DAQ-2024-004783

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DAQC-106-24
Site ID 11594 (B1)
MEMORANDUM

TO: FILE – TOOELE ARMY DEPOT (TEAD) – Hazardous Waste Incinerator

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: February 5, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Tooele County,
FRS ID# UT0000004904500006

INSPECTION DATE: January 30, 2024

SOURCE ADDRESS: Highway 36, south of Tooele, Tooele County, Utah

MAILING ADDRESS: Tooele Army Depot
JMTE – BOV, Building 501
1 Tooele Army Depot
Tooele, UT 84074-5003

SOURCE CONTACT: Lonnie Brown: 435-833-2526 – Environmental Engineer
[e-mail]

OPERATING STATUS: Rotary kiln / Deactivation Furnace / Hazard Waste Incenerator (HWI) was
Operating at time of the inspecton.

PROCESS DESCRIPTION: TEAD operates a rotary kiln furnace which flashes explosive residue
from projectiles. Pollution controls include a cyclone, an afterburner, and
ceramic baghouse. Feed materials are loaded by operators into a push-off
box which is controlled by the timer to allow only the predetermined
feed rate. The material drops onto the feed belt which drops the material
into the front end of the kiln. The material passes through the fuel oil
fired counter current kiln where the heat ignites and separates the shell.
Any ash or metal components that are not entrained in the flue gas are
discharged at the end of the kiln to collection bins. The flue gas goes
through the discharge duct to a preliminary cyclone where any heavy
entrained particles or sparks are collected and dropped to a tipping valve
and collection box. The gasses continue on to the afterburner and then
are ducted to the ceramic baghouse and then to the ambient air.
Additionally, the kiln is inside a total enclosure with any ambient air
from the enclosure entering to the baghouse. The whole system is
equipped with a continuous monitoring system (CMS) that measures all
required process parameters such as flows, pressure, levels, etcetera. The
MACT standard for hazardous waste incinerators applies to this source.
The disassembly line functions as a recycling process of spent ordinance
shells and its propellants. The brass part of the shells are recovered and
sold as scrap.

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APPLICABLE
REGULATIONS: Title V Permit # 4500006004, dated August 20, 2019, and revised
March 11, 2020

MACT (Part 63), A: NESHAP General Provisions
MACT (Part 63), EEE: NESHAP for Hazardous Waste Combustors

SOURCE INSPECTION
EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

Status:
All terms and conditions in this permit, including those provisions designed to limit the potential to
emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990 (CAA) except those
terms and conditions that are specifically designated as "State Requirements." (R307-415-6b)

This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Status:
Except as provided in R307-415-7b(1), the permittee may not operate except in compliance with
this permit. (See also Provision I.E, Application Shield)

This is a statement of fact and not an inspection item.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit noncompliance
constitutes a violation of the Air Conservation Act and is grounds for any of the following:
enforcement action; permit termination; revocation and reissuance; modification; or denial of a
permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been necessary
to halt or reduce the permitted activity in order to maintain compliance with the conditions of this
permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that the
Director may request in writing to determine whether cause exists for modifying, revoking and
reissuing, or terminating this permit or to determine compliance with this permit. Upon request, the
permittee shall also furnish to the Director copies of records required to be kept by this permit or,
for information claimed to be confidential, the permittee may furnish such records directly to the
EPA along with a claim of confidentiality. (R307-415-6a(6)(e))

I.C.4

Status:
This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing
of a request by the permittee for a permit modification, revocation and reissuance, or termination, or
of a notification of planned changes or anticipated noncompliance shall not stay any permit
condition, except as provided under R307-415-7f(1) for minor permit modifications. (R307-415-
6a(6)(c))

This is a statement of fact and not an inspection item.

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I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under "Enforceable Dates
and Timelines" at the front of this permit. An application may be submitted early for any reason.
(R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be accepted for
processing, but shall not be considered a timely application and shall not relieve the permittee of
any enforcement actions resulting from submitting a late application. (R307-415-5a(5))

I.D.4

Status:
Permit expiration terminates the permittee's right to operate unless a timely and complete renewal
application is submitted consistent with R307-415-7b (see also Provision I.E, Application Shield)
and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

The permit expires August 20, 2024. Application for renewal is due February 20, 2024. The
source is aware that the application for permit renewal is due by February 20, 2024.

I.E Application Shield.

