DAQ-2025-002566

DAQE-

RN142290004 May 6, 2025 Adam Cook
Sunroc Corporation 730 North 1500 West Orem, UT 84057
[e-mail] Dear Adam Cook,
Re: Engineer Review - Administrative Amendment to Approval Order (AO) DAQE-AN0142290001-10 for a 10-Year Review and Permit Updates Project Number: N142290004 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. Sunroc Corporation should complete this review within 10 business days of receipt. Sunroc Corporation 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 Sunroc Corporation does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Sunroc Corporation 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
Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N142290004 Owner Name Sunroc Corporation Mailing Address 730 North 1500 West
Orem, UT, 84057 Source Name Sunroc Corporation- Winchester Cinder Pit
Source Location 8 Miles North of St. George on Highway 18 Washington County, UT 84770
UTM Projection 268,734 m Easting, 4,119,184 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1429 (Stone, Crushed & Broken, NEC) Source Contact Kamren Garfield Phone Number [phone] Email [e-mail] Billing Contact Kamren Garfield Phone Number [phone]
Email [e-mail] Project Engineer Lucia Mason, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted November 27, 2024 Date of Accepted Application March 31, 2025

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 2
SOURCE DESCRIPTION General Description
Sunroc Corporation (Sunroc) operates the Winchester Cinder Aggregate Pit located approximately eight miles north of St. George in Washington County. Equipment includes two (2) crushers, two (2) screens, one (1) grizzly feeder, various conveyors, one (1) 759 hp diesel-
fired generator engine, and one (1) diesel fuel storage tank. Sunroc is permitted to produce up to 85,000 tons of aggregate material per year. NSR Classification: 10 Year Review Source Classification Located in Attainment Area Washington County Airs Source Size: B
Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source Project Proposal Administrative Amendment to Approval Order (AO) DAQE-AN0142290001-10 for a 10-Year Review and Permit Updates
Project Description This is an administrative amendment to AO DAQE-AN0142290001-10, dated January 19, 2010. The DAQ is conducting a 10-year review to update the language, format and rule applicability of the 2010 AO. No changes to equipment or operations are taking place at the Winchester Cinder Aggregate Pit. EMISSION IMPACT ANALYSIS This is a 10-year review. There are no changes to equipment or emissions at this time. Therefore, no modeling is required. [Last updated March 25, 2025]

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 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 1761.00 Carbon Monoxide 0 8.60
Nitrogen Oxides 0 36.49
Particulate Matter - PM10 0 5.18
Particulate Matter - PM2.5 0 5.18
Sulfur Dioxide 0 0.62
Volatile Organic Compounds 0 0.97 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 12
Change (TPY) Total (TPY)
Total HAPs 0 0.01

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

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding 10-Year Review
This is a 10-year review. There are no changes to equipment or emissions at this time. Therefore, a BACT analysis is not required. [Last updated March 25, 2025]
SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4] I.6 The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. [R307-150]

I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 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 Winchester Aggregate Plant Material: Cinder Aggregate
II.A.2 One (1) Crusher Rating: 210 tons per hour (tph) Manufacture Year: 1989 NSPS Applicability: 40 CFR 60 Subpart OOO

II.A.3 One (1) Crusher
Rating: 250 tph Manufacture Year: 1988 NSPS Applicability: 40 CFR 60 Subpart OOO

II.A.4 Two (2) Screens Rating: 450 tph (each) Manufacture Years: 1988, 1992
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.5 One (1) Grizzly Feeder Rating: 150 tph
NSPS Applicability: 40 CFR 60 Subpart OOO

II.A.6 Various Conveyors NSPS Applicability: 40 CFR 60 Subpart OOO

II.A.7 One (1) Diesel Storage Tank
Rating: 12,000 gallons
II.A.8 One (1) Diesel-Fired Generator Engine Rating: 759 Hp Manufacture Year: Pre-April 1, 2006 MACT Applicability: 40 CFR 63 Subpart ZZZZ

II.A.9 Other Assorted Equipment - Listed for informational purposes only - Associated off-highway mobile equipment, welders, pumps, motors, pressure washers, drilling/blasting equipment, and other equipment associated with construction material processing, manufacturing and maintenance.

