DAQ-2024-008390

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DAQC-564-24
Site ID 10706 (B1)

MEMORANDUM

TO: FILE – DUGWAY PROVING GROUND

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Jeremiah Marsigli, Environmental Scientist

DATE: June 7, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Tooele County,
FRS ID# UT0000004904500003

INSPECTION DATE: May 21, 2024

SOURCE ADDRESS: Dugway Proving Ground, 35 miles south of I-80 Rowley Junction,
(Exit 77) Tooele County

SOURCE CONTACT(S): Boyd Roberts , Air Program Manager
[phone]

Kay Rose , Mellor Engineering
[phone]
[e-mail]

OPERATING STATUS: Building 5109 boiler fired up during this inspection. No other boilers
were operating. No emergency generators operating.

PROCESS DESCRIPTION: Dugway Proving Ground (DPG), a United States Army installation, is
responsible for testing chemical and biological defense systems for the
United States and its allies. The chemical and biological defense system
testing is conducted at several facilities including the Combined
Chemical Test Facility (CCTF), Bushnell Materiel Test Facility (MTF),
and Lothar Salomon Life Science Test Facility (LSTF). Smoke and
obscurant testing and open burn and open detonation (OB/OD) of
munitions, propellants, explosives, and pyrotechnics are conducted on
the open ranges and in the Dugway Thermal Treatment Facility (DTTF).
Equipment supporting these facilities and activities include boilers,
heaters, generators, fuel storage tanks, degreasers, and fuel and chemical
dispensing. A municipal landfill, sewage lagoons, housing, woodshop,
airfield, and photographic processes are also present at DPG.

APPLICABLE
REGULATIONS: Title V Operating Permit # 4500003005, issued January 12, 2022
DAQE-AN107060057-23

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SOURCE INSPECTION
EVALUATION:
Title V Operating Permit # 4500003005

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

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)

Status: This is not an inspection item.

I.B Permitted Activity(ies).

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)

Status: In compliance. The permittee appeared to be operating in compliance with this
permit. See status of each condition below for details.

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 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))

Status: In compliance. This permit is not being modified, revoked, reopened, reissued, or
terminated for cause at this time. A renewal permit is in process. The permittee appeared to
be operating in compliance with this permit.

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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 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))

Status: In compliance. This permit expires January 12, 2027.

I.E Application Shield.

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))

Status: This permit has not expired. Application for renewal is due by July 12, 2026.

I.F Severability.

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))

Status: There have been no challenges to any portion of this permit.

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 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))

Status: In compliance. Annual emission fees have been paid as invoiced.

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I.H No Property Rights.

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

Status: This is not an inspection item.

I.I Revision Exception.

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))

Status: This is 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 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))

Status: In compliance. Entry into permitted facilities was granted as requested during this
inspection. Records were provided on site. No samples were taken.

I.K Certification.

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)

Status: In compliance. All necessary forms and reports submitted during the prior 12-month
period appeared to be properly certified.
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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 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

Status: In compliance. The latest annual compliance certification was received October 3,
2022. This report was reviewed in DAQC-553-23 and found to meet the requirements of this
condition.

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:

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

Status: This is not an inspection item.

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))

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))
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I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: In compliance. No emergency events were reported or recorded during the 12-month
period prior to this inspection.

I.O Operational Flexibility.

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

Status: This is not an inspection item.

I.P Off-permit Changes.

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

Status: This is not an inspection item.

I.Q Administrative Permit Amendments.

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

Status: This is not an inspection item.

I.R Permit Modifications.

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

Status: This is not an inspection item.

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.

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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.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

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

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch (mail code 8ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance. Records are kept as required. Monitoring reports have been submitted
every six months. No deviations have been recorded or reported.

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 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))

Status: This is not an inspection item.

I.U Inventory Requirements.

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

Status: In compliance. Emission inventories have been submitted as required.

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I.V Title IV and Other, More Stringent Requirements

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))

Status: This is 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 ECG-0: LPG-Fired Boilers and Heaters
All liquefied petroleum gas (LPG)-fired boilers and heaters irrespective of installation date or size rating.
This group includes but is not limited to emission unit ECG-1.

II.A.3 CG: LPG-Fired Boilers, Heaters, and Stationary Generators
All LPG-fired boilers and heaters rated at greater than 5.0 MMBtu/hr and all LPG-fired generators. This
group includes but is not limited to emission units ECG-1 and ICP-0.

II.A.4 ECG-1: NSPS LPG-Fired Boilers and Heaters
Two boilers located at building 8027, each with a maximum rating of 10.5 MMBtu/hr, and two boilers
located at building 4156, each with a maximum rating of 10.5 MMBtu/hr. These units are subject to 40
CFR 60 Subpart Dc.

II.A.5 ECO-0: Oil-Fired Boilers and Heaters
All oil-fired boilers and heaters irrespective of installation date or size rating. This group includes 31 units
≥ 1 MMBtu/hr each with a combined rating of 85.19 MMBtu/hr and 37 units < 1 MMBtu/hr each. This
group includes but is not limited to emission unit ECO-2.

II.A.6 ECO-2: NESHAP Oil-Fired Boilers
All existing oil-fired boilers that commenced construction or reconstruction on or before June 4, 2010. All
new oil-fired boilers that commenced construction or reconstruction after June 4, 2010. Twenty oil-fired
boilers are subject to 40 CFR 63 Subpart JJJJJJ. All affected emission units have a heat input capacity less
than 10 MMBtu/hr.

II.A.7 ICO-0: Stationary Diesel-Fired Generators
All emergency and non-emergency diesel-fired generators. Unit includes: 22 emergency engines rated at
≥ 600 hp each with a combined rating of 38,641 hp (28,816 kWm, 23,632 kWe), 43 emergency engines
rated at < 600 hp each with a combined rating of 8,379 hp (6,283 kWm, 4,856 kWe). Unit includes three
non-emergency engines: one rated at 201 hp (150 kWm, 100 kWe) at the Police Firing Range, and two
rated at 680 hp (507 kWm, 400 kWe) each at building 4165.

II.A.8 ICP-0: Stationary LPG-Fired Generators
All emergency LPG-fired generators. Unit includes three engines rated at < 600 hp each with a combined
rating of 471 hp (351 kWm, 265 kWe).

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II.A.9 ICE-0: Stationary Emergency Generators
All emergency generators.

II.A.10 NSPS-ICE: NSPS Stationary Compression Ignition ICE
Stationary compression ignition (CI) internal combustion engines (ICE) that are ordered after July 11,
2005, manufactured after April 1, 2006, and are not fire pump engines. Stationary CI ICE that are
modified, or reconstructed after July 11, 2005 are also included in this unit. These units are subject to 40
CFR 60 Subpart IIII and are located source-wide. All affected emission units have a displacement of less
than 10 liters per cylinder.

II.A.11 OT: Outdoor Testing and Training
Outdoor test materials and training operations such as smoke and obscurants, materiel and delivery
systems, munitions and incendiary devices.

II.A.12 OBOD-0: Open Burn/Open Detonation (Source Wide)
Open burning (OB) and open detonation (OD) of residual munitions and propellants, explosives, and
pyrotechnics (PEP) are conducted in the Dugway Thermal Treatment Facility (DTTF) and on the open
ranges.

II.A.13 OBOD-1: Open Burn at the DTTF
OB at the DTTF destroys solid propellant, propellant charges, and bulk explosives.

II.A.14 OBOD-2: Open Detonation at the DTTF
OD at the DTTF destroys conventional range recovered munitions, residual explosive material housed in
munitions, hung ordnance, solid propellants and obscurant when the explosive and non-explosive
components cannot be safely separated.

II.A.15 OBOD-3: Open Detonation on Open Range
Due to safety concerns, some munitions must be destroyed in place. In these emergency situations,
explosives ordnance experts use Department of Defense approved procedures best suited to the specific
circumstances.

II.A.16 TNK-1: Underground Storage Tanks
Four 20,000 gallon underground Fuel Oil No. 2 storage tanks. Three tanks are located at the Baker facility
and one tank is located at the Ditto facility.
Three underground gasoline storage tanks. One 10,000-gallon tank is located at the AAFES gas station,
one 20,000-gallon tank is located at the English Village Motor Pool and one 20,000-gallon tank is located
at the Ditto Motor Pool.

II.A.17 TNK-2: Aboveground Storage Tanks
Two 24,000 gallon aboveground JP-4 storage tanks located at the Michael Army Airfield. No unit-
specific applicable requirements.

II.A.18 NESHAP-CI RICE: NESHAP Stationary CI RICE
Existing emergency stationary compression ignition (CI) reciprocating internal combustion engines
(RICE) that are constructed or reconstructed before June 12, 2006. These units are subject to 40 CFR 63
Subpart ZZZZ and are located source-wide.

II.A.19 NESHAP-SI RICE: NESHAP Stationary SI RICE
Existing emergency stationary spark ignition (SI) reciprocating internal combustion engines (RICE) that
are constructed or reconstructed before June 12, 2006. These units are subject to 40 CFR 63 Subpart
ZZZZ and are located source-wide.
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II.A.20 MSWL: Municipal Solid Waste Landfill
The municipal solid waste landfill is located west of Fries Park. The landfill design capacity is less than
2.5 million megagrams.

Status: In compliance. No unapproved equipment was observed. Some of the equipment listed has
been removed. DAQE-AN107060057-23 updates this equipment list.

II.B Requirements and Limitations

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

II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

The permittee shall only use diesel and fuel oil that contain less than 15 ppm sulfur. [Origin: DAQE-
AN107060055-20]. [R307-203-1(1), R307-401-8]

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

To demonstrate compliance with the diesel fuel and fuel oil requirements for any diesel fuel and
fuel oil purchased, the permittee shall keep and maintain fuel purchase invoices. The permittee
shall obtain certification of sulfur content from the fuel supplier or fuel purchase invoices
indicating that the diesel fuel and fuel oil purchased meet the sulfur content requirement. Records
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

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

Status: In compliance. Purchase contracts require 15 ppm or less sulfur content. Dugway uses a bill
of lading to confirm sulfur content and reviews every 6 months. Certifications reviewed during this
inspection showed #2 ULS diesel was received from TSO Logistics.

II.B.1.b Condition:

Emissions from sources of fugitive dust shall be minimized. Any person who deposits materials that may
create fugitive dust on a public or private paved road shall clean the road promptly. [Origin: R307-205,
DAQE-AN107060055-20]. [R307-205-5, R307-205-6(2), R307-401-8]

II.B.1.b.1 Monitoring:

The permittee shall develop and implement a fugitive dust control plan, approved by the Director,
that minimizes fugitive dust. The permittee shall perform monitoring as described in the fugitive
dust control plan.

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II.B.1.b.2 Recordkeeping:

Records required by the most recently approved fugitive dust control plan shall be maintained in
accordance with the plan. Records demonstrating compliance with this condition shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.1.b.3 Reporting:

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

Status: In compliance. A fugitive dust control plan is in place. No excessive fugitive dust was
observed during this inspection. Dust control measures are tracked and recorded for each project.
These records were made available during this inspection.

II.B.1.c Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction.
[Origin: 40 CFR 82 Subpart F]. [40 CFR 82.150(b)]

II.B.1.c.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.c.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.c.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance. The permittee has certified compliance with this condition in the latest
annual compliance certification.

