DAQ-2025-000191

DAQE-AN130290007-25

{{$d1 }}

Ladislao Garcia
Broken Arrow Inc.
8960 North Clinton Landing
Lake Point, UT 84074
[e-mail]

Dear Mr. Garcia:

Re: Approval Order: Modification to Approval Order DAQE-AN130290006-23 to Add Emergency
Generator Engines
Project Number: N130290007

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on July 9,
2024. Broken Arrow Inc. must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Mr. Enqiang He, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received on
this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:EH:jg

cc: Tooele County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

January 8, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN130290007-25
Modification to Approval Order DAQE-AN130290006-23
to Add Emergency Generator Engines

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Broken Arrow Inc. - Broken Arrow Flux Operations

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

January 8, 2025
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12

DAQE-AN130290007-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Broken Arrow Inc. Broken Arrow Inc. - Broken Arrow Flux Operations

Mailing Address Physical Address
8960 North Clinton Landing 2600 North Ellerbeck Road
Lake Point, UT 84074 Grantsville, UT 84029

Source Contact UTM Coordinates
Name: Ladislao Garcia 368,170 m Easting
Phone: [phone],504,450 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 1474 (Potash, Soda, & Borate Minerals)

SOURCE INFORMATION
General Description
Broken Arrow Inc. (Broken Arrow) operates a salt processing plant located near Grantsville in Tooele
County. The process dries, screens, and loads salt harvested from the Great Salt Lake for shipment to
customers. The plant produces up to 500,000 tons of salt annually. The company also dries liquid
magnesium chloride concentrate. The magnesium chloride concentrate is brought to the plant by the
tanker trucks and dried by a new natural gas-fired burner. The plant processes up to 21 million gallons of
magnesium chloride concentrate a year.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA
Tooele County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
DAQE-AN130290007-25
Page 4

MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Description
Broken Arrow has requested a modification to AO DAQE-AN130290006-23 to add two (2) new
emergency generator engines. The diesel-fired generator engine is rated up to 1,474 hp (1,100 kW) and
will support the salt drying operations during emergencies. The natural gas/propane-fired generator
engine is rated up to 201 hp (150 kW) and will provide power to the magnesium chloride drying
operations during emergencies. Emissions from each of the emergency generator engines are calculated
based on 100 hours of operations per year and are added to the sitewide totals.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 96 16114.00
Carbon Monoxide 0.43 35.20
Nitrogen Oxides 0.37 11.54
Particulate Matter - PM10 0 38.02
Particulate Matter - PM2.5 0 36.77
Sulfur Dioxide 0 0.08
Volatile Organic Compounds 0.03 4.38

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 20 540
Change (TPY) Total (TPY)
Total HAPs 0.01 0.27

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
DAQE-AN130290007-25
Page 5

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to
the Director which may include but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Broken Arrow Salt Broken Arrow Flux Operations
II.A.2 Three (3) Salt Dryers Design Capacity: Rated at 40, 70, and 75 MMBtu/hr Fuel: Natural gas II.A.3 Baghouse 1 Controls: 40 MMBtu/hr dryer Flow Rate: 13,000 acfm Bag Diameter: 6" Bag Length: 9' Number of Bags: 140 Stack Height: 30' Stack Inside Dimension: 2.5' x 2.5'
DAQE-AN130290007-25
Page 6

II.A.4 Baghouse 2 Controls: 70 MMBtu/hr dryer Flow Rate: 50,000 acfm Bag Diameter: 4.6" Bag Length: 12' Number of Bags: 494 Stack Height: 45' Stack Inside Dimension: 4' x 4' II.A.5 Baghouse 3 Controls: 75 MMBtu/hr dryer
Flow Rate: 80,000 acfm Bag Diameter: 4.5" Bag Length: 10'
Number of Bags: 960 Stack Height: 45'
Stack Inside Diameter: 5'

II.A.6 One (1) Magnesium Chloride Dryer Design Capacity: 10 MMBtu/hr Fuel: Natural gas Burner: Low NOx burner
II.A.7 Five (5) Screens
Design Capacity: One (1) rated at 50 tons/hr; two (2) rated at 150 tons/hr each, two (2) rated at 300 tons/hr each

II.A.8 Seven (7) Storage Buildings Storage Capacities: 500, 500, 2,000, 2,500, 4,500, 15,000, and 20,000 tons
II.A.9 Miscellaneous Equipment
Associated conveyors, electric motors, front-end loaders, and haul trucks
II.A.10 One (1) Diesel Storage Tank Capacity: 10,000 gallons II.A.11 One (1) Emergency Generator Engine - New
Maximum Rated Capacity: 1,474 hp (1,100 kW)
Tier 4 certified Fuel: Diesel
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ
II.A.12 One (1) Emergency Generator Engine - New Maximum Rated Capacity: 201 hp (150 kW) Fuel: Natural gas or propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ

DAQE-AN130290007-25
Page 7

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Plant-Wide Requirements and Limitations
II.B.1.a The owner/operator shall not allow visible emissions to exceed the following limits:

A. The screens - 7% opacity

B. All conveyor transfer points - 7% opacity

C. Conveyor drop points - 15% opacity

D. The sodium chloride dryer baghouse stacks - 10% opacity

E. The magnesium chloride dryer stack - 10% opacity

F. The diesel-fired emergency generator engine - 20% opacity

G. The natural gas/propane-fired emergency generator engine - 10% opacity

H. All other points - 15% opacity.

[R307-309, R307-312-4, R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b The owner/operator shall not exceed the following production and consumption limits:

A. 500,000 tons of sodium chloride salt processed per rolling 12-month period

B. 21 million gallons of magnesium chloride concentrate processed per rolling 12-month
period

C. 272,000 MMBtu of natural gas consumed per rolling 12-month period.

[R307-401-8]

II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months B. Determine production by scale house records or vendor receipts C. Keep the records of production on a daily basis D. Determine natural gas consumption by billing statements from a utility company. The records of billing statements shall be kept on a monthly basis E. Keep the records of production and natural gas consumption for all periods when the plant is in operation. [R307-401-8]
DAQE-AN130290007-25
Page 8