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 6
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 produce no more than 85,000 tons of aggregate material per rolling 12-month period. Within the above total, no more than 20,000 tons of aggregate material processed may be brought from outside sources per rolling 12-month period.
[R307-401-8]
II.B.1.a.1 NEW To determine compliance with the above production limits the owner/operator shall:
A. Determine production using belt scale records near the initial feeder, or any other
methods approved by the Director
B. Calculate a new 12-month production total by the 20th day of each month using data
from the previous 12 months C. Keep records of production on a daily basis
D. Keep records of production for all periods the plant is in operation
[R307-401-8]

II.B.1.b NEW The owner/operator shall not exceed the following operational limits:
A. Generator Engine - 4,000 hours of operation per rolling 12-month period
B. Bulldozing Operations - 1,300 hours of operation per rolling 12-month period
[R307-401-8]
II.B.1.b.1
NEW
To determine compliance with the above operational limits the owner/operator shall:
A. Determine hours of operation by supervisor monitoring and maintaining an operations
log
B. Calculate a new 12-month hours of operation total by the 20th day of each month
using data from the previous 12 months [R307-401-8]

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 7
II.B.1.c NEW Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on-site to exceed 20% opacity. [R307-205-4]
II.B.1.c.1 NEW Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.2 NEW Aggregate Processing Equipment Requirements:
II.B.2.a NEW The owner/operator shall not allow visible emissions from the following emission units exceed the following opacity limits:
A. Crushers installed prior to April 22, 2008 - 15% opacity B. Crushers installed or modified on or after April 22, 2008 - 12% opacity B. All screens - 10% opacity C. All conveyor transfer points - 10% opacity
D. All conveyor drop points - 20% opacity
[R307-401-8]

II.B.2.b NEW The owner/operator shall install water sprays or chemical dust suppression sprays on each crusher, screen, and conveyor transfer point on-site to control fugitive emissions. The owner/operator shall operate the sprays as required to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] II.B.2.c NEW The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site within 60 days after achieving maximum production rate but not later than 180 days after initial startup. Performance tests shall meet the limitations specified in Table 3 of Subpart OOO. Records of initial performance tests shall be kept and maintained on site for the lifetime of the equipment. [40 CFR 60 Subpart A, 40 CFR 60 Subpart OOO]
II.B.2.c.1 NEW Initial performance tests for fugitive emission limits shall be conducted according to 40 CFR 60.675(c). The owner/operator may use methods and procedures specified in 40 CFR 60.675(e) as an alternative. [40 CFR 60 Subpart OOO]
II.B.2.d NEW The owner/operator shall submit written reports of the results of all performance tests conducted to demonstrate compliance with 40 CFR 60.672 to the Director, attn.: Compliance Section. The submission shall be postmarked no later than 180 days from the date of this AO
or no later than 180 days from equipment start-up, whichever is later. [40 CFR 60 Subpart A, R307-401-8]
II.B.3
NEW
Fugitive Dust Requirements:
II.B.3.a NEW The owner/operator shall not allow visible emissions from haul road traffic and mobile equipment in operational areas on-site exceed 20% opacity. [R307-201-3]

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 8
II.B.3.a.1 NEW Opacity observations of fugitive dust from haul road traffic and mobile equipment in operational areas shall be conducted similar 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. Visible emissions from haul road traffic and mobile equipment in operational areas 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-
201-3] II.B.3.b NEW The owner/operator shall not exceed the following lengths: A. All Unpaved Haul Roads - 0.64 miles total B. All Unpaved Loader Routes - 0.25 miles total
[R307-401-8]

II.B.3.c NEW The owner/operator shall cover all unpaved haul roads and wheeled-vehicle operational areas with road base material. [R307-401-8]
II.B.3.d NEW The owner/operator shall use water application on unpaved haul roads and loader routes to maintain opacity limits listed in this AO. If the temperature is below freezing, the owner/operator may stop applying water to the unpaved haul roads and wheeled-vehicle operational areas. The owner/operator shall resume applying water to the unpaved haul roads and wheeled-vehicle operational areas when the temperature is above freezing. [R307-401-8] II.B.3.d.1 NEW The owner/operator shall keep records of water application on unpaved haul roads for all periods when the plant is in operation. Records shall include the following items regarding unpaved haul roads:
A. Date and time treatments were made
B. Number of treatments made and quantity of water applied C. Rainfall amount received, if any D. The temperature, if the temperature is below freezing [R307-401-8] II.B.3.e NEW The owner/operator shall water storage piles to maintain the opacity limits listed in this AO. [R307-401-8]

