DAQ-2024-008271

DAQE-GN141870005-24

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Suzy Smith
Western Metals Recycling, LLC
4201 West 700 South
Salt Lake City, UT 84104
[e-mail]

Dear Ms. Smith:

RE: Replacement-in-Kind of Eddy Current Separators and Trommel at Western Metals Recycling's
Plymouth Location (Approval Order DAQE-AN141870004-23)
Project Number: N141870005

The Utah Division of Air Quality (UDAQ) has received your notification, dated March 29, 2024,
concerning the Replacement-in-Kind of the eddy current separators and trommel at the David J. Joseph
Company dba Western Metals Recycling, LLC’s Plymouth location. The UDAQ has determined that
these replacements meet the requirements outlined in R307-401-11. Because the proposed replacement
equipment is identical to the current equipment in Approval Order (AO)
DAQE-AN141870004-23, no updates are made to the AO.

The only charge for this project is the time spent by all UDAQ staff. If you have any questions, please
contact Dungan Adams, who can be reached at [phone] or [e-mail].

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DA:jg
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#s=Sig_es_:signer1:signature}}
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

May 30, 2024
REPLACEMENT IN KIND NOTIFICATION
To:
cc:
From:
Date:
RE:
Alan Humpherys, Utah Division of Air Quality
Jardee Steed, Western Metals Recycling
Brian Mensinger, Trinity Consultants
Chase Peterson, Trinity Consultants
Suzy Smith, Western Metals Recycling
March 29, 2024
Replacement-in-Kind Notification for Updated Eddy Current System and Replacement
Trommel
Western Metals Recycling’s Plymouth Location
Dear Alan,
The David J. Joseph Company dba Western Metals Recycling, LLC (WMR) owns and operates a metal
recycling plant located at 7400 West 21200 North Plymouth, Utah 84330 (Plymouth Location). The site is
located in Box Elder County, which is in attainment for all pollutants except particulate matter (PM) with an
aerodynamic diameter of 2.5 microns or less (PM2.5). The Plymouth Location currently operates under
approval order (AO) DAQE-AN141870004-23, issued March 22, 2023.
Per Utah Administrative Code (UAC) R307-401-11, Replacement-in-Kind Equipment, WMR is submitting this
letter as a written notification of its intent to replace the following, existing equipment with the proposed
equipment:
►Antiquated eddy current separators with modern eddy current separators, listed in Condition II.A.4 of its
AO.
►Worn trommel with updated trommel, listed in Condition II.A.3 of its AO.
Updated Eddy Current System
The Plymouth Location conducts metal shredding in addition to cutting, hand torching, and sorting of
ferrous and non-ferrous materials. The eddy current separators are used for metal recovery, separating
scrap materials by their primary component (aluminum, copper, stainless steel, tin, etc.). The sorted, non-
ferrous materials are deposited and stored in a covered environment, while the remaining metal containing
fluff continues to the finder separation system. Emissions associated with metal recovery and the eddy
current separators are comprised of fugitive PM10 and PM2.5.
The existing eddy current separators are over 20 years old; they are no longer supported by parts or
service. The proposed, new eddy current systems will have supported parts and service for future
maintenance. The new eddy current separators will serve the same purpose as the existing eddy current
separators and will have the same potential to emit (PTE) as the current units.
The new eddy current separators will operate at the same throughput as the existing eddy current
separators but will require less downtime. Thus, the change in equipment will not affect the Plymouth
Location’s annual throughput or its PTE. Therefore, WMR proposes to install the new eddy current
separators at the Plymouth Location under the Replacement-in-Kind requirements. In lieu of filing a notice of
intent (NOI) air permit application under R307-401-5, WMR is filing this notification, to address the conditions
of R307-401-11(2)(a).
WMR – Plymouth Location – Page 2
Replacement-in-Kind Notification
March 25, 2024

4525 Wasatch Blvd, Ste 200, Salt Lake City, UT 84124
P 801.272.3000 / F 801.272.3040
Trommel Replacement
The trommel at the Plymouth Location separates materials based on size. Larger items pass down the
trommel while smaller items are filtered out. Emissions associated with the trommel are comprised of PM10
and PM2.5.

