringing this up. I see what you are saying, in DAQE-AN0117680001-09 the generators are listed as 250
kW and 565 kW. Then in the current AO, DAQE-AN117680002-18, the generators are listed as 250 hp and 565 hp.
The current AO (DAQE-AN117680002-18) states each generator shall not exceed 5,470 hours of annual operation. The
current AO's emission limit for NOx is 67.99 TPY. When I calculate the emissions for 250 kW and 565 kW engines
assuming 5,470 hours of operation, I get 78.09 TPY of NOX which is above the limit in the current AO. This means the
emission limits in the current AO were probably calculated assuming 250 hp and 565 hp engines.
I think the best way to move forward is to redo plant wide emission calculations. Trying to calculate only the emission
reduction (as you submitted in the NOI) is confusing since the current AO does not correctly list the generators and their
associated emissions. The other viable option would be to redo the generator emission calculations for the current AO
with the 335 hp and 757 hp generators and then reduce the hours of operations and calculate the correct reduction.
Let me know what you think. I'd be happy to meet if you think that would be helpful.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Tue, Dec 12, 2023 at 3:48 PM
To: Dungan Adams <[e-mail]>
Hi Dungan,
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-3941150200946…3/238
Sorry just getting back to this, I will dig into these calcs and send you an update.
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Dec 12, 2023 at 4:27 PM
To: Kamren Garfield <[e-mail]>
Sounds great.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Jan 16, 2024 at 9:00 AM
To: Kamren Garfield <[e-mail]>
Good morning Kamren,
I wanted to follow up about the GRP Bacchus Pit project. Have you had the chance to look into emission calculations?
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Jan 30, 2024 at 10:23 AM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
I'm following up again about this project. It's approaching three months since I requested additional emission calculation
information. Please send an update when you get the chance.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Wed, Jan 31, 2024 at 10:40 AM
To: Dungan Adams <[e-mail]>
HI Dungan, sorry I’ve been on the road a lot the past couple months and this dropped off my radar. I will have updated
calcs to you by end of Friday. My apologies for the delay.
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, Jan 31, 2024 at 11:03 AM
To: Kamren Garfield <[e-mail]>
Kamren,
No worries. Thank you for the update.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Fri, Feb 2, 2024 at 4:44 PM
To: Dungan Adams <[e-mail]>
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-3941150200946…4/238
Dungan,
I have revised the calculations to reflect the engine sizes as they are shown in the current AO. Let me know if this works
for you. I had to reduce operation to 3,780 hrs for each engine to get the required NOx reduction.
[Quoted text hidden]
AO revision calcs rev. 2.2.24.xlsx
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Dungan Adams <[e-mail]>Tue, Feb 6, 2024 at 1:57 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
I've looked at the emission calculations you sent and I found them difficult to follow. I think the calculations assume the
PTE for NOx in the active AO is correct and I don't think it is. Calculating only the emission reduction from the operational
change doesn't take into account the inaccurate PTE in the current AO. I've really quickly put together some emission
calculations that show site-wide combustion PTE for the different operational hours and engine ratings. I used the
emission factors that you listed in the attachment, but if I am missing something please let me know.
Please take a look and let me know what you think.
Thanks,
Dungan
[Quoted text hidden]
GRP Bacchus Pit Calcs.xlsx
31K
Dungan Adams <[e-mail]>Tue, Mar 12, 2024 at 2:05 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
I am following up about this project. Have you had a chance to review the emission calculations from my last email?
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Tue, Mar 12, 2024 at 3:46 PM
To: Dungan Adams <[e-mail]>
The gaseous emissions make sense, but if I go with this method means I will also need to recalculate all the PM
emissions associated with the crushing operations to come up with a new sitewide PM potential to emit. That is why I
tried to stay with just showing the decrease. Can we just assume the PM emissions in the AO are correct and then
calculate what the generator decrease will be and subtract from the total in the current AO?
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, Mar 13, 2024 at 9:07 AM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
I have concerns with calculating emissions this way when the PTE in the active AO is incorrect. That being said, I
understand not wanting to redo more emission calculations. Let me talk with my manager and I will get back to you.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-3941150200946…5/238
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Wed, Mar 13, 2024 at 9:24 AM
To: Dungan Adams <[e-mail]>
Thanks for looking into that. My biggest concern with trying to recreate everything in the PM calcs is I don’t have access
to the original application that established the crushing limits and other assumptions that were made for that AO. So I
would be starting from scratch. In my experience we usually don’t touch any calcs that aren’t associated with the
modification.
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, Mar 13, 2024 at 5:49 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
Since the current engines and operation leads to NOx emissions ~12 TPY above the PTE in the active AO, calculating
new emissions by subtracting from this incorrect PTE will not be accepted. I think the best way to move forward would be
this:
As far as I understand there are three (3) point sources of non-PM emissions: the 335 hp generator, the 757 hp
generator, and the 4 MMBtu/hr boiler (The 3,000 gal diesel storage tank produces 0.00 TPY of VOCs). The rest of
the equipment produces only PM emissions. The combustion sources will be recalculated to make sure that NOx
emissions are actually below 50 TPY--the engine operation will need to be 3325 hours per year in order to meet
this requirement.
The PM emissions can be calculated by subtracting the difference between the current operation and the new
operation of the generators. I went through and updated the calculations I sent over last time. At current
production, assuming 335 hp and 757 hp generators, the PM10 and PM2.5 emissions are 2.85 TPY. At 3325 hours
the PM10 and PM2.5 emissions are 1.73 TPY. So, the operation reduction causes a 1.12 TPY reduction in PM 10
& 2.5.
This allows the NOx PTE to be accurate without emission recalculations for the crushing operations. Let me know what
you think.
[Quoted text hidden]
GRP Bacchus Pit Calcs.xlsx
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Kamren Garfield <[e-mail]>Mon, Mar 18, 2024 at 4:28 PM
To: Dungan Adams <[e-mail]>
Dungan,

I agree with your approach. Here are my updated calcs to reflect that. I couldn’t get the HAP and CO2e emissions to line
up exactly with yours. That said, I’m fine with using your calcs if you want to.

Let me know what you think.
Thanks for your patience on this.
[Quoted text hidden]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-3941150200946…6/238
AO revision calcs rev. 3.18.24.xlsx
31K
Dungan Adams <[e-mail]>Tue, Mar 19, 2024 at 11:35 AM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and Xylenes emission factors for Generator 3406.
For the CO2e emission factor for Generator 3406, I believe it should be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline fuel.
I think after those minor changes we should get the same values for HAPs and CO2e. Let me know if you have any
questions.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Tue, Mar 26, 2024 at 2:55 PM
To: Dungan Adams <[e-mail]>
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.
[Quoted text hidden]
AO revision calcs rev. 3.26.24.xlsx
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Dungan Adams <[e-mail]>Tue, Mar 26, 2024 at 3:24 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
This looks good to me. I'll let you know if any other questions come up, but I think we should be all set.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Fri, Apr 12, 2024 at 2:04 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the owner/operator shall not produce
more than 2,000,000 tons of aggregates per rolling 12-month period and shall not produce more than 350 tons of
aggregates per hour."
How is the 350 tons per hour limit being monitored and how are records being kept? I'm updating some of the outdated
language in the AO and want to make sure the recordkeeping and monitoring conditions match whatever GRP is currently
doing.
Thanks,
Dungan
[Quoted text hidden]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-3941150200946…7/238
Dungan Adams <[e-mail]>Fri, Apr 26, 2024 at 10:43 AM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
Following up about my question from April 12th.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Tue, May 7, 2024 at 10:00 AM
To: Dungan Adams <[e-mail]>
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher production is very uncommon. To my
knowledge this could be the only permit GRP has with an hourly crusher limit. The only way to track that would be to tie in
a data logger to the belt scale. I don’t think we have ever modeled that site, so I’m not sure where the hourly limit came
from. What would it take to get this condition removed?
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, May 8, 2024 at 2:41 PM
To: Kamren Garfield <[e-mail]>
Kamren,
I think we should be able to remove the hourly limit because from my understanding it doesn't have any impact on annual
PTE. I just reached out to our modeling department to see if they have concerns with the removal of the limit. I will let you
know when I hear back from them
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, May 15, 2024 at 9:36 AM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
I've removed the hourly production limit. I should have the updated permit for you to review in a couple of weeks.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Wed, May 15, 2024 at 9:50 AM
To: Dungan Adams <[e-mail]>
Great, thank you so much!
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, May 22, 2024 at 4:09 PM
To: Kamren Garfield <[e-mail]>
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-3941150200946…8/238
Hi Kamren,
During their review our compliance department noted the past two times this site has been inspected it looked like all
aggregate processing equipment had been permanently removed. I've attached the most recent inspection memo from
July 2023.
Do you want to update the equipment list to better account for the equipment on site or does GRP have plans to bring
back aggregate operation?
Thanks,
Dungan
[Quoted text hidden]
C-1044-23.pdf
3450K
Dungan Adams <[e-mail]>Thu, Jun 6, 2024 at 1:04 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
I am following up about this project.
I know you want to get this site under 50 tpy NOx before the northern wasatch front is reclassified to serious non-
attainment for ozone and the major source threshold changes. From my talks with compliance, because all of the
aggregate processing equipment was removed from the site for several years, if you are planning to bring it back now it
will be considered new equipment, require notification, and need to have visible emission observations conducted. If you
aren't planning to bring it back now, my understanding is that it will require another permit modification if/when the
aggregate equipment is brought back in the future.
Let me know what GRP's current plan is for the pit and I will communicate with compliance and adjust the permit
accordingly.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Thu, Jun 6, 2024 at 1:07 PM
To: Dungan Adams <[e-mail]>
Geneva Rock does have plans to bring crushing equipment back into the Bacchus Pit in the next year or
two. We want to keep the crushers and aggregate processing in the air permit.
[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Jun 6, 2024 at 1:08 PM
To: Kamren Garfield <[e-mail]>
Got it. I will relay this to compliance and see how they want to proceed.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Mon, Jun 10, 2024 at 2:02 PM
To: Dungan Adams <[e-mail]>
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-3941150200946…9/238
Sounds good. I don’t agree with removing the crusher equipment from the permit since it at one time was
constructed and operated. However, I’ll wait and see what Compliance says and we’ll discuss. Thanks,
[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Jun 13, 2024 at 10:32 AM
To: Kamren Garfield <[e-mail]>
Kamren,
The aggregate equipment can definitely stay in the AO since like you say it was at one time constructed and operated. I
just wanted to ask about it in case you didn't have any plans to bring the equipment back in the future.
Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to notify the DAQ
compliance section. GRP will be required to conduct Subpart OOO observations for applicable equipment and CO
emission testing for Subpart ZZZZ-applicable generator engines. GRP will also need to confirm the aggregate equipment
brought back on site is identical to the equipment permitted in their AO.
My manager is reviewing this project and I should have the engineering review for you to review soon. Let me know if you
have any questions or would like to discuss anything further.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Jun 27, 2024 at 2:00 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and let me know if you
have any questions or concerns. If everything looks good, please sign the cover page and return the document to me.
Thanks,
Dungan
[Quoted text hidden]
RN117680003.rtf
1592K
Kamren Garfield <[e-mail]>Fri, Jun 28, 2024 at 11:59 AM
To: Dungan Adams <[e-mail]>
Thanks for sending this over. Let me send this around to the group for review and I will get back to you with
any comments.
Have a great weekend.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 27, 2024 2:01 PM
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…10/238
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and let me know if you
have any questions or concerns. If everything looks good, please sign the cover page and return the document to me.

Thanks,
Dungan

On Thu, Jun 13, 2024 at 10:32 AM Dungan Adams <[e-mail]> wrote:
Kamren,

The aggregate equipment can definitely stay in the AO since like you say it was at one time constructed and operated. I
just wanted to ask about it in case you didn't have any plans to bring the equipment back in the future.

Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to notify the DAQ
compliance section. GRP will be required to conduct Subpart OOO observations for applicable equipment and CO
emission testing for Subpart ZZZZ-applicable generator engines. GRP will also need to confirm the aggregate
equipment brought back on site is identical to the equipment permitted in their AO.

My manager is reviewing this project and I should have the engineering review for you to review soon. Let me know if
you have any questions or would like to discuss anything further.

Thanks,
Dungan

On Mon, Jun 10, 2024 at 2:02 PM Kamren Garfield <[e-mail]> wrote:
Sounds good. I don’t agree with removing the crusher equipment from the permit since it at one time
was constructed and operated. However, I’ll wait and see what Compliance says and we’ll discuss.
Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:09 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…11/238

Got it. I will relay this to compliance and see how they want to proceed.

Thanks,
Dungan

On Thu, Jun 6, 2024 at 1:08 PM Kamren Garfield <[e-mail]> wrote:
Geneva Rock does have plans to bring crushing equipment back into the Bacchus Pit in the next
year or two. We want to keep the crushers and aggregate processing in the air permit.

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project.

I know you want to get this site under 50 tpy NOx before the northern wasatch front is reclassified to serious non-
attainment for ozone and the major source threshold changes. From my talks with compliance, because all of the
aggregate processing equipment was removed from the site for several years, if you are planning to bring it back
now it will be considered new equipment, require notification, and need to have visible emission observations
conducted. If you aren't planning to bring it back now, my understanding is that it will require another permit
modification if/when the aggregate equipment is brought back in the future.

Let me know what GRP's current plan is for the pit and I will communicate with compliance and adjust the permit
accordingly.

Thanks,
Dungan

On Wed, May 22, 2024 at 4:09 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

During their review our compliance department noted the past two times this site has been inspected it looked
like all aggregate processing equipment had been permanently removed. I've attached the most recent
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…12/238
inspection memo from July 2023.

Do you want to update the equipment list to better account for the equipment on site or does GRP have plans
to bring back aggregate operation?

Thanks,
Dungan

On Wed, May 15, 2024 at 9:50 AM Kamren Garfield <[e-mail]> wrote:
Great, thank you so much!

From: Dungan Adams <[e-mail]>
Sent: Wednesday, May 15, 2024 9:37 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I've removed the hourly production limit. I should have the updated permit for you to review in a couple of
weeks.

Thanks,
Dungan

On Wed, May 8, 2024 at 2:41 PM Dungan Adams <[e-mail]> wrote:
Kamren,

I think we should be able to remove the hourly limit because from my understanding it doesn't have any
impact on annual PTE. I just reached out to our modeling department to see if they have concerns with
the removal of the limit. I will let you know when I hear back from them

Thanks,
Dungan

On Tue, May 7, 2024 at 10:00 AM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher production is very
uncommon. To my knowledge this could be the only permit GRP has with an hourly crusher limit. The
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…13/238
only way to track that would be to tie in a data logger to the belt scale. I don’t think we have ever
modeled that site, so I’m not sure where the hourly limit came from. What would it take to get this
condition removed?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, April 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the owner/operator
shall not produce more than 2,000,000 tons of aggregates per rolling 12-month period and shall not
produce more than 350 tons of aggregates per hour."

How is the 350 tons per hour limit being monitored and how are records being kept? I'm updating some
of the outdated language in the AO and want to make sure the recordkeeping and monitoring
conditions match whatever GRP is currently doing.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 3:24 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

This looks good to me. I'll let you know if any other questions come up, but I think we should be all
set.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 2:55 PM Kamren Garfield <[e-mail]> wrote:
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…14/238
From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 19, 2024 11:35 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and Xylenes emission
factors for Generator 3406. For the CO2e emission factor for Generator 3406, I believe it should
be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline fuel.

I think after those minor changes we should get the same values for HAPs and CO2e. Let me
know if you have any questions.

Thanks,
Dungan

On Mon, Mar 18, 2024 at 4:28 PM Kamren Garfield <[e-mail]> wrote:
Dungan,

I agree with your approach. Here are my updated calcs to reflect that. I couldn’t get the HAP
and CO2e emissions to line up exactly with yours. That said, I’m fine with using your calcs if
you want to.

Let me know what you think.
Thanks for your patience on this.

Kamren

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 5:49 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Since the current engines and operation leads to NOx emissions ~12 TPY above the PTE in
the active AO, calculating new emissions by subtracting from this incorrect PTE will not be
accepted. I think the best way to move forward would be this:
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…15/238

As far as I understand there are three (3) point sources of non-PM emissions: the 335
hp generator, the 757 hp generator, and the 4 MMBtu/hr boiler (The 3,000 gal
diesel storage tank produces 0.00 TPY of VOCs). The rest of the equipment produces
only PM emissions. The combustion sources will be recalculated to make sure that NOx
emissions are actually below 50 TPY--the engine operation will need to be 3325 hours
per year in order to meet this requirement.

The PM emissions can be calculated by subtracting the difference between the current
operation and the new operation of the generators. I went through and updated the
calculations I sent over last time. At current production, assuming 335 hp and 757 hp
generators, the PM10 and PM2.5 emissions are 2.85 TPY. At 3325 hours the PM10 and
PM2.5 emissions are 1.73 TPY. So, the operation reduction causes a 1.12 TPY
reduction in PM 10 & 2.5.

This allows the NOx PTE to be accurate without emission recalculations for the crushing
operations. Let me know what you think.

On Wed, Mar 13, 2024 at 9:24 AM Kamren Garfield <[e-mail]> wrote:
Thanks for looking into that. My biggest concern with trying to recreate everything in the PM
calcs is I don’t have access to the original application that established the crushing limits
and other assumptions that were made for that AO. So I would be starting from scratch. In
my experience we usually don’t touch any calcs that aren’t associated with the modification.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 9:08 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I have concerns with calculating emissions this way when the PTE in the active AO is
incorrect. That being said, I understand not wanting to redo more emission calculations. Let
me talk with my manager and I will get back to you.

Thanks,
Dungan

On Tue, Mar 12, 2024 at 3:47 PM Kamren Garfield <[e-mail]> wrote:
The gaseous emissions make sense, but if I go with this method means I will also need to
recalculate all the PM emissions associated with the crushing operations to come up with
a new sitewide PM potential to emit. That is why I tried to stay with just showing the
decrease. Can we just assume the PM emissions in the AO are correct and then calculate
what the generator decrease will be and subtract from the total in the current AO?

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…16/238
From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project. Have you had a chance to review the emission
calculations from my last email?

Thanks,
Dungan

On Tue, Feb 6, 2024 at 1:57 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

I've looked at the emission calculations you sent and I found them difficult to follow. I
think the calculations assume the PTE for NOx in the active AO is correct and I don't
think it is. Calculating only the emission reduction from the operational change doesn't
take into account the inaccurate PTE in the current AO. I've really quickly put together
some emission calculations that show site-wide combustion PTE for the different
operational hours and engine ratings. I used the emission factors that you listed in the
attachment, but if I am missing something please let me know.

Please take a look and let me know what you think.

Thanks,
Dungan

On Fri, Feb 2, 2024 at 4:44 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
I have revised the calculations to reflect the engine sizes as they are shown in the
current AO. Let me know if this works for you. I had to reduce operation to 3,780 hrs
for each engine to get the required NOx reduction.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 14, 2023 2:10 PM
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…17/238
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Thanks for bringing this up. I see what you are saying, in DAQE-AN0117680001-09
the generators are listed as 250 kW and 565 kW. Then in the current AO, DAQE-
AN117680002-18, the generators are listed as 250 hp and 565 hp.

The current AO (DAQE-AN117680002-18) states each generator shall not exceed
5,470 hours of annual operation. The current AO's emission limit for NOx is 67.99
TPY. When I calculate the emissions for 250 kW and 565 kW engines assuming
5,470 hours of operation, I get 78.09 TPY of NOX which is above the limit in the
current AO. This means the emission limits in the current AO were probably
calculated assuming 250 hp and 565 hp engines.

I think the best way to move forward is to redo plant wide emission calculations.
Trying to calculate only the emission reduction (as you submitted in the NOI) is
confusing since the current AO does not correctly list the generators and their
associated emissions. The other viable option would be to redo the generator
emission calculations for the current AO with the 335 hp and 757 hp generators and
then reduce the hours of operations and calculate the correct reduction.

