DERR-2025-003212

ASH GROVE CEMENT COMPANY
A CRH COMPANY
WESTERN REGION
Hwy 132 6 Miles East of Leamington
LEAMINGTON, UTAH 84638
PHONE [phone] FAX [phone]
April 7, 2025
Utah State Emergency Response Commission
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84116
Juab County Sherriffs Office (Juab County LEPC)
P.O. Box 133
Nephi, UT 84648
Re: Ash Grove Cement Company, Leamington, UT Continuous Release, Written
Notification of a Change to a Follow-up Report (NRC Incident Report #1426313)
Initial Written Notification Report (NRC Incident Report #1351327)
Dear SERC and LEPC Representatives:
On behalf of Ash Grove Cement Company, I am writing to provide additional information about
the continuous release of ammonia from the main kiln stack at our cement plant located in
Leamington, Utah. This follows the initial telephone notification made on March 19, 2025 of a
statistically significant increase compared to our previously reported continuous release.
Pursuant to 40 CFR 355 .32, enclosed with this letter is a copy of the Written Notification of a
Change to Follow-up Report of the continuous release, as specified in 40 CFR 302.8(g)(2)(ii),
which we separately submitted to the appropriate office of the U.S. EPA.
Please let me know if you have questions about the enclosure.
Sincerely yours,
Ol~*~
Josh Ison '1' \1 \16
anager
Ash Grove Cement Company
Continuous Release Reporting Form
SECTION I: GENERAL
INFORMATION
Date of Initial Release: 103/19/2025 I
Form Approved 0MB No. 2050-0086
Expiration Date : 11-30-2022
CR-ERNS Number: 11426313
Date of Initial Call to NRC:103/19/2025
I
I
Type of Report: Select from the drop-down list, ~ the type of report that you Written Notification of a Change to Follow-up Report
are submitting
Signed Statement: 1 certify that the ha z ardous substance releases des cribed herein are continuous and stable in quantity
and rate under the definitions in 40 CFR 302.8 (a) or 355.32 and that all submitted information is accurate and current to the
best of my knowledge.
Do,e ~ U\, 1111A A.\t. Na m e and Positio11 IJosh Nelson Plant Manager I Signa ture (
I
\
\J
Part A. Facility or Vessel lnformation
Name of Facility or Vessel IAsh Grove Cement Company-Leamington Plant I
Person in Charge Name !Josh Nelson I Position I Plant Manager I of Facility or
Vessel Phone Number j435-857 -1200 I Alt Phone No . I I
Facility Address Street 16 Miles East of Leamington I Co unty jJuab I or Vessel Port of
Registration City I Leamington I State ~_] Zip Code j84638 I
Dun and Bradstreet Number for Facility 101-966-9803 I
Facility Nessel Latitude Deg ~Mm @I] Sec [ill Vessel LORAN Coordinates
Location
Longitude Deg [DMin ~ s~c Li
NOTE: Latitude/Longitude infimna1ion ca11 be abtai11 ed a, thefi>llowi 11 g websiles :hup://www.satsig.11et/111 apsllat-lo11g-fi11 der.htm,http://eanh.google.com/.
and http://www.census.gov/geo/landviewl. Do not us e P.O. Box, Rural Route o r Mailing Address. Use physical lo cation 011/y.
Part B. Population Information
Population
Density
Select from the drop-down list, the range that l
describes the population dens ity within a one-0-50 Persons
mile radi us o f your facility or vessel.
"" ..
...
Sensitive
Populations and
Ecosystems within
One-Mile Radius
Sensitive Popuiations or Ecosystems Estimate d Distance and Direction from
(e.g., e le menta ry sc hools. hosp it als. ret ir e ment communi ties. Facility, if Known
or wetlands·\
I None 11 I
EPA Fann 6100-10 , Continuous Release Reporting Form Paget of 5
Continuous Release Reporting Form
Form Approved 0MB No. 2050-0086
Expiration Date: 11-30-2022
/SECTION II: SOURCE
INFORMATION 11 CR-ERNS Number: 11426313
Part A: Basis for Assertin2 the Release is Continuous and Stable in Quantit)'. and Rate.
