DAQ-2024-012124

DAQE-AN121880006-24

{{$d1 }}

Christopher Rose
Staker Parson Companies
89 West 13490 South, Suite 100
Draper, UT 84020
[e-mail]

Dear Mr. Rose:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN2188004-05 for a
10-Year Review and Permit Updates
Project Number: N121880006

The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a
10-year administrative review of this source and its respective AO. Staker Parson Companies must
comply with the requirements of this AO, all applicable state requirements (R307), and Federal
Standards.

The project engineer for this action is Lucia Mason, 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.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:LM:jg

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

December 11, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN121880006-24
Administrative Amendment to Approval Order
DAQE-AN2188004-05 for a 10-Year Review
and Permit Updates

Prepared By
Lucia Mason, Engineer
[phone]
[e-mail]

Issued to
Western Rock Products Corporation - Fort Pierce Pit

Issued On
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Issued By

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Bryce C. Bird
Director
Division of Air Quality

December 11, 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 .............................................................................................................. 4
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 12
ACRONYMS ............................................................................................................................... 13

DAQE-AN121880006-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Staker Parson Companies Western Rock Products Corporation - Fort Pierce Pit

Mailing Address Physical Address
89 West 13490 South, Suite 100 1834 East 4150 South
Draper, UT 84020 St. George, UT 84790

Source Contact UTM Coordinates
Name: Christopher Rose 273,616 m Easting
Phone: [phone],102,050 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 1442 (Construction Sand & Gravel)

SOURCE INFORMATION
General Description
Western Rock Products Corporation (Western Rock Products), owned by Staker Parson Companies,
currently operates a crushing plant, an asphalt plant, and a concrete plant in St. George, Washington
County. The asphalt plant processes sand and gravel sourced off-site using asphalt binder and lime.
Equipment at the asphalt plant includes an asphalt plant and mixer, a baghouse, a pugmill with up to three
(3) lime silos, asphalt storage silos, cold feed bins, and recycled asphalt pavement (RAP) feed bins. The
recycled asphalt used is crushed and screened on-site. Equipment at the crushing plant includes jaw
crushers, cone crushers, screening plants, and diesel generators. The concrete batch plant mixes washed
sand and gravel with dry cement and water. Equipment at the concrete plant includes a concrete aggregate
batch and feeder bin, a cement silo with a dust collector, and a fly ash silo also with a dust collector.
Other equipment at the facility includes storage tanks, fuel oil and diesel tanks, off-highway vehicles, and
additional aggregate processing equipment. The plants at the facility are subject to the following
production limits and operating hours:

1. Aggregate plant: 1,000,000 tons of processed aggregate and 3,500 hours
2. Asphalt plant: 900,000 tons of asphalt production and 3,000 hours
3. Concrete plant: 200,000 cubic yards of concrete and 2,500 hours.

NSR Classification
10-Year Review

DAQE-AN121880006-24
Page 4

Source Classification
Located in Attainment Area
Washington County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), I: Standards of Performance for Hot Mix Asphalt Facilities
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

Project Description
This project is a 10-year review of Western Rock Products' Fort Piece Pit and the approved order
associated with it to update permit conditions, format, and rule applicability.

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 0 6097.00
Carbon Monoxide 0 65.17
Nitrogen Oxides 0 52.02
Particulate Matter - PM10 0 20.72
Particulate Matter - PM2.5 0 20.72
Sulfur Dioxide 0 30.29
Volatile Organic Compounds 0 15.73

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 9420
Change (TPY) Total (TPY)
Total HAPs 0 4.71

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]
DAQE-AN121880006-24
Page 5

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 condition or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years.
Used oil consumption records shall be kept for three (3) years. Emission inventories shall be kept five (5) years from the due date of each emission statement or until the next inventory is
due, whichever is longer. [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 UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Fort Pierce Pit Facility containing a crushing plant, asphalt plant, and concrete plant
II.A.2 Crushing Plant II.A.3 Two (2) Jaw Crushers Capacity: 500 tph (each) NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.4 Two (2) Cone Crushers Capacity: 500 tph (each) NSPS Applicability: 40 CFR 60 Subpart OOO II.A.5 Four (4) Screening Plants Capacity: 500 tph (each) NSPS Applicability: 40 CFR 60 Subpart OOO
DAQE-AN121880006-24
Page 6

II.A.6 Two (2) Diesel Generators Engine Rating: 600 hp [~447 kW] (each) MACT Applicability: 40 CFR 63 Subpart ZZZZ II.A.7 Asphalt Plant

II.A.8 One (1) Asphalt Plant and Mixer Capacity: 500 tph NSPS Applicability: 40 CFR 60 Subpart I II.A.9 One (1) Baghouse
II.A.10 One (1) Pugmill NSPS Applicability: 40 CFR 60 Subpart I
II.A.11 Three (3) Lime Silos
Vented through vent/fabric filter NSPS Applicability: 40 CFR 60 Subpart I

II.A.12 Six (6) Asphalt Storage Silos Capacity: 300 tons (each) NSPS Applicability: 40 CFR 60 Subpart I
II.A.13 Seven (7) Cold Feed Bins
II.A.14 Various RAP Feeder Bins
II.A.15 Concrete Plant
II.A.16 One (1) Concrete Aggregate Batcher and Feed Bin Capacity: 12 Cubic Yards II.A.17 One (1) Cement Silo with Dust Collector

II.A.18 One (1) Fly Ash Silo with Dust Collector II.A.19 Miscellaneous Equipment

II.A.20 Storage Tanks Contents: Fuel oil and diesel fuel
II.A.21 Off Highway Vehicles
Front-end loaders, bulldozers, scrapers, draglines, track hoes, haul trucks, water trucks, sweeper trucks, forklift trucks, boom trucks, etc.