Let me know what you think. I'd be happy to meet if you think that would be helpful.

Thanks,
Dungan

On Fri, Nov 10, 2023 at 12:11 PM Kamren Garfield <[e-mail]>
wrote:
Hi Dungan,

That is a great question, here is what I found while digging through some prior
records.

Approval Order DAQE-AN0117680001-09 (Dated July 28, 2009) listed the
generators as 250 KW and 565 KW. In November 2017 a reduction in emissions
was submitted to DAQ. In those calculations, both the KW and the equivalent hp
(as converted from kw) were expressed in the emission calculations (i.e. 250 KW
= 335 hp & 565 KW = 757 hp). It looks like the subsequent (current) AO was then
written to show the generator size reflected as hp but used the KW number, if that
makes sense. So now the current AO erroneously shows the sizes as 250 hp
and 565 hp when it should be in KW, which would make them the same as 335
hp and 757 hp. This is something that should have been caught during the ER
review but nobody did. Hopefully this makes sense and we can get it corrected in
this revision. I will be out most of next week but can hop on a call next Friday if
you want to discuss.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…18/238
Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 2, 2023 12:24 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the provided calculations and modification request, Generators 3406 and 3412
are listed as 335 hp and 757 hp respectively. In your current AO (DAQE-
AN117680002-18) the generators are listed as 250 hp and 565 hp. Can you
please clarify if you are changing generators as part of the modification?

The discrepancy generator has caused issues with the emission calculations. You
have calculated the reduction of annual emissions assuming the original
generators were 335 hp and 757 hp, but this is not the case. The annual NOx
emissions for 4200 hours of operation for the 335 hp and 757 hp generators is
59.96 TPY. The annual NOx emissions for 5470 hours of operation for the 335 hp
and 757 hp generators is 78.09 TPY, which is above the limit set in the AO. It's
fine to change the generators in the modification, but you will need to update your
emissions calculations to accurately reflect the change.

I hope this makes sense. Let me know if you have any questions.

Thanks,
Dungan

On Wed, Nov 1, 2023 at 9:58 AM Kamren Garfield <[e-mail]>
wrote:
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West Valley to include
PM2.5 and CO2e. Let me know if you have any questions.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, October 23, 2023 10:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…19/238

Hi Kamren,

Could you please provide emission calculations and state the emission
reductions for PM2.5 and CO2e? Both of these emissions were included in the
previous AO but were not specified in the minor modification NOI.

Here's a link to the DAQs emission calculation spreadsheets. The diesel
engine and boiler spreadsheets should help with the CO2e calculation. Let me
know if you have any questions.

Thanks,
Dungan

On Tue, Oct 10, 2023 at 3:20 PM Kamren Garfield <[e-mail]>
wrote:
Hi Dungan,
Look forward to working with you on this. Yes, I think that’s a good idea.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 10, 2023 2:26 PM
To: Kamren Garfield <[e-mail]>
Subject: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

My name is Dungan and I am working on processing the requested
modifications to the Geneva Rock Products Bacchus Pit. Everything looks
good so far.

You have requested that the manufacturer be removed from the crushers in
the approved equipment section. I think it would be a good idea to remove
the manufacturer from conditions II.A.15, II.A.16, II.A.17, and II.A.18 (Shown
below). I'm not sure why they were included in the first place.

II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
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II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
Manufacturer: El Jay

II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay

II.A.18 One (1) Sand Classifier
Size: 10'x24'
Manufacturer: Eagle Iron Autospec

Let me know if you would like to include this modification.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
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--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…22/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…23/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…24/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…25/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
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https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…26/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…27/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…28/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…29/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…30/238
--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

Kamren Garfield <[e-mail]>Tue, Jul 2, 2024 at 2:53 PM
To: Dungan Adams <[e-mail]>
Dungan, thanks for sending this over. With most everyone out of the office this week for the holiday, can we
have until COB next Friday (July 12) to review the draft ER?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 27, 2024 2:01 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and let me know if you
have any questions or concerns. If everything looks good, please sign the cover page and return the document to me.

Thanks,
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…31/238
Dungan

On Thu, Jun 13, 2024 at 10:32 AM Dungan Adams <[e-mail]> wrote:
Kamren,

The aggregate equipment can definitely stay in the AO since like you say it was at one time constructed and operated. I
just wanted to ask about it in case you didn't have any plans to bring the equipment back in the future.

Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to notify the DAQ
compliance section. GRP will be required to conduct Subpart OOO observations for applicable equipment and CO
emission testing for Subpart ZZZZ-applicable generator engines. GRP will also need to confirm the aggregate
equipment brought back on site is identical to the equipment permitted in their AO.

My manager is reviewing this project and I should have the engineering review for you to review soon. Let me know if
you have any questions or would like to discuss anything further.

Thanks,
Dungan

On Mon, Jun 10, 2024 at 2:02 PM Kamren Garfield <[e-mail]> wrote:
Sounds good. I don’t agree with removing the crusher equipment from the permit since it at one time
was constructed and operated. However, I’ll wait and see what Compliance says and we’ll discuss.
Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:09 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Got it. I will relay this to compliance and see how they want to proceed.

Thanks,
Dungan

On Thu, Jun 6, 2024 at 1:08 PM Kamren Garfield <[e-mail]> wrote:
Geneva Rock does have plans to bring crushing equipment back into the Bacchus Pit in the next
year or two. We want to keep the crushers and aggregate processing in the air permit.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…32/238

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project.

I know you want to get this site under 50 tpy NOx before the northern wasatch front is reclassified to serious non-
attainment for ozone and the major source threshold changes. From my talks with compliance, because all of the
aggregate processing equipment was removed from the site for several years, if you are planning to bring it back
now it will be considered new equipment, require notification, and need to have visible emission observations
conducted. If you aren't planning to bring it back now, my understanding is that it will require another permit
modification if/when the aggregate equipment is brought back in the future.

Let me know what GRP's current plan is for the pit and I will communicate with compliance and adjust the permit
accordingly.

Thanks,
Dungan

On Wed, May 22, 2024 at 4:09 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

During their review our compliance department noted the past two times this site has been inspected it looked
like all aggregate processing equipment had been permanently removed. I've attached the most recent
inspection memo from July 2023.

Do you want to update the equipment list to better account for the equipment on site or does GRP have plans
to bring back aggregate operation?

Thanks,
Dungan

On Wed, May 15, 2024 at 9:50 AM Kamren Garfield <[e-mail]> wrote:
Great, thank you so much!
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…33/238

From: Dungan Adams <[e-mail]>
Sent: Wednesday, May 15, 2024 9:37 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I've removed the hourly production limit. I should have the updated permit for you to review in a couple of
weeks.

Thanks,
Dungan

On Wed, May 8, 2024 at 2:41 PM Dungan Adams <[e-mail]> wrote:
Kamren,

I think we should be able to remove the hourly limit because from my understanding it doesn't have any
impact on annual PTE. I just reached out to our modeling department to see if they have concerns with
the removal of the limit. I will let you know when I hear back from them

Thanks,
Dungan

On Tue, May 7, 2024 at 10:00 AM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher production is very
uncommon. To my knowledge this could be the only permit GRP has with an hourly crusher limit. The
only way to track that would be to tie in a data logger to the belt scale. I don’t think we have ever
modeled that site, so I’m not sure where the hourly limit came from. What would it take to get this
condition removed?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, April 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…34/238

Hi Kamren,

In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the owner/operator
shall not produce more than 2,000,000 tons of aggregates per rolling 12-month period and shall not
produce more than 350 tons of aggregates per hour."

How is the 350 tons per hour limit being monitored and how are records being kept? I'm updating some
of the outdated language in the AO and want to make sure the recordkeeping and monitoring
conditions match whatever GRP is currently doing.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 3:24 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

This looks good to me. I'll let you know if any other questions come up, but I think we should be all
set.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 2:55 PM Kamren Garfield <[e-mail]> wrote:
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 19, 2024 11:35 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and Xylenes emission
factors for Generator 3406. For the CO2e emission factor for Generator 3406, I believe it should
be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline fuel.

I think after those minor changes we should get the same values for HAPs and CO2e. Let me
know if you have any questions.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…35/238

Thanks,
Dungan

On Mon, Mar 18, 2024 at 4:28 PM Kamren Garfield <[e-mail]> wrote:
Dungan,

I agree with your approach. Here are my updated calcs to reflect that. I couldn’t get the HAP
and CO2e emissions to line up exactly with yours. That said, I’m fine with using your calcs if
you want to.

Let me know what you think.
Thanks for your patience on this.

Kamren

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 5:49 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Since the current engines and operation leads to NOx emissions ~12 TPY above the PTE in
the active AO, calculating new emissions by subtracting from this incorrect PTE will not be
accepted. I think the best way to move forward would be this:

As far as I understand there are three (3) point sources of non-PM emissions: the 335
hp generator, the 757 hp generator, and the 4 MMBtu/hr boiler (The 3,000 gal
diesel storage tank produces 0.00 TPY of VOCs). The rest of the equipment produces
only PM emissions. The combustion sources will be recalculated to make sure that NOx
emissions are actually below 50 TPY--the engine operation will need to be 3325 hours
per year in order to meet this requirement.

The PM emissions can be calculated by subtracting the difference between the current
operation and the new operation of the generators. I went through and updated the
calculations I sent over last time. At current production, assuming 335 hp and 757 hp
generators, the PM10 and PM2.5 emissions are 2.85 TPY. At 3325 hours the PM10 and
PM2.5 emissions are 1.73 TPY. So, the operation reduction causes a 1.12 TPY
reduction in PM 10 & 2.5.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…36/238
This allows the NOx PTE to be accurate without emission recalculations for the crushing
operations. Let me know what you think.

On Wed, Mar 13, 2024 at 9:24 AM Kamren Garfield <[e-mail]> wrote:
Thanks for looking into that. My biggest concern with trying to recreate everything in the PM
calcs is I don’t have access to the original application that established the crushing limits
and other assumptions that were made for that AO. So I would be starting from scratch. In
my experience we usually don’t touch any calcs that aren’t associated with the modification.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 9:08 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I have concerns with calculating emissions this way when the PTE in the active AO is
incorrect. That being said, I understand not wanting to redo more emission calculations. Let
me talk with my manager and I will get back to you.

Thanks,
Dungan

On Tue, Mar 12, 2024 at 3:47 PM Kamren Garfield <[e-mail]> wrote:
The gaseous emissions make sense, but if I go with this method means I will also need to
recalculate all the PM emissions associated with the crushing operations to come up with
a new sitewide PM potential to emit. That is why I tried to stay with just showing the
decrease. Can we just assume the PM emissions in the AO are correct and then calculate
what the generator decrease will be and subtract from the total in the current AO?

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project. Have you had a chance to review the emission
calculations from my last email?

Thanks,
Dungan
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…37/238

On Tue, Feb 6, 2024 at 1:57 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

I've looked at the emission calculations you sent and I found them difficult to follow. I
think the calculations assume the PTE for NOx in the active AO is correct and I don't
think it is. Calculating only the emission reduction from the operational change doesn't
take into account the inaccurate PTE in the current AO. I've really quickly put together
some emission calculations that show site-wide combustion PTE for the different
operational hours and engine ratings. I used the emission factors that you listed in the
attachment, but if I am missing something please let me know.

Please take a look and let me know what you think.

Thanks,
Dungan

On Fri, Feb 2, 2024 at 4:44 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
I have revised the calculations to reflect the engine sizes as they are shown in the
current AO. Let me know if this works for you. I had to reduce operation to 3,780 hrs
for each engine to get the required NOx reduction.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 14, 2023 2:10 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Thanks for bringing this up. I see what you are saying, in DAQE-AN0117680001-09
the generators are listed as 250 kW and 565 kW. Then in the current AO, DAQE-
AN117680002-18, the generators are listed as 250 hp and 565 hp.

The current AO (DAQE-AN117680002-18) states each generator shall not exceed
5,470 hours of annual operation. The current AO's emission limit for NOx is 67.99
TPY. When I calculate the emissions for 250 kW and 565 kW engines assuming
5,470 hours of operation, I get 78.09 TPY of NOX which is above the limit in the
current AO. This means the emission limits in the current AO were probably
calculated assuming 250 hp and 565 hp engines.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…38/238

I think the best way to move forward is to redo plant wide emission calculations.
Trying to calculate only the emission reduction (as you submitted in the NOI) is
confusing since the current AO does not correctly list the generators and their
associated emissions. The other viable option would be to redo the generator
emission calculations for the current AO with the 335 hp and 757 hp generators and
then reduce the hours of operations and calculate the correct reduction.

Let me know what you think. I'd be happy to meet if you think that would be helpful.

Thanks,
Dungan

On Fri, Nov 10, 2023 at 12:11 PM Kamren Garfield <[e-mail]>
wrote:
Hi Dungan,

That is a great question, here is what I found while digging through some prior
records.

Approval Order DAQE-AN0117680001-09 (Dated July 28, 2009) listed the
generators as 250 KW and 565 KW. In November 2017 a reduction in emissions
was submitted to DAQ. In those calculations, both the KW and the equivalent hp
(as converted from kw) were expressed in the emission calculations (i.e. 250 KW
= 335 hp & 565 KW = 757 hp). It looks like the subsequent (current) AO was then
written to show the generator size reflected as hp but used the KW number, if that
makes sense. So now the current AO erroneously shows the sizes as 250 hp
and 565 hp when it should be in KW, which would make them the same as 335
hp and 757 hp. This is something that should have been caught during the ER
review but nobody did. Hopefully this makes sense and we can get it corrected in
this revision. I will be out most of next week but can hop on a call next Friday if
you want to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 2, 2023 12:24 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the provided calculations and modification request, Generators 3406 and 3412
are listed as 335 hp and 757 hp respectively. In your current AO (DAQE-
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…39/238
AN117680002-18) the generators are listed as 250 hp and 565 hp. Can you
please clarify if you are changing generators as part of the modification?

The discrepancy generator has caused issues with the emission calculations. You
have calculated the reduction of annual emissions assuming the original
generators were 335 hp and 757 hp, but this is not the case. The annual NOx
emissions for 4200 hours of operation for the 335 hp and 757 hp generators is
59.96 TPY. The annual NOx emissions for 5470 hours of operation for the 335 hp
and 757 hp generators is 78.09 TPY, which is above the limit set in the AO. It's
fine to change the generators in the modification, but you will need to update your
emissions calculations to accurately reflect the change.

I hope this makes sense. Let me know if you have any questions.

Thanks,
Dungan

On Wed, Nov 1, 2023 at 9:58 AM Kamren Garfield <[e-mail]>
wrote:
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West Valley to include
PM2.5 and CO2e. Let me know if you have any questions.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, October 23, 2023 10:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Could you please provide emission calculations and state the emission
reductions for PM2.5 and CO2e? Both of these emissions were included in the
previous AO but were not specified in the minor modification NOI.

Here's a link to the DAQs emission calculation spreadsheets. The diesel
engine and boiler spreadsheets should help with the CO2e calculation. Let me
know if you have any questions.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…40/238
Thanks,
Dungan

On Tue, Oct 10, 2023 at 3:20 PM Kamren Garfield <[e-mail]>
wrote:
Hi Dungan,
Look forward to working with you on this. Yes, I think that’s a good idea.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 10, 2023 2:26 PM
To: Kamren Garfield <[e-mail]>
Subject: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

My name is Dungan and I am working on processing the requested
modifications to the Geneva Rock Products Bacchus Pit. Everything looks
good so far.

You have requested that the manufacturer be removed from the crushers in
the approved equipment section. I think it would be a good idea to remove
the manufacturer from conditions II.A.15, II.A.16, II.A.17, and II.A.18 (Shown
below). I'm not sure why they were included in the first place.

II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron

II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
Manufacturer: El Jay

II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay

II.A.18 One (1) Sand Classifier
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…41/238
Size: 10'x24'
Manufacturer: Eagle Iron Autospec

Let me know if you would like to include this modification.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…42/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…43/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…44/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…45/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…46/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…47/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…48/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…49/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…50/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…51/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

Dungan Adams <[e-mail]>Tue, Jul 2, 2024 at 2:56 PM
To: Kamren Garfield <[e-mail]>
Yes, that is okay with me. Have a nice 4th of July weekend.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Fri, Jul 12, 2024 at 5:05 PM
To: Dungan Adams <[e-mail]>
Dungan,
Tried to get a hold of you and left you a message. Our group was out of town much of this week and I’m still
waiting to hear back from a couple more reviewers. Can you give us until COB Tuesday to send back the
draft ER? Thank you
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, July 2, 2024 2:56 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Yes, that is okay with me. Have a nice 4th of July weekend.

Thanks,
Dungan

On Tue, Jul 2, 2024 at 2:53 PM Kamren Garfield <[e-mail]> wrote:
Dungan, thanks for sending this over. With most everyone out of the office this week for the holiday, can
we have until COB next Friday (July 12) to review the draft ER?

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…52/238
Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 27, 2024 2:01 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and let me know if
you have any questions or concerns. If everything looks good, please sign the cover page and return the document to
me.

Thanks,
Dungan

On Thu, Jun 13, 2024 at 10:32 AM Dungan Adams <[e-mail]> wrote:
Kamren,

The aggregate equipment can definitely stay in the AO since like you say it was at one time constructed and
operated. I just wanted to ask about it in case you didn't have any plans to bring the equipment back in the future.

Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to notify the DAQ
compliance section. GRP will be required to conduct Subpart OOO observations for applicable equipment and CO
emission testing for Subpart ZZZZ-applicable generator engines. GRP will also need to confirm the aggregate
equipment brought back on site is identical to the equipment permitted in their AO.

My manager is reviewing this project and I should have the engineering review for you to review soon. Let me know
if you have any questions or would like to discuss anything further.

Thanks,
Dungan

On Mon, Jun 10, 2024 at 2:02 PM Kamren Garfield <[e-mail]> wrote:
Sounds good. I don’t agree with removing the crusher equipment from the permit since it at one time
was constructed and operated. However, I’ll wait and see what Compliance says and we’ll discuss.
Thanks,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…53/238
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:09 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Got it. I will relay this to compliance and see how they want to proceed.

Thanks,
Dungan

On Thu, Jun 6, 2024 at 1:08 PM Kamren Garfield <[e-mail]> wrote:
Geneva Rock does have plans to bring crushing equipment back into the Bacchus Pit in the next
year or two. We want to keep the crushers and aggregate processing in the air permit.

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project.

I know you want to get this site under 50 tpy NOx before the northern wasatch front is reclassified to serious
non-attainment for ozone and the major source threshold changes. From my talks with compliance, because all
of the aggregate processing equipment was removed from the site for several years, if you are planning to
bring it back now it will be considered new equipment, require notification, and need to have visible emission
observations conducted. If you aren't planning to bring it back now, my understanding is that it will require
another permit modification if/when the aggregate equipment is brought back in the future.

Let me know what GRP's current plan is for the pit and I will communicate with compliance and adjust the
permit accordingly.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…54/238

On Wed, May 22, 2024 at 4:09 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

During their review our compliance department noted the past two times this site has been inspected it
looked like all aggregate processing equipment had been permanently removed. I've attached the most
recent inspection memo from July 2023.

Do you want to update the equipment list to better account for the equipment on site or does GRP have
plans to bring back aggregate operation?

Thanks,
Dungan

On Wed, May 15, 2024 at 9:50 AM Kamren Garfield <[e-mail]> wrote:
Great, thank you so much!

From: Dungan Adams <[e-mail]>
Sent: Wednesday, May 15, 2024 9:37 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I've removed the hourly production limit. I should have the updated permit for you to review in a couple of
weeks.