For EA CH source of a release of a hazardous substance or mixture from your facility or vessel, provide
the following information on a SEP ARA TE sheet.
I Name of Source: I Kiln Main Stack
I. Indicate whether the re lease from this source is either:
□ Continuous without intenuption OR [8]
routine , anticipated, intermittent & incidental to
Note that unanticipated events, such as spills, pipe ruptures, equipment.failures, emergency shutdowns, or
accidents, do not qual[fy for reduced reporting under CERCLA section 103(/)(2). Unanticipated events are
not incidental to normal operations and, by definition, are not continuous or anticipated, and are not
sufficiently predictable or regular to be considered stable in quantity and rate.
i 2. Provide a brief statement describing the basis for stating that the release is continuous and stable in quantity and rate .
If malfunction, describe the malfunction and explain why the release from the malfunction should be considered
continuous and stable in quantity and rate given the note ab ove .
Ammonia is a natural byproduct of processing raw materials in the kiln as well as a byproduct
of the pollution control device employed on the main stack
3. Identify below how you established the pattern or release and calculated re lease estimates.
[8] Release data [8]Knowledge of Operating Procedures O Engineering estimate O Best Professional judgment
Other -
EPA Form 6100-10. Continuous Release Reporting Fom1 Page 2 of 5
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Continuous Release Reporting Form
SECTION II: SOURCE
INFORMATION
( continued)
I Name of Source: I Kiln Main Stack
Part B: Specific Information on the Source
Form Approved 0MB No. 2050-0086
Expiration Date : 11-30-2022
E-ERNSNumber: 11426313
For the source identified above, provide the following information. Please provide a SEP ARA TE sheet for
EA CH source.
AFFECTED MEDIUM. Identify the en v ironmental medium (i .e ., air, surface water, soil, or ground water) that is affected
by the release from this source . lfyour source re lease s hazardous substances to more than one medium (e .g ., a wastepile releasing
to air and ground water), treat the release to EACH medium as a sep arate source and complete Section II , Parts A, B, and C, of this
fonnat for EACH medium affecte d.
@ AIR If the medium affected is air, please also specify whether the source is a stack or a ground-based area source.
~ Stack Indicate stack height in feet or meters I 295 ft
Q SURFACE WATER
lfthe release affects an y surface water body, giv e the nam e of th e wate r body .
Surface
D Water Body
D Stream ff the releas e affe c ts a stream, g ive the stream order or avera ge tlow rate, in cubic feet per second .
Stream Order I OR Avera ge Flow R ate (cubic fee t/second)I
--------..::::::::::====;=~==~
Surface area of lake (in acres)'--1 _____ __,I Ave ra ge depth of lake (in meters)'--1 _____ __, D Lake
I f the releas e affects a Jake , giv e the surface area of th e lake in acres and the average depth in meters .
Q SOIL OR GROUND WATER
If the release is on or under ground , the loca tion of public water sunnl v wells withm tw o miles .
Optional Information
The fo ll owin g in fo rmati on is no t re quired lo compl y w ith th e regulation: howeve r, such informati o n w ill assi st EPA in evalu atin g the risk s
assoc iated with th e continu o us release . If thi s information is 1101 provided, EPA will mak e conservative assumption~ about the appropriate
values. Pl ease note that the un its s pec i tied be low are sugges ted uni ts. You may use utlw r un its: howeve r, be ce rtain th at the un its are clearl y
identified .