II.A.22 Miscellaneous aggregate processing equipment Grizzlies, feeders, splitters, traps, load bins, conveyors, screws, cyclones, clarifiers, and stackers
II.A.23 Miscellaneous
Welders, pumps, motors, pressure washers, parts washers, and other equipment associated with
construction materials processing, manufacture, and maintenance
For informational purposes only.

DAQE-AN121880006-24
Page 7

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the emission points listed to exceed
the following opacities:

A. Crushers - 15% opacity

B. Screens - 10% opacity

C. Conveyor transfer points - 10% opacity

D. Conveyor drop points - 20% opacity

E. Baghouse/bin vent exhaust points - 10% opacity

F. Diesel engines - 20% opacity

G. All other points - 20% opacity.

[R307-401-7]

II.B.1.a.1 Opacity observations shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b The owner/operator shall keep a current list of all aggregate, asphalt, and concrete processing
equipment listed in the Approved Equipment of this Approval Order. The list must be kept
on-site and available to the Director upon request. [R307-401-8]

II.B.1.c The owner/operator shall install a fabric filter on each material storage silo associated with the concrete batch plant and hot mix asphalt plant. Displaced air from each silo shall pass through a fabric filter before being vented to the atmosphere. [R307-401-8]
II.B.1.d The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD) in the generator engines. ULSD has a sulfur content of 15 ppm or less.
[40 CFR 60 Subpart ZZZZ]

II.B.1.d.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]
II.B.2 Production & Consumption Requirements
II.B.2.a The owner/operator shall not exceed the following limits in the aggregate plant: A. 1,000,000 tons of processed aggregate per rolling 12-month period B. 3,500 hours of operation per rolling 12-month period. [R307-401-8]
DAQE-AN121880006-24
Page 8

II.B.2.b The owner/operator shall not exceed the following limits in the asphalt plant: A. 900,000 tons of asphalt production per rolling 12-month period B. 3,000 hours of operation per rolling 12-month period. [R307-401-8]
II.B.2.c The owner/operator shall not exceed the following limits in the concrete plant: A. 200,000 cubic yards of concrete production per rolling 12-month period
B. 2,500 hours of operation per rolling 12-month period.
[R307-401-8]
II.B.2.d To determine compliance with II.B.2.a, II.B.2.b, and II.B.2.c, the owner/operator shall: A. Determine aggregate, asphalt, and concrete production using scale house records or vendor receipts B. Record production and hours of operation on a daily basis C. Determine hours of operation by supervisor monitoring and maintaining an operations log D. Use the production data and 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 E. Keep the production records for all periods the plant is in operation. [R307-401-8]
II.B.2.e The owner/operator shall not use more than 40% of recycled asphalt in the total asphalt product at any time. [R307-401-8]

II.B.2.e.1 The owner/operator shall determine compliance by dividing the hourly amount of recycled asphalt introduced to the plant by the actual hour production of the plant. The owner/operator shall keep daily records of the following: A. Total production B. Amount of recycled asphalt used in the total production C. Calculations of the percent recycled asphalt used in the total production. [R307-401-8]
II.B.3 Asphalt Plant Fuel Requirements
II.B.3.a The owner/operator shall use natural gas, liquified petroleum gas, #1 through #6 fuel oil, or on-specification used oil as fuel in the hot mix asphalt plant. [R307-401-8]
DAQE-AN121880006-24
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II.B.3.b The owner/operator shall comply with the following in respect to used oil burned at the asphalt plant: A. The concentration/parameters of contaminants in any used oil fuel shall not exceed the following levels: (1) Arsenic 5 ppm by weight (2) Cadmium 2 ppm by weight (3) Chromium 10 ppm by weight (4) Lead 100 ppm by weight (5) Total halogens 1,000 ppm by weight (6) Sulfur 0.5 percent by weight B. The flash point of all used oil to be burned shall not be less than 100 oF C. The owner/operator shall consider any used oil fuel that contains more than 1,000 ppm by weight of total halogens hazardous waste. The owner/operator shall not burn such fuel at the asphalt plant. [R307-401-8] II.B.3.b.1 The owner/operator shall:

A. Provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel marketer

B. Keep records of used oil fuel consumption and test reports for all periods when the plant is in operation. Records shall be made available to the Director upon request

C. Test used oil for halogen content by ASTM Method D-808-81, EPA Method 8240, or Method 8260 before it is transferred to the asphalt plant storage tank and burned

D. Only burn used oil that does not exceed any of the listed contaminants content and record the quantities of used oil burned on a daily basis