II.B.3.e.1 NEW The owner/operator shall keep records of water and /or chemical treatment used on storage piles for all periods the plant is in operation. [R307-401-8]
II.B.3.f NEW The source shall comply with the applicable requirements of Utah Administrative Code Rule R307-205 for Fugitive Emission and Fugitive Dust sources. [R307-205]

II.B.4 NEW Generator Engine Requirements:

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 9
II.B.4.a NEW The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, any combination of fuel oil #1 and #2, or diesel fuel oil additives) as fuel in the generator engine. [R307-401-8]
II.B.4.b NEW The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ]
II.B.4.b.1 NEW The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent. Certification of all fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. [R307-401-8]

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 10
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN0142290001-10 dated January 19, 2010
Incorporates Additional Information dated March 31, 2025
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. Rule applicability has been reviewed and updated. Notable Condition Updates: II.B.1.b - Generator engine operation was previously limited to 3,036,000 horsepower-hours annually. For ease of record keeping and permit consistency, the operational limit has been converted to 4,000 annual hours of operation. This conversion was possible because only one (1) engine (Equipment ID II.A.8) is listed in the approved equipment and therefore subject to this
operational limit. The PTE resulting from the 4,000 annual operating hours limit is equivalent to the PTE resulting from the 3,036,000 annual horsepower-hours limit. No emissions are increasing. II.B.1.c - A site-wide 20% opacity limit was added to the permit in accordance with R307-205-4 regarding fugitive emissions and fugitive dust. II.B.2.a - A 12% opacity limit for crushers installed or modified after April 22, 2008, has been added to the condition in accordance with 40 CFR 60 (NSPS) Subpart OOO. II.B.2.c, II.B.2.c.1, and II.B.2.d - Initial performance testing requirements were added to the permit in accordance with 40 CFR 60 (NSPS) Subparts A and OOO.
II.B.4.b - The sulfur content allowed in fuel oil burned onsite has been lowered from 0.5wt% to 15 ppm in accordance with 40 CFR 63 (MACT) Subpart ZZZZ. Emission Updates: The PTE for PM2.5 and CO2e were not specified in the previous AO (DAQE-AN0142290001-10, dated January 19, 2010) 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. CO2e was calculated based on the 759 hp rating listed in Equipment ID II.A.8 and 4,000 annual operational hours as limited in condition II.B.1.b. CO2e emission factors and global warming potentials were sourced from AP-42 Table 3.3-1 & Table 3.4-1. There are no other changes to the emission estimates at this time. Federal Standard Applicability Updates: 40 CFR 63 (MACT) Subpart ZZZZ has been added to the permit. See details in ER "Comment Regarding Federal Standard Applicability."
[Last updated May 5, 2025]
2. Comment regarding Compliance Notes: On December 27, 2024, the source confirmed that this site has not operated in several years. The
source has opted to keep their AO regardless. By maintaining this AO, the source is subject to annual NSR and aggregate fees. In the event of operations resuming, the source must notify the

