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Home My WebLink AboutDAQ-2024-004077usry. US Magnesium LLC 238 North 2200 West - Salt Lake City, UT U116-2921 80 1 I 532-2043 - 800 I 262-9624 - FACS I M I L E 80 1 I 5U - 1 407 I,TAH DEPARTMENT OF EWRONMENTAL OUAUTY JAN \ ?07)r'ii*d DIVISION OF AIR QUALITY Hand Deliverv January 3,2024 Mr. Bryce Bird, Director Division of Air Quality Utah Department of Eirvironmental Quality 195 North 1950 West P.O. Box 144820 Salt Lake City, UT 84114 RE: SEMI-ANNUAL NESHAP COi|PLIANCE REPORT, July-December 2023 Dear Mr. Bird: Please find enclosed the Semi-Annual NESHAP Compliance Report for the US Magnesium Rowley facility. The Rowley facility is covered by Subpart TTTTT - National Emissions Standards for Hazardous Air Pollutants for Primary Magnesium Refining. This report is for the period from July 1 through December 1,2023. Please contact me at (801) 532-1 522 ext. 1355, if you have any questions or need additional information. US Magnesium LLC Enclosure Jgffi L. Mensinger nvironmental Manager REVIEWED Initials JBR Date 1/9/2023 Comp Status Meets File # 10716 Blue 2 Mag plant shutdown since aug 2022 rpt is through dec 31 US Magnesium LLC Semi-annual NESHAP Subpart TTTTT Compliance Report 40 cFR 63.993 r(b) I 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 15 miles N of Exit 77 off I-80 Rowley, Utah 3 Certificationstatement I hereby certiff 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 Masnesium LLC Report Date:January 31,2024 Start of Reporting Period:July 1,2023 End of Reporting Period: December 31,2023 Page I of9 US Magnesium LLC Semi-annual NESHAP Subpart TTTTT Compliance Report 40 cFR 63.9931(b) Note: definitions used in this report are found in $40CFR63.2. 4 Events Consistent With F'acility Startup, Shutdown, & Malfunction (SSM) Plan, S63.9931(b)(4) During this period the primary magnesium was not in production. 5 Statement When There Are No Continuous Compliance Deviations, $63.9931(bX5) During this period the primary magnesium was not in production. 6 Statement If There Are No Periods Where Continuous Parameter Monitoring System (CPMS) Conditions Are "Out Of ControP', S63.9931(bX6) During this period the primary magnesium was not in production. 7 Emission Limit Deviations Where CPMS Is Not Used For Compliance, $63.9931(bX7) During this period the primary magnesium was not in production. 7.1 The total operating time of each affected source during the reporting period S63.9931(b)(7)(t). The operating time (hours) for the melt cell reactor trains were: Melt/Reactor Trains I 0 The operating times (hours) for the spray dryers were: Spray Dryer 01 0 Spray Dryer 02 0 Spray Dryer 03 0 Page2 of9 US Magnesium LLC Semi-annual NESHAP Subpart TTTTT Compliance Report 40 cFR 63.9931(b) The EOG and the 05106 Bin scrubber percent uptimes are shown below. EOG scrubber 0% 05106 scrubber 0% 7.2 Information on the number, duration, and cause of the deviations (including unknown causes, if applicable) as applicable and the corrective action taken, $63.9931(b)(7)(ii). During this period the primary magnesium was not in production. 8 Emission Limit Deviations Where CPMS Is Used f,'or Compliance, $63.9931(bX8) 8.1 The date and time that each malfunction started and stopped, S63.9931(bX8Xr). During this period the primary magnesium was not in production so no malfunctions were identified during the reporting period. 8.2 The date and time that each CMS was inoperative, except for zero (low-level) and high-level checks, s63.ee31(bx8xii). During this period the primary magnesium was not in production. 8.3 The date time, and duration that each CMS was out-of-control, including the information in section 963.8(c)(8) (Operation and maintenance of continuous monitoring systems), $63.9931(bx8)(iii). During this period the primary magnesium was not in production. 8.4 The date and time that each deviation started and stopped, and whether each deviation occurred during a period of startup, shutdown, or malfunction or during another period, S63.9931(b)(8)(iv). During this period the primary magnesium was not in production. 8.5 A srunmary 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, S63.9931(bX8Xv). During this period the primary magnesium was not in production. Page 3 of9 US Magnesium LLC Semi-annual NESIIAP Subpart TTTTT Compliance Report 40 cFR 63.9931(b) 8.6 A breakdown of the total duration of the deviations during the reporting period including those that are due to startup, shutdown, control equipment problems, process problems, other known causes, and other unknown causes, $63.993 I (bX8XvD. During this period the primary magnesium was not in production. 8.7 A swnmary of the total duration of CMS downtime during the reporting period and the total duration of CMS downtime as a percent of the total source operating time during the reporting period, S63.ee31(b)(8)(vii). During this period the primary magnesium was not in production. 8.8 A brief description of the process units, S63.9931(b)(8)(viii). Three Spray Dryers convert magnesium chloride rich brine into magnesium chloride powder (SDP), using the hot exhaust gas from a natural gas fired turbine. The brine is injected into the hot exhaust stream, where if flash dries to produce magnesium chloride powder. The SDP is separated from the hot gases in a bank of cyclonic separators. The hot gases pass through a dedicated packed bed scrubber, for removal of hydrogen chloride and particulate matter. The 05/06 Bin Set receives SDP from the three spray dryer cyclones. The SDP is pneumatically conveyed to the bin set. The conveyance air passes through a baghouse and a packed bed scrubber to remove hydrogen chloride and particulate matter. The scrubber discharge is emitted through the 05/06 Bin Set Scrubber stack. In the Melt/Reactor, the SDP is melted and sparged with chlorine. The chlorine reacts with the magnesium oxide to produce very pure magnesium chloride salt, which is used for production of magnesium metal. The off-gas from the Melt/Reactor system passes through the following equipment, in series: o A Chlorine Reduction Burner (CRB): where the excess chlorine gas is converted to hydrogen chloride. o An absorber and two packed bed scrubbers: the scrubbers are known as the East Packed Tower and the West Packed Tower. All of these vessels remove hydrogen chloride.o A High Energy Scrubber (HES), a venturi type scrubber designed primarily to remove particulate matter. The HES off-gas is emitted through the M/R Scrubber stack. The Emergency Off-gas (EOG) System actively collects fugitive emissions from the MelVReactor operations area. The off-gas passes through the EOG scrubber to remove chlorine, hydrogen chloride and particulate matter. The EOG scrubber is a packed bed scrubber and discharges through the EOG Scrubber stack. 8.9 A brief description of the cMS, s63.9931(b)(8)(ix). The CMS for Melt/Reactor operation uses flow meters and pressure transducers to monitor operating parameters. Page 4 of9 US Magnesium LLC Semi-annual NESHAP Subpart TTTTT Compliance Report 40 cFR 63.9e31(b) Unit CMS ID Measurement CRB Absorber FY_t0t7 Flow meter - absorber scrubber water flow (gpm) PY lll0 Pressure transducer - differential pressures across the absorber packing (inches HzO) West Packed Tower 1019FY Flow meter - west packed tower scrubber water flow (gpm) PY ll12 Pressure transducer - differential pressures across the west packed tower packing (inches HzO) East Packed Tower FY_l018 Flow meter - east packed tower scrubber water flow (gpm) PY_llll Pressure transducer - differential pressures across the east packed tower packing (inches HzO) High Energy Scrubber FY 1046 Flow meter - High energy scrubber water flow (epm) PY 1109 Pressure transducer - differential pressures across the high energy scrubber packing (inches HzO) Page 5 of9 US Magnesium LLC Semi-annual NESHAP Subpart TTTTT Compliance Report 40 cFR 63.9931(b) The CMS for Spray Dryer operation uses flow meters and pressure transducers to monitor operating conditions. Unit CMS ID Measurement 01 Spray Dryer Scrubber FT_2501 Flow meter - 0l spray dryer scrubber makeup water flow (gpm) FYJs02 Flow meter - 01 spray dryer scrubber east recirculation water flow (gpm) FY 2s03 Flow meter - 01 spray dryer scrubber west recirculation water flow (gpm) PYJs02 Pressure transducer - differential pressure across the 01 spray dryer scrubber packing (inches HzO) PDT 2503 Pressure transducer - differential pressure across the 0l spray dryer scrubber demister (inches HzO) 02 Spray Dryer Scrubber FT 2505 Flow meter - 02 spray dryer scrubber makeup water flow (gpm) FY_2506 Flow meter - 02 spray dryer scrubber north recirculation water flow (gpm) FY 2507 Flow meter - 02 spray dryer scrubber south recirculation water flow (gpm) PY_2510 Pressure transducer - differential pressure across the 02 spray dryer scrubber packing (inches HzO) 25t0PDT-Pressure transducer - differential pressure across the 02 spray dryer scrubber demister (inches HzO) 03 Spray Dryer Scrubber FT 2044 Flow meter - 03 spray dryer scrubber makeup water flow (gpm) FY_2045 Flow meter - 03 spray dryer scrubber east recirculation water flow (gpm) FY 2046 Flow meter - 03 spray dryer scrubber west recirculation water flow (gpm) PY_2033 Pressure transducer - differential pressure across the 03 spray dryer scrubber packing (inches HzO) PDT 2034 Pressure transducer - differential pressure across the 03 spray dryer scrubber demister (inches HzO) Page 6 of9 US Magnesium LLC Semi-annual NESIIAP Subpart TTTTT Compliance Report 40 cFR 63.9931(b) The Emergency Off-Gas scrubber uses a flow meter and a pressure transducer to monitor operating conditions. Unit CMS ID Measurement Emergency Off Gas Scrubber FY 1048 Flow meter - emergency off gas system scrubber water flow (gpm) PY_l113 Pressure transducer - differential pressure across the emergency off gas system scrubber packing (inches HzO) The 05/06 Bin Set scrubber uses a flow meter and a pressure transducer to monitor operating conditions. In addition, a temperature transducer (thermocouple) monitors discharge gas temperature. Unit CMS II)Measurement 05/06 Bin Set Scrubber FY 21248 Flow meter - 05/06 bin set scrubber recirculation water flow (gpm) FY 2124C Flow meter - 05/06 bin set scrubber spray water flow (gpm) PY_2036 Pressure transducer - differential pressure across the 05/06 bin set scrubber packing (inches HzO) TT.21228 Thermocouple - discharge gas temperature cF) 8.l0The date of the latest CMS certification or audit, S63.9931(bX8Xx). None. 8.l lA description of any changes in the CMS, processes or controls since the last reporting period, 563.ee31(bXsXxi) None. PageT of9 US Magnesium LLC Semi-annual NESHAP Subpart TTTTT Compliance Report 40 cFR 63.9931(b) Attachment I Chlorine Reduction Burner Absorber Deviations from Recirculating Flow Operating Parameter Range Starting and ending times are for the recorded l-hour block values. Operating hours : 0 Emergency Off-Gas Scrubber Deviations from Recirculating Flow Operating Parameter Range Starting and ending times are for the recorded 1-hour block values. Operating hours: 0. East Packed Tower Deviations from Recirculating Flow Operating Parameter Range Starting and ending times are for the recorded l-hour block values. Operating hours :0. West Packed Tower Deviations from Recirculating Flow Operating Parameter Range Starting and ending times are for the recorded 1-hour block values. Operating hours : 0. High Energy Scrubber Deviations from Recirculating Flow Operating Parameter Range Starting and ending times are for the recorded 1-hour block values. Operating hours :0 Spray Dryer 01 Scrubber Deviations from Recirculating Flow Operating Parameter Range Starting and ending times are for the recorded l-hour block values. Operating hours: 0. Spray Dryer 02 Scrubber Deviations from Recirculating Flow Operating Parameter Range Starting and ending times are for the recorded l-hour block values. Operating hours: 0. Spray Dryer 03 Scrubber Deviations from Recirculating Flow Operating Parameter Range Starting and ending times are for the recorded l-hour block values. Operating hours: 0. Page 8 of9 US Magnesium LLC Semi-annual NESHAP Subpart TTTTT Compliance Report 40 cFR 63.9931(b) 5/06 Bin Scrubber Deviations from Recirculating Flow Operating Parameter Range Starting and ending times are for the recorded l-hour block values. Operating hours:0 05/06 Bin Scrubber Deviations from Discharge Gas Temperature Operating Parameter Range Starting and ending times are for the recorded l-hour block values. Operating hours:0. UTAH DEPAFTMENT OF ENVIRONMENTAL OUAUTY JAN 5 2l,?4 DIVISION OF AIR QUALITY Page 9 of9