E. Comply with the State Division of Solid and Hazardous Waste in accordance with R315-15, UAC.

[R307-401-8]
II.B.4 Fugitive Emissions and Haul Road Requirements
II.B.4.a The owner/operator shall not allow visible emissions from unpaved roads, unpaved operational
areas, haul-road traffic and mobile equipment in operational areas to exceed 20% opacity. [R307-401-8]

II.B.4.a.1 Opacity observations of fugitive dust from intermittent sources shall be conducted according to 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. The number of observations and the time period shall be determined by the length of the intermittent source. For fugitive dust generated by mobile source, visible emissions shall be measured at the densest point of the plume, but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8]
DAQE-AN121880006-24
Page 10

II.B.4.b The owner/operator shall control fugitive particulate matter emissions by: A. Spraying all unpaved roads and other unpaved operational areas used by mobile equipment with water sprays and/or chemical treatments to control fugitive dust B. Treating at a sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless the temperature is below freezing C. Only using chemical treatments that have been approved by the Director. [R307-401-8] II.B.4.b.1 The owner/operator shall keep records of water and/or chemical treatment for all periods when the plant is in operation. The records shall include the following items:
A. The date of treatment

B. The number of treatments made, dilution ratio, and quantity
C. Rainfall received, if any, and approximate amount
D. The time of day treatments were made.

[R307-401-8]
II.B.4.c The owner/operator shall water storage piles to minimize generation of fugitive dust to comply with the opacity limit in this AO. [R307-401-8] II.B.4.d The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive
Emissions and Fugitive Dust Sources. [R307-205]

II.B.5 Baghouse Requirements II.B.5.a The owner/operator shall use a baghouse to control particulate emissions from the hot mix
asphalt plant on site. [R307-401-8]

II.B.5.a.1 The owner/operator shall maintain the baghouse such that: A. It is designed to handle at least 12,000 ACFM for the existing conditions B. All exhaust air from the drum mixer is routed through the baghouse before being vented to the atmosphere. [R307-401-8]
II.B.5.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across the hot mix asphalt plant baghouse. [R307-401-8]

II.B.5.c The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8]
II.B.5.c.1 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less.
[R307-401-8]

II.B.5.d At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]
DAQE-AN121880006-24
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II.B.5.e The owner/operator shall maintain the static pressure drop across the hot mix asphalt plant baghouse during operation between 2 and 6 inches of water column. [R307-401-8] II.B.6 Stack Testing Requirements
II.B.6.a The owner/operator shall not emit more than the following rates and concentrations from the asphalt baghouse exhaust stack: Pollutant lb/hr grains/dscf (68 degrees F, 29.92 in Hg) PM10 11.50 0.024 PM10 (RAP) 13.41 0.028 [R307-401-8] II.B.6.a.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8]

II.B.6.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]
II.B.6.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]
II.B.6.b The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.6.b.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.6.b.2 Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.6.b.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]

II.B.6.b.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8]
II.B.6.b.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

DAQE-AN121880006-24
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II.B.6.b.6 Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
II.B.6.c Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)
C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.6.c.1 PM10 Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. Condensable PM 40 CFR 51, Appendix M, Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN2188004-05 dated January 21, 2005

DAQE-AN121880006-24
Page 13

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-

RN121880006 December 10, 2024 Christopher Rose
Staker Parson Companies 89 West 13490 South, Suite 100 Draper, UT 84020
[e-mail] Dear Christopher Rose,
Re: Engineer Review - Administrative Amendment to Approval Order (AO) DAQE-AN2188004-05 for a 10-Year Review and Permit Updates Project Number: N121880006 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 (NSR) permitting program. Staker Parson Companies should complete this review within 10 business days of receipt. Staker Parson Companies should contact Lucia Mason at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Lucia Mason at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If Staker Parson Companies does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Staker Parson Companies 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 N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N121880006 Owner Name Staker Parson Companies Mailing Address 89 West 13490 South, Suite 100
Draper, UT, 84020 Source Name Western Rock Products Corporation- Fort Pierce Pit
Source Location 1834 E 4150 S St. George, UT 84790
UTM Projection 273,616 m Easting, 4,102,050 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1442 (Construction Sand & Gravel) Source Contact Christopher Rose Phone Number [phone] Email [e-mail] Billing Contact Christopher Rose Phone Number [phone]
Email [e-mail] Project Engineer Lucia Mason, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 13, 2024 Date of Accepted Application July 17, 2024

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 2
SOURCE DESCRIPTION General Description
Western Rock Products Corporation (Western Rock Products), owned by Staker Parson Companies, currently operates a crushing plant, an asphalt plant and a concrete plant in St. George, Washington County. The asphalt plant processes sand and gravel sourced off-site using
asphalt binder and lime. Equipment at the asphalt plant includes an asphalt plant and mixer, a baghouse, a pugmill with up to three lime silos, asphalt storage silos, cold feed bins and recycled asphalt pavement (RAP) feed bins. The recycled asphalt used is crushed and screened on-site. Equipment at the crushing plant includes jaw crushers, cone crushers, screening plants and diesel generators. The concrete batch plant mixes washed sand and gravel with dry cement and water. Equipment at the concrete plant includes a concrete aggregate batch and feeder bin, a cement silo with a dust collector and a fly ash silo also with a dust collector. Other equipment at the facility includes storage tanks, fuel oil and diesel tanks, off highway vehicles, and additional aggregate processing equipment. The plants at the facility are subject to the following production limits and operating hours:
A. Aggregate plant: 1,000,000 tons of processed aggregate and 3,500 hours B. Asphalt plant: 900,000 tons of asphalt production and 3,000 hours C. Concrete plant: 200,000 cubic yards of concrete and 2,500 hours
NSR Classification: 10 Year Review
Source Classification Located in Attainment Area Washington County Airs Source Size: SM
Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), I: Standards of Performance for Hot Mix Asphalt Facilities 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
Project Proposal Administrative Amendment to Approval Order (AO) DAQE-AN2188004-05 for a 10-Year Review and Permit Updates
Project Description This project is a 10-year review of Western Rock Products' Fort Piece Pit, and the approved order
associated with it to update permit conditions, format, and rule applicability. EMISSION IMPACT ANALYSIS
This is a 10-year review. No changes are being made to emissions or equipment at this time. Therefore, modeling is not currently required. [Last updated September 27, 2024]

