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Home My WebLink AboutDAQ-2025-0015641 DAQC-CI105350001-25 Site ID 10535 (B1) MEMORANDUM TO: FILE – LINDE INC. – Magna Gas Production Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jordan Garahana, Environmental Scientist DATE: February 20, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: February 13, 2025 SOURCE LOCATION: 12385 West SR 201 Magna, UT 84044 SOURCE CONTACTS: Rebecca Murray, Safety Health and Environment Specialist 385-347-7459 rebecca.murray@linde.com OPERATING STATUS: Operating normally at the time of inspection PROCESS DESCRIPTION: Linde produces oxygen and nitrogen for Kennecott and other companies cryogenic air separation. Air from the atmosphere is vented through a filter house, compressed, cooled to cryogenic temperatures (-300 to -350°F), and then fractionally distilled to separate out the oxygen and nitrogen. A regeneration heater is used to heat gaseous nitrogen. The heated nitrogen is used to regenerate re-purifier beds that absorb moisture and carbon dioxide from the incoming air. Two vaporizer heaters are used to heat water to temperatures high enough to allow vaporization in the pressure tubes. The heated water is pumped to the cryogenic oxygen/nitrogen product vaporizer unit. This heated water provides indirect heat transfer within the vaporizer to convert the cold liquid oxygen and nitrogen into gaseous form. The vaporizer is used less than 10% of the time and its main purpose is to provide a backup whenever the air separation facilities are down. Most of the finished products are transferred by pipeline to Kennecott, although some is trucked off site to other companies. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN105350003-19, dated April 4, 2019 NSPS (Part 60) Dc : Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, NSPS (Part 60) A: General Provisions, * - ) - # ) 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Linde Inc. - Magna Gas Production Plant 685 South Chevron Way 12385 West SR 201 North Salt Lake, UT 84054 Magna, UT 84044 SIC Code: 2813: (Industrial Gases) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, 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. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. No breakdowns have occurred since the previous inspection. Records are maintained as required and were provided as requested. No limits appear to have been exceeded. No Emission Inventory is required at this source. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Praxair Inc. Air Separation Plant II.A.2 Regeneration Heater One (1) 6.9 MMBtu/hr natural gas-fired heater 3 II.A.3 Vaporization Heaters Two (2) 17.3 MMBtu/hr (each) natural gas-fired heaters Including low NOx burners Status: In Compliance. No unapproved equipment was observed at the time of inspection. Some additional information gathered at the time of inspection includes: A Safety Kleen brands parts washer is onsite and operating. A 2.75 MMBtu Maxon Model 400 brand heater is onsite. II.B Requirements and Limitations II.B.1 The heaters shall be subject to the following requirements II.B.1.a Visible emissions from each of the stacks for the Regeneration Heater and the Vaporization Heaters shall not exceed 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed at the time of inspection. See the attached VEO form for additional information. II.B.1.b Operation of the Vaporization Heaters shall not exceed 2,000 hours per rolling 12-month period. [R307-401-8] II.B.1.b.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records of operating time shall be kept for all periods when the plant is in operation. The records of operating time shall be kept on a daily basis. Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. The operations log shall show the start and end times of any operation day. [R307-401-8] Status: In Compliance. The rolling 12-month total from February 2024 to January 2025, for hours of operation for the vaporization heaters is as follows: 681 hours of operation in the heaters. Runtime is recorded in a digital log. Rolling monthly totals are calculated by the 20th day of each month. The log and total were viewed onsite at the time of inspection. See the attachments section for a copy of the rolling 12-month total. II.B.1.c The owner/operator shall use only natural gas as a fuel in the regeneration and vaporization heaters. [R307-401-8] Status: In Compliance. Natural gas is the only fuel source utilized in the heaters. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. 4 NSPS (Part 60) Dc : Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: In Compliance. The source maintains records of operation for the vaporization heaters. The heaters operate only on natural gas and the limit set within this AO was not exceeded. NSPS (Part 60) A: General Provisions Status: Compliance with subpart A is determined by compliance with applicable federal subparts. In Compliance with Subpart Dc. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305] Status: In Compliance. The area is paved and no emissions were observed at the time of inspection. NOx and CO Emission Controls for Natural Gas-Fired Boilers 2.0-5.0 MMBtu [R307-315] Status: Not Applicable. The source has a 2.75 MMBtu heater onsite that applies to this rule. Currently, this heater has not been modified after the compliance date within this rule. The source was notified of the rule at the time of inspection. NOx and CO Emission Controls for Natural Gas-Fired Boilers Greater than 5.0MMBtu [R307-316] Status: Not Applicable. The heaters onsite are subject to this rule should they undergo any modifications to the burners. Currently, these heaters have not been modified after the compliance date within this rule. The source was notified of this rule at the time of inspection. Degreasing and Solvent Cleaning Operations [R307-335] Status: In Compliance. Source operates a Safety Kleen parts washer. The washer was in use at the time of inspection and was operated appropriately. There is a sign by the parts washer stating the lid should be closed when not in use. 5 EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from Linde Inc. - Magna Gas Production Plant on the Approval Order (AO) DAQE-AN105350003-19, dated April 4, 2019. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Carbon Monoxide 3.74 Carbon Monoxide 5.34 Nitrogen Oxides 4.45 Nitrogen Oxides 4.66 Particulate Matter - PM10 0.34 Particulate Matter - PM10 0.48 Particulate Matter - PM2.5 0.34 Particulate Matter - PM2.5 0.48 Sulfur Dioxide 0.03 Sulfur Dioxide 0.04 Volatile Organic Compounds 0.35 Volatile Organic Compounds 0.24 Hazardous Air Pollutant PTE lbs/yr Formaldehyde (CAS #50000) 6 Generic HAPs (CAS #GHAPS) 240 Generic HAPs (CAS #GHAPS) 2 Hexane (CAS #110543) 160 Lead (CAS #7439921) 0 PREVIOUS ENFORCEMENT ACTIONS: None within the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN105350003-19, dated April 4, 2019, the overall status is: In Compliance. In Compliance with the conditions listed within the AO. Facility is well maintained and records were made available upon request HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Hard hat, protective eyewear, and hearing protection are required to tour the facility. Inspect at the normal frequency. NSR RECOMMENDATIONS: Include the Safety Kleen brand parts washer to the equipment list. ATTACHMENTS: Applicable Supporting Documentation Included