DAQ-2024-004854

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DAQC-CI107420001-24
Site ID 10742 (B1)

MEMORANDUM

TO: FILE – INTREPID POTASH WENDOVER, LLC – Wendover Potash Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: January 18, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Tooele County

INSPECTION DATE: December 6, 2023

SOURCE LOCATION: Exit 4, Interstate 80 (the Blair exit) and the Frontage Road
Wendover, UT 84083
SOURCE CONTACTS: Todd Stubbs, Division Engineer
435-259-1282; [e-mail]

OPERATING STATUS: Operating normally at time of inspection.

PROCESS DESCRIPTION: Potash harvesting plant. Intrepid Potash collects brine from
shallow and deep aquifers in open ditches throughout the 88,000
acres of land. The collected brine is pumped into solar
evaporation ponds to reduce the water content and precipitate
undesirable salt. Over 5 billion gallons of brine is pumped into
the solar ponds each year. As the brine becomes saturated with
potash, it is transferred through a series of smaller evaporation
ponds and eventually into harvest ponds. When the ripened brine
finally reaches the harvest ponds, the potash ore (a combination
of salt and potash) is precipitated out on the pond floor. The
remaining brine in the harvest ponds is removed, and the potash
ore is harvested and transported to the mill for processing. The
mill separates the potash from the salts by use of the Flotation
method. The material is dried, compacted, and screened into
premium grades of potash. Next, the potash (standard and
granular) is conveyed and stored in a bulk storage warehouse
before being loaded into railcars or trucks for shipment.

The Wendover facility annually produces approximately 60,000
to 70,000 tons of potash and 300,000 tons of magnesium
chloride brine. Potash from the facility is used in fertilizer and in
oil field drillings. Magnesium chloride brine is used for
anti-icing, chemical intermediates, and specialty chemicals.
Magnesium chloride is stored in ditches and lined ponds and
does not pass through the processing plant.

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APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN107420014-19, dated July 22,
2019
NSPS (Part 60) IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines
MACT (Part 63) -CCCCCC: National Emission Standards for
Hazardous Air Pollutants for Source Category: Gasoline
Dispensing Facilities
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Intrepid Potash Wendover, LLC - Wendover
Potash Plant
Exit 4, Interstate 80 (the Blair exit) and the
Frontage Road
P.O. Box 580 Wendover, UT 84083
Wendover, UT 84083-0082

SIC Code: 1474: (Potash, Soda, & Borate Minerals)

Section I: GENERAL PROVISIONS

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 UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

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I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

Status: In Compliance. Each condition of Section I was reviewed at the time of inspection
and appeared to be in compliance. The source is not required to submit an emission
inventory at this time. The modification to the current AO was a change in the emission
limits for the Venturi Scrubber. Intrepid Potash submitted a performance test on
November 12, 2019 (DAQC-1559-19), demonstrating compliance with the new emission
limitations for the scrubber in the AO.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Potash Production Plant
Production plant includes all associated flotation, sizing, compaction, transferring and
stockpiling and loading equipment

II.A.2 Scrubbing Device
One (1) venturi type wet scrubber to control process and combustion emissions
Controls the 21 MMBtu/hr material dryer
Capacity: 14,000 acfm
Scrubbing liquid: water

II.A.3 Scrubbing Device (load-out)
One (1) wet scrubber to control emissions from the processes associated with the pre-
screening building.
Engart Dust Extraction Technology, type 27
Capacity: 18,000 acfm
Scrubbing liquid: water

II.A.4 Scrubbing Device (Tumbler Dryer)
One (1) wet scrubber to control emissions of process dust, emissions from the main product
compactor and combustion emissions
Controls the 2.5 MMBtu/hr material dryer.
Capacity: 34,000 acfm
Scrubber manufactured by Engart Dust Extraction Technology, type 36
Scrubbing liquid: water

II.A.5 Material Dryers
Two (2) product dryers
One (1) rated at 21 MMBtu/hr
One (1) rated at 2.5 MMBtu/hr
Fuel: propane

II.A.6 Unpaved Haul Roads and Operational Areas
Fugitive dust emissions associated with vehicle use from material harvesting and processing

II.A.7 Storage Tanks
Three (3) storage tanks

One (1) 23,000-gallon capacity
Service: fuel oil

Two (2) 700-gallon capacity each
Service: engine oil - For information purposes only.

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II.A.8 Storage Tank
One (1) storage tank
Capacity: 5,000 gallons
Service: gasoline

II.A.9 Storage Tanks
Three (3) pressurized storage propane tanks:
One (1) 30,000 gallons capacity
Two (2) 1,000 gallons capacity each

For information purposes only.