II.B.1.d Condition:

The permittee shall comply with the applicable requirements for labeling of products using ozone
depleting substance pursuant to 40 CFR 82, Subpart E - Labeling of Products Using Ozone-Depleting
Substances. [Origin: 40 CFR 82 Subpart E]. [40 CFR 82.102]

II.B.1.d.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart E.

14
II.B.1.d.2 Recordkeeping:

All records required in 40 CFR 82, Subpart E shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.d.3 Reporting:

All reports required in 40 CFR 82, Subpart E shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance. The permittee has certified compliance with this condition in the latest
annual compliance certification.

II.B.1.e Condition:

1. The permittee shall not sell supply or offer for sale any adhesive, sealant, adhesive primer or sealant
primer with a VOC content in excess of the limits in Table 1 of R307-342-5 and that was
manufactured on or after September 1, 2014.

2. The permittee shall not apply any adhesive, sealant, adhesive primer or sealant primer with a VOC
content in excess of the limits specified in Table 1 of R307-342-5 unless an add-on control device as
specified in R307-342-8 is used or unless the adhesive, sealant, adhesive primer or sealant primer was
manufactured before September 1, 2014.

3. The VOC content limits in Table 1 of R307-342-5 for adhesives applied to particular substrates shall
apply as follows:
a. If the permittee uses an adhesive or sealant subject to a specific VOC content limit for such
adhesive or sealant in Table 1 of R307-342-5, such specific limit is applicable rather than an
adhesive-to-substrate limit; and
b. If an adhesive is used to bond dissimilar substrates together, the applicable substrate category with
the highest VOC content shall be the limit for such use.
4. The permittee shall only use the following equipment to apply adhesives and sealants:
a. Electrostatic application;
b. Flow coater;
c. Roll coater;
d. Dip coater;
e. Hand application method;
f. Airless spray and air-assisted airless spray;
g. High volume, low pressure spray equipment operated in accordance with the manufacturer's
specifications; or
h. Other methods having a minimum 65% transfer efficiency.
5. Removal of an adhesive, sealant, adhesive primer or sealant primer from the parts of spray application
equipment shall be performed as follows:
a. In an enclosed cleaning system;
b. Using a solvent (excluding water and solvents exempt from the definition of volatile organic
compounds found in R307-101-2) with a VOC content less than or equal to 70 grams of VOC per
liter of material; or
c. Parts containing dried adhesive may be soaked in a solvent if the composite vapor pressure of the
solvent, excluding water and exempt compounds, is less than or equal to 9.5 mm Hg at 20 degrees
Celsius and the parts and solvent are in a closed container that remains closed except when adding
parts to or removing parts from the container.
15
d. Except as provided in 5.a. through 5.c., the permittee shall not use materials containing VOCs for
the removal of adhesives, sealants, or adhesive or sealant primers from surfaces, other than spray
application equipment, unless the composite vapor pressure of the solvent used is less than 45 mm
Hg at 20 degrees Celsius. (R307-342-7)
6. These requirements do not apply if exempted in accordance with R307-342-3.
[Origin: R307-342]. [R307-342]

II.B.1.e.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.e.2 Recordkeeping:

(a) For operations that are not exempt under R307-342-3, the permittee shall maintain records
demonstrating compliance, including:
i. A list of each adhesive, sealant, adhesive primer, sealant primer cleanup solvent and
surface preparation solvent in use and in storage;
ii. A material data sheet for each adhesive, sealant, adhesive primer, sealant primer, cleanup
solvent and surface preparation solvent;
iii. A list of catalysts, reducers or other components used and the mix ratio;
iv. The VOC content or vapor pressure, as applied; and
v. The monthly volume of each adhesive, sealant, adhesive primer, sealant primer cleanup
solvent and surface preparation solvent used.
(b) If an exemption is claimed pursuant to R307-342-3 the permittee shall record and maintain
operational records sufficient to demonstrate compliance. (R307-342-3(7))

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

II.B.1.e.3 Reporting:

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

Status: In compliance. No listed products are sold or offered to sell. Usage is tracked and VOC
calculations are kept. The permittee has a form that is filled out monthly by an EHS specialist to
help ensure compliant materials are used and applied properly. Records indicated 24.37 tons of
VOC emissions during the 12-month period ending April 30, 2024.

II.B.1.f Condition:

1. Except as provided in R307-361-4, the permittee shall not supply, solicit for application, or apply
within the counties in R307-361-2 any architectural coating with a VOC content in excess of the
corresponding limit specified in Table 1 of R307-361-5.
2. If a coating is recommended for use in more than one of the specialty coating categories listed in
Table 1 of R307-361-5, the most restrictive (lowest) VOC content limit shall apply. This requirement
applies to usage recommendations that appear anywhere on the coating container, anywhere on any
label or sticker affixed to the container, or in any sales, advertising, or technical literature supplied by
a manufacturer or anyone acting on their behalf. This requirement does not apply to coating categories
listed in R307-361-5(2)(b).
3. Sell-through of coatings. A coating manufactured before January 1, 2015, may be applied at any time.
R307-361-5(3) does not apply to any coating that does not display the date or date code required by
R307-361-6(1)(a).
16
4. Painting practices. All architectural coating containers used when applying the contents therein to a
surface directly from the container by pouring, siphoning, brushing, rolling, padding, ragging or other
means, shall be closed when not in use. These architectural coating containers include, but are not
limited to, drums, buckets, cans, pails, trays or other application containers. Containers of any VOC-
containing materials used for thinning and cleanup shall also be closed when not in use.
5. Thinning. The permittee shall not apply or solicit the application of any architectural coating that is
thinned to exceed the applicable VOC limit specified in Table 1 of R307-361-5.
6. Rust preventative coatings. The permittee shall not apply or solicit the application of any rust
preventative coating manufactured before January 1, 2015 for industrial use, unless such a rust
preventative coating complies with the industrial maintenance coating VOC limit specified in Table 1
of R307-361-5.
7. Coatings not listed in Table 1 of R307-361-5. For any coating that does not meet any of the
definitions for the specialty coatings categories listed in Table 1 of R307-361-5, the VOC content
limit shall be determined by classifying the coating as a flat, non-flat, or non-flat/high gloss coating,
based on its gloss, as defined in R307-361-3 and the corresponding flat, non-flat, or non-flat/high
gloss coating VOC limit in Table 1 of R307-361-5 shall apply.
8. The coatings described in R307-361-4 are exempt from the requirements of R307-361.
[Origin: R307-361]. [R307-361]

II.B.1.f.1 Monitoring:

The permittee shall use the following test methods.
(a) Determination of VOC content.
(i) For the purpose of determining compliance with the VOC content limits in Table 1, the
VOC content of a coating shall be calculated by following the appropriate formula
found in the definitions of VOC actual, VOC content, and VOC regulatory found in
R307-361-3.
(ii) The VOC content of a tint base shall be determined without colorant that is added after
the tint base is manufactured.
(iii) If the manufacturer does not recommend thinning, the VOC content shall be calculated
for the product as supplied.
(iv) If the manufacturer recommends thinning, the VOC content shall be calculated
including the maximum amount of thinning solvent recommended by the manufacturer.
(v) If the coating is a multi-component product, the VOC content shall be calculated as
mixed or catalyzed.
(vi) The coating contains silanes, siloxanes, or other ingredients that generate ethanol or
other VOC during the curing process, the VOC content shall include the VOCs emitted
during curing.

II.B.1.f.2 Recordkeeping:

Records demonstrating compliance with this condition shall be maintained in accordance with
Provision I.S.1 of this permit.

17
II.B.1.f.3 Reporting:

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

Status: In compliance. No listed products are sold or offered to sell. No exemptions are being used
at this time. Usage is tracked and VOC calculations are kept. The permittee has a form that is filled
out monthly by an EHS specialist to help ensure compliant materials are used and applied
properly. Records indicated 24.37 tons of VOC emissions during the 12-month period ending April
30, 2024.

II.B.1.g Condition:

(1) For any stationary storage container or service station that dispenses 10,000 gallons or more in any
one calendar month, the permittee shall not transfer or permit the transfer of gasoline from any
gasoline cargo tank into any stationary storage container with a capacity of 250 gallons or greater
unless such container is equipped with a submerged fill pipe that extends to no more than twelve
inches from the bottom of the storage tank for fill pipes installed on or before November 9, 2006, and
at least 90 percent of the gasoline vapor, by weight, displaced during the filling of the stationary
storage container is prevented from being released to the atmosphere. This requirement shall not
apply to:
(a) the transfer of gasoline into any stationary storage container of less than 550 gallons used
primarily for the fueling of implements of husbandry if such container is equipped with a
permanent submerged fill pipe;
(b) the transfer of gasoline into any stationary storage container having a capacity of less than 2,000
gallons which was installed prior to January 1, 1979, if such container is equipped with a
permanent submerged fill pipe;
(c) the transfer of gasoline to storage tanks equipped with floating roofs or their equivalent that
have been approved by the Director.
(2) The 90 percent performance standard of the vapor control system shall be based on operating
procedures and equipment specifications. The design effectiveness of such equipment and the
operating procedure must be documented and submitted to and approved by the Director.
(3) Each gasoline storage tank or gasoline cargo tank subject to paragraph (1), shall be equipped with
vapor control equipment, which includes, but is not limited to:
(a) vapor return lines and connections sufficiently free of restrictions to allow transfer of vapor to
the gasoline cargo tank or to the vapor control system, and to achieve the required recovery;
(b) a means of assuring that the vapor return lines are connected to the gasoline cargo tank, or vapor
control system, and storage tank during tank filling;
(c) restrictions in the storage tank vent line designed and operated to prevent:
(i) the release of gasoline vapors to the atmosphere during normal operation; and
(ii) gauge pressure in the gasoline cargo tank from exceeding 18 inches of water and vacuum
from exceeding 6 inches of water.
[Origin: R307-328-5]. [R307-328-5]

II.B.1.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.g.2 Recordkeeping:

Records documenting compliance with the design requirements for each affected unit shall be
maintained in accordance with Provision I.S.1 of this permit.
18
II.B.1.g.3 Reporting:

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

Status: In compliance. Throughput of the three applicable tanks is tracked. The permittee
maintains monthly report forms which lists the requirements of this condition and is certified by
personnel responsible for these tanks. Pressure certifications are on file for each underground
storage tank. Cargo tank certifications are verified by tank managers.