Thanks,
Dungan

On Wed, May 8, 2024 at 2:41 PM Dungan Adams <[e-mail]> wrote:
Kamren,

I think we should be able to remove the hourly limit because from my understanding it doesn't have any
impact on annual PTE. I just reached out to our modeling department to see if they have concerns with
the removal of the limit. I will let you know when I hear back from them

Thanks,
Dungan
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…55/238

On Tue, May 7, 2024 at 10:00 AM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher production is very
uncommon. To my knowledge this could be the only permit GRP has with an hourly crusher limit.
The only way to track that would be to tie in a data logger to the belt scale. I don’t think we have
ever modeled that site, so I’m not sure where the hourly limit came from. What would it take to get
this condition removed?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, April 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the owner/operator
shall not produce more than 2,000,000 tons of aggregates per rolling 12-month period and shall not
produce more than 350 tons of aggregates per hour."

How is the 350 tons per hour limit being monitored and how are records being kept? I'm updating
some of the outdated language in the AO and want to make sure the recordkeeping and monitoring
conditions match whatever GRP is currently doing.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 3:24 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

This looks good to me. I'll let you know if any other questions come up, but I think we should be
all set.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…56/238
On Tue, Mar 26, 2024 at 2:55 PM Kamren Garfield <[e-mail]> wrote:
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 19, 2024 11:35 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and Xylenes emission
factors for Generator 3406. For the CO2e emission factor for Generator 3406, I believe it
should be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline fuel.

I think after those minor changes we should get the same values for HAPs and CO2e. Let me
know if you have any questions.

Thanks,
Dungan

On Mon, Mar 18, 2024 at 4:28 PM Kamren Garfield <[e-mail]> wrote:
Dungan,

I agree with your approach. Here are my updated calcs to reflect that. I couldn’t get the HAP
and CO2e emissions to line up exactly with yours. That said, I’m fine with using your calcs if
you want to.

Let me know what you think.
Thanks for your patience on this.

Kamren

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 5:49 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…57/238
Hi Kamren,

Since the current engines and operation leads to NOx emissions ~12 TPY above the PTE in
the active AO, calculating new emissions by subtracting from this incorrect PTE will not be
accepted. I think the best way to move forward would be this:

As far as I understand there are three (3) point sources of non-PM emissions: the
335 hp generator, the 757 hp generator, and the 4 MMBtu/hr boiler (The 3,000 gal
diesel storage tank produces 0.00 TPY of VOCs). The rest of the equipment
produces only PM emissions. The combustion sources will be recalculated to make
sure that NOx emissions are actually below 50 TPY--the engine operation will need to
be 3325 hours per year in order to meet this requirement.

The PM emissions can be calculated by subtracting the difference between the
current operation and the new operation of the generators. I went through and
updated the calculations I sent over last time. At current production, assuming 335 hp
and 757 hp generators, the PM10 and PM2.5 emissions are 2.85 TPY. At 3325 hours
the PM10 and PM2.5 emissions are 1.73 TPY. So, the operation reduction causes a
1.12 TPY reduction in PM 10 & 2.5.

This allows the NOx PTE to be accurate without emission recalculations for the crushing
operations. Let me know what you think.

On Wed, Mar 13, 2024 at 9:24 AM Kamren Garfield <[e-mail]> wrote:
Thanks for looking into that. My biggest concern with trying to recreate everything in the
PM calcs is I don’t have access to the original application that established the crushing
limits and other assumptions that were made for that AO. So I would be starting from
scratch. In my experience we usually don’t touch any calcs that aren’t associated with the
modification.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 9:08 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I have concerns with calculating emissions this way when the PTE in the active AO is
incorrect. That being said, I understand not wanting to redo more emission calculations.
Let me talk with my manager and I will get back to you.

Thanks,
Dungan

On Tue, Mar 12, 2024 at 3:47 PM Kamren Garfield <[e-mail]> wrote:
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…58/238
The gaseous emissions make sense, but if I go with this method means I will also need
to recalculate all the PM emissions associated with the crushing operations to come up
with a new sitewide PM potential to emit. That is why I tried to stay with just showing
the decrease. Can we just assume the PM emissions in the AO are correct and then
calculate what the generator decrease will be and subtract from the total in the current
AO?

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project. Have you had a chance to review the emission
calculations from my last email?

Thanks,
Dungan

On Tue, Feb 6, 2024 at 1:57 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

I've looked at the emission calculations you sent and I found them difficult to follow. I
think the calculations assume the PTE for NOx in the active AO is correct and I don't
think it is. Calculating only the emission reduction from the operational change
doesn't take into account the inaccurate PTE in the current AO. I've really quickly put
together some emission calculations that show site-wide combustion PTE for the
different operational hours and engine ratings. I used the emission factors that you
listed in the attachment, but if I am missing something please let me know.

Please take a look and let me know what you think.

Thanks,
Dungan

On Fri, Feb 2, 2024 at 4:44 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
I have revised the calculations to reflect the engine sizes as they are shown in the
current AO. Let me know if this works for you. I had to reduce operation to 3,780
hrs for each engine to get the required NOx reduction.

Thanks,
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…59/238
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 14, 2023 2:10 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Thanks for bringing this up. I see what you are saying, in DAQE-AN0117680001-
09 the generators are listed as 250 kW and 565 kW. Then in the current AO,
DAQE-AN117680002-18, the generators are listed as 250 hp and 565 hp.

The current AO (DAQE-AN117680002-18) states each generator shall not exceed
5,470 hours of annual operation. The current AO's emission limit for NOx is 67.99
TPY. When I calculate the emissions for 250 kW and 565 kW engines assuming
5,470 hours of operation, I get 78.09 TPY of NOX which is above the limit in the
current AO. This means the emission limits in the current AO were probably
calculated assuming 250 hp and 565 hp engines.

I think the best way to move forward is to redo plant wide emission calculations.
Trying to calculate only the emission reduction (as you submitted in the NOI) is
confusing since the current AO does not correctly list the generators and their
associated emissions. The other viable option would be to redo the generator
emission calculations for the current AO with the 335 hp and 757 hp generators
and then reduce the hours of operations and calculate the correct reduction.

Let me know what you think. I'd be happy to meet if you think that would be
helpful.

Thanks,
Dungan

On Fri, Nov 10, 2023 at 12:11 PM Kamren Garfield <[e-mail]>
wrote:
Hi Dungan,

That is a great question, here is what I found while digging through some prior
records.

Approval Order DAQE-AN0117680001-09 (Dated July 28, 2009) listed the
generators as 250 KW and 565 KW. In November 2017 a reduction in
emissions was submitted to DAQ. In those calculations, both the KW and the
equivalent hp (as converted from kw) were expressed in the emission
calculations (i.e. 250 KW = 335 hp & 565 KW = 757 hp). It looks like the
subsequent (current) AO was then written to show the generator size reflected
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…60/238
as hp but used the KW number, if that makes sense. So now the current AO
erroneously shows the sizes as 250 hp and 565 hp when it should be in KW,
which would make them the same as 335 hp and 757 hp. This is something
that should have been caught during the ER review but nobody did. Hopefully
this makes sense and we can get it corrected in this revision. I will be out most
of next week but can hop on a call next Friday if you want to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 2, 2023 12:24 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the provided calculations and modification request, Generators 3406 and
3412 are listed as 335 hp and 757 hp respectively. In your current AO (DAQE-
AN117680002-18) the generators are listed as 250 hp and 565 hp. Can you
please clarify if you are changing generators as part of the modification?

The discrepancy generator has caused issues with the emission calculations.
You have calculated the reduction of annual emissions assuming the original
generators were 335 hp and 757 hp, but this is not the case. The annual NOx
emissions for 4200 hours of operation for the 335 hp and 757 hp generators is
59.96 TPY. The annual NOx emissions for 5470 hours of operation for the 335
hp and 757 hp generators is 78.09 TPY, which is above the limit set in the AO.
It's fine to change the generators in the modification, but you will need to
update your emissions calculations to accurately reflect the change.

I hope this makes sense. Let me know if you have any questions.

Thanks,
Dungan

On Wed, Nov 1, 2023 at 9:58 AM Kamren Garfield <[e-mail]>
wrote:
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West Valley to
include PM2.5 and CO2e. Let me know if you have any questions.

Thanks,
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…61/238
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, October 23, 2023 10:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Could you please provide emission calculations and state the emission
reductions for PM2.5 and CO2e? Both of these emissions were included in
the previous AO but were not specified in the minor modification NOI.

Here's a link to the DAQs emission calculation spreadsheets. The diesel
engine and boiler spreadsheets should help with the CO2e calculation. Let
me know if you have any questions.

Thanks,
Dungan

On Tue, Oct 10, 2023 at 3:20 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,
Look forward to working with you on this. Yes, I think that’s a good idea.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 10, 2023 2:26 PM
To: Kamren Garfield <[e-mail]>
Subject: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

My name is Dungan and I am working on processing the requested
modifications to the Geneva Rock Products Bacchus Pit. Everything
looks good so far.

You have requested that the manufacturer be removed from the crushers
in the approved equipment section. I think it would be a good idea to
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…62/238
remove the manufacturer from conditions II.A.15, II.A.16, II.A.17, and
II.A.18 (Shown below). I'm not sure why they were included in the first
place.

II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron

II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
Manufacturer: El Jay

II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay

II.A.18 One (1) Sand Classifier
Size: 10'x24'
Manufacturer: Eagle Iron Autospec

Let me know if you would like to include this modification.

Thanks,
Dungan

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…63/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…64/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…65/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…66/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…67/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…68/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…69/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…70/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…71/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…72/238
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…73/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

Dungan Adams <[e-mail]>Mon, Jul 15, 2024 at 7:50 AM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
Sorry I missed your call on Friday. EOD Tuesday July 16 for the ER sounds good -- I know this is a popular time for
vacation and the DAQ would really like GRP's comments and concurrence for this type of a modification.
Thanks,
Dungan
[Quoted text hidden]
Kamren Garfield <[e-mail]>Tue, Jul 16, 2024 at 5:11 PM
To: Dungan Adams <[e-mail]>
Cc: Grant Ensign <[e-mail]>
Dungan,
Here are the compiled comments on the draft ER. Nothing too major, let me know if you want to have a call
to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, July 15, 2024 7:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Sorry I missed your call on Friday. EOD Tuesday July 16 for the ER sounds good -- I know this is a popular time for
vacation and the DAQ would really like GRP's comments and concurrence for this type of a modification.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…74/238
On Fri, Jul 12, 2024 at 5:05 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Tried to get a hold of you and left you a message. Our group was out of town much of this week and I’m
still waiting to hear back from a couple more reviewers. Can you give us until COB Tuesday to send back
the draft ER? Thank you
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, July 2, 2024 2:56 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Yes, that is okay with me. Have a nice 4th of July weekend.

Thanks,
Dungan

On Tue, Jul 2, 2024 at 2:53 PM Kamren Garfield <[e-mail]> wrote:
Dungan, thanks for sending this over. With most everyone out of the office this week for the holiday,
can we have until COB next Friday (July 12) to review the draft ER?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 27, 2024 2:01 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and let me know if
you have any questions or concerns. If everything looks good, please sign the cover page and return the document
to me.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…75/238
On Thu, Jun 13, 2024 at 10:32 AM Dungan Adams <[e-mail]> wrote:
Kamren,

The aggregate equipment can definitely stay in the AO since like you say it was at one time constructed and
operated. I just wanted to ask about it in case you didn't have any plans to bring the equipment back in the future.

Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to notify the
DAQ compliance section. GRP will be required to conduct Subpart OOO observations for applicable equipment
and CO emission testing for Subpart ZZZZ-applicable generator engines. GRP will also need to confirm the
aggregate equipment brought back on site is identical to the equipment permitted in their AO.

My manager is reviewing this project and I should have the engineering review for you to review soon. Let me
know if you have any questions or would like to discuss anything further.

Thanks,
Dungan

On Mon, Jun 10, 2024 at 2:02 PM Kamren Garfield <[e-mail]> wrote:
Sounds good. I don’t agree with removing the crusher equipment from the permit since it at one
time was constructed and operated. However, I’ll wait and see what Compliance says and we’ll
discuss. Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:09 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Got it. I will relay this to compliance and see how they want to proceed.

Thanks,
Dungan

On Thu, Jun 6, 2024 at 1:08 PM Kamren Garfield <[e-mail]> wrote:
Geneva Rock does have plans to bring crushing equipment back into the Bacchus Pit in the
next year or two. We want to keep the crushers and aggregate processing in the air permit.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…76/238
From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project.

I know you want to get this site under 50 tpy NOx before the northern wasatch front is reclassified to serious
non-attainment for ozone and the major source threshold changes. From my talks with compliance, because
all of the aggregate processing equipment was removed from the site for several years, if you are planning
to bring it back now it will be considered new equipment, require notification, and need to have visible
emission observations conducted. If you aren't planning to bring it back now, my understanding is that it will
require another permit modification if/when the aggregate equipment is brought back in the future.

Let me know what GRP's current plan is for the pit and I will communicate with compliance and adjust the
permit accordingly.

Thanks,
Dungan

On Wed, May 22, 2024 at 4:09 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

During their review our compliance department noted the past two times this site has been inspected it
looked like all aggregate processing equipment had been permanently removed. I've attached the most
recent inspection memo from July 2023.

Do you want to update the equipment list to better account for the equipment on site or does GRP have
plans to bring back aggregate operation?

Thanks,
Dungan

On Wed, May 15, 2024 at 9:50 AM Kamren Garfield <[e-mail]> wrote:
Great, thank you so much!

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…77/238
From: Dungan Adams <[e-mail]>
Sent: Wednesday, May 15, 2024 9:37 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I've removed the hourly production limit. I should have the updated permit for you to review in a couple
of weeks.

Thanks,
Dungan

On Wed, May 8, 2024 at 2:41 PM Dungan Adams <[e-mail]> wrote:
Kamren,

I think we should be able to remove the hourly limit because from my understanding it doesn't have
any impact on annual PTE. I just reached out to our modeling department to see if they have
concerns with the removal of the limit. I will let you know when I hear back from them

Thanks,
Dungan

On Tue, May 7, 2024 at 10:00 AM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher production is
very uncommon. To my knowledge this could be the only permit GRP has with an hourly crusher
limit. The only way to track that would be to tie in a data logger to the belt scale. I don’t think we
have ever modeled that site, so I’m not sure where the hourly limit came from. What would it take
to get this condition removed?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, April 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…78/238
Hi Kamren,

In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the
owner/operator shall not produce more than 2,000,000 tons of aggregates per rolling 12-month
period and shall not produce more than 350 tons of aggregates per hour."

How is the 350 tons per hour limit being monitored and how are records being kept? I'm updating
some of the outdated language in the AO and want to make sure the recordkeeping and
monitoring conditions match whatever GRP is currently doing.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 3:24 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

This looks good to me. I'll let you know if any other questions come up, but I think we should be
all set.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 2:55 PM Kamren Garfield <[e-mail]> wrote:
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 19, 2024 11:35 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and Xylenes emission
factors for Generator 3406. For the CO2e emission factor for Generator 3406, I believe it
should be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline fuel.

I think after those minor changes we should get the same values for HAPs and CO2e. Let
me know if you have any questions.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…79/238
Thanks,
Dungan

On Mon, Mar 18, 2024 at 4:28 PM Kamren Garfield <[e-mail]> wrote:
Dungan,

I agree with your approach. Here are my updated calcs to reflect that. I couldn’t get the
HAP and CO2e emissions to line up exactly with yours. That said, I’m fine with using your
calcs if you want to.

Let me know what you think.
Thanks for your patience on this.

Kamren

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 5:49 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Since the current engines and operation leads to NOx emissions ~12 TPY above the PTE
in the active AO, calculating new emissions by subtracting from this incorrect PTE will not
be accepted. I think the best way to move forward would be this:

As far as I understand there are three (3) point sources of non-PM emissions: the
335 hp generator, the 757 hp generator, and the 4 MMBtu/hr boiler (The 3,000 gal
diesel storage tank produces 0.00 TPY of VOCs). The rest of the equipment
produces only PM emissions. The combustion sources will be recalculated to
make sure that NOx emissions are actually below 50 TPY--the engine operation
will need to be 3325 hours per year in order to meet this requirement.

The PM emissions can be calculated by subtracting the difference between the
current operation and the new operation of the generators. I went through and
updated the calculations I sent over last time. At current production, assuming 335
hp and 757 hp generators, the PM10 and PM2.5 emissions are 2.85 TPY. At 3325
hours the PM10 and PM2.5 emissions are 1.73 TPY. So, the operation reduction
causes a 1.12 TPY reduction in PM 10 & 2.5.

This allows the NOx PTE to be accurate without emission recalculations for the crushing
operations. Let me know what you think.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…80/238

On Wed, Mar 13, 2024 at 9:24 AM Kamren Garfield <[e-mail]> wrote:
Thanks for looking into that. My biggest concern with trying to recreate everything in
the PM calcs is I don’t have access to the original application that established the
crushing limits and other assumptions that were made for that AO. So I would be
starting from scratch. In my experience we usually don’t touch any calcs that aren’t
associated with the modification.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 9:08 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I have concerns with calculating emissions this way when the PTE in the active AO is
incorrect. That being said, I understand not wanting to redo more emission
calculations. Let me talk with my manager and I will get back to you.

Thanks,
Dungan

On Tue, Mar 12, 2024 at 3:47 PM Kamren Garfield <[e-mail]> wrote:
The gaseous emissions make sense, but if I go with this method means I will also
need to recalculate all the PM emissions associated with the crushing operations to
come up with a new sitewide PM potential to emit. That is why I tried to stay with
just showing the decrease. Can we just assume the PM emissions in the AO are
correct and then calculate what the generator decrease will be and subtract from the
total in the current AO?

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project. Have you had a chance to review the emission
calculations from my last email?

Thanks,
Dungan
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…81/238

On Tue, Feb 6, 2024 at 1:57 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

I've looked at the emission calculations you sent and I found them difficult to
follow. I think the calculations assume the PTE for NOx in the active AO is correct
and I don't think it is. Calculating only the emission reduction from the operational
change doesn't take into account the inaccurate PTE in the current AO. I've really
quickly put together some emission calculations that show site-wide combustion
PTE for the different operational hours and engine ratings. I used the emission
factors that you listed in the attachment, but if I am missing something please let
me know.

Please take a look and let me know what you think.

Thanks,
Dungan

On Fri, Feb 2, 2024 at 4:44 PM Kamren Garfield <[e-mail]>
wrote:
Dungan,
I have revised the calculations to reflect the engine sizes as they are shown in
the current AO. Let me know if this works for you. I had to reduce operation to
3,780 hrs for each engine to get the required NOx reduction.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 14, 2023 2:10 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Thanks for bringing this up. I see what you are saying, in DAQE-
AN0117680001-09 the generators are listed as 250 kW and 565 kW. Then in
the current AO, DAQE-AN117680002-18, the generators are listed as 250 hp
and 565 hp.

The current AO (DAQE-AN117680002-18) states each generator shall not
exceed 5,470 hours of annual operation. The current AO's emission limit for
NOx is 67.99 TPY. When I calculate the emissions for 250 kW and 565 kW
engines assuming 5,470 hours of operation, I get 78.09 TPY of NOX which is
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…82/238
above the limit in the current AO. This means the emission limits in the current
AO were probably calculated assuming 250 hp and 565 hp engines.

I think the best way to move forward is to redo plant wide emission
calculations. Trying to calculate only the emission reduction (as you submitted
in the NOI) is confusing since the current AO does not correctly list the
generators and their associated emissions. The other viable option would be to
redo the generator emission calculations for the current AO with the 335 hp
and 757 hp generators and then reduce the hours of operations and calculate
the correct reduction.

Let me know what you think. I'd be happy to meet if you think that would be
helpful.

Thanks,
Dungan

On Fri, Nov 10, 2023 at 12:11 PM Kamren Garfield <[e-mail]>
wrote:
Hi Dungan,

That is a great question, here is what I found while digging through some
prior records.