II.A.10 Various Equipment Items
Material processing equipment

Three (3) Screens
Capacities: one (1) at 33 tons per hour and two (2) at 55 tons per hour

Three (3) Crushers
Capacities: one (1) at 33 tons per hour and two (2) at 55 tons per hour

Conveyors
Leach tanks
Reclaim hopper
Belt feeder

II.A.11 Truck Mounted Fuel Storage Tanks
Three (3) truck mounted fuel tanks used to deliver diesel fuel to scrapers and other
equipment in the pond areas.
Capacities: one (1) 1,000 gallons, one(1) 500 gallons, and one (1) 250 gallons.

II.A.12 Diesel and Gasoline Engines
Ten (10) diesel engines manufactured between 1992 and 2005 have various ratings not to
exceed 116 hp each.
MACT Applicability: Subpart ZZZZ

Eleven (11) diesel engines manufactured between 2006 and 2014 have various ratings not to
exceed 116 hp each.
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

Twelve (12) gasoline engines have various ratings not to exceed 15 hp each.
MACT Applicability: Subpart ZZZZ

Status: In Compliance. The observed equipment appeared to be consistent with the
above listed equipment. Only two of the eleven diesel engines manufactured
between 2006 and 2014 (II.A.12) are currently on site as the engines vary based
on work load. No unapproved equipment was observed during the inspection.

II.B Requirements and Limitations

II.B.1 Site Requirements

II.B.1.a The owner/operator shall not exceed the following values:

A. All wet scrubbers - 15% opacity
B. Dryers - 10% opacity
C. All other points - 20% opacity. [R307-401-8]

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II.B.1.a.1 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. [R307-201-3]

Status: Not Observed. The area was extremely foggy making it extremely difficult to view
visible emissions. Refer to the VEO Form in the attachments for more details.

II.B.1.b The production of potash shall not exceed 210,000 tons per rolling 12-month period.
[R307-401-8]

II.B.1.b.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
of production shall be kept for all periods when the plant is in operation. Production shall be
determined by customer billing records or weight recordings. The records of production shall be
kept on a daily basis. [R307-401-8]

Status: In Compliance. For November 2022 to October 2023, Intrepid Potash produced
46,921 tons of potash. Records were reviewed during the inspection and are calculated
according to this condition.

II.B.2 Venturi Wet Scrubber Requirements

II.B.2.a The operating parameters shall be maintained within the following ranges for the venturi wet
scrubber:

A. The pressure drop shall not be less than 19 inches of water column.
B. The liquid flow rate shall not be less than 99 gallons per minute (gpm). [R307-401-8]

Status: In Compliance. The pressure drops and flow rates are kept above the required 19
inches of water column and 99 gpm flow rates for the Venturi Wet Scrubber. The source
indicated that if water stops flowing, the scrubber automatically stops. Records were
reviewed during the inspection and an example is included in the attachments.

II.B.2.b Exhaust air from the large product dryer shall be routed through the venturi wet scrubber before
being vented to the atmosphere. This venturi scrubber shall be sized to handle at least 5,000
ACFM. [R307-401-8]

Status: In Compliance. The exhaust air appeared to be routed through the Venturi Wet
Scrubber before being vented to the atmosphere. The Venturi Wet Scrubber is sized to
handle at least 5,000 ACFM.

II.B.3 Engart Wet Scrubber Requirements

II.B.3.a The owner/operator shall maintain the water flow rate of the internal spray nozzles at a minimum
of 7.5 gpm for Engart type 27 and 11 gpm for Engart type 36. [R307-401-8]

Status: In Compliance. The water flow rate is maintained above 7.5 gpm for the Engart
Type 27 Wet Scrubber, and 11 gpm for the Engart Type 36 Wet Scrubber. Records viewed
at the time of inspection confirmed the flow rates are maintained as required in this
condition.

II.B.3.b The Engart scrubber type 27 shall have a stack which is 50 feet high and vertically unrestricted.
[R307-401-8]

Status: In Compliance. The stack height was verified to be 50 unrestricted vertical feet.
Refer to the scrubber schematic in the attachments.

II.B.4 Testing Requirements.

