DAQ-2025-001858

1

DAQC-336-25
Site ID 10423 (B4)

MEMORANDUM

TO: STACK TEST FILE – INTERSTATE BRICK COMPANY

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Sirrine, Environmental Scientist

DATE: April 3, 2025

Source: Line #4 – Kiln Wet Scrubber, Mfg. Baghouse, and Primary Crusher Baghouse
Contact: Brittany Barney – 801-436-4051
Location: 9780 South 5200 West, West Jordan, Salt Lake County, UT
Tester: Montrose Air Quality Services, Beckie Hawkins 801-372-7049
FRS ID: UT0000004903500200
Permit: Title V Operating Permit 3500200002 dated August 22, 2023, revised February 12, 2025
Subject: Review of Stack Test Protocol received March 26, 2025
On March 26, 2025, the Utah Division of Air Quality (DAQ) received a protocol for stack emissions
testing of the Interstate Brick Company’s Line #4 - Kiln Wet Scrubber, Mfg. Baghouse, and Primary
Crusher Baghouse located in West Jordan, Salt Lake County, Utah. Stack testing will be performed June
16-20, 2025, to determine compliance with Conditions II.B.3.b, II.B.3.c, and II.B.4.b for PM10, PM2.5,
TF/HF, and SO2 emissions.

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 3A used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine moisture content: OK
5. RM 5 and 202 used to determine particulate concentrations of emissions: OK
6. RM 6C used to determine SO2 concentrations of emissions: OK
7. RM 7E used to determine NOX concentrations of emissions: OK
8. RM 13B used to determine Total Fluorides concentrations of emissions: OK

DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

* - / $ - - $ )
2

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENT: Stack Test Protocol received March 26, 2025
Source Test Plan Jor 2O25 Compliance Testing
Baghouse
LLC
For Submission To:
Utah Depaftment of Environmental Quality, Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116
Document Number: GPOS1AS-O52727-PP-98O
Proposed Test Date: June 16,2025
Test Plan Submiftal Date: March 24t 2(J25
0h
lacclaotttol
toatt, o&dlt
Line #4 Kaln Wet Scrubber, Line #4 Mfg.
Baghouse, Primary Crusher
Basalite Concrete Products
Interstate Brick
West Jordan, UT
Prepared For:
Basalite Concrete Products Llc
Interstate Brick
9780 South 5200 West
West Jordan, UT 84088
Prepared By:
Montrose Air Quality Services, LLC
6823 South 3600 West
Spanish Fork, UT 84660
U1 i. i-.'l Di-: PAR'1" M i:NT OF
E NVI RONfulENTAL QUALITYr-- ---_l
II rl -')^"'1: :
l,tt
nr,/tstoN oF AtR otlnLlTY
6/i\ MONTROSE STAE
Review and Ceftification
I ceftify 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 D7O36-O4.
Signature, -I-r--r.-- \\o-,t-.*o,March 24,2025
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.
Sisnature'
0/n rn A-rr"-'^- Date:
Name: U ,oO, Dunrnire Title:
March 24,2025
Repofting/QC Specialist IV
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Table of Contents
Section Paoe
1.0 Introduction........ ................5
1.1 Summary of Test Program .............5
1.2 Applicable Regulations and Emission Limits... ...................7
1.3 Key Personnel........... ...................8
2.0 Plant and Sampling Location Descriptions.............. ................10
2.L Process Description, Operation, and Control Equipment.............. .....10
2.2 Flue Gas Sampling Locations.. ......10
2.3 Operating Conditions and Process Data ......... 11
2.4 Plant Safety .......L2
2.4.1 Safety Responsibilities...... .......12
2.4.2 Safety Program and Requirements....... ................13
3.0 Sampling and Analytical Procedures .....L4
3.1 Test Methods............ .................14
3.1.1 EPA Method 1.............. ......L4
3.1.2 EPA Method 2.............. ......14
3.1.3 EPA Methods 3/3A........ ..... 15
3.1.4 EPA Method 4............, .......15
3.1.5 EPA Methods 3A, 6C, and 7E ....16
3.1.6 EPA Methods 5 and 202.......... ....18
3.1.7 EPA Method 138.......... ......2O
3.2 Process Test Methods............ ......21
4.0 Quality Assurance and Reporting........... ...............22
4.L QA Audits ..................22
4.2 Quality Control Procedures ..........22
4.2.1 Equipment Inspection and Maintenance ........,.......22
4.2.2 Audit Samples ...................22
4.3 Data Analysis and Validation ........22
4.4 Sample tdentification and Custody.... ............23
4.5 Quality Statement ......23
4.6 Repofting ..................24
4.5.1 Example Repoft Format..... .................24
4.6.2 Example Presentation of Test Results............. ......24
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List of Appendices
Appendix A Supporting Information.......... .................26
Appendix A.1 Units and Abbreviations...... ............27
Appendix A.2 Accreditation Information/Certifications............ ................ 36
Appendix A.3 Stack Schematics ...,......38
Appendix A.4 UDEQ Title V Operating Permit #3500200001 ........... .....,..42
Appendix "S" Field Work Safety Plan ..........81
List of Tables
Table 1-1 Summary of Test Program and Proposed Schedule ..........6
Table 1-2 Reporting Units and Emission Limits ..............7
Table 1-3 Test Personnel and Responsibilities ...........,...9
Table 2-1 Sampling Locations............ .......10
Table 4-1 Example Particulate Matter Emissions Results - Primary Crusher Baghouse......25
List of Figures
Figure 3-1 US EPA Methods 3A, 6C, and 7E Sampling Train........ ...................17
Figure 3-2 US EPA Method 5/202 Sampling Train ....... ..................19
Figure 3-3 US EPA Method 138 Sampling Train ............27
Figure 4-1 Typical Repoft Format ........24
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1.O Introduction
1.1 Summary of Test Program
Basalite Concrete Products LLC dba Interstake Brick contracted Montrose Air Quality
Services, LLC (Montrose) to perform a compliance emissions test program on the following
units at the facility located in West Jordan, UT: Line #4 Kiln Wet Scrubber, Line #4
Manufacturing Baghouse, Primary Crusher Baghouse. The tests will be conducted to
determine compliance with Permit Conditions II.B.3 (Line #4) and II.B.4 (Primary and
Secondary Crushers) contained in Title V Operation Permit 3500200002 issued by Utah
Depaftment of Environmental Quality (UDEQ) on October 10, 2018.
The specific objectives are to:
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I Measure emissions of sulfur dioxide (SOz), nitrogen oxides (NOx),
particulate matter less than 10 micrometers in aerodynamic diameter
(PMro), particulate matter less than 2.5 micrometers in aerodynamic
diameter (PMz.s), and total fluoride (TF) at the outlet of the Line #4 Kiln
Wet Scrubber.
Measure emissions of PMro and PMz.s at the outlet of the Line #4
Manufacturing Baghouse.
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. Measure emissions of PMro and PMz.s at the outlet of the Primary Crusher
Baghouse.
. 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.
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Table 1-1
Summary of Test Program and Proposed Schedulel
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 The test schedule is subject to change, based on process operation and availability.
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)une 17,2025 Line #4 Kiln Wet
Scrubber
Perform testing for
SOz, NOx, and TFIHF
Emissions
EPA 1, 2,3A.,
4,6C,7E, and
13B
June 18, 2025 Line #4 Kiln Wet
Scrubber
Perform testing for
PMro and PMz.s
Emissions
EPA t,2,3,
4, and 5/202
lune 19, 2025
Line #4
Manufacturing
Baghouse
Perform testing for
PMro and PMz.s TF/HF
Emissions
EPA L, 2, 3,
4, and 5/202
Primary Crusher
Baghouse
Perform testing for
PMro and PMz.s TFIHF
Emissions
EPA L, 2, 3,
4, and 5/202
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L.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 repofting units and emission limits are
presented in Table 1-2.
Table 1-2
Repofting Units and Emission Limits
Line #4 Kiln Wet
Scrubber
lblhr (1-hr avg.)UDEQ Title V
Operating
Permit
3500200001,
5rr.8.3.b.
lblhr (l-hr avg.)
lblhr (1-hr avg.)
lblhr (1-hr avg.)
Line #4
Manufacturing
Baghouse
PMro/PMz.s
lblhr (1-hr avg.)
grldsd (1-hr avg.)
Primary Crusher
Baghouse PMro/PMz.s
lb/hr (1-hr avs.)
!ildsd (1-hr avg.)
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1.3 Key Personnel
A list of pr{ect pafticipants is included below:
Facility Information
Source Location: Interstate Brick
9780 South 5200 West
West Jordan, UT 84088
Project Contact: Brittany Barney
Role: Environmental Coordinator
Company: Interstate Brick
Telephone: [phone]
Email: [e-mail]
Agency Information
Regulatory Agency: Utah Department of Environmental Quality, Division of Air Quality
Agency Contact: Harold Burge
Telephone: [phone]
Email: [e-mail]
Testing Company Information
Testing Firm: Montrose Air QualiW Seruices, LLC
Contact: BeckieHawkins
Title: District Manager
Telephone: [phone]
Email: [e-mail]
Laboratory Information
Laboratory: MAQS Spanish Fork
City, State: Spanish Fork, UT
Method: EPA Methods 5 and 202
Laboratory: Element One Inc.
City, State: Wilmington, NC
Method: EpA Method 13B
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Table 1-3 details the roles and responsibilities of the test team.
Table 1-3
Test Personnel and Responsibilities
Field Project Manager Facility interface, test crew coordination
Preparation, support PM
Preparation, support PM
G P08 1AS-0 5 27 27 -PP -980
2,O Plant and Sampling Location Descriptions
2.1 Process Description, Operation, and Control
Equipment
Interstate Brick Company operates a brick and tile manufacturing plant located at 9780
South 5200 West, in West Jordan City, Salt Lake County, Utah. All exhaust air from the Kiln
#3 process streams are routed through the Kiln #3 wet scrubber before being vented to the
atmosphere. All exhaust air from the Kiln #4 process streams are routed through the Kiln
#4 wet scrubber before being vented to the atmosphere. All exhaust air from the Primary
Crusher Building is routed through the Primary Crusher Baghouse before being vented to
the atmosphere.
2.2 Flue Gas Sampling Locations
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 Locations
Sample location(s) are verified in the field to conform to EPA Method 1. Acceptable cyclonic
flow conditions are confirmed priorto testing using EPA Method 1, Section 11,4. Appendix A
presents stack schematics and process flow diagrams.
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Isokinetic: 24 (12/ port)
Flow: 24 (L2/port)
Gaseous: TBD based on
Stratification Testing
zl.s / L.6 Isokinetic: 16 (8/port)toz / 7.6
Isokinetic: 24 (Lzlport)Primary Crusher t06 / 4.7
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2.3 Operating Conditions and Process Data
Emission tests are performed while the sources/units and air pollution control devices are
operating atthe conditions required by the permit. As per 5II.B.3.b.1.(5), 5II.B.3.c.1.(5),
and 5II.B.4.b.1.(5) of the UDEQ Title V Operating Permit #3500200001, "...For a
source/emission point, the production rate during compliance testing shall be no less than
90o/o of the maximum allowable production rate (Line #4 production rating of 26.97 tons of
product per hour and Primary Crusher rating of 100 tons per hour). If the maximum
allowable production rate cannot be achieved at the time of the test, the following
procedure shall be followed:
a) Testing shall be at no less than 90olo of the anticipated annual production rate.
b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be 110o/o of the rate achieved during the latest test.
c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to 110o/o of the highest tested rate that demonstrates
compliance with the limits limited in this condition."
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters for Line #4
Wet Scrubber:
. Scrubber pressure drop, measured in units of inches water column, gauge
pressure
. Scrubber liquid acidity/alkalinity, measured in units of pH
. Scrubber liquid flow rate, measured in units of gallons per minute (gpm)
. Production rate, measured in units of tons per hour (tph)
Data collected includes the following parameters for Line #4 Manufacturing Baghouse:
. Baghouse pressure drop, measured in units of inches water column, gauge pressure
. Production rate, measured in units of tph
Data collected includes the following parameters for Line #4 Manufacturing Baghouse:
. Baghouse pressure drop, measured in units of inches water column, gauge pressure
. Production rate, measured in units of tph
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2.4 Plant Safety I
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.L Safety Responsibilities
Planning
. 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.
. We must reach an agreement on the proper use of client emergency services
and ensure that proper response personnel are available, as needed.
. 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.
o Montrose will provide a list of equipment being brought to the site, if required
by the client.
Project Day
. Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate.
. 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.
. Montrose will provide equipment that can intefface 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.
. We will follow client direction regarding driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area.
. As per 40 CFR Part 50 Subpaft 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.
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o Safe access to the platforms and test polts, including any scaffolding or
man lifts.
o Sufficient utilities to perform all necessary testing.
. Montrose will use the client communication system, as directed, in case of
plant or project emergency.
. 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
. Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site.
r Montrose will clean up our work area to the same condition as it was prior to
our arrival.
. 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:
. All regulatory required policies/procedures and training for OSHA, EPA,
FMCSA, and MSHA
. Medical monitoring, as necessary
. Use of Personal Protective Equipment (PPE) and chemical detection equipment
. Hazard communication
. Pre-test and daily toolbox meetings
. Continued evaluation of work and potential hazards
. Near-miss and incident repofting 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".
13 of 95 GP08 1AS-0527 27 -PP -980
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3.O Sampling and Analytical Procedures I
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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 Oz, COz, and moisture. 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 peformance of the method is presented below:
. Method Options:
o S-type pitot tube coefficient is 0.84.
o Shodridge multimeter is used to measure velocity.
o Flow rate measurements are performed as part of the pollutant
sample trains.
o A dry molecular weight of 29.O lbllb-mol is utilized in flow rate
calculations for processes that emit essentially air-this is anticipated
to be the case for the Line #4 Manufacturing Baghouse and Primary
Crusher Baghouse exhaust sampling locations.