Status:
If the permittee submits a timely and complete application for renewal, the permittee's failure to
have an operating permit will not be a violation of R307-415, until the Director takes final action on
the permit renewal application. In such case, the terms and conditions of this permit shall remain in
force until permit renewal or denial. This protection shall cease to apply if, subsequent to the
completeness determination required pursuant to R307-415-7a(3), and as required by R307-415-
5a(2), the applicant fails to submit by the deadline specified in writing by the Director any
additional information identified as being needed to process the application. (R307-415-7b(2))

Application for renewal is due February 20, 2024.

I.F Severability.

Status:
In the event of a challenge to any portion of this permit, or if any portion of this permit is held
invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

This is a statement of fact and not an inspection item.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9. (R307-
415-6a(7))

I.G.2

Status:
The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

In compliance – The annual emission fee payment was received after the due date of October
2, 2023. The payment was received on October 21, 2023. This is because the DAQ sent the
invoice to the wrong email address. The source has provided the correct email address to the
DAQ, since the inspection. See Compliance Assistance below.

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I.H No Property Rights.

Status:
This permit does not convey any property rights of any sort, or any exclusive privilege. (R307-415-
6a(6)(d))

This is a statement of fact and not an inspection item.

I.I Revision Exception.

Status:
No permit revision shall be required, under any approved economic incentives, marketable permits,
emissions trading and other similar programs or processes for changes that are provided for in this
permit. (R307-415-6a(8))

This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the permittee
shall allow the Director or an authorized representative to perform any of the following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related activity is
conducted, or where records are kept under the conditions of this permit. (R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under the conditions of
this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control
equipment), practice, or operation regulated or required under this permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of assuring
compliance with this permit or applicable requirements. (R307-415-6c(2)(d))

I.J.2

Status:
Any claims of confidentiality made on the information obtained during an inspection shall be made
pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

In compliance – Required reports and records were made available and no claims of
confidentially were made at time of the inspection.

I.K Certification.

Status:

Any application form, report, or compliance certification submitted pursuant to this permit shall
contain certification as to its truth, accuracy, and completeness, by a responsible official as defined
in R307-415-3. This certification shall state that, based on information and belief formed after
reasonable inquiry, the statements and information in the document are true, accurate, and complete.
(R307-415-5d)

Reports and certifications submitted appeared to have certification statements and were
signed by responsible officials.

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I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying compliance
with the terms and conditions contained in this permit, including emission limitations, standards, or
work practices. This certification shall be submitted no later than the date shown under
"Enforceable Dates and Timelines" at the front of this permit, and that date each year following
until this permit expires. The certification shall include all the following (permittee may cross-
reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the certification;

I.L.1.b The identification of the methods or other means used by the permittee for determining the
compliance status with each term and condition during the certification period. Such methods and
other means shall include, at a minimum, the monitoring and related recordkeeping and reporting
requirements in this permit. If necessary, the permittee also shall identify any other material
information that must be included in the certification to comply with section 113(c)(2) of the Act,
which prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period covered by the
certification, including whether compliance during the period was continuous or intermittent. The
certification shall be based on the method or means designated in Provision I.L.1.b. The
certification shall identify each deviation and take it into account in the compliance certification.
The certification shall also identify as possible exceptions to compliance any periods during which
compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64
occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

I.L.2

Status:
The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director: (R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

In compliance – The initial annual compliance certification was received on January 29, 2024,
a day after the January 28, 2024, deadline. However, it should be noted that January 28 was a
Sunday.

The annual compliance certification has been revised to include the deviation mentioned in
the six-month monitoring report for report period January 1, 2023 – June 30, 2023, regarding
noncompliance with condition II.B.1.g. The annual compliance certification was deemed
acceptable after being revised. See status of condition I.S.2 and Compliance Assistance below.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any applicable
requirements as of the date of this permit, provided that:

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I.M.1.a Such applicable requirements are included and are specifically identified in this permit, or
(R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed in this permit.
(R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112, and the
provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable requirements
under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110 prior to or at the time of
issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA Section 408(a).
(R307-415-6f(3)(c))

I.M.2.d

Status:
The ability of the Director to obtain information from the source under Utah Code Ann. Section 19-
2-120, and the ability of the EPA to obtain information from the source under the CAA Section 114.
(R307-415-6f(3)(d))