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 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 0 6097.00 Carbon Monoxide 0 65.17
Nitrogen Oxides 0 52.02
Particulate Matter - PM10 0 20.72
Particulate Matter - PM2.5 0 20.72
Sulfur Dioxide 0 30.29
Volatile Organic Compounds 0 15.73 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 9420
Change (TPY) Total (TPY)
Total HAPs 0 4.71

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding 10-Year Review
This is a 10-year review. No changes are being made to emissions or equipment are being made at this time. Therefore, a BACT analysis is not currently required. [Last updated September 16, 2024]
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 condition or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years.
Used oil consumption records shall be kept for three (3) years. Emission inventories shall be kept five (5) years from the due date of each emission statement or until the next inventory is due, whichever is longer. [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 UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 5

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 NEW Fort Pierce Pit Facility containing a crushing plant, asphalt plant, and concrete plant

II.A.2 NEW Crushing Plant

II.A.3 NEW Two (2) Jaw Crushers Capacity: 500 tph (each) NSPS Applicability: 40 CFR 60 Subpart OOO

II.A.4 NEW Two (2) Cone Crushers Capacity: 500 tph (each) NSPS Applicability: 40 CFR 60 Subpart OOO

II.A.5 NEW Four (4) Screening Plants Capacity: 500 tph (each) NSPS Applicability: 40 CFR 60 Subpart OOO

II.A.6 NEW Two (2) Diesel Generators Engine Rating: 600 hp [~447 kW] (each) MACT Applicability: 40 CFR 63 Subpart ZZZZ

II.A.7
NEW
Asphalt Plant

II.A.8 NEW One (1) Asphalt Plant and Mixer Capacity: 500 tph NSPS Applicability: 40 CFR 60 Subpart I

II.A.9
NEW
One (1) Baghouse

II.A.10 NEW One (1) Pugmill NSPS Applicability: 40 CFR 60 Subpart I

II.A.11 NEW Three (3) Lime Silos Vented through vent/fabric filter NSPS Applicability: 40 CFR 60 Subpart I
II.A.12 NEW Six (6) Asphalt Storage Silos Capacity: 300 tons (each)
NSPS Applicability: 40 CFR 60 Subpart I

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 6
II.A.13 NEW Seven (7) Cold Feed Bins
II.A.14 NEW Various RAP Feeder Bins
II.A.15 NEW Concrete Plant

II.A.16 NEW One (1) Concrete Aggregate Batcher and Feed Bin Capacity: 12 Cubic Yards

II.A.17 NEW One (1) Cement Silo with Dust Collector
II.A.18 NEW One (1) Fly Ash Silo with Dust Collector

II.A.19 NEW Miscellaneous Equipment

II.A.20
NEW
Storage Tanks
Contents: Fuel oil and diesel fuel
II.A.21 NEW Off Highway Vehicles Front-end loaders, bulldozers, scrapers, draglines, track-hoes, haul trucks, water
trucks, sweeper truck, forklift trucks, boom trucks, etc.

II.A.22 NEW Miscellaneous aggregate processing equipment Grizzlies, feeders, splitters, traps, load bins, conveyors, screws, cyclones, clarifiers, and stacker

II.A.23 NEW Miscellaneous Welders, pumps, motors, pressure washers, parts washers, and other equipment associated with construction materials processing, manufacture, and maintenance
For informational purposes only.

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 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. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 NEW Site-Wide Requirements
II.B.1.a NEW The owner/operator shall not allow visible emissions from the emission points listed to exceed the following opacities: A. Crushers - 15% opacity B. Screens - 10% opacity C. Conveyor transfer points - 10% opacity
D. Conveyor drop points - 20% opacity
E. Baghouse/bin vent exhaust points - 10% opacity
F. Diesel engines - 20% opacity G. All other points - 20% opacity [R307-401-7]
II.B.1.a.1 NEW Opacity observations shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b NEW The owner/operator shall keep a current list of all aggregate, asphalt and concrete processing equipment listed in the Approved Equipment of this Approval Order. The list must be kept on-site and available to the Director upon request. [R307-401-8]

II.B.1.c NEW The owner/operator shall install a fabric filter on each material storage silo associated with the concrete batch plant and hot mix asphalt plant. Displaced air from each silo shall pass through a fabric filter before being vented to the atmosphere. [R307-401-8]