II.B.1.c The owner/operator shall install partial enclosures on all outdoor screening operations that sort material that has been processed by the sodium chloride salt dryers. The enclosures must be installed in a way to maintain the opacity limits set in this AO. [R307-401-8] II.B.2 Sodium Chloride Salt Dryer Requirements
II.B.2.a The owner/operator shall only use natural gas as fuel in the salt dryers. [R307-401-8] II.B.2.b The owner/operator shall install a low NOx burner in the 75 MMBtu/hr salt dryer that is certified to meet a NOx emission concentration of 30 ppm corrected to 3% oxygen. [R307-401-8]

II.B.2.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration for the 75 MMBtu/hr dryer on site. The record shall be kept for the life of the equipment. [R307-401-8] II.B.3 Requirements on the Baghouse
II.B.3.a The owner/operator shall use the baghouses to control process streams from their designated dryers. All exhaust air from the sodium chloride dryers shall be routed through the baghouses before being vented to the atmosphere. [R307-401-8]
II.B.3.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
differential pressure across each baghouse. The static pressure differential across each baghouse shall be between 2.0 to 5.0 inches of water column. [R307-401-8]

II.B.3.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of the reading is required on a daily basis when the dryer, the baghouse controls, operates. [R307-401-8]
II.B.3.c The owner/operator shall install a baghouse that is certified to meet a PM10 emission
concentration of 0.005 grains/dscf to control the 75 MMBtu/hr dryer. [R307-401-8]
II.B.3.c.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration. The record shall be kept for the life of the equipment. [R307-401-8] II.B.4 Magnesium Chloride Salt Dryer Requirements
II.B.4.a The owner/operator shall only use natural gas as fuel in the magnesium chloride salt dryer. [R307-401-8] II.B.4.b The owner/operator shall install a low NOx burner in the magnesium chloride salt dryer that is
certified to meet a NOx emission concentration of 30 ppm and a CO emission concentration of
100 ppm or less. [R307-401-8]
II.B.4.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentrations. The record shall be kept for the life of the equipment. [R307-401-8]
II.B.5 Road and Fugitive Dust
II.B.5.a The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas to exceed 15% opacity on site and 10% opacity at the property boundary. [R307-309-4, R307-309-5]
DAQE-AN130290007-25
Page 9

II.B.5.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-4, R307-401-8] II.B.5.b The owner/operator shall not allow the total length of the haul roads to exceed:
A. 0.90 miles of unpaved haul roads for the tanker trucks transporting magnesium chloride concentrate. The owner/operator shall pave no less than 0.1 miles of haul road
B. 0.81 miles of unpaved haul roads for the haul trucks transporting sodium chloride salt. The owner/operator shall pave no less than 300 feet of haul road.
[R307-401-8]

II.B.5.c The owner/operator shall apply water sprays and/or chemical suppressants to all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain the opacity limit in the AO. If chemical treatment is to be used, the chemical treatment plan must be approved by the Director. [R307-309, R307-401-8]
II.B.5.c.1 Records of water and/or chemical treatment shall be kept for all periods when the plant is in
operation. The records shall include the following items:
A. Date of treatment
B. Number of treatments made, dilution ratio, and quantity

C. Rainfall received, if any, and approximate amount
D. Time of day treatments were made
E. Records of temperature if the temperature was below freezing.

[R307-401-8]
II.B.5.d The owner/operator shall periodically sweep or spray clean the paved haul road to maintain the opacity limit in the AO. [R307-401-8] II.B.5.d.1 Records of cleaning the paved haul roads shall be kept for all periods the plant is in operation.
[R307-401-8]

II.B.5.e The owner/operator shall comply with all applicable requirements of R307-309 for fugitive emission and fugitive dust sources. [R307-309]

DAQE-AN130290007-25
Page 10

II.B.6 Emergency Generator Engine Requirements II.B.6.a The owner/operator shall install and operate the following emergency generator engines:
A. One (1) diesel-fired engine rated up to 1,474 hp (1,100 kW). The engine shall comply with the following Tier 4 standards:
HC = 0.14 g/hp-hr, NOx = 0.5 g/hp-hr, and PM = 0.02 g/hp-hr
B. One (1) natural gas/propane-fired engine rated up to 201 hp (150 kW). The engine shall comply with the following standards:
NOx = 2.0 g/hp-hr, CO = 4.0 g/hp-hr, and VOC = 1.0 g/hp-hr [40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, R307-401-8]

II.B.6.a.1 To demonstrate compliance with the above requirements, the owner/operator shall keep records of the manufacturer's certifications of the emission rates. The records shall be kept for the life of the equipment. [R307-401-8] II.B.6.b The owner/operator shall not operate each emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.6.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 60 Subpart ZZZZ, R307-401-8]
II.B.6.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
II.B.6.c The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 1,474-hp (1,100-kW) emergency generator engine and natural gas or propane in the 201-hp (150-kW) emergency generator engine. [R307-401-8]
II.B.6.c.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.6.c.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]
II.B.6.d The owner/operator shall not test the emergency generator engines at the same time.
[R307-410-4]

DAQE-AN130290007-25
Page 11

II.B.6.d.1 To comply with the above requirement, the owner/operator shall: A. Identify the engine to be tested B. Record the engine testing date C. Record the time the testing began and ended D. Keep the above records for all periods the plant is in operation. [R307-410-4]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN130290006-23 dated July 31, 2023 Incorporates NOI dated July 9, 2024 Incorporates Additional information dated August 2, 2024 Incorporates DAQE-MN130290007-24 dated September 24, 2024

DAQE-AN130290007-25
Page 12

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN130290007-24

November 21, 2024

Ladislao Garcia
Broken Arrow Inc.
8960 North Clinton Landing
Lake Point, UT 84074
[e-mail]

Dear Mr. Garcia:

Re: Intent to Approve: Modification to Approval Order DAQE-AN130290006-23 to Add Emergency
Generator Engines
Project Number: N130290007

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Mr. Enqiang He, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Mr. Enqiang He, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:EH:jg

cc: Tooele County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN130290007-24
Modification to Approval Order DAQE-AN130290006-23
to Add Emergency Generator Engines

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Broken Arrow Inc. - Broken Arrow Flux Operations

Issued On
November 21, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12

DAQE-IN130290007-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Broken Arrow Inc. Broken Arrow Inc. - Broken Arrow Flux Operations

Mailing Address Physical Address
8960 North Clinton Landing 2600 North Ellerbeck Road
Lake Point, UT 84074 Grantsville, UT 84029

