DAQ-2025-001341

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DAQC-238-25
Site ID 11594 (B1)

MEMORANDUM

TO: FILE – TOOELE ARMY DEPOT (TEAD) – Hazardous Waste Incinerator

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: February 4, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Tooele County,
FRS ID# UT0000004904500006

INSPECTION DATE: January 30, 2025

SOURCE ADDRESS: Highway 36, South of Tooele, Tooele County, Utah

MAILING ADDRESS: Tooele Army Depot
JMTE – BOV, Building 501
1 Tooele Army Depot
Tooele, UT 84074-5003

SOURCE CONTACT: Lonnie Brown: 435-833-2526 – Environmental Engineer
[e-mail]

Logan Stapert: 409-828-2301 – Environmental Engineer
[e-mail]

OPERATING STATUS: Rotary kiln / Deactivation Furnace / Hazard Waste Incenerator (HWI) was
Operating at time of the inspecton.

PROCESS DESCRIPTION: TEAD operates a rotary kiln furnace which flashes explosive residue
from projectiles. Pollution controls include a cyclone, an afterburner, and
ceramic baghouse. Feed materials are loaded by operators into a push-off
box which is controlled by the timer to allow only the predetermined
feed rate. The material drops onto the feed belt which drops the material
into the front end of the kiln. The material passes through the fuel oil
fired counter current kiln where the heat ignites and separates the shell.
Any ash or metal components that are not entrained in the flue gas are
discharged at the end of the kiln to collection bins. The flue gas goes
through the discharge duct to a preliminary cyclone where any heavy
entrained particles or sparks are collected and dropped to a tipping valve
and collection box. The gasses continue on to the afterburner and then
are ducted to the ceramic baghouse and then to the ambient air.
Additionally, the kiln is inside a total enclosure with any ambient air
from the enclosure entering to the baghouse. The whole system is
equipped with a continuous monitoring system (CMS) that measures all
required process parameters such as flows, pressure, levels, etcetera.

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The MACT standard for hazardous waste incinerators applies to this
source. The disassembly line functions as a recycling process of spent
ordinance shells and its propellants. The brass part of the shells are
recovered and sold as scrap.
APPLICABLE
REGULATIONS: Title V Operating Permit # 4500006005, dated October 22, 2024, and
revised October 22, 2024

MACT (Part 63), A: NESHAP General Provisions
MACT (Part 63), EEE: NESHAP for Hazardous Waste Combustors

SOURCE INSPECTION
EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the potential to
emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990 (CAA) except those
terms and conditions that are specifically designated as "State Requirements." (R307-415-6b)

Status: This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance with
this permit. (See also Provision I.E, Application Shield)

Status: This is a statement of fact and not an inspection item.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit noncompliance
constitutes a violation of the Air Conservation Act and is grounds for any of the following:
enforcement action; permit termination; revocation and reissuance; modification; or denial of a
permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been necessary
to halt or reduce the permitted activity in order to maintain compliance with the conditions of this
permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that the
Director may request in writing to determine whether cause exists for modifying, revoking and
reissuing, or terminating this permit or to determine compliance with this permit. Upon request, the
permittee shall also furnish to the Director copies of records required to be kept by this permit or,
for information claimed to be confidential, the permittee may furnish such records directly to the
EPA along with a claim of confidentiality. (R307-415-6a(6)(e))

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I.C.4

This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing
of a request by the permittee for a permit modification, revocation and reissuance, or termination, or
of a notification of planned changes or anticipated noncompliance shall not stay any permit
condition, except as provided under R307-415-7f(1) for minor permit modifications.
(R307-415-6a(6)(c))
Status: This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under "Enforceable Dates
and Timelines" at the front of this permit. An application may be submitted early for any reason.
(R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be accepted for
processing, but shall not be considered a timely application and shall not relieve the permittee of
any enforcement actions resulting from submitting a late application. (R307-415-5a(5))

I.D.4

Permit expiration terminates the permittee's right to operate unless a timely and complete renewal
application is submitted consistent with R307-415-7b (see also Provision I.E, Application Shield)
and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))
Status: The permit expires October 22, 2029. Application for renewal is due April 22, 2029.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's failure to
have an operating permit will not be a violation of R307-415, until the Director takes final action on
the permit renewal application. In such case, the terms and conditions of this permit shall remain in
force until permit renewal or denial. This protection shall cease to apply if, subsequent to the
completeness determination required pursuant to R307-415-7a(3), and as required by R307-415-
5a(2), the applicant fails to submit by the deadline specified in writing by the Director any
additional information identified as being needed to process the application. (R307-415-7b(2))

Status: Application for renewal is due April 22, 2029.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is held
invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))
Status: This is a statement of fact and not an inspection item.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

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I.G.2

The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))
Status: In compliance – The annual emission fee invoice payment was received on September 25,
2024, before the due date of October 20, 2024. See attached email dated February 5, 2025.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))
Status: This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable permits,
emissions trading and other similar programs or processes for changes that are provided for in this
permit. (R307-415-6a(8))
Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the permittee
shall allow the Director or an authorized representative to perform any of the following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related activity is
conducted, or where records are kept under the conditions of this permit. (R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under the conditions of
this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control
equipment), practice, or operation regulated or required under this permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of assuring
compliance with this permit or applicable requirements. (R307-415-6c(2)(d))

I.J.2

Any claims of confidentiality made on the information obtained during an inspection shall be made
pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))
Status: In compliance – Required reports and records were made available and no claims of
confidentially were made at time of the inspection.