II.B.4.a Emissions to the atmosphere at all times from the indicated emission points shall not exceed the
following rates and concentrations:

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Source: venturi wet scrubber
Pollutant: PM10 6.0 lb/hr and 0.05 grains/dscf (68 degrees F, 29.92 in Hg)

Source: Engart type 27 wet scrubber
Pollutant: PM10 2.05 lb/hr and 0.013 grains/dscf (68 degrees F, 29.92 in. Hg)

Source: Engart type 36 wet scrubber
Pollutant: PM10 3.87 lb/hr and 0.022 grains/dscf (68 degrees F, 29.92 in. Hg). [R307-401-8]

Status: In Compliance. The results from the most recent stack tests are as follows:

Venturi Wet Scrubber: 2.293 lb/hr and 0.041 gr/dscf (DAQC-1559-19).

Engart Type 27 Wet Scrubber: 0.028 lb/hr and 0.0017 gr/dscf. These values are taken from
the most recent stack test performed on December 5, 2023. The stack test has not yet been
reviewed by the DAQ.

Engart Type 36 Wet Scrubber: 0.1742 lb/hr and 0.0022 gr/dscf (DAQC-507-22).

II.B.4.b Stack testing to show compliance with the emission limitations shall be performed as specified
below:

Testing

Emissions Points: venturi wet scrubber and Engart wet scrubbers exhaust stacks

Testing Pollutant: PM10

Test Status: A new stack test of the venturi wet scrubber is required within 180 days after the
date of this AO. The initial compliance tests for Engart scrubbers were performed on June 5 and
6 of 2012. A compliance test is required on the emission point that has an emission rate limit.

Frequency: Compliance test at least once every five years, subsequent to the initial compliance
test. The most recent test was conducted on December 21, 2016. The Director may require
testing at any time. [R307-401-8]

Status: In Compliance.

The Venturi Wet Scrubber was stack tested on October 15, 2019, and will need to be stack
tested again in 2024.

The Engart Type 27 Wet Scrubber was stack tested on December 5, 2023, and will need to
be stack tested again in 2028.

The Engart Type 36 Wet Scrubber was stack tested on March 15, 2022, and will need to be
stack tested again in 2027.

II.B.4.c Notification

The Director shall be notified at least 30 days prior to conducting any required emission testing.
A source test protocol shall be submitted to DAQ when the testing notification is submitted to
the Director.

The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-401-8]

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II.B.4.d Reporting

The stack test results shall be submitted to the DAQ once testing is completed. The
owner/operator shall submit a copy of the results from the stack test as conducted to the Director
within 60 days after the test has been completed. [R307-401-8]

II.B.4.e Sample Location

The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other methods as approved by the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access
shall be provided to the test location. [R307-401-8]

II.B.4.f Volumetric Flow Rate

40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director.
[R307-401-8]

II.B.4.g PM10

For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51,
Appendix M, Methods 201, 201a, or other testing methods approved by the Director. The back
half condensibles shall also be tested using the method specified by the Director. All particulate
captured shall be considered PM10.

For stacks in which liquid drops are present, methods to eliminate the liquid drops should be
explored. If no reasonable method to eliminate the drops exists, then the following methods shall
be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate, or other testing
methods approved by the Director. The back half condensibles shall also be tested using the
method specified by the Director. The portion of the front half of the catch considered PM10 shall
be based on information in Appendix B of the fifth edition of the EPA document, AP-42, or other
data acceptable to the Director.

The back half condensibles shall not be used for compliance demonstration but shall be used for
inventory purposes. [R307-401-8]

II.B.4.h Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-401-8]

II.B.4.i New Source Operation

For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the production rate listed in this AO. If the production rate listed in this AO has
not been achieved at the time of the test, then compliance testing shall be conducted at no less
than 90% of the maximum production rate achieved as of the date of the test. [R307-401-8]

II.B.4.j Existing Source Operation

For an existing source/emission point, the production rate during all compliance testing shall be
no less than 90% of the maximum production achieved in the previous three (3) years.
[R307-401-8]

Status: In Compliance. The above stack testing conditions were reviewed at time of each
individual stack test audit.

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II.B.4.k The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the
continuous measurement of the change in pressure of the gas stream through the venturi
scrubber. The accuracy of the monitoring device must be certified by the manufacturer(s). The
monitoring device shall be accurate within plus or minus one inch of water column and must be
calibrated on an annual basis according to the manufacturer's instructions. Intermittent recording
of each of the readings shall be required on a daily basis and these records maintained.
[R307-401-8]

Status: In Compliance. The source appears to operate, calibrate, and maintain the pressure
gauge for the Venturi Scrubber. The calibration was last performed January 20, 2023.
Records are maintained on a daily basis. See attached Flow Meter and DP Gauge
Calibration record.