II.B.1.d NEW The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD) in the generator engines. ULSD has a sulfur content of 15 ppm or less. [40 CFR 60 Subpart ZZZZ]
II.B.1.d.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]
II.B.2 NEW Production & Consumption Requirements

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 8
II.B.2.a NEW The owner/operator shall not exceed the following limits in the aggregate plant:
A. 1,000,000 tons of processed aggregate per rolling 12-month period
B. 3,500 hours of operation per rolling 12-month period [R307-401-8]
II.B.2.b
NEW
The owner/operator shall not exceed the following limits in the asphalt plant:
A. 900,000 tons of asphalt production per rolling 12-month period B. 3,000 hours of operation per rolling 12-month period [R307-401-8] II.B.2.c NEW The owner/operator shall not exceed the following limits in the concrete plant: A. 200,000 cubic yards of concrete production per rolling 12-month period B. 2,500 hours of operation per rolling 12-month period [R307-401-8] II.B.2.d NEW To determine compliance with II.B.2.a, II.B.2.b, and II.B.2.c the owner/operator shall: A. Determine aggregate, asphalt and concrete production using scale house records or
vendor receipts B. Record production and hours of operation on a daily basis C. Determine hours of operation by supervisor monitoring and maintaining an operations
log D. Use the production data and 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
E. Keep the production records for all periods the plant is in operation [R307-401-8]
II.B.2.e NEW The owner/operator shall not use more than 40% of recycled asphalt in the total asphalt product at any time. [R307-401-8]

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 9
II.B.2.e.1 NEW The owner/operator shall determine compliance by dividing the hourly amount of recycled asphalt introduced to the plant by the actual hour production of the plant. The owner/operator shall keep daily records of the following:
A. Total production B. Amount of recycled asphalt used in the total production C. Calculations of the percent recycled asphalt used in the total production [R307-401-8] II.B.3 NEW Asphalt Plant Fuel Requirements
II.B.3.a NEW The owner/operator shall use natural gas, liquified petroleum gas, #1 through #6 fuel oil, or on-specification used oil as fuel in the hot mix asphalt plant. [R307-401-8]

II.B.3.b NEW The owner/operator shall comply with the following in respect to used oil burned at the asphalt plant: A. The concentration/parameters of contaminants in any used oil fuel shall not exceed
the following levels:
(1) Arsenic.................................. 5 ppm by weight
(2) Cadmium............................... 2 ppm by weight
(3) Chromium........................... 10 ppm by weight
(4) Lead................................... 100 ppm by weight
(5) Total halogens................ 1,000 ppm by weight
(6) Sulfur.................................. 0.5 percent by weight
B. The flash point of all used oil to be burned shall not be less than 100 oF. C. The owner/operator shall consider any used oil fuel that contains more than 1,000
ppm by weight of total halogens hazardous waste. The owner/operator shall not burn
such fuel at the asphalt plant. [R307-401-8]

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 10
II.B.3.b.1 NEW The owner/operator shall:
A. Provide test certification for each load of used oil fuel received. Certification shall be
either by their own testing or test reports from the used oil fuel marketer B. Keep records of used oil fuel consumption and test reports for all periods when the
plant is in operation. Records shall be made available to the Director upon request C. Test used oil for halogen content by ASTM Method D-808-81, EPA Method 8240 or
Method 8260 before it is transferred to the asphalt plant storage tank and burned D. Only burn used oil that does not exceed any of the listed contaminants content and
record the quantities of used oil burned on a daily basis
E. Comply with the State Division of Solid and Hazardous Waste in accordance with
R315-15, UAC
[R307-401-8]
II.B.4 NEW Fugitive Emissions and Haul Road Requirements
II.B.4.a NEW The owner/operator shall not allow visible emissions from unpaved roads, unpaved operational areas, haul-road traffic and mobile equipment in operational areas to exceed 20% opacity. [R307-401-8] II.B.4.a.1 NEW Opacity observations of fugitive dust from intermittent sources shall be conducted according to 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. The number of observations
and the time period shall be determined by the length of the intermittent source. For fugitive dust generated by mobile source, visible emissions shall be measured at the densest point of the plume, but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8] II.B.4.b NEW The owner/operator shall control fugitive particulate matter emissions by: A. Spraying all unpaved roads and other unpaved operational areas used by mobile
equipment with water sprays and/or chemical treatments to control fugitive dust
B. Treating at a sufficient frequency and quantity to maintain the surface material in a
damp/moist condition unless the temperature is below freezing
C. Only using chemical treatments that have been approved by the Director
[R307-401-8]

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 11
II.B.4.b.1 NEW The owner/operator shall keep records of water and/or chemical treatment for all periods when the plant is in operation. The records shall include the following items: A. The date of treatment B. The number of treatments made, dilution ratio, and quantity
C. Rainfall received, if any, and approximate amount
D. The time of day treatments were made
[R307-401-8]
II.B.4.c
NEW
The owner/operator shall water storage piles to minimize generation of fugitive dusts to
comply with the opacity limit in this AO. [R307-401-8] II.B.4.d NEW The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive Emissions and Fugitive Dust Sources. [R307-205]
II.B.5 NEW Baghouse Requirements
II.B.5.a NEW The owner/operator shall use a baghouse to control particulate emissions from the hot mix asphalt plant on site. [R307-401-8]
II.B.5.a.1 NEW The owner/operator shall maintain the baghouse such that: A. It is designed to handle at least 12,000 ACFM for the existing conditions B. All exhaust air from the drum mixer is routed through the baghouse before being
vented to the atmosphere
[R307-401-8]
II.B.5.b
NEW
The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
static pressure drop across the hot mix asphalt plant baghouse. [R307-401-8] II.B.5.c 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.5.c.1 NEW The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8] II.B.5.d NEW At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]