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I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit shall
contain certification as to its truth, accuracy, and completeness, by a responsible official as defined
in R307-415-3. This certification shall state that, based on information and belief formed after
reasonable inquiry, the statements and information in the document are true, accurate, and complete.
(R307-415-5d)
Status:

Reports and certifications submitted appeared to have certification statements and were
signed by responsible officials (ROs).

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying compliance
with the terms and conditions contained in this permit, including emission limitations, standards, or
work practices. This certification shall be submitted no later than the date shown under
"Enforceable Dates and Timelines" at the front of this permit, and that date each year following
until this permit expires. The certification shall include all the following (permittee may cross-
reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the certification;

I.L.1.b The identification of the methods or other means used by the permittee for determining the
compliance status with each term and condition during the certification period. Such methods and
other means shall include, at a minimum, the monitoring and related recordkeeping and reporting
requirements in this permit. If necessary, the permittee also shall identify any other material
information that must be included in the certification to comply with section 113(c)(2) of the Act,
which prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period covered by the
certification, including whether compliance during the period was continuous or intermittent. The
certification shall be based on the method or means designated in Provision I.L.1.b. The
certification shall identify each deviation and take it into account in the compliance certification.
The certification shall also identify as possible exceptions to compliance any periods during which
compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64
occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

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I.L.2

The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director: (R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance – The initial annual compliance certification for report period January 1, 2024
– December 31, 2024, was received on January 22, 2025, before the due date of January 28,
2025. The report has been revised to include the deviation mentioned in the six-month
monitoring report for report period January 1, 2024 – June 30, 2024, regarding
noncompliance with condition II.B.1.e. The revised annual compliance certification was
deemed acceptable after being received on February 25, 2025. See status of condition I.S.2.c
and Compliance Assistance below. Also, attached email dated February 4, 2025.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any applicable
requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this permit, or
(R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed in this permit.
(R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112, and the
provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable requirements
under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110 prior to or at the time of
issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA Section 408(a).
(R307-415-6f(3)(c))

I.M.2.d

The ability of the Director to obtain information from the source under Utah Code Ann. Section 19-
2-120, and the ability of the EPA to obtain information from the source under the CAA Section 114.
(R307-415-6f(3)(d))
Status: N/A – See section III of this permit.

I.N Reserved.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

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I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.
Status: These are statements of fact and not inspection items (I.O through I.R).

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be retained by the
permittee for a period of at least five years from the date of the monitoring sample, measurement,
report, or application. Support information includes all calibration and maintenance records, all
original strip-charts or appropriate recordings for continuous monitoring instrumentation, and
copies of all reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source shall record
the following information, where applicable: (R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement.

I.S.1.c

Additional record keeping requirements, if any, are described in Section II, Special Provisions.

Status: In compliance – Required records were provided during and after the inspection.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more frequently if
specified in Section II. All instances of deviation from permit requirements shall be clearly
identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible official in
accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i)

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I.S.2.c

The Director shall be notified promptly of any deviations from permit requirements including those
attributable to upset conditions as defined in this permit, the probable cause of such deviations, and
any corrective actions or preventative measures taken. Prompt, as used in this condition, shall be
defined as written notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to breakdowns shall
be reported in accordance with the provisions of R307-107. (R307-415-6a(3)(c)(ii))
I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to the
Director are to be sent to the following address or to such other address as may be required by the
Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b

All reports, notifications or other submissions required by this permit to be submitted to the EPA
should be sent to one of the following addresses or to such other address as may be required by the
Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications, applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance – The required six-month monitoring reports have been submitted for report
periods January 1, 2024 – June 30, 2024, and July 1, 2024 – December 31, 2024. The reports
were deemed acceptable.

The latest deviation notice was receivced on May 28, 2024. The deviation notice explains the
deviation that occurred on May 6, 2024, concerning an equipment malfunction. The report
was not received within 14 days of the deviation because it occurred during the Confirmatory
Performance Test (CFPT) and time was needed for the RO signature. See status of conditions
I.L.1 and Compliance Assistance below. Also, see attached email dated February 4, 2025.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

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I.T.1.a New applicable requirements become applicable to the permittee and there is a remaining permit
term of three or more years. No such reopening is required if the effective date of the requirement is
later than the date on which this permit is due to expire, unless the terms and conditions of this
permit have been extended pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that inaccurate
statements were made in establishing the emissions standards or other terms or conditions of this
permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to assure compliance
with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date of this permit
and are in conflict with existing permit conditions. (R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a Title IV
affected source under the Acid Rain Program. Upon approval by EPA, excess emissions offset plans
shall be deemed to be incorporated into this permit. (R307-415-7g(1)(b))

I.T.3

Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial permit
issuance and shall affect only those parts of this permit for which cause to reopen exists.
(R307-415-7g(2))
Status: This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150, Emission
Inventories. (R307-150)
Status:

In compliance – The 2023 annual emission inventory was submitted on April 11, 2024. The
2024 annual emisison inventory is due by April 15, 2025. See the SLEIS database.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of regulations
promulgated under Title IV of the Act, Acid Deposition Control, both provisions shall be
incorporated into this permit. (R307-415-6a(1)(b))
Status: This is a statement of fact and not an inspection item.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

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II.A.2

APE 1236: APE 1236M1 Deactivation Furnace
The APE 1236M1 deactivation furnace is a rotary furnace used to destroy ammunition ranging from small
arms through 20 mm. The furnace is equipped with a cyclone, diesel oil-fired afterburner, Sodium
Bicarbonate Injection System, high temperature baghouse, fan, and a stack. Located in Building 1320.