The typical sampling system is detailed as part of both the EPA Methods 5 and 202 sampling
train in Figure 3-2 and the EPA Method 13B sampling train in Figure 3-3.
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I 3.1.3 EPA Methods 3l3A - Gas Analysis for the Determination of
Dry Molecular Weight
Procedures found in EPA Methods 3 and 34 are used to measure the oxygen (Oz) and
carbon dioxide (COz) concentrations in the gas stream. These values are used in the
determination of the dry molecular weight of the stack gas. The balance of the stack gas is
assumed to be nitrogen (Nz) for this calculation, since the other components in the gas are
insignificant for the determination of dry molecular weight (e.9., carbon monoxide). The
molecular weight is used, along with the values obtained from the EPA Methods 2 and 4
(either EPA Methods 5 and 202 or EPA Method 138) testing, to calculate the gas volumetric
flow rate through the test location.
An integrated gas sample (IGS) is collected into a Tedlar bag from the back of either the
EPA Methods 5 and 202 sample train or the EPA Method 13B sample train for the duration of
each test run. Analysis of the IGS bag contents for the determination of Oz and COz is
performed using a calibrated paramagnetic Oz gas analyzer and an infrared COz analyzer.
The analyzers are calibrated using EPA Protocol 1 calibration gases.
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I 3.L.4 EPA Method 4, Determination of Moisture Content in Stackr Gas
I EPA Method 4 is used to measure the moisture content of gas streams. Gas is sampled
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:I
I o Condensed water is measured gravimetrically.
o Moisture sampling is performed as part of the pollutant (either EPA
Methods 5 and 202 and EPA Method 13B) sample trains. In these
cases, gas is sampled at an isokinetic rate, not constant.
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--
this is anticipated to be the case for all three exhaust sampling
locations.
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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 (o/o) error must result in a percent error within
*5olo 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-O11) 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
oF.
The typical sampling system is detailed as paft of both the EPA Methods 5 and 202
sampling train in Figure 3-2 and the EPA Method 13B sampling train in Figure 3-3.
3.1.5 EPA Methods 3A, 6C, and 7Et Determination of Oxygen,
Carbon Dioxide, Sulfur Dioxide, and Nitrogen Oxides
Concentrations in Emissions from Stationary Sources
(Instrumental Analyzer Procedures)
Concentrations of Oz, COz, SOz, and NOx are measured simultaneously using EPA Methods
3A, 5C, and 7E, which are instrumental test methods. Conditioned gas is sent to a series of
analyzers to measure the gaseous emission concentrations. The pefformance requirements
of the method must be met to validate the data.
Pertinent information regarding the pefformance of the method is presented below:
. Method Options:
o A dry extractive sampling system is used to report emissions on a dry
basis.
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Io A paramagnetic analyzer is used to measure Oz.
o A nondispersive infrared analyzer is used to measure COz.
o An ultraviolet absorption analyzer is used to measure SOz.
o A non-dispersive infrared analyzer is used to measure SOz.
o A fluorescence analyzer is used to measure SOz.
o A chemiluminescent analyzer is used to measure NOx.
o NO and NOz are measured separately and summed to report NOx
emissions.
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o A stratification test will be pefformed in line with the methodology
contained in EPA Method 7E, Section 8.2.4.
o The alternative NOx converter efficiency test described in EPA Method 7E
Section 16.2 may be used (bag procedure).
. Method Exceptions:
o For gaseous emissions sampling, MDL are calculated for each analyzer.
The ISDL is equal to the sensitivity of the instrumentation, which is 2o/o of
the span value.
. Target and/or Minimum Required Sample Duration: 50 minutes
. Target Analytes: Oz, COz, SOz, NOx
The typical sampling system is detailed in Figure 3-1.
Figure 3-1
US EPA itethods 3A, 6C, and 7E Sampling Train
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#f
.MET
MffiWEflcrc
ffiftfrm
CAUBRATION
GAS LINE
+
l.
ti:-s
ffiAO?Y€B'Mffiffil:WMVAE
HEATED
SAMPLE
LINE
MASS FLOW CONTROI.LER /
CALIBRATION GAS MANIFOLD
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3.1.6 EPA Methods 5 and 2O2, Determination of Particulate Matter
Emissions 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. FPM is withdrawn isokinetically from the source and collected on a glass fiber
filter maintained at a temperature of 120 + 14 oC (248 *,25 oF) or such other temperature
as specified by an applicable subpart of the standards or approved by the Administrator for
a particular application. The FPM mass, which includes any material that condenses at or
above the filtration temperature, is determined gravimetrically after the removal of
uncombined water.
CPM is collected in dry impingers after filterable PM has been collected on a filter maintained
as specified in Method 5. The organic and aqueous fractions of the impingers and an out-of-
stack CPM filter are then taken to dryness and weighed. The total of the impinger fractions
and the CPM filter represents the CPM.
Pertinent information regarding the performance of the method is presented below:
. 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 peformed by passing nitrogen
through the train under pressure.
. 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.
o The sum of the filterable PM (via Method 5) and CPM (via Method
202) are used as a surrogate for PMro and/or for PMz.s.
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a
a
Target and/or Minimum Required Sample Duration: 60 minutes
Analytical Laboratory: MAQS, Spanish Fork, Utah I
The typical sampling system is detailed in Figure 3-2.T
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Figure 3-2
US EPA Method 512O2 Sampling Train
FILTER
HOLDER
THERMOCOUPLE
THERMOCOUPTE
NO:ZLEL-
rl
T'r'#'
eilptv @dt{N/@dP)
100 ml Hro(dti.d / m !D)
I4ANOMETER +(mdllw / rc dD)Slll€ G6l(ndiled/Mlip)VACUUM
LINE
BY-PASS VALVE
JJ
19 of 95 G P08 1AS-0 5 27 27 -PP -980
3.t.7 EPA Method 13B, Determination of Total Fluoride Emissions
from Stationary Source (Specific Ion Electrode Method)
EPA Method 13B is a manual, isokinetic test method used to measure emissions of F-.
Gaseous and particulate F- are withdrawn isokinetically from the source and collected in
water and on a filter. The total F- is then determined by the specific ion electrode method.
Pertinent information regarding the performance of the method is presented below:
. Method Options:
o Certain specific ion meters have been designed specifically for fluoride
electrode use and give a direct readout of fluoride ion concentration.
These meters are used in lieu of calibration curves for fluoride
measurements over a narrow concentration range.
. Target and/or Minimum Required Sample Duration: 60 minutes
. Analytical Laboratory: Element One [nc., Wilmington, North Carolina
The typical sampling system is detailed in Figure 3-3.
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Figure 3-3
US EPA Method 13B Sampling Train
3.2 Process Test Methods
The applicable regulations do not require process samples to be collected during this test
program.
100 ml 100 ml
CONOENSING CONDENSING
REAGENT REAGENT
(ndifred / N tid (tundad dP)
ftpdncd/Nap) 200-3OOg
Slllca Gol
(mo<tlfled / no 0p)
BY-PASS VALVE
AN.qud)THERMOCOUPLESIJ
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4.O Quality Assurance and Reporting t
4.L QA Audits
Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality
assurance audits are peformed 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 pedorm some of the preparation and sample analyses, as needed.
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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.L Equipment Inspection and Maintenance
Each piece of field equipment that requires calibration is assigned a unique identiflcation
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.
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4.3 Data Analysis and Validation I
t
Montrose converts the raw field, laboratory, and process data to repofting units consistent
with the permit or subpaft. 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"forthis project are29.92
inches of mercury and 68 oF.I
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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 depafting from the test site including:
. Assign the unique sample identification number to each sample.
. Attach sample labels and integrity seals to all samples.
. Complete COC form(s), ensuring that the sample identification numbers on
the samples match the sample identification numbers on the COC.
. Pack and store samples in accordance with the test method requirements in
appropriate transport containers for protection from breakage, contamination,
or loss.
. 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:
. Remove samples and COC documents from vehicles and check into
designated secure sample holding areas.
. Store samples requiring additional measures such as refrigeration or dry ice
appropriately.
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I 4.5 Quality Statement
I 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 D7O36-O4 which are conducted by the
American Association for Laboratory Accreditation (A2l-A). All testing performed by Montrose
is supervised on site by at least one Qualified Individual (QI) as defined in D7035-04
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.t 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).
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4.6 Repofting
Montrose will prepare a final repoft to present the test data, calculations/equations,
descriptions, and results. Prior to release by Montrose, each report is reviewed and certified
by the pr{ect manager and their supervisor, or a peer. Source test reports will be
submitted to the facility or appropriate regulatory agency (upon customer approval) within
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
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Cover Page
Ceftification of Report
Table of Contents
Section
1.0 Introduction
2.O Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
4.O 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
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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.
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Table 4-1
Example Pafticulate Matter Emissions Results -
Primary Crusher Baghouse
Date xx xx xx
Time XX xx xx
Sampllng & Flue Gas Parameterc
Oz, o/o volume dry xx XX XX xx
COz, o/o volume dry xx XX XX XX
stack gas temperature, oF XX xx xx XX
moisture content, o/o volume XX xx XX xx
volumetric flow rate, dscfm XX xx xx XX
isokinetlc sampling ratlo, o/o xx XX xx XX
Process Information
material throughput rate, tph XX xx xx XX
fuel usage, MMBtu/hr XX xx xx xx
Baghouse pressure drop, in. w.c.xx XX XX XX
Filterable Pil (FPM) Results
grldsd XX xx xx xx
lblhr xx xx xx xx
lblton material throughput XX xx xx xx
Condensable PM (GPttl) Results
grldsd XX xx xx xx
lb/hr xx xx XX XX
lblton material throughput XX xx xx XX
Total Pl.l (TPtl = FPIII + GPtl) Results
grldsc,xx xx xx xx
lblhr XX XX xx XX
lblton material throughput xx xx xx xx
25 of 95 G P08 1AS-0 527 27 -PP -980
Appendix A
Supporting Information
GP08 1AS-0527 27 -PP-980
Appendix A.1
Units and Abbreviations
@ Xolo Oz
lccl
ldtoc
oF
oR
" HzO
13.6
AH
API
ug
Pa
P*
acfm
An
As
Btu
B*"
Ca
Cavs
Coi.
cf or ft3
cfm
Cc""
Crq
cm or m3
Crqa
Co
cP
cs
CS
Cs
Cv
D
dcf
dcm
Dn
Ds
dscf
dscfm
dscm
Fo
fpm
fps
ft
ft2
UNITS OF MEASUREMENT
corrected to Xolo oxygen (corrected for dilution air)
absolute value of the confidence coelficient
absolute value of the mean differences
degrees Celsius
degrees Fahrenheit
degrees Rankine
inches of water column
specific Aravity of mercury
pressure drop across orifice meter, inches HzO
velocity head of stack gas, inches HzO
total sampling time, minutes
microgram
density of acetone, mg/ml
density of water, 0.9982 g/ml or 0.002201 lblml
actual cubic feet of gas per minute at stack conditions
cross-sectional area of nozzle, ftz
cross-sectional area of stack, square feet (ft2)
British thermal unit
proportion by volume of water vapor in gas stream
particulate matter concentration in stack gas, gr/acf
average unadjusted gas concentration, ppmv
measured concentration of calibration gas, ppmv
cubic feet
cubic feet per minute
average gas concentration adjusted for bias, ppmv
average of initial and final system bias check responses from upscale
calibration gas, ppmv
cubic meters
actual concentration of the upscale calibration gas, ppmv
average of initial and final system bias check responses from low-level
calibration gas, ppmv
pitot tube coefficient
particulate matter concentration in stack gas, grldscf
calibration spoh, o/o or ppmv
measured concentration of calibration gas, ppmv
manufactured certified concentration of calibration gas, ppmv
drift assessment/ %o of span
dry cubic feet
dry cubic meters
diameter of nozzle, inches
diameter of stack, inches
dry standard cubic feet
dry standard cubic feet per minute
dry standard cubic meters
F-factor, dscf/MMBtu of heat input
feet per minute
feet per second
feet
square feet
gram
gallons
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9rgr/dsd
hr
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in
k
K
Kg
K4
kg
Kp
kwscftt
I
lb/hr
lb/MMBtu
lpm
m
M
m3
lTla
Mo
meq
mg
Mg
min
ml or mL
mm
MM
MMBtu/hr
lTln
mol
mol. wt. or MW
Ms
MW
n
n9
nm
Nm3
Pb"t
p9
Pe
P.
ppb
ppbv
ppbvd
ppm
ppmv
ppmvd
ppmvw
Ps
psi
psia
grains (7000 grains per pound)
grains per dry standard cubic feet
hour
percent of isokinetic sampling
inch
kilo or thousand (metric units, multiply by 103)
kelvin (temperature)
conversion factor 0,0154 grlmg
conversion factor 0. 002668 ((in. HgXft3))/((ml XoR))
kilogram
pitot tube constant (85.49 Vsec)
thousand wet standard cubic feet per hour
liters
pounds per hour
pounds per million Btu
liters per minute
meter or milli
thousand (English units) or mega (million, metric units)
cubic meters
mass of residue of acetone after evaporation, mg
molecular weight of stack gas; dry basis, lbllb-mole
milliequivalent
milligram
megagram (106 grams)
minute
milliliter
millimeter
million (English units)
mlllion Btu per hour
total amount of particulate matter collected, mg
mole
molecular weight
molecular weight of stack gas; wet basis, lb/lb-mole
molecular weight or megawatt
number of data points
nanogram
nanometer
normal cubic meter
barometric pressure, inches Hg
picogram
stack static pressure, inches HzO
barometric pressure of dry gas meter, inches Hg
parts per billion
parts per billion, by volume
parts per billion by volume, dry basis
parts per million
parts per million, by volume
parts per million by volume, dry basis
parts per million by volume, wet basis
absolute stack gas pressure, inches Hg
pounds per square inch
pounds per square inch absolute
29 of 95 G P08 1AS-0 5 27 27 -PP -980
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psig
Pstd
Q"
Q.
