DAQ-2024-010869

1

DAQC-976-24
Site ID 10251 (B4)
MEMORANDUM

TO: STACK TEST FILE – INTREPID POTASH – MOAB, LLC – Salt and Potash
Production Facility

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

FROM: Paul Bushman, Environmental Scientist

DATE: September 27, 2024

SUBJECT: Source: Three (3) Engart Wet Scrubber Exhausts – DS-01, DS-02, and DS-03
Location: Potash Road, Grand County, UT
Contact: Todd Stubbs: 435-259-1282
Tester: TETCO
Site ID #: 10251
Permit/AO #: Approval Order (AO) DAQE-AN102510004-13, dated October 1, 2013
Subject: Review of Pretest Protocol received September 26, 2024

On September 26, 2024, DAQ received a test notification for the testing of three (3) Engart Wet Scrubber
Exhausts – DS-01, DS-02, and DS-03 located at the Salt and Potash Production Facility on Potash Road,
Moab, Grand County, UT. Testing will be performed the week of November 4, 2024, to determine compliance
with the emission limits found in condition II.B.2.d of AO DAQE-AN102510004-13.

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

DEVIATIONS: Per source request, and in accordance with EPA RM 202, Section
1.2(a), testing for condensable particulate matter will be omitted. The
addition of straightening vanes proposed in the pretest protocol are in
accordance with the requirements of RM 5D, Section 8.1.2. 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 – Moab, LLC test notification and pretest protocol.
COMPLIANCE EMISSION TESTING PROTOCOL
INTREPID POTASH- MOAB, LLC, MOAB, UTAH
ENGART WET SCRUBBER EXHAUSTS DS-01, DS-02 AND DS-03

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-Moab, LLC Todd Stubbs 435- 259-1282
P O Box 1208
Moab, UT 84532

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

Facility and Location

Intrepid Potash-Moab, LLC, is located north of Moab in Grand County, Utah. This facility
produces potash and industrial salt. The sources to be tested are the three (3) Engart Wet
Scrubber Exhausts DS-01, DS-02 AND DS-03. Engart Scrubbers DS-01 and DS-02 control
emissions from four (4) production classifiers. Engart Scrubber DS-03 serves a variety of
production equipment.

Test Objective

The test objective is to comply with the facility’s approval order number DAQE- AN102510004-
13 and NSPS Subpart OOO requirements. Testing procedures will include accumulating
process and production data as well as testing for PM10 particulate matter emissions using EPA
Method 5 with all captured matter counted as PM10.

Previous stack flow and temperature measurements have been made on these sources. The stack
temperatures were near or below 85 °F. Since the stack temperatures are a factor of the season
and weather and not process oriented, and the Engart scrubbers no longer control any emissions
from the rotary kiln/tumbler, it is proposed that condensable particulate matter not be measured
on these sources as per EPA Method 202 section 1.2(a).

The allowable PM10 emission limits for each source are 0.013 gr/dscf and 2.05 lb/hr.

Test Date and Time

It is planned to complete all testing the week of November 4, 2024. The testing crew will arrive
and set up on the 4th and begin testing that afternoon if production permits. A pre-test meeting
may be scheduled by EPA, DAQ or Intrepid Potash, Moab.

Process Data and Instrumentation

All process and instrumentation data will be made available to DAQ personnel. The scrubber
water flow rate will be recorded during each test run. Production rates will be recorded by
Intrepid Potash, Moab personnel. The facility will run at normal conditions.

Test Procedures

Particulate matter testing will be conducted on the 3 Engart Scrubber exhaust stacks 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 on DS-03 will be sampled according to EPA Method 202 as specified in 40 CFR Part 51
Appendix M. Specific procedures are as follows:

1. The sample locations and the number of sample points will comply with the requirements
of EPA Method 1. Stack inside diameter measurement and upstream and downstream
disturbance distances for each source are outlined in the chart below. Two test ports
located at 90 degrees to each other are installed on each stack.

Source ID DS-01 DS-02 DS-03
Stack inside diameter, inches 35.5 35.5 35.5
Distance upstream from disturbance, inches 23 36 25
Distance downstream from disturbance, inches 21 22 33

2. Test run duration will be at least 60 minutes for the Method 5 tests. To comply with
NSPS Subpart OOO requirements, sample volume will be a minimum of 60 dscf.

3. EPA Method 2 will be used to determine the gas stream velocity. Type “S” pitot tubes
will be used with a Cp factor of 0.84. Dual inclined/vertical manometers with
graduations of 0.01 inches of water will be used. If the flows are below .05 inches of
water a more sensitive manometer will be used. The graduation marks on it are .005
inches of water. Direction of gas flow will be checked for gas cyclonics prior to testing.
Previous testing of the exhaust flows on the Engart Scrubbers, indicated a stratification
and cyclonic flow pattern that made them untestable. To correct the cyclonic flows
“egg-crate” type straightening vanes were installed. The dimensions of the straightening
vane cells were 7 x 7 inches and 16 inches in length. The “egg-crate” straightening vanes
were portable and were moved from stack to stack prior to testing. Further flow
measurements demonstrated that the cyclonic flows were corrected. Flows remained
somewhat stratified.

4. 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.

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

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

7. 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.

8. 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.