The new trommel will serve the same purpose as the existing trommel. It will operate at the same
throughput as the trommel. The PTE will not change with this replacement. Therefore, WMR proposes to
install the new trommel at the Plymouth Location under the Replacement-in-Kind requirements. In lieu of
filing an NOI air permit application under R307-401-5, WMR is filing this notification to address the conditions
of R307-401-11(2)(a).
UAC R307-401-11(1) Requirements and Compliance
(a) t he potential to emit of the process equipment is the same or lower;
The replacement of the eddy current separators and trommel will not increase the Plymouth
Location’s PTE. It will remain the same as listed in its AO, as presented in Table 1.
Table-1. PTE Listed in the Plymouth Location’s AO, Given in Tons per Year
NOX PM10 PM2.5 CO SO2 VOC CO2e Total HAP
0.65 4.23 1.83 0.60 0.00 38.98 344.20 4.39
(b) the number of emission points or emitting units is the same or lower;
The three (3) proposed eddy current separators and one (1) trommel will replace the existing units;
the number of emissions points will remain the same.
(c) no additional types of air pollutants are emitted as a result of the replacement;
The existing and proposed units both emit fugitive PM10 and PM2.5 emissions as a part of the metal
separation operations. No other air pollutants are emitted as a result of the replacement.
(d) the process equipment or pollution control equipment is identical to or functionally
equivalent to the replaced equipment;
The proposed eddy current separators are functionally equivalent to the existing eddy current
separators that are being replaced; both serve to separate the scrap materials by their primary
component. The existing equipment is obsolete, can no longer be serviced, and no longer has
access to replacement parts, as they are no longer made. For these reasons, the new equipment is
necessary.

The proposed trommel is functionally equivalent to the existing trommel with which it is being
replaced; both serve to separate the scrap materials by size. The existing trommel is old and worn.
To maintain the integrity of the process, the new trommel is necessary.
(e) the replacement does not change the basic design parameters of the process unit or
pollution control equipment;
The proposed replacement of the existing eddy current separators and trommel does not change the
basic design parameters of the metal recovery process.
(f) the replaced process equipment or pollution control equipment is permanently removed
from the stationary source, otherwise permanently disabled, or permanently barred
from operation;
The existing eddy current separators and trommel to be replaced will be permanently disabled and
removed from service.
WMR – Plymouth Location – Page 3
Replacement-in-Kind Notification
March 25, 2024

4525 Wasatch Blvd, Ste 200, Salt Lake City, UT 84124
P 801.272.3000 / F 801.272.3040
(g) the replacement process equipment or pollution control equipment does not trigger New
Source Performance Standards or National Emissions Standards for Hazardous Air
Pollutants under 42 U.S.C. 7411 or 7412; and
The proposed replacement eddy current separators and trommel are not subject to New Source
Performance Standards (NSPS) or National Emission Standards for Hazardous Air Pollutants under
42 U.S.C. 7411 or 7412.
(h) the replacement of the control apparatus or process equipment does not violate any
other provision of Title R307.
The proposed replacement eddy current separators and trommel will meet the applicable provision
of Title R307 and the current AO.

If you have any questions or comments about the information presented in this letter, please contact me at
[e-mail].
4/3/24, 12:24 PM State of Utah Mail - Fwd: WMR - Plymouth - Replacement in Kind Letter
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1794900369053336222&simpl=msg-f:17949003690533362…1/2
Dungan Adams <[e-mail]>
Fwd: WMR - Plymouth - Replacement in Kind Letter
2 messages
Alan Humpherys <[e-mail]>Fri, Mar 29, 2024 at 4:12 PM
To: Dungan Adams <[e-mail]>
Dungan,
Can you please process this project?
Site ID: 14187
Peer: EQ
Thanks,
Alan
---------- Forwarded message ---------
From: Smith, Suzy (WMR) <[e-mail]>
Date: Fri, Mar 29, 2024 at 11:47 AM
Subject: WMR - Plymouth - Replacement in Kind Letter
To: Alan Humpherys <[e-mail]>
Cc: Chase Peterson <[e-mail]>, Brian Mensinger <[e-mail]>,
Steed, Jardee (WMR) <[e-mail]>
Alan,

Attached is a replacement-in-kind letter for Western Metals Recycling’s Plymouth location. This letter addresses updates
to the Eddy Current system and the trommel replacement.

Please let me know if you have any questions.

Thanks,
Suzy Smith, P.E.
(Licensed in UT, CO, TX)
Environmental Engineer

Western Metals Recycling | Texas Port Recycling
4201 W 700 S • Salt Lake City, UT 84104
Phone: [phone]
Cell: 801.386.4233
[e-mail]

4/3/24, 12:24 PM State of Utah Mail - Fwd: WMR - Plymouth - Replacement in Kind Letter
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1794900369053336222&simpl=msg-f:17949003690533362…2/2

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--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
2024.03.29 WMR Plymouth RIK.pdf
232K
Alan Humpherys <[e-mail]>Fri, Mar 29, 2024 at 4:13 PM
To: "Smith, Suzy (WMR)" <[e-mail]>
Cc: Chase Peterson <[e-mail]>, Brian Mensinger <[e-mail]>, "Steed,
Jardee (WMR)" <[e-mail]>, Dungan Adams <[e-mail]>
Suzy,
I appreciate you submitting this. I've assigned this to Dungan Adams for review and processing. If you have any questions
in the meantime, please let me or Dungan know.
Thanks,
Alan
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