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 11
DAQ and comply with the conditions regarding modified sources in UAC R307-401 if any equipment not listed in Section II: Permitted Equipment is brought on site. Equipment installed
onsite must undergo initial performance tests according to conditions II.B.2.c, II.B.2.c.1, II.B.2.d, and 40 CFR 60 Subpart OOO. The source should review all federal and state rule applicability updates to ensure compliance. [Last updated March 25, 2025] 3. Comment regarding Federal Standard Applicability: NSPS Subpart OOO: Standards of Performance for Nonmetallic Mineral Processing Plants. NSPS Subpart OOO applies to facilities that operate crushers, screens and belt conveyors among
other aggregate processing equipment that commenced construction, modification, or reconstruction after August 31, 1983. All crushers and screens at this facility were manufactured after 1983. Therefore, NSPS Subpart OOO applies. NSPS Subpart IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. NSPS Subpart IIII applies to stationary diesel engines that were manufactured after April 1, 2006, and are not fire pump engines. On March 31, 2025, the source confirmed that the diesel generator listed in Equipment was manufactured prior to April 1, 2006. Therefore, NSPS Subpart IIII is not applicable.
MACT Subpart ZZZZ: National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. Subpart ZZZZ applies to facilities that operate reciprocating internal combustion engines. The generator engine listed in Equipment ID I.A.8 falls under this definition. Thus, MACT Subpart ZZZZ applies. MACT Subpart ZZZZ was not listed in the source's previous AO. Sunroc should review MACT Subpart ZZZZ to ensure compliance. [Last updated April 1, 2025]
4. 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. The facility is not subject to 40 CFR 61 (NESHAP) regulations. This facility is subject to 40 CFR 60 (NSPS) Subparts A and OOO and 40 CFR 63 (MACT) Subparts A and ZZZZ. Unlike MACT Subpart ZZZ, NSPS Subpart OOO does
not specifically exempt the facility from the obligation to obtain a Title V permit. Therefore, Title V applies to this facility as an area source. [Last updated April 1, 2025]

Engineer Review N142290004: Sunroc Corporation- Winchester Cinder Pit May 6, 2025 Page 12
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
<[e-mail]>Nov 27, 2024, 3:51 PM
to kgarfield
Lucia Mason
Hi Kamren,
The DAQ is making customary permit updates to the following three (3) Sunroc Approval Orders:
DAQE-AN0128990006-09, dated 10/12/2009 (SR 9 (Coral Canyon) Aggregate Pit)
DAQE-AN0121580005-09, dated 10/7/2009 (Mona Aggregate Processing Plant)
DAQE-AN0142290001-10, dated 1/13/2010 (Winchester Cinder Pit)
Please provide the following contact information for each site:
Site: phone number, and email (if applicable)
Company: physical address, billing address, mailing address, phone number, fax number (if applicable) and email
Environmental contact: name, physical address, mailing address, phone number, fax number (if applicable) and email
Billing contact: (if different from environmental contact): name, physical address, phone number, fax number (if applicable) and email
Name on Approval Order: (if different from environmental contact): name, physical address, mailing address, phone number, fax number (if applicable) and email
Please reach out with any questions.
Happy Thanksgiving!
Lucia
<[e-mail]>Dec 9, 2024, 11:54 AM
to me
Kamren Garfield
Hi Lucia,

The contact information/billing address will be the same for all the sites. See below in red for the requested information.

Thanks,
Kamren

From: Lucia Mason <[e-mail]>
Sent: Wednesday, November 27, 2024 3:51 PM
To: Kamren Garfield <[e-mail]>
Subject: Periodic Permit Updates (Division of Air Quality), Sites 12899, 12158, and 14229

