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HomeMy WebLinkAboutDAQ-2025-0017561 DAQC-305-25 Site ID 10645 (B4) MEMORANDUM TO: STACK TEST FILE – STAKER PARSON COMPANIES dba HALES SAND AND GRAVEL, INCORPORATED – Centerfield Asphalt Plant – Sanpete County THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Kyle Greenberg, Environmental Scientist DATE: March 21, 2025 SUBJECT: Source: Barber Greene DM-70 Hot Mix Asphalt Plant Location: 400 North 350 East, Centerfield, UT 84622 Contact: Chris Rose: 385-400-2119 Tester: Montrose Air Quality Services, LLC Site ID #: 10645 Permit/AO #: Approval Order DAQE-390-89, dated February 20, 1986 Subject: Review of Pretest Protocol dated March 14, 2025 On March 14, 2025, DAQ received a protocol for testing of a Barber Greene DM-70 Hot Mix Asphalt Plant at the Centerfield Asphalt Plant in Sanpete County, UT. Testing will be performed on May 6, 2025, to determine compliance with the emission limits found in conditions 2 and 5 in Approval Order DAQE-390-89, dated February 20, 1986. PROTOCOL CONDITIONS: 1. RM 1 used to determine sample velocity traverses: OK 2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK 3. RM 3 used to determine dry molecular weight of the gas stream: OK 4. RM 4 used to determine moisture content: OK 5. RM 5 used to determine particulate matter emissions: OK 6. RM 9 used to determine visible emissions opacity: OK 7. RM 202 used to determine condensable particulate matter: OK DEVIATIONS: None. CONCLUSION: The protocol appears to be acceptable. RECOMMENDATION: The methods proposed in the pretest protocol are sufficient to determine particulate matter emissions from the Barber Greene DM- 70 Hot Mix Asphalt Plant. It is recommended that the pretest protocol be determined as acceptable. ATTACHMENTS: Staker Parson Companies’ Test Notification Letter and Pretest Protocol 4 ' - ) - " Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT March 14, 2025 Subject: Compliance Test Plan, Barber Greene DM-70 HMAP Facility Name/Location: Staker Parson Materials & Construction - Centerfield, UT 84622 Montrose Document No.: GP081AS-053204-PP-967 Enclosed please find the compliance test plan for the above-referenced facility and source. The test plan documents the details of the testing that will be performed by Montrose Air Quality Services, LLC (Montrose) at Staker Parson Materials & Construction’s Centerfield, UT Barber Green DM-70 HMAP on May 6, 2025. The following distribution was provided for this project. Name Company/Agency No. of copies Electronic Copy Chris Rose Staker Parson Materials & Construction 89 West 13490 South, Suite 100 Draper, UT 84020 One (1) Electronic Copy Emailed PDF, March 14, 2025 (Chris.Rose@stakerparson.com) Chad Gilgen UDEQ, Division of Air Quality 195 North 1950 West Salt Lake City, UT 84116 Not Sent N/A ***COPIES HAVE NOT BEEN SENT TO ANY REGULATORY AGENCIES*** Please do not hesitate to contact our office at 801-372-7049 if you have any questions. Sincerely, Montrose Air Quality Services, LLC Beckie Hawkins District Manager 6823 S 3600 W Spanish Fork, UT 84660 BH/jd Source Test Plan for 2025 Compliance Testing Staker Parson Materials & Construction Barber Greene DM 70 Hot Mix Asphalt Plant (HMAP) Near Centerfield, UT 84622 February 20th, 1986 UDEQ Approval Order Prepared For: Staker Parson Materials & Construction 89 West 13490 South, Suite 100 Draper, UT 84020 Prepared By: Montrose Air Quality Services, LLC 6823 South 3600 West Spanish Fork, UT 84660 For Submission To: Utah Department of Environmental Quality, Division of Air Quality 195 North 1950 West Salt Lake City, UT 84116 Document Number: GP081AS-053204-PP-967 Proposed Test Dates: May 6, 2025 Test Plan Submittal Date: March 14, 2025 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT Review and Certification I certify that, to the best of my knowledge, the information contained in this document is complete and accurate and conforms to the requirements of the Montrose Quality Management System and ASTM D7036-04. Signature: Date: March 14, 2025 Name: Beckie Hawkins Title: District Manager I have reviewed, technically and editorially, details and other appropriate written materials contained herein. I hereby certify that to the best of my knowledge the presented material is authentic and accurate and conforms to the requirements of the Montrose Quality Management System and ASTM D7036-04. Signature: Date: March 14, 2025 Name: Joby Dunmire Title: Reporting QC Specialist IV 2 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT Table of Contents Section Page 1.0 Introduction ...................................................................................................... 5 1.1 Summary of Test Program ........................................................................... 5 1.2 Applicable Regulations and Emission Limits .................................................... 6 1.3 Key Personnel ............................................................................................ 7 2.0 Plant and Sampling Location Descriptions .............................................................. 8 2.1 Process Description, Operation, and Control Equipment ................................... 8 2.2 Flue Gas Sampling Location ......................................................................... 9 2.3 Operating Conditions and Process Data .......................................................... 9 2.4 Plant Safety .............................................................................................. 10 2.4.1 Safety Responsibilities ....................................................................... 10 2.4.2 Safety Program and Requirements ...................................................... 11 3.0 Sampling and Analytical Procedures ..................................................................... 12 3.1 Test Methods ............................................................................................ 12 3.1.1 EPA Method 1, Sample and Velocity Traverses for Stationary Sources ....... 12 3.1.2 EPA Method 2, Determination of Stack Gas Velocity and Volumetric Flow Rate (Type S Pitot Tube) .................................................................... 12 3.1.3 EPA Method 3, Gas Analysis for the Determination of Dry Molecular Weight 13 3.1.4 EPA Method 4, Determination of Moisture Content in Stack Gas ............... 14 3.1.5 EPA Methods 5 and 202, Determination of Particulate Matter from Stationary Sources and Dry Impinger Method for Determining Condensable Particulate Emissions from Stationary Sources ...................................... 15 3.1.6 EPA Method 9, Visual Determination of the Opacity of Emissions .............. 17 3.2 Process Test Methods ................................................................................. 17 4.0 Quality Assurance and Reporting ......................................................................... 18 4.1 QA Audits ................................................................................................. 18 4.2 Quality Control Procedures .......................................................................... 18 4.2.1 Equipment Inspection and Maintenance ............................................... 18 4.2.2 Audit Samples .................................................................................. 18 4.3 Data Analysis and Validation ....................................................................... 18 4.4 Sample Identification and Custody ............................................................... 19 4.5 Quality Statement ..................................................................................... 19 4.6 Reporting ................................................................................................. 19 4.6.1 Example Report Format ..................................................................... 20 4.6.2 Example Presentation of Test Results ................................................... 20 3 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT List of Appendices Appendix A Supporting Information .......................................................................... 22 Appendix A.1 Units and Abbreviations ................................................................. 23 Appendix A.2 Accreditation Information/Certifications ........................................... 32 Appendix A.3 Exhaust Stack Schematic ............................................................... 34 Appendix A.4 February 20th, 1986 UDEQ Approval Order ....................................... 35 Appendix “S” Field Work Safety Plan ......................................................................... 