Approval Order DAQE-AN0117680001-09 (Dated July 28, 2009) listed the
generators as 250 KW and 565 KW. In November 2017 a reduction in
emissions was submitted to DAQ. In those calculations, both the KW and
the equivalent hp (as converted from kw) were expressed in the emission
calculations (i.e. 250 KW = 335 hp & 565 KW = 757 hp). It looks like the
subsequent (current) AO was then written to show the generator size
reflected as hp but used the KW number, if that makes sense. So now the
current AO erroneously shows the sizes as 250 hp and 565 hp when it
should be in KW, which would make them the same as 335 hp and 757 hp.
This is something that should have been caught during the ER review but
nobody did. Hopefully this makes sense and we can get it corrected in this
revision. I will be out most of next week but can hop on a call next Friday if
you want to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 2, 2023 12:24 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…83/238
Hi Kamren,

In the provided calculations and modification request, Generators 3406 and
3412 are listed as 335 hp and 757 hp respectively. In your current AO
(DAQE-AN117680002-18) the generators are listed as 250 hp and 565 hp.
Can you please clarify if you are changing generators as part of the
modification?

The discrepancy generator has caused issues with the
emission calculations. You have calculated the reduction of annual
emissions assuming the original generators were 335 hp and 757 hp, but
this is not the case. The annual NOx emissions for 4200 hours of operation
for the 335 hp and 757 hp generators is 59.96 TPY. The annual NOx
emissions for 5470 hours of operation for the 335 hp and 757 hp generators
is 78.09 TPY, which is above the limit set in the AO. It's fine to change the
generators in the modification, but you will need to update your emissions
calculations to accurately reflect the change.

I hope this makes sense. Let me know if you have any questions.

Thanks,
Dungan

On Wed, Nov 1, 2023 at 9:58 AM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West Valley to
include PM2.5 and CO2e. Let me know if you have any questions.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, October 23, 2023 10:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Could you please provide emission calculations and state the emission
reductions for PM2.5 and CO2e? Both of these emissions were included
in the previous AO but were not specified in the minor modification NOI.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…84/238
Here's a link to the DAQs emission calculation spreadsheets. The diesel
engine and boiler spreadsheets should help with the CO2e calculation.
Let me know if you have any questions.

Thanks,
Dungan

On Tue, Oct 10, 2023 at 3:20 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,
Look forward to working with you on this. Yes, I think that’s a good
idea.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 10, 2023 2:26 PM
To: Kamren Garfield <[e-mail]>
Subject: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

My name is Dungan and I am working on processing the requested
modifications to the Geneva Rock Products Bacchus Pit. Everything
looks good so far.

You have requested that the manufacturer be removed from the
crushers in the approved equipment section. I think it would be a good
idea to remove the manufacturer from conditions II.A.15, II.A.16,
II.A.17, and II.A.18 (Shown below). I'm not sure why they were
included in the first place.

II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron

II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
Manufacturer: El Jay

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…85/238
II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay

II.A.18 One (1) Sand Classifier
Size: 10'x24'
Manufacturer: Eagle Iron Autospec

Let me know if you would like to include this modification.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…86/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…87/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…88/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…89/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…90/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…91/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…92/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…93/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…94/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…95/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…96/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

GRP. West Valley. COMPILED Comments. Air Quality AO ER for comment 7.16.2024.rtf
1607K
Dungan Adams <[e-mail]>Thu, Jul 18, 2024 at 1:21 PM
To: Kamren Garfield <[e-mail]>
Thanks for sending these over. I am planning to have a response to your comments by the end of the week.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Fri, Jul 19, 2024 at 3:56 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
Attached is the updated ER. Below are my responses to comments, please let me know if you have any questions.
- If GRP wants to remove submerged fill pipes as BACT, I need to see some type of justification as to why they are
infeasible. The DAQ has recently issued an AO which requires submerged fill pipes for new diesel storage tanks of
a similar size.
- The "up to" language for equipment ratings will not be accepted. While I am okay with removing the manufacturer,
etc. to help make the equipment more generic, allowing a range of equipment sizes is not common in AOs. Using a
range of ratings makes it almost impossible to estimate actual site emissions. Future
modifications/amendments would become increasingly challenging and the summary of emissions would no longer
provide a realistic estimate of the permitted equipment. If GRP ends up wanting to use lower rated equipment than
what is permitted when the equipment is brought back, they can apply for a Reduction in Air Pollutants under
R307-401-12. This permit amendment would not go through public comment and is substantially cheaper and
quicker process.
- The boiler is updated to allow for #1 or #2 diesel, natural gas, or propane. The diesel engines are updated to
allow for #1 or #2 diesel.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…97/238
- The "as necessary" language will not be included in watering conditions. Watering shall operate to meet the
opacity limits throughout the permit. If the opacity limits are met, watering does not need to occur. The use of "as
needed" creates room for interpretation and is not necessary language.
- If GRP wants to change the static pressure across the baghouse water column, I need to see something from the
baghouse manufacturer. The standard language DAQ uses now is: "During operation of the baghouse, the
owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for
normal operations." I can switch to that if you provide the manufacturer range.
- Recording engine operation monthly in an operations log would not accurately track engine usage. How do you
know how many total hours an engine has run each month if you do not track daily operation? If you keep track of
engine operation in some other way, I can update recordkeeping to monthly.
If you would like to meet to discuss anything I am happy to do so.
Thanks,
Dungan
[Quoted text hidden]
RN117680003 updated w GRP comments.rtf
1606K
Kamren Garfield <[e-mail]>Tue, Jul 30, 2024 at 5:15 PM
To: Dungan Adams <[e-mail]>
Dungan,

Thanks for the explanations, see my responses to your email below in red.

Also a couple things I just noticed:
Can you combine Approved Equipment items II.A.5 & 6 to just say Four (4) Triple Deck Screens?
II.B.5.d is only supposed to say generators (remove boilers)
Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, July 19, 2024 3:57 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the updated ER. Below are my responses to comments, please let me know if you have any questions.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…98/238
- If GRP wants to remove submerged fill pipes as BACT, I need to see some type of justification as to why they are
infeasible. The DAQ has recently issued an AO which requires submerged fill pipes for new diesel storage tanks of
a similar size.
The main justification against submerged fill pipes is the cost of implementation vs the minimal
reduction of VOC emissions. VOC emissions from all 5 tanks combined is 0.02 tons per year.
According to EPA studies done at bulk gasoline plants, submerged filling provides a VOC reduction of
22%. Submerged fill pipes would lead to a VOC reduction of approximately .0044 tons sitewide per
year. I haven’t done a deep dive into a cost analysis for retrofit fill pipes, but to evacuate and nitrogen
purge a tank with the proper pipe install I think $1,500 per tank would be a starting point. I know DAQ
doesn’t have a published threshold of what constitutes a control as economically feasible, but that
puts submerged fill pipes at a cost of $34,090 per ton of VOC removal, projected over 10 years. This
figure is 3-4x dollar values for past controls deemed economically feasible by DAQ.

- The "up to" language for equipment ratings will not be accepted. While I am okay with removing the manufacturer,
etc. to help make the equipment more generic, allowing a range of equipment sizes is not common in AOs. Using a
range of ratings makes it almost impossible to estimate actual site emissions. Future
modifications/amendments would become increasingly challenging and the summary of emissions would no longer
provide a realistic estimate of the permitted equipment. If GRP ends up wanting to use lower rated equipment than
what is permitted when the equipment is brought back, they can apply for a Reduction in Air Pollutants under
R307-401-12. This permit amendment would not go through public comment and is substantially cheaper and
quicker process.
Noted, shouldn’t be a problem.

- The boiler is updated to allow for #1 or #2 diesel, natural gas, or propane. The diesel engines are updated to
allow for #1 or #2 diesel.
Perfect, thank you.

- The "as necessary" language will not be included in watering conditions. Watering shall operate to meet the
opacity limits throughout the permit. If the opacity limits are met, watering does not need to occur. The use of "as
needed" creates room for interpretation and is not necessary language.
Fair enough.

- If GRP wants to change the static pressure across the baghouse water column, I need to see something from the
baghouse manufacturer. The standard language DAQ uses now is: "During operation of the baghouse, the
owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for
normal operations." I can switch to that if you provide the manufacturer range.
Pending; I’m waiting on some information on the baghouse specs for this item. Please give me a couple days to
see what I can find from the manufacturer, I will get back to you on this.

- Recording engine operation monthly in an operations log would not accurately track engine usage. How do you
know how many total hours an engine has run each month if you do not track daily operation? If you keep track of
engine operation in some other way, I can update recordkeeping to monthly.
Each engine and the boiler have/will have a non-resettable hour meter that is recorded monthly to
determine hours of operation.

If you would like to meet to discuss anything I am happy to do so.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-394115020094…99/238
Thanks,
Dungan

On Thu, Jul 18, 2024 at 1:21 PM Dungan Adams <[e-mail]> wrote:
Thanks for sending these over. I am planning to have a response to your comments by the end of the week.

Thanks,
Dungan

On Tue, Jul 16, 2024 at 5:11 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Here are the compiled comments on the draft ER. Nothing too major, let me know if you want to have a
call to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, July 15, 2024 7:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Sorry I missed your call on Friday. EOD Tuesday July 16 for the ER sounds good -- I know this is a popular time for
vacation and the DAQ would really like GRP's comments and concurrence for this type of a modification.

Thanks,
Dungan

On Fri, Jul 12, 2024 at 5:05 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Tried to get a hold of you and left you a message. Our group was out of town much of this week and
I’m still waiting to hear back from a couple more reviewers. Can you give us until COB Tuesday to
send back the draft ER? Thank you
Kamren

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…100/238
From: Dungan Adams <[e-mail]>
Sent: Tuesday, July 2, 2024 2:56 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Yes, that is okay with me. Have a nice 4th of July weekend.

Thanks,
Dungan

On Tue, Jul 2, 2024 at 2:53 PM Kamren Garfield <[e-mail]> wrote:
Dungan, thanks for sending this over. With most everyone out of the office this week for the
holiday, can we have until COB next Friday (July 12) to review the draft ER?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 27, 2024 2:01 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and let me
know if you have any questions or concerns. If everything looks good, please sign the cover page and return
the document to me.

Thanks,
Dungan

On Thu, Jun 13, 2024 at 10:32 AM Dungan Adams <[e-mail]> wrote:
Kamren,

The aggregate equipment can definitely stay in the AO since like you say it was at one time constructed and
operated. I just wanted to ask about it in case you didn't have any plans to bring the equipment back in the
future.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…101/238
Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to notify
the DAQ compliance section. GRP will be required to conduct Subpart OOO observations for applicable
equipment and CO emission testing for Subpart ZZZZ-applicable generator engines. GRP will also need to
confirm the aggregate equipment brought back on site is identical to the equipment permitted in their AO.

My manager is reviewing this project and I should have the engineering review for you to review soon. Let
me know if you have any questions or would like to discuss anything further.

Thanks,
Dungan

On Mon, Jun 10, 2024 at 2:02 PM Kamren Garfield <[e-mail]> wrote:
Sounds good. I don’t agree with removing the crusher equipment from the permit since it at
one time was constructed and operated. However, I’ll wait and see what Compliance says
and we’ll discuss. Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:09 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Got it. I will relay this to compliance and see how they want to proceed.

Thanks,
Dungan

On Thu, Jun 6, 2024 at 1:08 PM Kamren Garfield <[e-mail]> wrote:
Geneva Rock does have plans to bring crushing equipment back into the Bacchus Pit in the
next year or two. We want to keep the crushers and aggregate processing in the air permit.

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…102/238
I am following up about this project.

I know you want to get this site under 50 tpy NOx before the northern wasatch front is reclassified to
serious non-attainment for ozone and the major source threshold changes. From my talks with
compliance, because all of the aggregate processing equipment was removed from the site for several
years, if you are planning to bring it back now it will be considered new equipment, require notification,
and need to have visible emission observations conducted. If you aren't planning to bring it back now,
my understanding is that it will require another permit modification if/when the aggregate equipment is
brought back in the future.

Let me know what GRP's current plan is for the pit and I will communicate with compliance and adjust
the permit accordingly.

Thanks,
Dungan

On Wed, May 22, 2024 at 4:09 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

During their review our compliance department noted the past two times this site has been
inspected it looked like all aggregate processing equipment had been permanently removed. I've
attached the most recent inspection memo from July 2023.

Do you want to update the equipment list to better account for the equipment on site or does GRP
have plans to bring back aggregate operation?

Thanks,
Dungan

On Wed, May 15, 2024 at 9:50 AM Kamren Garfield <[e-mail]> wrote:
Great, thank you so much!

From: Dungan Adams <[e-mail]>
Sent: Wednesday, May 15, 2024 9:37 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…103/238
I've removed the hourly production limit. I should have the updated permit for you to review in a
couple of weeks.

Thanks,
Dungan

On Wed, May 8, 2024 at 2:41 PM Dungan Adams <[e-mail]> wrote:
Kamren,

I think we should be able to remove the hourly limit because from my understanding it doesn't
have any impact on annual PTE. I just reached out to our modeling department to see if they
have concerns with the removal of the limit. I will let you know when I hear back from them

Thanks,
Dungan

On Tue, May 7, 2024 at 10:00 AM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher
production is very uncommon. To my knowledge this could be the only permit GRP has with
an hourly crusher limit. The only way to track that would be to tie in a data logger to the belt
scale. I don’t think we have ever modeled that site, so I’m not sure where the hourly limit
came from. What would it take to get this condition removed?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, April 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the
owner/operator shall not produce more than 2,000,000 tons of aggregates per rolling 12-
month period and shall not produce more than 350 tons of aggregates per hour."

How is the 350 tons per hour limit being monitored and how are records being kept? I'm
updating some of the outdated language in the AO and want to make sure the
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…104/238
recordkeeping and monitoring conditions match whatever GRP is currently doing.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 3:24 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

This looks good to me. I'll let you know if any other questions come up, but I think we
should be all set.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 2:55 PM Kamren Garfield <[e-mail]> wrote:
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 19, 2024 11:35 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and Xylenes
emission factors for Generator 3406. For the CO2e emission factor for Generator
3406, I believe it should be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline fuel.

I think after those minor changes we should get the same values for HAPs and CO2e.
Let me know if you have any questions.

Thanks,
Dungan

On Mon, Mar 18, 2024 at 4:28 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…105/238

I agree with your approach. Here are my updated calcs to reflect that. I couldn’t get
the HAP and CO2e emissions to line up exactly with yours. That said, I’m fine with
using your calcs if you want to.

Let me know what you think.
Thanks for your patience on this.

Kamren

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 5:49 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Since the current engines and operation leads to NOx emissions ~12 TPY above the
PTE in the active AO, calculating new emissions by subtracting from this incorrect
PTE will not be accepted. I think the best way to move forward would be this:

As far as I understand there are three (3) point sources of non-PM emissions:
the 335 hp generator, the 757 hp generator, and the 4 MMBtu/hr boiler (The
3,000 gal diesel storage tank produces 0.00 TPY of VOCs). The rest of the
equipment produces only PM emissions. The combustion sources will be
recalculated to make sure that NOx emissions are actually below 50 TPY--the
engine operation will need to be 3325 hours per year in order to meet this
requirement.

The PM emissions can be calculated by subtracting the difference between
the current operation and the new operation of the generators. I went through
and updated the calculations I sent over last time. At current production,
assuming 335 hp and 757 hp generators, the PM10 and PM2.5 emissions
are 2.85 TPY. At 3325 hours the PM10 and PM2.5 emissions are 1.73 TPY.
So, the operation reduction causes a 1.12 TPY reduction in PM 10 & 2.5.

This allows the NOx PTE to be accurate without emission recalculations for the
crushing operations. Let me know what you think.

On Wed, Mar 13, 2024 at 9:24 AM Kamren Garfield <[e-mail]>
wrote:
Thanks for looking into that. My biggest concern with trying to recreate
everything in the PM calcs is I don’t have access to the original application that
established the crushing limits and other assumptions that were made for that
AO. So I would be starting from scratch. In my experience we usually don’t touch
any calcs that aren’t associated with the modification.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…106/238

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 9:08 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I have concerns with calculating emissions this way when the PTE in the active
AO is incorrect. That being said, I understand not wanting to redo more emission
calculations. Let me talk with my manager and I will get back to you.

Thanks,
Dungan

On Tue, Mar 12, 2024 at 3:47 PM Kamren Garfield <[e-mail]>
wrote:
The gaseous emissions make sense, but if I go with this method means I will
also need to recalculate all the PM emissions associated with the crushing
operations to come up with a new sitewide PM potential to emit. That is why I
tried to stay with just showing the decrease. Can we just assume the PM
emissions in the AO are correct and then calculate what the generator
decrease will be and subtract from the total in the current AO?

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project. Have you had a chance to review the
emission calculations from my last email?

Thanks,
Dungan

On Tue, Feb 6, 2024 at 1:57 PM Dungan Adams <[e-mail]>
wrote:
Hi Kamren,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…107/238
I've looked at the emission calculations you sent and I found them difficult to
follow. I think the calculations assume the PTE for NOx in the active AO is
correct and I don't think it is. Calculating only the emission reduction from
the operational change doesn't take into account the inaccurate PTE in the
current AO. I've really quickly put together some emission calculations that
show site-wide combustion PTE for the different operational hours and
engine ratings. I used the emission factors that you listed in the attachment,
but if I am missing something please let me know.

Please take a look and let me know what you think.

Thanks,
Dungan

On Fri, Feb 2, 2024 at 4:44 PM Kamren Garfield <[e-mail]>
wrote:
Dungan,
I have revised the calculations to reflect the engine sizes as they are
shown in the current AO. Let me know if this works for you. I had to
reduce operation to 3,780 hrs for each engine to get the required NOx
reduction.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 14, 2023 2:10 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Thanks for bringing this up. I see what you are saying, in DAQE-
AN0117680001-09 the generators are listed as 250 kW and 565 kW.
Then in the current AO, DAQE-AN117680002-18, the generators are
listed as 250 hp and 565 hp.

The current AO (DAQE-AN117680002-18) states each generator shall not
exceed 5,470 hours of annual operation. The current AO's emission limit
for NOx is 67.99 TPY. When I calculate the emissions for 250 kW and
565 kW engines assuming 5,470 hours of operation, I get 78.09 TPY of
NOX which is above the limit in the current AO. This means the emission
limits in the current AO were probably calculated assuming 250 hp and
565 hp engines.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…108/238
I think the best way to move forward is to redo plant wide emission
calculations. Trying to calculate only the emission reduction (as you
submitted in the NOI) is confusing since the current AO does not correctly
list the generators and their associated emissions. The other viable option
would be to redo the generator emission calculations for the current AO
with the 335 hp and 757 hp generators and then reduce the hours of
operations and calculate the correct reduction.

Let me know what you think. I'd be happy to meet if you think that would
be helpful.

Thanks,
Dungan

On Fri, Nov 10, 2023 at 12:11 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

That is a great question, here is what I found while digging through
some prior records.

Approval Order DAQE-AN0117680001-09 (Dated July 28, 2009) listed
the generators as 250 KW and 565 KW. In November 2017 a
reduction in emissions was submitted to DAQ. In those calculations,
both the KW and the equivalent hp (as converted from kw) were
expressed in the emission calculations (i.e. 250 KW = 335 hp & 565
KW = 757 hp). It looks like the subsequent (current) AO was then
written to show the generator size reflected as hp but used the KW
number, if that makes sense. So now the current AO erroneously
shows the sizes as 250 hp and 565 hp when it should be in KW, which
would make them the same as 335 hp and 757 hp. This is something
that should have been caught during the ER review but nobody did.
Hopefully this makes sense and we can get it corrected in this
revision. I will be out most of next week but can hop on a call next
Friday if you want to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 2, 2023 12:24 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…109/238
In the provided calculations and modification request, Generators 3406
and 3412 are listed as 335 hp and 757 hp respectively. In your current
AO (DAQE-AN117680002-18) the generators are listed as 250 hp and
565 hp. Can you please clarify if you are changing generators as part
of the modification?