N/A – See section III of this permit.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events beyond
the control of the source, including acts of God, which situation requires immediate corrective
action to restore normal operation, and that causes the source to exceed a technology-based
emission limitation under this permit, due to unavoidable increases in emissions attributable to the
emergency. An emergency shall not include noncompliance to the extent caused by improperly
designed equipment, lack of preventive maintenance, careless or improper operation, or operator
error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance with such
technology-based emission limitations if the affirmative defense is demonstrated through properly
signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize levels of
emissions that exceeded the emission standards, or other requirements in this permit.
(R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two working days of the
time when emission limitations were exceeded due to the emergency. This notice must contain a
description of the emergency, any steps taken to mitigate emissions, and corrective actions taken.
This notice fulfills the requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

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I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency
has the burden of proof. (R307-415-6g(4))

I.N.4

Status:
This emergency provision is in addition to any emergency or upset provision contained in any other
section of this permit. (R307-415-6g(5))

No emergency events were reported since the last inspection, which was conducted on
February 28, 2023.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

I.Q

Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

I.R

Permit Modifications.

Status:
Permit modifications are governed by R307-415-7f.

These are statements of fact and not inspection items (I.O through I.R).

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be retained by the
permittee for a period of at least five years from the date of the monitoring sample, measurement,
report, or application. Support information includes all calibration and maintenance records, all
original strip-charts or appropriate recordings for continuous monitoring instrumentation, and
copies of all reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source shall record
the following information, where applicable: (R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement.

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I.S.1.c

Status:
Additional record keeping requirements, if any, are described in Section II, Special Provisions.

In compliance – Required records were provided at time of the inspection.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more frequently if
specified in Section II. All instances of deviation from permit requirements shall be clearly
identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible official in
accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i)

I.S.2.c

The Director shall be notified promptly of any deviations from permit requirements including those
attributable to upset conditions as defined in this permit, the probable cause of such deviations, and
any corrective actions or preventative measures taken. Prompt, as used in this condition, shall be
defined as written notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to breakdowns shall
be reported in accordance with the provisions of R307-107. (R307-415-6a(3)(c)(ii))
I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to the
Director are to be sent to the following address or to such other address as may be required by the
Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b

All reports, notifications or other submissions required by this permit to be submitted to the EPA
should be sent to one of the following addresses or to such other address as may be required by the
Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

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Status:
For reports, notifications, or other correspondence related to permit modifications, applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

In compliance – The required six-month monitoring reports, have been submitted, for report
periods January 1, 2023 – June 30, 2023, and July 1, 2023 – December 31, 2023. The latest
deviation notice was receivced on March 27, 2023. The deviation notice explains how opacity
readings were not conducted for the fourth quarter of 2022 (condition II.B.1.g). However, the
deviation was not detected until January 24, 2023. Therefore, the deviation was noted in the
six-month monitoring report for the report period January 1, 2023 – June 30, 2023, and the
2023 annual compliance certification. See status of conditions I.L.1 and II.B.1.g. Also,
Compliance Assistance below.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a remaining permit
term of three or more years. No such reopening is required if the effective date of the requirement is
later than the date on which this permit is due to expire, unless the terms and conditions of this
permit have been extended pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that inaccurate
statements were made in establishing the emissions standards or other terms or conditions of this
permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to assure compliance
with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date of this permit
and are in conflict with existing permit conditions. (R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a Title IV
affected source under the Acid Rain Program. Upon approval by EPA, excess emissions offset plans
shall be deemed to be incorporated into this permit. (R307-415-7g(1)(b))

I.T.3

Status:
Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial permit
issuance and shall affect only those parts of this permit for which cause to reopen exists.
(R307-415-7g(2))

This is a statement of fact and not an inspection item.

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I.U Inventory Requirements.

Status:

An emission inventory shall be submitted in accordance with the procedures of R307-150, Emission
Inventories. (R307-150)

In compliance – The 2022 annual emission inventory was submitted on April 13, 2023. The
2023 annual emisison inventory is due by April 15, 2024. See the SLEIS database.

I.V Title IV and Other, More Stringent Requirements

Status:
Where an applicable requirement is more stringent than an applicable requirement of regulations
promulgated under Title IV of the Act, Acid Deposition Control, both provisions shall be
incorporated into this permit. (R307-415-6a(1)(b))

This is a statement of fact and not an inspection item.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2

Status:
APE 1236: APE 1236M1 Deactivation Furnace

The APE 1236M1 deactivation furnace is a rotary furnace used to destroy ammunition ranging from small
arms through 20 mm. The furnace is equipped with a cyclone, diesel oil-fired afterburner, Sodium
Bicarbonate Injection System, high temperature baghouse, fan, and a stack. Located in Building 1320.