Source Contact UTM Coordinates
Name: Ladislao Garcia 368,170 m Easting
Phone: [phone],504,450 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 1474 (Potash, Soda, & Borate Minerals)

SOURCE INFORMATION
General Description
Broken Arrow Inc. (Broken Arrow) operates a salt processing plant located near Grantsville in Tooele
County. The process dries, screens, and loads salt harvested from the Great Salt Lake for shipment to
customers. The plant produces up to 500,000 tons of salt annually. The company also dries liquid
magnesium chloride concentrate. The magnesium chloride concentrate is brought to the plant by the
tanker trucks and dried by a new natural gas-fired burner. The plant processes up to 21 million gallons of
magnesium chloride concentrate a year.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA
Tooele County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
DAQE-IN130290007-24
Page 4

MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Description
Broken Arrow has requested a modification to AO DAQE-AN130290006-23 to add two (2) new
emergency generator engines. The diesel-fired generator engine is rated up to 1,474 hp (1,100 kW) and
will support the salt drying operations during emergencies. The natural gas/propane-fired generator
engine is rated up to 201 hp (150 kW) and will provide power to the magnesium chloride drying
operations during emergencies. Emissions from each of the emergency generator engines are calculated
based on 100 hours of operations per year and are added to the sitewide totals.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 96 16114.00
Carbon Monoxide 0.43 35.20
Nitrogen Oxides 0.37 11.54
Particulate Matter - PM10 0 38.02
Particulate Matter - PM2.5 0 36.77
Sulfur Dioxide 0 0.08
Volatile Organic Compounds 0.03 4.38

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 20 540
Change (TPY) Total (TPY)
Total HAPs 0.01 0.27

PUBLIC NOTICE STATEMENT
The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director.
A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Tooele Transcript on November 27, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the
public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

DAQE-IN130290007-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT

II.A.1 Broken Arrow Salt Broken Arrow Flux Operations
DAQE-IN130290007-24
Page 6

II.A.2 Three (3) Salt Dryers Design Capacity: Rated at 40, 70, and 75 MMBtu/hr Fuel: Natural gas II.A.3 Baghouse 1
Controls: 40 MMBtu/hr dryer Flow Rate: 13,000 acfm Bag Diameter: 6"
Bag Length: 9' Number of Bags: 140 Stack Height: 30'
Stack Inside Dimension: 2.5' x 2.5'
II.A.4 Baghouse 2 Controls: 70 MMBtu/hr dryer Flow Rate: 50,000 acfm Bag Diameter: 4.6" Bag Length: 12' Number of Bags: 494 Stack Height: 45' Stack Inside Dimension: 4' x 4' II.A.5 Baghouse 3
Controls: 75 MMBtu/hr dryer
Flow Rate: 80,000 acfm Bag Diameter: 4.5"
Bag Length: 10'
Number of Bags: 960 Stack Height: 45'
Stack Inside Diameter: 5'

II.A.6 One (1) Magnesium Chloride Dryer Design Capacity: 10 MMBtu/hr Fuel: Natural gas Burner: Low NOx burner
II.A.7 Five (5) Screens
Design Capacity: One (1) rated at 50 tons/hr; two (2) rated at 150 tons/hr each, two (2) rated at 300 tons/hr each

II.A.8 Seven (7) Storage Buildings Storage Capacities: 500, 500, 2,000, 2,500, 4,500, 15,000, and 20,000 tons
II.A.9 Miscellaneous Equipment
Associated conveyors, electric motors, front-end loaders, and haul trucks

II.A.10 One (1) Diesel Storage Tank Capacity: 10,000 gallons
II.A.11 One (1) Emergency Generator Engine - New
Maximum Rated Capacity: 1,474 hp (1,100 kW)
Tier 4 certified
Fuel: Diesel
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

DAQE-IN130290007-24
Page 7

II.A.12 One (1) Emergency Generator Engine - New Maximum Rated Capacity: 201 hp (150 kW) Fuel: Natural gas or propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Plant-Wide Requirements and Limitations II.B.1.a The owner/operator shall not allow visible emissions to exceed the following limits: A. The screens - 7% opacity B. All conveyor transfer points - 7% opacity C. Conveyor drop points - 15% opacity D. The sodium chloride dryer baghouse stacks - 10% opacity E. The magnesium chloride dryer stack - 10% opacity F. The diesel-fired emergency generator engine - 20% opacity G. The natural gas/propane-fired emergency generator engine - 10% opacity H. All other points - 15% opacity. [R307-309, R307-312-4, R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall not exceed the following production and consumption limits: A. 500,000 tons of sodium chloride salt processed per rolling 12-month period B. 21 million gallons of magnesium chloride concentrate processed per rolling 12-month period C. 272,000 MMBtu of natural gas consumed per rolling 12-month period. [R307-401-8]
DAQE-IN130290007-24
Page 8

II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months B. Determine production by scale house records or vendor receipts C. Keep the records of production on a daily basis D. Determine natural gas consumption by billing statements from a utility company. The records of billing statements shall be kept on a monthly basis E. Keep the records of production and natural gas consumption for all periods when the plant is in operation. [R307-401-8]
II.B.1.c The owner/operator shall install partial enclosures on all outdoor screening operations that sort material that has been processed by the sodium chloride salt dryers. The enclosures must be
installed in a way to maintain the opacity limits set in this AO. [R307-401-8]

II.B.2 Sodium Chloride Salt Dryer Requirements II.B.2.a The owner/operator shall only use natural gas as fuel in the salt dryers. [R307-401-8]

II.B.2.b The owner/operator shall install a low NOx burner in the 75 MMBtu/hr salt dryer that is certified to meet a NOx emission concentration of 30 ppm corrected to 3% oxygen. [R307-401-8]
II.B.2.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission
concentration for the 75 MMBtu/hr Dryer on site. The record shall be kept for the life of the equipment. [R307-401-8]

II.B.3 Requirements on the Baghouse
II.B.3.a The owner/operator shall use the baghouses to control process streams from their designated dryers. All exhaust air from the sodium chloride dryers shall be routed through the baghouses
before being vented to the atmosphere. [R307-401-8]