41 List of Tables Table 1-1 Summary of Test Program and Proposed Schedule ......................................... 5 Table 1-2 Reporting Units and Emission Limits ............................................................ 6 Table 1-3 Test Personnel and Responsibilities .............................................................. 7 Table 2-1 Sampling Location ..................................................................................... 9 Table 4-1 Example Emissions Results - Barber Greene DM-70 Drum Mix HMAP, Near Centerfield, Utah .............................................................................................. 21 List of Figures Figure 3-1 EPA Methods 5/202 Sampling Train ........................................................... 16 Figure 4-1 Typical Report Format ............................................................................. 20 4 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 1.0 Introduction 1.1 Summary of Test Program Staker Parson Materials & Construction contracted Montrose Air Quality Services, LLC (Montrose) to perform a compliance emissions test program on the following unit located near Centerfield, UT: Barber Greene DM-70 Drum Mix Hot Mix Asphalt Plant (HMAP). The tests are being conducted to determine compliance with Permit Conditions 2., 5., and 6. contained in the UDEQ Approval Order issued February 20th, 1986, as well as 40 CFR Part 60, Subpart I emission limits. The specific objectives are to: x Measure emissions of PM at the outlet of the Barber Greene DM-70 Drum Mix HMA Plant, controlled by a venturi wet scrubber. x Visually determine the opacity of emissions (VEOs) at the outlet of the Barber Greene DM-70 Drum Mix HMA Plant, controlled by a venturi wet scrubber. x Conduct the test program with a focus on safety. Montrose will provide the test personnel and the necessary equipment to measure emissions as outlined in this test plan. Facility personnel will provide the process and production data to be included in the final report. A summary of the test program and proposed schedule is presented in Table 1-1. Table 1-1 Summary of Test Program and Proposed Schedule Proposed Test Date Unit ID/ Source Name Activity/Parameters Test Methods No. of Runs Duration (Minutes) May 6, 2025 Barber Greene DM-70 Drum Mix HMA Plant Traverse Points EPA M1 -- -- Stack Gas Velocity, Volumetric Flow Rate EPA M2 3 60 Oω, Nω, CO, COω EPA M3 3 60 HωO EPA M4 3 60 PM EPA M5/202 3 60 Opacity EPA M9 3 6 5 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT To simplify this test plan, a list of Units and Abbreviations is included in Appendix A. Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not defined. Please refer to the list for specific details. 1.2 Applicable Regulations and Emission Limits The results from this test program are presented in units consistent with those listed in the applicable regulations or requirements. The reporting units and emission limits are presented in Table 1-2. Table 1-2 Reporting Units and Emission Limits Unit ID/ Source Name Parameter Reporting Units Emission Limit Emission Limit Reference Barber Greene DM-70 Drum Mix HMA Plant PM gr/dscf 0.04 40 CFR Part 60, Subpart I PM gr/dscf 0.03 February 20th, 1986 UDEQ AO Condition 5. Opacity % 20 February 20th, 1986 UDEQ AO Condition 2. 6 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 1.3 Key Personnel A list of project participants is included below: Facility Information Source Location: Staker Parson Barber Greene DM-70 Drum Mix HMA Plant Near Centerfield, UT 84622 Project Contact: Chris Rose Role: Environmental Coordinator Company: Staker Parson Telephone: 385-400-2119 Email: chris.rose@stakerparson.com Agency Information Regulatory Agency: Utah Department of Environmental Quality, Division of Air Quality Agency Contact: Chad Gilgen Telephone: 385-306-6500 Email: cgilgen@utah.gov Testing Company Information Testing Firm: Montrose Air Quality Services, LLC Contact: Beckie Hawkins Austin Tramell Title: District Manager Field Project Manager Telephone: 801-372-7049 801-794-2950 Email: behawkins@montrose-env.com AuTramell@montrose-env.com Laboratory Information Laboratory: MAQS Spanish Fork City, State: Spanish Fork, UT Method: US EPA Method 5 and 202 Table 1-3 details the roles and responsibilities of the test team. Table 1-3 Test Personnel and Responsibilities Role Primary Assignment Additional Responsibilities Field Project Manager Operate mobile lab Facility interface, test crew coordination Client Project Manager Coordinate Project Post-test follow up Technician Execute stack platform responsibilities Preparation, support PM 7 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 2.0 Plant and Sampling Location Descriptions 2.1 Process Description, Operation, and Control Equipment Staker Parson Companies owns and operates the Barber Greene DM-70 Drum Mix HMA Plant located near Centerfield, Utah in Sanpete County. Asphaltic concrete paving is a mixture of well graded, high-quality aggregate and liquid asphaltic cement which is heated and mixed in measured quantities to produce bituminous pavement material. Aggregate constitutes 92 weight percent of the total mixture. Aside from the amount and grade of asphalt used, mix characteristics are determined by the relative amounts and types of aggregate used. A certain percentage of fine aggregate (% less than 74 micrometers in physical diameter) is required for the production of good quality asphaltic concrete. The drum mix process simplifies the conventional process by using proportioning feed controls in place of hot aggregate storage bins, vibrating screens, and the mixer. Aggregate is introduced at the end of the revolving drum mixer, and the asphalt is injected midway along the drum. The burner sits at the opposite end of where the aggregate enters the drum mixer. A variable flow asphalt pump is linked electronically to the aggregate belt scales to control mix specifications. The hot mix is discharged from the revolving drum mixer into surge bins or storage bins. Emissions from the asphalt drum mixer are vented to a venturi wet scrubber before being emitted to the atmosphere. Plant production shall not exceed 500,000 tons per year as per February 20th, 1986 UDEQ AO Condition 14. 8 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 2.2 Flue Gas Sampling Location Actual stack measurements, number of traverse points, and location of traverse points will be evaluated in the field as part of the test program. Table 2-1 presents the anticipated stack measurements and traverse points for the sampling locations listed. Table 2-1 Sampling Location Sampling Location Stack Inside Diameter (in.) Distance from Nearest Disturbance Number of Traverse Points Downstream EPA “B” (in./dia.) Upstream EPA “A” (in./dia.) Barber Greene DM-70 Drum Mix HMA Plant 60 120 / 2 30 / 0.5 Isokinetic: 24 (12/port) Sample location measurements are verified in the field to conform to EPA Method 1. Acceptable cyclonic flow conditions are confirmed prior to testing using EPA Method 1, Section 11.4. Appendix A presents a stack schematic. 2.3 Operating Conditions and Process Data Emission tests are performed while the source and air pollution control device are operating at the conditions required by the permit. The unit will be tested when operating at the minimum of 90% of the permitted operating capacity. Plant personnel are responsible for establishing the test conditions and collecting all applicable unit-operating data. Data to be collected includes the following parameters: x Total asphaltic material throughput, tons per hour (ton/hr or tph) x Pressure drop across the HMA venturi wet scrubber (inches of water column or in. wc) x Asphalt mix temperature, degrees Fahrenheit 9 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 2.4 Plant Safety Montrose will comply with all safety requirements at the facility. The facility Client Sponsor, or designated point of contact, is responsible for ensuring routine compliance with plant entry, health, and safety requirements. The Client Sponsor has the authority to impose or waive facility restrictions. The Montrose test team leader has the authority to negotiate any deviations from the facility restrictions with the Client Sponsor. Any deviations must be documented. 