Q"to
R
SBRnat
SBr
scf
scfh
scfm
scm
scmh
sec
sf, sq. ft., or ft2
std
t
T o.gzs
T"
Tm
ton or t
tph or tons/hr
tpy or tons/yr
T,
Trto
V
va
V"*
Vrc
V.
Vm(std)
vru
vn
vs
Vwc(std)
Vwl(std)
Vwss(std)
W
wa
Wrmp
Wss
Y
pounds per square inch gauge
standard absolute pressure, 29.92 inches Hg
volumetric flow rate, actual conditions, acfm
volumetric flow rate, standard conditions, scfm
volumetric flow rate, dry standard conditions, dscfm
ideal gas constant 21.85 ((in. Hg) (ft3))/((oR) (lbmole))
post-run system bias check, o/o of span
pre-run system bias check, o/o of span
standard cubic feet
standard cubic feet per hour
standard cubic feet per minute
standard cubic meters
standard cubic meters per hour
second
square feet
standard
metric ton (1000 kg)
t-value
absolute average ambient temperature, oR (+459.67 for English)
absolute average dry gas meter temperature, oR (+459.67 for English)
ton = 2000 pounds
tons per hour
tons per year
absolute average stack gas meter temperature, oR (+459.67 for English)
absolute temperature at standard conditions
volt
volume of acetone blank, ml
volume of acetone used in wash, ml
total volume HzO collected in impingers and silica gel, grams
volume of gas sampled through dry gas meter, ft3
volume of gas measured by the dry gas meter, corrected to standard
conditions, dscf
stack gas volume sampled, acf
volume collected at stack conditions through nozzle, acf
average stack gas velocity, feet per second
volume of water vapor condensed, corrected to standard conditions, scf
volume of water vapor in gas sampled from impingers, scf
volume of water vapor in gas sampled from silica gel, scf
watt
weight of residue in acetone wash, mg
total weight of impingers, grams
total weight of silica gel, grams
dry gas meter calibration factor, dimensionless
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AAS
ACDP
ACE
AD
ADL
AETB
AS
ASTM
BACT
BDL
BHP
BIF
BLS
cc
CD
CE
CEM
CEMS
CERMS
CET
CFR
CGA
CHNOS
CNCG
CO
coc
COMS
CPM
CPMS
CT
CTM
cro
cvAAs
De
DE
Dioxins
DLL
DNCG
ECD
EIT
ELCD
EMPC
EPA
EPRI
ES
ESP
EU
FCCU
FGD
ABBREVIATIONS
atomic absorption spectroscopy
air contaminant discharge permit
analyzer calibration error, percent of span
absolute difference
above detection limit
Air Emissions Testing Body
applicable standard (emission limit)
American Society for Testing and Materials
best achievable control technology
below detection limit
brake horsepower
boiler and industrial furnace
black liquor solids
confldence coefficient
calibration drift
calibration error
continuous emissions monitor
continuous emissions monitoring system
continuous emissions rate monitoring system
calibration error test
Code of Federal Regulations
cylinder gas audit
elemental analysis for determination of C, H, N, O, and S content in fuels
concentrated non-condensable gas
catalytic oxidizer
chain of custody
continuous opacity monitoring system
condensable particulate matter
continuous parameter monitoring system
combustion turbine
conditional test method
catalytic thermal oxidizer
cold vapor atomic absorption spectroscopy
equivalent diameter
destruction efficiency
polychlorinated dibenzo-p-dioxins (PCDDS)
detection level limited
dilute non-condensable gas
electron capture detector
Engineer in Training
el ectrolyti c cond uctivity detector (ha I I detector)
estimated maximum possible concentration
US Environmental Protection Agency
Electric Power Research Institute
emission standard (applicable limit)
electrostatic preci pitator
emission unit
fluid catalytic cracking unit
fl ue gas desulfurization
31 of 95 GP08 1AS-0527 27 -PP -980
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FI
FIA
FID
FPD
FPM
FNR
FTPB
FTRB
Furans
GC
GC/MS
GFMS
GFC
GHG
HAP
HC
HHV
HPLC
HRGC/HRMS
HRSG
IC
ICAP
ICPCR
ICP-MS
IR
ISO
KW
LFG
LHV
LPG
MACT
MDI
MDL
MNOC
MRL
MS
NA
NCASI
NCG
ND
NDIR
NESHAP
NG
NIOSH
NIST
NMC
NMOC
NMVOC
NPD
NSPS
flame ionization
flame ionization analyzer
flame ionization detector
fl ame photometric detector
fi lterable particulate matter
Fourier-transform infrared spectroscopy
field train proof blank
field train recovery blank
polychlorinated d ibenzofurans (PCDFS)
gas chromatography
gas chromatogra phy/mass spectroscopy
g ra ph ite fu rnace atom ic a bsorption spectroscopy
gas filter correlation
greenhouse gas
hazardous air pollutant
hydrocarbons
higher heating value
high performance liquid chromatography
high -resolution gas chromatog raphy/high-resolution mass spectroscopy
heat recovery steam generator
ion chromatography
inductively-coupled argon plasma emission spectroscopy
ion chromatography with a post-column reactor
inductively coupled plasma-mass spectroscopy
infrared radiation
International Standards Organization
kilowatts
landfill gas
lower heating value
liquified petroleum gas
maximum achievable control technology
methylene diphenyl diisocyanate
method detection limit
maximum normal operating conditions
method repofting limit
mass spectrometry
not applicable or not available
National Council for Air and Steam Improvement
non-condensable gases
not detected
non-dispersive infrared
National Emissions Standards for Hazardous Air Pollutants
natural gas
National Institute for Occupational Safety and Health
National Institute of Standards and Technology
non-methane cutter
non-methane organic compounds
non-methane volatile organic compounds
nitrogen phosphorus detector
New Source Performance Standards
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OSHA
PAH
PCB
PCWP
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PE
PFAS
PI
PID
PM
PMro
PMz.s
POM
PS
PSD
PSEL
PST
PTE
PTM
QA/QC
QI
QSTI
RA
RAA
RACT
RATA
RCTO
RICE
RM
RTO
SAM
SCD
scR
SD
Semi-VOST
SRM
TAP
TBD
TCA
TCD
TGNENMOC
TGNMOC
TGOC
THC
TIC
TO
TO
TPM
TSP
TTE
ULSD
Occupational Safety and Health Administration
polycyclic aromatic hydrocarbons
polychlorinated biphenyl compounds
plywood and composite wood products
Professional Engineer
per- and polyfluoroalkyl substances (PFAS)
photoionization
photoionization detector
particulate matter
particulate matter less than 10 microns in aerodynamic diameter
particulate matter less than 2,5 microns in aerodynamic diameter
polycyclic organic matter
performance specifi cation
particle size distribution
plant site emission limits
performance specifi cation test
permanent total enclosure
performance test method
quality assurance and quality control
Qualified Individual
Qualified Source Testing Individual
relative accuracy
relative accurary audit
reasonably available control technology
relative accuracy test audit
rotary concentrator thermal oxidizer
stationary reciprocating internal combustion engine
reference method
regenerative thermal oxidizer
sulfuric acid mist
su lfur chemiluminescent detector
selective catalytic reduction system
standard deviation
seml-volatile organic compounds sample train
standard reference material
toxic air pollutant
to be determined
thermal conductivity analyzer
thermal conductivity detector
total gaseous non-ethane non-methane organic compounds
total gaseous non-methane organic compounds
total gaseous organic compounds
total hydrocarbons
tentatively identifi ed compound
thermal oxidizer
toxic organic (as in EPA Method TO-15)
total particulate matter
total suspended particulate matter
temporary total enclosure
ultra-low sulfur diesel
33 of 95 GP08 1AS-0 527 27 -PP -980
UV
VE
voc
VOST
WC
WWTP
ultraviolet radiation range
visible emissions
volatile organic compounds
volatile organic sample train
water column
waste water treatment plant
Clz
ClOz
co
Co
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CHgCHO acetaldehyde
silver
arsenic
barium
beryllium
carbon
cadmium
cadmium sulfide
formaldehyde
methanol
methane
ethylene oxide
ethane
acrolein
propionaldehyde
propane
Ag
As
Ba
Be
c
cd
cds
CHzO
CHsOH
CHa
CzH+O
CzHe
CrHcO
CaHeO
CgHe
Coz
Cr
Cu
Eto
EtOH
F.
Hz
HzO
HzOz
HzS
HzSOr
HCI
Hg
IPA
MDI
MeClz
MEK
MeOH
Mn
Nz
NHs
Ni
NO
NOz
CHEI,IICAL NOMENCLATURE
NOx nitrogen oxides
Oz oxygenP phosphorus
Pb lead
PCDD polychlorinated dibenzo-p-dloxins
PCDF polychlorinated dibenzofuransSb antimonySOz sulfur dioxideSOr sulfur trioxide
SO, sulfur oxides
TCDD tetrachlorodibenzodioxin
TCDF tetrachlorodibenzofuran
TGOC total gaseous organic concentration
TF total fluoride
THC total hydrocarbons
Tl thallium
TRS total reduced sulfur compounds
Zn zinc
CeHsOH phenol
chlorine
chlorine dioxide
carbon monoxide
cobalt
carbon dioxide
chromium
copper
ethylene oxide
ethyl alcohol (ethanol)
fluoride ion
hydrogen
water
hydrogen peroxide
hydrogen sulflde
sulfuric acid
hydrogen chloride
mercury
isopropyl alcohol
methylene diphenyl diisocyanate
methylene chloride
methyl ethyl ketone
methanol
manganese
nitrogen
ammonia
nickel
nitric oxide
nitrogen dioxide
35 of 95 GP08 1AS-0 527 27 -PP -980
Appendix A.2
Accreditation Informatio n I Certifications
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Appendix A.3
Stack Schematics
G P08 1AS-0 5 27 27 -PP -980
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Stack Drawlng & Travrme Polnl Locadon
Cllent lnt rrt t Bdck Comprny
Clty / Stata: W..t Jordrn, ln h
soum: Llm *i Klln W.i Scrubbcr
Job No.: PRO,{52727
Dato: 3/4i2025
lnput q[ Joby Dunml]r
ot Trrw[.: Vrloclty or Parllcultt :FttggttEi. Pon Typ. Port Dllmotcr
Stlck Ar.., Ff:
Numb.r o, Porlr:
Dlm.t r, lnch..: 72
H.lght, t .t:
28.n1
Strck Duct Dlam.t.l! L.ngth ofPort lncher:6.00
UFtrr.m Frcm Flow Dlttutblnc. (A):00
't80
0.E3 TotalNumbcrofTEv.rtaPolnt :u
Fmm Flil Dl3turbrnca 2.il Numb.r of Polntr Dar Dort / trryaltat 12 12
TNCHES lnslde St!d(
lnchaa
Out ldc Mpph
lncll.Polnt No.
L
*,1,_",..
I
1
2
3
1
5
6
7
8
I
l0
11
12
1.5
t.8
8.5
1L7
18.0
25.6
46.4
5.1.0
5e.3
Gt.5
tt.2
70.5
7.5
10.8
1 '4.5
't8.1
21.0
3r.6
52.1
00.0
65.3
69.5
73.2
76.5
'MJurtcd polntt dlm.t.r > 24' no polnt clo3.r th.n 1.0 lnch
' MJuat d polnt dlm.t.r32'l' no polnt clo..rth.n 0.5 lnch
Stack Dlrmt r b.trrron 12-24 lrch6 mlnlmum polntt !rc 6 ;
.lpolnt perpottl,thoE/2dllm.t ]!down lf !mrnd
up3f.rm crftrrlr la mat
o
!=oE
GP08 1AS-0527 27 -PP -980
Stack Drawlng & Travorse Polnt Locatlon
Cllant: lnt r.tat Brlck Complny
City / State: W.d Jordln, Utrh
Source: Lln. rr4 lllnufaclurlng Blghous
Job No. : PROJ{52727
Dato: 3r{2025
lnput By: Joby Dunmlru
o, Trrvcr.: Vcloclty or Prrtlculrt :Plrtlcuht PortTypc
Strck Ana, Ff:
Numb.r o, Ports:
Duct Dltm.tort L.ngth of Pod, lncho3:
0.994
2
5.00
't6Upitr.lm From Flow Dl.turb.n6 (A):Totd Numbot of Travar. Polnta:
INCHES ln.ldc St ct
lncha3
Out ldc Nlpplo
lnchcaPolnt No.
I
2
3
1
5
6
7
I
0.5
't.a
2.4
4.4
0.1
10.0
1L1
1t.0
rdju3i.d 5.5
0.4
7.6
0.4
11.1
15.9
17.1
18.0
21-s INCHES
ldlust.d
' AdJurtod polnt dlarflct r > 24' no polnt clor.r th.n 1,0 lnch
' Adru3t d polntr dllmat.r S 2rl" no polnt clo3cr than 0.5 lnch
Stack Dl.m.torr bctwocn 12-Zl lnch.. mlnlmum polnb !ro E;
'0 polnt per port lt tho E / 2 dhmct lt down3tr.lm lnd
up3tralm crltarh lr mat
?o
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I40 of 95 GP08 1AS-05 27 27 -PP -980
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Strck Dmwlng & Travorue Polnt Locatlon
Cliont IntcEtd. Brlck Comp.ny
Clty / Stalo: W..t Jord.n, Utah
Sourco: Prlm.ry Cru.h.r Btghour.
JobNo.: PRO.r{527?
Date: 3rttzoils
lnput Bla Joby Dunmlrc
of Tr!wrt.: V.loclty or Plrtlculltc:Plrllcuhtc Port Typ. Port Dllm.ter
Stack Ane, Ff:
Number of Poilr:
L.ngilh of Porl, lnch..:
Total Numbor of Trlelto Polntr:
Dllmct r, lnch.3: 26
H.lght f..t:
3.6E7
Silck 2.00
Up.lr..m F om Flow Dl3turbanc. (A):36 1.3E
4.08
u
Numbar of Polnta Dgr Dort / trllrc]te:
26.0 INCHES lnrld. Strck
lncher
Out ld. illpplc
lnch.aPolnt No.