Status: In compliance – A natural gas system has been installed for the Deactivation Furnace or Hazard
Waste Incenerator (HWI), (item II.A.2). The diesel and propane fuel systems have been
diconnnected from the furnace. The furnace has strictly operated on natural gas, starting January
6, 2025. The natural gas system was installed and operated prior to submitting the notice of permit
modification, which was received on January 22, 2025. See attached permit modification notice.

However, under 40 CFR 63 Subpart EEE 63.1206(b)(5)(ii), (Hazardous Waste Incinerators) the
source is allowed to make changes if the changes do not affect the emisisons of the deactivation
furnace. This was proven by reviewing the CEMs CO data, which indicated that the furnace
continued to operate, on natural gas, with CO emisisons under 100 ppm. Tooele Army Depot also
conducted a stack test to verify furnace emisison after the natural gas fuel conversion. See status of
condition II.B.1.d, Compliance Assistanc (below) and attached snapshot of the CEMs CO data
dated January 21, 2025.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Condition on APE 1236: APEM1 Deactivation Furnace

II.B.1.a Condition:

The permittee shall comply with all applicable requirements of 40 CFR 63 Subpart EEE including but not
limited to (a)-(f) below:
(a) Emissions limits - (40 CFR 63.1219(a)). The permittee shall not discharge or cause combustion
gases to be emitted into the atmosphere that contain:

(1) For dioxins and furans:

A. For incinerators equipped with either a waste heat boiler or dry air pollution control system,
either:
(i) Emissions of dioxins and furans shall not exceed 0.20 ng TEQ/dscm, corrected to 7
percent oxygen; or
(ii) Emissions of dioxins and furans shall not exceed 0.40 ng TEQ/dscm, corrected to 7
percent oxygen, provided that the combustion gas temperature at the inlet to the initial
particulate matter control device is 400 °F or lower based on the average of the test run
average temperatures. (For purposes of compliance, operation of a wet particulate matter
control device is presumed to meet the 400 °F or lower requirement);

B. Emissions of dioxins and furans shall not exceed 0.40 ng TEQ/dscm, corrected to 7
percent oxygen, for incinerators not equipped with either a waste heat boiler or dry air
pollution control system;

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C. A source equipped with a wet air pollution control system followed by a dry air
pollution control system is not considered to be a dry air pollution control system, and a
source equipped with a dry air pollution control system followed by a wet air pollution
control system is considered to be a dry air pollution control system for purposes of this
standard;

(2) Mercury in excess of 130 micrograms/dscm, corrected to 7 percent oxygen;

(3) Cadmium and lead in excess of 230 micrograms/dscm, combined emissions, corrected to
7 percent oxygen;
(4) Arsenic, beryllium, and chromium in excess of 92 micrograms/dscm, combined
emissions, corrected to 7 percent oxygen;
(5) For carbon monoxide and hydrocarbons, either:

(i) Carbon monoxide in excess of 100 parts per million by volume, over an hourly rolling
average (monitored continuously with a continuous emissions monitoring system), dry
basis and corrected to 7 percent oxygen. If the permittee elects to comply with this carbon
monoxide standard rather than the hydrocarbon standard under paragraph (a)(5)(ii), the
permittee shall also document that, during the destruction and removal efficiency (DRE)
test runs or their equivalent as provided by 40 CFR 63.1206(b)(7), hydrocarbons do not
exceed 10 parts per million by volume during those runs, over an hourly rolling average
(monitored continuously with a continuous emissions monitoring system), dry basis,
corrected to 7 percent oxygen, and reported as propane; or

(ii) Hydrocarbons in excess of 10 parts per million by volume, over an hourly rolling average
(monitored continuously with a continuous emissions monitoring system), dry basis,
corrected to 7 percent oxygen, and reported as propane;

(6) Hydrogen chloride and chlorine gas (total chlorine) in excess of 32 parts per million by volume,
combined emissions, expressed as a chloride (Cl(-)) equivalent, dry basis and corrected to 7
percent oxygen; and
(7) Particulate matter in excess of 0.013 gr/dscf corrected to 7 percent oxygen.

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(b) Destruction and removal efficiency standard (DRE)- (40 CFR §63.1219(c)).

(1) Except as provided in paragraph (b)(2), the permittee shall achieve a destruction and
removal efficiency (DRE) of 99.99% for each principle organic hazardous constituent
(POHC) designated under paragraph (b)(3). The permittee shall calculate DRE for each POHC
from the following equation:

DRE = [1 - (Wout / Win)] x 100%

Where:

Win = mass feedrate of one POHC in a waste feedstream; and

Wout = mass emission rate of the same POHC present in exhaust emissions prior
to release to the atmosphere.