The discrepancy generator has caused issues with the
emission calculations. You have calculated the reduction of annual
emissions assuming the original generators were 335 hp and 757 hp,
but this is not the case. The annual NOx emissions for 4200 hours of
operation for the 335 hp and 757 hp generators is 59.96 TPY. The
annual NOx emissions for 5470 hours of operation for the 335 hp and
757 hp generators is 78.09 TPY, which is above the limit set in the AO.
It's fine to change the generators in the modification, but you will need
to update your emissions calculations to accurately reflect the change.

I hope this makes sense. Let me know if you have any questions.

Thanks,
Dungan

On Wed, Nov 1, 2023 at 9:58 AM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West Valley
to include PM2.5 and CO2e. Let me know if you have any
questions.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, October 23, 2023 10:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Could you please provide emission calculations and state the
emission reductions for PM2.5 and CO2e? Both of these emissions
were included in the previous AO but were not specified in the minor
modification NOI.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…110/238
Here's a link to the DAQs emission calculation spreadsheets. The
diesel engine and boiler spreadsheets should help with the CO2e
calculation. Let me know if you have any questions.

Thanks,
Dungan

On Tue, Oct 10, 2023 at 3:20 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,
Look forward to working with you on this. Yes, I think that’s a
good idea.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 10, 2023 2:26 PM
To: Kamren Garfield <[e-mail]>
Subject: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

My name is Dungan and I am working on processing the
requested modifications to the Geneva Rock Products Bacchus
Pit. Everything looks good so far.

You have requested that the manufacturer be removed from the
crushers in the approved equipment section. I think it would be a
good idea to remove the manufacturer from conditions II.A.15,
II.A.16, II.A.17, and II.A.18 (Shown below). I'm not sure why they
were included in the first place.

II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron

II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
Manufacturer: El Jay

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…111/238
II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay

II.A.18 One (1) Sand Classifier
Size: 10'x24'
Manufacturer: Eagle Iron Autospec

Let me know if you would like to include this modification.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…112/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…113/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…114/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…115/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…116/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…117/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…118/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…119/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…120/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…121/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…122/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…123/238
--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

Dungan Adams <[e-mail]>Fri, Aug 2, 2024 at 1:21 PM
To: Kamren Garfield <[e-mail]>
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…124/238
Hi Kamren,
Let me know whenever you have the information about the baghouses and I will update the permit accordingly. I have
changed the engine conditions to include the non-resettable meter and have monthly recordkeeping. I've also updated the
permit to have four (4) triple deck screens and fixed the boiler mistake in II.B.5.d.
My main concern with the BACT justification you have provided is that the submerged fill piping is BACT for new tanks.
The new tanks are not yet permitted to be on site and should not be full of diesel. The cost of purging diesel and cleaning
the tanks should not be included in any economic justification as this is proposed control for new tanks. Let me know if
you have any questions about this.
Thanks,
Dungan
[Quoted text hidden]

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
Dungan Adams <[e-mail]>Tue, Sep 3, 2024 at 11:53 AM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
Any update on the baghouse information?
Thanks,
Dungan
On Fri, Aug 2, 2024 at 1:21 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,
Let me know whenever you have the information about the baghouses and I will update the permit accordingly. I have
changed the engine conditions to include the non-resettable meter and have monthly recordkeeping. I've also updated
the permit to have four (4) triple deck screens and fixed the boiler mistake in II.B.5.d.
My main concern with the BACT justification you have provided is that the submerged fill piping is BACT for new tanks.
The new tanks are not yet permitted to be on site and should not be full of diesel. The cost of purging diesel and
cleaning the tanks should not be included in any economic justification as this is proposed control for new tanks. Let me
know if you have any questions about this.
Thanks,
Dungan
On Tue, Jul 30, 2024 at 5:15 PM Kamren Garfield <[e-mail]> wrote:
Dungan,

Thanks for the explanations, see my responses to your email below in red.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…125/238

Also a couple things I just noticed:
Can you combine Approved Equipment items II.A.5 & 6 to just say Four (4) Triple Deck Screens?
II.B.5.d is only supposed to say generators (remove boilers)
Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, July 19, 2024 3:57 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the updated ER. Below are my responses to comments, please let me know if you have any questions.

- If GRP wants to remove submerged fill pipes as BACT, I need to see some type of justification as to why they
are infeasible. The DAQ has recently issued an AO which requires submerged fill pipes for new
diesel storage tanks of a similar size.
The main justification against submerged fill pipes is the cost of implementation vs the minimal
reduction of VOC emissions. VOC emissions from all 5 tanks combined is 0.02 tons per year.
According to EPA studies done at bulk gasoline plants, submerged filling provides a VOC
reduction of 22%. Submerged fill pipes would lead to a VOC reduction of approximately .0044
tons sitewide per year. I haven’t done a deep dive into a cost analysis for retrofit fill pipes, but to
evacuate and nitrogen purge a tank with the proper pipe install I think $1,500 per tank would be a
starting point. I know DAQ doesn’t have a published threshold of what constitutes a control as
economically feasible, but that puts submerged fill pipes at a cost of $34,090 per ton of VOC
removal, projected over 10 years. This figure is 3-4x dollar values for past controls deemed
economically feasible by DAQ.

- The "up to" language for equipment ratings will not be accepted. While I am okay with removing the
manufacturer, etc. to help make the equipment more generic, allowing a range of equipment sizes is not
common in AOs. Using a range of ratings makes it almost impossible to estimate actual site emissions. Future
modifications/amendments would become increasingly challenging and the summary of emissions would no
longer provide a realistic estimate of the permitted equipment. If GRP ends up wanting to use lower rated
equipment than what is permitted when the equipment is brought back, they can apply for a Reduction in Air
Pollutants under R307-401-12. This permit amendment would not go through public comment and is
substantially cheaper and quicker process.
Noted, shouldn’t be a problem.

- The boiler is updated to allow for #1 or #2 diesel, natural gas, or propane. The diesel engines are updated to
allow for #1 or #2 diesel.
Perfect, thank you.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…126/238

- The "as necessary" language will not be included in watering conditions. Watering shall operate to meet the
opacity limits throughout the permit. If the opacity limits are met, watering does not need to occur. The use of
"as needed" creates room for interpretation and is not necessary language.
Fair enough.

- If GRP wants to change the static pressure across the baghouse water column, I need to see something
from the baghouse manufacturer. The standard language DAQ uses now is: "During operation of the
baghouse, the owner/operator shall maintain the static pressure drop within the range recommended by the
manufacturer for normal operations." I can switch to that if you provide the manufacturer range.
Pending; I’m waiting on some information on the baghouse specs for this item. Please give me a couple days
to see what I can find from the manufacturer, I will get back to you on this.

- Recording engine operation monthly in an operations log would not accurately track engine usage. How do
you know how many total hours an engine has run each month if you do not track daily operation? If you keep
track of engine operation in some other way, I can update recordkeeping to monthly.
Each engine and the boiler have/will have a non-resettable hour meter that is recorded monthly to
determine hours of operation.

If you would like to meet to discuss anything I am happy to do so.

Thanks,
Dungan

On Thu, Jul 18, 2024 at 1:21 PM Dungan Adams <[e-mail]> wrote:
Thanks for sending these over. I am planning to have a response to your comments by the end of the week.

Thanks,
Dungan

On Tue, Jul 16, 2024 at 5:11 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Here are the compiled comments on the draft ER. Nothing too major, let me know if you want to
have a call to discuss.

Thanks,
Kamren

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…127/238
From: Dungan Adams <[e-mail]>
Sent: Monday, July 15, 2024 7:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Sorry I missed your call on Friday. EOD Tuesday July 16 for the ER sounds good -- I know this is a popular time
for vacation and the DAQ would really like GRP's comments and concurrence for this type of a modification.

Thanks,
Dungan

On Fri, Jul 12, 2024 at 5:05 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Tried to get a hold of you and left you a message. Our group was out of town much of this week
and I’m still waiting to hear back from a couple more reviewers. Can you give us until COB
Tuesday to send back the draft ER? Thank you
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, July 2, 2024 2:56 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Yes, that is okay with me. Have a nice 4th of July weekend.

Thanks,
Dungan

On Tue, Jul 2, 2024 at 2:53 PM Kamren Garfield <[e-mail]> wrote:
Dungan, thanks for sending this over. With most everyone out of the office this week for the
holiday, can we have until COB next Friday (July 12) to review the draft ER?

Thanks,
Kamren

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…128/238
From: Dungan Adams <[e-mail]>
Sent: Thursday, June 27, 2024 2:01 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and let
me know if you have any questions or concerns. If everything looks good, please sign the cover page and
return the document to me.

Thanks,
Dungan

On Thu, Jun 13, 2024 at 10:32 AM Dungan Adams <[e-mail]> wrote:
Kamren,

The aggregate equipment can definitely stay in the AO since like you say it was at one time constructed
and operated. I just wanted to ask about it in case you didn't have any plans to bring the equipment
back in the future.

Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to
notify the DAQ compliance section. GRP will be required to conduct Subpart OOO observations for
applicable equipment and CO emission testing for Subpart ZZZZ-applicable generator engines. GRP
will also need to confirm the aggregate equipment brought back on site is identical to the equipment
permitted in their AO.

My manager is reviewing this project and I should have the engineering review for you to review soon.
Let me know if you have any questions or would like to discuss anything further.

Thanks,
Dungan

On Mon, Jun 10, 2024 at 2:02 PM Kamren Garfield <[e-mail]> wrote:
Sounds good. I don’t agree with removing the crusher equipment from the permit since it
at one time was constructed and operated. However, I’ll wait and see what Compliance
says and we’ll discuss. Thanks,

Kamren

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…129/238
From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:09 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Got it. I will relay this to compliance and see how they want to proceed.

Thanks,
Dungan

On Thu, Jun 6, 2024 at 1:08 PM Kamren Garfield <[e-mail]> wrote:
Geneva Rock does have plans to bring crushing equipment back into the Bacchus Pit
in the next year or two. We want to keep the crushers and aggregate processing in the
air permit.

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project.

I know you want to get this site under 50 tpy NOx before the northern wasatch front is reclassified
to serious non-attainment for ozone and the major source threshold changes. From my talks with
compliance, because all of the aggregate processing equipment was removed from the site for
several years, if you are planning to bring it back now it will be considered new equipment, require
notification, and need to have visible emission observations conducted. If you aren't planning to
bring it back now, my understanding is that it will require another permit modification if/when the
aggregate equipment is brought back in the future.

Let me know what GRP's current plan is for the pit and I will communicate with compliance and
adjust the permit accordingly.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…130/238
On Wed, May 22, 2024 at 4:09 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

During their review our compliance department noted the past two times this site has been
inspected it looked like all aggregate processing equipment had been permanently removed.
I've attached the most recent inspection memo from July 2023.

Do you want to update the equipment list to better account for the equipment on site or does
GRP have plans to bring back aggregate operation?

Thanks,
Dungan

On Wed, May 15, 2024 at 9:50 AM Kamren Garfield <[e-mail]> wrote:
Great, thank you so much!

From: Dungan Adams <[e-mail]>
Sent: Wednesday, May 15, 2024 9:37 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I've removed the hourly production limit. I should have the updated permit for you to review in
a couple of weeks.

Thanks,
Dungan

On Wed, May 8, 2024 at 2:41 PM Dungan Adams <[e-mail]> wrote:
Kamren,

I think we should be able to remove the hourly limit because from my understanding it
doesn't have any impact on annual PTE. I just reached out to our modeling department to
see if they have concerns with the removal of the limit. I will let you know when I hear back
from them

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…131/238
On Tue, May 7, 2024 at 10:00 AM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher
production is very uncommon. To my knowledge this could be the only permit GRP has
with an hourly crusher limit. The only way to track that would be to tie in a data logger to
the belt scale. I don’t think we have ever modeled that site, so I’m not sure where the
hourly limit came from. What would it take to get this condition removed?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, April 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the
owner/operator shall not produce more than 2,000,000 tons of aggregates per rolling
12-month period and shall not produce more than 350 tons of aggregates per hour."

How is the 350 tons per hour limit being monitored and how are records being kept? I'm
updating some of the outdated language in the AO and want to make sure the
recordkeeping and monitoring conditions match whatever GRP is currently doing.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 3:24 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

This looks good to me. I'll let you know if any other questions come up, but I think we
should be all set.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 2:55 PM Kamren Garfield <[e-mail]> wrote:
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…132/238
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 19, 2024 11:35 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and Xylenes
emission factors for Generator 3406. For the CO2e emission factor for Generator
3406, I believe it should be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline fuel.

I think after those minor changes we should get the same values for HAPs and
CO2e. Let me know if you have any questions.

Thanks,
Dungan

On Mon, Mar 18, 2024 at 4:28 PM Kamren Garfield <[e-mail]>
wrote:
Dungan,

I agree with your approach. Here are my updated calcs to reflect that. I couldn’t
get the HAP and CO2e emissions to line up exactly with yours. That said, I’m
fine with using your calcs if you want to.

Let me know what you think.
Thanks for your patience on this.

Kamren

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 5:49 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…133/238
Hi Kamren,

Since the current engines and operation leads to NOx emissions ~12 TPY
above the PTE in the active AO, calculating new emissions by subtracting from
this incorrect PTE will not be accepted. I think the best way to move forward
would be this:

As far as I understand there are three (3) point sources of non-PM
emissions: the 335 hp generator, the 757 hp generator, and the 4
MMBtu/hr boiler (The 3,000 gal diesel storage tank produces 0.00 TPY
of VOCs). The rest of the equipment produces only PM emissions. The
combustion sources will be recalculated to make sure that NOx
emissions are actually below 50 TPY--the engine operation will need to
be 3325 hours per year in order to meet this requirement.

The PM emissions can be calculated by subtracting the difference
between the current operation and the new operation of the generators. I
went through and updated the calculations I sent over last time. At
current production, assuming 335 hp and 757 hp generators, the PM10
and PM2.5 emissions are 2.85 TPY. At 3325 hours the PM10 and PM2.5
emissions are 1.73 TPY. So, the operation reduction causes a 1.12 TPY
reduction in PM 10 & 2.5.

This allows the NOx PTE to be accurate without emission recalculations for the
crushing operations. Let me know what you think.

On Wed, Mar 13, 2024 at 9:24 AM Kamren Garfield <[e-mail]>
wrote:
Thanks for looking into that. My biggest concern with trying to recreate
everything in the PM calcs is I don’t have access to the original application
that established the crushing limits and other assumptions that were made
for that AO. So I would be starting from scratch. In my experience we usually
don’t touch any calcs that aren’t associated with the modification.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 9:08 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I have concerns with calculating emissions this way when the PTE in the
active AO is incorrect. That being said, I understand not wanting to redo
more emission calculations. Let me talk with my manager and I will get back
to you.

Thanks,
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…134/238
Dungan

On Tue, Mar 12, 2024 at 3:47 PM Kamren Garfield
<[e-mail]> wrote:
The gaseous emissions make sense, but if I go with this method means I
will also need to recalculate all the PM emissions associated with the
crushing operations to come up with a new sitewide PM potential to emit.
That is why I tried to stay with just showing the decrease. Can we just
assume the PM emissions in the AO are correct and then calculate what
the generator decrease will be and subtract from the total in the current
AO?

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project. Have you had a chance to review the
emission calculations from my last email?

Thanks,
Dungan

On Tue, Feb 6, 2024 at 1:57 PM Dungan Adams
<[e-mail]> wrote:
Hi Kamren,

I've looked at the emission calculations you sent and I found
them difficult to follow. I think the calculations assume the PTE for NOx
in the active AO is correct and I don't think it is. Calculating only the
emission reduction from the operational change doesn't take into
account the inaccurate PTE in the current AO. I've really quickly put
together some emission calculations that show site-wide combustion
PTE for the different operational hours and engine ratings. I used the
emission factors that you listed in the attachment, but if I am missing
something please let me know.

Please take a look and let me know what you think.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…135/238
On Fri, Feb 2, 2024 at 4:44 PM Kamren Garfield
<[e-mail]> wrote:
Dungan,
I have revised the calculations to reflect the engine sizes as they are
shown in the current AO. Let me know if this works for you. I had to
reduce operation to 3,780 hrs for each engine to get the required
NOx reduction.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 14, 2023 2:10 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Thanks for bringing this up. I see what you are saying, in DAQE-
AN0117680001-09 the generators are listed as 250 kW and 565 kW.
Then in the current AO, DAQE-AN117680002-18, the generators are
listed as 250 hp and 565 hp.

The current AO (DAQE-AN117680002-18) states each generator
shall not exceed 5,470 hours of annual operation. The current AO's
emission limit for NOx is 67.99 TPY. When I calculate the emissions
for 250 kW and 565 kW engines assuming 5,470 hours of operation,
I get 78.09 TPY of NOX which is above the limit in the current AO.
This means the emission limits in the current AO were probably
calculated assuming 250 hp and 565 hp engines.

I think the best way to move forward is to redo plant wide emission
calculations. Trying to calculate only the emission reduction (as you
submitted in the NOI) is confusing since the current AO does not
correctly list the generators and their associated emissions. The
other viable option would be to redo the generator emission
calculations for the current AO with the 335 hp and 757 hp
generators and then reduce the hours of operations and calculate
the correct reduction.

Let me know what you think. I'd be happy to meet if you think that
would be helpful.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…136/238
On Fri, Nov 10, 2023 at 12:11 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

That is a great question, here is what I found while digging
through some prior records.

Approval Order DAQE-AN0117680001-09 (Dated July 28, 2009)
listed the generators as 250 KW and 565 KW. In November 2017
a reduction in emissions was submitted to DAQ. In those
calculations, both the KW and the equivalent hp (as converted
from kw) were expressed in the emission calculations (i.e. 250 KW
= 335 hp & 565 KW = 757 hp). It looks like the subsequent
(current) AO was then written to show the generator size reflected
as hp but used the KW number, if that makes sense. So now the
current AO erroneously shows the sizes as 250 hp and 565 hp
when it should be in KW, which would make them the same as
335 hp and 757 hp. This is something that should have been
caught during the ER review but nobody did. Hopefully this makes
sense and we can get it corrected in this revision. I will be out
most of next week but can hop on a call next Friday if you want to
discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 2, 2023 12:24 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the provided calculations and modification request, Generators
3406 and 3412 are listed as 335 hp and 757 hp respectively. In
your current AO (DAQE-AN117680002-18) the generators are
listed as 250 hp and 565 hp. Can you please clarify if you are
changing generators as part of the modification?

The discrepancy generator has caused issues with the
emission calculations. You have calculated the reduction of annual
emissions assuming the original generators were 335 hp and 757
hp, but this is not the case. The annual NOx emissions for 4200
hours of operation for the 335 hp and 757 hp generators is 59.96
TPY. The annual NOx emissions for 5470 hours of operation for
the 335 hp and 757 hp generators is 78.09 TPY, which is above
the limit set in the AO. It's fine to change the generators in the
modification, but you will need to update your emissions
calculations to accurately reflect the change.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…137/238

I hope this makes sense. Let me know if you have any questions.

Thanks,
Dungan

On Wed, Nov 1, 2023 at 9:58 AM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West
Valley to include PM2.5 and CO2e. Let me know if you have
any questions.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, October 23, 2023 10:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Could you please provide emission calculations and state the
emission reductions for PM2.5 and CO2e? Both of these
emissions were included in the previous AO but were not
specified in the minor modification NOI.

Here's a link to the DAQs emission calculation spreadsheets.
The diesel engine and boiler spreadsheets should help with the
CO2e calculation. Let me know if you have any questions.

Thanks,
Dungan

On Tue, Oct 10, 2023 at 3:20 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,
Look forward to working with you on this. Yes, I think that’s a
good idea.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…138/238

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 10, 2023 2:26 PM
To: Kamren Garfield <[e-mail]>
Subject: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

My name is Dungan and I am working on processing the
requested modifications to the Geneva Rock Products
Bacchus Pit. Everything looks good so far.