1
2
3
1
5
6
7
8
0
10
1'l
12
1.0
1.7
3.1
4.6
0.5
9.3
16.7
19.5
21.1
an.9
21.t
25.0
'.dJu.t d 3.0
t.7
5.1
0,8
8.5
11.3
14.7
21.5
23.1
u.9
26.3
n.0
3G.0 INCHES
'adluatad
'Adju.t d polnt dl.mot.r > 2t0' no polnt clot r th.n 1.0 lnch
' AdJu.t d polntr dlameLr S 24' no polnt cloaor thrn 0.5 lnch
Strd( Dlam.t I b.lwon 12-24 lrch6 mlnlmum polntt .E 8 ;
4 polnts per port lf th. 8 / 2 dl.m.iorr downrtrum rnd
up3tr.!m crltarla 13 mat.
tlitcHEs
o
-.E)iE
41 of 95 GP08 1AS-0 s27 27 -PP -980
Appendix A.4
UDEQ Title V Operating Permit #35OO2OOOO1
G P08 1AS-0s 27 27 -PP -980
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Department of
Environmental Quality
Alan Matheson
Exeantive Director
DIVISION OF AIR QUALITY
Bryce C. Bind
Director
10423
State of Utah
GARYR. HEBAERT
Goveraor
SPENCERJ. COX
Liaterrarrt Governor
Title V Operating Permit
PERMIT IIUMBER: 350020000 1
DATE OF PERMIT: October 10,2018
Date of Last Revision: October 10, 2018
This Operating Perrrit is issued to, and applies to the following:
Name of Permittee:
lnterstate Brick Company
9780 South 5200 West
West Jordan, UT 84081-5625
Permitted Location:
Interstate Brick Company Plant
9780 South 5200 West
West Jordan, UT 84081-5625
UTM coordinates: 413,500 m Easting, 4,497,500 m Northing
SIC code: 3251 (Brick & Structural Clay Tile)
By:Prepared By:
Bryce C. Bird, Director Robert Grandy
195 North 1950 Wcst. Salt lakc City, UT
Mailing Address: P.O. Box 144820 . Salt Iltc City, UT E4l 14-4820
Tclephone (801) 5364000 . Fu (801) 5364099 . T.D.D. (801 ) 903-3978
w.deq.uah.gov
printcdon 4y.dfgy**G P08 1AS-0 5 27 27 -PP -980
ENFORCEABLE DATES AND TIMELINES
The following dates or timeframes are referenced in
Section I: General Provisions of this permit.
Annual Certification Due: October 10, and on that date of every calendar year that this
permit is in force.
Aprill0,2023
October 10,2023
written notification within 14 days.
Renewal application due:
Perrnit expiration date:
Definition of "prompt":
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ABSTRACT
Interstate Brick Company (ISB) operates a manufacturing plant in West Jordan City, Utah. Emissions are
primarily associated with the hauling and processing of raw clay to produce brick and tile products. ISB is
located in Salt Lake County, a non-attainment area for PM1s, PM 2.5, SO2, and a maintenance area for Ozone.
ISB is a major source of CO. ISB is subject to 40 CFR Part 63 Subpart A- General Provisions, and Subpart
CCCCCC- Gasoline Dispensing Facilities.
Project OPP0104230003 Page44 of 95 gnBYAIE@81fl @bfl EtllBS02oooo I
PermiUActivitv Date Issued Recorded Chanqes
Title V initial application
(Proiect #OPP0 1 04230003)
October 10,
2018
Initial permit issued.
OPERATING PERMIT HISTORY
I ProjectoPP0l04230003 Pree{S of 95 6nWnD6lil@brPit1ilt$0200001
Table of Contents
ENFORCEABLE DATES AND TIMELII\ES
't
OPERATING PERMIT IIISTORY.
SECTION I: GENERAL PROVISIONS............................5
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Issued under authority of Utah Code Ann. Section 19-2-104 and 19-2-109.1, and in accordance with
Utah Administrative Code R307-415 Operating Permit Requirements.
All definitions, terms and abbreviations used in this permit conform to those used in Utah Administrative
Code R307-l0l and R307415 (Rules), and 40 Code of Federal Regulations (CFR), except as otherwise
defined in this permit. Unless noted otherwise, references cited in the permit conditions refer to the Rules.
Where a permit condition in Section I, General Provisions, partially recites or summarizes an applicable rule,
the full text of the applicable portion of the rule shall govern interpretations of the requirements of the rule.
In the case of a conflict between the Rules and the permit terms and conditions of Section II, Special
Provisions, the perrnit terms and conditions of Section II shall govem except as noted in Provision I.M,
Permit Shield.
SECTION I: GENERAL PROYISIONS
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". (R307-4 1 5-6b)
Permitted Activitv(ies).
Except as provided in R307415-7b(1), the pennittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)
Dutv to Complv.
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. (R307415-6a(6)(a))
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. (R307415-6a(6)O)
The permittee shall fumish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modiffing,
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 fumish such records directly to the EPA along with a claim of
confidentiality. (R3 074 I 5 -6a(6Xe))
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. (R307415-6a(6)(c))
Project OPP0104230003 Page 5 47 of 95 ritB roeDffi 05 maxilEp{mDooor
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I.D.2
I.D.3
I.D.4
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Permit Expiration and Renewal.
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. (ru07a15-6a(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. (R307415-5a(lXc))
An application for renewal submiued 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. (ru07a1 5-5a(5))
Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307415-7b (see also Provision I.E,
Application Shield) and R307415-5a(l)(c) (see also Provision I.D.2). (ru07a15-7c(2))
Apnlication 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 pemrit renewal application. ln such case, the tenns 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 R307415 -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. (R3074 15 -7b(2))
Severabilitv.
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. (rc07a15-6a(5))
Permit f,'ee.
The pemrittee shall pay an annual emission fee to the Director consistent with R307415-9.
@307a1s-6a(7))
The emission fee shall be due on October I of each calendar year or 45 days after the sowce
receives notice of the amount of the fee, whichever is later. (R307415-9(4Xa))
No Propertv Riehts.
This permit does not convey any property rights of any sort, or any exclusive privilege.
(R30741s-6a(6)(d))
Revision Exceotion.
No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar prograrns or processes for changes that are
provided for in this permit. (ru07a15-6a(8))
Inspection and Entrv.
Upon presentation of credentials and other documents as may be required by law, the
I.J
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Project OPP0f04230003 Page 6 48 of 95 ritB r001ffi 05 ?railFf;rfi 40001
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permittee shall allow the Director or an authorized representative to perform any of the
following:
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.
(R30741s-6c(2)(a)
Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307415-6c(2xb))
Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-41 5-6c(2Xc))
Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements. (R307415-
6c(2Xd))
Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section l9-l-306. (R307415-6c(2)(e))
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 inqurry, the statements and information in the document
are true, accurate, and complete. (R307415-5d)
Comoliance Cerffi cation.
Permittee shall submit to the Director an annual compliance certification, certiffing
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): (R307415-
6c(s))
The identification of each term or condition of this permit that is the basis of the
certification;
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
necesszry, the permittee also shall identiff 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;
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.l.b. The certification shall identiff each deviation and
take it into account in the compliance certification. The certification shall also
identi$ as possible exceptions to compliance any periods during which compliance
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is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and
Such other facts as the Director may require to determine the compliance status.
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: (R307415-
6c(s)(d))
Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129
Permit Shield.
Compliance with the provisions of this perrnit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:
Such applicable requirements are included and are specifically identified in this
permit, or (R307415-6f(t)(a)
Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307415-6f(lXb)
Nothing in this perrnit shall alter or affect any of the following:
The emergency provisions of Utah Code Ann. Section l9-l-202 and Section 19-2-
ll2, and the provisions of the CAA Section 303. (R307415-6f(3)(a))
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 l9-2-ll0
prior to or at the time of issuance of this permit. (R307415-6f(3xb)
The applicable requirements of the Acid Rain Program, consistent with the CAA
Section a08(a). (R30741 s-6f(3Xc))
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. (R307415-6f(3xd))
Emergencv Provision.
An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307a15-6g(l))
An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:
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An emergency occurred and the permittee can identiff the causes of the emergency.
(R30741s-6g(3Xa)
The permitted facility was at the time being properly operated. (R307415-
0e(:)(b))
During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R3074 I 5-6g(3Xc))
The permittee submitted notice of the emergency to the Director within two
working days of the time when emission limitations were exceeded due to the
emergency. This notice must contain a description of the emergency, any steps
taken to mitigate emissions, and corrective actions taken. This notice fulfills the
requirement of Provision I. S.2.c below. (R3074 1 5 -6g(3xd)
In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (m07al5-6g(a))
This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (ru07a15-69(5))
Ooerational Flexibilitv.
Operational flexibility is govemed by R307415-7d(l).
Off-oermit Chanees.
Off-permit changes are govemed by R307415 -7d(2).
Administrative Permit Amendments.
Administrative permit amendments are govemed by R307415-7e.
Permit Modilications.
Permit modifications are governed by R307415-7f.
Records and Reporting.
Records.
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. (R307415-6a(3)(b)(ii))
For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable: (R307415-
6a(3XbXi))
The date, place as defined in this permit, and time of sampling or
measurement.
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r.s.l.b.2
r.s.l.b.3
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I.S.2
I.S.2.a
The date analyses were performed.
The company or entity that performed the analyses.
The analytical techniques or methods used.
The results ofsuch analyses.
The operating conditions as existing at the time of sampling or
measurement.
Additional record keeping requirements, if any, are described in Section II, Special
Provisions.
Reports.
Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from perrnit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))
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. (R307415-
6a(3)(c)(i)
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 ofsuch 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.
(R3074 I s-6a(3)(c)(ii))
Notification Addresses.
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 ciry, uT 841144820
Phone: [phone]
All reports, notifications or other submissions required by this permit to be
submiued 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 certifi cations:
Environmental Protection Agency, Region VItr
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129
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For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:
Environmental Protection Agency, Region VIII
Office of Parbrerships and Regulatory Assistance Air and Radiation Program
(mail code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]
Reopening for Cause.
A permit shall be reopened and revised under any of the following circumstances:
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 R3074 I 5 -7 c(3), application shield. (R3074 I 5-7e( 1)(a))
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. (R307415-7e(l)(c))
EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R3074 I 5-7g( I )(d))
Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions. (R307415-
7e(lXe))
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-
7e(l)O))
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. (B07al s-7g(2))
Inventorv Requirements.
An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission lnventories. (R307-l 50)
Title IV and Other. More Strineent 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. (R307415-6a(lXb)
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SECTION II: SPECIAL PROVISIONS
Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-4 I s4(3Xa) and R3074 1 54(4))
Permitted Source
Source-wide
Line #1
Tunnel Kiln #1. Listed for identification purposes only. Not approved for operation.
Line #3
Includes: Line #3 kiln, packed tower scrubber (60,000 ACFM) with mist eliminator, and
baghouse (MilaoPul).
Line ll4
Includes: Line #4 kiln
Wet scrubber (89,800 ACFM) with mist eliminator, vacuum cleaner, shapes dryer, and baghouse
(MilaoPul).
Grizzly Hopper
Pre-August 31, 1983.
Primary and Secondary Crushers
Pre40 CFR Part 60, Subpart OOO facilities:
(A) primary crusher (100 ton/hr) with pulse jet baghouse. Primary crusher replaced after the
NSPS effective date with equipment of equal or smaller size. Exempted from Subpart OOO by
provision 40 CFR 60.670(dXl).
(B) Secondary crusher/grinding. Pre-August 31,1983.
(C) Screens. Pre-August 31,1983.
Silos
Two lime silos.
Clay Storage Piles
Storage for raw materials.
Gasoline Storage Tank- 40 CFR 63 Subpart CCCCCC
Above ground gasoline storage tank for fueling vehicles. Capacity approximately 1,000 gallons.
Throughput less than 10,000 gallons per month.
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II.A. l0 Diesel Storage Tanks
Above-ground diesel storage tank for fueling vehicles. Capacity approximately 2,000 gallons.
II.A.I I Degreasers
Four parts washers.
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I II.B Requirements and LimitationsI
The following emission limitations, standards, and operational limitations apply to the permitted facility
I as indicated:I ILB.I Permitted Source (Source wide)
I rl.B.l.a Condition:
Plant wide production/consumption shall not exceed:
I l) 2,880 tons raw clay consumption per rolling 24-hour period.
I 2) 393,236 tons of brick produced in Line #3 and Linell4 combined per
I rolling l2-month period.
3) 512,582 tons of brick produced plant-wide per rolling l2-month
I oeriod.
[Authority granted under R307a0l-8(l)(a)[BACT]; condition originated in DAQE-AN104230017-161.
I tr.B.l.a.I Monitoring:
I il.B.t.a.2 "::ffi;quirements
for this permit condition shall serve as monitoring'
I To demonstrate compliance with a rolling l2-month total, a new l2-month total shall bef calculated by the twentieth day of each month using data from the previous 12 months.
I To demonstrate compliance with a rolling 24-hour total, a new 24-hour total shall be calculated
I after each hour ofoperation using data from the previous 24 hours.
Production/consumption records shall be kept on a daily basis and maintained in accordance with
I provision I.S.l of his permit.
II.B.l.a.3 Reporting:
I H;fir1"
no reporting requirements for this provision except those specified in Section I of this
I II.B.l.b condition:
Visible emissions from the following emission points shall not exceed the following values:
I (l) All screens - lo% opacity.
(2) All conveyor transfer points - l0%o opacity.
I (3) All baghouses - lo% opacity.
(4) All buildings enclosing crushers - 10% opacity.
I ,r, ^, crushers - l5%o opacity.
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(6) All other points onsite- 20%o opacity.
[Authority granted under R307401-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-161.