II.B.5.e NEW The owner/operator shall maintain the static pressure drop across the hot mix asphalt plant baghouse during operation between 2 and 6 inches of water column. [R307-401-8]
II.B.6 NEW Stack Testing Requirements

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 12
II.B.6.a NEW The owner/operator shall not emit more than the following rates and concentrations from the asphalt baghouse exhaust stack: Pollutant lb/hr grains/dscf (68 degrees F, 29.92 in Hg) PM10 11.50 0.024 PM10 (RAP) 13.41 0.028
[R307-401-8]

II.B.6.a.1 NEW Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8] II.B.6.a.2 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]
II.B.6.a.3 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] II.B.6.b NEW The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]

II.B.6.b.1 NEW Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8]
II.B.6.b.2 NEW Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.6.b.3 NEW Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]
II.B.6.b.4
NEW
Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8]

II.B.6.b.5 NEW Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 13
II.B.6.b.6 NEW Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed
below. [R307-401-8] II.B.6.c NEW Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)
C. Averaging Time - As specified in the applicable test method
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.6.c.1
NEW
PM10
Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. Condensable PM 40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to the Director.
[R307-401-8]

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 14
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN2188004-05 dated January 21, 2005
REVIEWER COMMENTS
1. Comment regarding 10-Year Review:
This is a 10-year review. The language and formatting of this AO have been updated to reflect the style of modern permits. PTE values and the approved equipment list have been moved to respective new sections. All contact information has been updated. The source is not modifying and/or installing any equipment. The PTE for PM2.5 and CO2e were not specified in the previous AO (DAQE-AN2188004-05, dated January 21, 2005) and have been added to the Summary of Emissions. For a conservative estimate, the PTE of PM2.5 was set equal to the PTE of PM10 (20.72 tpy). CO2e was calculated based two (2) 600 hp diesel engines and 8,760 annual operational hours for both engines. CO2e emission factors and global warming potentials were sourced from AP-42 Table 1.4-2 and A-1 to Subpart A of 40 CFR Part 98. There are no other changes to the emission estimates at this time.
[Last updated November 20, 2024]
2. Comment regarding Federal Standard Applicability: NSPS, 40 CFR 60
NSPS Subpart I (Standards of Performance for Hot Mix Asphalt Facilities) applies to hot mix asphalt facilities that commenced construction or modification after June 11th, 1973. The facility includes a hot mix asphalt plant built after 1973, thus Subpart I applies.
NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants) applies
to facilities that operate crushers, screens and belt conveyors among other aggregate processing equipment. The facility includes crushers, screens and other aggregate processing equipment. Therefore, Subpart OOO applies.
Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines) applies to compression ignition (CI) internal combustion engines (ICE). Subpart IIII exempts non-fire pump engines with model years before 2007. On November 11, 2024, the source confirmed that the engines listed in Equipment ID II.A.6 were manufactured in 2003. Thus, the engines were manufactured before the 2007 cutoff and NSPS Subpart IIII does not apply.
NESHAP, 40 CFR 61
There are no applicable NESHAP subparts. MACT, 40 CFR 63 MACT Subpart ZZZZ (National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) applies to facilities which operate reciprocating internal
combustion engines. The two generators at the facility fall under this definition. Thus, Subpart ZZZZ applies.

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 15
MACT Subpart LLLLL (National Emission Standards for Hazardous Air Pollutants: Asphalt Processing and Asphalt Roofing Manufacturing) applies to asphalt processing and asphalt roof
manufacturing at major HAP sources. The facility operates a hot mix asphalt plant but is not a major HAP source. Therefore, Subpart LLLLL does not apply. MACT Subpart AAAAAAA (National Emissions Standards for Hazardous Air Pollutants for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing) applies to asphalt processing and
asphalt roof manufacturing at area sources. However, Subpart AAAAAAA does not apply to hot mix asphalt plants that are used in the paving of roads or hardstand, or applications where the asphalt may be used in the fabrication of a built-up roof. The asphalt processing plant in question is a hot mix plant, therefore Subpart AAAAAAA does not apply to the facility.
[Last updated November 20, 2024] 3. 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. However, the facility is subject to 40 CFR 60 (NSPS) Subparts I and OOO under Section 111 of the Act. Therefore, Title V regulations apply to the facility as an area source. [Last updated October 31, 2024]