In compliance – No unapproved equipment was noted, regarding the HWI, at time of the
inspection. It was noted that new continuous monitoring system (CMS) and control panel
instrumentation was installed by August 24, 2022. Permit modification was not required, it is
considered to be a replacement-in-kind.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 APE 1236M1 Deactivation Furnace ( APE 1236).

II.B.1.a Condition:

The permittee shall comply with all applicable requirements of 40 CFR 63 Subpart EEE including but not
limited to (a)-(f) below:

(a) Emissions limits- (40 CFR §63.1219(a)). The permittee shall not discharge or cause combustion gases
to be emitted into the atmosphere that contain:

(1) Dioxin and furans:

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(A) For incinerators equipped with either a waste heat boiler or dry air
pollution control system, either:

(i) Emissions of dioxins and furans shall not exceed 0.20 ng
TEQ/dscm, corrected to 7 percent oxygen; or

(ii) Emissions of dioxins and furans shall not exceed 0.40 ng
TEQ/dscm, corrected to 7 percent oxygen, provided that the
combustion gas temperature at the inlet to the initial particulate
matter control device is 400 °F or lower based on the average of
the test run average temperatures. (For purposes of compliance,
operation of a wet particulate matter control device is presumed to
meet the 400 °F or lower requirement);

(B) Emissions of dioxins and furans shall not exceed 0.40 ng TEQ/dscm,
corrected to 7 percent oxygen, for incinerators not equipped with either a
waste heat boiler or dry air pollution control system;

(C) A source equipped with a wet air pollution control system followed by
a dry air pollution control system is not considered to be a dry air pollution
control system, and a source equipped with a dry air pollution control
system followed by a wet air pollution control system is considered to be a
dry air pollution control system for purposes of this standard;

(2) Mercury in excess of 130 micrograms/dscm, corrected to 7 percent oxygen;

(3) Cadmium and lead in excess of 230 micrograms/dscm, combined emissions, corrected to 7
percent oxygen;

(4) Arsenic, beryllium, and chromium in excess of 92 micrograms/dscm, combined emissions,
corrected to 7 percent oxygen;

(5) For carbon monoxide and hydrocarbons, either:

(i) Carbon monoxide in excess of 100 parts per million by volume, over an
hourly rolling average (monitored continuously with a continuous emissions
monitoring system), dry basis and corrected to 7 percent oxygen. If you elect to
comply with this carbon monoxide standard rather than the hydrocarbon standard
under paragraph (a)(5)(ii), you must also document that, during the destruction
and removal efficiency (DRE) test runs or their equivalent as provided by
§63.1206(b)(7), hydrocarbons do not exceed 10 parts per million by volume
during those runs, over an hourly rolling average (monitored continuously with a
continuous emissions monitoring system), dry basis, corrected to 7 percent
oxygen, and reported as propane; or

(ii) Hydrocarbons in excess of 10 parts per million by volume, over an hourly
rolling average (monitored continuously with a continuous emissions monitoring
system), dry basis, corrected to 7 percent oxygen, and reported as propane;

(6) Hydrogen chloride and chlorine gas (total chlorine) in excess of 32 parts per million by
volume, combined emissions, expressed as a chloride (Cl(-)) equivalent, dry basis and corrected
to 7 percent oxygen; and

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(7) Particulate matter in excess of 0.013 gr/dscf corrected to 7 percent oxygen.

(b) Destruction and removal efficiency standard (DRE)- (40 CFR §63.1219(c)).

(1) Except as provided in paragraph (b)(2), the permittee shall achieve a destruction and
removal efficiency (DRE) of 99.99% for each principle organic hazardous constituent
(POHC) designated under paragraph (b)(3). The permittee shall calculate DRE for each POHC
from the following equation:

DRE = [1 - (Wout / Win)] x 100%

Where:

Win = mass feedrate of one POHC in a waste feedstream; and

Wout = mass emission rate of the same POHC present in exhaust emissions prior
to release to the atmosphere.