I Project OPP0104230003 Page 13 55 of 95 TitEFOelffiErEIUAIifrtrqO000lI
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rLB.1.b.r Monitoring:
If an affected emission unit is operated during a calendar quarter, an opacity observation of the
emission unit shall be performed in the calendar quarter that the emission unit was operated. The
opacity observation can be conducted at any time during the quarter. The opacity observation
shall be conducted by an individual trained on the observation procedures of40 CFR 60,
Appendix A, Method 9, while the emission unit is operating. If visible emissions other than
condensed water vapor are observed from the emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial visual
emission observation. The opacity determination shall be performed in accordance with 40 CFR
60, Appendix A, Method 9.
Recordkeeping:
The permittee shall keep a log which includes the location and description of each affected
emission unit. For each calendar quarter for each affected emission trnit, the log shall include
either the date of the opacity observation and if visual emission other than condensed water vapor
were observed or a note that the emission rnit was not operated. For each observed visual
emission other than condensed water vapor the permittee shall record: date and time of visual
emission observation, emission unit location and description, time and date of opacity
determination, and percent opacity. The records required by this provision and all data required
by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with Provision LS.l of
this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
The moisture content of the clay shall be maintained at an average of no less than 4.0%by
weight. [Authority granted under R307a0l-8(l)(a)[BACT]; condition originated in DAQE-
AN104230017-161.
Monitoring:
Clay moisture content shall be monitored using a moisture meter. The moisture meter shall be
calibrated biannually according to manufacturer specifications and procedures.
Recordkeeping:
Clay moisture content shall be recorded once a calendar week. Records of moisture meter
calibrations shall be maintained. A copy of manufacturer specifications for moisture meter
operation, maintenance, and calibration shall be kept on site. Records shall be maintained in
accordance with Provision I.S.l of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
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I II.B.I.d condition:
The plant-wide emissions of VOCs from the brick manufacturing plant and associated operations shall
I not exceed 14.87 tons per rolling l2-month period for VOCs. [Authority granted under R307-401-
I 8(1Xa)[BACT]; condition originated in DAQE-AN104230017-16).
a II.B.l.d.l Monitoring:I Compliance with the limitation shall be demonstrated on a rolling l2-month total. Based on the
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each month, a new l2-month total shall be calculated using data from the
The VOC emissions shall be determined by maintaining a record of VOC-emitting materials
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used each month. The record shall include the following data for each material used:
A. Name of the Voc-emitting material, such as: paint, adhesive, solvent, thinner,
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reducers, chemical compounds, toxics, isocyanates, etc.
B. Density of each material used (pounds per gallon).
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C. PercentbyweightofallVOCineachmaterialused.
D. Gallons of each VOC-emitting material used.
I E. The amount of VOC emiued monthly by each material used shall be calculated by
the following procedure :
I voc : r*%tr* x t Di#iriv ( tb )l x Gar consumed *ffib
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F. The amount of VOC emitted monthly from all materials used.
G. The amount of VOCs reclaimed for the month shall be similarly quantified and
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quantities calculated above to provide the monthly total
II.B.1.d.2 Recordkeeping:
I Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.
r II.8.1.d.3 Reporting:I There are no reporting requirements for this provision except those specified in Section I of this
permit.
II.B.1.e Condition:
t The plant-wide emissions of HAPs from the brick manufacturing plant and associated
operations shall not exceed:
t T.2tonsperrolling l2-monthperiodforHCl
6.7 tons per rolling 12-month period for IIF
I 7.0 tons per rolling l2-month period for miscellaneous HAPs
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18.2 tons per rolling l2-month period for all HAPs combined.
[Authority granted under R307a01-8(1Xa)[BACT]; condition originated in DAQE-AN104230017-161.
Monitoring:
Compliance with the limitation shall be demonstrated on a rolling l2-month total. Based on the
twentieth day of each month, a new l2-month total shall be calculated using data from the
previous 12 months.
Compliance with HF and HCI limitations listed above shall be demonstrated using the mass
balance plan approved by the Director, submitted by ISB on October 22,2009 (See AO DAQE-
AN104230017-16, Appendices A-C) .
If ISB submits any additional revised mass balance methods for determining annual emissions to
the Director for approval, the plan shall include, at a minimum, the following:
A. Proposed test methods and test frequency for determining the weight of the elemental fluorine
contained in the clays used to manufacture brick.
B. Proposed test methods and test frequency for determining the weight of the elemental fluorine
contained in the finished product.
C. Calculation method of determining emissions of HCL and Ftr which will demonstrate
compliance with the HCI and IIF emission limitations listed above. The miscellaneous HAP
emissions shall be determined by maintaining a record of tlAP-emitting materials used each
month. The record shall include the following data for each material used:
l. Name of the HAP-emitting material, such as: paint, adhesive, solvent, thinner,
reducers, chemical compounds, toxics, isocyanates, etc.
2. Density of each material used (pounds per gallon).
3. Percent by weight of all HAP in each material used.
4. Gallons of each HAP-emitting material used.
5. The amount of HAP emitted monthly by each material used shall be calculated by
the following procedure:
HAP:%HAPbvWeiehtx [Densitv( lb )] xGalConsumedx l ton
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6. The amount of HAPs emitted monthly from all materials used.
7. The amount of HAPs reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above to provide the monthly total VOC
emissions.
Recordkeeping:
Results of monitoring shall be maintained in accordance with Provision I.S.l of this permit.
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Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Fugitive Dust:(l) The permittee shall submit and abide by a fugitive dust control plan acceptable to the Dhector for
control of dust. lOrigin: DAQE-ANI04230017-161.
The fugitive dust control plan must include contact information, site address, total area of disturbance,
expected start and completion dates, identification ofdust suppressant and plan certification by signature
of a responsible person. [Origin: R307-309-6(5)]
(2) Opacity caused by fugitive dust shall not exceed l0%o at the property boundary, and20% on site.
[Origin: R307-309-5(l )]
(3) State Only Requirements: The above opacity requirements shall not apply when the wind speed
exceeds 25 miles per hour if the owner or operator has implemented, and continues to implement, the
accepted fugitive dust control plan and administers one or more of the following contingency measures:
(a) Pre-event watering;
(b) Hourly watering;
(c) Additional chemical stabilization;
(d) Cease or reduce fugitive dust producing operations to the extent practicable.
[Origin: R307-309-5(3)]
(a) The permittee shall limit vehicle speeds on haul roads as follows:
(a) 15 mph within the plant and in the vicinity of the crusher; and
(b) 25 mph between the plant and the paved highway. Speed limit signs shall be posted at the
entrance to the active haul road area.
[Origin: DAQE-AN I 04230017 -t 6].
(5) All roads and other operational areas that are used by mobile equipment shall be sprayed with water
to control fugitive dust. Treatment shall be applied of sufficient frequency and quantity to maintain the
surface material in a condition such that fugitive emissions are minimized, unless the ambient temperature
could result in freezing conditions.
[Authority granted under R307401-8(l)(a)[BACT]; condition originated in DAQE-AN104230017-16}
(6) The storage piles shall be watered to minimize generation of fugitive dusts as dry conditions warrant
or as determined necessary by the Director.
[Authority granted under R307a0l-8(l)(a)[BACT]; condition originated in DAQE-AN104230017-161.
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II.B.1.f.1 Monitoring:
(l) For paragraph (l) ofthe above condition: recordkeeping shall serve as monitoring for the
most recently approved fugitive dust control plan.
(2) For paragraph (2) of the above condition: adherence to the most recently approved fugitive
dust control plan shall be monitored to demonstrate that appropriate measures are being
implemented to control fugitive dust in lieu of monitoring via visible emissions observations.
(3) For paragraph (3) of the above condition: wind speed shall be measured by an anemometer to
identifu periods when velocity exceeds 25 mph. [Origin: R307-309-5(4); State Only
Requirement]
(4) For paragraph (4) of the above condifion: vehicle/equipment speed shall be observed at a
minimum of once each year. Additionally, at least once each year, all speed limit signs shall be
inspected to assure they are still present.
(5) For paragraph (5) of the above condition: recordkeeping shall serve as monitoring (fugitive
dust control requirements that apply to roads).
(6) For paragraph (6) of the above condition: recordkeeping shall serye as monitoring (fugitive
dust control requirements that apply to storage piles).
Recordkeeping:
The following records shall be maintained in accordance with Provision I.S.l of this permit:
(l) The most recently approved fugitive dust conftol plan. Records required by the most recently
approved fugitive dust contol plan shall be maintained in accordance with the plan.
(2) Measures taken to control fugitive dust.
(3) If wind speeds are measured to establish an exception from the visible emissions limits,
records of the administered contingency measures and the wind speed measurements shall be
maintained. [State Only Requirement]
(4) Observations of the vehicle/equipment speed, and inspections of speed limit signs.
(5) Records of water treatnent to suppress fugitive dust from roads. [n addition to the
requirements of Provision I.S.l of this permit, records shall include the following items:
A. Number of treatments made;
B. Dilution ratio of treatments;
C. Quantity applied;
D. Rainfall received, if any, approximate amount; and
E. Time of day treatments were made.
[Origin: DAQE-AN I 04230017 -t 6)
(6) Records of water treatment to suppress fugitive dust from storage piles. In addition to the
requirements of Provision LS.l of this permit, records shall include the following items:
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A. Number of treatments made;
B. Dilution ratio of treatrnents;
C. Quantity applied;
D. Rainfall received, if any, approximate amount; and
E. Time of day treatments were made.
[Origin: DAQE-ANI 04230017 -161.
(7) Records shall be maintained in accordance with section I.S.l of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Line #3
Condition:
All exhaust air from Kiln #3 process streams shall be routed through the wet scrubber before being vented
to the atmosphere. [Authority granted under R307401-8(1)(a)[BACT]; condition originated in DAQE-
AN104230017-16).
Monitoring:
Records required for this permit condition will serve as monitoring.
Recordkeeping:
Records shall be kept for all periods when the scrubber is not in use during line #3 operation.
Records shall be maintained in accordance with Provision I.S.l of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Emissions from the Kiln #3 Scrubber Tunnel shall not exceed:
Total PM2.5* .....8.66 lb/hr (l-hr average).
PMrg ......8.66 lb/hr (1-hr average).
NO*...... 5.07 lb/hr (1-hr average).
SOz ...... 8.09 lb/hr (1-hr average).
Total Fluorides...... 1.7 7 lb/tu ( 1 -hr average).
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* Including front halfand back halfcondensables.
[Authority granted under R307a0l-8(l)(a)[BACT]; condition originated in DAQE-AN104230017-161.
Monitoring:
Stack testing shall be performed as specified below:
(l) Frequency
Kiln #3 Scrubber Tunnel emissions shall be tested as follows:
PMle and PM 2.5......every three calendar years.
NO,...................... every three calendar years*.
SO2...................... every calendar year.
Total Fluorides........ every five years based on the date of the last test.
Additional tests may also be required at the direction of the Director.
* If production exceeds 294,927 tons of brick produced per rolling l2-month period then testing
will be conducted each calendar year and within 90 days of exceeding the 294,927 ton limit.
(2) Notification
At least 30 days before the test, the source shall notiff the Director of the date, time, and place of
testing and provide a copy ofthe test protocol. The source shall attend a pretest conference if
determined necessary by the Director.
(3) Methods
(a) Sample Location
The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method 1, and Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test
location.
(b) Emissions tests:
(1) PMro and PM 2.5:
(i) 40 CFR 51, Appendix M, Method 201a and Method 202, or
(ii) 40 CFR 60, Appendix A, Method 5 and 40 CFR 51, Appendix M,
Method 202.
(2) NO.: 40 CFR 60, Appendix A, Method 7E.
(3) SOz: 40 CFR 60, Appendix A, Method 6C.
(4) Total Fluorides: 40 CFR 60, Appendix A, Method 13B.
(c) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.
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(d) Or other EPA approved testing methods acceptable to the Director.
(4) Calculations
To deterrnine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director to give the results in the specified units of the
emission limitation.
(5) Production Rate During Testing
For a source/emission point, the production rate during compliance testing shall be no less than
90% of the maximum allowable production rate (17.92 tons of product per hour). If the maximum
allowable production rate cannot be achieved at the time of the test, the following procedure shall
be followed:
(a) Testing shall be at no less thar,9Ooh of the anticipated annual production rate.
(b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be 110% of the rate achieved during the latest test.
(c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to ll0Yo of the highest tested rate that demonstrates compliance with
the limits limited in this condition.
Recordkeeping:
Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Emissions from the Line #3 Baghouse shall not exceed:
(l) Total PM2.5* ..........0.18 lbAr and 0.016 grains/dscf (1-hr average); and
(2) PMrg**. ..... 0.18lbftr and 0.016 grains/dscf (l-hr average).
*(dry filterable particulate only), including front half and back half condensables.
**(dry filterable particulate only)
[Authority granted under R307401-8(l)(a)[BACT]; condition originated in DAQE-AN104230017-161.
Monitoring:
Stack testing shall be performed as specified below:
(l) Frequency: every three calendulr years.
Additional tests may also be required at the direction of the Director.
Project OPP0104230003 Page 21 63 of 95 ritB roerffi 0l ft oriopqE46s61
(2) Notification
At least 30 days before the test, the source shall notiff the Director of the date, time, and place of
testing and provide a copy ofthe test protocol. The source shall attend a pretest conference if
determined necessary by the Director.
(3) Methods
(a) Sample Location
The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method 1, and Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test
location.
(b) Emissions tests for PMls and PM 2.5:
(1) 40 CFR 51, Appendix M, Method 201a (Method202, dry impinger not
required), or
(2) 40 CFR 60, Appendix A, Method 5 (40 CFR 51, Appendix M,
Method 202, dry impinger not required).
(c) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.
(d) Or other EPA approved testing methods acceptable to the Director.
(4) Calculations
To determine mass emission rates (lblhr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director to give the results in the specified units of the
emission limitation.
(5) Production Rate During Testing
For a source/emission point, the production rate during compliance testing shall be no less than
90% of the maximum allowable production rute (17.92 tons of product per hour). If the maximum
allowable production rate cannot be achieved at the time of the test, the following procedure shall
be followed:
(a) Testing shall be at no less than90o/o of the anticipated annual production rate.
(b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be 110% of the rate achieved during the latest test.
(c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to ll0o/o of the highest tested rate that demonstrates compliance with
the limits limited in this condition.
Recordkeeping:
Records shall be maintained in accordance with Provision I.S.l of this permit.
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Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Line #3 tunnel kiln production shall not exceed 17.92 tons ofproduct per hour.
lAuthority granted under R307a0l-8(l)(a)[BACT]; condition originated in DAQE-AN104230017-161.
Monitoring:
Production calculations shall be based on tons ofproduct per hour averaged over a rolling}4-
hour period. A new 24-hour average shall be calculated after each hour of operation using data
from the previous 24 hours.
Recordkeeping:
Production/consumption records shall be kept on a daily basis and kept for all periods when the
plant is in operation. Records shall be maintained in accordance with provision I.S.l of his
permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Clay Prep for Line #3 shall not exceed 6,240 hours of operation per rolling l2-month period (does not
lnclude Kiln # 3 operating hours) [Authority granted under R307a0l-8(l)(a)[BACT]; condition
originated in DAQE-AN104230017 -l 61.
Monitoring:
Hours of operation shall be calculated based on a rolling l2-month period, a new l2-month total
shall be calculated by the twentieth day of each month using data from the previous 12 months.
Recordkeeping:
Records shall be kept on a daily basis and kept for all periods when the plant is in operation.
Records shall be maintained in accordance with provision I.S.l of his permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Natural gas shall be used for fuel in Kiln #3 with propane as a backup. [Authority granted under R307-
a0 1 -8( 1 Xa)[BACT] ; condition originated in DAQE-AN 104230017 -l 61.
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Monitoring:
Records required for this permit condition will serve as monitoring.
Recordkeeping:
To demonstrate compliance, fuel records shall be kept for all periods when the facility is in
operation indicating purchase ofnatural gas or propane.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
The minimum pressure drop for the Line #3 scrubber shall be 0.1 inches/w.g.
The above limit does not apply during start-up and shut-down of the scrubber. Pressure gauges shall be
located such that an inspector/operator can safely read the indicator at any time.
[Authority granted under R307401-8(l)(a)[BACT]; condition originated in DAQE-AN104230017-161.
Monitoring:
Pressure drop shall be measured once per operating day to demonstrate compliance with the
limitation.
Pressure gauges must be certified by the manufacturer to be acctrate within plus or minus five
percent of the w.g. design. Pressure gauges must be calibrated on an annual basis in accordance
with the manufacturer's instructions.
Recordkeeping:
Pressure drop monitoring results shall be recorded on a daily basis.
Records shall be kept onsite for pressure gauges and shall include: manufacturer certifications,
calibrations, and operating instructions.
Records shall be maintained in accordance with Provision I.S.1 of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Line #3 scrubber fluid shall be maintained between 5-9 pH.
When the scrubber is in operation, the pH shall be within the range specified above, except during start-
up and shutdown of the scrubber.
[Authority granted under R307a0l-8(l)(a)[BACT]; condition originated in DAQE-ANI04230017-161.
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I II.B.2.h.l Monitoring:I
A monitoring device for the continuous measurement of scrubbing solution pH shall be installed,
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calibrated, maintained, and operated.
The monitoring device shall be certified by the manufacturer to be accurate within plus or minus
t ffiffi:#:l:h;ff;;fl:." and must be calibrated on an anmral basis in accordance with the
I ffiJ#l?X;'ll;,device
shall be located such that an inspector/operator can safely read the
1I.8.2.h.2 Recordkeeping:
I ffi# L':,'1,?",,fi[t1:"#[';ffi?:H$T; :Jl"rii#:;""'#t* is not required Records
I rl.8.2.h.3 Reporting:I
I Sffr:"
no reporting requirements for this provision except those specified in section I of this
ILB.2.i Condition:
t The minimum flow rate of Line #3 scrubber fluid shall be 200 gallons per minute.
- When the scrubber is in operation, the minimum flow rate shall be as specified above, except during
f start-up and shutdown of the scrubber. [Authority ganted under R307a01-8(l)(a)[BACT]; conditionr originated in DAQE-AN104230017-161.
I II.B.2.i.l Monitoring:t
A monitoring device for the continuous measurement of flow rate shall be installed, calibrated,
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maintained, and operated.
The monitoring device shall be certified by the manufacturer to be accwate within plus or minus
I [:.#:?::S:'h; i;:ffiffX rate and must be calibrated on an annual basis in accordance with
The flow rate monitoring device shall be located such that an inspector/operator can safely read
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the indicator at any time.
1I.8.2.i.2 Recordkeeping:
t The scrubber flow rate shall be recorded once per operating day. Continuous recording is not
required.
I r1.8.2.i.3 Reporting:I
There are no reporting requirements for this provision except those specified in Section I of this
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Line #4
Condition:
All exhaust air from Kiln #4 process streams shall be routed through the wet scrubber before being vented
to the atmosphere. [Authority granted under R307a0l-8(IXa)[BACT]; condition originated in DAQE-
AN104230017-161.
Monitoring:
Records required for this permit condition will serve as monitoring.
Recordkeeping:
Records shall be kept for all periods when the scrubber is not in use during line #4 operation.
Records shall be maintained in accordance with Provision I.S.l of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Emissions from the Kiln #4 Scrubber Tunnel shall not exceed:
Total PM2.5* .....3.97 lb/hr (l-hr average).
PMrg ......3.97 lblfu (l -hr average).
NO* ..... 10.52 lbltu (l-hr average).
SO2 .......5.87 lb/lr (l-hr average).
Total Fluorides ......3.25 lb/hr (l-hr average).
*including front half and back half condensables.
[Authority granted under R307a0l-8(l)(a)[BACT]; condition originated in DAQE-AN104230017-161.
Monitoring:
Stack testing shall be performed as specified below:
(1) Frequency
Kiln fi4 Scrubber Tunnel emissions shall be tested as follows:
PMls and PM 2.5......every tbree calendar years.
NO*...................... every three calendar years*.
SO2...................... every calendar year.
Total Fluorides........ every five years based on the date of the last stack test.
Additional tests may also be required at the direction of the Director.
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TProject OPP0f04230003 Pzge26 68 of 95 TitB r0erAc65 lzafl i9p4040001
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* If production exceeds 294,927 tons of brick produced per rolling l2-month period then testing
will be conducted each calendar year and within 90 days of exceeding the 294,927 ton limit.
(2) Notification
At least 30 days before the test, the source shall notiff the Director of the date, time, and place of
testing and provide a copy ofthe test protocol. The source shall attend a pretest conference if
determined necessary by the Director.
(3) Methods
(a) Sample Location
The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method l, and Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Administration (MS[IA) approved access shall be provided to the test
location.
(b) Emissions tests:
(1) PMro and PM 2.5:
(i) 40 CFR 51, Appendix M, Method 20la and Method 202, or
(ii) 40 CFR 60, Appendix A, Method 5 and 40 CFR 51, Appendix M,
Method 202.
(2) NO.: 40 CFR 60, Appendix A, Method 7E.
(3) SOz: 40 CFR 60, Appendix A, Method 6C.
(4) Total Fluorides: 40 CFR 60, Appendix A, Method l38.
(c) a0 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.
(d) Or other EPA approved testing methods acceptable to the Director.
(4) Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director to give the results in the specified rrnits of the
emission limitation.
(5) Production Rate During Testing
For a source/emission point, the production rate during compliance testing shall be no less than
90% of the maximum allowable production rate (26.97 tons of product per hour). If the maximum
allowable production rate cannot be achieved at the time of the test, the following procedure shall
be followed:
(a) Testing shall be at no less than 90% ofthe anticipated annual production rate.
(b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be 110% of the rate achieved during the latest test.
Project OPP0104230003 Ptge27 69 of 95 ritB r0elrc05 &axilFErilo00ol
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(c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to ll0Yo of the highest tested rate that demonstrates compliance with
the limits limited in this condition.
Recordkeeping:
Records shall be maintained in accordance with Provision I.S.l of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Emissions from the LnetA Baghouse shall not exceed:
Total PM2.5* ... 0.34 lb/hr and 0.016 grains/dscf (l-hr average).
PMro ...............0.34|blhr (dry filterable particulate only), and 0.016 grains/dscf (l-hr average).
*(dry filterable particulate only), including front half and back half condensables
[Authority granted under R307a01-8(IXa)[BACT]; condition originated in DAQE-AN104230017-16).
Monitoring:
Stack testing shall be performed as specified below:
(1) Frequency: every three calendar years.
Additional tests may also be required at the direction of the Dtector.
(2) Notification
At least 30 days before the test, the source shall noti$ the Director of the date, time, and place of
testing and provide a copy ofthe test protocol. The source shall attend a pretest conference if
determined necessary by the Director.
(3) Methods
(a) Sample Location
The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method 1, and Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Adminisfration (MSHA) approved access shall be provided to the test
location.
(b) Emissions tests for PMls and PM 2.5:
(l) 40 CFR 51, Appendix M, Method 20la (Method202, dry impinger not
required), or
(2) 40 CFR 60, AppendixA, Method 5 (40 CFR 51, Appendix M,
Method 202, dry impinger not required).
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(c) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.
(d) Or other EPA approved testing methods acceptable to the Director.
(4) Calculations
To determine mass emission rates (lb/tr, etc.) the pollutant concentration as deterrnined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necesszlry
conversion factors determined by the Director to give the results in the specified units of the
emission limitation.
(5) Production Rate During TestingI ;st:;*i,H'#triHff##:i:::ilx:t ::;tH;1;"#1Til::f.#'**ii,tl"#ffi-
I ;l?L?:f.ra:oduction
rate cannot be achieved at the time of the test, the following procedure shall
(a) Testing shall be at no less than90o/o of the anticipated annual production rate.I f,i#li..;::i:HJ;T[ffi,Tf]ffi'#;r,i:',I.]"':;i:1"*tili;l11tffil#,
I $l,Lr*?:T,[:*i?iJr:'"f,il:Tff*]:TL".:i.','#Hl"T.',"J::lll,ii,"*["*-,
I r.8.3.c.2 .."",.::;:r:
rimited in this condition
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Records shall be maintained in accordance with Provision I.S.l of this permit.
II.8.3.c.3 Reporting:
I There are no reporting requirements for this provision except those specified in Section I of this
permit.
I II.B.3.d Condition:I
Line #4 tunnel kiln production shall not exceed 26.97 tons ofproduct per hour averaged over a rolling 24-
f hour period. [Authority granted under R307a01-8(1)(a)[BACT]; condition originated in DAQE-I ANro423oor7-161.
r II.B.3.d.l Monitoring:I Production calculations shall be based on tons ofproduct per hour averaged over a rolling 24-
I [:Hffil1;#3rrf;ff averase shall be calculated after each hour oroperation using data
II.B.3.d.2 Recordkeeping:
I Production/consumption records shall be kept on a daily basis and kept for all periods when the
plant is in operation. Records shall be maintained in accordance with provision I.S.l of his
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Permit'
I ProjectoPP0104230003 Prse29 71 of 95 ritB r0eu60E EaxfiFiB.t04000 I
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Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Clay Prep for Line # 4 shall not exceed 6,240 hours of operation per rolling l2-month period (does not
Include Kiln # 4 operating hours) [Authority granted under R307401-8(l)(a)[BACT]; condition
originated in DAQE-AN 104230017 -l 61.
Monitoring:
Hours of operation shall be calculated based on a rolling l2-month period, a new l2-month total
shall be calculated by the twentieth day of each month using data from the previous 12 months.
Recordkeeping:
Records shall be kept on a daily basis and kept for all periods when the plant is in operation.
Records shall be maintained in accordance with provision I.S.1 of his pennit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Natural gas shall be used for fuel in Kiln #4 with propane as a backup. [Authority granted under R307-
a0 I -8( I )(a)[BACT] ; condition originated in DAQE-AN I 042300 I 7- I 61.
Monitoring:
Records required for this permit condition will serve as monitoring.
Recordkeeping:
To demonstrate compliance, fuel records shall be kept for all periods when the facility is in
operation indicating purchase ofnatural gas or propane.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
The minimum pressure drop for the Line #4 scrubber shall be 2.0 inches/w.g.
The above limit does not apply during start-up and shut-down of the scrubber.
Pressure gauges shall be located such that an inspector/operator can safely read the indicator at any time.
[Authority granted under R307a0l-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-161.
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I rl.B.3.g.l Monitoring:
I ffiirfff.p shall be measured once per operating day to demonstrate compliance with the
Pressure gauges must be certified by the manufacturer to be accurate within plus or minus five
f percent of the w.g. design. Pressure gauges must be calibrated on an annual basis in accordance
I with the manufacturer's instructions.
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II'B'3'g'2
;:::;nitoring resurts shall be recorded on a daily basis.
t Records shall be kept onsite for pressure gauges and shall include: manufacturer certifications,
I calibrations, and operating instructions.
t [.B.3.g.3 #:ll
be maintained in accordance with Provision I'S'l of this permit'
I Sr:f;r:"
no reporting requirements for this provision except those specified in Section I of this
I
II.B.3.h Condition:
Line lA scrubber fluid shall be maintained between 5-9 pH.
I When the scrubber is in operation, the pH shall be within the range specified above, except duringr start-up and shutdown of the scrubber. [Authority granted under R307a01-8(l)(a)[BACT]; condition
originated in DAQE-AN104230017 -16).
I II.B.3.h.l Monitoring:
f A monitoring device for the continuous measurement of scrubbing solution pH shall be installe{
I ca[brated, maintained, and operated.
I H:[?::f,111ffffi#1!;:"fff1:',"iffiffin'H#Ji;::H:m]lJ]'#T:*I manufacturer's instructions.
I The pH monitoring device shall be located such that an inspector/operator can safely read the
I indicator at any time.
r II.B.3.h.2 Recordkeeping:I The pH shall be recorded once per operating day. Continuous recording is not required.