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

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

11. Test preparation and sample recovery will be performed in the contractor’s sampling
trailer or a clean area on Intrepid Potash’s property. The Method 5 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.

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

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

Site Access

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

Test Site

The test areas shall include applicable control rooms, stacks and associated areas, and the area
around the contractor’s testing trailer for preparation and clean up.

Estimates of Test Parameters

DS-01 DS-02 DS-03
Velocity fpm 1,100 1,100 1,000
Moisture % 2 2 3
Temperature o F 70 75 83

Potential Hazards

Moving Equipment Yes
Hot Equipment Yes
Chemical Potash, Corrosive
Other Noise

Quality Assurance

All testing and analysis in these tests will be conducted according to Methods 5, 9, 202 and
appropriate sections of the EPA Quality Assurance Handbook for Air Pollution Measurement
Systems Vol. III.

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.

APPENDIX A

Source Schematics

Facility:
Stack Identification:

Engart Scrubber
2Number of Ports
Process
Type:
Control Unit
Type:Potash Production
2Estimated Moisture, percent
70Estimated Temperature, oF
1,100Estimated Velocity, fpm
21b: Distance downstream from last disturbance, inches
35g: Distance of Sample Level to ground, feet
35.5 Stack Inside Diameter, inches
Intrepid Potash-Moab LLC
Engart Wet Scrubber DS-01
a: Distance upstream from next disturbance, inches 23a
g
b
Egg crate installed
cell size 7x7 inches
16 inches deep
Figure 1. Facility Schematic Representation
Facility:
Stack Identification:

Engart Scrubber
2Number of Ports
Process
Type:
Control Unit
Type:Potash Production
2Estimated Moisture, percent
75Estimated Temperature, oF
1,100Estimated Velocity, fpm
22b: Distance downstream from last disturbance, inches
35g: Distance of Sample Level to ground, feet
35.5 Stack Inside Diameter, inches
Intrepid Potash-Moab LLC
Engart Wet Scrubber DS-02
a: Distance upstream from next disturbance, inches 36a
g
b
Egg crate installed
cell size 7x7 inches
16 inches deep
Figure 1. Facility Schematic Representation
Facility:
Stack Identification:

Engart Scrubber
2Number of Ports
Process
Type:
Control Unit
Type:Potash Production
3Estimated Moisture, percent
83Estimated Temperature, oF
1,000Estimated Velocity, fpm
33b: Distance downstream from last disturbance, inches
35g: Distance of Sample Level to ground, feet
35.5 Stack Inside Diameter, inches
Intrepid Potash-Moab LLC
Engart Wet Scrubber DS-03
a: Distance upstream from next disturbance, inches 25a
g
b
Egg crate installed
cell size 7x7 inches
16 inches deep
Figure 3. Facility Schematic Representation
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:12/19/2022 METER SERIAL #:27863 BAROMETRIC PRESSURE (in Hg):25.35 25.35 25.35 IF Y VARIATION EXCEEDS 2.00%,
METER PART #:Console 4 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 11 832.125 842.747 10.622 71 72 88 69 71 75.0 10.00 3.20 8.9659 8.9541 0.999 1.895
2 0.8137 11 842.747 853.441 10.694 71 84 85 71 74 78.5 10.00 3.20 8.9680 8.9541 0.998 1.883
3 0.8137 11 853.441 864.062 10.621 71 84 82 74 74 78.5 10.00 3.20 8.9067 8.9541 1.005 1.883
AVG = 1.001 0.31
1 0.5317 13 806.381 813.332 6.951 71 78 77 71 72 74.5 10.00 1.20 5.8390 5.8509 1.002 1.656
2 0.5317 13 813.332 820.303 6.971 71 77 78 71 71 74.3 10.00 1.20 5.8585 5.8509 0.999 1.657
3 0.5317 13 820.303 827.282 6.979 71 75 78 71 72 74.0 10.00 1.20 5.8680 5.8509 0.997 1.658
AVG = 0.999 0.15
1 0.3307 13 892.625 897.750 5.125 68 73 72 70 70 71.3 11.76 0.45 4.3221 4.2917 0.993 1.603
2 0.3307 13 897.750 903.142 5.392 68 72 72 70 70 71.0 12.38 0.45 4.5494 4.5180 0.993 1.604
3 0.3307 13 903.142 908.557 5.415 68 72 73 70 70 71.3 12.43 0.45 4.5666 4.5362 0.993 1.603
AVG = 0.993 -0.46
AVERAGE DRY GAS METER CALIBRATION FACTOR, Y = 0.998
AVERAGE DH@ = 1.716
(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 #4
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, V m (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:
Temperature
Source 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 Temperature
Difference
(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
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 = 0.476
PB =0.476
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:
Temperature
Source Reference Sensor
(Medium)(oF)(oF)
Probe AIR 63 62
AIR 64 62
ICE WATER 33 34
BOIL WATER 204 204
SILICONE OIL
1/16/2024 51 G
M. McNamara
in.
0.002
2
0
1
1
1
in.
in.
Yes
Yes
0.004
5
1
3 1/2
Heat Check 248
Temperature Sensor Calibration
2
1
0Stack
Omega CL3512A
Probe Yes
Yes
Continuity Check
Temperature Temperature
Difference
(oF)
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