II.B.1.h Condition:

(1) The permittee shall only use gasoline cargo tanks designed and maintained to be vapor tight during
loading and unloading operations as well as during transport, except for normal pressure venting
required under United States Department of Transportation Regulations.
(2) The design of the vapor recovery system shall be such that when the gasoline cargo tank is connected
to an approved storage tank vapor recovery system or loading terminal, 90% vapor recovery
efficiencies are realized. The connectors of the gasoline cargo tanks shall be compatible with the
fittings on the fill pipes and vapor vents at the storage containers and gasoline loading terminals
where the gasoline cargo tank will service or be serviced. Adaptors may be used to achieve
compatibility.
(3) The permittee shall not knowingly allow the introduction of gasoline into, dispensing of gasoline
from, or transportation of gasoline in a gasoline cargo tank that does not meet the leak tight testing
requirements of 40 CFR 63.425(e).
(4) A vapor-laden gasoline cargo tank may be refilled only at installations equipped to recover, process
or dispose of vapors. Gasoline cargo tanks that only service locations with storage containers
specifically exempted from the requirements of R307-328-5 need not be retrofitted to comply with
the requirements of R307-328-6(1)-(3), provided such gasoline cargo tanks are loaded through a
submerged fill pipe or approved equivalent equipment. The design and effectiveness of all equivalent
equipment shall be documented and submitted to and approved by the Director.
[Origin: R307-328-6]. [R307-328-6]

II.B.1.h.1 Monitoring:

Annually, based on the date of the most recent test, all gasoline cargo tanks and their vapor
collection systems shall be tested for leakage in accordance with the test methods and vapor
tightness standards in 40 CFR 63.425(e). (origin: R307-328-7).

II.B.1.h.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit. Additionally,
records shall be kept as required in (a) and (b) below.
(a) The permittee or operator of a gasoline cargo tank shall have documentation in their
possession demonstrating that the gasoline cargo tank has passed the annual test in R307-
328-7(1) within the preceding twelve months.
(b) Vapor tightness documentation, as well as record of any maintenance performed, shall be
retained by the permittee or operator of the gasoline cargo tank for a five year period and be
available for review by the Director or the Director's representative.
(origin: R307-328-7).

19
II.B.1.h.3 Reporting:

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

Status: In compliance. Gasoline service station monthly reports confirm compliance with this
condition. Cargo tank certifications are verified by tank managers. Dugway does not own any
gasoline tanker trucks.

II.B.1.i Condition:

The permittee shall not allow gasoline to be handled in a manner that would result in vapor releases to the
atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the
following:

(1) Minimize gasoline spills;
(2) Clean up spills as expeditiously as practicable;
(3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when
not in use;
(4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oil/water separators.

At all times, the permittee shall operate and maintain any affected emission unit, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. Determination of whether such operation 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, review of operation and maintenance procedures, review
of operation and maintenance records, and inspection of the source.

The permittee shall only load gasoline into storage tanks by utilizing submerged filling, as defined in 40
CFR 63.11132. Submerged fill pipes installed on or before November 9, 2006, shall be no more than 12
inches from the bottom of the tank. The distance shall be measured from the point in the opening of the
submerged fill pipe that is the greatest distance from the bottom of the storage tank.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 3 of 40 CFR 63 Subpart CCCCCC.

[Origin: 40 CFR 63 Subpart CCCCCC]. [40 CFR 63.11111(c), 40 CFR 63.11115, 40 CFR 63.11116(a),
40 CFR 63.11117, 40 CFR 63.11130]

II.B.1.i.1 Monitoring:

Records required for this permit condition will serve as monitoring. Additionally, the permittee
shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 3 of
40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130].

II.B.1.i.2 Recordkeeping:

The permittee shall keep records demonstrating monthly throughput is less than the 100,000-
gallon threshold level. Records shall be available within 24 hours of a request by the Director to
document gasoline throughput in the affected emission unit. [40 CFR 63.11111(e), 40 CFR
63.11117(d)]
20
The permittee shall keep records of the occurrence and duration of each malfunction of operation
(i.e., process equipment) or the air pollution control and monitoring equipment. Records shall be
kept of actions taken during periods of malfunction to minimize emissions in accordance with 40
CFR 63.11115(a), including corrective actions to restore malfunctioning process and air pollution
control and monitoring equipment to its normal or usual manner of operation. [40 CFR
63.11115(b), 40 CFR 63.11125(d)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130]

Documentation shall be kept that demonstrates compliance with this provision. Records shall be
maintained in accordance with Provision I.S.1. of this permit.

II.B.1.i.3 Reporting:

The permittee shall submit the applicable notifications as required under 40 CFR 63.11124(a).
[40 CFR 63.11117(e)]

The permittee shall submit reports as specified in 40 CFR 63.11126(b). [40 CFR 63.11115(b)]

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

Status: On January 31, 2012, Dugway submitted notification that submerged filling meets the
standard for GDFs. A service order form was attached. Gasoline service station monthly reports
confirm compliance with items 1-4 of this condition. Records of monthly throughput are
maintained to confirm compliance with the 100,000 gallon threshold. 40 CFR 63.11126(b) states
an annual report is not due if no malfunctions occurred for the calendar year. No report was
submitted by March 15, 2021 or 2022. In compliance.

Status: In compliance. Gasoline service station monthly reports confirm compliance with this
condition. No gasoline spills were recorded during the 12-month period preceding this inspection.
Storage tanks were certified for vapor tightness and installation of submerged filling equipment in
a 2012 Notification of Compliance Status.

II.B.1.j Condition:

The permittee shall comply with the applicable requirements for servicing of motor vehicle air
conditioners pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle Air Conditioners. [Origin:
40 CFR 82 Subpart B]. [40 CFR 82.30(b)]

II.B.1.j.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart B.

II.B.1.j.2 Recordkeeping:

All records required in 40 CFR 82, Subpart B shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

21
II.B.1.j.3 Reporting:

All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are no
additional reporting requirements except as specified in Section I of this permit.

Status: In compliance. The permittee has certified compliance with this condition in the latest
annual compliance certification.

II.B.1.k Condition:

The permittee shall mitigate the impacts on air quality and visibility from prescribed fire.
i. Management of On-Going Fires. If, after consultation with the land manager, the Director determines
that a prescribed fire, wildfire, or any smoke transported from other locations, is degrading air quality
to levels that could violate the National Ambient Air Quality Standards or burn plan conditions, the
land manager shall promptly stop igniting additional prescribed fires.
ii. A prescribed fire that covers less than 20 acres per burn or less than 30,000 cubic feet of piled
material shall only be ignited either
a) when the clearing index is 500 or greater, or
b) when the clearing index is between 400 and 499, if;
i) The prescribed fire is recorded as a de minimis prescribed fire on the annual burn schedule;
and
ii) The land manager obtains approval from the Director by e-mail or phone prior to ignition of
the burn.
iii. Land managers shall not conduct prescribed burning or pile burning when the clearing index is below
500 until the Director approves the application required in R307-240-4(1).
[Origin: R307-204, R307-240]. [R307-204-4, R307-204-6, R307-240-4]

II.B.1.k.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.k.2 Recordkeeping:

For a prescribed fire that covers less than 20 acres per burn or less than 30,000 cubic feet of piled
material that is ignited when the clearing index is between 400 and 499, the permittee shall keep
records that include the following: hourly photographs, any complaints, hourly meteorological
conditions, an hourly description of the smoke plume, and Director approvals.

Records of Director approvals and records demonstrating compliance with this condition shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.1.k.3 Reporting:

The land manager shall notify the Division of all wildfires, including nonfull suppression events.
a) Non-burning Alternatives to Fire. Each land manager shall submit to the director annually, by
March 15, a list of areas treated using non-burning alternatives to fire during the previous
calendar year, including the number of acres, the specific types of alternatives used, and the
location of these areas.
b) Long-term Fire Projections. Each land manager shall provide to the Director annually, by
March 15, long-term projections of future prescribed fire activity for annual assessment of
visibility impairment.
22
c) For a prescribed fire that covers less than 20 acres per burn or less than 30,000 cubic feet of
piled material that is ignited when the clearing index is between 400 and 499, the land
manager shall submit to the Director hourly photographs, a record of any complaints, hourly
meteorological conditions and an hourly description of the smoke plume.
d) Land managers who request a burn permit when the clearing index is below 500 shall submit
to the Director an application that demonstrates that the conditions in Subsections 19-2a-
105(3) through 19-2a-105(5) are met. (R307-240-4)

To ensure proper credit when notifying the Director, send the documentation to the Director,
attn.: Smoke Coordinator. There are no additional reporting requirements for this provision
except those specified in Section I of this permit.

Status: In compliance. There were no prescribed fires during calendar year 2023, and a few in
2024-to-date. The permittee attempts to cut down on incidents of prescribed fires through
alternative measures, such as using heavy equipment to clear areas and removing tumble weed
buildup on fence lines.

II.B.1.l Condition:

The permittee shall not operate a degreasing or solvent cleaning operation unless the following conditions
are met.
(1) A cover shall be installed which shall remain closed except during actual loading, unloading or
handling of parts in cleaner. The cover shall be designed so that it can be easily operated with one
hand if:
(a) The volatility of the solvent is greater than 2 kPa (15 mm Hg or 0.3 psi) measured at 38 degrees
C (100 degrees F),
(b) The solvent is agitated, or
(c) The solvent is heated.
(2) An internal draining rack for cleaned parts shall be installed on which parts shall be drained until all
dripping ceases. If the volatility of the solvent is greater than 4.3 kPa (32 mm Hg at 38 degrees C
(100 degrees F)), the drainage facility must be internal, so that parts are enclosed under the cover
while draining. The drainage facility may be external for applications where an internal type cannot
fit into the cleaning system.
(3) Waste or used solvent shall be stored in covered containers.
(4) Tanks, containers and all associated equipment shall be maintained in good operating condition, and
leaks shall be repaired immediately or the degreaser shall be shutdown.
(5) Written procedures for the operation and maintenance of the degreasing or solvent cleaning
equipment shall be permanently posted in an accessible and conspicuous location near the
equipment.
(6) If the solvent volatility is greater than 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38 degrees C (100
degrees F), or if solvent is heated above 50 degrees C (120 degrees F), then one of the following
control devices shall be used:
(a) Freeboard that gives a freeboard ratio greater than 0.7;
(b) Water cover if the solvent is insoluble in and heavier than water); or
(c) Other systems of equivalent control, such as a refrigerated chiller or carbon adsorption.
(7) If used, the solvent spray shall be a solid fluid stream at a pressure that does not cause excessive
splashing and may not be a fine, atomized or shower type spray.
[Origin: R307-335]. [R307-335-4]

23
II.B.1.l.1 Monitoring:

A visual inspection shall be made at least once each quarter to demonstrate compliance with this
condition. Records required for this permit condition will also serve as monitoring.

II.B.1.l.2 Recordkeeping:

Documentation of the visual inspections and records demonstrating compliance with this
condition shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.l.3 Reporting:

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

Status: In compliance. Only non-VOC containing solution is used (Safety Kleen Premium). A
quarterly inspection form is maintained to demonstrate compliance.

II.B.1.m Condition:

(1) For all solvent cleaning operations, the permittee shall not use solvent products with a VOC content
greater than the amounts specified in Table 1 of R307-304-5, unless either an add-on control device
as specified in R307-304-7 is used or the alternative method in paragraph (2) is used.
(2) As an alternative to the limits in Table 1 and for all general miscellaneous cleaning operations, the
permittee may use a cleaning material with a VOC composite vapor pressure no greater than 8 mm
Hg at 20 degrees Celsius.
(3) The permittee shall store used applicators and shop towels in closed fireproof containers.
These requirements do not apply to the exemptions listed in R307-304-3.
[Origin: R307-304]. [R307-304]

II.B.1.m.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.m.2 Recordkeeping:

The permittee shall maintain records demonstrating compliance with this condition. Records shall
include the VOC content or composite vapor pressure of the solvent product applied. If an add-on
control device is used, records shall also be kept of key system parameters necessary to ensure
compliance with R307-304-7 as specified in R307-304-8. Records shall be maintained in
accordance with Provision I.S.1 of this permit and shall be available to the director upon request.