(2) 99.9999% DRE. If you burn the dioxin-listed hazardous wastes F020, F021, F022, F023,
F026, or F027 (see 40 CFR §261.31), you must achieve a DRE of 99.9999% for each POHC that
you designate under paragraph (b)(3). You must demonstrate this DRE performance on POHCs
that are more difficult to incinerate than tetra-, penta-, and hexachlorodibenzo-p-dioxins and
dibenzofurans. You must use the equation in paragraph (b)(1) to calculate DRE for each POHC.
In addition, you must notify the Administrator of your intent to incinerate hazardous wastes F020,
F021, F022, F023, F026, or F027.

(3) Principal organic hazardous constituent (POHC).

(i) You must treat each POHC in the waste feed that you specify under paragraph
(b)(3)(ii) to the extent required by paragraphs (b)(1) and (b)(2).

(ii) You must specify one or more POHCs that are representative of the most
difficult to destroy organic compounds in your hazardous waste feedstream. You
must base this specification on the degree of difficulty of incineration of the
organic constituents in the hazardous waste and on their concentration or mass in
the hazardous waste feed, considering the results of hazardous waste analyses or
other data and information.

(c) Significant figures- (40 CFR 63.1219 (d)).

(d) Compliance with Standards- (40 CFR 63.1206(b)).

(e) Operating requirements- (40 CFR 63.1206 (c)).

(f) General Provisions- The permittee shall comply with all applicable requirements of 40 CFR 63
Subpart A as given in Table 1 of 40 CFR 63 Subpart EEE.

[Authority granted under 40 CFR 63 Subpart EEE; condition originated in 40 CFR 63 Subpart EEE]

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II.B.1.a.1 Monitoring:

The permittee shall comply with all applicable performance testing and monitoring requirements of 40
CFR 63 Subpart EEE including but not limited to those given in 40 CFR 63.1207, 1208, 1209, and 1215.

The permittee shall comply with all applicable requirements of 40 CFR 63 Subpart A as given in Table 1
of 40 CFR 63 Subpart EEE.

II.B.1.a.2 Recordkeeping:

The permittee shall comply with the recordkeeping requirements in Section I of this permit and any
additional recordkeeping requirements of:

(a) 40 CFR 63 Subpart EEE including but not limited to those given in 40 CFR 63.1211.

(b) 40 CFR 63 Subpart A as given in Table 1 of 40 CFR 63 Subpart EEE.

II.B.1.a.3

Status:
Reporting:

The permittee shall comply with the reporting requirements in Section I of this permit and any additional
reporting and notification requirements of:

(a) 40 CFR 63 Subpart EEE, as applicable, including but not limited to those given in 40 CFR
63.1207, 1210, 1211, 1212 and 1215.

(b) 40 CFR 63 Subpart A as given in Table 1 of 40 CFR 63 Subpart EEE.

In compliance – Comprehensive performance test (CPT) for the APE 1236 M2 Deactivation
Furnace was conducted on October 23-26, 2021. This test demonstrates compliance with the
emission limits found in condition II.B.1.a and 40 CFR 60, Subpart EEE (Hazardous Waste
Incinerators). The CPT has a five year requirement. Initially, the CPT was planned to be conducted
during the week of August 16, 2021. However, due to atmospheric smoke from wildfires the test
was postponed until the end of October 2021. A deviation report dated August 30, 2021, was
submitted asking for an extension. The extension was approved. The results of the October 2021
test are as follows:

14
Test Date Test Method Pollutant Test Results Permit Limit
October 23-26, 2021 23A/PCDD Dioxins & Furans 0.0051 0.20 ng
TEQ/dscm
N/A Mercury N/A 130 ug/dscm
M29 SVM 18 230 ug/dscm
M29 LVM 2.7 92 ug/dscm
CEMs CO 22 100 ppmv (dry)
M25A THC 1.7 10 ppmv (dry)
M26/5 HCl/Cl2 0.56 32 ppmv (dry)
M26/5 PM 0.0011 0.013 gr/dscf
M0010 DRE 99.9985 99.99%

Notes:
- All results corrected to 7% O2.
- Mercury emissions not measured (no mercury is feed to the furnace).
- CO and THC values are highest maximum hourly rolling averages reported during the CPT.

The next CPT is not required to be performed until 2026.

The CFPT is scheduled to be performed in May of 2024.

The semiannual excessive emission, monitoring and periodic startup, shutdown, and malfuction
reports for the report periods January 1, 2023 - June 30, 2023, and July 1, 2023 - December 31,
2023, have also been submitted according to Subpart EEE.