II.B.3.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The static pressure differential across each baghouse shall be between 2.0 to 5.0 inches of water column. [R307-401-8] II.B.3.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. The pressure gauge shall measure the pressure drop in 1-inch water column
increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of the reading is required on a daily basis
when the dryer the baghouse controls operates. [R307-401-8]

II.B.3.c The owner/operator shall install a baghouse that is certified to meet a PM10 emission concentration of 0.005 grains/dscf to control the 75 MMBtu/hr Dryer. [R307-401-8]
II.B.3.c.1 The owner/operator shall keep a record of the manufacturer's certification of the emission
concentration. The record shall be kept for the life of the equipment. [R307-401-8]

II.B.4 Magnesium Chloride Salt Dryer Requirements
II.B.4.a The owner/operator shall only use natural gas as fuel in the magnesium chloride salt dryer.
[R307-401-8]

DAQE-IN130290007-24
Page 9

II.B.4.b The owner/operator shall install a low NOx burner in the magnesium chloride salt dryer that is certified to meet a NOx emission concentration of 30 ppm and a CO emission concentration of 100 ppm or less. [R307-401-8] II.B.4.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission
concentrations. The record shall be kept for the life of the equipment. [R307-401-8]
II.B.5 Road and Fugitive Dust II.B.5.a The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic and
mobile equipment in operational areas to exceed 15% opacity on site and 10% opacity at the property boundary. [R307-309-4, R307-309-5]
II.B.5.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-4, R307-401-8]
II.B.5.b The owner/operator shall not allow the total length of the haul roads to exceed:
A. 0.90 miles of unpaved haul roads for the tanker trucks transporting magnesium chloride
concentrate. The owner/operator shall pave no less than 0.1 miles of haul road
B. 0.81 miles of unpaved haul roads for the haul trucks transporting sodium chloride salt.
The owner/operator shall pave no less than 300 feet of haul road.
[R307-401-8]

II.B.5.c The owner/operator shall apply water sprays and/or chemical suppressant to all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain the opacity limit in the AO. If chemical treatment is to be used, the chemical treatment plan must be approved by the Director. [R307-309, R307-401-8]
II.B.5.c.1 Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items:

A. Date of treatment
B. Number of treatments made, dilution ratio, and quantity
C. Rainfall received, if any, and approximate amount

D. Time of day treatments were made

E. Records of temperature if the temperature was below freezing.

[R307-401-8]

II.B.5.d The owner/operator shall periodically sweep or spray clean the paved haul road to maintain the opacity limit in the AO. [R307-401-8]
II.B.5.d.1 Records of cleaning the paved haul roads shall be kept for all periods the plant is in operation.
[R307-401-8]

DAQE-IN130290007-24
Page 10

II.B.5.e The owner/operator shall comply with all applicable requirements of R307-309 for fugitive emission and fugitive dust sources. [R307-309] II.B.6 Emergency Generator Engine Requirements
II.B.6.a The owner/operator shall install and operate the following emergency generator engines: A. One (1) diesel-fired engine rated up to 1,474 hp (1,100 kW). The engine shall comply with the following Tier 4 standards: HC = 0.14 g/hp-hr, NOx = 0.5 g/hp-hr, and PM = 0.02 g/hp-hr B. One (1) natural gas/propane-fired engine rated up to 201 hp (150 kW). The engine shall comply with the following standards: NOx = 2.0 g/hp-hr, CO = 4.0 g/hp-hr, and VOC = 1.0 g/hp-hr [40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, R307-401-8]
II.B.6.a.1 To demonstrate compliance with the above requirements, the owner/operator shall keep records of the manufacturer's certifications of the emission rates. The records shall be kept for the life of
the equipment. [R307-401-8]

II.B.6.b The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.6.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the following:

A. The date the emergency engine was used
B. The duration of operation in hours
C. The reason for the emergency engine usage.

[40 CFR 60 Subpart ZZZZ, R307-401-8]
II.B.6.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ] II.B.6.c The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the 1,474-hp (1,100-kW) emergency generator engine and natural gas or propane in the
201-hp (150-kW) emergency generator engine. [R307-401-8]

II.B.6.c.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.6.c.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

II.B.6.d The owner/operator shall not test the emergency generator engines at the same time. [R307-410-4]
DAQE-IN130290007-24
Page 11

II.B.6.d.1 To comply with the above requirement, the owner/operator shall: A. Identify the engine to be tested B. Record the engine testing date C. Record the time the testing began and ended D. Keep the above records for all periods the plant is in operation. [R307-410-4]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN130290006-23 dated July 31, 2023 Incorporates NOI dated July 9, 2024 Incorporates Additional information dated August 2, 2024 Incorporates DAQE-MN130290007-24 dated September 24, 2024

DAQE-IN130290007-24
Page 12

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

PUBLIC NOTICE
A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:
Company Name: Broken Arrow Inc.
Location: Broken Arrow Inc. - Broken Arrow Flux Operations – 2600 North Ellerbeck Rd., Grantsville, UT
Project Description: Broken Arrow Inc. operates a salt processing plant locat-ed near Grantsville in Tooele County. The process dries, screens, and loads
salt harvested from the
Great Salt Lake for shipment to customers. The plant produces up to 500,000 tons of salt annually. The company also dries liquid magnesium chloride
concentrate. The magnesium chloride concentrate is brought in to the plant by the tanker trucks and dried by a new natural gas-fired burner. The plant
processes up to 21 million gallons of magnesium chloride concentrate a year.
The company has requested to add two (2) emergency generator engines to provide power to the salt drying operations during emergencies. The
completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and
the State air quality rules. The Director intends to issue an Approval Order
pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public
inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division
at this same address on or before December 27, 2024, will be considered in
making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at [e-mail]. If anyone so requests
to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5,
a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documenta-
tion to enable the Director to fully consider the substance and significance of the issue. Date of Notice: November 27, 2024
(Published in the Tooele Transcript Bulletin November 27, 2024)

DAQE-NN130290007-24

November 21, 2024

Tooele Transcript
Legal Advertising Dept.
58 N Main
Tooele, UT 84074

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Tooele Transcript on
November 27, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Tooele County
cc: Wasatch Front Regional Council