II.B.1.m.3 Reporting:

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

9Status: In compliance. Only non-VOC containing solution is used (Safety Kleen Premium).

24
II.B.2 Conditions on ECG-0: LPG-Fired Boilers and Heaters.

II.B.2.a Condition:

Visible emissions shall be no greater than 20 percent opacity for affected emission units constructed after
April 25, 1971. [Origin: DAQE-AN107060055-20, R307-201]. [R307-201-3(2)]

II.B.2.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.a.2 Recordkeeping:

In lieu of monitoring via visible emission observations, the permittee shall keep one of the
following sets of records for each affected emission unit, as applicable:
(a) Documentation that the emission unit can only burn natural gas and/or liquefied petroleum
gas;
(b) Documentation that the fuels other than natural gas and/or liquefied petroleum gas cannot be
supplied to the emission unit without modification of the fuel supply system; or
(c) Fuel bills or fuel meter readings that demonstrate only natural gas and/or liquefied petroleum
gas are combusted in the emission unit.

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each affected emission unit the log shall include the type of records that will be
used in lieu of monitoring via visible emission observations. If fuel bills or fuel meter readings
will be used in lieu of monitoring via visible emission observations, the permittee shall review
fuel bills or fuel meter readings once per quarter and record in the log the types of fuel
combusted. The records and log required by this condition shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.2.a.3 Reporting:

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

Status: In compliance. Only propane is burned in these units. Dugway complies with item c above
by tracking fuel usage monthly.

II.B.2.b Condition:

Visible emissions shall be no greater than 40 percent opacity for affected emission units constructed on or
before April 25, 1971. [Origin: DAQE-AN107060055-20, R307-201]. [R307-201-3(1)]

II.B.2.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.b.2 Recordkeeping:

In lieu of monitoring via visible emission observations, the permittee shall keep one of the
following sets of records for each affected emission unit, as applicable:
25
(a) Documentation that the emission unit can only burn natural gas and/or liquefied petroleum
gas;
(b) Documentation that the fuels other than natural gas and/or liquefied petroleum gas cannot be
supplied to the emission unit without modification of the fuel supply system; or
(c) Fuel bills or fuel meter readings that demonstrate only natural gas and/or liquefied petroleum
gas are combusted in the emission unit.

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each affected emission unit the log shall include the type of records that will be
used in lieu of monitoring via visible emission observations. If fuel bills or fuel meter readings
will be used in lieu of monitoring via visible emission observations, the permittee shall review
fuel bills or fuel meter readings once per quarter and record in the log the types of fuel
combusted. The records and log required by this condition shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.2.b.3 Reporting:

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

Status: In compliance. Only propane is burned in these units. Dugway complies with item c above
by tracking fuel usage monthly.

II.B.3 Conditions on CG: Conditions on LPG-Fired Boilers, Heaters, and Stationary Generators

II.B.3.a Condition:

LPG consumption shall not exceed 1,750,000 gallons per rolling 12-month period. [Origin: DAQE-
AN107060055-20]. [R307-401-8]

II.B.3.a.1 Monitoring:

By the 15th day of each month, the permittee shall calculate the total volume of fuel consumed in
the previous 12 months. Fuel consumption for each affected emission unit shall be determined by
a fuel meter, fuel bills, or trip tickets.

II.B.3.a.2 Recordkeeping:

Records of fuel consumption shall be kept on a monthly basis for each affected emission unit.
Results of monitoring shall be maintained as described in Provision I.S.1 of this permit.

II.B.3.a.3 Reporting:

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

Status: In compliance. Records are kept and were made available. The 12-month rolling total of
LPG consumption through April 30, 2024 was 719,129 gallons.

26
II.B.4 Conditions on ECG-1: NSPS LPG-Fired Boilers and Heaters.

II.B.4.a Condition:

The permittee shall keep monthly records of the amount of fuel combusted each month for each affected
emission unit. [Origin: Alternative Monitoring EPA Approval 11/20/03]. [40 CFR 60.13(i), 40 CFR
60.48c(g)]

II.B.4.a.1 Monitoring:

Fuel consumption for the affected emission units shall be determined by a common line fuel
meter, fuel bills, or tank system gauge. Fuel consumption shall be prorated between the affected
emission units based upon the respective design heat input rates.

II.B.4.a.2 Recordkeeping:

Records of the amounts of fuel combusted during each month for each affected unit shall be
maintained as described in provision I.S.1 of this permit.

II.B.4.a.3 Reporting:

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

Status: In compliance. Consumption is tracked and recorded on a monthly tracking sheet.

II.B.4.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. [Origin: DAQE-AN107060055-20]. [40 CFR 60.11(d), R307-401-8]

II.B.4.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.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.

27
II.B.4.b.3 Reporting:

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

Status: In compliance. Dugway has a preventative maintenance plan in place. Base operations
contractor Chenega performs maintenance and keeps records in maintenance logs which are kept
at each boiler and heater. Spot review of the logs showed run times and maintenance performed.

II.B.5 Conditions on ECO-0: Oil-Fired Boilers and Heaters.

II.B.5.a Condition:

Visible emissions shall be no greater than 20 percent opacity for affected emission units constructed after
April 25, 1971. [Origin: DAQE-AN107060055-20, R307-201]. [R307-201-3(2)]

II.B.5.a.1 Monitoring:

If an affected emission unit is operated during a semi-annual period, an opacity observation of the
emission unit shall be performed in the semi-annual period that the emission unit was operated.
The opacity observation can be conducted at any time during the semi-annual period. The opacity
observation shall be conducted by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9, while the emission unit is operating. If visible emissions other than
condensed water vapor are observed from the emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial visual
emission observation. The opacity determination shall be performed in accordance with 40 CFR
60, Appendix A, Method 9.

II.B.5.a.2 Recordkeeping:

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each semi-annual period for each affected emission unit, the log shall include
either the date of the opacity observation and if visual emissions other than condensed water
vapor were observed or a note that the emission unit was not operated. For each observed visual
emission other than condensed water vapor the permittee shall record: date and time of visual
emission observation, emission unit location and description, time and date of opacity
determination, and percent opacity. The records required by this provision and all data required
by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.5.a.3 Reporting:

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

Status: In compliance. Semi-annual opacity observations have been performed and recorded by
Method 9 certified individuals. No excess emissions were noted during review of records.

II.B.5.b Condition:

Visible emissions shall be no greater than 40 percent opacity for affected emission units constructed on or
before April 25, 1971. [Origin: DAQE-AN107060055-20, R307-201]. [R307-201-3(1)]
28
II.B.5.b.1 Monitoring:

If an affected emission unit is operated during a semi-annual period, an opacity observation of the
emission unit shall be performed in the semi-annual period that the emission unit was operated.
The opacity observation can be conducted at any time during the semi-annual period. The opacity
observation shall be conducted by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9, while the emission unit is operating. If visible emissions other than
condensed water vapor are observed from the emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial visual
emission observation. The opacity determination shall be performed in accordance with 40 CFR
60, Appendix A, Method 9.

II.B.5.b.2 Recordkeeping:

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each semi-annual period for each affected emission unit, the log shall include
either the date of the opacity observation and if visual emissions other than condensed water
vapor were observed or a note that the emission unit was not operated. For each observed visual
emission other than condensed water vapor the permittee shall record: date and time of visual
emission observation, emission unit location and description, time and date of opacity
determination, and percent opacity. The records required by this provision and all data required
by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.5.b.3 Reporting:

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

Status: In compliance. Semi-annual opacity observations have been performed and recorded by
Method 9 certified individuals. No excess emissions were noted during review of records.

II.B.5.c Condition:

For affected emission units with a heat input rating greater than 1.0 MMBtu/hr each, combined
consumption of #1 and #2 fuel oil shall not exceed 1,000,000 gallons per rolling 12-month period.
[Origin: DAQE-AN107060055-20]. [R307-401-8]

II.B.5.c.1 Monitoring:

By the 15th day of each month, the permittee shall calculate the total volume of fuel consumed in
the previous 12 months. Fuel consumption for each affected emission unit shall be determined by
a fuel meter and/or log.

II.B.5.c.2 Recordkeeping:

Records shall be kept on a monthly basis for each affected emission unit. Results of monitoring
shall be maintained as described in Provision I.S.1 of this permit.

29
II.B.5.c.3 Reporting:

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

Status: In compliance. The 12-month rolling total ending April 30, 2024, was 281,817 gallons.

II.B.5.d 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. [Origin: DAQE-AN107060055-20]. [R307-401-4, R307-401-8]

II.B.5.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.5.d.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.

II.B.5.d.3 Reporting:

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

Status: In compliance. Dugway has a preventative maintenance plan in place. Base operations
contractor Chenega performs maintenance and keeps records in maintenance logs which are kept
at each boiler and heater. Spot review of the logs showed run times and maintenance performed.

II.B.6 Conditions on ECO-2: NESHAP Oil-Fired Boilers.

II.B.6.a Condition:

For each affected emission unit, the permittee shall comply with each applicable work practice standard,
emission reduction measure, and management practice specified in 40 CFR 63 Subpart JJJJJJ Table 2 no
later than the applicable compliance date specified in 40 CFR 63.11196. The permittee shall also comply
with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 8 of 40 CFR 63 Subpart
JJJJJJ. [Origin: 40 CFR 63 Subpart JJJJJJ]. [40 CFR 63.11196, 40 CFR 63.11201, 40 CFR 63.11235, 40
CFR 63 Subpart JJJJJJ Table 2, 40 CFR 63 Subpart JJJJJJ Table 8]

II.B.6.a.1 Monitoring:

To demonstrate continuous compliance, the permittee shall conduct a tune-up biennially for each
new and existing oil-fired boiler with heat input capacity greater than 5 MMBtu/hr as specified in
40 CFR 63.11223. (40 CFR 63 Subpart JJJJJJ Table 2(4) and (5)) Each biennial tune-up shall be
conducted no more than 25 months after the previous tune-up.
30
To demonstrate continuous compliance, the permittee shall conduct a tune-up every five years for
each new and existing oil-fired boiler with heat input capacity less than or equal to 5 MMBtu/hr
as specified in 40 CFR 63.11223. (40 CFR 63 Subpart JJJJJJ Table 2(12) and (13)) Each 5-year
tune-up shall be conducted no more than 61 months after the previous tune-up.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart JJJJJJ.

II.B.6.a.2 Recordkeeping:

The permittee shall keep records as required in 40 CFR 63.11225(c). Records shall be maintained
as specified in 40 CFR 63.11225(d) and Provision I.S.1 of this permit.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart JJJJJJ.

II.B.6.a.3 Reporting:

The permittee shall submit notifications and reports as specified in 40 CFR 63.11225.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart JJJJJJ.

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

Status: In compliance. The initial notification for Subpart JJJJJJ was submitted to the DAQ on
August 14, 2012. Dugway determined it was an area source for HAPs. A list of boilers was included
in the notification. Biennial and five-year tune-ups have been performed and recorded.

