DAQ-2025-002269

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DAQC-402-25
Site ID 10011 (B1)

MEMORANDUM

TO: FILE – STAKER & PARSON COMPANIES – Brigham City North Pit

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Haynes, Environmental Scientist

DATE: April 28, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, SM-80, Box Elder County,
FRS #UT0000004900300012

INSPECTION DATE: Inspection on April 23, 2025. Records received April 25, 2025.

SOURCE LOCATION: 33 South 900 East, Brigham City, UT

MAILING ADDRESS: Corporate Office:
P.O. Box 3429, Ogden, UT 84409

SOURCE CONTACTS: J Cowlishaw, Environmental Specialist: 385-405-4315
[e-mail]

Chad Beimer: 801-388-0431

Scott Leishman: 435-374-8840

Mike Jensen, Asphalt Plant: 801-430-5076

OPERATING STATUS: The concrete batch plant and the asphalt plant were operating at time of
inspection. The aggregate and wash plants were down for maintenance.

PROCESS DESCRIPTION: The Staker & Parson Brigham City North Pit produces aggregate material
that is used to produce on-site concrete and asphalt. The concrete and
asphalt products are trucked to other Staker & Parson facilities.

APPLICABLE REGULATIONS:

Approval Order DAQE-AN100110007-15 dated March 20, 2015

SOURCE EVALUATION:

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]

Status: This is a statement of fact and not an inspection item.
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I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
Status: In compliance – No limitations were noted to be exceeded at time of inspection.

I.3 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]

Status: In compliance – Records were provided at time of inspection.

I.4 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]

Status: In compliance – The source appeared to be well maintained and properly operated at the
time of inspection. Maintenance activities are tracked with the PEAK 2 database. The E-Maintenance database is currently being implemented, to track preventative
maintenance (PM).

I.5 The owner/operator shall comply with R307-150 Series. Inventories, Testing, and Monitoring.
[R307-150]

Status: In compliance – According to the Brigham City North Pit and the SLEIS database the
emission inventories are required to be submitted every 3 years. The 2023 emission
inventory was received, by the DAQ, on April 19, 2024. See the SLEIS database and
emission inventory below.

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
Status: In compliance – No breakdowns have occurred since the last inspection, conducted on
May 30, 2023.

I.7 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]

Status: In compliance – No modifications to the equipment or processes were noted at time of the
inspection.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:
II.A.1 The Brigham City North Pit
Aggregate Processing, Asphalt and Concrete Batch Plants

II.A.2 The Aggregate Processing Plant - New Equipment
One (1) Jaw Crusher rated at 500 tons per hour (tph) - Subpart OOO
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II.A.3 One (1) Cone Crusher rated at 500 tph, Mfg. 2005 - Subpart OOO
II.A.4 One (1) Impact Crusher rated at 500 tph, Mfg. 2004 - Subpart OOO

II.A.5 Four (4) Screens, 8' x 20' each, Mfg. 2004 - Subpart OOO
II.A.6 One (1) Screen, 6' x 18', Mfg. 2004 - Subpart OOO

II.A.7 One (1) Double Deck Screen, 8' x 20', Mfg. 2005 - Subpart OOO
II.A.8 Two (2) Double Deck Screens, 8' x 20' each - New Equipment, Subpart OOO
II.A.9 Two (2) Power Screens rated at 250 tph each - Subpart OOO
II.A.10 Three (3) Overhead Loadout Bins, 250 tons each - Subpart OOO

II.A.11 The Asphalt Plant
One (1) Asphalt Plant - Subpart I
II.A.12 One (1) Baghouse, 45,000 acfm - Subpart I
II.A.13 Four (4) Liquid Asphalt Storage Tanks, 25,000 gallons each

II.A.14 Three (3) Asphalt Storage Silo, 300 tons

II.A.15 One (1) Lime Storage Silo, 900 barrels
II.A.16 Eight (8) Cold Feed Bins, (2) Recycle Bins

