DAQ-2024-010850

1

DAQC-978-24
Site ID 10742 (B4)

MEMORANDUM

TO: STACK TEST FILE – INTREPID POTASH WENDOVER, LLC – Wendover
Potash Plant

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Paul Bushman, Environmental Scientist

DATE: September 27, 2024

SUBJECT: Source: Venturi Scrubber
Location: Exit 4, Interstate 80 and the Frontage Road, Wendover, Utah
Contact: Todd Stubbs: 435-259-1282
Tester: TETCO
Site ID #: 10742
Permit/AO #: Approval Order (AO) DAQE-AN1074200014-19 dated July 22, 2019
Subject: Review of Pretest Protocol received September 26, 2024
On September 26, 2024, Utah Division of Air Quality (DAQ) received a test notification for the testing of
the Venturi Scrubber located at the Wendover Potash Plant, Tooele County, Utah. Testing will be
performed November 10-11, 2024, to determine compliance with the emission limits found in condition
II.B.4.a of AO DAQE-AN1074200014-19.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3 used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine the moisture content within the gas stream: OK
5. RM 5 used to determine total particulate emissions: OK
6. RM 202 used to determine condensable particulate emissions: OK

DEVIATIONS: Due to water droplets present in the effluent gas, RM 201A Section 1.5
states to use RM 5 in lieu of RM 201A.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Intrepid Potash Wendover, LLC test notification and pretest protocol.
COMPLIANCE EMISSION TESTING PROTOCOL
FOR PARTICULATE MATTER
INTREPID WENDOVER POTASH, WENDOVER, UTAH
VENTURI WET SCRUBBER

Project Organization and Responsibility

The following personnel and the testing contractor are presently anticipated to be involved in the
testing program. The Utah Department of Environmental Quality, Division of Air Quality (DAQ)
and EPA may have their own personnel to observe all phases including the process

Company Contacts
Intrepid Potash, Wendover LLC Todd Stubbs 435 259-1282
P O Box 580
Wendover, UT 84083

TETCO Dean Kitchen 801 492-9106
391 East 620 South
American Fork, UT 84003

Facility and Location

The facility to be tested is Intrepid Potash, Wendover LLC located on the frontage road
approximately 4 (four) miles east of Wendover, Utah. The source to be tested is the Venturi Wet
Scrubber exhaust that serves the dryer heated by a 21 MMBtu/hr burner. The burner is fired with
propane.

Test Objective

The test objective is to comply with the facility’s approval order number DAQE-
AN0107420014-19. Testing procedures will include accumulating process and production data as
well as testing for PM10 particulate matter emissions using EPA Method 5. Condensable
particulate matter (CPM) will be measured according to EPA Method 202 and is not for
compliance but informational purposes only.

The allowable PM10 emission limits for this source are 0.05 gr/dscf and 6.0 lb/hr.

Test Date and Time

It is planned to complete this test November 11-12, 2024. The testing crew will arrive and set up
the testing equipment November 11th and begin testing that afternoon if production permits.
Testing will continue on November 12th as needed. A pre-test meeting may be scheduled by EPA,
DAQ or Intrepid Potash.

Process Data and Instrumentation

All process and instrumentation data will be made available to DAQ personnel. The venturi
scrubber water flow rate and pressure drop will be recorded by TETCO personnel during each test
run. The amount of material processed through the kiln dryer will be recorded by Intrepid Potash
Wendover personnel. The facility will run at normal conditions.

Site Access

Sample location access is by man-lift. Full-body harnesses will be used for anyone ascending in
the man-lift.

Potential Hazards

Moving Equipment Yes
Hot Equipment Yes
Chemical Pot Ash, Corrosive
Other Noise

Test Site

The stack inside diameter is 24.75 inches. Port location is depicted in Appendix 1 of this protocol.
The sample ports are located 7.3 diameters (15 feet) downstream from the last disturbance and
approximately 7.3 diameters (15 feet) upstream from the next disturbance. Sample port placement
conforms to the requirements of EPA Method 1.

Quality Assurance

All testing and analysis in these tests will be conducted according to Methods 5, 202 and
appropriate sections of 40 CFR 51 Appendix M.

Reporting

Reporting will be prepared by the testing contractor according to EPA Quality Assurance
Guidelines. A complete copy of raw data and test calculations summary will be included in the
reports. All process and production data will be recorded by Intrepid Potash, Wendover personnel
for inspection by DAQ and EPA, if requested.

Estimates of Test Parameters

Flow 19,000 fpm
Moisture 4-5 %
Temperature 125o F

Test Procedures

Particulate matter testing will be conducted on the Venturi Scrubber exhaust stack according to
EPA Method 5. The reason for using EPA Method 5 instead of Method 201A for PM10 is because
there are water droplets in the stack exhaust. The back-half of the Method 5 sampling train will be
sampled according to EPA Method 202 as specified in 40 CFR Part 51 Appendix M. Specific
procedures are as follows:

1. The total number of sample points will be 12 according to EPA Method 1. Six points will
be sampled on each port. Test run time will be at least 60 minutes.