II.B.6.b Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Administrator that may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart JJJJJJ]. [40 CFR
63.11196, 40 CFR 63.11201(d), 40 CFR 63.11205(a)]

II.B.6.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.6.b.2 Recordkeeping:

The permittee shall keep records as required in 40 CFR 63.11225(c). Records shall be maintained
as specified in 40 CFR 63.11225(d) and Provision I.S.1 of this permit.

31
II.B.6.b.3 Reporting:

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

Status: In compliance. A preventative and ongoing maintenance program is in place. Contractors
perform the required work and keep records in logbooks kept at each boiler.

II.B.7 Conditions on ICO-0: Stationary Diesel-Fired Generators

II.B.7.a Condition:

Visible emissions shall be no greater than 20 percent opacity for affected emission units manufactured
after January 1, 1973, except for operation not exceeding 3 minutes in any hour. [Origin: DAQE-
AN107060055-20, R307-201]. [R307-201-3(5)]

II.B.7.a.1 Monitoring:

If an affected emission unit is operated during a semi-annual period, an opacity observation of the
emission unit shall be performed in the semi-annual period that the emission unit was operated.
The opacity observation can be conducted at any time during the semi-annual period. The opacity
observation shall be conducted by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9, while the emission unit is operating. If visible emissions other than
condensed water vapor are observed from the emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial visual
emission observation. The opacity determination shall be performed in accordance with 40 CFR
60, Appendix A, Method 9.

II.B.7.a.2 Recordkeeping:

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each semi-annual period for each affected emission unit, the log shall include
either the date of the opacity observation and if visual emissions other than condensed water
vapor were observed or a note that the emission unit was not operated. For each observed visual
emission other than condensed water vapor the permittee shall record: date and time of visual
emission observation, emission unit location and description, time and date of opacity
determination, and percent opacity. The records required by this provision and all data required
by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.7.a.3 Reporting:

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

Status: In compliance. These units have only operated for maintenance and to perform semi-annual
opacity observations. Observations have been recorded, with no excess opacity documented.

32
II.B.7.b Condition:

Visible emissions shall be no greater than 40 percent opacity for affected emission units manufactured
before January 1, 1973, except for operation not exceeding 3 minutes in any hour.
[Origin: DAQE-AN107060055-20, R307-201]. [R307-201-3(6)]

II.B.7.b.1 Monitoring:

If an affected emission unit is operated during a semi-annual period, an opacity observation of the
emission unit shall be performed in the semi-annual period that the emission unit was operated.
The opacity observation can be conducted at any time during the semi-annual period. The opacity
observation shall be conducted by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9, while the emission unit is operating. If visible emissions other than
condensed water vapor are observed from the emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial visual
emission observation. The opacity determination shall be performed in accordance with 40 CFR
60, Appendix A, Method 9.

II.B.7.b.2 Recordkeeping:

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each semi-annual period for each affected emission unit, the log shall include
either the date of the opacity observation and if visual emissions other than condensed water
vapor were observed or a note that the emission unit was not operated. For each observed visual
emission other than condensed water vapor the permittee shall record: date and time of visual
emission observation, emission unit location and description, time and date of opacity
determination, and percent opacity. The records required by this provision and all data required
by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.7.b.3 Reporting:

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

Status: In compliance. These units have only operated for maintenance and to perform semi-annual
opacity observations. Observations have been recorded, with no excess opacity documented.

II.B.7.c Condition:

The consumption of diesel shall be no greater than 250,000 gallons per rolling 12-month period for all
affected emission units except those used for emergency power generation. [Origin: DAQE-
AN107060055-20]. [R307-401-8]

II.B.7.c.1 Monitoring:

By the 15th day of each month, the permittee shall calculate the total volume of fuel consumed in
the previous 12 months. Fuel consumption for each affected emission unit shall be determined by
a fuel meter, fuel bills, or trip tickets.

33
II.B.7.c.2 Recordkeeping:

Records of fuel consumption shall be kept on a monthly basis for each affected emission unit.
Results of monitoring shall be maintained as described in Provision I.S.1 of this permit.

II.B.7.c.3 Reporting:

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

Status: In compliance. These units have only operated for maintenance and to perform semi-annual
opacity observations. 12-month rolling fuel consumption was recorded as 0 gallons as no fuel has
been transferred to any of these units during this time period.

II.B.7.d 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. [Origin: DAQE-AN107060055-20]. [R307-401-8]

II.B.7.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.7.d.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.

II.B.7.d.3 Reporting:

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

Status: In compliance. Dugway has a preventative maintenance plan in place. Maintenance logs are
kept onsite at each piece of equipment.

II.B.8 Conditions on ICP-0: Stationary LPG-Fired Generators

II.B.8.a 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. [Origin: DAQE-AN107060055-20]. [R307-401-8]
34
II.B.8.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.8.a.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.

II.B.8.a.3 Reporting:

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

Status: In compliance. Dugway has a preventative maintenance plan in place. Maintenance logs are
kept onsite at each piece of equipment.

II.B.9 Conditions on ICE-0: Stationary Emergency Generators

II.B.9.a Condition:

Emergency generators shall be used for electricity producing operation only during the periods when
electric power from the public utility is interrupted or during maintenance. [Origin: DAQE-
AN107060055-20]. [R307-401-8]

II.B.9.a.1 Monitoring:

Hours of operation for each affected emission unit shall be determined by an hour meter and/or a
log.

II.B.9.a.2 Recordkeeping:

For each affected emission unit, the permittee shall record the following information for each
usage: date(s), total hours used, and reason for usage. These records and the results of monitoring
shall be maintained as described in Provision I.S.1 of this permit.

II.B.9.a.3 Reporting:

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

Status: In compliance. Dugway has contracted Chenega to maintain and operate the emergency
generators. Operation logbooks are kept by the contractors and audited by the environmental
group. Logs record reasons for. Maintenance run hours were under the annual limit.

II.B.10 Conditions on NSPS-ICE: NSPS Stationary Compression Ignition (CI) Internal Combustion
Engines (ICE).

II.B.10.a Condition:

2007 model year and later non-emergency stationary affected emission units with a displacement of less
than 30 liters per cylinder shall comply with the emission standards for new CI engines in 40 CFR
35
60.4201 for the 2007 model year and later stationary CI ICE, as applicable. Modified or reconstructed
affected emission units shall meet the emission standards for new CI engines in 40 CFR 60.4201
applicable to the model year, maximum engine power, and displacement of the modified or reconstructed
engine. If the permittee conducts performance tests in-use on stationary CI ICE with a displacement of
less than 30 liters per cylinder they shall meet the not-to-exceed (NTE) standards as indicated in 40 CFR
60.4212. [Origin: 40 CFR 60 Subpart IIII]. [40 CFR 63 Subpart ZZZZ, 40 CFR 60.4204(b), 40 CFR
60.4204(d), 40 CFR 60.4204(e)]

II.B.10.a.1 Monitoring:

The permittee shall comply by purchasing an engine certified to the emission standards in 40
CFR 60.4204(b) for the same model year and maximum engine power. The engine shall be
installed and configured according to the manufacturer's emission-related specifications, except
as permitted in 40 CFR 60.4211(g). [40 CFR 60.4211(c)]

For modified or reconstructed affected emission units that must comply with the emission
standards specified in 40 CFR 60.4204(e), the permittee shall demonstrate compliance by
purchasing, or otherwise owning or operating, an engine certified to the emission standards in 40
CFR 60.4204(e) or by conducting a performance test in accordance with 40 CFR 60.4211(e)(2).
[40 CFR 60.4211(e)].

II.B.10.a.2 Recordkeeping:

The permittee shall keep records of engine certifications indicating compliance with the
standards. The permittee shall keep records demonstrating compliance with the manufacturer's
emission-related specifications for engine installation and configuration, except as permitted in
40 CFR 60.4211(g). Results of monitoring shall be maintained in accordance with Provision I.S.1
of this permit.

II.B.10.a.3 Reporting:

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

Status: In compliance. Only DAQ approved generators meeting these requirements have been
installed.

II.B.10.b Condition:

Pre-2007 model year emergency stationary affected emission units that are not fire pump engines shall
comply with the emission standards in Table 1 of 40 CFR 60 Subpart IIII. Modified or reconstructed
affected emission units shall meet the emission standards in Table 1 of 40 CFR 60 Subpart IIII applicable
to the model year, maximum engine power, and displacement of the modified or reconstructed engine. If
the permittee conducts performance tests in-use on stationary CI ICE with a displacement of less than 30
liters per cylinder they shall meet the not-to-exceed (NTE) standards as indicated in 40 CFR 60.4212.
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 63 Subpart ZZZZ, 40 CFR 60.4205(a), 40 CFR 60.4205(e), 40
CFR 60.4205(f)]

II.B.10.b.1 Monitoring:

The permittee shall demonstrate compliance according to one of the methods specified in
paragraphs (a) through (e) of this section.
36
(a) Purchasing an engine certified to emission standards for the same model year and maximum
engine power as described in 40 CFR parts 1039 and 1042, as applicable. The engine shall
be installed and configured according to the manufacturer's specifications.
(b) Keeping records of performance test results for each pollutant for a test conducted on a
similar engine. The test must have been conducted using the same methods specified in 40
CFR 60 Subpart IIII and these methods must have been followed correctly.
(c) Keeping records of engine manufacturer data indicating compliance with the standards.
(d) Keeping records of control device vendor data indicating compliance with the standards.
(e) Conducting an initial performance test to demonstrate compliance with the emission
standards according to the requirements specified in 40 CFR 60.4212, as applicable.
(Origin: 40 CFR 60.4211(b))

For modified or reconstructed affected emission units that must comply with the emission
standards specified in 40 CFR 60.4205(f), the permittee shall demonstrate compliance by
purchasing, or otherwise owning or operating, an engine certified to the emission standards in 40
CFR 60.4205(f) or by conducting a performance test in accordance with 40 CFR 60.4211(e)(2).
[40 CFR 60.4211(e)].

II.B.10.b.2 Recordkeeping:

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

II.B.10.b.3 Reporting:

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

Status: In compliance. Only DAQ approved generators meeting these requirements have been
installed.

II.B.10.c Condition:

2007 model year and later emergency stationary affected emission units with a displacement of less than
30 liters per cylinder that are not fire pump engines shall comply with the emission standards for new
nonroad CI engines in 40 CFR 60.4202, for all pollutants, for the same model year and maximum engine
power for the 2007 model year and later emergency stationary CI ICE. Modified or reconstructed affected
emission units shall meet the emission standards for new nonroad CI engines in 40 CFR 60.4202
applicable to the model year, maximum engine power, and displacement of the modified or reconstructed
engine. If the permittee conducts performance tests in-use on stationary CI ICE with a displacement of
less than 30 liters per cylinder they shall meet the not-to-exceed (NTE) standards as indicated in 40 CFR
60.4212. [Origin: 40 CFR 60 Subpart IIII]. [40 CFR 63 Subpart ZZZZ, 40 CFR 60.4205(b), 40 CFR
60.4205(e), 40 CFR 60.4205(f)]

II.B.10.c.1 Monitoring:

The permittee shall comply by purchasing an engine certified to the emission standards in 40
CFR 60.4205(b) for the same model year and maximum engine power. The engine shall be
installed and configured according to the manufacturer's emission-related specifications, except
as permitted in 40 CFR 60.4211(g). [40 CFR 60.4211(c)]

For modified or reconstructed affected emission units that must comply with the emission
standards specified in 40 CFR 60.4205(f), the permittee shall demonstrate compliance by
37
purchasing, or otherwise owning or operating, an engine certified to the emission standards in 40
CFR 60.4205(f) or by conducting a performance test in accordance with 40 CFR 60.4211(e)(2).
[40 CFR 60.4211(e)].