II.A.17 The Concrete Batch Plant
One (1) Concrete Batch Plant, 140 cubic yards per hour, equipped with a baghouse to control fugitive emissions from truck loading

II.A.18 One (1) Concrete Plant Loadout Baghouse

II.A.19 One (1) Double Cement Storage Silo, 180 tons (equipped with a dust collector)
II.A.20 One (1) Flyash Storage Silo, 51 tons (equipped with a dust collector)

II.A.21 One (1) Direct Contact Water Heater rated at 10.0 MMBtu/hr
II.A.22 The Sand Plant - New Equipment
One (1) Sand Plant, 100 tons per hour, equipped with a baghouse to control particulate emissions

II.A.23 Five (5) Material Feed Bins
II.A.24 One (1) Drum Dryer

II.A.25 For All Plants
Associated Miscellaneous Equipment including conveyors, stackers, screens, and transfer augers - Subpart OOO

II.A.26 Associated Miscellaneous Equipment including loaders, haul, and water trucks

Status: In compliance – No unapproved equipment was noted on site. II.A.2 Jaw Crusher has been replaced with Grizzly screen. Items II.A.22, II.A.23, and II.A.24 no longer onsite.
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II.B.1 Site-wide Requirements
II.B.1.a Staker and Parson Companies shall notify the director in writing when the installation of the
new equipment listed in Condition II.A has been completed and is operational. To ensure
proper credit when notifying the director, send your correspondence to the director, Attn:
Compliance Section.
If the construction and/or installation have not been completed within eighteen months from
the date of this AO, the director shall be notified in writing on the status of the construction and/or installation. At that time, the director shall require documentation of the continuous
construction and/or installation of the operation and may revoke the AO. [R307-401]
Status: In compliance – The new asphalt plant was already operating under the temporary
relocation permit, DAQE-AN0115180013-10, April of 2013, therefore no notification is required.

II.B.1.b Visible emissions from any stationary point or fugitive emission source associated with the
source shall not exceed 20% opacity, except where indicated otherwise. Opacity observations
of emissions from stationary sources shall be conducted in accordance with 40 CFR 60,
Appendix A, Method 9. [R307-401]
Status: In compliance – All stationary points (concrete batch and asphalt plants), and fugitive
visible emissions detected at time of the visit were less than 10% opacity. The attached
VEO of the concrete mix plant’s top exit shows no visible emissions (see attached VEO
form).

II.B.1.c The following production and/or consumption limits shall not be exceeded:
A. 2,800,000 tons of processed aggregate per rolling 12-month period

B. 300,000 tons of pit run material per rolling 12-month period
C. The allowable operating hours for the aggregate processing plant shall be between
4:00 am and 11:00 pm.
D. 350,000 tons of asphalt production per rolling 12-month period

E. 4,000 tons of petroleum contaminated soils used per rolling 12-month period
F. 292,000 tons of sand processed per rolling 12-month period

G. The allowable operating hours for the sand processing plant shall be between 9:00 am
and 5:00 pm.
H. 150,000 cubic yards of concrete production per rolling 12-month period

I. 86,100 MMBtu of natural gas consumption per rolling 12-month period

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To determine compliance with a rolling 12-month total the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12
months. Records of consumption/production shall be kept for all periods when the plant is in
operation. Production/consumption shall be determined by the belt scale on the initial feeder,
vendor receipts, or other methods approved by the director. The records of
consumption/production shall be kept on a daily basis. Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. Natural gas consumption shall
be determined by monthly billing statements from a utility company. [R307-401-8]
Status: In compliance – Plant production and/or consumption for the rolling 12-month period
April 2024 through March 2025:

Item Material Limit Actual
A Processed Aggregate 2,800,000 Tons 2,319,432 Tons
B Pit Run Material 300,000 Tons 20,200 Tons
C Hours of Aggregate Processing 4:00 am – 11:00 pm Within Hours
D Asphalt Production 350,000 Tons 168,562 Tons
E Petroleum Contaminated Soil Used 4,000 Tons 0.0 Tons
F Sand Processed 292,000 Tons 0.0 Tons
G Hours of Sand Processing 9:00 am – 5:00 pm 0.0 Hours
H Concrete Production 150,000 Cubic Yards 57,111 Cubic Yards
I Natural Gas Consumption* 86,100 MMBtu 38,962 MMBtu

*Note: Natural gas consumption was for the rolling 12-month period March 2024
through February 2025.

II.B.2

II.B.2.a
Roads and Fugitive Dust Limitations and Requirements

The owner/operator shall abide by all applicable requirements of R307-205 for Fugitive
Emission and Fugitive Dust sources. [R307-205]

Status: In compliance – All visible emissions from haul roads and operational areas, detected at
time of inspection, were less than 20% opacity. It appeared that proper management
practices are in place. See attached VEO Form.

II.B.2.b Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational
areas shall not exceed 20% opacity at any point. Visible emission determinations shall use 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. [R307-401-8]
Status: In compliance – haul-road traffic did not appear to exceed opacity limit.

II.B.2.c All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless the air temperature
at the site is below freezing. All paved haul roads shall be controlled by a combination of
sweeping and watering. The opacity shall not exceed 20% during all times the areas are in use.
If chemical treatment is to be used, the plan must be approved by the director. Records of
water and/or chemical treatment and sweeping activity shall be kept for all periods when the plant is in operation. The records shall include the following items:

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A. Date;
B. Number of treatments made, dilution ratio, and quantity;

C. Rainfall received, if any, and approximate amount;
D. Time of day treatments were made;

E. Sweeping activity or area swept;
F. Records of temperature if the temperature is below freezing. [R307-401-8]
Status: In compliance – A dedicated water truck was operating at time of the inspection and is
used when needed. Water records contained the required information. Sweeping Utah or Staker & Parson sweeps paved roads as needed. Magnesium chloride applications are
done 3 times per year, and the last application was on March 28, 2025.

II.B.2.d The in-plant haul roads shall not exceed the following limitations:
A. Unpaved haul roads shall not exceed 1.2 miles in length

B. Paved haul roads shall not exceed 1.32 miles in length

C. Both unpaved and paved haul roads shall have a speed limit of 15 mph
The haul road speed shall be posted, at a minimum, on site at the beginning of the haul road so
that it is clearly visible from the haul road. [R307-401-8]

Status: In compliance – Haul road lengths appeared to be within required distances. Road lengths were confirmed during NSR. Several speed limit signs posted throughout facility.

II.B.2.e The storage piles shall be watered to minimize generation of fugitive dusts, as conditions
warrant or as determined necessary by the director. Records of water and/or chemical
treatment shall be kept for all periods when the plant is in operation. [R307-401-8]
Status: In compliance – Storage piles are watered by the water truck as needed with attached
side sprays. See status of condition II.B.2.c.

II.B.3 NSPS Subpart OOO Affected Equipment
II.B.3.a Visible emissions from the following emission points shall not exceed the following values:

A. Crushers that commenced construction, were modified, or reconstructed before April
22, 2008 - 15% opacity;
B. Crushers that commenced construction, were modified, or reconstructed after April 22,
2008 - 12% opacity;

C. Screening operations and conveyor belt transfer points that commenced construction, were modified, or reconstructed before April 22, 2008 - 10% opacity;

D. Screening operations and conveyor belt transfer points that commenced construction,
were modified, or reconstructed after April 22, 2008 - 7% opacity;
E. All Conveyor Drop Points - 20% opacity;

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F. All Diesel Engines - 20% opacity;
G. All Other Points - 20% opacity.

