DAQ-2025-000211

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-021-25
Site ID 10742 (B1)

Todd Stubbs
Intrepid Potash Wendover, LLC
P.O. Box 1208
Moab, UT 84532

Dear Mr. Stubbs:

Re: Compliance Advisory – Intrepid Potash Wendover, LLC – Wendover Potash Plant –
Condition II.B.4.a of Approval Order DAQE-AN107420014-19 – Tooele County

On January 8, 2025, a representative of the Utah Division of Air Quality (DAQ) reviewed the
report of a stack test conducted November 11, 2024, of the Venturi Wet Scrubber at Intrepid
Potash Wendover, LLC Wendover Potash Plant in Tooele County, UT. The DAQ observed an
exceedance of the particulate matter concentration limits, which may be a violation of Condition
II.B.4.a of Approval Order DAQE-AN107420014-19.

Intrepid Potash Wendover, LLC is required to comply with the above regulations. A written
response to this letter is required within ten (10) business days of receipt of this letter.

Additional details about the above observations and regulations are attached to this letter. Please
contact Paul Bushman at 385-232-4132 or [e-mail] if you have any questions about
this letter.

Sincerely,

Chad Gilgen, Manager
Minor Source Compliance Section

CG:PB:jl

cc: Tooele County Health Department

January 14, 2025
DAQC-021-25
Page 2

Potential Violation(s)
On January 8, 2025, an inspector from the DAQ reviewed the report of a stack test conducted
November 11, 2024, of the venturi wet scrubber at Intrepid Potash Wendover, LLC Wendover
Potash Plant in Tooele County, UT.

At the time of the inspection, the DAQ documented the following potential violation of a
failed stack test. The observed particulate matter emissions were:

0.054 grains/dscf
3.694 lb/hr

This is in exceedance of the particulate matter emissions of Condition II.B.4.a of Approval
Order DAQE-AN107420014-19.

AO Conditions/Rules
Condition II.B.4.a of Approval Order DAQE-AN107420014-19 dated July 22, 2019

Emissions to the atmosphere at all times from the indicated emission points shall not exceed the following rates and concentrations: Source: venturi wet scrubber Pollutant: PM10 6.0 lb/hr and 0.05 grains/dscf (68°F, 29.92 in Hg)

The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ.
You are responsible for complying with the Utah Air Conservation Rules. There are possible
administrative and civil penalties for failing to do so. Section 19-2-115 of the Utah Code
Annotated provides that violators of the Utah Air Conservation Act and/or any order issued there
under may be subject to a civil penalty of up to $10,000 per day for each violation.

The written response to this CA will be considered in resolving the deficiencies documented in
this letter. It may include information demonstrating compliance with the regulations or a
schedule to bring your company back into compliance with the applicable regulations. The DAQ
will review your response and this CA may be revised as a result of that review. Failure to
respond in writing within ten (10) business days of receipt of this CA will be considered in any
subsequent enforcement action and the assessment of penalties.

Possible DAQ actions to resolve a CA include: No Further Action Letter, Warning Letter, Early
Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or
Notice of Violation and Order to Comply.

This CA does not limit or preclude the DAQ from pursuing enforcement options concerning this
inspection. Also, this CA does not constitute a bar to enforcement action for conditions that the
DAQ did not observe or evaluate, or any other conditions found during future inspections.

A meeting may be requested to discuss this CA. Please contact Paul Bushman at 385-232-4132 or
[e-mail] if you would like to request a meeting or if you have any questions about
this letter.