II.B.10.c.2 Recordkeeping:

The permittee shall keep records of engine certifications indicating compliance with the
standards. The permittee shall keep records demonstrating compliance with the manufacturer's
emission-related specifications for engine installation and configuration, except as permitted in
40 CFR 60.4211(g). Results of monitoring shall be maintained in accordance with Provision I.S.1
of this permit.

II.B.10.c.3 Reporting:

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

Status: In compliance. Only DAQ approved generators meeting these requirements have been
installed.

II.B.10.d Condition:

The permittee shall operate and maintain affected emission units that achieve the emission standards as
required in 40 CFR 60.4204 and 60.4205 over the entire life of the engine. The permittee shall do all of
the following, except as permitted in 40 CFR 60.4211(g):
(1) Operate and maintain the stationary CI ICE and control device according to the manufacturer's
emission-related written instructions;

(2) Change only those emission-related settings that are permitted by the manufacturer; and
(3) Meet the requirements of 40 CFR part 1068, as applicable.
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4206, 40 CFR 60.4211(a), 40 CFR 63 Subpart ZZZZ]

II.B.10.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.10.d.2 Recordkeeping:

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

II.B.10.d.3 Reporting:

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

Status: In compliance. Dugway keeps records of engine certifications indicating compliance with
the standards. The engines are operated according to manufacturer recommendations, and
maintenance is performed and recorded by contractor Chenega.

38
II.B.10.e Condition:

For all affected emission units with a displacement of less than 30 liters per cylinder that use diesel fuel,
the permittee shall use diesel fuel that meets the requirements of 40 CFR 1090.305 for nonroad diesel
fuel. [Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4207(b), 40 CFR 63 Subpart ZZZZ]

II.B.10.e.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.10.e.2 Recordkeeping:

The permittee shall maintain records of diesel fuel purchase invoices or obtain certification from
the diesel fuel supplier. The diesel fuel purchase invoices and/or certifications shall indicate the
diesel fuel meets the requirements in 40 CFR 1090.305. Records demonstrating compliance with
this condition shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.10.e.3 Reporting:

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

Status: In compliance. For all diesel fuel combusted, Dugway maintains fuel receipt records and
documentation demonstrating compliance with this provision. These records are maintained.

II.B.10.f Condition:

For all affected emission units, except those that are modified, reconstructed, or removed from one
existing location and reinstalled at a new location, the permittee shall comply with paragraphs (1) through
(7).
(1) The permittee shall not install affected emission units (excluding fire pump engines) that do not meet
the applicable requirements for 2007 model year engines.
(2) The permittee shall not install affected emission units with a maximum engine power of less than 19
KW (25 HP) (excluding fire pump engines) that do not meet the applicable requirements for 2008
model year engines.
(3) The permittee shall not install non-emergency affected emission units with a maximum engine power
of greater than or equal to 19 KW (25 HP) and less than 56 KW (75 HP) that do not meet the
applicable requirements for 2013 model year non-emergency engines.
(4) The permittee shall not install non-emergency affected emission units with a maximum engine power
of greater than or equal to 56 KW (75 HP) and less than 130 KW (175 HP) that do not meet the
applicable requirements for 2012 model year non-emergency engines.
(5) The permittee shall not install non-emergency affected emission units with a maximum engine power
of greater than or equal to 130 KW (175 HP), including those above 560 KW (750 HP), that do not
meet the applicable requirements for 2011 model year non-emergency engines.
(6) The permittee shall not install non-emergency affected emission units with a maximum engine power
of greater than or equal to 560 KW (750 HP) that do not meet the applicable requirements for 2015
model year non- emergency engines.
(7) The permittee shall not import affected emission units with a displacement of less than 30 liters per
cylinder that do not meet the applicable requirements specified in paragraphs (1) through (6) of this
section after the dates specified in 40 CFR 60.4208.
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4208, 40 CFR 63 Subpart ZZZZ]

39
II.B.10.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.10.f.2 Recordkeeping:

The permittee shall keep records of the install date of each affected emission unit and the
applicable requirements under 40 CFR 60 Subpart IIII for the respective model year engine.
Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.10.f.3 Reporting:

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

Status: In compliance. Only DAQ approved generators meeting these requirements have been
installed.

II.B.10.g Condition:

The permittee shall operate the emergency stationary ICE according to the requirements in paragraphs (1)
through (3). In order for the engine to be considered an emergency stationary ICE under 40 CFR 60
Subpart IIII, any operation other than as described in 40 CFR 60.4211(f), is prohibited. If the engine is
not operated according to the requirements in 40 CFR 60.4211(f), it will not be considered an emergency
engine and shall meet all requirements for non-emergency engines.
(1) There is no time limit on the use of emergency stationary ICE in emergency situations.
(2) Emergency stationary ICE may be operated for any combination of the purposes specified in 40 CFR
60.4211(f)(2) for a maximum of 100 hours per calendar year. Any operation for non-emergency
situations as allowed by 40 CFR 60.4211(f)(3) counts as part of the 100 hours per calendar year
allowed by this paragraph.
(a) Emergency stationary ICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
authority and transmission operator, or the insurance company associated with the engine. A
petition for approval of additional hours to be used for maintenance checks and readiness testing
is not required if the permittee maintains records indicating that federal, state, or local standards
require maintenance and testing of emergency affected emission units beyond 100 hours per
calendar year.
(3) The permittee may operate the emergency stationary ICE up to 50 hours per calendar year in non-
emergency situations, as specified in 40 CFR 60.4211(f)(3).
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4211(f), 40 CFR 63 Subpart ZZZZ]

II.B.10.g.1 Monitoring:

If an emergency stationary CI ICE does not meet the standards applicable to non-emergency
engines, the permittee shall install a non-resettable hour meter prior to startup of the engine. [40
CFR 60.4209(a)] Records required for this permit condition will also serve as monitoring.

II.B.10.g.2 Recordkeeping:

Records of each affected emission unit shall be kept on a monthly basis in an operation and
maintenance log to demonstrate compliance with this provision. Records shall distinguish
40
between maintenance-related hours and emergency use-related hours. If additional hours are to be
used for maintenance checks and readiness testing, the permittee shall maintain records indicating
that federal, state, or local standards require maintenance and testing of emergency ICE beyond
100 hours per calendar year.

Starting with the model years in Table 5 of 40 CFR 60 Subpart IIII, if an emergency affected
emission unit does not meet the standards applicable to non-emergency engines in the applicable
model year, the permittee shall keep records of the operation of the engine in emergency and non-
emergency service that are recorded through the non-resettable hour meter. The permittee shall
record the time of operation of the engine and the reason the engine was in operation during that
time. [40 CFR 60.4214(b)]

Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.10.g.3 Reporting:

For applicable emergency stationary CI ICE with a maximum engine power more than 100 HP,
the permittee shall submit an annual report as specified in 40 CFR 60.4214(d). There are no
additional reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Run hour records show no engines subject to this condition ran over 100
hours for non-emergency situations in 2023. A spreadsheet is maintained to show compliance.

II.B.11 Conditions on OT: Outdoor Testing and Training

II.B.11.a Condition:

Outdoor testing and training operations shall be performed at a location such that the intended actual
point of release is not closer than 2 km from the boundary of property comprising Dugway Proving
Ground or which Dugway has a legal use agreement. [Origin: DAQE-AN107060055-20]. [R307-401-8]

II.B.11.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.11.a.2 Recordkeeping:

For each test and training operation, the permittee shall record that no point of release was closer
than 2 km from the boundary of property comprising Dugway Proving Ground (DPG) or for
which DPG has a legal use agreement. The records shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.11.a.3 Reporting:

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

Status: In compliance. The OT operations are with the defined boundary listed above. Records
confirm compliance.

41
II.B.11.b Condition:

The permittee shall submit an annual plan of outdoor tests and training operations for planned releases to
be performed in the upcoming year (federal fiscal year beginning October 1) for approval of test
parameters no later than June 30 of each year for the new federal fiscal year. The plan shall include all
tests and training operations which may result in the release of criteria pollutants and HAPs into the
atmosphere and the following information:
(1) Name of each test or training operation material(s) which release criteria pollutants and HAPs into
the air.
(2) Maximum quantities which may be released.
(3) Maximum rates of release (quantity per hour).
(4) Projected dates of release.
[Origin: DAQE-AN107060055-20]. [R307-401-8]

II.B.11.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.11.b.2 Recordkeeping:

The permittee shall maintain the following records for each test and training operation:
(a) Purpose of the test or training operation.
(b) Start and end date of test or training operation.
(c) Names (common and chemical names) and quantities of each criteria pollutant and HAP
released.

The permittee shall maintain these records and a copy of each submittal required by this permit
condition in accordance with Provision I.S.1 of this permit. All records shall be available for
review, upon request, by the Director or Director's representative.

II.B.11.b.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, within 30 days of
the end of each quarter the permittee shall submit a report containing information that describes
the tests or training operations as they actually occurred. The reports shall include all tests and
training operations that resulted in the release of criteria pollutants and HAPs into the atmosphere
and include the following information:
(a) A list of actions accomplished.
(b) A brief description of each test and training operation, including the following:
(1) Purpose of the test or training operation.
(2) Start and end date of test or training operation.
(3) Names (common and chemical names) and quantities of each criteria pollutant and
HAP released.

Status: In compliance. Dugway has submitted annual notifications and quarterly reports. The last
annual plan was submitted via email on June 7, 2023, and covers from October 1, 2023 to
September 30, 2024.

42
II.B.12 Conditions on OBOD-0: Open Burn/Open Detonation (Source Wide).

II.B.12.a Condition:

Open burn (OB) and open detonation (OD) of residual munitions and propellants, explosives, and
pyrotechnics (PEP) at the affected emission unit shall be conducted in the DTTF (OBOD-1 & OBOD-2)
unless emergency in-place OD on the open range (OBOD-3) is necessary for safety reasons and is
conducted in compliance with the Utah State issued Resource Conservation and Recovery Act permit.
[Origin: DAQE-AN107060055-20]. [R307-202-8, R307-401-8]

II.B.12.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.12.a.2 Recordkeeping:

For each OB and OD event at the affected emission unit, the permittee shall record the following
information: date and time of the event, type of event (OB or OD), general location (DTTF or
Open Range), UTM coordinates, and a description of the item which was burned or detonated.
For each OD on the open range at the affected emission unit, the permittee shall also record the
date of UDWMRC authorization. The permittee shall maintain the records in accordance with
Provision I.S.1 of this permit.

II.B.12.a.3 Reporting:

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

Status: In compliance. A log is kept for OB/OD activities and locations. Each event requires a
RCRA permit prior to OB or OD.