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN130290007-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Broken Arrow Inc.
Location: Broken Arrow Inc. - Broken Arrow Flux Operations – 2600 North Ellerbeck Rd.,
Grantsville, UT
Project Description: Broken Arrow Inc. operates a salt processing plant located near Grantsville in
Tooele County. The process dries, screens, and loads salt harvested from the
Great Salt Lake for shipment to customers. The plant produces up to 500,000
tons of salt annually. The company also dries liquid magnesium chloride
concentrate. The magnesium chloride concentrate is brought in to the plant by the
tanker trucks and dried by a new natural gas-fired burner. The plant processes up
to 21 million gallons of magnesium chloride concentrate a year. The company
has requested to add two (2) emergency generator engines to provide power to
the salt drying operations during emergencies.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before December 27, 2024, will be considered in
making the final decision on the approval/disapproval of the proposed project. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: November 27, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN130290007 November 12, 2024 Ladislao Garcia
Broken Arrow Inc. 8960 North Clinton Landing Lake Point, UT 84074
[e-mail] Dear Ladislao Garcia,
Re: Engineer Review: Modification to AO DAQE-AN130290006-23 to Add Emergency Generator Engines Project Number: N130290007 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Broken Arrow Inc. should complete this review within 10 business days of receipt. Broken Arrow Inc. should contact Mr. Enqiang He at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Enqiang He at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Broken Arrow Inc. does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Broken Arrow Inc. has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N130290007: Broken Arrow Inc. - Broken Arrow Flux Operations November 12, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N130290007 Owner Name Broken Arrow Inc. Mailing Address 8960 North Clinton Landing
Lake Point, UT 84074 Source Name Broken Arrow Inc. - Broken Arrow Flux Operations
Source Location 2600 North Ellerbeck Rd. Grantsville, UT 84029
UTM Projection 368,170 m Easting, 4,504,450 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1474 (Potash, Soda, & Borate Minerals) Source Contact Ladislao Garcia Phone Number [phone] Email [e-mail] Billing Contact Ladislao Garcia Phone Number [phone]
Email [e-mail] Project Engineer Mr. Enqiang He, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted July 9, 2024 Date of Accepted Application October 31, 2024

Engineer Review N130290007: Broken Arrow Inc. - Broken Arrow Flux Operations November 12, 2024 Page 2
SOURCE DESCRIPTION General Description
Broken Arrow Inc. operates a salt processing plant located near Grantsville in Tooele County. The process dries, screens, and loads salt harvested from the Great Salt Lake for shipment to customers. The plant produces up to 500,000 tons of salt annually. The company also dries liquid
magnesium chloride concentrate. The magnesium chloride concentrate is brought to the plant by the tanker trucks and dried by a new natural gas-fired burner. The plant processes up to 21 million gallons of magnesium chloride concentrate a year. NSR Classification: Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Tooele County Airs Source Size: B
Applicable Federal Standards NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal
Modification to AO DAQE-AN130290006-23 to Add Emergency Generator Engines Project Description Broken Arrow has requested a modification to AO DAQE-AN130290006-23 to add two (2) new emergency generator engines. The diesel-fired generator engine is rated up to 1,474 hp (1,100 kW) and will support the salt drying operations during emergencies. The natural gas/propane fired generator engine is rated up to 201 hp (150 kW) and will provide power to the magnesium chloride drying operations during emergencies. Emissions from each of the emergency generator
engines are calculated based on 100 hours of operations per year, and are added to the sitewide totals. EMISSION IMPACT ANALYSIS The source is not required to model for any criteria pollutants and HAPs because the emission increases are below the modeling thresholds per R307-410-4 and R307-410-5. The DAQ conducted in-house modeling for
1-hr NO2 emissions. The modeling result shows that the predicted impact plus background NO2 concentration (176.3 μg/m3) is still less than the NAAQS (188 μg/m3) under the condition that the source shall not test the emergency generator engines at the same time. This condition has been incorporated into this AO. [Last updated August 12, 2024]

Engineer Review N130290007: Broken Arrow Inc. - Broken Arrow Flux Operations November 12, 2024 Page 3
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 96 16114.00 Carbon Monoxide 0.43 35.20
Nitrogen Oxides 0.37 11.54
Particulate Matter - PM10 0 38.02
Particulate Matter - PM2.5 0 36.77
Sulfur Dioxide 0 0.08
Volatile Organic Compounds 0.03 4.38 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 20 540
Change (TPY) Total (TPY)
Total HAPs 0.01 0.27

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N130290007: Broken Arrow Inc. - Broken Arrow Flux Operations November 12, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding the emergency generator engine The diesel-fired emergency generator engine rated up to 1,474 hp (1,100 kW) The engine will be an EPA certified Tier 4 engine. The source shall burn diesel fuel with ultra-low sulfur content at 15 ppm or lower. Visible emissions from the engine are limited at 20% opacity.
The minor NSR Section considers these limitations as BACT. The natural gas/propane fired emergency generator engine rated at 201 hp (150 kW)
The emissions from this engine are very small, with NOx being the most at 0.29 tpy. All other emissions are less than 0.02 tpy. It is, therefore, economically infeasible to install any add-on
controls. The engine will be subject to the standards in Table 1 to NSPS Subpart JJJJ as follows: NOx = 2.0 g/hp-hr, CO = 4.0 g/hp-hr, and VOC = 1.0 g/hp-hr.
Visible emissions from the engine are limited at 10% opacity. The minor NSR Section considers these limitations as BACT. [Last updated November 12, 2024]

SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]

Engineer Review N130290007: Broken Arrow Inc. - Broken Arrow Flux Operations November 12, 2024 Page 5
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Broken Arrow Salt Broken Arrow Flux Operations II.A.2 Three (3) Salt Dryers Design Capacity: Rated at 40, 70, and 75 MMBtu/hr
Fuel: Natural gas II.A.3 Baghouse 1 Controls: 40 MMBtu/hr dryer
Flow Rate: 13,000 acfm Bag Diameter: 6" Bag Length: 9'
Number of Bags: 140 Stack Height: 30' Stack Inside Dimension: 2.5' x 2.5'

