DAQ-2025-001514

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. 800 346-3128
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-271-25
Site ID 10725 (B5)

Kenneth Banks, Sr. Environmental Compliance Manager
Clean Harbors Aragonite, LLC
P.O. Box 1339
Grantsville, UT 84029-1339

Dear Mr. Banks:

Re: Clean Harbors Aragonite, LLC (Clean Harbors) – Pretest Protocol for Carbon Monoxide
(CO), Carbon Dioxide (CO2), Flow, Nitrogen Oxides (NOx), Oxygen (O2), Sulfur
Dioxide (SO2), and Total Hydrocarbons (THC) Relative Accuracy Test – Tooele County

The Utah Division of Air Quality (DAQ) reviewed Clean Harbors pretest protocol dated March 7,
2025. The proposed test shall be performed under the following conditions:

Clean Harbors monitoring system to be certified:

Main Stack
Channel Manufacturer Model # Monitor SN
NOx #1 Thermo Scientific 42i - HL 0614216782
CO Low #1 Servomex XENTRA 4900 653204
O2 #1 Servomex XENTRA 4900 4021
CO2 #1 Servomex XENTRA 4900 653204
THC #1 Thermo Scientific 51i-HT 1434964304
SO2 #1 Servomex XENTRA 4900 4021

NOx #2 Thermo Scientific 42i - HL 0614216783
CO low #2 Servomex XENTRA 4900 653305
O2 #2 Servomex XENTRA 4900 4022
CO2 #2 Servomex XENTRA 4900 653305
THC #2 Thermo Scientific 51i-HT 1203299856
SO2 #2 Servomex XENTRA 4900 4022

NOx #2b Thermo Scientific 42i - HL 0836633949
CO low #2b Servomex XENTRA 4900 653205
/ % Ú Û Û Ù Û Þ
DAQC-271-25
Page 2

Main Stack
Channel Manufacturer Model # Monitor SN
O2 #2b Servomex XENTRA 4900 652525
CO2 #2b Servomex XENTRA 4900 653205
THC #2b Thermo Scientific 51i-HTa 1203299855
SO2 #2b Servomex XENTRA 4900 652525

Alliance Technical Group will conduct a relative accuracy/performance specification test on
Clean Harbors continuous monitoring system.

Relative accuracy must be determined in the units of the emission standard or equivalent units of
the emission standard, i.e., tons/year shall be tested in pounds/hour.

The DAQ understands that Alliance Source Testing’s staff will conduct testing as follows:

Test Date Point
Source Parameter EPA Reference Method
May 6, 2025 Main
Stack
CO, CO2, NOx, O2, SO2, and
THC
1, 2, 3A, 4, 6 or 6C, 7E, 10, and
25A

• Reference Method 1 - Sample and Velocity Traverses for Stationary Point Sources as
outlined in 40 CFR 60 Appendix A shall be used to determine the location and number
of sampling points as applicable.

• Reference Method 2 - Determination of Stack Gas Velocity and Volumetric Flow Rate
– (Type S Pitot Tube) as outlined in 40 CFR 60 Appendix A.

• Reference Method 3A - Determination of Oxygen and Carbon Dioxide Concentrations
in Emissions from Stationary Point Sources – (Instrumental Analyzer Procedure) as
outlined in 40 CFR 60 Appendix A.

• Reference Method 4 - Determination of Moisture Content in Stack Gases as outlined in
40 CFR 60 Appendix A shall be used to determine the stack gas moisture content.

• Reference Method 6C - Determination of Sulfur Dioxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.

• Reference Method 7E - Determination of Nitrogen Oxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix
A.

• Reference Method 10 - Determination of Carbon Monoxide Emissions from Stationary
Point Sources – (NDIR Instrumental Procedure) as outlined in 40 CFR 60 Appendix A.
DAQC-271-25
Page 3

• Reference Method 25A - Determination of Total Gaseous Organic Concentration
Using a Flame Ionization Analyzer as outlined in 40 CFR 60 Appendix A. Zero drift
and calibration drift checks are required at the beginning and end of each run.

• Deviations - The Division of Air Quality must be notified of and approve deviations of
the Reference Method test. Any deviation from these conditions without approval from
the DAQ may constitute rejection of these tests.

Acceptance of a protocol does not relieve the owner/operator and the testing contractor
from strict adherence to all applicable EPA methods, DAQ policies, Utah Air Quality
Rules (UAQR), and methods approved by the Director. Any deviation from EPA
methods, DAQ policies, UAQR, and methods approved by the Director must be
addressed separately and express written consent given prior to commencement of
testing.

• Field data (Point Source emission data and test data) shall be turned over to the DAQ
in a timely manner for review.

• The Director will determine the relative accuracy of each monitoring system based on
Point Source continuous emission monitoring data and test data acquired by the staff
member of the DAQ during the test.

• All test reports must be submitted to the Director not later than 60 days after
completion of the test.

• The test report shall include all raw calibration data and raw emission data with date
and time stamps.

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number.

2. Raw stack test data and continuous monitor data with date and time stamps.

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

DAQC-271-25
Page 4

2. During testing, the Point Source combusted fuels, used raw materials, and maintained
process conditions representative of normal operations, and operated under such other
relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements and
information contained in the report are true, accurate, and complete.

Should you have any questions concerning this matter, contact me at [phone] or by email
at [e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

RL:jl

cc: Tooele County Health Department
Alliance Technical Group
* $ . # ( ) - — - @ @ v A ? A D ? H w C A ˜
Rob Leishman Jr