2.4.1 Safety Responsibilities Planning x Montrose must complete a field review with the Client Sponsor prior to the project date. The purpose of the review is to develop a scope of work that identifies the conditions, equipment, methods, and physical locations that will be utilized along with any policies or procedures that will affect our work. x We must reach an agreement on the proper use of client emergency services and ensure that proper response personnel are available, as needed. x The potential for chemical exposure and actions to be taken in case of exposure must be communicated to Montrose. This information must include expected concentrations of the chemicals and the equipment used to identify the substances. x Montrose will provide a list of equipment being brought to the site, if required by the client. Project Day x Montrose personnel will arrive with the appropriate training and credentials for the activities they will be performing and the equipment that they will operate. x Our team will meet daily to review the Project Scope, Job Hazard Assessment, and Work Permits. The Client Sponsor and Operations Team are invited to participate. x Montrose will provide equipment that can interface with the client utilities previously identified in the planning phase and only work with equipment that our client has made ready and prepared for connection. x We will follow client direction regarding driving safety, safe work permitting, staging of equipment, and other crafts or work in the area. x As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the following provisions at each sample location: o Sampling ports, which meet EPA minimum requirements for testing. The caps should be removed or be hand-tight. o Safe sampling platforms. 10 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT o Safe access to the platforms and test ports, including any scaffolding or man lifts. o Sufficient utilities to perform all necessary testing. x Montrose will use the client communication system, as directed, in case of plant or project emergency. x Any adverse conditions, unplanned shutdowns or other deviations to the agreed scope and project plan must be reviewed with the Client Sponsor prior to continuing work. This will include any safe work permit and hazard assessment updates. Completion x Montrose personnel will report any process concerns, incidents or near misses to the Client Sponsor prior to leaving the site. x Montrose will clean up our work area to the same condition as it was prior to our arrival. x We will ensure that all utilities, connection points or equipment have been returned to the pre-project condition or as stated in the safe work permit. In addition, we will walk out the job completion with Operations and the Client Sponsor if required by the facility. 2.4.2 Safety Program and Requirements Montrose has a comprehensive health and safety program that satisfies State and Federal OSHA requirements. The program includes an Illness and Injury Prevention Program, site- specific safety meetings, and training in safety awareness and procedures. The basic elements include: x All regulatory required policies/procedures and training for OSHA, EPA, FMCSA, and MSHA x Medical monitoring, as necessary x Use of Personal Protective Equipment (PPE) and chemical detection equipment x Hazard communication x Pre-test and daily toolbox meetings x Continued evaluation of work and potential hazards x Near-miss and incident reporting procedures as required by Montrose and the Client Montrose will provide standard PPE to employees. The PPE will include but is not limited to; hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand protections, and fall protection. In addition, our trailers are equipped with four gas detectors to ensure that workspace has no unexpected equipment leaks or other ambient hazards. The detailed Site Safety Plan for this project is attached to this test plan in Appendix “S”. 11 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 3.0 Sampling and Analytical Procedures 3.1 Test Methods The test methods for this test program have been presented in Table 1-1. Additional information regarding specific applications or modifications to standard procedures is presented below. 3.1.1 EPA Method 1, Sample and Velocity Traverses for Stationary Sources EPA Method 1 is used to assure that representative measurements of volumetric flow rate are obtained by dividing the cross-section of the stack or duct into equal areas, and then locating a traverse point within each of the equal areas. Acceptable sample locations must be located at least two stack or duct equivalent diameters downstream from a flow disturbance and one-half equivalent diameter upstream from a flow disturbance. 3.1.2 EPA Method 2, Determination of Stack Gas Velocity and Volumetric Flow Rate (Type S Pitot Tube) EPA Method 2 is used to measure the gas velocity using an S-type pitot tube connected to a pressure measurement device, and to measure the gas temperature using a calibrated thermocouple connected to a thermocouple indicator. Typically, Type S (Stausscheibe) pitot tubes conforming to the geometric specifications in the test method are used, along with an inclined manometer. The measurements are made at traverse points specified by EPA Method 1. The molecular weight of the gas stream is determined from independent measurements of O2, CO2, and moisture content. The stack gas volumetric flow rate is calculated using the measured average velocity head, the area of the duct at the measurement plane, the measured average temperature, the measured duct static pressure, the molecular weight of the gas stream, and the measured moisture. Pertinent information regarding the performance of the method is presented below: o S-type pitot tube coefficient is 0.84. o Shortridge multimeter may be used to measure velocity. The typical sampling system is detailed as part of the EPA Method 5/202 sampling train in Figure 3-1. 12 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 3.1.3 EPA Method 3, Gas Analysis for the Determination of Dry Molecular Weight EPA Method 3 is used to calculate the dry molecular weight of the stack via measurement of the percent O2 and CO2 in the gas stream. A gas sample is extracted from a stack by multi- point, integrated sampling. The gas sample is analyzed for percent CO2 and percent O2 using either an Orsat or a Fyrite analyzer. Alternatively, an assigned value of 30.0 lb/lb-mol, in lieu of actual measurements, is used for processes burning natural gas, coal, or oil. Pertinent information regarding the performance of the method is presented below: x Method Options: o An Orsat analyzer is used to measure the analyte concentrations. o Multi-point integrated sampling is performed. x Method Exceptions: o A value of 30.0 is assigned for dry molecular weight, in lieu of actual measurements, for processes burning natural gas, coal, or oil. x Target and/or Minimum Required Sample Duration: 60 minutes x Target and/or Minimum Recommended Sample Volume: 1.0 ft3 x Target Analytes: O2 and CO2 13 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 3.1.4 EPA Method 4, Determination of Moisture Content in Stack Gas EPA Method 4 is a manual method used to measure the moisture content of gas streams. Gas is sampled at a constant sampling rate through a probe and impinger train. Moisture is removed using a series of pre-weighed impingers containing methodology-specific liquids and silica gel immersed in an ice water bath. The impingers are weighed after each run to determine the percent moisture. Pertinent information regarding the performance of the method is presented below: o Condensed water is measured gravimetrically. o Since it is theoretically impossible for measured moisture to be higher than psychrometric moisture, the psychrometric moisture is also calculated, and the lower moisture value is used in the calculations. o Minimum Required Sample Volume: 21 scf o Moisture content is determined from the EPA Methods 5 and 202 sampling training. In this case, gas is sampled at an isokinetic rate, not constant. o Method Options: o EPA Approved Alternative Method 009 (ALT-009) is used as an alternative to a two-point post-test meter box calibration. This procedure uses a calculation to check the meter box calibration factor rather than requiring a physical post-test meter box calibration using a standard dry gas meter. The average calculated meter box percent (%) error must result in a percent error within ±5% of Y. If not, a full calibration is performed, and the results are presented using the Y factor that yields the highest emissions. o EPA Approved Alternative Method 011 (ALT-011) is used as an alternative to the EPA Method 2 two-point thermocouple calibration. This procedure involves a single-point in-field check using a reference thermometer to confirm that the thermocouple system is operating properly. The temperatures of the thermocouple and reference thermometers shall agree to within ±2 °F. The typical sampling system is detailed in Figure 3-1 as part of the EPA Method 2 and 4 sampling train. 14 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 3.1.5 EPA Methods 5 and 202, Determination of Particulate Matter from Stationary Sources and Dry Impinger Method for Determining Condensable Particulate Emissions from Stationary Sources EPA Methods 5 and 202 are manual, isokinetic methods used to measure FPM and CPM emissions. The methods are performed in conjunction with EPA Methods 1, 2, 3, and 4. The stack gas is sampled through a nozzle, probe, heated filter, unheated CPM filter, condenser, and impinger train. FPM is collected from the probe and heater filter. CPM is collected from the unheated CPM filter and the impinger train. The samples are analyzed gravimetrically. The sum of FPM and CPM represents TPM. The FPM, CPM, and TPM results are reported in emission concentration and emission rate units. FPM results are compared to applicable emission limits for this source. Pertinent information regarding the performance of the method is presented below: x Method Options: o Glass sample nozzles and probe liners are used. o Stainless steel sample nozzles and glass probe liners are used. o As an alternative to baking glassware, a field train proof blank sample is recovered. o The post-test nitrogen purge is performed using the sampling system meter box and vacuum pump. o The post-test nitrogen purge is performed by passing nitrogen through the train under pressure. x Method Exceptions: o Stainless steel probe liners are used. o A heated flexible probe extension is used to connect the sample probe to the impinger box. o Single-point isokinetic sampling is performed at this stack due to space restrictions. x Target and/or Minimum Required Sample Duration: 60 minutes x Analytical Laboratory: MAQS, Spanish Fork, Utah The typical sampling system is detailed in Figure 3-1. 15 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT Figure 3-1 EPA Methods 5/202 Sampling Train 16 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 3.1.6 EPA Method 9, Visual Determination of the Opacity of Emissions EPA Method 9 is used to observe the visual opacity of emissions (opacity). The observer stands at a distance sufficient to provide a clear view of the emissions with the sun oriented in the 140° sector to their back. The line of vision is perpendicular to the plume direction and does not include more than one plume diameter. Observations are recorded at 15- second intervals and are made to the nearest 5% opacity. The qualified observer is certified according to the requirements of EPA Method 9, section 3.1. Pertinent information regarding the performance of the method is presented below: x Method Options: o Averaging period is 6 minutes (40 CFR Part 60, Subpart I). Observations are attempted to be made 30 minutes before, during, or within 30 minutes after each concurrent particulate run, unless weather conditions are unfavorable. 3.2 Process Test Methods The applicable regulations do not require process samples to be collected during this test program. 17 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 4.0 Quality Assurance and Reporting 4.1 QA Audits Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality assurance audits are performed as part of the test program to ensure that the results are calculated using the highest quality data available. This program ensures that the emissions data we report are as accurate as possible. The procedures included in the cited reference methods are followed during preparation, sampling, calibration, and analysis. Montrose is responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose will also perform the sampling, sample recovery, storage, and shipping. Approved contract laboratories may perform some of the preparation and sample analyses, as needed. 4.2 Quality Control Procedures Montrose calibrates and maintains equipment as required by the methods performed and applicable regulatory guidance. Montrose follows internal procedures to prevent the use of malfunctioning or inoperable equipment in test programs. All equipment is operated by trained personnel. Any incidence of nonconforming work encountered during testing is reported and addressed through the corrective action system. 4.2.1 Equipment Inspection and Maintenance Each piece of field equipment that requires calibration is assigned a unique identification number to allow tracking of its calibration history. All field equipment is visually inspected prior to testing and includes pre-test calibration checks as required by the test method or regulatory agency. 4.2.2 Audit Samples When required by the test method and available, Montrose obtains EPA TNI SSAS audit samples from an accredited provider for analysis along with the samples. Currently, the SSAS program has been suspended pending the availability of a second accredited audit sample provider. If the program is reinstated, the audit samples will be ordered. If required as part of the test program, the audit samples are stored, shipped, and analyzed along with the emissions samples collected during the test program. The audit sample results are reported along with the emissions sample results. 4.3 Data Analysis and Validation Montrose converts the raw field, laboratory, and process data to reporting units consistent with the permit or subpart. Calculations are made using proprietary computer spreadsheets or data acquisition systems. One run of each test method is also verified using a separate example calculation. The example calculations are checked against the spreadsheet results and are included in the final report. The “Standard Conditions” for this project are 29.92 inches of mercury and 68 °F. 18 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 4.4 Sample Identification and Custody The on-site Field Project Manager will assume or assign the role of sample and data custodian until relinquishing custody. The sample custodian will follow proper custody procedures before departing from the test site including: x Assign the unique sample identification number to each sample. x Attach sample labels and integrity seals to all samples. x Complete COC form(s), ensuring that the sample identification numbers on the samples match the sample identification numbers on the COC. x Pack and store samples in accordance with the test method requirements in appropriate transport containers for protection from breakage, contamination, or loss. x Keep samples in a secure locked area if not in the direct presence of Montrose staff. The sample custodian will follow proper custody procedures upon arriving at the Montrose office including: x Remove samples and COC documents from vehicles and check into designated secure sample holding areas. x Store samples requiring additional measures such as refrigeration or dry ice appropriately. 4.5 Quality Statement Montrose is qualified to conduct this test program and has established a quality management system that led to accreditation with ASTM Standard D7036-04 (Standard Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual functional assessments for conformance with D7036-04 which are conducted by the American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04 Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the documented limits in the test methods are met by using approved test protocols for each project as defined in D7036-04 Sections 7.2.1 and 12.10. Additional quality assurance information is included in the appendices. The content of this test plan is modeled after the EPA Emission Measurement Center Guideline Document (GD-042). 4.6 Reporting Montrose will prepare a final report to present the test data, calculations/equations, descriptions, and results. Prior to release by Montrose, each report is reviewed and certified by the project manager and their supervisor, or a peer. Source test reports will be submitted to the facility or appropriate regulatory agency (upon customer approval) within 19 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT 60 days of the completion of the field work. The report will include a series of appendices to present copies of the intermediate calculations and example calculations, raw field data, laboratory analysis data, process data, and equipment calibration data. 4.6.1 Example Report Format The report is divided into various sections describing the different aspects of the source testing program. Figure 4-1 presents a typical Table of Contents for the final report. Figure 4-1 Typical Report Format Cover Page Certification of Report Table of Contents Section 1.0 Introduction 2.0 Plant and Sampling Location Descriptions 3.0 Sampling and Analytical Procedures 4.0 Test Discussion and Results 5.0 Internal QA/QC Activities Appendices A Field Data and Calculations B Facility Process Data C Laboratory Analysis Data D Quality Assurance/Quality Control E Regulatory Information 4.6.2 Example Presentation of Test Results Table 4-1 presents the typical tabular format that is used to summarize the results in the final source test report. Separate tables will outline the results for each target analyte and compare them to their respective emissions limits. 