(2) 99.9999% DRE. If you burn the dioxin-listed hazardous wastes F020, F021, F022, F023,
F026, or F027 (see 40 CFR §261.31), you must achieve a DRE of 99.9999% for each POHC that
you designate under paragraph (b)(3). You must demonstrate this DRE performance on POHCs
that are more difficult to incinerate than tetra-, penta-, and hexachlorodibenzo-p-dioxins and
dibenzofurans. You must use the equation in paragraph (b)(1) to calculate DRE for each POHC.
In addition, you must notify the Administrator of your intent to incinerate hazardous wastes F020,
F021, F022, F023, F026, or F027.

(3) Principal organic hazardous constituent (POHC).

(i) You must treat each POHC in the waste feed that you specify under paragraph
(b)(3)(ii) to the extent required by paragraphs (b)(1) and (b)(2).

(ii) The permittee shall specify one or more POHCs that are representative of the most
difficult to destroy organic compounds in your hazardous waste feedstream. The
permittee shall base this specification on the degree of difficulty of incineration of the
organic constituents in the hazardous waste and on their concentration or mass in
the hazardous waste feed, considering the results of hazardous waste analyses or
other data and information.

(c) The permittee shall determiune significant figures according to 40 CFR 63.1219 (d).

(d) The permittee shall comply with the standards according to 40 CFR 63.1206(b).

(e) The permittee shall operate according to the requirerments in 40 CFR 63.1206 (c).

(f) General Provisions - The permittee shall comply with all applicable requirements of 40 CFR 63
Subpart A as given in Table 1 of 40 CFR 63 Subpart EEE.

[Origin 40 CFR 63 Subpart EEE]. [40 CFR 63.1219(a), 40 CFR 63.1219(c), 40 CFR 63.1219(d), 40 CFR
63.1206(b), 40 CFR 63.1206(c)]

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II.B.1.a.1 Monitoring:

The permittee shall comply with all applicable performance testing and monitoring requirements of 40
CFR 63 Subpart EEE including but not limited to those given in 40 CFR 63.1207, 1208, 1209, and 1215.

The permittee shall comply with all applicable requirements of 40 CFR 63 Subpart A as given in Table 1
of 40 CFR 63 Subpart EEE.

II.B.1.a.2 Recordkeeping:

The permittee shall comply with the recordkeeping requirements in Section I of this permit and any
additional recordkeeping requirements of:

(a) 40 CFR 63 Subpart EEE including but not limited to those given in 40 CFR 63.1211.

(b) 40 CFR 63 Subpart A as given in Table 1 of 40 CFR 63 Subpart EEE.

II.B.1.a.3

Reporting:

The permittee shall comply with the reporting requirements in Section I of this permit and any additional
reporting and notification requirements of:

(a) 40 CFR 63 Subpart EEE, as applicable, including but not limited to those given in 40 CFR
63.1207, 1210, 1211, 1212 and 1215.

(b) 40 CFR 63 Subpart A as given in Table 1 of 40 CFR 63 Subpart EEE.
Status: In compliance – The comprehensive performance test (CPT) for the furnace was conducted on
October 23-26, 2021. This test demonstrates compliance with the emission limits found in this
condition and 40 CFR 60, Subpart EEE. The CPT has a five year requirement. The results of the
October 2021 test are as follows:

Test Date Test Method Pollutant Test Results Permit Limit
October 23-26, 2021 23A/PCDD Dioxins & Furans 0.0051 0.20 ng
TEQ/dscm
N/A Mercury N/A 130 ug/dscm
M29 SVM 18 230 ug/dscm
M29 LVM 2.7 92 ug/dscm
CEMs CO 22 100 ppmv (dry)
M25A THC 1.7 10 ppmv (dry)
M26/5 HCl/Cl2 0.56 32 ppmv (dry)
M26/5 PM 0.0011 0.013 gr/dscf
M0010 DRE 99.9985 99.99%

Notes:
- All results corrected to 7% O2.
- Mercury emissions not measured (no mercury is fed to the furnace).
- CO and THC values are highest maximum hourly rolling averages reported during the CPT.

The next CPT will be performed in 2026.

14
The confirmatory performance test (CFPT) was performed on May 26, 2024. The CFPT has a 2.5
year requirement. Which means they are conducted between CPTs. The results of the CFPT,
reviewed at time of the inspection, were found to be in compliance with the permitted limits in this
condition.

The semiannual excessive emission, monitoring and periodic startup, shutdown, and malfuction
reports for the report periods January 1, 2024 - June 30, 2024, and July 1, 2024 - December 31,
2024, have also been submitted according to Subpart EEE.

See status of condition I.S.2

II.B.1.b Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate any permitted plant equipment, including associated air pollution
control equipment, in a manner consistent with good air pollution control practice for minimizing
emissions. Determination of whether acceptable operating and maintenance procedures are being used
will be based on information available to the Director which may include, but is not limited to,
monitoring results, opacity observations, review of operating and maintenance procedures, and inspection
of the source. [Origin: DAQE-AN115940059-20]. [R307-401-4]

II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.b.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance. Records shall
be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.b.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

Status: In compliance – A Daily Operating Log is maintained and daily inspections are conducted by the
furnace staff. Weekly, monthly, and quarterly maintenance is conducted and electronically tracked
in the Sharepoint database. Records were made available for review at time of the inspection.