Engineer Review N121880006: Western Rock Products Corporation- Fort Pierce Pit December 10, 2024 Page 16
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
SUMMARY
One (1) Engine # of Engines Total Annual Emissions
CO2e 3,048 2 6097
tpy
Equipment Details
Rating 600 hp = (447.8 kw)
Operational Hours 8,760 hours/year
Sulfur Content 15 ppm or 0.0015%
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 0.024 14.40 63.07
CO 5.50E-03 3.30 14.45
PM10 7.00E-04 0.42 1.84
PM2.5 7.00E-04 0.42 1.84
VOC 6.42E-04 0.38 1.69
SO2 1.21E-05 0.01 0.03 AP-42 Table 3.4-1
HAP 0.01 0.03 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 1.16 696 3,048
Methane (mass basis)25 6.35E-05 0 0CO2e3,053
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
Benzene 7.76E-04 3.26E-03 1.43E-02
Toluene 2.81E-04 1.18E-03 5.17E-03
Xylenes 1.93E-04 8.11E-04 3.55E-03
Formaldehyde 7.89E-05 3.31E-04 1.45E-03
Acetaldehyde 2.52E-05 1.06E-04 4.64E-04
Acrolein 7.88E-06 3.31E-05 1.45E-04
Naphthalene 1.30E-04 5.46E-04 2.39E-03
Acenaphthylene 9.23E-06 3.88E-05 1.70E-04
Acenaphthene 4.68E-06 1.97E-05 8.61E-05
Fluorene 1.28E-05 5.38E-05 2.35E-04Phenanthrene4.08E-05 1.71E-04 7.51E-04
Anthracene 1.23E-06 5.17E-06 2.26E-05
Fluoranthene 4.03E-06 1.69E-05 7.41E-05
Pyrene 3.71E-06 1.56E-05 6.82E-05
Benz(a)anthracene 6.22E-07 2.61E-06 1.14E-05
Chrysene 1.53E-06 6.43E-06 2.81E-05
Benzo(b)fluoranthene 1.11E-06 4.66E-06 2.04E-05
Benzo(k)fluoranthene 2.18E-07 9.16E-07 4.01E-06
Benzo(a)pyrene 2.57E-07 1.08E-06 4.73E-06
Indeno(1,2,3-cd)pyrene 4.14E-07 1.74E-06 7.62E-06
Dibenz(a,h)anthracene 3.46E-07 1.45E-06 6.37E-06Benzo(g,h,l)perylene 5.56E-07 2.34E-06 1.02E-05
Emission Factor
(lb/MMBtu)
AP-42 Table 3.3-2,
Table 3.4-3, &
Table 3.4-4
(1,3-Butadiene will
not popluate if the
engine size is greater
than 600 hp. AP-42
does not list 1,3-
Butadiene for engines greater than
600 hp.)
Diesel-Fired Engines
Emergency Engines should
equal 100 hours of operation
per year
Manufacturer Data,
AP-42 Table 3.3-1,
& Table 3.4-1
AP-42 Table 3.3-1
& Table 3.4-1
Page 2 of 2 Version 1.1
February 21, 2019
2/28/23, 11:37 AM State of Utah Mail - Utah Division of Air Quality Periodic Review
https://mail.google.com/mail/u/0/?ik=1e137a1c28&view=pt&search=all&permmsgid=msg-a%3Ar-622581799179368361&simpl=msg-a%3Ar-62258179…1/1
Colby Johnson <[e-mail]>
Utah Division of Air Quality Periodic Review
Colby Johnson <[e-mail]>Mon, Feb 6, 2023 at 2:21 PM
To: "Scovill, Nakeasha (Staker Parson)" <[e-mail]>
Hi Nakeasha,
The Utah Division of Air Quality is conducting a 10-year review of Western Rock Products Corporation - Fort Pierce Pit
and the Approval Order (AO) associated with it (DAQE-AN2188004-05).
The original AO was issued in 2005 but it appears you are the current listed contact from our most recent compliance
documentation/visits (May 2021).
Our 10-year review process will primarily update the formatting and language on the AO to make it similar to modern
permits. The permit requirements will stay the same. However, if state or federal laws have changed since the AO was
issued, the requirements in the AO may be subject to change. You or your company will NOT be charged anything for
this project.
I just have a few things to confirm with you to get this process started:
1. Are you still the best person to contact regarding this site and Approval Order?
2. Can you confirm the following mailing address, physical address, coordinates, and site name:
Mailing: 820 North 1080 East, St. George, Utah 84701
Physical: 2 miles east of the Bloomington exit south of St. George, Washington County, Utah
UTM Coordinates: 4,102.2 km Northing, 274.5 km Easting (Zone 12)
Site Name: Western Rock Products Corporation - Fort Pierce Pit
Best Regards,
--
Colby Johnson
Environmental Engineer
Phone: [phone]
Email: [e-mail]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
2/28/23, 11:37 AM State of Utah Mail - Utah Division of Air Quality Periodic Review
https://mail.google.com/mail/u/0/?ik=1e137a1c28&view=pt&search=all&permmsgid=msg-f%3A1757188020076464647&simpl=msg-f%3A1757188020…1/2
Colby Johnson <[e-mail]>
Utah Division of Air Quality Periodic Review
Scovill, Nakeasha (Staker Parson) <[e-mail]>Tue, Feb 7, 2023 at 8:51 AM
To: Colby Johnson <[e-mail]>
Good morning,

Please see the responses in red below. Let me know if you need anything else.

