DAQ-2024-004350

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DAQC-1356-23
Site ID 10472 (B1)

MEMORANDUM

TO: FILE – ASH GROVE CEMENT COMPANY (SALT LAKE CITY CEMENT
TERMINAL)

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Irene Tucker, Environmental Scientist

DATE: December 5, 2023

SUBJECT: PARTIAL COMPLIANCE EVALUATION, MINOR, SALT LAKE COUNTY

INSPECTION DATE: November 30, 2023

SOURCE LOCATION: 81 West Central Avenue (4105 South), Salt Lake City

SOURCE CONTACT: Grant Ensign, Environmental Specialist, Clyde Companies,
O=[phone], C= [phone]

OPERATING STATUS: There is no access into the site. Most of the equipment has been
torn down except for the silos. There are new apartments being
built on the site. See the pictures in the attachment.

PROCESS DESCRIPTION: The Salt Lake City cement terminal stores and distributes fly
ash. Geneva Rock Products currently leases and operates the
terminal. In the winter, when the price of the product is lower,
the silo is filled with 3,200 tons of flyash via a bulk tanker. In the
spring the material is loaded into tankers and sent to paving
projects. The silos are empty the rest of the year.

APPLICABLE REGULATIONS: Approval Order (AO) DAQ-0887-1, dated April 29, 1987

SOURCE INSPECTION
EVALUATION:

1. Ash Grove Cement West, Inc. shall install the proposed cement bulk terminal according to the
information submitted in the notice of intent dated January 30, 1987. The terminal shall consist of the
following:

A. Cement unloading from railroad cars into two silos, pneumatic conveyors.

B. Cement loading from two silos into trucks, drop chutes.

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2. Visible emissions from any point or fugitive emissions source associated with the installation or
control facilities shall not exceed 20% opacity. Opacity observations of emissions from stationary
sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. Opacity
observations of intermittent sources shall use procedures similar to Method 9, but the requirement for
observations to be made at 15-second intervals over a 6-minute period shall not apply. Opacity of any
reading shall not exceed 20% for intermittent sources.

3. All unpaved haul roads and other operational areas in use shall be water sprayed to minimize fugitive
dust as dry conditions warrant or as determined necessary by the Executive Secretary. Water
treatment may be replaced by chemical dust suppression, provided a plan is approved by the
Executive Secretary.

4. All installations and facilities authorized by this approval order shall be adequately and properly
maintained.

5. The Executive Secretary shall be notified upon start-up of the installation, as an initial compliance
inspection is required.

Status: Not applicable. This equipment was installed in 1987.

6. Emissions generated during the transfer of cement from the rail cars into the silos (transfer shall be by
pneumatic conveyor) shall be controlled by baghouses placed on top of the silos. The baghouses shall
filter all of the displaced air before the air is vented to the atmosphere. The baghouses shall operate
whenever a silo is being loaded.

7. Emissions generated during the loading of trucks shall be controlled by a baghouse, which filters all
of the displaced air before the air is vented to the atmosphere. The baghouse shall operate whenever a
truck is being loaded.

Status: No longer applicable for AO Conditions 1, 2, 3, 4, 6, and 7 as Geneva Rock Products no
longer operates the Ash Grove Cement Company (Salt Lake City Cement Terminal).

8. The annual throughput of cement shall not exceed 75,000 tons without prior approval in accordance
with section 3.1, UACR. Records of throughput shall be kept for all periods when the plant is in
operation. Records of throughput shall be made available on request and shall include a period of two
years ending with the date of the request. Throughput shall be determined by scale records kept by
Ashgrove Cement West, Inc.

Status: According to Geneva Rock Products, this facility was last operated two years ago. See the
email attachment for additional information.

EMISSION INVENTORY: An Emission Inventory Report is not required. Based on
previous calculations, emissions are:

Pollutants Tons/Year

PM 0.1

PREVIOUS ENFORCEMENT
ACTIONS: None in the last 5 years.
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HPV STATUS: Not Applicable.

COMPLIANCE STATUS &
RECOMMENDATIONS: Geneva Rock Products has ceased all operations at the Ash
Grove Cement Company (Salt Lake City Cement Terminal).
Almost all the equipment has been torn down, and new
apartment buildings are being constructed on the site.

RECOMMENDATION FOR
NEXT INSPECTION: Geneva Rock Products has ceased all operations at the Ash
Grove Cement Company (Salt Lake City Cement Terminal).
Check on the status of the AO Revocation Letter.

RECOMMENDATION FOR
NEXT INSPECTION: Geneva Rock Products has ceased all operations at the Ash
Grove Cement Company (Salt Lake City Cement Terminal).
Inspect the AO Revocation Letter.

ATTACHMENT: See photographs, email documentation