II.B.4.l The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the
continuous measurement of the scrubbing liquid flow rate through all scrubbers. The monitoring
device must be certified by the manufacturer to be accurate within plus or minus ten percent of
the design scrubbing liquid flow rate and must be calibrated on an annual basis in accordance
with the manufacturer's instructions. Intermittent recording of each of the readings shall be
required on a daily basis and these records maintained. [R307-401-8]

Status: In Compliance. The source appears to operate and maintain the flow meters for
each scrubber. The flow meters were last calibrated on January 20, 2023. Records are
maintained on a daily basis. See attached Flow Meter and DP Gauge Calibration record.

II.B.5 Fuel Requirements

II.B.5.a The owner/operator shall use only propane as a fuel in the material dryers. [R307-401-8]

Status: In Compliance. The source uses only propane as fuel in the material dryers.

II.B.5.b The owner/operator shall only use gasoline fuel in the 12 gasoline engines. [40 CFR 63 Subpart
ZZZZ]

Status: In Compliance. The source stated that they use only gasoline in the gasoline
engines.

II.B.5.c The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel additives) in the 21
diesel engines. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and
contain no more than 15 ppm sulfur. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

II.B.5.c.1 To demonstrate compliance with the fuel oil requirements, the owner/operator shall keep and
maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel
meets the ULSD requirements or the owner/operator shall obtain certification of the sulfur
content from the fuel supplier. [R307-401-8]

Status: In Compliance. The source uses only ULSD as a fuel in the diesel engines. A
Certificate of Analysis provided indicates the sulfur content to be 6.9 ppm, below the
15-ppm sulfur limit. See attached HF Sinclair Certificate of Analysis and RelaDyne diesel
invoice.

II.B.6 Haul Road Requirements

II.B.6.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources
on site to exceed 20 percent opacity. [R307-205]

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II.B.6.a.1 Visible emission determinations shall use procedures similar to Method 9. The normal
requirement for observations to be made at 15-second intervals over a six-minute period,
however, shall not apply. Visible emissions shall be measured at the densest point of the plume
but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height
of the vehicle. [R307-401-8]

Status: Not Observed. The area was extremely foggy making it extremely difficult to view
visible emissions. The haul roads and operational areas have high magnesium chloride and
salt content due to the nature of the operation and excessive moisture was observed on the
haul roads from recent precipitation making visible emissions highly unlikely. Refer to the
VEO Form in the attachments for more details.

II.B.6.b The owner/operator shall use water application or other control options contained in R307-205 to
minimize emissions from fugitive dust and fugitive emissions sources, including haul roads,
storage piles, and disturbed areas. Controls shall be applied to ensure the opacity limits in this
AO are not exceeded. [R307-205, R307-401-8]

II.B.6.b.1 The owner/operator shall keep and maintain records of water application for all periods that the
source is in operation. Records of water application shall include:

A. Date

B. Time of day that water was applied or sweeping occurred

C. Quantity of water applied. [R307-401-8]

Status: Not Applicable. Due to the nature of the site, the haul roads, storage piles, and
disturbed areas contain a high content of magnesium chloride and salt, which mitigates the
need for consistent watering. However, the source stated that they rent a water truck
during the summer to water as needed and maintain watering records if operational.

II.B.7 Engine Requirements

II.B.7.a The owner/operator shall not operate the 21 diesel engines for more than 12,000 hours combined
per rolling 12-month period. [R307-401-8]

II.B.7.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. Records shall be kept for all periods when the plant is in
operation. Records documenting usage shall be kept in an operations log. [R307-401-8]

Status: In Compliance. From a previous inspection (DAQC-267-20), the source calculates
the engine hours under the following method:

“They typically harvest from two or more ponds at a time, so there are often more than 31
‘Harvesting Days’ in a month.

At the end of harvesting each pond, the elevator engines are shut off and the operators
harvest the ramp (made from potash) that they had driven on to access the rest of the pond.
This typically takes 5 days, so five days for each pond completed in a month are deducted
from the gross "Harvesting Days."

The operators said the engines operate about 90% of the time while harvesting. The
remaining 10% is for startup, shutdown, refueling, maintenance, etc.

Using these data and typical operating routines, I calculate the monthly hourly engine
usage using this formula:

Monthly usage = [ (Harvesting Days) - (5 x Ponds Completed) ] x 24 hours x 90%”

The rolling 12-month total for November 2022 - October 2023, the source operated the
engines for 6,329 hours. See attached engine hour totals.
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Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

NSPS (Part 60) -IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: In Compliance. NSPS (Part 60), IIII is applicable to the eleven non-emergency diesel-fueled
engines manufactured between 2006-2014 that have various ratings not to exceed 116 hp each and
commenced construction after July 11, 2005. Intrepid Potash inspects belts and air filters and changes
the oil and oil filters every 250 hours.