II.B.1.c Condition:

Hours of operation shall be no greater than 3,340 hours per rolling 12-month period while feeding
hazardous waste (HW). [Origin: DAQE:AN115940059-20]. [R307-401-8]

II.B.1.c.1 Monitoring:

By the 15th day of each month, the permittee shall calculate the total hours of HW operations in the
previous 12 months for the affected emission unit. The hours of HW operations for the affected emission
unit shall be determined by an hour meter and/or a log.

15
II.B.1.c.2 Recordkeeping:

Records of monitoring shall be kept on a daily basis during operations. Results of monitoring shall be
maintained as described in Provision I.S.1 of this permit.

II.B.1.c.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.
Status: In compliance – The HWI operated for 1,709.98 hours for the calander year 2024.

II.B.1.d Condition:

The permittee shall use only #1 or #2 fuel oil as a primary fuel and propane as a pilot fuel. [Origin
DAQE-AN115940059-20]. [R307-401-8]

II.B.1.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.d.2 Recordkeeping:

The permittee shall keep one or more of the following sets of records for the affected emission unit:

(a) Documentation that the burners can only use the fuels listed in this condition;

(b) Documentation that fuels other than those listed in this condition cannot be supplied to the burners
without modification of the fuel supply system; or

(c) Fuel bills or fuel meter readings that demonstrate only the fuels listed in this condition are combusted
in the burners.

If fuel bills or fuel meter readings will be used, the permittee shall review fuel bills or fuel meter readings
at least once per quarter to determine compliance with this condition. The records required by this
condition shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.d.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

Status: N/A – The propane and diesel fuel systems have been removed and replaced with a new natural gas
system. The HWI furnace curenly only operates on natural gas. See status of condition II.A.

II.B.1.e Condition:

Gas residence time shall be no less than 2 seconds in the afterburner during the HW incineration period.
[Origin: DAQE-AN115940059-20]. [R307-401-8]

16
II.B.1.e.1 Monitoring:

In lieu of monitoring gas residence time, the permittee shall monitor stack gas velocity as follows:

(a) Frequency. The stack gas velocity shall be measured at least once every 30 seconds during each HW
incineration period, as defined in this permit. The stack gas velocity data recorder shall be located such
that an inspector/operator can safely read the output.

(b) Calibration. The velocity readings shall be accurate to plus or minus 5 feet per second. The velocity
measurement device shall be calibrated against a primary standard at least once every 12 months. The
primary standard shall be established by the permittee and shall be submitted to the Director for approval.

The permittee shall be considered to be in compliance with gas residence time requirement of this
condition when the stack gas velocity is less than or equal to 70 feet per second.

II.B.1.e.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.e.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

Status: In compliance – Stack gas velocity is continuously monitored by the data recorder. The data
recorder is calibrated annually by Coterie Environmental. Stack gas velocity and calibration
records are maintained. A hardstop interlock reported to be set at 44 feet/second (Ft/S). The stack
gas velocity reading was approximately 34.2 Ft/S at time of the inspection.

II.B.1.f Condition:

Baghouse pressure drop shall be no less than 1.0 inches of water column.
[Origin: DAQE-AN115940059-20]. [R307-401-7]

I.B.1.f.1 Monitoring:

The permittee shall monitor the pressure drop across the baghouse as follows:

(a) Frequency. The pressure drop shall be measured at least once every 30 seconds during each HW
incineration period, as defined in this permit. The pressure drop data recorder shall be located such that an
inspector/operator can safely read the output.

(b) Calibration. The pressure drop readings shall be accurate to plus or minus 0.5 inches of water column.
The pressure drop measurement device shall be calibrated against a primary standard at least once every
12 months. The primary standard shall be established by the permittee and shall be submitted to the
Director for approval.

II.B.1.f.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

17
II.B.1.f.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

Status: In compliance – The baghouse pressure drop (pd) is continuously monitored by the data recorder.
The data recorder is calibrated annually by Coterie Environmental. Baghouse pd and calibration
records are maintained. According to the records, the baghouse pd has not been less than 1.0 inches
of water column since the last inspection. A waste feed cut off keeps the pd from going below 1.0
inches of water colmn. The pd readings was approximately 9.0 inches of water column at time of
the inspection.

II.B.1.g Condition:

Visible emissions shall be no greater than 10 percent opacity from the high temperature ceramic bag
stack. [Origin: DAQE-AN115940059-20]. [R307-401-8]

II.B.1.g.1 Monitoring:

An opacity determination shall be conducted once in each quarter that the affected emission unit is
operated. The opacity determination shall be conducted by a certified observer in accordance with 40
CFR 60, Appendix A, Method 9.

II.B.1.g.2 Recordkeeping:

Results of monitoring and all data required by 40 CFR 60, Appendex A, Method 9 shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.1.g.3

Reporting:

There are no reporting requirements for this provision except those specified in Section I of this permit.

Status: In compliance – Visible emission observations (VEOs) are conducted monthly by the HWI staff.
The staff is EPA Method 9 certified. Reviewed records indicated 0% opacity from the baghouse
stack.

II.C Emissions Trading
(R307-415-6a(10))

Not applicable to this source.

II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

II.E Source-specific Definitions: There are no source-specific definitions in this permit.

18
SECTION III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with
Provision I.M, Permit Shield:

III.A. (Permit Shield)

This regulation is not applicable to the Permitted Source for the following reason(s): A shield has
not been requested [Last updated February 20, 2020]

SECTION IV: ACID RAIN PROVISIONS

IV.A This source is not subject to Title IV. This section is not applicable.