2. EPA Method 2 will be used to determine the gas stream velocity. Calibration data for the
geometrically calibrated type “S” pitot tubes are included with this protocol. Dual
inclined/vertical manometers with graduations in .01 of an inch of water will be used.
Direction of gas flow will be checked for gas cyclonics prior to testing.

3. EPA Method 3 will be used to determine the gas stream dry molecular weight if the exhaust
gas is not ambient. An integrated flue gas sample will be taken from the exhaust line after
the dry gas meter orifice during each test run and analyzed at the completion of the test
with a Fyrite to determine the molecular weight of the effluent gas stream. If the exhaust
gas is ambient air then TETCO will use a dry molecular weight of 28.84 lb/lbmol (20.9
percent O2, 79.1 percent N2) in all calculations.

4. EPA Method 4 will be used to determine the gas stream moisture content.

5. The back-half, or condensible particulate matter will be handled according to EPA
Method 202 and will be for informational purposes only.

6. The barometric pressure will be measured with a barometer which is periodically checked
against a mercury barometer. The barometer will be checked prior to testing to assure an
accurate barometric pressure.

7. All current calibration data is submitted with this protocol, except nozzle calibration which
will be done at the test site. Nozzle calibration will be included on the first page of each set
of run sheets for each respective test run. Any calibration that is not current will be
re-calibrated prior to the test dates.

8. The glass fiber filters that will be used conform to the requirements of EPA Method 5.

9. Probe liners will be 316 stainless steel for all Method 5 tests.

10. Test preparation and sample recovery will be performed in the contractor's sampling trailer
or a clean area on Intrepid Potash’s property. The laboratory work and analysis will be
done by the contractor as soon as possible after the test project at 391 East 620 South,
American Fork, Utah.

11. Verbal results will be reported to a representative of Intrepid Potash, Wendover.
The written report will follow within 30 days following the completion of the test.

12. If maintenance or operating problems arise during the test, the test may be stopped. This
determination will be made by Intrepid Potash, Wendover representatives and operating
personnel in consultation with DAQ representatives

APPENDIX A

Facility Schematic
Facility:
Stack Identification:

33'g: Distance of Sample Level to Ground, feet
Intrepid Potach, Wendover
4-5
Venturi Scrubber
15'
15'
a: Distance upstream from next disturbance, feet
b: Distance downstream from last disturbance, feet
Salt DryerType:
Number of Ports
Process
Type:
Control Unit
2
Estimated Temperature, oF
Figure 1. Facilty Schematice Representation
Estimated Velocity, fpm
24.75"
Venturi Scrubber
 Stack Inside Diameter, inches
Estimated Moisture, percent
120
2,600
a
g
b
APPENDIX B