MACT (Part 63) -CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category:
Gasoline Dispensing Facilities

Status: In Compliance. The source has a monthly throughput less than 10,000 gallons. Equipment and
associated control equipment appeared to be properly maintained. No spills were noted around the
equipment. Gasoline throughput records are kept. See attached gasoline throughput records.

MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. MACT (Part 63), ZZZZ is applicable to ten of the non-emergency diesel-fueled
engines manufactured between 1992-2005 and have ratings not to exceed 116 hp each and commenced
construction after July 11, 2005, and the twelve gasoline engines not to exceed 15 hp each. Intrepid
Potash inspects belts and air filters and changes the oil and oil filters every 250 hours.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]

Status: In Compliance. The Certificate of Analysis from HF Sinclair dated December 7, 2023,
indicated the sulfur content was 6.9 ppm, meeting the requirements of this rule.

Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

Status: In Compliance. No fugitive emissions were observed due to fog and no track-out was
observed. The haul-roads and operational areas have a high salt content due to the nature of the
facility, which helps mitigate fugitive dust. A water truck is rented in the summer when necessary.

Stationary Sources [R307-210]

Status: In Compliance. This rule is satisfied by compliance with 40 CFR Part 60 Subpart IIII. Refer
to the Federal Requirements Section for more details.

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National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. This rule is satisfied by compliance with 40 CFR Part 63 Subpart ZZZZ and
Subpart CCCCCC. Refer to the Federal Requirements Section for more details.

EMISSION INVENTORY:

The emissions listed below are an estimate of the total potential emissions (PTE) from Intrepid Potash
Wendover, LLC - Wendover Potash Plant on the Approval Order (AO) DAQE- AN107420014-19, dated
July 22, 2019. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 20050.00
Carbon Monoxide 21.14
Nitrogen Oxides 63.66
Particulate Matter - PM10 98.40
Particulate Matter - PM2.5 15.21
Sulfur Dioxide 4.36
Sulfur Oxides 43.47
Volatile Organic Compounds 5.86

Hazardous Air Pollutant PTE lbs/yr
Acetaldehyde (CAS #75070) 6
Benzene (Including Benzene From Gasoline) (CAS #71432) 8
Ethyl Benzene (CAS #100414) 4
Formaldehyde (CAS #50000) 10
Generic HAPs (CAS #GHAPS) 80
Hexane (CAS #110543) 10
Methanol (CAS #67561) 62
Toluene (CAS #108883) 63
Xylenes (Isomers And Mixture) (CAS #1330207) 11

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN107420014-19
dated July 22, 2019: In Compliance. The source appears to be
well maintained and operated. Required records were current and
reviewed on site and also made available after the inspection via
email.

HPV STATUS: Not Applicable.

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RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the regular inspection frequency for this type of
source. Inspect between October 1 – April 1, as the plant does
not typically process material during the summer months.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, Diesel Monthly Hours, Gasoline Monthly Hours,
Engart Type 27 Schematic, Calibration Records, Fuel Purchase
Invoice, Certificate of Analysis, Scrubber Flow Rate, and
Pressure Drop Examples
Wendover Intrepid Potash
Diesel Monthly Hours – AO Limit % - 2023

DATE Monthly HRS 12 Month TTL AO Limit %
12,000 HRS
1-Jan-2023 497 5,916 49%
1-Feb-2023 972 6,305 53%
1-Mar-2023 670 6,089 51%
1-Apr-2023 799 5,678 47%
1-May-2023 626 5,311 44%
1-Jun-2023 389 5,268 44%
1-Jul-2023 842 5,750 48%
1-Aug-2023 583 5,901 49%
1-Sep-2023 691 6,329 53%
1-Oct-2023 259 6,329 53%
1-Nov-2023 389 6,718 56%
1-Dec-2023 562 7,279 61%

Wendover Intrepid Potash
Gasoline 12 Month Usage and Rolling 12 Month Average AO % - 2023

Month Monthly 12 Month
Gallons Average
Jan-23 598 9,190
Feb-23 763 8,986
Mar-23 813 8,918
Apr-23 749 8,794
May-23 957 8,868
Jun-23 1298 9,234
Jul-23 1278 9,385
Aug-23 1390 10,519
Sep-23 986 10,847
Oct-23 635 11,015
Nov-23 391 10,516
Dec-23 591 10,449