EMISSION INVENTORY: The 2023 annual Emission Inventory was submitted on April 11,
2024.

The 2024 annual Emission Invenmtory should be submitted by
April 15, 2025.

PREVIOUS ENFORCEMENT
ACTIONS: March 17, 2020 – ESA was signed and paid, for exceeding the
dioxin/furan limit on March 13-14, 2019. Results of retesting on
January 21-22, 2020, have been reviewed and deemed
acceptable.

May 2, 2022 – Warning Letter, for submitting annual emisison
fee late (C-577-22).

19
COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with the conditions of permit 4500006005, dated
October 22, 2024, and revised October 22, 2024, at time of
inspection.

HPV STATUS: N/A

COMPLIANCE
ASSISTANCE: 1) Discussed revising annual compliance certification report.
See status of condition I.L.1.

2) Discussed why the deviation notice regarding the May 6,
2024, deviation was not submitted within 14 days of the
deviation. See status of condition I.S.2.c.

3) Discussed Subpart EEE 63.1206 (b)(5)(ii) in regards to permit
modification regarding new furnace natural fuel system.
See status of conditons II.A and II.B.1.d.

RECOMMENDATIONS FOR
NEXT INSPECTION: Obtain a vehicle pass at building 100, before entering the TEAD.
Fridays are not considered to be a work day. Look for AO or
revised TV Permit concerning new natural gas fuel system.
Inspect as usual.

ATTACHMENT: VEO Form
Correspondence
Snapshot of CEMs CO Data
Permit Modification Notice
Joe Rockwell <[e-mail]>
Title V Inspection
4 messages
Brown, Lonnie D CIV USARMY JMC (USA) <[e-mail]>Thu, Jan 30, 2025 at 12:01 PM
To: "[e-mail]" <[e-mail]>
Here you go

Thanks,

Lonnie Brown
Tooele Army Depot
Chief of Env.
[e-mail]
Office: [phone]
Emergency: [phone]

2024-0729 SEMI Jan 24-June 24 with Cert to the DAQ stamped.pdf
445K
Joe Rockwell <[e-mail]>Tue, Feb 4, 2025 at 2:13 PM
To: "Brown, Lonnie D CIV USARMY JMC (USA)" <[e-mail]>, [e-mail]
Hi Lonnie and Logan -
Thanks for the Semi Annual Periodic Startup, Shutdown, Malfunction and Six Month Monitoring reports, for the first part of
2024.
I did not catch this at time of the inspection, but it looks like the deviation notice regarding the May 6, 2024, deviation was
not submitted within 14 days of the deviation. I might have to send a Warning letter.
Thanks for revising the 2024 ACC report and sending me the Conformity test results. Looking forward to receiving them.
I'm currently looking into the gas leak and if it qualifies as a deviation.
Thank you for your cooperation.
Joe Rockwell | Environmental Scientist
Phone: [phone]
2/13/25, 3:30 PM State of Utah Mail - Title V Inspection
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1822701636333576254&simpl=msg-f:18227016363335762…1/4

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Brown, Lonnie D CIV USARMY JMC (USA) <[e-mail]>Tue, Feb 4, 2025 at 2:39 PM
To: Joe Rockwell <[e-mail]>, "Stapert, Logan T CIV USARMY JMC (USA)" <[e-mail]>
At the time the flow meter deviation, I was in the middle of the CfPT and I could get away to complete the
report. The following week I submitted the report as shown in the attached email, the problem arose when it
when for signature. It took time to have the commander sign the letter and submit it to the state.

Lonnie Brown
TEAD Env.
Office: [phone]

From: Joe Rockwell <[e-mail]>
Sent: Tuesday, February 4, 2025 2:13 PM
To: Brown, Lonnie D CIV USARMY JMC (USA) <[e-mail]>; Stapert, Logan T CIV USARMY JMC
(USA) <[e-mail]>
Subject: Re: Title V Inspecon

Hi Lonnie and Logan -

Thanks for the Semi Annual Periodic Startup, Shutdown, Malfunction and Six Month Monitoring reports, for the first part of
2024.

I did not catch this at time of the inspection, but it looks like the deviation notice regarding the May 6, 2024, deviation was
not submitted within 14 days of the deviation. I might have to send a Warning letter.

Thanks for revising the 2024 ACC report and sending me the Conformity test results. Looking forward to receiving them.

I'm currently looking into the gas leak and if it qualifies as a deviation.

