DAQ-2024-007301

January 29, 2024
Attn: NSPS Contact & Mr. Chad Gilgen,
Minor Source Compliance, Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
RE: NSPS UUU 2023 2nd Semiannual Report
NSPS OOO 2023 2nd Semiannual Report
40 CFR §60.735; UAC R307-210
Geofortis Utah, LLC
DAQE-AN160190001-20
DAQ NSPS Contact & Mr. Gilgen:
Geofortis Utah, LLC (Geofortis) is submitting semiannual reporting to the Division of Air Quality
(DAQ) of the approved dryer, ball mill, and pozzolans processing facility in Tooele, Project
Number N160190001. The Division of Air Quality (DAQ) issued the Approval Order (AO) DAQE-
DAQE-AN160190001-20 for the Tooele Pozzolans Processing Plant on September 30, 2020. The
pozzolans dryer is an affected facility under Code of Federal Regulations Title 40 (40 CFR) Part 60
Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral industries (NSPS
UUU). The pozzolans dryer is a rotary design controlled by a dedicated cyclone and fabric filter
baghouse. The ball mill crusher is subject to 40 CFR, Part 60 Subpart OOO - Standards of
Performance for Nonmetallic Mineral Processing Plants (NSPS OOO). The ball mill crusher is also
controlled by a dedicated fabric filter. Pursuant to NSPS UUU and NSPS OOO, §60.735 and §
60.676, Geofortis submits this semiannual summary of control device operating parameters from
July 1 to December 31, 2023, in which no exceedances were visually observed.
Reportable exceedances for pozzolans dryer control device operating parameters are described
in NSPS UUU, §60.735(c)(1), and NSPS OOO § 60.676(d). The Geofortis Tooele Pozzolans
Processing Plant pozzolans dryer utilizes a dry control device; therefore, §60.735(c)(2) and (3) do
not apply. For semiannual reporting purposes, NSPS UUU requires the following:
NSPS UUU, §60.735(c):
(c) Each owner or operator shall submit written reports semiannually of exceedances of
control device operating parameters required to be monitored by § 60.734 of this subpart.
For the purpose of these reports, exceedances are defined as follows:
(1) All 6-minute periods during which the average opacity from dry control devices is
greater than 10%;
DocuSign Envelope ID: 27451694-CE18-47C4-B5D6-6C5F9B07227E
REVIEWED
Initials: CG Date: 4-10-24
Compliance Status: NSPS OOO and UUU
Semi-Annual Report
File # 16019 (B2)
Page 2 of 2
Geofortis NSPS UUU & NSPS OOO 2023 2nd Semiannual Report
January 29, 2024

NSPS OOO, §60.676(d):
(d) After the initial performance test of a wet scrubber, the owner or operator shall submit
semiannual reports to the Administrator of occurrences when the measurements of the
scrubber pressure loss and liquid flow rate decrease by more than 30 percent from the
average determined during the most recent performance test.

NSPS UUU §60.734(c) specifically exempts industrial rotary pozzolans dryers from requirements
to monitor opacity of emissions, due to the US EPA determination while developing NSPS UUU
and NSPS OOO that the potential particulate matter emission rate for such dryers is less than
0.01 gr/dscf. However, Geofortis has developed voluntary internal procedures to check
baghouse operating parameters and conduct a brief visual and auditory inspection to confirm
baghouses are operating properly once per shift. These observations are qualitative checks along
with required differential pressure drop readings per day. Based upon this information,
maintenance, and differential pressure drop readings, there were no visible exceedances to
report from July 1 to December 31, 2023, pursuant to opacity standards in NSPS UUU / OOO.

Pursuant to NSPS OOO, Geofortis performs quarterly Method 22 opacity readings. As stated
earlier, Geofortis also performs daily observations of the entire plant. Although there were no
visible exceedances, the third quarter Method 22 documentation was not logged directly on-site.

It should be noted that AO DAQE-AN160190001-20, Conditions II.B.2.f and II.B.3.d, require that
Geofortis maintain the dryer and ball mill crusher baghouse differential pressures between 2.0
and 6.0 inches of water column. For both baghouses, Geofortis had multiple instances of
differential pressure below the assessed AO range. During low readings of differential pressure,
and on a daily basis, the stacks were observed and determined to have no emissions or zero
percent opacity. Geofortis plans to submit an AO modification and revision of Conditions II.B.2.f
and II.B.3.d consistent with the manufacturer’s recommendations.

Should the DAQ have any questions regarding this semiannual report, please contact Eric Sturm,
with Air Regulations Consulting, LLC (ARC), and environmental consultant for Geofortis, at
402.817.7887 or [e-mail].

Sincerely,

Jason Grieser,
Geofortis Plant Manager

Cc: Eric Sturm, ARC Principal, Sr. Consultant
Kyle Fletcher, Geofortis Assistant Plant Manager
Andrew McKane, Geofortis EHS Coordinator
DocuSign Envelope ID: 27451694-CE18-47C4-B5D6-6C5F9B07227E
4/10/24, 3:40 PM State of Utah Mail - Geofortis NSPS UUU and OOO Semiannual Reports
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permmsgid=msg-f:1789482794747832829&simpl=msg-f:1789482794747832829 1/1
Chad Gilgen <[e-mail]>
Geofortis NSPS UUU and OOO Semiannual Reports
Eric Sturm <[e-mail]>Mon, Jan 29, 2024 at 8:02 PM
To: Chad Gilgen <[e-mail]>
Cc: Jason Grieser <[e-mail]>, Kyle Fletcher <[e-mail]>, Andrew McKane
<[e-mail]>
Good evening, Chad,

For Geofortis Utah, LLC - Pozzolans Processing Facility, DAQE-AN160190001-20, please find the attached
NSPS UUU and OOO 2nd 2023 Semiannual Report for the one(1) pozzolans dryer and one(1) ball
mill operating on-site, respectively. If there are any questions, please let me know.

Best regards.
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Geofortis UT 2023 NSPS Report 2nd Semiannual_01292024vsigned.pdf
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