20 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 HMAP Source Emissions Testing 2025 Compliance Source Test Plan, Centerfield, UT Table 4-1 Example Emissions Results - Barber Greene DM-70 Drum Mix HMAP, Near Centerfield, Utah Parameter/Units Run 1 Run 2 Run 3 Average Date XX XX XX Time XX XX XX Process Data throughput, ton/hr XX XX XX XX wet scrubber pressure drop, in. wc XX XX XX XX Sampling & Flue Gas Parameters O2, % volume dry XX XX XX XX CO2, % volume dry XX XX XX XX flue gas temperature, °F XX XX XX XX moisture content, % volume XX XX XX XX volumetric flow rate, dscfm XX XX XX XX FPM/CPM/TPM concentration, gr/dscf XX XX XX XX emission rate, lb/hr XX XX XX XX Opacity of Emissions Results opacity, % XX XX XX XX 21 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT Appendix A Supporting Information 22 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT Appendix A.1 Units and Abbreviations 23 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT UNITS OF MEASUREMENT @ X% O2 corrected to X% oxygen (corrected for dilution air) |CC| absolute value of the confidence coefficient |d| absolute value of the mean differences ºC degrees Celsius ºF degrees Fahrenheit ºR degrees Rankine " H2O inches of water column 13.6 specific gravity of mercury Ʃ+pressure drop across orifice meter, inches H2O Ʃ3 velocity head of stack gas, inches H2O LJ total sampling time, minutes μgmicrogram Ǐa density of acetone, mg/ml Ǐw density of water, 0.9982 g/ml or 0.002201 lb/ml acfm actual cubic feet of gas per minute at stack conditions An cross-sectional area of nozzle, ft2 As cross-sectional area of stack, square feet (ft2) Btu British thermal unit Bws proportion by volume of water vapor in gas stream Ca particulate matter concentration in stack gas, gr/acf CAvg average unadjusted gas concentration, ppmv CDir measured concentration of calibration gas, ppmv cf or ft3 cubic feet cfm cubic feet per minute CGas average gas concentration adjusted for bias, ppmv CM average of initial and final system bias check responses from upscale calibration gas, ppmv cm or m3 cubic meters CMA actual concentration of the upscale calibration gas, ppmv CO average of initial and final system bias check responses from low-level calibration gas, ppmv Cp pitot tube coefficient Cs particulate matter concentration in stack gas, gr/dscf CS calibration span, % or ppmv CS measured concentration of calibration gas, ppmv CV manufactured certified concentration of calibration gas, ppmv D drift assessment, % of span dcf dry cubic feet dcm dry cubic meters Dn diameter of nozzle, inches Ds diameter of stack, inches dscf dry standard cubic feet dscfm dry standard cubic feet per minute dscm dry standard cubic meters Fd F-factor, dscf/MMBtu of heat input fpm feet per minute fps feet per second ft feet ft2 square feet ggram gal gallons 24 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT gr grains (7000 grains per pound) gr/dscf grains per dry standard cubic feet hr hour I percent of isokinetic sampling in inch k kilo or thousand (metric units, multiply by 10 3) K kelvin (temperature) K3 conversion factor 0.0154 gr/mg K4 conversion factor 0.002668 ((in. Hg)(ft3))/((ml)(°R)) kg kilogram Kp pitot tube constant (85.49 ft/sec) kwscfh thousand wet standard cubic feet per hour l liters lb/hr pounds per hour lb/MMBtu pounds per million Btu lpm liters per minute m meter or milli M thousand (English units) or mega (million, metric units) m3 cubic meters ma mass of residue of acetone after evaporation, mg Md molecular weight of stack gas; dry basis, lb/lb-mole meq milliequivalent mg milligram Mg megagram (10 6 grams) min minute ml or mL milliliter mm millimeter MM million (English units) MMBtu/hr million Btu per hour mn total amount of particulate matter collected, mg mol mole mol. wt. or MW molecular weight Ms molecular weight of stack gas; wet basis, lb/lb-mole MW molecular weight or megawatt n number of data points ng nanogram nm nanometer Nm3 normal cubic meter Pbar barometric pressure, inches Hg pg picogram Pg stack static pressure, inches H2O Pm barometric pressure of dry gas meter, inches Hg ppb parts per billion ppbv parts per billion, by volume ppbvd parts per billion by volume, dry basis ppm parts per million ppmv parts per million, by volume ppmvd parts per million by volume, dry basis ppmvw parts per million by volume, wet basis Ps absolute stack gas pressure, inches Hg psi pounds per square inch psia pounds per square inch absolute 25 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT psig pounds per square inch gauge Pstd standard absolute pressure, 29.92 inches Hg Qa volumetric flow rate, actual conditions, acfm Qs volumetric flow rate, standard conditions, scfm Qstd volumetric flow rate, dry standard conditions, dscfm R ideal gas constant 21.85 ((in. Hg) (ft 3))/((°R) (lbmole)) SBfinal post-run system bias check, % of span SBi pre-run system bias check, % of span scf standard cubic feet scfh standard cubic feet per hour scfm standard cubic feet per minute scm standard cubic meters scmh standard cubic meters per hour sec second sf, sq. ft., or ft2 square feet std standard t metric ton (1000 kg) T 0.975 t-value Ta absolute average ambient temperature, ºR (+459.67 for English) Tm absolute average dry gas meter temperature, ºR (+459.67 for English) ton or t ton = 2000 pounds tph or tons/hr tons per hour tpy or tons/yr tons per year Ts absolute average stack gas meter temperature, ºR (+459.67 for English) Tstd absolute temperature at standard conditions Vvolt Va volume of acetone blank, ml Vaw volume of acetone used in wash, ml Vlc total volume H2O collected in impingers and silica gel, grams Vm volume of gas sampled through dry gas meter, ft3 Vm(std)volume of gas measured by the dry gas meter, corrected to standard conditions, dscf Vma stack gas volume sampled, acf Vn volume collected at stack conditions through nozzle, acf Vs average stack gas velocity, feet per second Vwc(std)volume of water vapor condensed, corrected to standard conditions, scf Vwi(std)volume of water vapor in gas sampled from impingers, scf Vwsg(std)volume of water vapor in gas sampled from silica gel, scf Wwatt Wa weight of residue in acetone wash, mg Wimp total weight of impingers, grams Wsg total weight of silica gel, grams Y dry gas meter calibration factor, dimensionless 26 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT ABBREVIATIONS AAS atomic absorption spectroscopy ACDP air contaminant discharge permit ACE analyzer calibration error, percent of span AD absolute difference ADL above detection limit AETB Air Emissions Testing Body AS applicable standard (emission limit) ASTM American Society for Testing and Materials BACT best achievable control technology BDL below detection limit BHP brake horsepower BIF boiler and industrial furnace BLS black liquor solids CC confidence coefficient CD calibration drift CE calibration error CEM continuous emissions monitor CEMS continuous emissions monitoring system CERMS continuous emissions rate monitoring system CET calibration error test CFR Code of Federal Regulations CGA cylinder gas audit CHNOS elemental analysis for determination of C, H, N, O, and S content in fuels CNCG concentrated non-condensable gas CO catalytic oxidizer COC chain of custody COMS continuous opacity monitoring system CPM condensable particulate matter CPMS continuous parameter monitoring system CT combustion turbine CTM conditional test method CTO catalytic thermal oxidizer CVAAS cold vapor atomic absorption spectroscopy De equivalent diameter DE destruction efficiency Dioxins polychlorinated dibenzo-p-dioxins (PCDDs) DLL detection level limited DNCG dilute non-condensable gas ECD electron capture detector EIT Engineer in Training ELCD electrolytic conductivity detector (hall detector) EMPC estimated maximum possible concentration EPA US Environmental Protection Agency EPRI Electric Power Research Institute ES emission standard (applicable limit) ESP electrostatic precipitator EU emission unit FCCU fluid catalytic cracking unit FGD flue gas desulfurization 27 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT FI flame ionization FIA flame ionization analyzer FID flame ionization detector FPD flame photometric detector FPM filterable particulate matter