Thank you for your cooperation.
2/13/25, 3:30 PM State of Utah Mail - Title V Inspection
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1822701636333576254&simpl=msg-f:18227016363335762…2/4
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

[Quoted text hidden]
---------- Forwarded message ----------
From: "Brown, Lonnie D CIV USARMY JMC (USA)" <[e-mail]>
To: "Mccall, David K CIV USARMY JMC (USA)" <[e-mail]>
Cc:
Bcc:
Date: Thu, 16 May 2024 09:27:26 -0700
Subject: 2024-05-06 Deviation Report-Flow RATA
Please review this letter.
3 attachments
2024-05-06 Deviation Report-Flow RATA.docx
76K
smime.p7s
6K
2024-05-06 Deviation Report-Flow RATA.eml
114K
Joe Rockwell <[e-mail]>Tue, Feb 4, 2025 at 10:01 PM
To: [e-mail], [e-mail]
Hey Lonnie -
Thank you for explaining the situation, regarding the deviation notice. I will use it in the inspection memo.
I will get back with you tomorrow concerning the gas leak.
Thanks
Joe Rockwell | Environmental Scientist
Phone: [phone]

2/13/25, 3:30 PM State of Utah Mail - Title V Inspection
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1822701636333576254&simpl=msg-f:18227016363335762…3/4
195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
2/13/25, 3:30 PM State of Utah Mail - Title V Inspection
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1822701636333576254&simpl=msg-f:18227016363335762…4/4
Joe Rockwell <[e-mail]>
Potential Deviation
5 messages
Stapert, Logan T CIV USARMY JMC (USA) <[e-mail]>Tue, Feb 4, 2025 at 7:18 AM
To: "[e-mail]" <[e-mail]>
Cc: "Brown, Lonnie D CIV USARMY JMC (USA)" <[e-mail]>
Good Morning Joe,

Yesterday afternoon we had a gas leak from one of the fittings on the afterburner fuel train on the new natural gas system
on the APE Deactivation Furnace. We have yet to encounter this type of situation and wanted to reach out and see if this
is something that we need to report as a deviation or what?

Please advise,

Logan Stapert
Tooele Army Depot
Environmental Engineer
[e-mail]
Office: [phone]

Joe Rockwell <[e-mail]>Wed, Feb 5, 2025 at 10:41 PM
To: "Stapert, Logan T CIV USARMY JMC (USA)" <[e-mail]>
Cc: [e-mail]
Hi Logan -
Still working on an answer to your question regarding the NG leak.
We may have discussed this when I was on-site. When was the Natural Gas System installed on the APE Deactivation
Furnace? I know it was recent, but I'm not sure of the date?
Thank You,
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
2/13/25, 3:36 PM State of Utah Mail - Potential Deviation
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1823136754242889386&simpl=msg-f:18231367542428893…1/4
You don't often get email from [e-mail]. Learn why this is important

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Stapert, Logan T CIV USARMY JMC (USA) <[e-mail]>Thu, Feb 6, 2025 at 12:04 PM
To: Joe Rockwell <[e-mail]>
Cc: "Brown, Lonnie D CIV USARMY JMC (USA)" <[e-mail]>
Joe,

We began feeding with the natural gas system on January 6th.

Thank you,

Logan Stapert
Tooele Army Depot
Environmental Engineer
[e-mail]
Office: [phone]

From: Joe Rockwell <[e-mail]>
Sent: Wednesday, February 5, 2025 10:41 PM
To: Stapert, Logan T CIV USARMY JMC (USA) <[e-mail]>
Cc: Brown, Lonnie D CIV USARMY JMC (USA) <[e-mail]>
Subject: Re: Potenal Deviaon

Hi Logan -

Still working on an answer to your question regarding the NG leak.

We may have discussed this when I was on-site. When was the Natural Gas System installed on the APE Deactivation
Furnace? I know it was recent, but I'm not sure of the date?

Thank You,
2/13/25, 3:36 PM State of Utah Mail - Potential Deviation
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1823136754242889386&simpl=msg-f:18231367542428893…2/4
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

[Quoted text hidden]
Joe Rockwell <[e-mail]>Thu, Feb 6, 2025 at 11:32 PM
To: "Stapert, Logan T CIV USARMY JMC (USA)" <[e-mail]>
Thanks Logan.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Joe Rockwell <[e-mail]>Thu, Feb 13, 2025 at 3:36 PM
To: "Stapert, Logan T CIV USARMY JMC (USA)" <[e-mail]>
Cc: [e-mail]
Do not worry about the natural gas leak.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

2/13/25, 3:36 PM State of Utah Mail - Potential Deviation
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1823136754242889386&simpl=msg-f:18231367542428893…3/4
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
2/13/25, 3:36 PM State of Utah Mail - Potential Deviation
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1823136754242889386&simpl=msg-f:18231367542428893…4/4
Joe Rockwell <[e-mail]>
Title V Fee Payments
2 messages
David Beatty <[e-mail]>Wed, Feb 5, 2025 at 11:24 AM
To: Joe Rockwell <[e-mail]>
Tooele Army Depot 09/25/24 $15,734.00 Paid in Full
Western Electric Zirconium 10/21/24 $3,922.26 Paid in Full
--
David P. Beatty, P.E.
Manager | Operating Permits Section
Phone: [phone]
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Joe Rockwell <[e-mail]>Wed, Feb 5, 2025 at 3:08 PM
To: David Beatty <[e-mail]>
Thanks David.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
2/28/25, 4:08 PM State of Utah Mail - Title V Fee Payments
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1823242863407210296&simpl=msg-f:18232428634072102…1/1
Joe Rockwell <[e-mail]>
Furnace Change Over
2 messages
Brown, Lonnie D CIV USARMY JMC (USA) <[e-mail]>Mon, Feb 10, 2025 at 12:49
PM
To: "[e-mail]" <[e-mail]>
Cc: "Stapert, Logan T CIV USARMY JMC (USA)" <[e-mail]>
TEAD believe that by changing the furnace from fuel oil to natural gas meets the regulations
Under subpart EEE 63.1206(b)(5)(ii)
Changes that will not affect compliance. If you determine that a change will not adversely affect compliance with the
emission standards or operating requirements, you must document the change in the operating record upon making such
change. You must revise as necessary the performance test plan, Documentation of Compliance, Notification of
Compliance, and start-up, shutdown, and malfunction plan to reflect these changes.