II.B.12.b Condition:

To meet the clearing index requirement, the following conditions shall exist at the time of each non-
emergency OB and OD event at the approximate location of the event:
(1) Mixing height greater than or equal to 500 meters,
(2) Wind speed greater than or equal to three miles per hour,
(3) Wind speed less than or equal to 15 miles per hour, and
(4) No air quality advisories or alerts for Tooele County.

Each event shall be conducted between one hour after sunrise and one hour before sunset.
[Origin: DAQE-AN107060055-20]. [R307-202-7, R307-401-8]

II.B.12.b.1 Monitoring:

Prior to each event, the permittee shall evaluate compliance with the requirements of this
provision using data collected at the location of the event and/or data collected at a location with
conditions representative of those at the location of the event.

43
II.B.12.b.2 Recordkeeping:

For each event, the permittee shall record the following information: date and time of event,
results of the monitoring, and a description of each test method and/or data source used to
evaluate compliance with this provision. The records shall be kept in accordance with Provision
I.S.1 of this permit.

II.B.12.b.3 Reporting:

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

Status: In compliance. All required items are confirmed and logged prior to a detonation event.

II.B.12.c Condition:

The permittee shall conduct each OB and OD event at the DTTF (OBOD-1 & OBOD-2) in accordance
with the current sound focusing mitigation plan (SFMP) as approved by the Director. The SFMP shall
include procedures to minimize the effects of over pressure on people outside the DPG boundary. The
plan shall contain specific criteria that will be used to decide whether or not to proceed with each OB and
OD event. If a nuisance as defined in Section 76-10-803 of the Utah Code is created by an OB event, the
OB portion of the SFMP shall be revised and approved by the Director before conducting any additional
OB events. If a nuisance as defined in Section 76-10-803 is created by an OD event, the OD portion of
the SFMP shall be revised and approved by the Director before conducting any additional OD events.
[Origin: DAQE-AN107060055-20]. [R307-401-8]

II.B.12.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.12.c.2 Recordkeeping:

Records of all actions taken to implement the sound focusing mitigation plan (SFMP) shall be
maintained and include the date and time the action was taken along with the reason(s) for
implementing the specific action. These records and the current SFMP shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.12.c.3 Reporting:

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

Status: In compliance. Records of actions taken to implement the sound focusing mitigation plan
prior to each event are in place. Detonation events are placed on hold when atmosphere conditions
may create over pressure.

44
II.B.13 Conditions on OBOD-1: Open Burn at the DTTF.

II.B.13.a Condition:

Net explosive weight shall be no greater than 1,500 lbs per event. A sign cautioning the public shall be
posted on the facility boundary and Durand Road if an OB event is used to thermally treat waste
containing more than 325 pounds of HCl. [Origin: DAQE-AN107060055-20]. [R307-202-7, R307-401-8]

II.B.13.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.13.a.2 Recordkeeping:

The permittee shall keep a log of the net explosive weight of each item destroyed. If a sign is
required, that shall also be noted in the log along with verification the sign was posted. The
records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.13.a.3 Reporting:

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

Status: In compliance. No OBOD-1 events occurred at the DTTF in the previous 12 months.

II.B.13.b Condition:

Net explosive weight shall be no greater than 150,000 lbs per rolling 12-month period.
[Origin: DAQE-AN107060055-20]. [R307-202-7, R307-401-8]

II.B.13.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.13.b.2 Recordkeeping:

By the 15th day of each month, the permittee shall calculate the total net explosive weight of
items destroyed in the previous 12 months. The records shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.13.b.3 Reporting:

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

Status: In compliance. No OBOD-1 events occurred at the DTTF in the previous 12 months.

45
II.B.14 Conditions on OBOD-2: Open Detonation at the DTTF.

II.B.14.a Condition:

Net explosive weight shall be no greater than 1,500 lbs per event. [Origin: DAQE-AN107060055-20].
[R307-202-7, R307-401-8]

II.B.14.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.14.a.2 Recordkeeping:

The permittee shall keep a log of the net explosive weight of each item destroyed. The records
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.14.a.3 Reporting:

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

Status: In compliance. No OBOD-2 events occurred at the DTTF in the previous 12 months.

II.B.14.b Condition:

Net explosive weight shall be no greater than 150,000 lbs per rolling 12-month period.
[Origin: DAQE-AN107060055-20]. [R307-202-7, R307-401-8]

II.B.14.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.14.b.2 Recordkeeping:

By the 15th day of each month, the permittee shall calculate the total net explosive weight of
items destroyed in the previous 12 months. The records shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.14.b.3 Reporting:

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

Status: In compliance. No OBOD-2 events occurred at the DTTF in the previous 12 months.

II.B.15 Conditions on OBOD-3: Open Detonation on Open Range.

II.B.15.a Condition:

Net explosive weight shall be no greater than 1,500 lbs per event. Each event shall be conducted after the
area has been secured according to Table 6-3 in PAM 385-64 "Emergency withdrawal distances for
46
nonessential personnel," and between one hour after sunrise and one hour before sunset. [Origin: DAQE-
AN107060055-20]. [R307-202-7, R307-401-8]

II.B.15.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.15.a.2 Recordkeeping:

The permittee shall keep a log of the net explosive weight of each item destroyed. For each event,
the permittee shall also record the following information:
(a) date and time of event,
(b) time of official sunrise and official sunset for the date of event,
(c) location of event,
(d) a description of why the item which was detonated could not be moved to the DTTF, and
(e) verification that the area was secured before the detonation was performed.
The records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.15.a.3 Reporting:

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

Status: In compliance. Open Detonation on Open Range events totaled 180.18 lbs during the
12-month period ending April 30, 2024.

II.B.15.b Condition:

Net explosive weight shall be no greater than 50,000 lbs per rolling 12-month period. [Origin: DAQE-
AN107060055-20]. [R307-202-7, R307-401-8]

II.B.15.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.15.b.2 Recordkeeping:

By the 15th day of each month, the permittee shall calculate the total net explosive weight of
items destroyed in the previous 12 months. The records shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.15.b.3 Reporting:

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

Status: In compliance. Open Detonation on Open Range events totaled 180.18 lbs during the
12-month period ending April 30, 2024.

47
II.B.16 Conditions on NESHAP-CI RICE: NESHAP Stationary CI RICE.

II.B.16.a Condition:

The permittee shall comply with the following operating limitations and other requirements at all times
for each emergency affected emission unit:
1. The permittee shall operate the affected emission unit according to the requirements in paragraphs 1.a
through 1.c. In order for the engine to be considered an emergency stationary RICE under 40 CFR 63
Subpart ZZZZ, any operation other than as described in 40 CFR 63.6640(f) is prohibited. If the engine
is not operated according to the requirements in 40 CFR 63.6640(f), it will not be considered an
emergency engine and shall meet all requirements for non-emergency engines.
a. There is no time limit on the use of emergency stationary RICE in emergency situations.
b. Emergency stationary RICE may be operated for any combination of the purposes specified in 40
CFR 63.6640(f)(2) for a maximum of 100 hours per calendar year. Any operation for non-
emergency situations as allowed by 40 CFR 63.6640(f)(4) counts as part of the 100 hours per
calendar year allowed by this paragraph.
(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
authority and transmission operator, or the insurance company associated with the engine. A
petition for approval of additional hours to be used for maintenance checks and readiness
testing is not required if the permittee maintains records indicating that federal, state, or local
standards require maintenance and testing of emergency RICE beyond 100 hours per calendar
year.
c. The permittee may operate the affected emission unit up to 50 hours per calendar year in non-
emergency situations as specified in 40 CFR 63.6640(f)(4).
2. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 500 hours of operation or annually, whichever comes first;
b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace
as necessary; and
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup the permittee shall minimize the engine's time spent at idle and minimize the
engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed
30 minutes, after which time the non-startup emission limitations apply.
3. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
[Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6603(a), 40 CFR 63.6605(a), 40 CFR 63.6625(h), 40
CFR 63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d, 40 CFR 63 Subpart ZZZZ
Table 8]

II.B.16.a.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed. [40 CFR
63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule or if
performing the management practice on the required schedule would otherwise pose an
unacceptable risk under federal, state, or local law, the management practice can be delayed until
the emergency is over or the unacceptable risk under federal, state, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or
48
the unacceptable risk under federal, state, or local law has abated. [40 CFR 63 Subpart ZZZZ
Table 2d Footnote 2]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(i).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.16.a.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
through the non-resettable hour meter. The permittee shall document how many hours are spent
for emergency operation, including what classified the operation as emergency and how many
hours are spent for non-emergency operation. If the engines are used for the purposes specified in
40 CFR 63.6640(f)(2)(ii) or (iii) or 40 CFR 63.6640(f)(4)(ii), the permittee shall keep records of
the notification of the emergency situation, and the date, start time, and end time of engine
operation for these purposes. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that federal, state, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per calendar year. [40 CFR 63.6640(f)(2)(i)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation [including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan]. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

49
II.B.16.a.3 Reporting:

The permittee shall report any failure to perform the management practice on the schedule
required and the federal, state or local law under which the risk was deemed unacceptable. [40
CFR 63 Subpart ZZZZ Table 2d Footnote 2]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665] The permittee shall also
report each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

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

Status: In compliance. Emergency engines are operated for emergency and maintenance purposes
only. A preventative maintenance program is in place and includes the requirements of this
condition. Maintenance testing is recorded in logbooks, and this preventative program is designed
to not exceed 100 hours per year. Non-resettable hour meters are installed on all engines.

II.B.16.b Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Administrator which may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart ZZZZ].
[40 CFR 63.6605(b)]

II.B.16.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.16.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)] The permittee shall document activities performed to assure proper operation
and maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and Provision
I.S.1 of this permit.

II.B.16.b.3 Reporting:

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

Status: In compliance. A preventative maintenance program is in place. All maintenance testing is
recorded in logbooks that are kept by the contractor performing this work. All engines appeared to
be in good operational order.