Hi Kamren,

The DAQ is making customary permit updates to the following three (3) Sunroc Approval Orders:
DAQE-AN0128990006-09, dated 10/12/2009 (SR 9 (Coral Canyon) Aggregate Pit)
DAQE-AN0121580005-09, dated 10/7/2009 (Mona Aggregate Processing Plant)
DAQE-AN0142290001-10, dated 1/13/2010 (Winchester Cinder Pit)
Please provide the following contact information for each site:
Site: phone number, and email (if applicable)
801-802-6900
[e-mail]
Company: physical address, billing address, mailing address, phone number, fax number (if applicable) and email
4/2/25, 9:33 AM Periodic Permit Updates (Division of Air Quality), Sites 12899, 12158, and 14229 - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/QgrcJHsBvFDdgDHJwnjMVKtxtgQHxtwLLWq 1/6
730 N 1500 W, Orem, UT 84057
801-802-6900
Environmental contact: name, physical address, mailing address, phone number, fax number (if applicable) and email
Kamren Garfield
730 N 1500 W
Orem, UT 84057
801-802-6933
[e-mail]
Billing contact: (if different from environmental contact): name, physical address, phone number, fax number (if applicable) and email
Same as Environmental Contact; also add [e-mail]
Name on Approval Order: (if different from environmental contact): name, physical address, mailing address, phone number, fax number (if applicable) and email
Adam Cook, Vice President
730 N 1500 W
Orem, UT 84057
801-802-6900
[e-mail]
<[e-mail]>Dec 10, 2024, 9:29 AM
to Kamren
Lucia Mason
Perfect. Thank you.
<[e-mail]>Dec 27, 2024, 11:58 AM
to Kamren
Lucia Mason
Hi Kamren,
I wasn't able to determine the cost of annual aggregate fees or what date triggers annual fees. Once management is back in the office I'll reach out with answers.
If Sunroc doesn't intend on using the equipment that was originally permitted at the Mona Aggregate Processing Plant (site 12158) the DAQ would encourage you to apply for a permit revocation before the end of the year. It's unlikely that revoc
letters for either site 12158 or the Winchester Cinder Pit (site 14229) would be issued before the start of 2025. However, if annual NSR or aggregate fees would be triggered due to the change in calendar years the DAQ would discuss internally
determine if waiving the fees is possible.
Lastly, please confirm the address of the SR9 Coral Canyon Aggregate Pit for the site's 10-year review.
Let me know how you would like to proceed with respect to sites 12158 and 14229. Please reach out with any questions.
Happy holidays!
Lucia
4/2/25, 9:33 AM Periodic Permit Updates (Division of Air Quality), Sites 12899, 12158, and 14229 - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/QgrcJHsBvFDdgDHJwnjMVKtxtgQHxtwLLWq 2/6
<[e-mail]>Jan 8, 2025, 11:03 AM
to Kamren
Lucia Mason
Hi Kamren,
I'm following up on the email I sent on December 27th. Aggregate fees will be billed within the next few days while NSR fees typically are issued February 1st. However, if Sunroc Corporation chooses to issue revocations for sites 12158 and 14
the near future the DAQ will consider waiving the annual fees for these sites. Let me know how you would like to proceed.
You can apply for a permit revocation here: https://utahgov.co1.qualtrics.com/jfe/form/SV_0OFm4bCnka4CQVo
Lastly, "North Coral Ridge Dr" is the address the DAQ currently has on file for site 12899, Coral Canyon Aggregate Pit. Is there a more specific address you use for the site?
Please reach out with any questions.
Best,
Lucia
<[e-mail]>Jan 8, 2025, 12:11 PM
to me
Kamren Garfield
Thanks for the reminder. I have reached out to our area managers for their approval to revoke those permits, I will get back to you on that.

As for Coral Canyon, I can’t find a good street address in our leases or on Google, I only have legal descriptions with township, range, etc. Let’s just stick with the current address in our Approval Order:

Thanks,

Kamren Garfield
ENVIRONMENTAL SPECIALIST
O [phone] C [phone]WWW.CLYDEINC.COM
<[e-mail]>Jan 8, 2025, 12:15 PM
to Kamren
Lucia Mason
Sounds good. Thank you.
<[e-mail]>Jan 16, 2025, 11:40 AM
to Kamren
Lucia Mason A
Hey Kamren,
4/2/25, 9:33 AM Periodic Permit Updates (Division of Air Quality), Sites 12899, 12158, and 14229 - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/QgrcJHsBvFDdgDHJwnjMVKtxtgQHxtwLLWq 3/6
Encrypted attachment warning – Be careful with this attachment. This message contains 1 encrypted attachment that can't be scanned for malicious content. Avoid downloading it unless you know the sender and are
confident that this email is legitimate.
I have a follow up question on site 12899. Our latest compliance report for the site notes that the horizontal shaft impactors (II.A.4), the cone crusher (II.A.5), the two (2) closed-circuit impactor plants (II.A.6), and the 800 hp diesel generator (II.A
have all be removed from the site. Is this correct? If so, would Sunroc like this equipment removed from their AO?
Please let me know how you would like to proceed.
Best,
Lucia
One attachment • Scanned by Gmail
DAQC-CI1289900…
<[e-mail]>Jan 28, 2025, 12:35 PM
to me
Kamren Garfield
Lucia,
Let’s keep all the equipment on the Coral Canyon permit. Also, let’s keep the Winchester and Mona permits active.
<[e-mail]>Jan 28, 2025, 12:36 PM
to Kamren
Lucia Mason
Thank you.
<[e-mail]>Jan 30, 2025, 12:20 PM
to Kamren
Lucia Mason
Hi Kamren,
I have a follow up thought on our conversation Tuesday. Both the Winchester and Mona sites are in attainment areas. You're welcome to bank the NOx emissions from these sites, but the banked emissions wouldn't have value unless the site's
location is redesignated as a nonattainment area for particulate matter, ozone or NOx. Even in the unlikely instance of a redesignation there could be complications with using emissions banked before the redesignation. You would also need to
the AOs to bank the emissions associated with them in the first place. I just thought I'd add some context in case it changes your thoughts on revoking either AO.
I also finally figured out how much annual aggregate fees are. They're based on total annual emissions as follows:
<20 tpy: $207.00
20-79 tpy: $414.00
80-99 tpy: $1,035.00
100+ tpy: $1,449.00
Lastly, assuming you'd still like to keep both AOs, could you confirm the addresses and UTM coordinates for the Mona and Winchester pits?
4/2/25, 9:33 AM Periodic Permit Updates (Division of Air Quality), Sites 12899, 12158, and 14229 - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/QgrcJHsBvFDdgDHJwnjMVKtxtgQHxtwLLWq 4/6
Thanks,
Lucia
<[e-mail]>Feb 13, 2025, 8:21 AM
to Kamren
Lucia Mason
Hey Kamren,
I'm checking in on the email I sent on January 30th. When you have a chance could you send over location coordinates for the Mona and Winchester pits?
Thanks,
Lucia
<[e-mail]>Feb 13, 2025, 9:26 AM
to me
Kamren Garfield
Lucia,

UTM for Mona Pit is 428930.89 m E, 4411542.74 m N
For the Mona address, just stick with the 1040 East North Canyon Road address.

UTM for the Winchester Pit is 268709.84 m E, 4119253.68 m N
Also keep the existing address for this pit
<[e-mail]>Feb 13, 2025, 10:58 AM
to Kamren
Lucia Mason
Thank you. I'll reach out if the DAQ needs additional information.
<[e-mail]>Mar 24, 2025, 4:18 PM (9 days ago)
to Kamren
Lucia Mason
Hi Kamren,
Could you confirm the manufacture year of the 759hp diesel engine listed in AO DAQE-AN0142290001-10, equipment ID II.A.6? The manufacture date determines the applicability of 40 CFR 60 (NSPS) Subpart IIII.
Thanks,
Lucia
Mar 31, 2025, 10:14 AM (2 days ago)
to me
Kamren Garfield
4/2/25, 9:33 AM Periodic Permit Updates (Division of Air Quality), Sites 12899, 12158, and 14229 - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/QgrcJHsBvFDdgDHJwnjMVKtxtgQHxtwLLWq 5/6
The engine permitted for Winchester was most likely a pre-2006 model subject to Subpart ZZZZ.
<[e-mail]>8:20 AM (1 hour ago)
to Kamren
Lucia Mason
Hi Kamren,
Thanks for the response. I want to pass a condition change in the Winchester permit by you. Condition II.A.1.b(B) of the current AO (DAQE-AN0142290001-10) limits engine use to 3,036,000 hp-hours per rolling 12-month period. Would it be al
convert the hp-hrs to hours? This works out to 4,000 hours of operation per rolling 12-month period for the approved 759 hp engine. Measuring engine use in hp-hours is no longer standard practice at the DAQ and it would be good to update th
Winchester permit to match modern AOs. Let me know if the change works on your end.
Thanks,
Lucia
8:50 AM (42 minutes ago)
to me
Kamren Garfield
Yes that’s fine.