[40 CFR 60 Subpart OOO, R307-401-8]

Status: In compliance – There were no visible emissions detected from operations at time of
inspection. See status of condition II.B.1.b.
II.B.3.b Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:
A. All crushers
B. All screens C. All conveyor transfer points
The sprays shall operate whenever conditions warrant or as determined necessary by the
director.
[ 40 CFR 60 Subpart OOO, R307-401-8]

Status: In compliance – The required water sprays have been installed and are operational.

II.B.4 Subpart I Affected Equipment
II.B.4.a The baghouse shall control process streams from the asphalt plant drum. This baghouse shall
be sized to handle at least 45,000 ACFM for the existing conditions. All exhaust air from the
drum shall be routed through the baghouse before being vented to the atmosphere. [R307-401]

Status:

In compliance – All ducting was in place and it appeared that exhaust from the asphalt
plant drum was routed through the baghouse. The ACFM was confirmed during NSR
process.

II.B.4.b The following operating parameters shall be maintained within the indicated ranges:

A. Asphalt Plant Baghouse
The pressure drop shall not be less than 0.5 inches of water column or more than 6.0 inches of
water column.

They shall be monitored with equipment located such that an inspector/operator can safely read the output any time. The readings shall be accurate to within the following ranges:

B. Pressure drop - Plus or minus 0.5 inches of water column

All instruments shall be calibrated according to the manufacturer’s instructions at least once every 12 months. [R307-401]

Status: In compliance – An electronic baghouse pressure drop gauge is in the control room. No
pressure reading was taken because the baghouse was not running during inspection.

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II.B.4.c Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Asphalt Plant Baghouse Exhaust Stack
Pollutant lb/hr grains/dscf (68 of, 29.92 in Hg)
PM10 5.40 0.024
PM10 (RAP) 6.30 0.028
[R307-401-8]

Status:

In compliance – The last stack test performed on the Gencor 300 Hot Mix Asphalt Plant
was conducted on July 20, 2023 (DAQC-1007-23). Stack test results:

Pollutant Actual Emissions
(lb/hr)
Limit
(lb/hr)
Actual Emissions
(gr/dscf)
Limit
(gr/dscf)
PM10 - 5.40 - 0.024
PM10 (RAP) 1.97 6.30 0.001 0.028
Note: During this set of tests, the plant was operating on recycled asphaltic product
(RAP).

II.B.4.d Stack testing to show compliance with the emission limitations stated in the above condition
shall be performed as specified below:

A. Emissions Point Pollutant Testing Test
Emissions Point Pollutant Status Frequency
Asphalt Plant PM10 (Virgin and RAP) * @
Baghouse Stack

B. Testing Status
* PM10 testing was performed on September 18, 2014.

@ Test every five years. The director may require testing at any time.
Compliance testing shall not be required for both virgin and recycled materials
during the same testing period. Testing shall be performed for the product
being produced during the time of testing.

C. Notification

The director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the director.

The source test protocol shall be approved by the director prior to performing the test. The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the director.

D. Sample Location

The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other methods as approved by the director. An Occupational Safety and
Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved
access shall be provided to the test location.
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E. Volumetric Flow Rate

40 CFR 60, Appendix A, Method 2 or other testing methods approved by the director.
F. PM10

The following methods shall be used to measure filterable particulate emissions: 40 CFR 51,
Appendix M, Method 201 or 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.

The following methods shall be used to measure condensable particulate emissions: 40 CFR
51, Appendix M, Method 202, or other EPA-approved testing method, as acceptable to the
director.

The condensable particulate emissions shall not be used for compliance demonstration, but
shall be used for inventory purposes.

G. Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the director, to give the results in the specified units of the
emission limitation.

H. New Source Operation

For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the production rate listed in this AO. If the maximum AO allowable
production rate has not been achieved at the time of the test, the following procedure shall be
followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be
110% of the tested achieved rate, but not more than the maximum allowable
production rate. This new allowable maximum production rate shall remain in
effect until successfully tested at a higher rate.