50
II.B.17 Conditions on NESHAP-SI RICE: NESHAP Stationary SI RICE.

II.B.17.a Condition:

The permittee shall comply with the following operating limitations and other requirements at all times
for each emergency affected emission unit:
1. The permittee shall operate the affected emission unit according to the requirements in paragraphs 1.a
through 1.c. In order for the engine to be considered an emergency stationary RICE under 40 CFR 63
Subpart ZZZZ, any operation other than as described in 40 CFR 63.6640(f), is prohibited. If the
engine is not operated according to the requirements in 40 CFR 63.6640(f), it will not be considered
an emergency engine and shall meet all requirements for non-emergency engines.
a. There is no time limit on the use of emergency stationary RICE in emergency situations.
b. Emergency stationary RICE may be operated for any combination of the purposes specified in 40
CFR 63.6640(f)(2) for a maximum of 100 hours per calendar year. Any operation for non-
emergency situations as allowed by 40 CFR 63.6640(f)(4) counts as part of the 100 hours per
calendar year allowed by this paragraph.
(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
authority and transmission operator, or the insurance company associated with the engine. A
petition for approval of additional hours to be used for maintenance checks and readiness
testing is not required if the permittee maintains records indicating that federal, state, or local
standards require maintenance and testing of emergency RICE beyond 100 hours per calendar
year.
c. The permittee may operate the affected emission unit up to 50 hours per calendar year in non-
emergency situations as specified in 40 CFR 63.6640(f)(4).
2. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 500 hours of operation or annually, whichever comes first;
b. Inspect spark plugs every 1,000 hours of operation or annually, whichever comes first, and
replace as necessary; and
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup, the permittee shall minimize the engine's time spent at idle and minimize
the engine's startup time to a period needed for appropriate and safe loading of the engine, not to
exceed 30 minutes, after which time the non-startup emission limitations apply.
3. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
[Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6603(a), 40 CFR 63.6605(a), 40 CFR 63.6625(h), 40
CFR 63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d, 40 CFR 63 Subpart ZZZZ
Table 8]

II.B.17.a.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed. [40 CFR
63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule, or if
performing the management practice on the required schedule would otherwise pose an
unacceptable risk under federal, state, or local law, the management practice can be delayed until
the emergency is over or the unacceptable risk under federal, state, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or
51
the unacceptable risk under federal, state, or local law has abated. [40 CFR 63 Subpart ZZZZ
Table 2d Footnote 2]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution
control practice for minimizing emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63
Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(j).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.17.a.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
through the non-resettable hour meter. The permittee shall document how many hours are spent
for emergency operation, including what classified the operation as emergency and how many
hours are spent for non-emergency operation. If the engines are used for the purposes specified in
40 CFR 63.6640(f)(2)(ii) or (iii) or 40 CFR 63.6640(f)(4)(ii), the permittee shall keep records of
the notification of the emergency situation, and the date, start time, and end time of engine
operation for these purposes. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that federal, state, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per calendar year. [40 CFR 63.6640(f)(2)(i)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation [including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan]. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

52
II.B.17.a.3 Reporting:

The permittee shall report any failure to perform the management practice on the schedule
required and the federal, state or local law under which the risk was deemed unacceptable. [40
CFR 63 Subpart ZZZZ Table 2d Footnote 2]
The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63 Subpart ZZZZ Table 8. [40 CFR 63.6665] The permittee shall also report
each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

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

Status: In compliance. Emergency engines are operated for emergency and maintenance purposes
only. A preventative maintenance program is in place and includes the requirements of this
condition. Maintenance testing is recorded in logbooks, and this preventative program is designed
to not exceed 100 hours per year. Non-resettable hour meters are installed on all engines.

II.B.17.b Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Administrator which may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR
63.6605(b)]

II.B.17.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.17.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)] The permittee shall document activities performed to assure proper operation
and maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and Provision
I.S.1 of this permit.

II.B.17.b.3 Reporting:

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

Status: In compliance. A preventative maintenance program is in place. All maintenance testing is
recorded in logbooks that are kept by the contractor performing this work. All engines appeared to
be in good operational order.

53
II.B.18 Conditions on MSWL: Municipal Solid Waste Landfill.

II.B.18.a Condition:

(1) Design capacity.
(a) The permittee shall submit an amended design capacity report to the Administrator as provided
in paragraph (2).
(b) When an increase in the maximum design capacity of a landfill with an initial design capacity
less than 2.5 million megagrams or 2.5 million cubic meters results in a revised maximum
design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters,
the permittee shall comply with 40 CFR 62.16714(e).
(40 CFR 62.16714(d))
(2) Amended design capacity report. An amended design capacity report shall be submitted providing
notification of an increase in the maximum design capacity of the landfill to meet or exceed 2.5
million megagrams and 2.5 million cubic meters. This increase in design capacity may result from an
increase in the permitted volume of the landfill or an increase in the density as documented in the
annual recalculation required in the recordkeeping for this condition.
(40 CFR 62.16724(b))
[Origin: 40 CFR 62 Subpart OOO]. [40 CFR 62.16714(d), 40 CFR 62.16724(b)]

II.B.18.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.18.a.2 Recordkeeping:

If the permittee converts design capacity from volume to mass or mass to volume to demonstrate
that landfill design capacity is less than 2.5 million megagrams or 2.5 million cubic meters, as
provided in the definition of "design capacity" in 40 CFR 62.16730, the permittee shall keep
readily accessible, on-site records of the annual recalculation of site-specific density, design
capacity, and the supporting documentation. Off-site records may be maintained if they are
retrievable within 4 hours. Either paper copy or electronic formats are acceptable. (40 CFR
62.16726(f))

The permittee shall keep copies of all reports submitted to comply with this condition and all
documentation supporting any report. Records shall be maintained in accordance with 40 CFR
62.16726 and Provision I.S.1 of this permit.

II.B.18.a.3 Reporting:

The permittee shall submit an amended design capacity report within 90 days of an increase in
the maximum design capacity of the landfill to meet or exceed 2.5 million megagrams and 2.5
million cubic meters. (40 CFR 62.16724(b)) There are no additional reporting requirements for
this provision except those specified in Section I of this permit.

Status: In compliance. The current design capacity is below the 2.5 million megagrams limit.

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

Not applicable to this source.

54
II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

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

DAQE-AN107060057-23

This approval order updates the equipment list. There are no additional conditions not already
included in the Title V permit conditions listed above.

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
II.A.1 Dugway Proving Ground
Tests Chemical and Biological Defense Systems
II.A.2 Liquefied Petroleum Gas (LPG)-Fired Boilers
A. Bio Lab (Building 2028) Boilers
Rating: 7 MMBtu/hr each
Quantity: 2
NSPS Applicability: None
B. Bio Lab (Building 2029-A) Boilers
Boilers less than 5 MMBtu/hr each, exempt from requirements of this
AO as per R307-401-10, listed for informational purposes.
II.A.3 LPG-Fired Boilers (Cont'd)
C. Combined Chem Lab (Building 4156)
Boilers Rating: 10.5 MMBtu/hr
each
Quantity: 2 Burner Rating: 90 ppm NOx
NSPS Applicability: 40 CFR 60 Subpart Dc
D. Material Test Facility (Building 8027)
Boilers Rating: 10.461 MMBtu/hr
each
Quantity: 2 Burner Rating: 40 ppm NOx
NSPS Applicability: 40 CFR 60 Subpart Dc
55
II.A.4 Fuel Oil-Fired Boilers and Heaters
68 fuel oil-fired boilers and heaters smaller than 10 MMBtu/hr, 20 of which are subject to 40
CFR 63 Subpart JJJJJJ
A. 31 units larger than or equal to 1 MMBtu/hr with a combined rating of
86.19 MMBtu/hr
B. 37 units smaller than 1 MMBtu/hr, exempt from requirements of this AO as
per R307-401-10, listed for information purposes only.
II.A.5 LPG-Fired Emergency Generator Engines
3 engines rated at less than 600 hp with a combined rating of 471 hp (351 kWm, 265 kWe).
II.A.6 Diesel-Fired Emergency Generator Engines
A. 21 engines rated at or greater than 600 hp with a combined rating of 37,886
hp (28,253 kWm, 23,131 kWe) (one NEW)
B. 42 engines rated at less than 600 hp with a combined rating of 8,157 hp
(6,082 kWm, 4,671 kWe).
II.A.7 Diesel-Fired Non-Emergency Generator Engines
A. Police Firing Range Generator Engine
Rating: 201 hp (150 kWm, 100 kWe)
Manufacture Date: March 2016
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII/40 CFR 63 Subpart
ZZZZ
B. Chem Lab Generator Engines
Rating: 680 hp (507 kWm, 400 kWe) each
Quantity: 2
Manufacture Date: May 2011
NSPS/MACT Applicability: 40 CFR 60 Subpart IIII/40 CFR 63 Subpart
ZZZZ
II.A.8 Outdoor Testing and Training (OT)
Outdoor test materials and training operations such as smoke and obscurants, material and
delivery systems, munitions and incendiary devices.
II.A.9 Open Burn/Open Detonation (Source Wide) (OBOD-0)
Open Burning (OB) and Open Detonation (OD) of residual munitions and propellants,
explosives, and pyrotechnics (PEP) are conducted in the Dugway Thermal Treatment
Facility (DTTF) and on the open ranges.
II.A.10 OBOD-1
Open Burn at the DTTF destroys solid propellant, propellant charges, and bulk explosives.
II.A.11 OBOD-2
Open Detonation at the DTTF destroys conventional range recovered munitions, residual
explosive material housed in munitions, hung ordnance, solid propellants and obscurant when
the explosive and nonexplosive components cannot be safely separated.
II.A.12 OBOD-3
Due to safety concerns, some munitions must be destroyed in place. In these emergency
situations, explosives ordnance experts use Department of Defense approved procedures best
suited to the specific circumstances.
56
II.A.13 Underground Storage Tanks (TNK-1)
Four 20,000-gallon underground Fuel Oil No. 2 storage tanks. Three tanks are located at the
Baker facility and one tank is located at the Ditto facility.
Three underground gasoline storage tanks. One 10,000-gallon tank is located at the AAFES
gas station, one 20,000-gallon tank is located at the English Village Motor Pool and one
20,000- gallon tank is located at the Ditto Motor Pool.
II.A.14 Aboveground Storage Tanks (TNK-2)
Two 24,000-gallon aboveground JP-4 storage tanks located at the Michael Army Airfield.
II.A.15 Combined Chemical Test Facility (CCTF)*
The CCTF includes emission units CCTF-1 (Bldg 4156) and CCTF-2 (Bldg 4165). Chemical
agent operations are conducted at CCTF. Air from each room where chemical agent operations
are performed is exhausted to the atmosphere through laboratory exhaust stacks equipped with
multiple HEPA and carbon filters in series.
Operated in accordance with Army regulations PAM385-61, AR 50-1, and other the rules and
standards.
II.A.16 Bushnell Material Test Facility (BMTF)*
The BMTF and associated buildings (BMTF-1 - 8) are used to test military hardware under
varied direct exposure to chemical agents and non-agents. Operations are conducted in Multi-
Purpose Chambers, Agent Transfer Chambers, Thermal Pollution Abatement Device, Closed
System Chamber, and Agent Repository. Emission controls include Pollution Abatement
System, Redundant Pollution Abatement System, HEPA filters, and carbon filters. Operated in
accordance with Army regulations PAM385-61 and AR 50-1.
II.A.17 Life Sciences Test Facility (LSTF)*
The LSTF and associated buildings are used to conduct operations with biosafety level (BSL) 1,
2, and 3 materials. The LSTF includes emission units LSTF 1 through 4. BSL-3 operations are
conducted in Class II or III Biological Safety Cabinets (BSCs). HEPA filters controls emissions
to the atmosphere from the containment area.
Operated in accordance with Army regulations PAM385-10, PAM 385-69, AR 50-1, and other
CDC and HHS rules and standards.
*Listed for information purposes only.
Status: In compliance. No unapproved equipment was observed.

57
EMISSIONS INVENTORY: Taken from DAQ’s 2023 emissions inventory database:

PREVIOUS ENFORCEMENT
ACTIONS: None during the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Dugway should be considered in compliance with the Title V Operating
Permit conditions evaluated during this inspection. No further action is
recommended.

HPV STATUS: Not Applicable

COMPLIANCE
ASSISTANCE: None requested

RECOMMENDATION FOR
NEXT INSPECTION: Dugway operates on a 4 day work week. Inspections are recommended
Monday through Thursday. A background check is required prior to
entry. Photo ID and vehicle registration required prior to entry.
Photographs are not allowed.

ATTACHMENT: VEO Form