Fo r a stac k rel ease to ai r, provide the fo ll ow in g info rma io n. if avai lab le :
In side di ameter (feet o r meters) ~ Gas Ex it Ve loc ity /fl or meters/sec) B Gas Temp (d egrees Fa hrenh eit , Kelv in, or Celsiu s) ~~
For a release to s urface water. prov id e th e fo ll owin g in fo rm ation, if ava il able:
Ave rage ve locity of surface w ater (feet/second) ~! -------~
'EPA Fom1 6100 -10 , Continuous Releas e Re porting Form Page 3 of 5
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Continuous Release Reporting Form
SECTION II: SOURCE INFORMATION
( continued)
Fonn ·A:pprove<l OMBNo . 2050-0086
Ex piration Date : 11-30-2022
CR-ERNS Number: 11426313
Part C: Identity and Quantity of Each Hazardous Substance or Mixture Released From Each Source
Pleas e provide a SEPARATE sheet for EACH source.
I Name of Source: !Kiln Main Stack
List each hazardous substance released from the source identified above and provide the following information. Include units where appropri ate . R adio nu clides in curies (C i).
Nom1al Range
(in lb s., kg, or Ci per day)
Name of Hazardous Substance CASRN # Upper Bound Lower Bo und
Number of Days
Release Occurs
jper year)
Total Quantity
Re leased in Previous Year
.Lin lb s ., kg, or C i)
Period of the
Re lease
II
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List each mixture released from the source identified above and provide the following information. Include unit s where appropriate. Radionuclides in curies (Ci).
Name of Mixture
L
Nam e o f Hazardous
Substance
Co mponents
Nonnal Ran ge of loRI Nonnal Ran ge of
Components t...:::..=_J Mixture
(in lb s., kg, or Ci per day) (in lbs ., kg, or Ci per day)
Weight Upper Lower Upper Lower
CASRN # Percentage Bound Bound Bound Bound
Number of Day s
Re lea se Occurs
(per year)
Total Quantity of
Mixture Rele ase d
in Prev io us Year
(in lb s ., kg or Ci)
Period of
the
Release
1 1._ ··-·--···· J I ··············-·.l l _ ............ !I .. . .J I_ ..... i I JI ... JI I L ..
: l·-···---l I ............................... J t 1 I l I ......... .J .. J I ............................... I I JI __ ./ I ·-·-···················-' I
: I JI.. ! L : I : I ....... 1 ······ ; I J L ....... I L _ 1t :1
EPA Form 6 I 00 -10 , Continuous Release Reporting Form t'age 4 0 1 5
Continuous Release Reporting Form
Form Approved 0MB No . 2050-0086
Expiration Date: 11-30-2022
I
SECTION III: SUBSTANCE 11 I
'--· _____ IN_F_O_RMA_· _T_IO_N ___ __. CR-ERNS Number: 1426313
Calculation of the SSI Trigger
For EACH hazardous substance component of a mixture indicated in Section II, Part C, list the names of
the releasing sources and their upper bounds. Please use a SEPARATE sheet for EACH hazardous
substance.
Name of Hazardous Substance: !Ammonia
To calculate the SSI trigger (i.e ., the upper bound of the nonnal range of a release) for the hazardous substance identified
above, aggregate the upper bounds of the normal range of the identified hazardous substance across all sources identified in
Section II, Part C. If the hazardous substance is also a component of a mixture, be certain to include the upper bound of the
component as calculated in Section IT , Part C , in your calculation of th e SSI trigger.
Name of Source (s)
Upper Bound of the Nom1al Range of
the Release (specify lbs., kg ., or Ci)
TOTAL -SSI trigger for this hazardous substance release*: 2,100 lbs
* This method for calcula ting the SSI trigger for the hazardous substance assumes that all releases of the
s ame hazardous substance or mixture occur simultaneously. To the extent that a hazardous substance is
released from your facility fi'orn different sources and at different frequencies, y ou may adjust the SSI trigger
as appropriate so that it more accurately reflects the frequency and quantity of the release. The SSI trigger
in the final analysis must reflect the upper bound of the normal range of the release, taking into
consideration all sources of the release at the.facility or vessel. The normal range of the release includes all
releases previously reported or occurring over a 24-hour period during the previous year.
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EPA Fom1 6100-10 , Continuous Release Reporting Form
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