I rI.B.3.h.3 Reporting:I
There are no reporting requirements for this provision except those specified in Section I of this
I Permit'
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Condition:
The minimum flow rate of Line #4 scrubber fluid shall be 600 gallons per minute.
When the scrubber is in operation, the minimum flow rate shall be as specified above, except during
start-up and shutdown of the scrubber. [Authority granted under R307a0l-8(1)(a)[BACT]; condition
originated in DAQE-AN1 042300 I 7-1 61.
Monitoring:
A monitoring device for the continuous measurement of flow rate shall be installe{ calibrated,
maintained, and operated.
The monitoring device shall be certified by the manufacturer to be accurate within plus or minus
five percent of the desip flow rate and must be calibrated on an annual basis in accordance with
the manufacturer's instructions.
The flow rate monitoring device shall be located such that an inspector/operator can safely read
the indicator at any time.
Recordkeeping:
The scrubber flow rate shall be recorded once per operating day. Continuous recording is not
required.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Primarv and Secondary Crushers
Condition:
All exhaust air from the Primary Crusher Building shall be routed through the Primary Crusher Baghouse
before being vented to the atmosphere. [Authority granted under R307401-8(1Xa)[BACT]; condition
originated in DAQE-ANI042300 I 7-1 61.
Monitoring:
Records required for this permit condition will serve as monitoring.
Recordkeeping:
Records shall be kept for all periods when the Primary Crusher Baghouse is not in use dtring
crusher operation. Records shall be maintained in accordance with Provision LS.1 of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
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Emissions from the Primary Crusher Baghouse Vent shall not exceed:
Total PM2.5 0.56 lb/hr and 0.010 grains/dscf (1-hr average).
PMr0........................0.56 lb/hr (dry filterable particulate only), and 0.010 grains/dscf (l-hr average).
*(dry filterable particulate only), including front half and back half condensables.
[Authority granted under R307a0l-8(1)(a)[BACT]; condition originated in DAQE-AN104230017-161.
II.B.4.b.l Monitoring:
Stack testing shall be performed as specified below:
(1) Frequency: every three calendar years.
Additional tests may also be required at the direction of the Director.
(2) Notification
At least 30 days before the test, the source shall notiff the Director of the date, time, and place of
testing and provide a copy ofthe test protocol. The source shall attend a pretest conference if
determined necessary by the Director.
(3) Methods
(a) Sample Location
The emission point shall conform to the requirements of 40 CFR 60, Appendix A,
Method l, and Occupational Safety and Health Administration (OS[IA) or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test
location.
(b) Emissions tests for PMls and PM 2.5:
(l) 40 CFR 51, Appendix M, Method 201a (Method20z, dry impinger not
required), or
(2) 40 CFR 60, Appendix A, Method 5 (40 CFR 51, Appendix M,
Method 202, dry impinger not required).
(c) a0 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow
rate.
(d) Or other EPA approved testing methods acceptable to the Director.
(4) Calculations
To determine mass emission rates (lb/lr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director to give the results in the specified units of the
emission limitation.
Page 33 75 of 95 TitE F0elffi6E 8DtflFf;ril40001
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(5) Production Rate During Testing
For a source/emission point, the production rate during compliance testing shall be no less than
90% of the maximum allowable production rate (crusher rating 100 tons/hr). If the maximum
allowable production rate cannot be achieved at the time of the test, the following procedure shall
be followed:
(a) Testing shall be at no less than90Yo of the anticipated annual production rate.
(b) If the test demonstrates compliance with the limits listed above, the maximum
allowable production rate shall be lLD% of the rate achieved during the latest test.
(c) If a higher production rate is necessary, upon notification to the Director, ISB may
increase production to ll0o/o of the highest tested rate that demonstrates compliance with
the limits limited in this condition.
Recordkeeping:
Records shall be maintained in accordance with Provision I.S.l of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
The minimum pressure drop for the Primary Crusher Baghouse shall be:
(A) 2.0 in inches/w.g. when using polyester felt; or
(B) 0.4 in inches/w.g. when using PTFE membrane
The above limits do not apply during a period of ten crusher operating days following filter media
replacement.
Pressure gauges shall be located such that an inspector/operator can safely read them at any time.
[Authority granted under R307401-8(l)(a)[BACT]; condition originated in DAQE-AN104230017-161.
Monitoring:
Pressure drop shall be measured once per operating day to demonstrate compliance with the
above limitation.
Pressure gauges must be certified by the manufacturer to be accurate within plus or minus five
percent of the w.g. design. Pressure gauges must be calibrated on an annual basis in accordance
with the manufacturer's instructions.
Recordkeeping:
Pressure drop monitoring results shall be recorded on a daily basis.
Records shall be kept onsite for pressure gauges and shall include: manufacturer certifications,
calibrations, and operating instructions.
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Records shall be maintained in accordance with Provision I.S.1 of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Gasoline Storaee Tank- 40 CFR 63 Subpart CCCCCC
Condition:
For each gasoline storage tank with a throughput less than 10,000 gallons per month the permiuee shall
allow gasoline to be handled in a manner that would not result in vapor releases to the atmosphere for
extended periods of time. Measures to be taken include, but are not limited to, the following:
(l) Minimize gasoline spills;
(2) Clean up spills as expeditiously as practicable;
(3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal
when not in use;
(4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oiVwater ssparators.
The permittee shall also, at all times, operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance procedures are being used will be based on information available to the Administrator which
may include, but is not limited to, monitoring results, review of operation and maintenance procedures,
review of operation and maintenance records, and inspection of the source. [Authority granted under: 40
CFR63 SubpartCCCCCC40I;conditionoriginatedin40CFR63.lll16and63.1lll5l.
Monitoring:
The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.1I130]
Records required for this permit condition will serve as monitoring.
Recordkeeping:
The permittee shall, upon request of the Director, demonstrate their monthly throughput is less
than 10,000 gallons within 24 hours of the request.
Records shall be maintained in accordance with Provision I.S.1 of this permit.
A log shall be maintained to document records in accordance with 40 CFR 63.11125. [40 CFR
63.11 111(e) and 63.11I l60)l
The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.1I130].
t ProjectoPP0104230003 Page35 77 of 95 ritB r0el,668 mari{EtrfmDoool
II.B.5.a.3
II.B.6
II.B.6.a
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Degreasers
Condition:
The permittee shall ensure that the following conditions are met:
(1) Each solvent degreaser is equipped with a cover which shall remain closed except during actual
loading, unloading or handling of parts in cleaner. The cover shall be designed so that it can be easily
operated with one hand if:
(a) the volatility of the solvent is greater than 2 kPa (15 mm Hg or 0.3 psi) measured at 38
degrees C (100 degrees F),
(b) the solvent is agitated, or
(c) the solvent is heated.
(2) An internal draining rack for cleaned parts shall be installed on which parts shall be drained until all
dripping ceases. If the volatility of the solvent is greater than 4.3 kPa (32 mm Hg at 3 8
degrees C (100 degrees F)), the drainage facility must be internal, so that parts are enclosed under the
cover while draining. The drainage facility may be extemal for applications where an intemal type cannot
fit into the cleaning system.
(3) Waste or used solvent shall be stored in covered containers.
(4) Tanls, containers and all associated equipment shall be maintained in good operating condition and
leaks shall be repaired immediately or the degreaser shall be shutdown.
(5) Written procedures for the operation and maintenance of the degreasing or solvent cleaning equipment
shall be permanently posted in an accessible and conspicuous location near the equipment.
(6) If the solvent volatility is greater than 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38 degrees C (100
degrees F), or ifsolvent is heated above 50 degrees C (120 degrees F), then one ofthe
following control devices shall be used:
(a) freeboard that gives a freeboard ratio greater than 0.7;
(b) water cover if the solvent is insoluble in and heavier than water;
(c) other systems ofequivalent control, such as a refrigerated chiller or carbon absorption.
(7) Ifused, the solvent spray shall be a solid fluid stream at a pressure which does not cause
excessive splashing and may not be a fine, atomized or shower type spray.
[Authority granted under R307-3354; condition originated in R307-3354].
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tProject OPP0104230003 Page 36 78 of 95 ritE roetffi CI! fi mi{Fpff 4se61
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I II.B.6.a.l Monitoring:r
A visual observation shall be conducted each calendar month for all equipment and applicable
I work practices.
II.B.6.a.2 Recordkeeping:
I mHH"JTJ.Hffi:fililS*il",'tiTr",ffi:ff:'(s)beingusedsharlberecorded
I rI.B.6.a.3 Reporting:I
There are no reporting requirements for this provision except those specified in Section I of this
t Perrnit'
tr.C Emissions Trading
t
(R30741s6a(10))
Not applicable to this source.
I II.D Alternative Operating Scenarios.t (Bo7al5-6a(e))
I
Not applicable to this source.
tr.E Source-specific Definitions.
t There are no source specific definitions for this permit.
I
t A permit shield was not granted for any specific requirements.
I SECTION IV: ACID RAIN PROVISIONS
Ptge37 79 of 95 TitIl6p9lO*?tAIfiFP{m40001
fV.A Thls source is not subiect to Tltle fV. This section ls not aoolicable.I
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I ProjectoPP0104230003
REVIEWER COMMENTS
This operating permit incorporates all applicable requirements contained in the following documents:
lncorporates DAQE-ANI04230017-16 dated October 24, 2016
I . Comment on the current approval order (DAQE-ANI04230017-16): does not allow the operation
of Kiln #1. As stated in DAQE-AN104230017-16 , UISB shall not operate Kiln #l until the
replacement scrubber for Kiln #l has been approved in accordance with R307-401-8." [Last
updated March 22,2018)
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IProject OPP0104230003 Page 38 80 of 95 ritB r00tA365 rtarflFpfi 40001
Appendix *S"
Field Work Safety Plan
MM?NT+R[H
SITE SAFETY PLAN BOOKLET
Projecti pRoJ-os2T2T
Gustomer: Basalite / lnterstate Brick
Location: West Jordan. Utah
Units: Line 4 Kiln Wet Scrubber. Line 4
Glient Project Manager: Chevnev Guvmon/Austin Tramr
Revision Date: June 29th,2023
82 of 95 GP08 1AS-0 5 27 27 -PP -980
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Page 1 of2
Site Safety Plan and JHA Purpose and lnstructions
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. Allemployees
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.
!nstructions
The SSP consists of the following:
1. A Pre-Mobilization Test Plan - To be completed in it's entirety by the client project Manager
prior to the test.
2. A Job Hazard Analysis is a standardized, two.page, fillable form that is used to evaluated the
tasUsite's particular hazards and controls. The form also includes a daily toolbox topic and
daily hazard review with sign off by the team. The client Project Manager is responsible to
complete the JHA form through section L Upon arrival at the test site, the team will review the
form for accuracy, making any corrections required and complete the remainder of the JHA.
Section 9 will require at least three tasks, hazards and controls be identified for the project.
Each team member has the option to discuss making changes or adding to the JHA and must
sign on the Job Hazard Analysis form in agreement and sign in Section 10. The JHA is to be
modified when conditions change. A toolbox meeting with a daily topic in addition to a review of
the hazard analysis is required daily for the duration of the test. An additional sheet of paper
with the toolbox topic and signatures can be added to the SSP packet.
3. Hazard Control Matrix - contains useful information on both engineering and
administrative controls that a crew can use to reduce or eliminate the hazards they have
observed plus applicable PPE that may be required.
4. Emergency Action Plan - The Job Supervisor/ Client Project Manager (CPM) will complete
the Emergency Action Plan form and ensure that all employees are familiar with the facility
emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior
to work commencing. ln 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, signed, and posted.
5. Additional Forms, as applicable
a. MEWP Lift lnspection Form
b. Heat Stress Prevention Form Based on Heat lndex
c. Extended Hours Form
83 of 95
AQS-FRM-1.13R1
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Page 2 of 2
Site Safety Plan and JHA Purpose and lnstructions
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
GP08 1AS-0 5 27 27 -PP -980
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a
NOx
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other
lf other, explain:
Flammable:
PRoJECT NAME/LOCATION: lnterstate Brick - west Jordan, UT pROJECT #: PROJ-052727
TEST DATE. Weekof June 161h,2025 PROJ ECT MANAGER: choyney Guymon/Austin rramell
TEST SCOpE. PM/CPM on all 3 sources; SO2, NOx, and Total Fluoride on Line #4 Kiln Wet Scrubber.
slTE CoNTACT: Name: Brittany Bamey contact Phone: [phone]
Page 1 of 2
PRE.MOBILIZATION TEST I N FORMATION
Source TVpe: New SOurCe: _ Revisit: X Pq#lDateffe66' PRoJ-04121l/Ju|v23,2O24lChevnevGuvmon
Coal Fired Electric Utility: _ EthanolPlant: _ Chemical Mfg. of
CemenVLime Kiln Plant
-
Specialty Mfg. of: Bricks
Antlclpated Effluent Composition - check allthat apply and fill in expected concentration in ppm/%
z
SOz
tr
voc
Toxic: Corroslve: Duat:
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co
Engineering Controls to be lmplemented:
Addltlonal Safety Equ lpment Required:
Personal gas monitors: _
Respiratory Protection:
Half Face_ Full Face_ HEPA Filters_ Supplied Air:
Approximate Flue Gas Temperatures, (F)
below 210 210 to 450 450 to 950 above 950
lf other, explain:
Approxlmate Duct Pressure, (lwg):
tr
below
(Safety Dept. Approval)
z
-3 to +3
u
+3 to +7
u
other
z
above
AQS-FRM-1.17
GP08 1AS-0 5 27 27 -PP-980
lf other, explain:
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PRE.MOBILIZATION TEST INFORMATION
Sampling Locatlon: Stack Port x
Approximate Sampling Platform Height, (ft)
Duct Port _
tr
below 6
lf other, explain:
trtrtr
6 to 50 50 to 100 above 100
tr
other
Access and Protection:
Elevators: _ Ladders: _ MEWP Lift: _ Scaffold: _ Equipment Hoist: _
Guardrails: X Toe plate: _ Engineered Tie Off Points: _ Heat Shield: _
Other:
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Describe how equipment will be mobilized to the sampling location:
Hoisted or hand canied
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Additional Information:t
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Prepared by:
Reviewed by:
[6fs; March 4,2025
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AQS-FRM-1.17
G P08 1AS- 0 527 27 -PP -980
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Effluent Ghemical Resu latorv Limits
Gas Name Ghemlcal
Formula
Cal OSHA PELi
(ppm)
Cal OSHA
STEL2(ooml
NIOSH REL
TWA3 (ppm)
Gal OSHA
Celllng
(ooml
IDLH.