FTIR Fourier-transform infrared spectroscopy FTPB field train proof blank FTRB field train recovery blank Furans polychlorinated dibenzofurans (PCDFs) GC gas chromatography GC/MS gas chromatography/mass spectroscopy GFAAS graphite furnace atomic absorption spectroscopy GFC gas filter correlation GHG greenhouse gas HAP hazardous air pollutant HC hydrocarbons HHV higher heating value HPLC high performance liquid chromatography HRGC/HRMS high-resolution gas chromatography/high-resolution mass spectroscopy HRSG heat recovery steam generator IC ion chromatography ICAP inductively-coupled argon plasma emission spectroscopy ICPCR ion chromatography with a post-column reactor ICP-MS inductively coupled plasma-mass spectroscopy IR infrared radiation ISO International Standards Organization kW kilowatts LFG landfill gas LHV lower heating value LPG liquified petroleum gas MACT maximum achievable control technology MDI methylene diphenyl diisocyanate MDL method detection limit MNOC maximum normal operating conditions MRL method reporting limit MS mass spectrometry NA not applicable or not available NCASI National Council for Air and Steam Improvement NCG non-condensable gases ND not detected NDIR non-dispersive infrared NESHAP National Emissions Standards for Hazardous Air Pollutants NG natural gas NIOSH National Institute for Occupational Safety and Health NIST National Institute of Standards and Technology NMC non-methane cutter NMOC non-methane organic compounds NMVOC non-methane volatile organic compounds NPD nitrogen phosphorus detector NSPS New Source Performance Standards 28 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT OSHA Occupational Safety and Health Administration PAH polycyclic aromatic hydrocarbons PCB polychlorinated biphenyl compounds PCWP plywood and composite wood products PE Professional Engineer PFAS per- and polyfluoroalkyl substances (PFAS) PI photoionization PID photoionization detector PM particulate matter PM10 particulate matter less than 10 microns in aerodynamic diameter PM2.5 particulate matter less than 2.5 microns in aerodynamic diameter POM polycyclic organic matter PS performance specification PSD particle size distribution PSEL plant site emission limits PST performance specification test PTE permanent total enclosure PTM performance test method QA/QC quality assurance and quality control QI Qualified Individual QSTI Qualified Source Testing Individual RA relative accuracy RAA relative accuracy audit RACT reasonably available control technology RATA relative accuracy test audit RCTO rotary concentrator thermal oxidizer RICE stationary reciprocating internal combustion engine RM reference method RTO regenerative thermal oxidizer SAM sulfuric acid mist SCD sulfur chemiluminescent detector SCR selective catalytic reduction system SD standard deviation Semi-VOST semi-volatile organic compounds sample train SRM standard reference material TAP toxic air pollutant TBD to be determined TCA thermal conductivity analyzer TCD thermal conductivity detector TGNENMOC total gaseous non-ethane non-methane organic compounds TGNMOC total gaseous non-methane organic compounds TGOC total gaseous organic compounds THC total hydrocarbons TIC tentatively identified compound TO thermal oxidizer TO toxic organic (as in EPA Method TO-15) TPM total particulate matter TSP total suspended particulate matter TTE temporary total enclosure ULSD ultra-low sulfur diesel 29 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT UV ultraviolet radiation range VE visible emissions VOC volatile organic compounds VOST volatile organic sample train WC water column WWTP waste water treatment plant 30 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT CHEMICAL NOMENCLATURE Ag silver NOx nitrogen oxides As arsenic O2 oxygen Ba barium P phosphorus Be beryllium Pb lead C carbon PCDD polychlorinated dibenzo-p-dioxins Cd cadmium PCDF polychlorinated dibenzofurans CdS cadmium sulfide Sb antimony CH2Oformaldehyde SO2 sulfur dioxide CH3CHO acetaldehyde SO3 sulfur trioxide CH3OH methanol SOx sulfur oxides CH4 methane TCDD tetrachlorodibenzodioxin C2H4O ethylene oxide TCDF tetrachlorodibenzofuran C2H6 ethane TGOC total gaseous organic concentration C3H4O acrolein THC total hydrocarbons C3H6O propionaldehyde Tl thallium C3H8 propane TRS total reduced sulfur compounds C6H5OH phenol Zn zinc Cl2 chlorine ClO2 chlorine dioxide CO carbon monoxide Co cobalt CO2 carbon dioxide Cr chromium Cu copper EtO ethylene oxide EtOH ethyl alcohol (ethanol) H2 hydrogen H2Owater H2O2 hydrogen peroxide H2S hydrogen sulfide H2SO4 sulfuric acid HCl hydrogen chloride Hg mercury IPA isopropyl alcohol MDI methylene diphenyl diisocyanate MeCl2 methylene chloride MEK methyl ethyl ketone MeOH methanol Mn manganese N2 nitrogen NH3 ammonia Ni nickel NO nitric oxide NO2 nitrogen dioxide 31 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT Appendix A.2 Accreditation Information/Certifications 32 of 55 GP081AS-053204-PP-967 St a k e r P a r s o n – B a r b e r G r e e n e D M - 7 0 P o r t a b l e H M A P S o u r c e E m i s s i o n s T e s t i n g 20 2 5 C o m p l i a n c e S o u r c e T e s t P l a n , C e n t e r f i e l d , U T 33 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT Appendix A.3 Exhaust Stack Schematic 34 of 55 GP081AS-053204-PP-967 60.0" 30.0" =A= 0.50 diameters 120.0" =B= 2.00 diameters Port length is 1.5" Stack Diagram of the Barber Greene DM70 HMA Plant 35 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT Appendix A.4 )HEUXDU\WKUDEQ Approval Order 36 of 55 GP081AS-053204-PP-967 37 of 55 GP081AS-053204-PP-967 38 of 55 GP081AS-053204-PP-967 39 of 55 GP081AS-053204-PP-967 40 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT Appendix “S” Field Work Safety Plan 41 of 55 GP081AS-053204-PP-967 SITE SAFETY PLAN BOOKLET Project: _____________________ Customer: ___________________ Location: ____________________ Units: _________________ Client Project Manager: ______________________ Revision Date:June 29th, 2023 42 of 55 GP081AS-053204-PP-967 PROJ-053204 Staker Parson - Barber Gre Near Centerfield, Utah Drum-Type HMAP Cheyney Guymon/Austin Trame Page 1 of 2 Site Safety Plan and JHA Purpose and Instructions Purpose Employee safety is the top priority of Montrose Environmental Group. All employees must be trained to assess and mitigate hazards. The District Manager and Project Manager are responsible to ensure all hazards have been properly identified and managed. All employees have Stop Work Authority in all situations where an employee feels they or their co-worker cannot perform a job safely or if there is a task for which they have not been adequately trained. The Site Safety Plan (SSP) has been developed to help assist Montrose test crews with identifying physical and health hazards and determining how the hazards will be managed. Additionally, the SSP will help each crew manage the safety of the employees by providing emergency procedures and information. The booklet contains a several safety forms that may be required in the field. Instructions The SSP consists of the following: communicated to all employees, signed, and posted. Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed, CPM will maintain a roster and be responsible for accounting for all employees. The Job to work commencing. In the event of an emergency situation/ evacuation, the Job Supervisor/ emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior the Emergency Action Plan form and ensure that all employees are familiar with the facility 4. Emergency Action Plan -The Job Supervisor/ Client Project Manager (CPM) will complete observed plus applicable PPE that may be required. administrative controls that a crew can use to reduce or eliminate the hazards they have 3. Hazard Control Matrix - contains useful information on both engineering and with the toolbox topic and signatures can be added to the SSP packet. the hazard analysis is required daily for the duration of the test. An additional sheet of paper modified when conditions change. A toolbox meeting with a daily topic in addition to a review of sign on the Job Hazard Analysis form in agreement and sign in Section 10. The JHA is to be Each team member has the option to discuss making changes or adding to the JHA and must Section 9 will require at least three tasks, hazards and controls be identified for the project. form for accuracy, making any corrections required and complete the remainder of the JHA. complete the JHA form through section 8. Upon arrival at the test site, the team will review the daily hazard review with sign off by the team.The client Project Manager is responsible to task/site’s particular hazards and controls. The form also includes a daily toolbox topic and 2. A Job Hazard Analysis is a standardized, two-page, fillable form that is used to evaluated the prior to the test. 1. A Pre-Mobilization Test Plan – To be completed in it’s entirety by the client project Manager AQS-FRM-1.13R1 Extended Hours Formc. Heat Stress Prevention Form Based on Heat Indexb. MEWP Lift Inspection Forma. Additional Forms, as applicable5. 