See status of conditions I.S.2.c and I.S.3.b.

II.B.1.b Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate any permitted plant equipment, 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. [Authority granted under R307-401-4; condition originated in DAQE-AN115940059-20].

II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.b.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance. Records shall
be maintained in accordance with Provision I.S.1 of this permit.

15
II.B.1.b.3

Status:
Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

In compliance – The HWI appeard to be properly maintained and operated. A Daily Operating Log
is maintained and daily inspections are conducted by the furnace staff. Weekly, monthly, and
quarterly maintenance is conducted and electronically tracked. Conducted maintenance is sent to
Lonnie Brown for filing. Records were made available for review at time of the inspection.

II.B.1.c Condition:

Hours of operation shall be no greater than 3,340 hours per rolling 12-month period while feeding
hazardous waste (HW). [Authority granted under R307-401-(8); condition originated in DAQE-
AN115940059-20].

II.B.1.c.1 Monitoring:

By the 15th day of each month, the permittee shall calculate the total hours of HW operations in the
previous 12 months for the affected emission unit. The hours of HW operations for the affected emission
unit shall be determined by an hour meter and/or a log.

II.B.1.c.2 Recordkeeping:

Records of monitoring shall be kept on a daily basis during operations. Results of monitoring shall be
maintained as described in Provision I.S.1 of this permit.

II.B.1.c.3

Status:
Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

In compliance – The HWI operated for 1,440.30 hours for the 12-month period January
2023 - December 2023.

II.B.1.d Condition:

The permittee shall use only #1 or #2 fuel oil as a primary fuel and propane as a pilot fuel. [Authority
granted under R307-401-(8); condition originated in DAQE-AN115940059-20].

II.B.1.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.d.2 Recordkeeping:

The permittee shall keep one or more of the following sets of records for the affected emission unit:

(1) Documentation that the burners can only use the fuels listed in this condition;

(2) Documentation that fuels other than those listed in this condition cannot be supplied to the burners
without modification of the fuel supply system; or

16
(3) Fuel bills or fuel meter readings that demonstrate only the fuels listed in this condition are combusted
in the burners.

If fuel bills or fuel meter readings will be used, the permittee shall review fuel bills or fuel meter readings
at least once per quarter to determine compliance with this condition. The records required by this
condition shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.d.3

Status:
Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

In compliance – #2 diesel (ultra low sulfur (ULS)) fuel was delivered to the TEAD by Offen
Petroleum on January 24, 2024. #2 diesel is the only fuel used by the HWI. Propane is the only fuel
used for the pilot.

II.B.1.e Condition:

Gas residence time shall be no less than 2 seconds in the afterburner during the HW incineration period.
[Authority granted under R307-401-(8); condition originated in DAQE-AN115940059-20].

II.B.1.e.1 Monitoring:

In lieu of monitoring gas residence time, the permittee shall monitor stack gas velocity as follows:

(a) Frequency. The stack gas velocity shall be measured at least once every 30 seconds during each HW
incineration period, as defined in this permit. The stack gas velocity data recorder shall be located such
that an inspector/operator can safely read the output.

(b) Calibration. The velocity readings shall be accurate to plus or minus 5 feet per second. The velocity
measurement device shall be calibrated against a primary standard at least once every 12 months. The
primary standard shall be established by the permittee and shall be submitted to the Director for approval.

The permittee shall be considered to be in compliance with gas residence time requirement of this
condition when the stack gas velocity is less than or equal to 70 feet per second. [R307-415-6b]

II.B.1.e.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.e.3

Status:
Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

In compliance – Stack gas velocity is continuously monitored by the data recorder. The data
recorder is calibrated annually by Coterie Environmental. Stack gas velocity and calibration
records are maintained. A hardstop interlock reported to be set at 44 feet/second (Ft/S). The stack
gas velocity reading was approximately 27.7 Ft/S at time of the inspection.

17
II.B.1.f Condition:

Baghouse pressure drop shall be no less than 1.0 inches of water column. [Authority granted under R307-
401-(7); condition originated in DAQE-AN115940059-20].

II.B.1.f.1 Monitoring:

The permittee shall monitor the pressure drop across the baghouse as follows:

(a) Frequency. The pressure drop shall be measured at least once every 30 seconds during each HW
incineration period, as defined in this permit. The pressure drop data recorder shall be located such that an
inspector/operator can safely read the output.

