DAQ-2024-007299

4/10/24, 3:14 PM State of Utah Mail - Request of 180 Day Extension on Stack Test for Dryer 3 RHEx Vernal Mine
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1795171225100349517&simpl=msg-f:17951712251003495…1/2
Chad Gilgen <[e-mail]>
Request of 180 Day Extension on Stack Test for Dryer 3 RHEx Vernal Mine
3 messages
Eric Sturm <[e-mail]>Mon, Apr 1, 2024 at 3:58 PM
To: Chad Gilgen <[e-mail]>
Cc: Mike Cina <[e-mail]>
Mr. Gilgen,
My company helps assist Ramsey Hill Exploration, LLC (RHEx) with air permitting and compliance matters. RHEx
inquired about obtaining an extension to stack test their newly added sand dryer in 2023 (Dryer 3). The new Dryer 3’s
operation is still in its infancy and not yet up to maximum capacity. RHEx’s NOI for Dryer 3 was approved on July 31,
2023, and began commercial operation in November 2023. RHEx’s AO for Dryer 3 is attached.
In the attached AO, and Condition II.B.4.f.1, it indicates that a test for PM on the sand dryer is to be performed within 180
days of startup. Due to the cold winter temperatures, lack of sales (i.e., reduced run time), and related difficulty in tuning
the dryer operation, RHEx cannot yet sustainably run Dryer 3 near maximum capacity.
Condition II.B.4.f.1, and NSPS Subpart UUU require the stack testing to be conducted on Dryer 3 when operating at
maximum capacity. Additionally, NSPS Subpart UUU requires three runs of at least two hours per run, contiguously. At
this time, RHEx cannot yet sustain the rated capacity on Dryer 3 for the six to eight hours as required for the NSPS
Subpart UUU Method 5 stack testing.
RHEx would respectfully request a 180-day extension to test; this would be very helpful to ensure the test is valid and
performed near maximum capacity for the dryer. This would allow for dryer tuning and assimilation of operations during
warmer temperatures, which would further assist RHEx in getting the new dryer up to rated capacity.
If agreeable with the DAQ, a 180-day extension would then move the testing deadline to ~October 1, 2024. Is DAQ open
to an extension for RHEx Dryer 3?
We will make ourselves available for a call if you have any questions or wish to further discuss.
Sincerely.
Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
REVIEWED
Initials: CG Date: 4-10-24
Compliance Status: Stack Test Extension Request
File # 15971 (B2)
4/10/24, 3:14 PM State of Utah Mail - Request of 180 Day Extension on Stack Test for Dryer 3 RHEx Vernal Mine
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1795171225100349517&simpl=msg-f:17951712251003495…2/2
M: 402.310.4211
.VCF | LinkedIn

DAQE-AN159710004-23 (1).pdf
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Chad Gilgen <[e-mail]>Mon, Apr 1, 2024 at 3:58 PM
To: [e-mail]
I am out on leave until April 8, 2024, and will only be checking emails periodically during that time. If you need immediate
assistance, please contact the DAQ Front Desk at 801-536-4000.
Thanks,
Chad
--
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
Chad Gilgen <[e-mail]>Wed, Apr 10, 2024 at 3:13 PM
To: Eric Sturm <[e-mail]>
Cc: Mike Cina <[e-mail]>
Hello Eric,
Based on the information provided, the DAQ concurs with your request to extend the stack testing deadline for Dryer 3 to
early October 2024.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
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