43 of 55 GP081AS-053204-PP-967 Page 2 of 2 Site Safety Plan and JHA Purpose and Instructions The SSP is a living document. The Project Manager should continually update their SSPs as new information and conditions change or if new hazards are presented. Each completed SSP should be maintained with the Test Plan in the office for a period of 3 years. There will be an audit process developed for the Site Safety Plans. AQS-FRM-1.13R1 44 of 55 GP081AS-053204-PP-967 Page 1 of 2 PRE-MOBILIZATION TEST INFORMATION Source Type: New Source: ____ Revisit: ____ Prj#/Date/Tech: __________________________ Coal Fired Electric Utility: ____ Ethanol Plant: ____ Chemical Mfg. of _________________________ Cement/Lime Kiln Plant: ____ Specialty Mfg. of: ___________ Other: _______________ Anticipated Effluent Composition – check all that apply and fill in expected concentration in ppm/% CO NOX SO2 VOC other If other, explain: _______________________________________________________ Flammable: _______ Toxic: ________ Corrosive: _______ Dust: __________ Engineering Controls to be Implemented: ______________________________________________________________________________________ __________________________________________________________________________________ Additional Safety Equipment Required: Personal gas monitors: ____ Respiratory Protection: Half Face____ Full Face____ HEPA Filters____ Supplied Air: _____ (Safety Dept. Approval) Approximate Flue Gas Temperatures, (F) below 210 210 to 450 450 to 950 above 950 other If other, explain: _______________________________________________________ Approximate Duct Pressure, (iwg): below -3 -3 to +3 +3 to +7 above +7 other If other, explain: _______________________________________________________ PROJECT NAME/LOCATION: ______________________ PROJECT #: ____________________ TEST DATE: ______________________ PROJECT MANAGER: ___________________ TEST SCOPE: ___________________________________________________________ SITE CONTACT: Name: _____________________ Contact Phone: _________________________ AQS-FRM-1.17 45 of 55 GP081AS-053204-PP-967 X AET Program of Aug. 15, 2019/Cheyney Guymon Portable Drum Mix HMAP Staker Parson - Near Centerfield, UT PROJ-053204 5/6/2025 Austin Tramell PM/CPM, VEs Testing on Barber Greene DM-70 Portable Drum Mix HMAP Chris Rose 385-400-2119 Page 2 of 2 PRE-MOBILIZATION TEST INFORMATION Sampling Location: Stack Port ____ Duct Port ____ Approximate Sampling Platform Height, (ft) Effluent Chemical Regulatory Limits Gas Name Chemical Formula Cal OSHA PEL1 (ppm) Cal OSHA STEL2 (ppm) NIOSH REL TWA3 (ppm) Cal OSHA Ceiling (ppm) IDLH4 (ppm) Carbon Monoxide CO 25 200 35 200 1,200 Nitric Oxide NOx 25 ND5 25 ND 100 Sulfur Dioxide SO2 2 5 2 ND 100 Hydrogen Chloride HCl 0.3 2 ND 2 50 Hydrogen Sulfide H2S 10 15 10 (10 min.)C 50 100 California Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) based on an 8-hour shift; 2: Cal OSHA Short-term Exposure Limit (STEL) based on a 15-minute period; 3: National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) Time-weighted Average (TWA) based on an 8-hour shift; 4: Immediately Dangerous to Life or Health (IDLH); 5: Not Defined (ND); C: Ceiling Limit - Maximum allowable human exposure limit for an airborne or gaseous substance, which is not to be exceeded, even momentarily. Prepared by: Date: Reviewed by: Date: ______________________________________________________________________________ ______________________________________________________________________________ Additional Information: ______________________________________________________________________________ ______________________________________________________________________________ Describe how equipment will be mobilized to the sampling location: Other:_____________________________________________________________________________ Guardrails: ____ Toe plate: ____ Engineered Tie Off Points: ____ Heat Shield: ____ Elevators: ____ Ladders: ____ MEWP Lift: ____ Scaffold: ____ Equipment Hoist: ____ Access and Protection: If other, explain: _______________________________________________________ below 6 6 to 50 50 to 100 above 100 other AQS-FRM-1.17 46 of 55 GP081AS-053204-PP-967 Hoisted or hand carried Joby Dunmire March 14, 2025 Job Hazard Analysis 1 of 3 1. Client Rep Job Preparation Job Site Walk Through Completed Site Specific Training Complete Safe Work Permit Received from Client 2.Facility Information/Emergency Preparedness If non-emergency medical attention is needed, call: AXIOM #: 877-502-9466. Plant Emergency # Certified First Aid Person: EMS Location Evacuation Routes Rally Point Severe Weather Shelter Location Eye Wash & Safety Shower Location Operational: Yes No Source Information: (list type): Stack Gas Temp. (oF)Stack Gas Press. ("H2O)Stack Gas Components: Stack Gas Inhalation Potential?Yes No If yes, see List of Hazard Chemicals. 3.Error Risk Time Pressure Remote Work Location > 12 hr shift Working > 8 consecutive days Lack of procedures Extreme temps, wind >30mph Personal illness/fatigue Vague work guidance Monotonous Activity First day back after time off Multiple job locations Other: 4.Physical Hazards Hazard Controls Dust Hazards Dust Mask Goggles Other: Thermal Burn Hot Gloves Heat Shields Other Protective Clothing: Electrical Hazards Connections Protected from Elements External GFCI Other: XP Rating Requirement Intrinsically Safe Requirement Inadequate Lighting Install Temporary Lighting Headlamps Slip and Trip Housekeeping Barricade Area Other: Hand Protection Cut Resistant Gloves Pinch Pts. General Electrical Impact Resistant Other: Potential Hazards for Consideration Secondary Permits Hot Work Confined Space Excavation Working from Heights Falling objects Fall protection Drop zone protection Platform load ratings See also Sect. 7 Scaffold inspection Ladder inspection Barricades for equipment Electrical Exposed wire/connector Verify equipment grounding Arc Flash Lifting Crane lift plan Rigging inspection Tag lines used Hoists in place Respiratory Unexpected exposure Chemical Dust (combustible) PEL provided See also Sect. 8 Cartridges or supplied air available Gas detection equipment 5.Required PPE Hard Hats Safety Glasses Safety Toe Shoe/Boot Hearing Protection Safety Spotter Hi-Vis Vests Harness/Lanyard*Goggles Personal Monitor Type: Metatarsal Guards Hot Gloves Face Shield Respirator Type: Nomex/FRC Other PPE: Client Contact Name Date Facility SSP Writer PM If the heat index is expected to be above 91°, fill out the Heat Stress Prevention Form. All hazards and mitigation steps must be documented. If this JHA does not cover all the hazards identified, use Section 9 to document that information. AQS-FRM-1.18 47 of 55 GP081AS-053204-PP-967 Staker Parson - Barber Greene DM-70 HMAP Joby Dunmire Chris Rose May 6, 2025 Austin Tramell Near Centerfield, Utah Job Hazard Analysis 2 of 3 Additional Work Place Hazards 6.Critical Procedures – check all that apply – *indicates additional form must be completed or collected from client Heat Stress Prevention* Confined Space* Roof Work Scaffold Cold Weather Work Hazardous Energy Control* Other: 7.Working From Heights Fall Protection Fixed Guardrails/Toe boards Fall Prevention PPE Warning Line System Falling Objects Protection Barricading Netting House Keeping Tethered Tools Catch Blanket or Tarp Fall Hazard Communication Adjacent/Overhead Workers Contractor Contact Client Contact 8.Other Considerations Environmental Hazards - Weather Forecast Heat/Cold Lightning Rain Snow Ice Tornado Wind Speed Steps for Mitigation: Electrical Safety Planning Plant Hook up:110V 220/240V 480V Generator Hard wired into panel Electrical Classified Area: Yes No Trailer Grounded: Yes No Plug Type Electrical Hook Up Responsibility: List of Hazardous Chemicals Other Chemicals: Acetone Nitric Acid Hydrogen Peroxide Compressed Gases Hexane Sulfuric Acid Isopropyl Alcohol Flammable Gas Toluene Hydrochloric Acid Liquid Nitrogen Non-Flammable Gas H2S Carbon Monoxide Steps for Mitigation: Wildlife/Fauna in Area Poison Ivy Poison Oak Insects: Wildlife: Personnel w/ known allergies to bees stings or other allergens?Yes No 9.Observed Hazards and Mitigation Steps Task Potential Hazard(s) Steps for Mitigation ● 11 22 33 ● 11 22 33 ● 11 22 33 ● 11 22 33 Exposure Monitoring MEWP* AQS-FRM-1.18 48 of 