DAQ-2025-000854

SM conrpliancc a,^,,,,,,U14Al-|Ul W fuf"f fC
REVIEWED
ENERGY ,,,r l6(7J CB\)
Initials:
fanuary 29,2025
Attn: Mr, Chad Gilgen, &
New Source Performance Standards Contact
Department of Environmental Quality
Division of Air Quality
P.O. Box 744820
Salt Lake city, UT 84714-4820
RE: NSPS UUU & NSPS OOO 2024 2nd Semiannual Reports
40 CFR 560.7351560.736; UAC R307'210
SM Energy Company - Anderson Sand Mine
AO: DAQE-GN16187 0002-24
Project Number: N 161870002
Mr. Gilgen & New Source Performance Standards Contact:
1700 Lincoln Street
Suite 320O
Denver. Colorado 80203
303.861.8140
303.851.0934
SM-Energy.com
ENVIRONMENTAL QUALIW
FEB - 3 2025
DIVISION OFAIR QUALITY
SM Energy Company (SM) owns the approved sand dryer and crusher for the processing facility at
the Bundick Mine, formally the Anderson Sand Mine, Project Number N161870001. The Division
of Air Quality (DAQ) issued the Approval Order (AO) for the Anderson Sand Mine on September
LO,ZO24 IDAQE-AN16787OOO7-24), The AO was originally issued to XCL SandCo, LLC, and then
transferred to SM on October 2,2024 with AO: DAQE-GN161870002-24 and Project Number:
N161870002. SM contracts a third-party, Ramsey Hill Exploration, LLC (RHEx), to operate the
Bundick Mine.
The sand 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
UUUJ, The sand dryer is rotary design controlled by a dedicated cyclone and fabric filter baghouse'
The crusher is subject to 40 CFR, Part 60 Subpart OOO - Standards of Performance for Nonmetallic
Mineral Processing Plants (NSPS OOO). The crusher also is controlled by a dedicated spray bar, as
needed, upon visual observations and checks. Pursuant to NSPS UUU and NSPS OOO, 560.735 and S
60.676,respectively, SM and RHEx submits this semiannual summary of control device operating
parameters from October 10 to December 37,2024, in which no exceedances were observed.
Reportable exceedances for the sand dryer control device operating parameters are described in
NSPS UUU, $60.735[c)(1). The Anderson Sand Mine sand dryer utilizes a dry control device;
therefore, 560.735(c)(2) and (3) do not apply. During this period, the baghouse for the dryer was
operated at levels consistent with manufacturer specifications. An initial test for sand dryer and
crusher is due in 2025 and will be coordinated through the DAQ for protocol approval beforehand.
For semiannual reporting purposes, NSPS UUU and NSPS OOO require the following:
NSPS UUU, $60.735(c):
(c) Each owner or operator shall submit written reports semionnually of exceedances of
control device operating parameters required to be monitored by S 60.734 of this subpart, For
the purpose ofthese repor$, exceedances are defined as follows:
(1) All 6-minute periods during which the averoge opacity from dry control devices is greater
than 700/o;
DEPARTMENT OF
Page 2 of 2
SM NSPS UUU & NSPS OOO 20242^d SemiannualReport
January 29,2024
NSPS OOO, $60.676(d):
(d) After the initial performance test of a wet scrubber (or sproy bar), the owner or operotar
shall submit semionnual reports to the Administrator of occurrences when the measurements
ofthe scrubber pressure loss and liquid flow rate decrease by more than 30 percent from the
average determined during the most recent performance tesL
NSPS UUU $60.73a(c) specifically exempts indusrial rotary sand 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, SM and RHEx have developed voluntary internal procedures to check baghouse
operating parameters and conduct a brief visual and auditory inspection to confirm baghouses and
spray bar are operating properly, once per shift. These observations are qualitative checks, which
are performed along with required differential pressure drop readings once per day of operation,
Based upon this information, maintenance, and differential pressure drop readings, there were no
exceedances to report from October 10 to December 31,2024, pursuant to opacity standards in
NSPS UUU and NSPS OOO.
Should the DAQ have any questions with this semiannual report, please contact Eric Sturm, with Air
Regulations Consulting, LLC (ARC) at 402.877.7 887 or [e-mail].
Sincerely, ,a),MZ:
Mike Cina,
RHEx, Director of Operations
Eric Sturm, ARC Principal, Sr. Consultant
Ryan Sokolowski, SM Air Quality Specialist
Cc: