DAQ-2024-004076

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US Magnesium LLC
238 North 2200 West - Salt Lake City, UT U116-2921
801 t 532-2043 - 800 1262-9624 - FACS I M r LE 801 t 5v-1 407
LTAH DEPABTMENT OF
ENVIRONMENTAL OUAUTY
,JAN i,'r[7r,
llund D"ilttwcl
DIVISION OF AIR QUALITY
Hand Deliverv
January 3,2024
Mr. Bryce Bird, Director
Division of Air Quality
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144824
Salt Lake Caty, UT 84114
RE: SEii!-ANNUAL NESHAP COi,IPLIANCE REPORT, July-December 2023
Dear Mr. Bird:
Please find enclosed the Semi-Annual NESHAP Compliance Report for the US Magnesium
Rowley facility. The commercial-grade hydrochloric acid production unit at the Rowley facility is
covered by Subpart NNNNN - National Emissions Standards for Hazardous Air Pollutants for
Hydrochloric Acid Production. This report is for the period from July 1 through December 31,
2023.
Please contact me at (801) 532-1 522 ert. 1355, if you have any questions or need additional
information.
Sincerely,
Jeffrey L. Mensinger
Environmental Manager
US Magnesium LLC
Enclosure
?
US Magnesium LLC
Semi-annual NESHAP Subpart NNNNN Compl iance Report
40 CFR 63.9050(c)
Report Information
Contact Information
2.1 Mailing Address
US Magnesium LLC
238 North 2200 West
Salt Lake City, UT 84116
2.2 Facility Location
US Magnesium LLC
l5 miles N of Exit 77 off I-80
Rowley, Utah
3 Certificationstatement
I hereby certify that, based on information and belief formed after reasonable inquiry, the statements and
information in this report are true, accurate and complete.
3.1 Name:Ron L. Thayer, President
Semiannual MACT Report for US
Maenesium LLC
Report Date:January 31,2024
Start of Reporting Period:J:uly 1,2023
End of Reporting Period:December 31,2023
Page 1 of4
US Magnesium LLC
Semi-annual NESIIAP Subpart NNNNN Compliance Report
40 CFR 63.9050(c)
Note: definitions used in this report are found in $40CFR63.2.
4 Events Consistent With Facility Startup, Shutdown, & Malfunction (SSM) Plan, $63.9050(c)(a)
During this reporting period, the 36oh hydrochloric acid plant was not in production.
5 Statement When There Are No Deviations from Emission Limitations (emission limits or operating
limits), $63.9050(cX5)
There were no operating limit deviations, the 36%hydrochloric acid plant was not in production.
6 Statement If There Are No Periods Where Continuous Monitoring System (CMS) Conditions Are
"Out Of ControP', $63.9050(c)(6)
There were no periods the CMS was "out of control." During this reporting period, the36%
hydrochloric acid plant was not in production.
7 Verification of Use of LDAR Plan and Any Periods Procedures Were Not Followed, $63.9050(c)(7)
LDAR Plan procedures were followed. During this reporting period, the 360/o hydrochloric acid plant
was not in production.
8 Revisions to Monitoring Plan and/or LDAR Plan, 563. 9050(cXS)
There were no revisions needed or made to the LDAR Plan.
9 Use of Control Devices and Verification of No Process Changes, $63.9050(c)(9)
Emissions from the hydrochloric acid production process are controlled using a sodium hydroxide
scrubber. Emissions from the 36o/ohydrochloric acid storage tank and rail/truck loading stations are
controlled using a wet scrubber. There were no process changes during the reporting period.
10 Planned Routine Maintenance That Caused or May Cause an HCI Storage Tank Control Device Not
to Meet the Emission Limits, $63.9050(cX10)
(i) A description of the planned routine maintenance that was performed for each HCI storage tank
control device during the reporting period.
None. During this reporting period, the 36o/ohydrochloric acid plant was not in production.
(iD A description of the planned routine maintenance that is anticipated to be performed for each HCI
storage tank control device during the next reporting period.
Page 2 of 4
US Magnesium LLC
Semi-annual NESHAP Subpart NNNNN Compliance Report
40 CFR 63.9050(c)
There is no routine maintenance planned or anticipated to be performed on the 36%ohydrochloric acid
storage tank wet scrubber during the next reporting period.
40 CFR 63.9050(d) - Information for each deviation from an emission limitation occurring at an affected
source where you are using a CMS to comply with the emission limitation.
(l) There were no CMS malfunctions.
(2) There were no periods the CMS was inoperative.
(3) There were no periods the CMS was out-of-contro1.
(4) Date and time that each deviation started and stopped: During this reporting period, the 36Yo
hydrochloric acid plant was not in production.
(5) A summary of the total duration of the deviation during the reporting period and the total duration as
a percent of the total source operating time during that reporting period: During this reporting period,
the 36Yo hydrochloric acid plant was not in production.
(6) A breakdown of the total duration of the deviations during the reporting period into those that are
due to startup, shutdown, control equipment problems, process problems, other known causes, and
other unknown causes: During this reporting period, the 360/o hydrochloric acid plant was not in
production.
(7) There was no CMS downtime.
(8) Emissions from the hydrochloric acid production process are controlled using a sodium hydroxide
scrubber. Emissions from the 36%ohydrochloric acid storage tank and rail/truck loading stations are
controlled using a wet scrubber.
(9) There were no changes in CMS, processes, or controls since the last reporting period.
Page 3 of4
US Magnesium LLC
Semi-annual NESHAP Subpart NNNNN Compliance Report
40 CFR 63.90s0(c)
Attachment A
Acid Plant Sodium Hydroxide Scrubber Deviations from Daily
Average Recirculated Liquor pH Not Less Than 8.0 Operating Limit
Duration is number of I hour blocks below the daily average limit for the calendar day.
Operating hours :0.
Acid Plant Sodium Hydroxide Scrubber Deviations from Daily
Average Liquor Recirculation Rate Operating Limit
Duration is number of I hour blocks below the daily average limit for the calendar day.
Operating hours :0.
Date Duration
(hours)
Percent Operating
Hours Cause
Durine this reporting period. the 36oh hydrochloric acid plant was not in production.
Date Duration
(hours)
Percent Operating
Hours Cause
Durine this reportins period. the360/o hydrochloric acid plant was not in production.
UTAH DEPAHTMENT OF
ENVIRONMENTAL QUALITY
i,t l\l r)(:
DIVISION OF AIH QUALITY
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