You have requested that the manufacturer be removed from
the crushers in the approved equipment section. I think it
would be a good idea to remove the manufacturer from
conditions II.A.15, II.A.16, II.A.17, and II.A.18 (Shown
below). I'm not sure why they were included in the first
place.

II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron

II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
Manufacturer: El Jay

II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay

II.A.18 One (1) Sand Classifier
Size: 10'x24'
Manufacturer: Eagle Iron Autospec

Let me know if you would like to include this modification.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…139/238
Thanks,
Dungan

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…140/238
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…141/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…142/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…143/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…144/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…145/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…146/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…147/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…148/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…149/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…150/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…151/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
Kamren Garfield <[e-mail]>Thu, Sep 5, 2024 at 4:13 PM
To: Dungan Adams <[e-mail]>
Hi Dungan,

Let’s just keep the baghouse as is.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…152/238

Regarding the submerged fill on the diesel tanks, the main concern is the additional cost of outfitting tanks
with the proper fittings and dip pipe on the tanks. I reached out to Westech, our preferred fuel system
vendor, and in their opinion $1,500 to add submerged fill to a diesel tank would be absolute minimum cost,
and likely higher. With the VOC reduction being more than $34,000 per ton of VOC, Geneva Rock does not
agree with that being considered an economically feasible control. Even with brand new tanks, this cost
would be realized.

I believe these were the last two items to nail down on this ER.

Let me know if you want to discuss further.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, August 2, 2024 1:22 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Let me know whenever you have the information about the baghouses and I will update the permit accordingly. I have
changed the engine conditions to include the non-resettable meter and have monthly recordkeeping. I've also updated the
permit to have four (4) triple deck screens and fixed the boiler mistake in II.B.5.d.

My main concern with the BACT justification you have provided is that the submerged fill piping is BACT for new tanks.
The new tanks are not yet permitted to be on site and should not be full of diesel. The cost of purging diesel and cleaning
the tanks should not be included in any economic justification as this is proposed control for new tanks. Let me know if
you have any questions about this.

Thanks,
Dungan

On Tue, Jul 30, 2024 at 5:15 PM Kamren Garfield <[e-mail]> wrote:
Dungan,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…153/238
Thanks for the explanations, see my responses to your email below in red.

Also a couple things I just noticed:
Can you combine Approved Equipment items II.A.5 & 6 to just say Four (4) Triple Deck Screens?
II.B.5.d is only supposed to say generators (remove boilers)
Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, July 19, 2024 3:57 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the updated ER. Below are my responses to comments, please let me know if you have any questions.

- If GRP wants to remove submerged fill pipes as BACT, I need to see some type of justification as to why they
are infeasible. The DAQ has recently issued an AO which requires submerged fill pipes for new
diesel storage tanks of a similar size.
The main justification against submerged fill pipes is the cost of implementation vs the minimal
reduction of VOC emissions. VOC emissions from all 5 tanks combined is 0.02 tons per year.
According to EPA studies done at bulk gasoline plants, submerged filling provides a VOC reduction
of 22%. Submerged fill pipes would lead to a VOC reduction of approximately .0044 tons sitewide
per year. I haven’t done a deep dive into a cost analysis for retrofit fill pipes, but to evacuate and
nitrogen purge a tank with the proper pipe install I think $1,500 per tank would be a starting point. I
know DAQ doesn’t have a published threshold of what constitutes a control as economically
feasible, but that puts submerged fill pipes at a cost of $34,090 per ton of VOC removal, projected
over 10 years. This figure is 3-4x dollar values for past controls deemed economically feasible by
DAQ.

- The "up to" language for equipment ratings will not be accepted. While I am okay with removing the
manufacturer, etc. to help make the equipment more generic, allowing a range of equipment sizes is not
common in AOs. Using a range of ratings makes it almost impossible to estimate actual site emissions. Future
modifications/amendments would become increasingly challenging and the summary of emissions would no
longer provide a realistic estimate of the permitted equipment. If GRP ends up wanting to use lower rated
equipment than what is permitted when the equipment is brought back, they can apply for a Reduction in Air
Pollutants under R307-401-12. This permit amendment would not go through public comment and is
substantially cheaper and quicker process.
Noted, shouldn’t be a problem.

- The boiler is updated to allow for #1 or #2 diesel, natural gas, or propane. The diesel engines are updated to
allow for #1 or #2 diesel.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…154/238
Perfect, thank you.

- The "as necessary" language will not be included in watering conditions. Watering shall operate to meet the
opacity limits throughout the permit. If the opacity limits are met, watering does not need to occur. The use of "as
needed" creates room for interpretation and is not necessary language.
Fair enough.

- If GRP wants to change the static pressure across the baghouse water column, I need to see something from
the baghouse manufacturer. The standard language DAQ uses now is: "During operation of the baghouse, the
owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for
normal operations." I can switch to that if you provide the manufacturer range.
Pending; I’m waiting on some information on the baghouse specs for this item. Please give me a couple days to
see what I can find from the manufacturer, I will get back to you on this.

- Recording engine operation monthly in an operations log would not accurately track engine usage. How do you
know how many total hours an engine has run each month if you do not track daily operation? If you keep track
of engine operation in some other way, I can update recordkeeping to monthly.
Each engine and the boiler have/will have a non-resettable hour meter that is recorded monthly to
determine hours of operation.

If you would like to meet to discuss anything I am happy to do so.

Thanks,
Dungan

On Thu, Jul 18, 2024 at 1:21 PM Dungan Adams <[e-mail]> wrote:
Thanks for sending these over. I am planning to have a response to your comments by the end of the week.

Thanks,
Dungan

On Tue, Jul 16, 2024 at 5:11 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Here are the compiled comments on the draft ER. Nothing too major, let me know if you want to have
a call to discuss.

Thanks,
Kamren

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…155/238
From: Dungan Adams <[e-mail]>
Sent: Monday, July 15, 2024 7:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Sorry I missed your call on Friday. EOD Tuesday July 16 for the ER sounds good -- I know this is a popular time
for vacation and the DAQ would really like GRP's comments and concurrence for this type of a modification.

Thanks,
Dungan

On Fri, Jul 12, 2024 at 5:05 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Tried to get a hold of you and left you a message. Our group was out of town much of this week
and I’m still waiting to hear back from a couple more reviewers. Can you give us until COB
Tuesday to send back the draft ER? Thank you
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, July 2, 2024 2:56 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Yes, that is okay with me. Have a nice 4th of July weekend.

Thanks,
Dungan

On Tue, Jul 2, 2024 at 2:53 PM Kamren Garfield <[e-mail]> wrote:
Dungan, thanks for sending this over. With most everyone out of the office this week for the
holiday, can we have until COB next Friday (July 12) to review the draft ER?

Thanks,
Kamren

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…156/238
From: Dungan Adams <[e-mail]>
Sent: Thursday, June 27, 2024 2:01 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and let
me know if you have any questions or concerns. If everything looks good, please sign the cover page and
return the document to me.

Thanks,
Dungan

On Thu, Jun 13, 2024 at 10:32 AM Dungan Adams <[e-mail]> wrote:
Kamren,

The aggregate equipment can definitely stay in the AO since like you say it was at one time constructed
and operated. I just wanted to ask about it in case you didn't have any plans to bring the equipment back
in the future.

Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to notify
the DAQ compliance section. GRP will be required to conduct Subpart OOO observations for applicable
equipment and CO emission testing for Subpart ZZZZ-applicable generator engines. GRP will also need
to confirm the aggregate equipment brought back on site is identical to the equipment permitted in
their AO.

My manager is reviewing this project and I should have the engineering review for you to review soon. Let
me know if you have any questions or would like to discuss anything further.

Thanks,
Dungan

On Mon, Jun 10, 2024 at 2:02 PM Kamren Garfield <[e-mail]> wrote:
Sounds good. I don’t agree with removing the crusher equipment from the permit since it at
one time was constructed and operated. However, I’ll wait and see what Compliance says
and we’ll discuss. Thanks,

Kamren

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…157/238
From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:09 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Got it. I will relay this to compliance and see how they want to proceed.

Thanks,
Dungan

On Thu, Jun 6, 2024 at 1:08 PM Kamren Garfield <[e-mail]> wrote:
Geneva Rock does have plans to bring crushing equipment back into the Bacchus Pit in
the next year or two. We want to keep the crushers and aggregate processing in the air
permit.

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project.

I know you want to get this site under 50 tpy NOx before the northern wasatch front is reclassified to
serious non-attainment for ozone and the major source threshold changes. From my talks with
compliance, because all of the aggregate processing equipment was removed from the site for
several years, if you are planning to bring it back now it will be considered new equipment, require
notification, and need to have visible emission observations conducted. If you aren't planning to
bring it back now, my understanding is that it will require another permit modification if/when the
aggregate equipment is brought back in the future.

Let me know what GRP's current plan is for the pit and I will communicate with compliance and
adjust the permit accordingly.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…158/238
On Wed, May 22, 2024 at 4:09 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

During their review our compliance department noted the past two times this site has been
inspected it looked like all aggregate processing equipment had been permanently removed. I've
attached the most recent inspection memo from July 2023.

Do you want to update the equipment list to better account for the equipment on site or does GRP
have plans to bring back aggregate operation?

Thanks,
Dungan

On Wed, May 15, 2024 at 9:50 AM Kamren Garfield <[e-mail]> wrote:
Great, thank you so much!

From: Dungan Adams <[e-mail]>
Sent: Wednesday, May 15, 2024 9:37 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I've removed the hourly production limit. I should have the updated permit for you to review in a
couple of weeks.

Thanks,
Dungan

On Wed, May 8, 2024 at 2:41 PM Dungan Adams <[e-mail]> wrote:
Kamren,

I think we should be able to remove the hourly limit because from my understanding it
doesn't have any impact on annual PTE. I just reached out to our modeling department to
see if they have concerns with the removal of the limit. I will let you know when I hear back
from them

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…159/238
On Tue, May 7, 2024 at 10:00 AM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher
production is very uncommon. To my knowledge this could be the only permit GRP has
with an hourly crusher limit. The only way to track that would be to tie in a data logger to
the belt scale. I don’t think we have ever modeled that site, so I’m not sure where the
hourly limit came from. What would it take to get this condition removed?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, April 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the
owner/operator shall not produce more than 2,000,000 tons of aggregates per rolling 12-
month period and shall not produce more than 350 tons of aggregates per hour."

How is the 350 tons per hour limit being monitored and how are records being kept? I'm
updating some of the outdated language in the AO and want to make sure the
recordkeeping and monitoring conditions match whatever GRP is currently doing.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 3:24 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

This looks good to me. I'll let you know if any other questions come up, but I think we
should be all set.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 2:55 PM Kamren Garfield <[e-mail]> wrote:
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…160/238
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 19, 2024 11:35 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and Xylenes
emission factors for Generator 3406. For the CO2e emission factor for Generator
3406, I believe it should be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline fuel.

I think after those minor changes we should get the same values for HAPs and
CO2e. Let me know if you have any questions.

Thanks,
Dungan

On Mon, Mar 18, 2024 at 4:28 PM Kamren Garfield <[e-mail]>
wrote:
Dungan,

I agree with your approach. Here are my updated calcs to reflect that. I couldn’t
get the HAP and CO2e emissions to line up exactly with yours. That said, I’m fine
with using your calcs if you want to.

Let me know what you think.
Thanks for your patience on this.

Kamren

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 5:49 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…161/238
Hi Kamren,

Since the current engines and operation leads to NOx emissions ~12 TPY above
the PTE in the active AO, calculating new emissions by subtracting from this
incorrect PTE will not be accepted. I think the best way to move forward would be
this:

As far as I understand there are three (3) point sources of non-PM
emissions: the 335 hp generator, the 757 hp generator, and the 4
MMBtu/hr boiler (The 3,000 gal diesel storage tank produces 0.00 TPY of
VOCs). The rest of the equipment produces only PM emissions. The
combustion sources will be recalculated to make sure that NOx emissions
are actually below 50 TPY--the engine operation will need to be 3325
hours per year in order to meet this requirement.

The PM emissions can be calculated by subtracting the difference
between the current operation and the new operation of the generators. I
went through and updated the calculations I sent over last time. At current
production, assuming 335 hp and 757 hp generators, the PM10 and
PM2.5 emissions are 2.85 TPY. At 3325 hours the PM10 and PM2.5
emissions are 1.73 TPY. So, the operation reduction causes a 1.12 TPY
reduction in PM 10 & 2.5.

This allows the NOx PTE to be accurate without emission recalculations for the
crushing operations. Let me know what you think.

On Wed, Mar 13, 2024 at 9:24 AM Kamren Garfield <[e-mail]>
wrote:
Thanks for looking into that. My biggest concern with trying to recreate
everything in the PM calcs is I don’t have access to the original application that
established the crushing limits and other assumptions that were made for that
AO. So I would be starting from scratch. In my experience we usually don’t
touch any calcs that aren’t associated with the modification.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 9:08 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I have concerns with calculating emissions this way when the PTE in the active
AO is incorrect. That being said, I understand not wanting to redo more
emission calculations. Let me talk with my manager and I will get back to you.

Thanks,
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…162/238
Dungan

On Tue, Mar 12, 2024 at 3:47 PM Kamren Garfield <[e-mail]>
wrote:
The gaseous emissions make sense, but if I go with this method means I
will also need to recalculate all the PM emissions associated with the
crushing operations to come up with a new sitewide PM potential to emit.
That is why I tried to stay with just showing the decrease. Can we just
assume the PM emissions in the AO are correct and then calculate what the
generator decrease will be and subtract from the total in the current AO?

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project. Have you had a chance to review the
emission calculations from my last email?

Thanks,
Dungan

On Tue, Feb 6, 2024 at 1:57 PM Dungan Adams
<[e-mail]> wrote:
Hi Kamren,

I've looked at the emission calculations you sent and I found
them difficult to follow. I think the calculations assume the PTE for NOx in
the active AO is correct and I don't think it is. Calculating only the
emission reduction from the operational change doesn't take into account
the inaccurate PTE in the current AO. I've really quickly put together
some emission calculations that show site-wide combustion PTE for the
different operational hours and engine ratings. I used the emission factors
that you listed in the attachment, but if I am missing something please let
me know.

Please take a look and let me know what you think.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…163/238
On Fri, Feb 2, 2024 at 4:44 PM Kamren Garfield
<[e-mail]> wrote:
Dungan,
I have revised the calculations to reflect the engine sizes as they are
shown in the current AO. Let me know if this works for you. I had to
reduce operation to 3,780 hrs for each engine to get the required NOx
reduction.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 14, 2023 2:10 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Thanks for bringing this up. I see what you are saying, in DAQE-
AN0117680001-09 the generators are listed as 250 kW and 565 kW.
Then in the current AO, DAQE-AN117680002-18, the generators are
listed as 250 hp and 565 hp.

The current AO (DAQE-AN117680002-18) states each generator shall
not exceed 5,470 hours of annual operation. The current AO's
emission limit for NOx is 67.99 TPY. When I calculate the emissions for
250 kW and 565 kW engines assuming 5,470 hours of operation, I get
78.09 TPY of NOX which is above the limit in the current AO. This
means the emission limits in the current AO were probably calculated
assuming 250 hp and 565 hp engines.

I think the best way to move forward is to redo plant wide emission
calculations. Trying to calculate only the emission reduction (as you
submitted in the NOI) is confusing since the current AO does not
correctly list the generators and their associated emissions. The other
viable option would be to redo the generator emission calculations for
the current AO with the 335 hp and 757 hp generators and then reduce
the hours of operations and calculate the correct reduction.

Let me know what you think. I'd be happy to meet if you think that
would be helpful.

Thanks,
Dungan

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…164/238
On Fri, Nov 10, 2023 at 12:11 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

That is a great question, here is what I found while digging through
some prior records.

Approval Order DAQE-AN0117680001-09 (Dated July 28, 2009)
listed the generators as 250 KW and 565 KW. In November 2017 a
reduction in emissions was submitted to DAQ. In those calculations,
both the KW and the equivalent hp (as converted from kw) were
expressed in the emission calculations (i.e. 250 KW = 335 hp & 565
KW = 757 hp). It looks like the subsequent (current) AO was then
written to show the generator size reflected as hp but used the KW
number, if that makes sense. So now the current AO erroneously
shows the sizes as 250 hp and 565 hp when it should be in KW,
which would make them the same as 335 hp and 757 hp. This is
something that should have been caught during the ER review but
nobody did. Hopefully this makes sense and we can get it corrected
in this revision. I will be out most of next week but can hop on a call
next Friday if you want to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 2, 2023 12:24 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the provided calculations and modification request, Generators
3406 and 3412 are listed as 335 hp and 757 hp respectively. In your
current AO (DAQE-AN117680002-18) the generators are listed as
250 hp and 565 hp. Can you please clarify if you are changing
generators as part of the modification?

The discrepancy generator has caused issues with the
emission calculations. You have calculated the reduction of annual
emissions assuming the original generators were 335 hp and 757
hp, but this is not the case. The annual NOx emissions for 4200
hours of operation for the 335 hp and 757 hp generators is 59.96
TPY. The annual NOx emissions for 5470 hours of operation for the
335 hp and 757 hp generators is 78.09 TPY, which is above the limit
set in the AO. It's fine to change the generators in the modification,
but you will need to update your emissions calculations to
accurately reflect the change.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…165/238
I hope this makes sense. Let me know if you have any questions.

Thanks,
Dungan

On Wed, Nov 1, 2023 at 9:58 AM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West
Valley to include PM2.5 and CO2e. Let me know if you have any
questions.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, October 23, 2023 10:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Could you please provide emission calculations and state the
emission reductions for PM2.5 and CO2e? Both of these
emissions were included in the previous AO but were not
specified in the minor modification NOI.

Here's a link to the DAQs emission calculation spreadsheets. The
diesel engine and boiler spreadsheets should help with the CO2e
calculation. Let me know if you have any questions.

Thanks,
Dungan

On Tue, Oct 10, 2023 at 3:20 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,
Look forward to working with you on this. Yes, I think that’s a
good idea.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…166/238
Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 10, 2023 2:26 PM
To: Kamren Garfield <[e-mail]>
Subject: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

My name is Dungan and I am working on processing the
requested modifications to the Geneva Rock Products
Bacchus Pit. Everything looks good so far.

You have requested that the manufacturer be removed from
the crushers in the approved equipment section. I think it
would be a good idea to remove the manufacturer from
conditions II.A.15, II.A.16, II.A.17, and II.A.18 (Shown below).
I'm not sure why they were included in the first place.

II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron

II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
Manufacturer: El Jay

II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay

II.A.18 One (1) Sand Classifier
Size: 10'x24'
Manufacturer: Eagle Iron Autospec

Let me know if you would like to include this modification.

Thanks,
Dungan
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…167/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…168/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…169/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…170/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…171/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…172/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…173/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…174/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…175/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…176/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…177/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…178/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…179/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…180/238
Dungan Adams <[e-mail]>Fri, Sep 6, 2024 at 10:03 AM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
I agree that $34,000/ton of VOC reduced is not economically feasible control technology. If you provide the estimate from
Westech, I am comfortable removing the submerged fill requirement for the new tanks. Any email communication is fine
as justification, you do not need a full quote.
Thanks,
Dungan
On Thu, Sep 5, 2024 at 4:14 PM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

Let’s just keep the baghouse as is.

Regarding the submerged fill on the diesel tanks, the main concern is the additional cost of outfitting tanks
with the proper fittings and dip pipe on the tanks. I reached out to Westech, our preferred fuel system
vendor, and in their opinion $1,500 to add submerged fill to a diesel tank would be absolute minimum
cost, and likely higher. With the VOC reduction being more than $34,000 per ton of VOC, Geneva Rock
does not agree with that being considered an economically feasible control. Even with brand new tanks,
this cost would be realized.

I believe these were the last two items to nail down on this ER.