Thanks,

Lonnie Brown
Tooele Army Depot
Chief of Env.
[e-mail]
Office: [phone]
Emergency: [phone]

Joe Rockwell <[e-mail]>Mon, Feb 10, 2025 at 2:27 PM
To: "Brown, Lonnie D CIV USARMY JMC (USA)" <[e-mail]>
Thanks Lonnie.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

2/13/25, 3:41 PM State of Utah Mail - Furnace Change Over
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1823701284086472094&simpl=msg-f:18237012840864720…1/2
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
2/13/25, 3:41 PM State of Utah Mail - Furnace Change Over
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1823701284086472094&simpl=msg-f:18237012840864720…2/2
Joe Rockwell <[e-mail]>
State Inspection
2 messages
Brown, Lonnie D CIV USARMY JMC (USA) <[e-mail]>Thu, Feb 13, 2025 at 9:31 AM
To: "[e-mail]" <[e-mail]>
Cc: "Stapert, Logan T CIV USARMY JMC (USA)" <[e-mail]>
Attached is a hour snap shot of January 21, 2025. If you look at the highlighted Hourly Totals lbs./hr. you can see it
increasing, which tells me the furnace was feeding. Then the highlighted CO show zero all the way down. Most of the
time this is typical, if we start seeing an increase then we tune our burners and corrects the issue.
Book2.xlsx
23K
Joe Rockwell <[e-mail]>Thu, Feb 13, 2025 at 1:43 PM
To: "Brown, Lonnie D CIV USARMY JMC (USA)" <[e-mail]>
This is a real help!
Thank You,
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
2/28/25, 4:20 PM State of Utah Mail - State Inspection
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1823960487080976229&simpl=msg-f:18239604870809762…1/1
Joe Rockwell <[e-mail]>
Tooele Army Depot - TV Permit Modification Notice
3 messages
Joe Rockwell <[e-mail]>Fri, Feb 7, 2025 at 2:17 PM
To: Tad Anderson <[e-mail]>
Hi Tad -
Hope all is well.
I inspected the Tooele Army Depot on Jan 30th. At the time of the inspection I learned that a rotary kiln incinerator natural
gas system had been installed and started operations on Jan 6th. The DAQ received the permit modification notice on
Jan 22, 2025, regarding the new gas system. Scott Hanks informed me that you are currently working on an AO for the
permit modification. In the meantime, Tooele Army Depot reported that the new gas system had a leak on Feb 3rd. They
want to know if the leak qualifies as a permit deviation? How can the leak be a deviation if it is not yet permitted! What
is your take?
Thanks,
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
Tad Anderson <[e-mail]>Fri, Feb 7, 2025 at 2:54 PM
To: Joe Rockwell <[e-mail]>, Jacob Hurley <[e-mail]>
Joe,
TEAD North the incinerator is currently in the process of being updated for the conversion. You are correct to think that
the source cannot have a deviation if it is not in the permit. The source is out of compliance since they have installed and
operating the kiln on natural gas. Jacob Hurley is permitting this project and I have a feeling that it will get
expedited since it is considered a permit violation. I have included Jacob in this email so he is aware. I would be
interested in what we do compliance wise in this instance.
Thanks,
Tad
[Quoted text hidden]
2/13/25, 3:39 PM State of Utah Mail - Tooele Army Depot - TV Permit Modification Notice
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-a:r8438016157788826788&simpl=msg-a:r860987448963338…1/2
--
Tad D Anderson | Environmental Engineer | New Source Review Section
Phone: [phone]
Joe Rockwell <[e-mail]>Wed, Feb 12, 2025 at 3:49 PM
To: Tad Anderson <[e-mail]>
Thanks Tad.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Fri, Feb 7, 2025 at 2:17 PM Joe Rockwell <[e-mail]> wrote:
[Quoted text hidden]
2/13/25, 3:39 PM State of Utah Mail - Tooele Army Depot - TV Permit Modification Notice
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-a:r8438016157788826788&simpl=msg-a:r860987448963338…2/2
Joe Rockwell <[e-mail]>
Tooele Army Depot - TV Permit Modification Notice
2 messages
Joe Rockwell <[e-mail]>Fri, Feb 7, 2025 at 1:01 PM
To: Scott Hanks <[e-mail]>
Hey Scott -
It was really nice talking with you today. It has been a while.
Attached is the permit modification notice regarding the new natural gas system, for the rotary kiln incinerator, at the
Tooele Army Depot.
Have a great weekend.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
Tooele Army Depot - Deactivation Furnace Modification.pdf
7199K
Scott Hanks <[e-mail]>Fri, Feb 7, 2025 at 2:34 PM
To: Joe Rockwell <[e-mail]>
Thanks Joe. Have an awesome weekend!
Scott Hanks
Environmental Engineer | Operating Permits Section
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
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2/28/25, 4:17 PM State of Utah Mail - Tooele Army Depot - TV Permit Modification Notice
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-a:r-5255164757925664056&simpl=msg-a:r-51394908812181…1/1