Thanks,

Kamren GarfieldENVIRONMENTAL ENGINEER
Thank you very much.Thank you!Thank you.
4/2/25, 9:33 AM Periodic Permit Updates (Division of Air Quality), Sites 12899, 12158, and 14229 - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/QgrcJHsBvFDdgDHJwnjMVKtxtgQHxtwLLWq 6/6
Equipment Details
Rating 759 hp = (566.5 kw)
Operational Hours 4,000 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 18.22 36.43
CO 5.50E-03 4.17 8.35
PM10 7.00E-04 0.53 1.06
PM2.5 7.00E-04 0.53 1.06
VOC 6.42E-04 0.49 0.97
SO2 1.21E-05 0.01 0.02 AP-42 Table 3.4-1
HAP 0.01 0.02 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 1.16 880 1,761
Methane (mass basis)25 6.35E-05 0 0CO2e1,763
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
Benzene 7.76E-04 4.12E-03 8.25E-03
Toluene 2.81E-04 1.49E-03 2.99E-03
Xylenes 1.93E-04 1.03E-03 2.05E-03
Formaldehyde 7.89E-05 4.19E-04 8.38E-04
Acetaldehyde 2.52E-05 1.34E-04 2.68E-04
Acrolein 7.88E-06 4.19E-05 8.37E-05
Naphthalene 1.30E-04 6.91E-04 1.38E-03
Acenaphthylene 9.23E-06 4.90E-05 9.81E-05
Acenaphthene 4.68E-06 2.49E-05 4.97E-05
Fluorene 1.28E-05 6.80E-05 1.36E-04Phenanthrene4.08E-05 2.17E-04 4.34E-04
Anthracene 1.23E-06 6.53E-06 1.31E-05
Fluoranthene 4.03E-06 2.14E-05 4.28E-05
Pyrene 3.71E-06 1.97E-05 3.94E-05
Benz(a)anthracene 6.22E-07 3.30E-06 6.61E-06
Chrysene 1.53E-06 8.13E-06 1.63E-05
Benzo(b)fluoranthene 1.11E-06 5.90E-06 1.18E-05
Benzo(k)fluoranthene 2.18E-07 1.16E-06 2.32E-06
Benzo(a)pyrene 2.57E-07 1.37E-06 2.73E-06
Indeno(1,2,3-cd)pyrene 4.14E-07 2.20E-06 4.40E-06
Dibenz(a,h)anthracene 3.46E-07 1.84E-06 3.68E-06Benzo(g,h,l)perylene 5.56E-07 2.95E-06 5.91E-06
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 1 of 1 Version 1.1
February 21, 2019
DAQC-238-18
Site ID 14229 (Bl\
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
MEMORANDUM
FILE - SUNROC CORP - Winchester Cinder Pit
Jay Morris, Minor Source Compliance Section Manager erl?/\
Jared James, Environmental Scientist Ay'1/
February 15,2018
Full Compliance Evaluation (FCE), minor, Washington County, AIRS #05300076
TNSPECTION DATE:
SOURCE LOCATION:
souRCE GoNTACT(S):
OPERATTNG STATUS:
PROCESS DESCRIPTION:
APPLICABLE REGULATIONS :
SOURCE EVALUATION:
EMISSION INVENTORY:
February 7,2018
Eight miles north of St. George, Washington County. Take Bluff
Street Exit (Exit 6), tum right (Northwest), and follow BlufVSR
l8 approximately 8 miles. Take the Ledges Parkway exit, turn
right, enter ioundabout, then immediate right. Take road to the
end and then follow the gravel road Southeast to the pit.
None on site. Sam Bernard, Environmental Engineer
801-802-69s 4
Temporarily down
Bulldozer rips material which is shipped to another location for
processing. The site is permitted for an aggregate plant with
crushers, screens, conveyors, a diesel generator, a diesel storage
tank and miscellaneous off-highway equipment.
Approval Order DAQE-AN0142290001-10, dated January 19,
201 0.
Unable to determine compliance. No personnel or
crushing/screening equipment were on site. Two front loaders
were parked on site.
The following data is from the engineer's calculations:
Pollutant
PMIO
NOx
s02
CO
VOC
HAPs
Tons/year
5.18
36.49
0.62
8.60
0.97
0.01
PREVIOUS ENFORCEMENT
ACTIONS:
COMPLIANCE STATUS &
RECOMMENDATIONS:
RECOMMENDATION FOR
NEXT INSPECTION:
ATTACHMENTS:
None in the past five years.
Unable to determine compliance. The source was not operating.
Sunroc does take bank material and transports it to other plants
for processing as needed.
The source has no current plans to put crushing/screening
equipment on site.
None.