DAQ-2024-004079

zAr
COMPASS MINERALS
\-/
Compass Minerals
765 N 10500 W
Ogden, UT 84404
www.co m passm inera ls.co m
r [phone]
t .:*--.!
,. l:,1 l,,
_J
December t2,2023
Mr. Bryce Bird
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84116
RE:Report of Potential Permit Deviation (Operating Permit No. 5700001004)
Mr. Bird,
ln accordance with Operating Permit provision LS.2.c, and Utah Administrative Code (UAC) R307-
a15-6a(3)(c)(ii), Compass Minerals Ogden Inc. (Compass Minerals) is reporting potential deviations from
permit condition ll.B.2.a. associated with salt harvest.
Condition: The following production limits sholl not be exceeded; 1,685,000 tons of salt harvested
from ponds per rolling 12-month period.
Monitoring: The permittee sholl colculote o new 72-month totol by the 20th doy of each month
using doto from the previous 12 months.
On November 28, 2023, Compass Minerals determined that the 12-month rolling sum of
harvested salt had exceeded the indicated production limit for the months of September and October
2023, as noted in the table below. The facility's environmental compliance management system is
configured to track and document permit required tasks through to completion; in this case, however, the
manual task of calculating a new 12-month rolling total by the 20th of each month for the previous 12
months was missed on two consecutive months, allowing the potential exceedance of the production limit
to go undetected.
After this issue was identified, Compass Minerals completed a detailed review of the manner in
which the Company tracks and records harvested salt and determined that, in addition to the months of
September and October of 2023, the preceding and subsequent months of August 2023 and November
2023 also potentially exceeded the 12-month rolling production limit for harvested salt:
i i2-tv6"th nottine pen;d '"- - i.tiniir"ii;d'-.--._ -
I
: (tons) ,
e/1.12022 - 813112023 7,69 1,037
te I 1_1 7922 - e_ I 3ol ?"g73_
, 1rlu2122- 7013u2023 1,849,165
: t2l tl2o22 - 1.1.130 12023 L,9t9,292
Upon discovery of the deviation, salt harvest was halted and will not be restarted untilthe rolling
average is within permit limits. To improve tracking of salt harvest tonnage and to prevent a reoccurrence
r-
REVIEWED
Initials JBR Date 1/9/2023
Comp Status Meets
File # 10917 Blue 2
Post onsite Insp. monthly
totals from spreadsheet
failed. Put into new
system for better tracking.
Salt harvesting was
stopped and will hold
until numbers corrected.
New excess emissions
expected from harvest.
NFA is required by DAQ
due to wet nature of
harvest and low chances
of reoccurance.
of this exceedance, Compass Minerals intends to add the metric to an existing business analytics solution
to provide better visibility to harvesting production limits throughout the month and to a wider audience.
Further, Compass Minerals has reviewed the importance of timely completing these reports and
immediately identifying salt harvest tonnages that are approaching the harvest limit and addressing the
issue with the Operations team.
Finally, Compass Minerals reviewed the basis for the salt harvest tonnage limit, which was
required as a means of minimizing fugitive dust emissions and does not implicate downstream process
limitsinanyotherpartoftheplant. AspreviouslydiscussedwithDivisionofAirQuality,thesaltharvested
off the ponds is wet with a high percentage of magnesium chloride, which substantially limits the creation
of dust during harvesting activities. lndeed, at no point in the last four months has Compass Minerals
identified any exceedance of opacity limits in the area of the salt harvest.
Please contact Vikrant Chavan ([e-mail], [phone]) if you have any
questions regarding the information provided.
ln accordance with Operating Permit provision l.K and UAC R307-415-5.d and based on
information and belief formed after reasonable inquiry, I certify that the statements and information in
this document are true, accurate, and complete.
Vice President, Operations
Compass Minerals Ogden lnc.