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II.A.4 Baghouse 2 Controls: 70 MMBtu/hr dryer Flow Rate: 50,000 acfm
Bag Diameter: 4.6" Bag Length: 12' Number of Bags: 494
Stack Height: 45' Stack Inside Dimension:4' x 4'
II.A.5 Baghouse 3 Controls: 75 MMBtu/hr dryer Flow Rate: 80,000 acfm Bag Diameter: 4.5"
Bag Length: 10' Number of Bags: 960 Stack Height: 45'
Stack Inside Diameter: 5' II.A.6 One (1) Magnesium Chloride Dryer Design Capacity: 10 MMBtu/hr
Fuel: Natural gas Burner: Low NOx burner
II.A.7 Five (5) Screens Design Capacity: One (1) rated at 50 tons/hr; two (2) rated at 150 tons/hr each, two (2) rated at 300 tons/hr each II.A.8 Seven (7) Storage Buildings Storage Capacities: 500, 500, 2,000, 2,500, 4,500, 15,000, and 20,000 tons

II.A.9 Miscellaneous Equipment Associated conveyors, electric motors, front-end loaders and haul trucks
II.A.10 One (1) Diesel Storage Tank Capacity: 10,000 gallons
II.A.11 NEW One (1) Emergency Generator Engine - New Maximum Rated Capacity: 1,474 hp (1,100 kW) Tier 4 certified Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ
II.A.12 NEW One (1) Emergency Generator Engine - New Maximum Rated Capacity: 201 hp (150 kW) Fuel: Natural gas or propane
NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ

Engineer Review N130290007: Broken Arrow Inc. - Broken Arrow Flux Operations November 12, 2024 Page 7

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Plant-Wide Requirements and Limitations
II.B.1.a NEW The owner/operator shall not allow visible emissions to exceed the following limits: A. The screens - 7% opacity
B. All conveyor transfer points - 7% opacity
C. Conveyor drop points - 15% opacity
D. The sodium chloride dryer baghouse stacks - 10% opacity E. The magnesium chloride dryer stack - 10% opacity F. The diesel-fired emergency generator engine - 20% opacity G. The natural gas/propane fired emergency generator engine - 10% opacity
H. All other points - 15% opacity. [R307-309, R307-312-4, R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall not exceed the following production and consumption limits: A. 500,000 tons of sodium chloride salt processed per rolling 12-month period B. 21 million gallons of magnesium chloride concentrate processed per rolling 12-month
period C. 272,000 MMBtu of natural gas consumed per rolling 12-month period.
[R307-401-8]

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II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall:
A. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months B. Determine production by scale house records or vendor receipts
C. Keep the records of production on a daily basis
D. Determine natural gas consumption by billing statements from a utility company. The
records of billing statements shall be kept on a monthly basis
E. Keep the records of production and natural gas consumption for all periods when the
plant is in operation. [R307-401-8] II.B.1.c The owner/operator shall install partial enclosures on all outdoor screening operations that sort material that has been processed by the sodium chloride salt dryers. The enclosures must be installed in a way to maintain the opacity limits set in this AO. [R307-401-8]
II.B.2 Sodium Chloride Salt Dryer Requirements
II.B.2.a The owner/operator shall only use natural gas as fuel in the salt dryers. [R307-401-8]
II.B.2.b The owner/operator shall install a low NOx burner in the 75 MMBtu/hr salt dryer that is certified to meet a NOx emission concentration of 30 ppm corrected to 3% oxygen. [R307-401-8]
II.B.2.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration for the 75 MMBtu/hr Dryer on site. The record shall be kept for the life of the equipment. [R307-401-8]

II.B.3 Requirements on the Baghouse
II.B.3.a The owner/operator shall use the baghouses to control process streams from their designated dryers. All exhaust air from the sodium chloride dryers shall be routed through the baghouses before being vented to the atmosphere. [R307-401-8]
II.B.3.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
differential pressure across each baghouse. The static pressure differential across each baghouse shall be between 2.0 to 5.0 inches of water column. [R307-401-8]
II.B.3.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the
indicator at any time. The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of the reading is required on a daily basis when the dryer the baghouse controls operates. [R307-401-8] II.B.3.c The owner/operator shall install a baghouse that is certified to meet a PM10 emission concentration of 0.005 grains/dscf to control the 75 MMBtu/hr Dryer. [R307-401-8]

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II.B.3.c.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration. The record shall be kept for the life of the equipment. [R307-401-8]
II.B.4 Magnesium Chloride Salt Dryer Requirements II.B.4.a The owner/operator shall only use natural gas as fuel in the magnesium chloride salt dryer. [R307-401-8]

II.B.4.b The owner/operator shall install a low NOx burner in the magnesium chloride salt dryer that is certified to meet a NOx emission concentration of 30 ppm and a CO emission concentration of 100 ppm or less. [R307-401-8]

II.B.4.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission
concentrations. The record shall be kept for the life of the equipment. [R307-401-8] II.B.5 Road and Fugitive Dust II.B.5.a The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas to exceed 15% opacity on site and 10% opacity at the property boundary. [R307-309-4, R307-309-5]
II.B.5.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-4, R307-401-8]
II.B.5.b The owner/operator shall not allow the total length of the haul roads to exceed: A. 0.90 miles of unpaved haul roads for the tanker trucks transporting magnesium
chloride concentrate. The owner/operator shall pave no less than 0.1 miles of haul
road.
B. 0.81 miles of unpaved haul roads for the haul trucks transporting sodium chloride salt.
The owner/operator shall pave no less than 300 feet of haul road. [R307-401-8]
II.B.5.c The owner/operator shall apply water sprays and/or chemical suppressant to all unpaved roads
and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain the opacity limit in the AO. If chemical treatment is to be used, the chemical treatment plan must be approved by the Director. [R307-309, R307-401-8]

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II.B.5.c.1 Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of treatment B. Number of treatments made, dilution ratio, and quantity
C. Rainfall received if any, and approximate amount
D. Time of day treatments were made
E. Records of temperature if the temperature was below freezing. [R307-401-8] II.B.5.d The owner/operator shall periodically sweep or spray clean the paved haul road to maintain the opacity limit in the AO. [R307-401-8]
II.B.5.d.1 Records of cleaning the paved haul roads shall be kept for all periods the plant is in operation. [R307-401-8]
II.B.5.e The owner/operator shall comply with all applicable requirements of R307-309 for fugitive emission and fugitive dust sources. [R307-309]
II.B.6 NEW Emergency Generator Engine Requirements
II.B.6.a NEW The owner/operator shall install and operate the following emergency generator engines: A. One (1) diesel-fired engine rated up to 1,474 hp (1,100 kW). The engine shall comply
with the following Tier 4 standards:
HC = 0.14 g/hp-hr, NOx = 0.5 g/hp-hr, and PM = 0.02 g/hp-hr
B. One (1) natural gas/propane fired engine rated up to 201 hp (150 kW). The engine
shall comply with the following standards:
NOx = 2.0 g/hp-hr, CO = 4.0 g/hp-hr, and VOC = 1.0 g/hp-hr [R307-401-8]
II.B.6.a.1 NEW To demonstrate compliance with the above requirements, the owner/operator shall keep records of the manufacturer's certifications of the emission rates. The records shall be kept for the life of the equipment. [R307-401-8] II.B.6.b NEW The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