(b) Calibration. The pressure drop readings shall be accurate to plus or minus 0.5 inches of water column.
The pressure drop measurement device shall be calibrated against a primary standard at least once every
12 months. The primary standard shall be established by the permittee and shall be submitted to the
Director for approval.

II.B.1.f.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.f.3

Status:
Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

In compliance – The baghouse pressure drop (pd) is continuously monitored by the data recorder.
The data recorder is calibrated annually by Coterie Environmental. Baghouse pd and calibration
records are maintained. According to the records, the baghouse pd has not been less than 1.0 inches
of water column since the last inspection. A water feed cut off keeps the pd from going below 1.0
inches of water colmn. The pd readings was approximately 16.5 inches of water column at time of
the inspection.

II.B.1.g Condition:

Visible emissions shall be no greater than 10 percent opacity from the high temperature ceramic bag
stack. [Authority granted under R307-401-(8); condition originated in DAQE-AN115940059-20].

II.B.1.g.1 Monitoring:

An opacity determination shall be conducted once in each quarter that the affected emission unit is
operated. The opacity determination shall be conducted in accordance with 40 CFR 60, Appendix A,
Method 9.

II.B.1.g.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

18
II.B.1.g.3

Status:
Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

In compliance - Visible emission observations (VEOs) are conducted quarterly by the HWI staff.
The staff is EPA Method 9 certified. Reviewed records indicated 0% opacity from the baghouse
stack. Records also indicated that VEOs were not conducted for the fourth quarter of 2022. This
deviation was not noted until January 24, 2023.

See status of conditions I.L.1 and I.S.2.

An enforcement action is not required, since a deviation notice has been submitted to the DAQ.

II.C Emissions Trading
(R307-415-6a(10))

Not applicable to this source.

II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

II.E Source-specific Definitions: There are no source-specific definitions in this permit.

SECTION III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with
Provision I.M, Permit Shield:

III.A. (Permit Shield)

This regulation is not applicable to the Permitted Source for the following reason(s): A shield has
not been requested [Last updated February 20, 2020]

SECTION IV: ACID RAIN PROVISIONS

IV.A This source is not subject to Title IV. This section is not applicable.

EMISSION INVENTORY: The 2022 annual Emission Inventory was submitted on April 13,
2023.

The 2023 annual Emission Invenmtory should be submitted by
April 15, 2024.

19
Tooele Army Depot’s 2022 Total Emission Inventory Summary:

Pollutants Total Tons /Year
PM10 53.75
PM2.5 5.65
SO2 1.09
NOx 40.19
VOC 3.40
CO 16.37

PREVIOUS ENFORCEMENT
ACTIONS: March 17, 2020 – ESA was signed and paid, for exceeding the
dioxin/furan limit on March 13-14, 2019. Results of retesting on
January 21-22, 2020, have been reviewed and deemed
acceptable.

May 2, 2022 – Warning Letter, for submitting annual emisison
fee late (C-577-22).

COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with the conditions of permit 4500006004, at time
of inspection.

HPV STATUS: N/A

COMPLIANCE
ASSISTANCE: 1) Discussed the late annual emisison fee. See status of condition
I.G.2.

2) Discussed the late annual compliance certification report.
See status of conditons I.L.1.

3) Discussed revising annual compliance certification report.
See status of condition I.L.1

4) Discussed the HWI’s future conversion from fuel oil to
natural gas.

RECOMMENDATIONS FOR
NEXT INSPECTION: Obtain a vehicle pass at building 100, before entering the TEAD.
Fridays are not considered to be a work days. Verify if HWI has
been converted to natural gas. Inspect as usual.

ATTACHMENT: VEO Form
Correspondence
2/5/24, 8:04 PM State of Utah Mail - Updated Annual Report
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1790100429852404499&simpl=msg-f:17901004298524044…1/1
Joe Rockwell <[e-mail]>
Updated Annual Report
2 messages
Brown, Lonnie D CIV USARMY JMC (USA) <[e-mail]>Mon, Feb 5, 2024 at 3:39 PM
To: "[e-mail]" <[e-mail]>
Please se the updated Annual Report
2024-0201 Update to 2023 Annual Report.pdf
253K
Joe Rockwell <[e-mail]>Mon, Feb 5, 2024 at 8:04 PM
To: "Brown, Lonnie D CIV USARMY JMC (USA)" <[e-mail]>
The report looks great.
Thanks Lonnie,
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
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