55 GP081AS-053204-PP-967 Job Hazard Analysis 3 of 3 10.JHA REVIEW: Crew Names & Signatures 11.Daily JHA Meeting & Review Items to review: ●Change in conditions ●Extended work hours ●Daily Safety Topic ● New workers or contractors ●Occurrence of near misses or injuries Printed Name Signature 2 Discussion TopicDay Initialing demonstrates that site conditions and hazards have not changed from the original SSP. If changes did occur, make the necessary updates to this JHA and add notes as applicable in Section 9. Initials 9 8 7 6 3 Date Printed Name Signature Date 5 4 11 10 AQS-FRM-1.18 49 of 55 GP081AS-053204-PP-967 1 2 3 4 5 6 Local Hospital/ Clinic Telephone Number: 7 8 9 10 11 12 13 14 15 16 17 MEG Job Supervisor/ CPM's Telephone Number: Plant's #1 Contact Person's Name: Plant's #1 Contact Person's Telephone Number: MEG Job Safety Supervisor's Telephone Number: Plant's Emergency Telephone Number: Emergency Ops Radio Channel: The Fire Extinguisher is Located: Eye Wash and Safety Shower Location: The First Aid Kit is Located: Page 1 of 2 The Job Supervisor/ Client Project Manager (CPM) will ensure that all employees are familiar with the facility emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior to work commencing. In the event of an emergency situation/ evacuation, the Job Supervisor/ CPM will maintain a roster and be responsible for accounting for all employees. The Job Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed, communicated to all employees, and posted. • You must follow the client’s emergency action plan first, and notify your Supervisor immediately. •If incident is life threatening, CALL 911 IMMEDIATELLY • If non-emergency medical attention is needed, call AXIOM Medical number: 877-502-9466. EMERGENCY ACTION PLAN FORM MEG Job Supervisor/ CPM's Name: MEG Job Safety Supervisor (if applicable): Evacuation Routes: Severe Weather Shelter Location: Plant's #2 Contact Person's Name: Plant's #2 Contact Person's Telephone Number: Designated Assembly Point Location: AQS-FRM-1.11 50 of 55 GP081AS-053204-PP-967 1 2 4 5 Signature: Date: Printed Name: Signature: Date: EVACUATE:____________________________________; OTHER:_______________________________________; Alarm Tones: EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBLY MAP REVIEW: Crew Names and Signatures Printed Name: Draw the evacuation and assembly map here Page 2 of 2 EMERGENCY EVACUATION AND ASSEMBLY MAP 3 Designated Shelter(s) Description: Designated Assembly Point(s) Description: YES or NO Facility Name: Facility Alarm (Circle): FIRE:_________________________________________; CHEMICAL/ GAS:_______________________________; SHELTER-IN-PLACE:_____________________________; AQS-FRM-1.11 51 of 55 GP081AS-053204-PP-967 Serial Number: Make: Rented or Owned: x Check “Yes” if an item is adequate, operational, and safe. x Check “No” to indicate that a repair or other corrective action is required prior to use. x Check “N/A” to indicate “Not Applicable.” Yes No N/A ܆ ܆ ܆ 2. Hydraulic fluid level is sufficient, with the platform fully lowered ܆ ܆ ܆ 3. Hydraulic system pressure (see manufacturer specs) is acceptable. If the pressure is low, determine cause and repair in accordance with accepted procedures as outlined in service manual. ܆ ܆ ܆ 4. Tires and wheel lug nuts (for tightness)܆ ܆ ܆ 5. Hoses and cables (i.e. worn areas or chafing)܆ ܆ ܆ 6. Platform rails and safety gate (no damage present)܆ ܆ ܆ 7. Pivot pins secure ܆ ܆ ܆ 8. Welds are not cracked and structural members are not bent or broken ܆ ܆ ܆ 9. Warning and instructional labels are legible and secure, and load capacity is clearly marked.܆ ܆ ܆ 10. Manufacturer’s Instruction Manual is present inside the bucket ܆ ܆ ܆ 11. Base controls (switches and push buttons) can be properly operated ܆ ܆ ܆ 12. Platform conditions are safe (i.e. not slippery)܆ ܆ ܆ 13. Fire extinguisher is present, mounted and fully charged, located inside the bucket ܆ ܆ ܆ 14. Headlights, safety strobe light and back-up alarm are functional ܆ ܆ ܆ 15. Workplace is free of hazards (overhead powerlines, obstructions, level surface, high winds, etc.) *Do not operate if winds are 20 mph, unless otherwise specified by manufacturer recommendations. ܆ ܆ ܆ Operator Name & Signature Location Date Ground Control Name & Signature Location Date Harness Inspections: Printed Name Signature Date Printed Name Signature Date Printed Name Signature Date Daily MEWP Lift Inspection Form Page 1 of 1 atthe beginning of each shift or following 6 to 8 hours of use. All checks must be completed prior to each work shift, before operation of the MEWP lift. This checklist must be used MEWP Lift Model #: loose hoses, etc.) – if something can be easily loosened by hand then it is not sufficient. 1.All MEWP lift components are in working condition (i.e. no loose or missing parts, torn or Items to be Inspected AQS-FRM-1.16 52 of 55 GP081AS-053204-PP-967 Page 1 of 1 001AS-SAFETY-FM-3 Extended Hours Safety Audit Project Number: Date: Time: When a project is expected to extend past a 14-hour work day, this form must be completed to evaluate the condition of the crew, and the safety of the work environment. Permission to proceed into extended work hours must come from a District Manager (DM) or Regional Vice President (RVP). Technical RVPs can authorize moving forward, if they are in the field or if they are managing the project. 1.Hold test crew meeting Test crew initials: The test leader should look for signs of the following in their crews: x Irritability x Lack of motivation x Headaches x Giddiness x Fatigue x Depression x Reduced alertness, lack of concentration and memory The test leader should assess the environmental and hazardous concerns: x Temperature and weather x Lighting x Working from Heights x Hoisting x PPE (i.e. respirators, etc.) x Pollutant concentration in ambient air (SO2, H2S, ect.) x Reason for extended hours x Reason for delay ƒProduction limitations x Impending Weather 3.Contact the client The PM, DM or RVP must discuss with client any identified safety concerns, the client’s needs and mutually agree on how to proceed. Discussion should also include the appropriate rest period needed before the next day’s work shift can begin. The DM and/or a RVP must be informed on the final decision. Final Outcome: Approver: During this time, they can come to an agreement on how to proceed. Itemsto discuss include: extended work period. If the DM is the acting PM on the job site, they must contact the RVP. The PM must contact either the DM or RVP to discuss the safety issues that may arise due to the Notify DM or RVP2. 53 of 55 GP081AS-053204-PP-967 Page 1 of 1 001AS-SAFETY-FM-5 Heat Stress Prevention Form This form is to be used when the Expected Heat Index is above 91° F, and is to be kept with project documentation. Project Manager (PM): Expected High Temp: Date(s): Expected Heat Index: 1. Review the signs of Heat Exhaustion and Heat Stroke 2. If Heat Index is above 91° F: x Provide cold water and/or sports drinks to all field staff (avoid caffeinated drinks and energy drinks which can increase core temperature). o Bring no less than one gallon of water per employee x If employee(s) are dehydrated, on blood pressure medication or not acclimated to heat, ensure they are aware of the heightened risk for heat illness x Provide cool head bands/vests/etc. x Have ice available to employees x Implement work shift rotations and breaks, particularly for employees working in direct sunlight. x Provide as much shade at the jobsite as possible, including tarps, tents or other acceptable temporary structures. x PM should interview each field staff periodically to evaluate for signs of heat illness 3. If Heat Index is above 103° F: x Employees must stop for drinks and breaks every hour (about 4 cups/hour) x Employees are not permitted to work alone for more than one hour at a time without a break offering shade and drinks x Employees should wear cool bands and vests if working outside more than one hour at a time x PM should interview each field staff every 2 hours to evaluate for signs of heat illness 54 of 55 GP081AS-053204-PP-967 Staker Parson – Barber Greene DM-70 Portable HMAP Source Emissions Testing2025 Compliance Source Test Plan, Centerfield, UT This is the Last Page of This Document If you have any questions, please contact one of the following individuals by email or phone. Name: Beckie Hawkins Title: District Manager Region: USA - Stack - Great Plains - Operations Email: behawkins@montrose-env.com Phone: 801-372-7049 Name: Cheyney Guymon Title: Client Project Manager Region: Great Plains Region, Utah Office Email: chguymon@montrose-env.com Phone: 801-362-4978 55 of 55 GP081AS-053204-PP-967