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II.B.6.b.1 NEW To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall
include the following:
A. The date the emergency engine was used
B. The duration of operation in hours
C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.6.b.2 NEW To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

II.B.6.c NEW The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 1,474-hp (1,100-kW) emergency generator engine, and natural gas or propane in the 201 hp (150-kW) emergency generator engine. [R307-401-8]

II.B.6.c.1 NEW The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.6.c.2 NEW To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]
II.B.6.d
NEW
The owner/operator shall not test the emergency generator engines at the same time. [R307-
410-4] II.B.6.d.1 NEW To comply with the above requirement, the owner/operator shall: A. Identify the engine to be tested
B. Record the engine testing date
C. Record the time the testing began and ended
D. Keep the above records for all periods the plant is in operation.
[R307-410-4]

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PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes DAQE-AN130290006-23 dated July 31, 2023
Incorporates NOI dated July 9, 2024 Incorporates Additional information dated August 2, 2024 Incorporates DAQE-MN130290007-24 dated September 24, 2024
REVIEWER COMMENTS
1. Comment regarding emission estimates for the emergency generator engines: The diesel-fired emergency generator engine rated up to 1,474 hp (1,100 kW) The emissions are calculated based on 100 hours per year of operations. The emissions factors used in the calculations include Tier 4 standards for NOx, PM2.5 and PM10, and VOCs. Other emission factors are from AP-42 Chapter 3.4. The natural gas/propane fired emergency generator engine rated at 201 hp (150 kW) The emissions are calculated based on 100 hours per year of operations. The emission factors are from AP-42 Chapter 3.2. [Last updated August 12, 2024]
2. Comment regarding NSPS and MACT Applicability: 40 CFR 60 (NSPS) Subpart OOO applies to nonmetallic mineral processing plants. Sodium Chloride (salt) is defined as a nonmetallic mineral in 60.671, however this site does not crush or grind minerals. Therefore, Subpart OOO does not apply to this source. 40 CFR 60 (NSPS) Subpart Dc applies to facilities that operate steam generating units for which construction, modification, or reconstruction commenced after June 9, 1989 and that has a maximum heat input capacity of 100 MMBTU/h or less, but greater than or equal to 10 MMBTU/h. This source operated two natural gas-fired dryers rated between 10 and 100 MMBtu/hr. However, these dryers do not meet the definition of "steam generating unit" as defined in 60.41c; therefore, Subpart
Dc does not apply to this source. 40 CFR 60 (NSPS) Subpart IIII applies to the 1,474-hp (1,100-kW) diesel-fired engine.
40 CFR 60 (NSPS) Subpart JJJJ applies to the 201-hp (150-kW) natural gas/propane fired engine.
40 CFR 63 (MACT) Subpart BBBBBBB applies to owners and operators of chemical preparation
facilities. This source only processes salt which is not a "target-HAP'' as defined in 63.11588; therefore, Subpart BBBBBBB does not apply to this source. 40 CFR 63 (MACT) Subpart ZZZZ applies to the emergency generator engines. [Last updated August 12, 2024] 3. Comment regarding Title V applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,

Engineer Review N130290007: Broken Arrow Inc. - Broken Arrow Flux Operations November 12, 2024 Page 13
Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants. 4. Any Title IV affected source. This source is not a major source, or a Title IV affected source. NSPS Subparts IIII and JJJJ, and MACT Subpart ZZZZ specifically exempt the source from the obligation to obtain a Title V
Operating Permit if the source is not required for the permit for a reason other than being subject to the standards. There are no other reasons why this source would be required to obtain a Title V permit; therefore, Title V does not apply to this facility as per R307-415-4(2)(c). [Last updated August 12, 2024]

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ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds

DAQE-MN130290007-24

M E M O R A N D U M

TO: EQ He, NSR Engineer

FROM: Dave Prey, Air Quality Modeler

DATE: September 24, 2024
SUBJECT: Modeling Analysis Review for the Notice of Intent for Broken Arrow Inc. – Salt
Processing Plant, Tooele County, Utah
_____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.
I. OBJECTIVE
Broken Arrow (Applicant) is seeking an approval order for their Salt Processing Plant located in
Tooele County, Utah. The process dries, screens, and loads salt harvested from the Great Salt Lake
for shipment to customers. The plant produces up to 500,000 tons of sodium chloride salt annually.
The company also dries liquid magnesium chloride concentrate. The magnesium chloride
concentrate is brought in to the plant by the tanker trucks and dried by a new natural gas-fired
burner. The plant shall process up to 21 million gallons of magnesium chloride concentrate a year.
Broken Arrow has requested a modification to AO DAQE-AN130290006-23 to add two (2) new
emergency generator engines. The diesel-fired generator engine is rated up to 1,100 kW and will
support the salt drying operations during emergencies. The natural gas/propane fired generator
engine is rated up to 150 kW and will provide power to the magnesium chloride drying operations
during emergencies.

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility would be in compliance with State and Federal
concentration standards.

II. APPLICABLE RULE(S)

Utah Air Quality Rules:

R307-401-6 Condition for Issuing an Approval Order
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutants in Attainment Areas

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

+ .
DP
DP
DAQE-MN130290007-24
Page 2
III. MODELING METHODOLOGY

A. Applicability
Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. The emission rate for NOx
warranted a modeling review to demonstrate compliance with the one-hour NO2 NAAQS.
Modeling was performed by the UDAQ.

B. Assumptions

1. Topography/Terrain

The Plant is at an elevation 4265 feet with terrain features that have an affect on
concentration predictions.

a. Zone: 12

b. Approximate Location:

UTM (NAD83): 368173 meters East
4504426 meters North

2. Urban or Rural Area Designation
After a review of the appropriate 7.5 minute quadrangles, it was concluded the area is
“rural” for air modeling purposes.