Calibration Data

METHOD 5 DRY GAS METER CALIBRATION USING CRITICAL ORIFICES
1) Select three critical orifices to calibrate the dry gas meter which bracket the expected operating range.
2) Record barometric pressure before and after calibration procedure.
3) Run at tested vacuum (from Orifice Calibration Report), for a period of time
necessary to achieve a minimum total volume of 5 cubic feet.
4) Record data and information in the GREEN cells, YELLOW cells are calculated.
TECHNICIAN:INITIAL FINAL AVG (Pbar)
DATE:12/18/2023 METER SERIAL #:26144 BAROMETRIC PRESSURE (in Hg):25.45 25.45 25.45 IF Y VARIATION EXCEEDS 2.00%,
METER PART #:Console 5 CRITICAL ORIFICE SET SERIAL #:1453S EQUIPMENT ID #:ORIFICE SHOULD BE RECALIBRATED
K'TESTED TEMPERATURES °F ELAPSED
FACTOR VACUUM DGM READINGS (FT3)AMBIENT DGM INLET DGM OUTLET DGM TIME (MIN)DGM DH (1)(2)(3)Y
ORIFICE #RUN #(AVG)(in Hg)INITIAL FINAL NET (Vm)INITIAL FINAL INITIAL FINAL AVG q (in H2O)Vm (STD)Vcr (STD)Y VARIATION (%)DH@
1 0.8137 10 61.712 70.918 9.206 73 99 110 85 90 96.0 8.25 2.70 7.4955 7.4023 0.988 1.536
2 0.8137 10 70.918 77.963 7.045 73 107 112 90 91 100.0 6.25 2.70 5.6950 5.6078 0.985 1.525
3 0.8137 10 77.963 92.694 14.731 73 110 115 91 94 102.5 13.00 2.70 11.8552 11.6643 0.984 1.518
AVG = 0.985 -0.08
1 0.5317 13 39.754 44.884 5.130 72 75 84 67 74 75.0 7.25 1.10 4.3210 4.2546 0.985 1.513
2 0.5317 13 44.884 53.841 8.957 72 83 95 74 81 83.3 12.50 1.10 7.4298 7.3356 0.987 1.490
3 0.5317 13 53.841 61.606 7.765 72 94 100 81 85 90.0 10.75 1.10 6.3619 6.3086 0.992 1.472
AVG = 0.988 0.17
1 0.3307 13 92.841 100.319 7.478 75 81 85 78 83 81.8 16.75 0.40 6.2076 6.0966 0.982 1.410
2 0.3307 13 100.319 110.209 9.890 75 85 94 83 88 87.5 22.00 0.40 8.1236 8.0074 0.986 1.395
3 0.3307 13 110.209 117.677 7.468 75 94 98 88 91 92.8 16.50 0.40 6.0759 6.0056 0.988 1.382
AVG = 0.985 -0.08
AVERAGE DRY GAS METER CALIBRATION FACTOR, Y = 0.986
AVERAGE DH@ = 1.471
(1)=Net volume of gas sample passed through DGM, corrected to standard conditions
K1 =17.64 oR/in. Hg (English), 0.3858 oK/mm Hg (Metric)
Tm =Absolute DGM avg. temperature (oR - English, oK - Metric) DH@ = 0.75 q DH Vm(std)
Vcr(std) Vm
(2)=Volume of gas sample passed through the critical orifice, corrected to standard conditions
Tamb =Absolute ambient temperature (oR - English, oK - Metric)
K' = Average K' factor from Critical Orifice Calibration REFERENCE IN OUT
(3)=DGM calibration factor 32 33 32
72 73 73
203 203 202
TEMPERATURE SENSORS oF
2024 Pre-Calibration
Console #5
30
19
12
Joseph Wells
ENVIRONMENTAL SUPPLY COMPANY
USING THE CRITICAL ORIFICES AS CALIBRATION STANDARDS:
The following equations are used to calculate the standard volumes of air passed through the DGM, Vm (std), and the critical orifice, Vcr(std), and the DGM calibration factor, Y. These equations are automatically calculated in the spreadsheet above.
()2 ()
Type S Pitot Tube Inspection Data
Date:Pitot Tube Identification:
Technician:
Dt=0.375 Is PA = PB ?
Is 1.05 • Dt  PA & PB  1.50 • Dt ?
PA = 0.479
PB =0.479
a1 < 10o a1 = o
a2 < 10o a2 = o
b1 < 5o b1 = o
b2 < 5o b2 = o
Z  0.125 in.Z = in.
W W  0.03125 in.W = in.
W > 3 inches W = in.
Z > 3/4 inch Z = in.
Y ≥ 3 inches Y = in.
The pitot tube meets the specifications for a calibration factor of 0.84?Yes
Reference:
TemperatureSource Reference Sensor
(Medium)(oF)(oF)
Probe AIR 64 64
AIR 64 63
ICE WATER 33 33
BOIL WATER 204 205
SILICONE OIL
Heat Check 248
Temperature Sensor Calibration
1
0
1Stack
Omega CL3512A
Probe Yes
Yes
Continuity Check
Temperature TemperatureDifference
(oF)
0
in.
in.
Yes
Yes
0.002
4
0.875
3 3/4
1/16/2024 38 G
M. McNamara
in.
0.018
1
1
2
1
b2
b1
B
A
w
Dt
PA
PB
Date:1/2/24 Calibrator:Reference:
Temperature Temperature
Source Difference
(Medium)(oF)
Water 0
Water -2
Water 0
Water -2
Water 0
Water -1
Water 0
Water -2
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water -1
Water 0
Water -1
Water 0
Water 0
Water 0
Water 0
Water 0
Water -1
Water 0
Water -1
Water 0
Water 0
Water 1
Water 0
Water 0
Water -2
Water 0
Water -1
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
202
33 33
Impinger Out K 33 33
203 203
33 33
Impinger Out J
Impinger Out H
Impinger Out I
33
203
33
203
33
203
33
203
203
201
33
G
H
Oven (3)33 33
203 203
Oven (4)33
203
Oven 33 33
203 203
Oven 33 33
33
203 202
Oven (3)
A
201203
33
Oven (3)33 33
Oven (4)
Thermocouple
Location
203 201
Impinger Out F 33 33
203
203
203
203 202
203 203
33
33
Impinger Out G
203 201
Oven (3)33
203 203
33 33
203Oven (4)
203
Impinger Out D 33 33
203 203
Impinger Out E 33 34
203 203
203
33 33
203Impinger Out B
Impinger Out C 33 33
203 202
202
Impinger Out A 33 33
203
Oven (3)
Oven (4)
TETCO
Sample Box Temperature Sensor Calibration
B
C 203 203
33 33
33 33
203
33 33
Xuan N. Dang Omega CL3512A
Unit ID Reference
(oF)
Sensor
(oF)
Temperature
33
D
E
Oven 33 33
203 202F
Oven (4)
Balance Denver Instruments, Model A-250, SN B045284
Weights Used Troemner Weight Set,
SN 98-115146
Certified Weight Measured Weight Difference
grams grams grams
0.1000 0.1000 0.0000
0.5000 0.5000 0.0000
1.0000 1.0000 0.0000
10.0000 10.0000 0.0000
50.0000 50.0001 -0.0001
100.0000 100.0000 0.0000
120.0000 120.0001 -0.0001
150.0000 150.0000 0.0000
Technician Michael McNamara
TETCO
Annual Balance Calibration Check
Date 1/23/24