3) The owner/operator shall request a higher production rate when necessary.
Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the
test is successful. This process may be repeated until the maximum AO
production rate is achieved.

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I. Existing Source Operation

For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three (3) years.
[R307-401]

Status: In compliance – The stack test report was received, reviewed, and accepted by the DAQ.
See status of condition II.B.4.c and source files.

II.B.4.e Visible Emissions from the baghouse exhaust stack and silo binvent exhaust points shall not exceed 10% opacity.
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9.
For sources that are subject to NSPS, opacity shall be determined by conducting observations
in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. [R307-401]

Status: In compliance – A VEO was performed on the top exit of the concrete mix plant at time
of the inspection, and no emissions were observed (0% opacity). See attached VEO Form.

II.B.5 Concrete Batch Plant
II.B.5.a Visible Emissions from the concrete plant loadout baghouse and the storage silos shall not
exceed 10% opacity.
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401]

Status: In compliance – Emissions from the concrete loadout baghouse and storage silos were less than 10% opacity.

II.B.6 Fuel and Fuel Combustion Equipment Requirements and Limitations:

II.B.6.a The owner/operator shall use natural gas as a fuel for the water heater, and natural gas, liquid propane fuel, on-specification used oil, #1 to #6 fuel oil, or biofuel as fuel sources for the
asphalt plant. The owner/operator shall use fuel oil as fuel for other on-site equipment.
[R307-401-8]

Status: In compliance – No fuels other than the ones specified are used on-site.

II.B.6.b The sulfur content of any fuel oil or diesel burned shall not exceed:
A. 0.50 percent by weight for fuels used in the asphalt plant.
B. 15 ppm by weight for diesel fuels consumed in all other equipment.
[R307-401-8]

Status: In compliance – The most recent Pilot Thomas Logistics invoice showed Ultra-Low
Sulfur Diesel (ULSD) was delivered to the facility on April 21, 2025.

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II.B.6.c Visible emissions from the water heater shall not exceed 10% opacity. Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A,
Method 9. [R307-401-8]

Status: In compliance – No visible emissions from the water heater were observed at the time of
inspection.

II.B.6.d Sources burning used oil for energy recovery shall comply with the following:

A. The concentrations/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 degrees F.
C. The owner/operator shall 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. Records of used oil fuel consumption and the test reports shall be
kept for all periods when the plant is in operation. Records shall be made available to
the director or the director's representative upon request. The records shall include the
three-year period prior to the date of the request.

D. Used oil that does not exceed any of the listed contaminants content may be burned.
The owner/operator shall record the quantities of oil burned on a daily basis.

E. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall
be considered a hazardous waste and shall not be burned in the asphalt plant. The oil
shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240,
or Method 8260 before used oil fuel is transferred to the asphalt plant fuel tank and
burned.

F. Sources utilizing used oil as a fuel shall comply with the State Division of Solid and
Hazardous Waste in accordance with R315-15, UAC.
[R307-401-8]

Status:

N/A – The source does not burn used oil. See status of condition II.B.6.a.

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Section III: APPLICABLE FEDERAL REQUIREMENTS

All applicable requirements of 40 CFR 60 subparts I and OOO have been included in the conditions of
the AO.

EMISSION INVENTORY: The 2023 Emissions Inventory was submitted on April 19, 2024. Total
Emission Inventory Summary:
Pollutants Tons/Year
PM10 34.67
PM2.5 8.56
SOX 0.30
NOX 20.19
VOC 4.75
CO 18.58

PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with the conditions of AO
DAQE-AN100110007-15, dated March 20, 2015, at time of the
inspection.

HPV STATUS: N/A

COMPLIANCE ASSISTANCE: None.

RECOMMENDATION FOR
NEXT INSPECTION: Maintenance of the aggregate and wash plants is conducted on
Tuesdays. Inspect as usual.

ATTACHMENTS: VEO Form