Let me know if you want to discuss further.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, August 2, 2024 1:22 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Let me know whenever you have the information about the baghouses and I will update the permit accordingly. I have
changed the engine conditions to include the non-resettable meter and have monthly recordkeeping. I've also updated
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…181/238
the permit to have four (4) triple deck screens and fixed the boiler mistake in II.B.5.d.

My main concern with the BACT justification you have provided is that the submerged fill piping is BACT for new tanks.
The new tanks are not yet permitted to be on site and should not be full of diesel. The cost of purging diesel and
cleaning the tanks should not be included in any economic justification as this is proposed control for new tanks. Let me
know if you have any questions about this.

Thanks,
Dungan

On Tue, Jul 30, 2024 at 5:15 PM Kamren Garfield <[e-mail]> wrote:
Dungan,

Thanks for the explanations, see my responses to your email below in red.

Also a couple things I just noticed:
Can you combine Approved Equipment items II.A.5 & 6 to just say Four (4) Triple Deck Screens?
II.B.5.d is only supposed to say generators (remove boilers)
Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, July 19, 2024 3:57 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the updated ER. Below are my responses to comments, please let me know if you have any questions.

- If GRP wants to remove submerged fill pipes as BACT, I need to see some type of justification as to why
they are infeasible. The DAQ has recently issued an AO which requires submerged fill pipes for new
diesel storage tanks of a similar size.
The main justification against submerged fill pipes is the cost of implementation vs the minimal
reduction of VOC emissions. VOC emissions from all 5 tanks combined is 0.02 tons per year.
According to EPA studies done at bulk gasoline plants, submerged filling provides a VOC
reduction of 22%. Submerged fill pipes would lead to a VOC reduction of approximately .0044
tons sitewide per year. I haven’t done a deep dive into a cost analysis for retrofit fill pipes, but to
evacuate and nitrogen purge a tank with the proper pipe install I think $1,500 per tank would be a
starting point. I know DAQ doesn’t have a published threshold of what constitutes a control as
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
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economically feasible, but that puts submerged fill pipes at a cost of $34,090 per ton of VOC
removal, projected over 10 years. This figure is 3-4x dollar values for past controls deemed
economically feasible by DAQ.

- The "up to" language for equipment ratings will not be accepted. While I am okay with removing the
manufacturer, etc. to help make the equipment more generic, allowing a range of equipment sizes is not
common in AOs. Using a range of ratings makes it almost impossible to estimate actual site emissions. Future
modifications/amendments would become increasingly challenging and the summary of emissions would no
longer provide a realistic estimate of the permitted equipment. If GRP ends up wanting to use lower rated
equipment than what is permitted when the equipment is brought back, they can apply for a Reduction in Air
Pollutants under R307-401-12. This permit amendment would not go through public comment and is
substantially cheaper and quicker process.
Noted, shouldn’t be a problem.

- The boiler is updated to allow for #1 or #2 diesel, natural gas, or propane. The diesel engines are updated to
allow for #1 or #2 diesel.
Perfect, thank you.

- The "as necessary" language will not be included in watering conditions. Watering shall operate to meet the
opacity limits throughout the permit. If the opacity limits are met, watering does not need to occur. The use of
"as needed" creates room for interpretation and is not necessary language.
Fair enough.

- If GRP wants to change the static pressure across the baghouse water column, I need to see something
from the baghouse manufacturer. The standard language DAQ uses now is: "During operation of the
baghouse, the owner/operator shall maintain the static pressure drop within the range recommended by the
manufacturer for normal operations." I can switch to that if you provide the manufacturer range.
Pending; I’m waiting on some information on the baghouse specs for this item. Please give me a couple days
to see what I can find from the manufacturer, I will get back to you on this.

- Recording engine operation monthly in an operations log would not accurately track engine usage. How do
you know how many total hours an engine has run each month if you do not track daily operation? If you keep
track of engine operation in some other way, I can update recordkeeping to monthly.
Each engine and the boiler have/will have a non-resettable hour meter that is recorded monthly to
determine hours of operation.

If you would like to meet to discuss anything I am happy to do so.

Thanks,
Dungan

On Thu, Jul 18, 2024 at 1:21 PM Dungan Adams <[e-mail]> wrote:
Thanks for sending these over. I am planning to have a response to your comments by the end of the week.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…183/238
Thanks,
Dungan

On Tue, Jul 16, 2024 at 5:11 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Here are the compiled comments on the draft ER. Nothing too major, let me know if you want to
have a call to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, July 15, 2024 7:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Sorry I missed your call on Friday. EOD Tuesday July 16 for the ER sounds good -- I know this is a popular time
for vacation and the DAQ would really like GRP's comments and concurrence for this type of a modification.

Thanks,
Dungan

On Fri, Jul 12, 2024 at 5:05 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Tried to get a hold of you and left you a message. Our group was out of town much of this week
and I’m still waiting to hear back from a couple more reviewers. Can you give us until COB
Tuesday to send back the draft ER? Thank you
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, July 2, 2024 2:56 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Yes, that is okay with me. Have a nice 4th of July weekend.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…184/238
Thanks,
Dungan

On Tue, Jul 2, 2024 at 2:53 PM Kamren Garfield <[e-mail]> wrote:
Dungan, thanks for sending this over. With most everyone out of the office this week for the
holiday, can we have until COB next Friday (July 12) to review the draft ER?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 27, 2024 2:01 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and let
me know if you have any questions or concerns. If everything looks good, please sign the cover page and
return the document to me.

Thanks,
Dungan

On Thu, Jun 13, 2024 at 10:32 AM Dungan Adams <[e-mail]> wrote:
Kamren,

The aggregate equipment can definitely stay in the AO since like you say it was at one time constructed
and operated. I just wanted to ask about it in case you didn't have any plans to bring the equipment
back in the future.

Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to
notify the DAQ compliance section. GRP will be required to conduct Subpart OOO observations for
applicable equipment and CO emission testing for Subpart ZZZZ-applicable generator engines. GRP
will also need to confirm the aggregate equipment brought back on site is identical to the equipment
permitted in their AO.

My manager is reviewing this project and I should have the engineering review for you to review soon.
Let me know if you have any questions or would like to discuss anything further.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
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Thanks,
Dungan

On Mon, Jun 10, 2024 at 2:02 PM Kamren Garfield <[e-mail]> wrote:
Sounds good. I don’t agree with removing the crusher equipment from the permit since it
at one time was constructed and operated. However, I’ll wait and see what Compliance
says and we’ll discuss. Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:09 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Got it. I will relay this to compliance and see how they want to proceed.

Thanks,
Dungan

On Thu, Jun 6, 2024 at 1:08 PM Kamren Garfield <[e-mail]> wrote:
Geneva Rock does have plans to bring crushing equipment back into the Bacchus Pit
in the next year or two. We want to keep the crushers and aggregate processing in the
air permit.

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project.

I know you want to get this site under 50 tpy NOx before the northern wasatch front is reclassified
to serious non-attainment for ozone and the major source threshold changes. From my talks with
compliance, because all of the aggregate processing equipment was removed from the site for
several years, if you are planning to bring it back now it will be considered new equipment, require
notification, and need to have visible emission observations conducted. If you aren't planning to
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
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bring it back now, my understanding is that it will require another permit modification if/when the
aggregate equipment is brought back in the future.

Let me know what GRP's current plan is for the pit and I will communicate with compliance and
adjust the permit accordingly.

Thanks,
Dungan

On Wed, May 22, 2024 at 4:09 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

During their review our compliance department noted the past two times this site has been
inspected it looked like all aggregate processing equipment had been permanently removed.
I've attached the most recent inspection memo from July 2023.

Do you want to update the equipment list to better account for the equipment on site or does
GRP have plans to bring back aggregate operation?

Thanks,
Dungan

On Wed, May 15, 2024 at 9:50 AM Kamren Garfield <[e-mail]> wrote:
Great, thank you so much!

From: Dungan Adams <[e-mail]>
Sent: Wednesday, May 15, 2024 9:37 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I've removed the hourly production limit. I should have the updated permit for you to review
in a couple of weeks.

Thanks,
Dungan
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…187/238

On Wed, May 8, 2024 at 2:41 PM Dungan Adams <[e-mail]> wrote:
Kamren,

I think we should be able to remove the hourly limit because from my understanding it
doesn't have any impact on annual PTE. I just reached out to our modeling department to
see if they have concerns with the removal of the limit. I will let you know when I hear
back from them

Thanks,
Dungan

On Tue, May 7, 2024 at 10:00 AM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher
production is very uncommon. To my knowledge this could be the only permit GRP has
with an hourly crusher limit. The only way to track that would be to tie in a data logger
to the belt scale. I don’t think we have ever modeled that site, so I’m not sure where the
hourly limit came from. What would it take to get this condition removed?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, April 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the
owner/operator shall not produce more than 2,000,000 tons of aggregates per rolling
12-month period and shall not produce more than 350 tons of aggregates per hour."

How is the 350 tons per hour limit being monitored and how are records being kept?
I'm updating some of the outdated language in the AO and want to make sure the
recordkeeping and monitoring conditions match whatever GRP is currently doing.

Thanks,
Dungan
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
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On Tue, Mar 26, 2024 at 3:24 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

This looks good to me. I'll let you know if any other questions come up, but I think we
should be all set.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 2:55 PM Kamren Garfield <[e-mail]> wrote:
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 19, 2024 11:35 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and Xylenes
emission factors for Generator 3406. For the CO2e emission factor for Generator
3406, I believe it should be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline fuel.

I think after those minor changes we should get the same values for HAPs and
CO2e. Let me know if you have any questions.

Thanks,
Dungan

On Mon, Mar 18, 2024 at 4:28 PM Kamren Garfield <[e-mail]>
wrote:
Dungan,

I agree with your approach. Here are my updated calcs to reflect that. I
couldn’t get the HAP and CO2e emissions to line up exactly with yours. That
said, I’m fine with using your calcs if you want to.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…189/238

Let me know what you think.
Thanks for your patience on this.

Kamren

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 5:49 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Since the current engines and operation leads to NOx emissions ~12 TPY
above the PTE in the active AO, calculating new emissions by subtracting from
this incorrect PTE will not be accepted. I think the best way to move forward
would be this:

As far as I understand there are three (3) point sources of non-PM
emissions: the 335 hp generator, the 757 hp generator, and the 4
MMBtu/hr boiler (The 3,000 gal diesel storage tank produces 0.00 TPY
of VOCs). The rest of the equipment produces only PM emissions. The
combustion sources will be recalculated to make sure that NOx
emissions are actually below 50 TPY--the engine operation will need to
be 3325 hours per year in order to meet this requirement.

The PM emissions can be calculated by subtracting the difference
between the current operation and the new operation of the generators.
I went through and updated the calculations I sent over last time. At
current production, assuming 335 hp and 757 hp generators, the PM10
and PM2.5 emissions are 2.85 TPY. At 3325 hours the PM10 and PM2.5
emissions are 1.73 TPY. So, the operation reduction causes a 1.12 TPY
reduction in PM 10 & 2.5.

This allows the NOx PTE to be accurate without emission recalculations for the
crushing operations. Let me know what you think.

On Wed, Mar 13, 2024 at 9:24 AM Kamren Garfield <[e-mail]>
wrote:
Thanks for looking into that. My biggest concern with trying to recreate
everything in the PM calcs is I don’t have access to the original application
that established the crushing limits and other assumptions that were made
for that AO. So I would be starting from scratch. In my experience we usually
don’t touch any calcs that aren’t associated with the modification.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…190/238
From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 9:08 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I have concerns with calculating emissions this way when the PTE in the
active AO is incorrect. That being said, I understand not wanting to redo
more emission calculations. Let me talk with my manager and I will get back
to you.

Thanks,
Dungan

On Tue, Mar 12, 2024 at 3:47 PM Kamren Garfield
<[e-mail]> wrote:
The gaseous emissions make sense, but if I go with this method means I
will also need to recalculate all the PM emissions associated with the
crushing operations to come up with a new sitewide PM potential to emit.
That is why I tried to stay with just showing the decrease. Can we just
assume the PM emissions in the AO are correct and then calculate what
the generator decrease will be and subtract from the total in the current
AO?

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project. Have you had a chance to review the
emission calculations from my last email?

Thanks,
Dungan

On Tue, Feb 6, 2024 at 1:57 PM Dungan Adams
<[e-mail]> wrote:
Hi Kamren,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…191/238
I've looked at the emission calculations you sent and I found
them difficult to follow. I think the calculations assume the PTE for NOx
in the active AO is correct and I don't think it is. Calculating only the
emission reduction from the operational change doesn't take into
account the inaccurate PTE in the current AO. I've really quickly put
together some emission calculations that show site-wide combustion
PTE for the different operational hours and engine ratings. I used the
emission factors that you listed in the attachment, but if I am missing
something please let me know.

Please take a look and let me know what you think.

Thanks,
Dungan

On Fri, Feb 2, 2024 at 4:44 PM Kamren Garfield
<[e-mail]> wrote:
Dungan,
I have revised the calculations to reflect the engine sizes as they are
shown in the current AO. Let me know if this works for you. I had to
reduce operation to 3,780 hrs for each engine to get the required
NOx reduction.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 14, 2023 2:10 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Thanks for bringing this up. I see what you are saying, in DAQE-
AN0117680001-09 the generators are listed as 250 kW and 565 kW.
Then in the current AO, DAQE-AN117680002-18, the generators are
listed as 250 hp and 565 hp.

The current AO (DAQE-AN117680002-18) states each generator
shall not exceed 5,470 hours of annual operation. The current AO's
emission limit for NOx is 67.99 TPY. When I calculate the emissions
for 250 kW and 565 kW engines assuming 5,470 hours of operation,
I get 78.09 TPY of NOX which is above the limit in the current AO.
This means the emission limits in the current AO were probably
calculated assuming 250 hp and 565 hp engines.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…192/238
I think the best way to move forward is to redo plant wide emission
calculations. Trying to calculate only the emission reduction (as you
submitted in the NOI) is confusing since the current AO does not
correctly list the generators and their associated emissions. The
other viable option would be to redo the generator emission
calculations for the current AO with the 335 hp and 757 hp
generators and then reduce the hours of operations and calculate
the correct reduction.

Let me know what you think. I'd be happy to meet if you think that
would be helpful.

Thanks,
Dungan

On Fri, Nov 10, 2023 at 12:11 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

That is a great question, here is what I found while digging
through some prior records.

Approval Order DAQE-AN0117680001-09 (Dated July 28, 2009)
listed the generators as 250 KW and 565 KW. In November 2017
a reduction in emissions was submitted to DAQ. In those
calculations, both the KW and the equivalent hp (as converted
from kw) were expressed in the emission calculations (i.e. 250
KW = 335 hp & 565 KW = 757 hp). It looks like the subsequent
(current) AO was then written to show the generator size reflected
as hp but used the KW number, if that makes sense. So now the
current AO erroneously shows the sizes as 250 hp and 565 hp
when it should be in KW, which would make them the same as
335 hp and 757 hp. This is something that should have been
caught during the ER review but nobody did. Hopefully this makes
sense and we can get it corrected in this revision. I will be out
most of next week but can hop on a call next Friday if you want to
discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 2, 2023 12:24 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…193/238

In the provided calculations and modification request, Generators
3406 and 3412 are listed as 335 hp and 757 hp respectively. In
your current AO (DAQE-AN117680002-18) the generators are
listed as 250 hp and 565 hp. Can you please clarify if you are
changing generators as part of the modification?

The discrepancy generator has caused issues with the
emission calculations. You have calculated the reduction of
annual emissions assuming the original generators were 335 hp
and 757 hp, but this is not the case. The annual NOx emissions
for 4200 hours of operation for the 335 hp and 757 hp generators
is 59.96 TPY. The annual NOx emissions for 5470 hours of
operation for the 335 hp and 757 hp generators is 78.09 TPY,
which is above the limit set in the AO. It's fine to change the
generators in the modification, but you will need to update your
emissions calculations to accurately reflect the change.

I hope this makes sense. Let me know if you have any questions.

Thanks,
Dungan

On Wed, Nov 1, 2023 at 9:58 AM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West
Valley to include PM2.5 and CO2e. Let me know if you have
any questions.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, October 23, 2023 10:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Could you please provide emission calculations and state the
emission reductions for PM2.5 and CO2e? Both of these
emissions were included in the previous AO but were not
specified in the minor modification NOI.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…194/238

Here's a link to the DAQs emission calculation spreadsheets.
The diesel engine and boiler spreadsheets should help with the
CO2e calculation. Let me know if you have any questions.

Thanks,
Dungan

On Tue, Oct 10, 2023 at 3:20 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,
Look forward to working with you on this. Yes, I think that’s
a good idea.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 10, 2023 2:26 PM
To: Kamren Garfield <[e-mail]>
Subject: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

My name is Dungan and I am working on processing the
requested modifications to the Geneva Rock Products
Bacchus Pit. Everything looks good so far.

You have requested that the manufacturer be removed from
the crushers in the approved equipment section. I think it
would be a good idea to remove the manufacturer from
conditions II.A.15, II.A.16, II.A.17, and II.A.18 (Shown
below). I'm not sure why they were included in the first
place.

II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron

II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…195/238
Manufacturer: El Jay

II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay

II.A.18 One (1) Sand Classifier
Size: 10'x24'
Manufacturer: Eagle Iron Autospec

Let me know if you would like to include this modification.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…196/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…197/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…198/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…199/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…200/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…201/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…202/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…203/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…204/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…205/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…206/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…207/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…208/238

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
Dungan Adams <[e-mail]>Wed, Oct 2, 2024 at 1:03 PM
To: Kamren Garfield <[e-mail]>
Hi Kamren,
I am following up about this project. Please provide the justification for the submerged fill costs and we can get the draft
finalized.
Thanks,
Dungan
On Fri, Sep 6, 2024 at 10:03 AM Dungan Adams <[e-mail]> wrote:
Hi Kamren,
I agree that $34,000/ton of VOC reduced is not economically feasible control technology. If you provide the estimate
from Westech, I am comfortable removing the submerged fill requirement for the new tanks. Any email communication
is fine as justification, you do not need a full quote.
Thanks,
Dungan
On Thu, Sep 5, 2024 at 4:14 PM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

Let’s just keep the baghouse as is.

Regarding the submerged fill on the diesel tanks, the main concern is the additional cost of outfitting
tanks with the proper fittings and dip pipe on the tanks. I reached out to Westech, our preferred fuel
system vendor, and in their opinion $1,500 to add submerged fill to a diesel tank would be absolute
minimum cost, and likely higher. With the VOC reduction being more than $34,000 per ton of VOC,
Geneva Rock does not agree with that being considered an economically feasible control. Even with
brand new tanks, this cost would be realized.

I believe these were the last two items to nail down on this ER.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…209/238
Let me know if you want to discuss further.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, August 2, 2024 1:22 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Let me know whenever you have the information about the baghouses and I will update the permit accordingly. I have
changed the engine conditions to include the non-resettable meter and have monthly recordkeeping. I've also
updated the permit to have four (4) triple deck screens and fixed the boiler mistake in II.B.5.d.

My main concern with the BACT justification you have provided is that the submerged fill piping is BACT for new
tanks. The new tanks are not yet permitted to be on site and should not be full of diesel. The cost of purging diesel
and cleaning the tanks should not be included in any economic justification as this is proposed control for new tanks.
Let me know if you have any questions about this.

Thanks,
Dungan

On Tue, Jul 30, 2024 at 5:15 PM Kamren Garfield <[e-mail]> wrote:
Dungan,

Thanks for the explanations, see my responses to your email below in red.

Also a couple things I just noticed:
Can you combine Approved Equipment items II.A.5 & 6 to just say Four (4) Triple Deck
Screens?
II.B.5.d is only supposed to say generators (remove boilers)
Thanks,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…210/238
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, July 19, 2024 3:57 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

Attached is the updated ER. Below are my responses to comments, please let me know if you have any questions.