(ppm)
Sarbon Monoxide co 25 200 35 200 1,200
Nitric Oxide NO,25 ND5 25 ND 100
Sulfur Dioxide SOz 2 5 2 ND 100
Hvdroqen Chloride HCt 0.3 2 ND 2 50
Hydrogen Sulfide HzS 10 15 10 (10 min.)c 50 100
1alifomia Occupational Safety and Health Administntion (OSHA) Parmissible Exposure Limrt @EL) based on an 8-hour shift:
2: Cal OSHA Short-term Exposure Linit (STEL) bas@d on a 15-minute pariod;
3: National lnstitute for Occupational Safety and Heafth (NIOSH) Recommended Exposure Limit (REL) Time-weighted Avenge (TWA) based
on an 1-hour shift;
4: lmmediately Dangerous to Life or Heafth (IDLH);
5: Not Defined (ND);
C: Ceiling Limit - Maximum allowable human exposure ilmrt for an aitbome or gaseous substance, which is not to be exceeded, even
momantaily.
Joby Dunmire
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\ A,1\)N ll(()\t Job Hazard Analysis
Error RIck
EI time Pressure E Remote Work Location EI > 12 hr shift E wo*ing > 8 consecutive days
E Ucf of procedures E] Exreme temps, wind >30mph E Personal illnes#fatigue E Vague work guidance
E Monotonous Ac,tivity E rirst day back after time off E Uuttlpte joO locations I Other:
PPE E Hard Hats ! Safety Glasses I Safety Toe Shoe/Boot ! Hearing Protection Esafety Spotter
E Hi-Vis Vests E Hamess/Lanyard* E Goggles E Personal Monitor Type:
E Mehtarsal Guards E Hot Gloves E Face Shield E RespiratorT),pe:
E Nomex/FRC E Other PPE:
1of3/av
1.k0lient lntoBtat€ Brlck Comgeny Sontact Name Bdttany Bamy )ate W@k of Jun6 '16, 2025
FaciliV West Jordan, UtBh Facillty SSP Writer Joby DunmlB PM
Client Rep I
Job Preparation
[ .too Site Walk Through Completed tr
E Sate Work Permit Received from Client
-l
Site Specific Training Complete
lf the heat lndex ls expected to be above 91', flll out the Heat Stress Preventlon Form.
Faclllty lnformation/Emergency Preparedness
rntion is neededlf non-emergency medical aftention is nooded, call: AXIOM #: 877-502-9466.
Plant Emergency# _ Certified FirstAid Person:
EMS Location Evacuation Routes Rally Point
Severe Weather Shelter Location Eye Wash & Safety Shower Location
Operational: EYes ENo
Source lnformatlon: (llst type):
Stack Gas Temp. (oF) Stack Gas Press. ("H2O) Stack Gas Components:
StackGaslnhalationPotential? EYes EIruo lfvss.sesListofHazardChemicats.
Physical Hazards
Dust Hazards
Thermal Bum
Electrical Hazards
lnadequate Lighting
Slip and Trip
Hand Protection
E Hot cloves E Heat Shields E Other Protective Clothing:
E Connections Protected from Elements ! Extemal GFCI E Other:
E XP Rating Requirement I lntrinsically Safe Requirement
E lnstrall Temporary Lighting El Headlamps
! Housekeeping E Banicade Area E Other:
El Cut Resistant Gloves Ef Pinch fts. El General E gearicat ! lmpact Resistant
E other:
Secondary Permits i E Hot Wo* E Confined Space ! Excavation
Worklng from Heights i E r"tting objects E Fall protection El orop zone protectlon f] ehtform load ratings
sec atro Sect 7 i E scarolu inspection EJ Ladder inspection E Banicades for equipment
Electrical i E ExposeO wire/connector [1 Verity equipment grounding ! Arc Flash
Lifting i E Crane lift plan fl Rigging inspeclion EI tag lines used E Hoists in place
Respiratory : E Unexpected exposure E Chemical E Dust (combustible) fl PEL provided
See atso sect. 8 i E C"rtrlOg"s or supplied air available E Gas detection
AQS-FRM.1.18
G P08 1AS-0 5 27 27 -PP -980
Or\ M()N I R()st
Addifional Work Place Hazards
Job Hazard Analysis t
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7.
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8.
Procedures - check all that apply - *indicates additional form must be completed or collected from client
El Heat Stress Prevention" E Confined Space* E MEWP* E Roof Work E Scattotd
E CotO Weather Work ft Hazardous Energy Control. E Exposure Monitoring E Other:
From Helghts
Fall Protection
Falling Objects Protection
F all Hazard Communication
E Fixed Guardrails/Toe boards E fatt Prevention PPE Waming Line System
E Banicading E Netting fl House Keeping flTethered Tools E Catctr Blanket orTarp
E AdjacenUOverhead Workers E Contractor Contact E] Client Contact
Other Considerations
Environmental Hazards - Weather Forecast
E HeaVCold Eugntning ! Rain E Snow E lce El Tomado E Wind Speed
Steps for Mitigation:
actrical Safety Planning
PlantHookup: EttOV rf22OI24OV E aAOv E Generator EHardwiredintopanel
Electrical Classified Area: EYes ! No Trailer Grounded: E Yes E Uo Plug Type
El€ctrical Hook U p Responsibility:
List of Hazardous Chemicals
E] Acetone E ruitric ecio
Other Chemicals:
I Hydrogen Peroxide E Compressed Gases
EI Hexane fl Suffuric Acid E lsopropyl Alcohol I Flammable Gas
E Toluene E Hydrochloric Acid E UquiA Nitrogen I Non-Flammable Gas
E rzs E Carbon Monoxide
Steps for Mitigation:
lildlife/Fauna in Area
! Poison lvy !Poison Oak Elnsects:!Wildlife:
Personnel w/ known allergies to bees stings or other allergens? [ Yes Eruo
9.Hazards and
Task
a 1
2
3
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AQS-FRM-1.18
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JHA REVIEW: Crew Names & Signatures
Prlnted Name Slqnature Date Prlnted Name Slqnature Date
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AQS-FRM-1.18
G P08 1AS-0 5 27 27 -PP -980
JHA Meetinq & Review
to revlew:
. Change in conditions o Extended work hours o Daily Safety Topic
o New workers or contractors o Occunence of near misses or injuries
demonstmtos that site conditlons and hazards have not changed from the orlglnal SSP. lf changes did occur, make the
updates to thls JHA and add notes as applicable in Sectlon 9.
Day Dlscusslon Toplc lnltlals
2
3
4
5
6
7
8
9
l0
1'.|
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Page 1 of 2
EMERGENCY ACTION PLAN FORM
The Job Supervlsor/ Cllent ProJect Manager (CPM) wlll ensure that all employees are famlllar wlth the faclllty emergency and evacuatlon
procedures, assembly/ rally points, alert systems, and signals prior to work commencing. ln tho evont of an emorgoncy sltuatlon/
evacuatlon, the Job Supervlsor/ CPM wlll malntaln a roster and be responslble for accountlng for all employees. The Job Supervlsor/
CPM wil! ensure that thia Emergency Action Plan Form is completed, communicated to all employees, and posted.
.Uou must follow the cllent's emergency actlon plan first, and notlfy your Supervlsor immedlately..lf incident is lifo throatening, CALL 911 IMMEDIATELLY
.E non+mergency medlcal attentlon ls needed, call AXIOM Medlcal number: 877-502-9466.
AQS-FRM-1.11
90 of 95 G P08 1AS-0 5 27 27 -PP -980
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1 MEG Job Supervisor/ CPM's Name:
2 MEG Job Supervisor/ CPM's Telephone Number:
3 itlEG Job Safety Supervisor (if applicable):
4 MEG Job Safety Supervisor's Telephone Number:
5 Plant's Emergency Telephone Number:
6 Local Hospital/ Clinic Telephone Number:
7 Emergency Ops Radio Channel:
8 Plant's #1 Contact Person's Name:
I Plant's #1 Gontact Person's Telephone Number:
10 Plant's #2 Contact Person's Name:
11 Plant's #2 Contact Person's Telephone Number:
12 Designated Assembly Point Location:
13 Evacuation Routes:
14 Severe Weather Shelter Location:
15 Eye Wash and Safety Shower Location:
16 Ihe Flrst Aid Klt ls Located:
17 Ihe Fire Extinguisher is Located:
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EMERGENCY EVACUATION AND ASSEMBLY MAP
1 Facility Name:
2 Facility Aarm (Circle):YES or NO
3
Alarm Tones:
cHEMtUu
SHELTER-IN.PLACE:
EVACUA
tatltED.
4 Designated Shelter(s) Description:
5 Designated Assembly Point(s! Description:
N*+'
s
Draw the .v.cuatlon and assembly map here
EMERGENCY ACTION PIAN FORM AND EVACUATION ASSEMBLY MAP REVIEW: Crew Names and Signatures
Printed Nome:Sianature:Dote:Printed Nome:SiEnoture:Date:
AQS.FRM-1.11
91 of 95 GP08 1AS-0 5 27 27 -PP -980
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Page 1 of 1
Daily MEWP Lift lnspection Form
All checks must be completed prior to each work shift, before operation of the MEWP lift. This checklist must be used
atthe beginning of each shift or following 6 to I hours of use.
MEWP Lift Model#:Serial Number:
Make:Rented or Owned:
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Yes No N/A
n!n
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. Check "Yes" if an item is adequate, operational, and safe.. Check "No'to indicate that a repair or other corrective action is required prior to use.. Check "N/A'to indicate "Not Applicable.'
Items to be lnspected
1. All MEWP lift components are in working condition (i.e. no loose or missing parts, torn orloose hoses, etc.) - if something can be easily loosened by hand then it is not sufficient.
2. Hydraulic fluid level is sufficient, with the platform fully lowered
3. Hydraulic system pressure (see manufacturer specs) is acceptable.
lf 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. wom 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. Waming and instructional labels are legible and secure, and load capacity is clearly marked.
10. Manufacture/s lnstruction 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 wlnds are 20 mph, unless otherwise speclfled by manufacturer
recommendatlons.
n
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tr
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!
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!n
!n
trtr
trtr
trtr
trtr
trtr
trtr
!tr
!n
trtr
Operator Name & Signature Location Date tGround Control Name & Signature Location Date
Harness lnspectlons:I
Printed Name Signature Date t
Printed Name Signature Date
IPrinted Name Signature
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M MONTROSE
Page 1 of 1
Extended Hours Safety Audit
Project Number:
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 meetinq Test crew initials:
o Temperature and weather o Hoistingo Lighting . PPE (i.e. respirators, etc.). Working from Heights . Pollutant concentration in ambient air (SOz,
HzS, ect.)
Notifv DM or RVP
The PM must contact either the DM or RVP to discuss the safety issues that may arise due to the
extended work period. lf the DM is the acting PM on the job site, they must contact the RVP.
During this time, they can come to an agreement on how to proceed. ltemsto discuss include:
a
a
I
a
Reason for extended hours
Reason for delay
Production limitations
lmpending Weather
Gontact the client
The PM, DM or RVP must discuss with client any identified safety concems, 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
finaldecision.
FlnalOutcome:
Approver:
2.
OOlAS-SAFETY-FM.3
G P08 1AS-0 5 27 27 -PP -980
The test leader should look for signs of the following in their crews:
o lnitability. Lack of motivationo Headaches. Giddiness
. Fatigue. Depression
o Reduced alertness, lack of concentration and
memory
The test leader should assess the environmental and hazardous concems:
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oA yoN I Rosr
Page 1 of 1
Heat Stress Prevention Form
This form is to be used when the Expected Heat lndex is above 91' F, and is to be kept with project
documentation.
Prolect Manaser (PM):Expected Hlqh Temp:
Date(s):Exoected Heat lndex:
Review the signs of Heat Exhaustion and Heat Stroke
lf Heat lndex is above 91' F:. Provide cold water and/or sports drinks to allfield staff (avoid caffeinated drinks and energy
drinks which can increase core temperature).
o Bring no less than one gallon of water per employee. lf employee(s) are dehydrated, on blood pressure medication or not acclimated to heat,
ensure they are aware of the heightened risk for heat illnesso Provide cool head bands/vests/etc.. Have ice available to employees. lmplement work shifr rotations and breaks, particularly for employees working in direct
sunlight.r Provide as much shade at the jobsite as possible, including tarps, tents or other acceptable
temporary structures.. PM should interview each field staff periodically to evaluate for signs of heat illness
lf Heat lndex is above 103' F:o Employees must stop for drinks and breaks every hour (about 4 cups/hour). Employees are not permitted to work alone for more than one hour at a time without a
break offering shade and drinks. Employees should wear cool bands and vests if working outside more than one hour at a
time. PM should interview each field staff every 2 hours to evaluate for signs of heat illness
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Nausa o.wmling ffi Nauea orvomitlng
R.pid,reakpul*
-
--
R.pld,rtronSpuEc
Mu$tecramps II rvreybe(i
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 PIains - Operations
Emai! : [e-mail]
Phone: [phone]
Name: Cheyney Guymon
Title: Client Project Manager
Region: Great PIains Region, Utah Office
Email : [e-mail]
Phone: 80 L-362-4978
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ENVTRONMENTAL OUALITY
DIVISION OF AIR OUALITY
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