From: Colby Johnson <[e-mail]>
Sent: Monday, February 6, 2023 2:22 PM
To: Scovill, Nakeasha (Staker Parson) <[e-mail]>
Subject: [EXT] Utah Division of Air Quality Periodic Review

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
are expecting this email and know the contents are safe. If you believe this email may be phishing or malicious,
please use the Report Phish button.
Hi Nakeasha,

The Utah Division of Air Quality is conducting a 10-year review of Western Rock Products Corporation - Fort Pierce Pit
and the Approval Order (AO) associated with it (DAQE-AN2188004-05).

The original AO was issued in 2005 but it appears you are the current listed contact from our most recent compliance
documentation/visits (May 2021).

Our 10-year review process will primarily update the formatting and language on the AO to make it similar to modern
permits. The permit requirements will stay the same. However, if state or federal laws have changed since the AO was
issued, the requirements in the AO may be subject to change. You or your company will NOT be charged anything for
this project.

I just have a few things to confirm with you to get this process started:
1. Are you still the best person to contact regarding this site and Approval Order? Yes
2. Can you confirm the following mailing address, physical address, coordinates, and site name:
Mailing: 820 North 1080 East, St. George, Utah 84701 In regards to anything dealing with Air Quality
please use the following mailing address: 89 West 13490 South, Suite 100 Draper, Utah 84020 (with
attention to myself if possible)
Physical: 2 miles east of the Bloomington exit south of St. George, Washington County, Utah A little more
accurate: 1834 E 4150 S, St. George, Utah 84790
UTM Coordinates: 4,102.2 km Northing, 274.5 km Easting (Zone 12) A little more accurate: 273616.97 mE
4102050.22 mN
2/28/23, 11:37 AM State of Utah Mail - Utah Division of Air Quality Periodic Review
https://mail.google.com/mail/u/0/?ik=1e137a1c28&view=pt&search=all&permmsgid=msg-f%3A1757188020076464647&simpl=msg-f%3A1757188020…2/2
Site Name: Western Rock Products Corporation - Fort Pierce Pit - Correct
Best Regards,
--

Colby Johnson
Environmental Engineer
Phone: [phone]
Email: [e-mail]
airquality.utah.gov

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

ATTENTION: Ce courriel vient de l'exterieur de l'entreprise. Ne cliquez pas sur les liens, et n'ouvrez pas les pièces
jointes, à moins que vous ne connaissiez l'expéditeur du courriel et savez que le contenu est sécuritaire. Si vous
pensez qu’il s’agit d’un courriel d’hameçonnage ou malveillant, veuillez cliquer sur le bouton Signaler une tentative
d’hameçonnage.
Lucia Mason <[e-mail]>
5 New 10-year reviews
1 message
Alan Humpherys <[e-mail]>Thu, Jun 13, 2024 at 8:08 AM
To: Lucia Mason <[e-mail]>
Lucia,
Here are 5 more 10-year reviews. They were initially started by another engineer, so the projects are created with some work done already. Please let me know
what questions you have.
Project #1: 12188-0006
Old AO: DAQE-AN2188004-05
Peer: EQ
Project #2: 12101-0007
Old AO: DAQE-493-01
Peer: Tim
Site #3: 10520-0004
Old AO: DAQE-1041-93
Peer: Dylan
Site #4: 10954-0002
Old AO: DAQE-251-93
Peer: Christine
Site #5: 10017-0004
Old AO: DAQE-AN0100170001-09
Peer: Tim
Thanks,
Alan
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
8/22/24, 12:14 PM State of Utah Mail - 5 New 10-year reviews
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801755276052051181&simpl=msg-f:1801755276052051181 1/2
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
8/22/24, 12:14 PM State of Utah Mail - 5 New 10-year reviews
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1801755276052051181&simpl=msg-f:1801755276052051181 2/2
Lucia Mason <[e-mail]>
Western Rock Products Env. Contact
2 messages
Meikle, Travis L (Staker Parson) <[e-mail]>Thu, Jul 25, 2024 at 2:38 PM
To: "[e-mail]" <[e-mail]>
Cc: "Rose, Chris (Staker & Parson Companies)" <[e-mail]>
Lucia,

I received the voice message you left about needing the environmental contact for Western Rock Products. Chris Rose is our Environmental Specialist his phone
number is [phone] and his email is [e-mail]. He is Cc’d on this email. Please reach out to me or Chris if you need additional
information.

Thank you.

Travis Meikle
General Manager

Western Rock Products
A CRH COMPANY
4617 S. Pioneer Rd., Ste 300
St. George, UT 84790

O [phone]
C [phone]
E [e-mail]

8/22/24, 12:14 PM State of Utah Mail - Western Rock Products Env. Contact
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1805584852920837551&simpl=msg-f:1805584852920837551&simpl=msg-a:r-4496148466185022315 1/2
www.westernrock.com

Lucia Mason <[e-mail]>Thu, Jul 25, 2024 at 5:10 PM
To: "Meikle, Travis L (Staker Parson)" <[e-mail]>
Thank you! I'll be in touch with Chris soon.
[Quoted text hidden]
8/22/24, 12:14 PM State of Utah Mail - Western Rock Products Env. Contact
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1805584852920837551&simpl=msg-f:1805584852920837551&simpl=msg-a:r-4496148466185022315 2/2