- If GRP wants to remove submerged fill pipes as BACT, I need to see some type of justification as to why
they are infeasible. The DAQ has recently issued an AO which requires submerged fill pipes for new
diesel storage tanks of a similar size.
The main justification against submerged fill pipes is the cost of implementation vs the minimal
reduction of VOC emissions. VOC emissions from all 5 tanks combined is 0.02 tons per year.
According to EPA studies done at bulk gasoline plants, submerged filling provides a VOC
reduction of 22%. Submerged fill pipes would lead to a VOC reduction of approximately .0044
tons sitewide per year. I haven’t done a deep dive into a cost analysis for retrofit fill pipes, but to
evacuate and nitrogen purge a tank with the proper pipe install I think $1,500 per tank would be
a starting point. I know DAQ doesn’t have a published threshold of what constitutes a control as
economically feasible, but that puts submerged fill pipes at a cost of $34,090 per ton of VOC
removal, projected over 10 years. This figure is 3-4x dollar values for past controls deemed
economically feasible by DAQ.

- The "up to" language for equipment ratings will not be accepted. While I am okay with removing the
manufacturer, etc. to help make the equipment more generic, allowing a range of equipment sizes is not
common in AOs. Using a range of ratings makes it almost impossible to estimate actual site emissions.
Future modifications/amendments would become increasingly challenging and the summary of emissions
would no longer provide a realistic estimate of the permitted equipment. If GRP ends up wanting to use
lower rated equipment than what is permitted when the equipment is brought back, they can apply for a
Reduction in Air Pollutants under R307-401-12. This permit amendment would not go through public
comment and is substantially cheaper and quicker process.
Noted, shouldn’t be a problem.

- The boiler is updated to allow for #1 or #2 diesel, natural gas, or propane. The diesel engines are updated
to allow for #1 or #2 diesel.
Perfect, thank you.

- The "as necessary" language will not be included in watering conditions. Watering shall operate to meet
the opacity limits throughout the permit. If the opacity limits are met, watering does not need to occur. The
use of "as needed" creates room for interpretation and is not necessary language.
Fair enough.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…211/238
- If GRP wants to change the static pressure across the baghouse water column, I need to see something
from the baghouse manufacturer. The standard language DAQ uses now is: "During operation of the
baghouse, the owner/operator shall maintain the static pressure drop within the range recommended by the
manufacturer for normal operations." I can switch to that if you provide the manufacturer range.
Pending; I’m waiting on some information on the baghouse specs for this item. Please give me a couple
days to see what I can find from the manufacturer, I will get back to you on this.

- Recording engine operation monthly in an operations log would not accurately track engine usage. How
do you know how many total hours an engine has run each month if you do not track daily operation? If you
keep track of engine operation in some other way, I can update recordkeeping to monthly.
Each engine and the boiler have/will have a non-resettable hour meter that is recorded monthly
to determine hours of operation.

If you would like to meet to discuss anything I am happy to do so.

Thanks,
Dungan

On Thu, Jul 18, 2024 at 1:21 PM Dungan Adams <[e-mail]> wrote:
Thanks for sending these over. I am planning to have a response to your comments by the end of the week.

Thanks,
Dungan

On Tue, Jul 16, 2024 at 5:11 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Here are the compiled comments on the draft ER. Nothing too major, let me know if you want to
have a call to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, July 15, 2024 7:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…212/238
Sorry I missed your call on Friday. EOD Tuesday July 16 for the ER sounds good -- I know this is a popular
time for vacation and the DAQ would really like GRP's comments and concurrence for this type of a
modification.

Thanks,
Dungan

On Fri, Jul 12, 2024 at 5:05 PM Kamren Garfield <[e-mail]> wrote:
Dungan,
Tried to get a hold of you and left you a message. Our group was out of town much of this
week and I’m still waiting to hear back from a couple more reviewers. Can you give us until
COB Tuesday to send back the draft ER? Thank you
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, July 2, 2024 2:56 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Yes, that is okay with me. Have a nice 4th of July weekend.

Thanks,
Dungan

On Tue, Jul 2, 2024 at 2:53 PM Kamren Garfield <[e-mail]> wrote:
Dungan, thanks for sending this over. With most everyone out of the office this week for the
holiday, can we have until COB next Friday (July 12) to review the draft ER?

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 27, 2024 2:01 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…213/238
Attached is the Engineering Review for the Bacchus Pit Modification. Please review the document and
let me know if you have any questions or concerns. If everything looks good, please sign the cover
page and return the document to me.

Thanks,
Dungan

On Thu, Jun 13, 2024 at 10:32 AM Dungan Adams <[e-mail]> wrote:
Kamren,

The aggregate equipment can definitely stay in the AO since like you say it was at one time
constructed and operated. I just wanted to ask about it in case you didn't have any plans to bring the
equipment back in the future.

Before GRP brings the aggregate equipment back on site and resumes operation, GRP will need to
notify the DAQ compliance section. GRP will be required to conduct Subpart OOO observations for
applicable equipment and CO emission testing for Subpart ZZZZ-applicable generator engines. GRP
will also need to confirm the aggregate equipment brought back on site is identical to the equipment
permitted in their AO.

My manager is reviewing this project and I should have the engineering review for you to review
soon. Let me know if you have any questions or would like to discuss anything further.

Thanks,
Dungan

On Mon, Jun 10, 2024 at 2:02 PM Kamren Garfield <[e-mail]> wrote:
Sounds good. I don’t agree with removing the crusher equipment from the permit since
it at one time was constructed and operated. However, I’ll wait and see what
Compliance says and we’ll discuss. Thanks,

Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:09 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Got it. I will relay this to compliance and see how they want to proceed.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…214/238
Thanks,
Dungan

On Thu, Jun 6, 2024 at 1:08 PM Kamren Garfield <[e-mail]> wrote:
Geneva Rock does have plans to bring crushing equipment back into the Bacchus
Pit in the next year or two. We want to keep the crushers and aggregate processing
in the air permit.

From: Dungan Adams <[e-mail]>
Sent: Thursday, June 6, 2024 1:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modificaon to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project.

I know you want to get this site under 50 tpy NOx before the northern wasatch front is
reclassified to serious non-attainment for ozone and the major source threshold changes. From
my talks with compliance, because all of the aggregate processing equipment was removed
from the site for several years, if you are planning to bring it back now it will be considered new
equipment, require notification, and need to have visible emission observations conducted. If
you aren't planning to bring it back now, my understanding is that it will require another permit
modification if/when the aggregate equipment is brought back in the future.

Let me know what GRP's current plan is for the pit and I will communicate with compliance and
adjust the permit accordingly.

Thanks,
Dungan

On Wed, May 22, 2024 at 4:09 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

During their review our compliance department noted the past two times this site has been
inspected it looked like all aggregate processing equipment had been permanently removed.
I've attached the most recent inspection memo from July 2023.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…215/238
Do you want to update the equipment list to better account for the equipment on site or does
GRP have plans to bring back aggregate operation?

Thanks,
Dungan

On Wed, May 15, 2024 at 9:50 AM Kamren Garfield <[e-mail]> wrote:
Great, thank you so much!

From: Dungan Adams <[e-mail]>
Sent: Wednesday, May 15, 2024 9:37 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I've removed the hourly production limit. I should have the updated permit for you to
review in a couple of weeks.

Thanks,
Dungan

On Wed, May 8, 2024 at 2:41 PM Dungan Adams <[e-mail]> wrote:
Kamren,

I think we should be able to remove the hourly limit because from my understanding it
doesn't have any impact on annual PTE. I just reached out to our modeling department
to see if they have concerns with the removal of the limit. I will let you know when I hear
back from them

Thanks,
Dungan

On Tue, May 7, 2024 at 10:00 AM Kamren Garfield <[e-mail]> wrote:
Hi Dungan,

We have not crushed in there in several years, however, an hourly limit on crusher
production is very uncommon. To my knowledge this could be the only permit GRP
has with an hourly crusher limit. The only way to track that would be to tie in a data
logger to the belt scale. I don’t think we have ever modeled that site, so I’m not sure
where the hourly limit came from. What would it take to get this condition removed?
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…216/238

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Friday, April 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the active AO for this site (DAQE-AN117680002-18) Condition II.B.1.b states "the
owner/operator shall not produce more than 2,000,000 tons of aggregates per rolling
12-month period and shall not produce more than 350 tons of aggregates per hour."

How is the 350 tons per hour limit being monitored and how are records being kept?
I'm updating some of the outdated language in the AO and want to make sure the
recordkeeping and monitoring conditions match whatever GRP is currently doing.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 3:24 PM Dungan Adams <[e-mail]> wrote:
Hi Kamren,

This looks good to me. I'll let you know if any other questions come up, but I think
we should be all set.

Thanks,
Dungan

On Tue, Mar 26, 2024 at 2:55 PM Kamren Garfield <[e-mail]>
wrote:
Alright man I think this should do it. Let me know what you think.
Thanks for your help on this.

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 19, 2024 11:35 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…217/238

Hi Kamren,

I don't think you converted from lb/MMBtu to lb/hp-hr for the Toluene and
Xylenes emission factors for Generator 3406. For the CO2e emission factor for
Generator 3406, I believe it should be 1.15 lb/hp-hr. 1.08 lb/hp-hr is for gasoline
fuel.

I think after those minor changes we should get the same values for HAPs and
CO2e. Let me know if you have any questions.

Thanks,
Dungan

On Mon, Mar 18, 2024 at 4:28 PM Kamren Garfield <[e-mail]>
wrote:
Dungan,

I agree with your approach. Here are my updated calcs to reflect that. I
couldn’t get the HAP and CO2e emissions to line up exactly with yours. That
said, I’m fine with using your calcs if you want to.

Let me know what you think.
Thanks for your patience on this.

Kamren

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 5:49 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Since the current engines and operation leads to NOx emissions ~12 TPY
above the PTE in the active AO, calculating new emissions by subtracting
from this incorrect PTE will not be accepted. I think the best way to move
forward would be this:

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…218/238
As far as I understand there are three (3) point sources of non-PM
emissions: the 335 hp generator, the 757 hp generator, and the 4
MMBtu/hr boiler (The 3,000 gal diesel storage tank produces 0.00
TPY of VOCs). The rest of the equipment produces only PM
emissions. The combustion sources will be recalculated to make sure
that NOx emissions are actually below 50 TPY--the engine operation
will need to be 3325 hours per year in order to meet this
requirement.

The PM emissions can be calculated by subtracting the difference
between the current operation and the new operation of the
generators. I went through and updated the calculations I sent over
last time. At current production, assuming 335 hp and 757 hp
generators, the PM10 and PM2.5 emissions are 2.85 TPY. At 3325
hours the PM10 and PM2.5 emissions are 1.73 TPY. So, the
operation reduction causes a 1.12 TPY reduction in PM 10 & 2.5.

This allows the NOx PTE to be accurate without emission recalculations for
the crushing operations. Let me know what you think.

On Wed, Mar 13, 2024 at 9:24 AM Kamren Garfield
<[e-mail]> wrote:
Thanks for looking into that. My biggest concern with trying to recreate
everything in the PM calcs is I don’t have access to the original application
that established the crushing limits and other assumptions that were made
for that AO. So I would be starting from scratch. In my experience we
usually don’t touch any calcs that aren’t associated with the modification.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, March 13, 2024 9:08 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I have concerns with calculating emissions this way when the PTE in the
active AO is incorrect. That being said, I understand not wanting to redo
more emission calculations. Let me talk with my manager and I will get
back to you.

Thanks,
Dungan

On Tue, Mar 12, 2024 at 3:47 PM Kamren Garfield
<[e-mail]> wrote:
The gaseous emissions make sense, but if I go with this method means
I will also need to recalculate all the PM emissions associated with the
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…219/238
crushing operations to come up with a new sitewide PM potential to
emit. That is why I tried to stay with just showing the decrease. Can we
just assume the PM emissions in the AO are correct and then calculate
what the generator decrease will be and subtract from the total in the
current AO?

From: Dungan Adams <[e-mail]>
Sent: Tuesday, March 12, 2024 2:05 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

I am following up about this project. Have you had a chance to review
the emission calculations from my last email?

Thanks,
Dungan

On Tue, Feb 6, 2024 at 1:57 PM Dungan Adams
<[e-mail]> wrote:
Hi Kamren,

I've looked at the emission calculations you sent and I found
them difficult to follow. I think the calculations assume the PTE for
NOx in the active AO is correct and I don't think it is. Calculating only
the emission reduction from the operational change doesn't take into
account the inaccurate PTE in the current AO. I've really quickly put
together some emission calculations that show site-wide combustion
PTE for the different operational hours and engine ratings. I used the
emission factors that you listed in the attachment, but if I am missing
something please let me know.

Please take a look and let me know what you think.

Thanks,
Dungan

On Fri, Feb 2, 2024 at 4:44 PM Kamren Garfield
<[e-mail]> wrote:
Dungan,
I have revised the calculations to reflect the engine sizes as they
are shown in the current AO. Let me know if this works for you. I
had to reduce operation to 3,780 hrs for each engine to get the
required NOx reduction.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…220/238

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 14, 2023 2:10 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

Thanks for bringing this up. I see what you are saying, in DAQE-
AN0117680001-09 the generators are listed as 250 kW and 565
kW. Then in the current AO, DAQE-AN117680002-18, the
generators are listed as 250 hp and 565 hp.

The current AO (DAQE-AN117680002-18) states each generator
shall not exceed 5,470 hours of annual operation. The current
AO's emission limit for NOx is 67.99 TPY. When I calculate the
emissions for 250 kW and 565 kW engines assuming 5,470 hours
of operation, I get 78.09 TPY of NOX which is above the limit in
the current AO. This means the emission limits in the current AO
were probably calculated assuming 250 hp and 565 hp engines.

I think the best way to move forward is to redo plant wide emission
calculations. Trying to calculate only the emission reduction (as
you submitted in the NOI) is confusing since the current AO
does not correctly list the generators and their associated
emissions. The other viable option would be to redo the generator
emission calculations for the current AO with the 335 hp and 757
hp generators and then reduce the hours of operations and
calculate the correct reduction.

Let me know what you think. I'd be happy to meet if you think that
would be helpful.

Thanks,
Dungan

On Fri, Nov 10, 2023 at 12:11 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

That is a great question, here is what I found while digging
through some prior records.
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…221/238

Approval Order DAQE-AN0117680001-09 (Dated July 28,
2009) listed the generators as 250 KW and 565 KW. In
November 2017 a reduction in emissions was submitted to
DAQ. In those calculations, both the KW and the equivalent hp
(as converted from kw) were expressed in the emission
calculations (i.e. 250 KW = 335 hp & 565 KW = 757 hp). It
looks like the subsequent (current) AO was then written to show
the generator size reflected as hp but used the KW number, if
that makes sense. So now the current AO erroneously shows
the sizes as 250 hp and 565 hp when it should be in KW, which
would make them the same as 335 hp and 757 hp. This is
something that should have been caught during the ER review
but nobody did. Hopefully this makes sense and we can get it
corrected in this revision. I will be out most of next week but
can hop on a call next Friday if you want to discuss.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Thursday, November 2, 2023 12:24 PM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

In the provided calculations and modification request,
Generators 3406 and 3412 are listed as 335 hp and 757 hp
respectively. In your current AO (DAQE-AN117680002-18) the
generators are listed as 250 hp and 565 hp. Can you please
clarify if you are changing generators as part of the
modification?

The discrepancy generator has caused issues with the
emission calculations. You have calculated the reduction of
annual emissions assuming the original generators were 335
hp and 757 hp, but this is not the case. The annual NOx
emissions for 4200 hours of operation for the 335 hp and 757
hp generators is 59.96 TPY. The annual NOx emissions for
5470 hours of operation for the 335 hp and 757 hp generators
is 78.09 TPY, which is above the limit set in the AO. It's fine to
change the generators in the modification, but you will need to
update your emissions calculations to accurately reflect the
change.

I hope this makes sense. Let me know if you have any
questions.

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…222/238
Thanks,
Dungan

On Wed, Nov 1, 2023 at 9:58 AM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,

Here are the updated emission calcs for Geneva Rock West
Valley to include PM2.5 and CO2e. Let me know if you have
any questions.

Thanks,
Kamren

From: Dungan Adams <[e-mail]>
Sent: Monday, October 23, 2023 10:51 AM
To: Kamren Garfield <[e-mail]>
Subject: Re: Minor Modification to Geneva Rock Bacchus
Pit

Hi Kamren,

Could you please provide emission calculations and state
the emission reductions for PM2.5 and CO2e? Both of these
emissions were included in the previous AO but were not
specified in the minor modification NOI.

Here's a link to the DAQs emission calculation spreadsheets.
The diesel engine and boiler spreadsheets should help with
the CO2e calculation. Let me know if you have any
questions.

Thanks,
Dungan

On Tue, Oct 10, 2023 at 3:20 PM Kamren Garfield
<[e-mail]> wrote:
Hi Dungan,
Look forward to working with you on this. Yes, I think
that’s a good idea.

Thanks,
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…223/238
Kamren

From: Dungan Adams <[e-mail]>
Sent: Tuesday, October 10, 2023 2:26 PM
To: Kamren Garfield <[e-mail]>
Subject: Minor Modification to Geneva Rock Bacchus Pit

Hi Kamren,

My name is Dungan and I am working on processing the
requested modifications to the Geneva Rock Products
Bacchus Pit. Everything looks good so far.

You have requested that the manufacturer be removed
from the crushers in the approved equipment section. I
think it would be a good idea to remove the manufacturer
from conditions II.A.15, II.A.16, II.A.17, and II.A.18
(Shown below). I'm not sure why they were included in the
first place.

II.A.15 One (1) Feeder
Rating: 600 tph
Manufacturer: Syntron

II.A.16 One (1) Wet Plant Screen
Size: 5'x16'
Manufacturer: El Jay

II.A.17 One (1) Triple Deck Screen
Manufacturer: El Jay

II.A.18 One (1) Sand Classifier
Size: 10'x24'
Manufacturer: Eagle Iron Autospec

Let me know if you would like to include this modification.

Thanks,
Dungan
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…224/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…225/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…226/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…227/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…228/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…229/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…230/238
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…231/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…232/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…233/238

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…234/238
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…235/238
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…236/238

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…237/238
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
10/3/24, 11:05 AM State of Utah Mail - Minor Modification to Geneva Rock Bacchus Pit
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7775062766183905776&simpl=msg-a:r-39411502009…238/238
10/5/23, 3:03 PM State of Utah Mail - Fwd: Geneva Rock Products Bacchus Pit - Notice of Intent
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1778859026378610940&simpl=msg-f:1778859026378610940 1/2
Dungan Adams <[e-mail]>
Fwd: Geneva Rock Products Bacchus Pit - Notice of Intent
1 message
Alan Humpherys <[e-mail]>Wed, Oct 4, 2023 at 2:42 PM
To: Dungan Adams <[e-mail]>
Dungan,
Can you please process this permit modification?
Site ID: 11768
Peer: EQ
Thanks,
Alan
---------- Forwarded message ---------
From: Kamren Garfield <[e-mail]>
Date: Wed, Oct 4, 2023 at 12:57 PM
Subject: Geneva Rock Products Bacchus Pit - Notice of Intent
To: Alan Humpherys <[e-mail]>
Cc: Ana Williams <[e-mail]>, Grant Ensign <[e-mail]>
Alan,
Please see the attached NOI for Geneva Rock Bacchus Pit in West Valley.

Thanks,

Clyde
Companies
Kamren Garfield
ENVIRONMENTAL SPECIALIST
O [phone] 
C [phone]
WWW.CLYDEINC.COM

10/5/23, 3:03 PM State of Utah Mail - Fwd: Geneva Rock Products Bacchus Pit - Notice of Intent
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1778859026378610940&simpl=msg-f:1778859026378610940 2/2
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
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GRP. West Valley. AO Update Submittal 10.4.23.pdf
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