3. Ambient Air
It was determined the Plant boundary used in the AQIA meets the State’s definition of
ambient air.

4. Building Downwash

The source was modeled with the AERMOD model. All structures at the plant were used in
the model to account for their influence on downwash.
5. Meteorology

Five (5) years of off-site surface and upper air data were used in the analysis consisting of
the following:

Surface – Salt Lake Airport, UT NWS: 2016-2020
Upper Air – Salt Lake Airport, UT NWS: 2016-2020
6. Background

The background concentrations were based on concentrations measured in Erda, Utah.

7. Receptor and Terrain Elevations

DAQE-MN130290007-24
Page 3
The modeling domain used consisted of receptors including property boundary receptors.
This area of the state contains mountainous terrain and the modeling domain has simple and
complex terrain features in the near and far fields. Therefore, receptor points representing
actual terrain elevations from the area were used in the analysis.

8. Model and Options

The State-accepted AERMOD model was used to predict air pollutant concentrations under a simple/complex terrain/wake effect situation. In quantifying concentrations, the
regulatory default option was selected.

9. Air Pollutant Emission Rates

Source
UTM Coordinates Modeled Emission Rates
Easting Northing NOx
(m) (m) (lb/hr) (tons/yr) hrs/year
BAGHS3 368173 4504426 1.23 5.40 8760
BAGHS2 368173 4504448 1.15 5.04 8760
BAGHS1 368174 4504465 0.00 0.00 8760
MGCLDRY 368185 4504341 0.16 0.72 8760
EGENSALT 368278 4504489 1.60 0.08 100
EGENMAG 368278 4504484 5.80 0.29 100

Total 9.95 11.54

10. Source Location and Parameters

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
BAGHS3 POINT 4267.1 10.7 35.0 372 20.70 1.52
BAGHS2 POINT 4267.3 12.2 40.0 372 17.49 1.31
BAGHS1 POINT 4267.6 9.1 30.0 372 17.37 0.67
MGCLDRY POINT 4270.6 14.5 47.6 478 20.00 0.46
EGENSALT POINT 4263.7 3.0 10.0 533 20.00 0.15
EGENMAG POINT 4263.5 2.1 6.9 533 20.00 0.15

DAQE-MN130290007-24
Page 4
IV. RESULTS AND CONCLUSIONS

A. National Ambient Air Quality Standards

The below table provides a comparison of the predicted total air quality concentrations with the NAAQS. The predicted total concentrations are less than the NAAQS.

Air Pollutant Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
NO2 1-Hour 158.2 7.5 18.1 0.0 176.3 188 93.8%

V. PERMIT CONDITIONS
The following suggested permit language should be included under the Terms and Conditions in the AO:
• No more than one emergency generator shall be tested at the same time.

DP:jg

Equipment Details
Rating 1,474 hp = (1100 kw)
Operational Hours 100 hours/yearSulfur Content 15 ppm or 0.0015%
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 0.5 1.62 0.08
CO 5.50E-03 8.11 0.41
PM10 0.02 0.06 0.00
PM2.5 0.02 0.06 0.00
VOC 0.14 0.45 0.02
SO2 1.21E-05 0.02 0.00 AP-42 Table 3.4-1
HAP 0.02 0.00 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 1.16 1,710 85
Methane (mass basis)25 6.35E-05 0 0CO2e86
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
Benzene 7.76E-04 8.01E-03 4.00E-04
Toluene 2.81E-04 2.90E-03 1.45E-04
Xylenes 1.93E-04 1.99E-03 9.96E-05
Formaldehyde 7.89E-05 8.14E-04 4.07E-05
Acetaldehyde 2.52E-05 2.60E-04 1.30E-05
Acrolein 7.88E-06 8.13E-05 4.07E-06
Naphthalene 1.30E-04 1.34E-03 6.71E-05
Acenaphthylene 9.23E-06 9.52E-05 4.76E-06
Acenaphthene 4.68E-06 4.83E-05 2.41E-06
Fluorene 1.28E-05 1.32E-04 6.60E-06
Phenanthrene 4.08E-05 4.21E-04 2.10E-05
Anthracene 1.23E-06 1.27E-05 6.35E-07
Fluoranthene 4.03E-06 4.16E-05 2.08E-06
Pyrene 3.71E-06 3.83E-05 1.91E-06
Benz(a)anthracene 6.22E-07 6.42E-06 3.21E-07
Chrysene 1.53E-06 1.58E-05 7.89E-07
Benzo(b)fluoranthene 1.11E-06 1.15E-05 5.73E-07
Benzo(k)fluoranthene 2.18E-07 2.25E-06 1.12E-07
Benzo(a)pyrene 2.57E-07 2.65E-06 1.33E-07
Indeno(1,2,3-cd)pyrene 4.14E-07 4.27E-06 2.14E-07
Dibenz(a,h)anthracene 3.46E-07 3.57E-06 1.79E-07
Benzo(g,h,l)perylene 5.56E-07 5.74E-06 2.87E-07
AP-42 Table 3.3-2,
Table 3.4-3, &
Table 3.4-4
(1,3-Butadiene will
not popluate if the
engine size is greater
than 600 hp. AP-42 does not list 1,3-
Butadiene for engines
greater than 600 hp.)
Diesel-Fired Engines
AP-42 Table 3.3-1
& Table 3.4-1
Manufacturer Data,
AP-42 Table 3.3-1,
& Table 3.4-1
Emission Factor
(lb/MMBtu)
Emergency Engines should equal 100 hours of operation per year
Page 1 of 1 Version 1.1February 21, 2019
Broken Arrow 2024 AO modification Emissions Summary
Current AO DAQE-AN130290006-23Emissions 1100kW diesel engine 150 kW natural gas engine
PM10 38.02 0 0
PM2.5 36.77 0 0
Nox 11.17 0.08 0.29
CO 34.77 0.41 0.020
SO2 0.08 0 0
VOC 4.35 0.02 0.01
HAPs 0.26 0 0.01
CO2e 16018 86 10
Projected Emissions (tpy)
38.02
36.77
11.54
35.200
0.08
4.38
0.27
16114