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HomeMy WebLinkAboutDAQ-2025-000192 DAQE-AN117930014-25 {{$d1 }} William Kaiser Savage Services Corporation 901 West Legacy Center Way Midvale, UT 84047 WilliamKaiser@savageservices.com Dear Mr. Kaiser: Re: Approval Order: Modification to Approval Order DAQE-AN117930013-24 to Increase the Throughput Limit of M-I WATE Project Number: N117930014 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on October 28, 2024. Savage Services Corporation must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Christine Bodell, who can be contacted at (385) 290-2690 or cbodell@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:CB:jg cc: Southeastern Utah District Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 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-AN117930014-25 Modification to Approval Order DAQE-AN117930013-24 to Increase the Throughput Limit of M-I WATE Prepared By Christine Bodell, Engineer (385) 290-2690 cbodell@utah.gov Issued to Savage Services Corporation - Savage Energy Terminal 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 .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 12 ACRONYMS ............................................................................................................................... 13 DAQE-AN117930014-25 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Savage Services Corporation Savage Services Corporation - Savage Energy Terminal Mailing Address Physical Address 901 West Legacy Center Way 2025 East 5000 South Midvale, UT 84047 Price, UT 84501 Source Contact UTM Coordinates Name: William Kaiser 519,150 m Easting Phone: (801) 424-7272 4,375,880 m Northing Email: WilliamKaiser@savageservices.com Datum NAD83 UTM Zone 12 SIC code 5171 (Petroleum Bulk Stations & Terminals) SOURCE INFORMATION General Description Savage Services Corporation (Savage) operates the Savage Energy Terminal located in Price in Carbon County. Savage operates terminals to transload coal and crude oil. Coal is trucked in, crushed, screened, stored in piles, and transloaded to railcars. Crude oil is transloaded via submerged loading with a vapor balance line using mobile transfer racks that pump crude oil between trucks and railcars. Annual coal and crude oil transloads are limited to 7 million tons and 4.38 million bbls, respectively. Savage is not permitted to transload crude oil after 2025. In addition, Savage transloads up to 12,000 and 27,000 tons per year of magnesium hydroxide and M-I WATE, respectively. NSR Classification Minor Modification at Minor Source Source Classification Located in Attainment Area Carbon County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants MACT (Part 63), A: General Provisions DAQE-AN117930014-25 Page 4 MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities Title V (Part 70) Area Source Project Description Savage is permitted to transload up to 18,000 tons of M-I WATE per year under AO DAQE-AN117930013-24, issued July 3, 2024. Savage is requesting to increase the permitted throughput of M-I WATE by 9,000 tons per year, for a total of 27,000 tons of M-I WATE annually. 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 0 6305.00 Carbon Monoxide 0 3.88 Nitrogen Oxides 0 7.07 Particulate Matter - PM10 0.08 45.38 Particulate Matter - PM2.5 0.01 5.71 Sulfur Dioxide 0 0.28 Volatile Organic Compounds 0 70.23 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Benzene (Including Benzene From Gasoline) (CAS #71432) 0 580 Hexane (CAS #110543) 0 10120 Toluene (CAS #108883) 0 200 Xylenes (Isomers And Mixture) (CAS #1330207) 0 50 Change (TPY) Total (TPY) Total HAPs 0 5.48 DAQE-AN117930014-25 Page 5 SECTION I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Savage Energy Terminal (Price) II.A.2 Four (4) Coal Truck Unloading Facilities Control: Enclosed receiving hoppers equipped with water sprays II.A.3 Five (5) Stacking Tubes With associated coal stockpiles II.A.4 Two (2) Radial Stackers Control: Covered II.A.5 One (1) Sampling Crusher Capacity: 2 tph Control: Enclosed in the building II.A.6 Two (2) Underpile Reclaim Systems DAQE-AN117930014-25 Page 6 II.A.7 One (1) Underground Reclaim II.A.8 One (1) Wash Plant With associated conveyor II.A.9 One (1) Radial Conveyor 36" x 100' Radial Stock Conveyor Control: Covered II.A.10 One (1) Belt Conveyor 36" x 150' conveyor to load out belt Control: Covered II.A.11 One (1) Silo Capacity: 10,000 tons Control: Enclosed extendable chute for railcar loading II.A.12 Three (3) Diesel Fuel Tanks Capacity: Less than 42,000 gallons each II.A.13 Three (3) Storage Tanks Capacity: One (1) 10,000 gallon; Two (2) 20,000 gallon Contents: Antifreeze -Listed for informational purposes only- II.A.14 One (1) Gasoline Fuel Dispensing Station Gravity Fed Capacity: 500 gallons MACT Applicability: Subpart CCCCCC II.A.15 Four (4) Oil Transloading Racks Rating: 260 bbl/hr II.A.16 Four (4) Condensate Collectors Capacity: 5 gallon (each) II.A.17 Four (4) Vapor Capture Systems Activated Carbon (55 gallon each) II.A.18 One (1) Emergency Generator Rating: 350 hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.19 One (1) Boiler Capacity: 10.5 MMBtu/hr Fuel: Natural Gas NSPS Applicability: Subpart Dc II.A.20 Haul Roads Control: Water sprayed and chemically treated II.A.21 Mobile Loading Conveyors *Listed for informational purposes DAQE-AN117930014-25 Page 7 II.A.22 Magnesium Hydroxide/M-I WATE Transloading One (1) electric blower (for information only) and (1) baghouse SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All crushers - 15% opacity B. All screens - 10% opacity C. All conveyor transfer points - 10% opacity D. All diesel engines - 20% opacity E. Conveyor drop points - 10% opacity F. Silo - 10% opacity G. All baghouses - 10% opacity H. All other points - 20% opacity. [R307-401-8] II.B.1.b Opacity observations of emissions from stationary sources shall be conducted while in operation in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 Coal Transloading Requirements II.B.2.a The owner/operator shall not exceed the following: A. 7,000,000 tons of total coal throughput per rolling 12-month period B 1,000,000 tons of coal processed (crushed and screened) per rolling 12-month period. [R307-401-8] DAQE-AN117930014-25 Page 8 II.B.2.a.1 The owner/operator shall: A. Determine the coal throughput with truck scales B. Determine the coal processed (crushed and screened) by supervisor monitoring of an operations log C. Record the coal throughput and coal processed (crushed and screened) each day D. Calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months E. Keep all the records for all periods when the plant is in operation. [R307-401-8] II.B.3 Coal Transfer and Crushing Requirements II.B.3.a The owner/operator shall enclose the following transfer points: A. Each conveyor transfer or drop point B. Reclaim conveyor from the primary coal stockpile to the stacking tube C. All wash plants with associated screens, crushers, and conveyors. [R307-401] II.B.3.b The owner/operator shall cover all above-ground conveyors. All reclaim points for the primary coal storage shall be beneath the stockpile. [R307-401] II.B.3.c The owner/operator shall operate water sprays and/or chemical treatment to control fugitive dust emissions from storage piles. Water sprays and/or chemical treatment shall operate as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401] II.B.3.c.1 Records of water or chemical treatment shall be kept for all periods when the plant is in operation. [R307-401-8] II.B.3.d The owner/operator shall install and operate water sprays or chemical dust suppression sprays at the following points to control fugitive emissions: A. All crushers B. All screens The sprays shall operate as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] II.B.3.e The owner/operator shall control the disturbed or stripped areas at all times (24 hours per day, every day) for the duration of the project/operation until the area is reclaimed. Areas disturbed during construction of the facility and not subjected to repeated disturbance shall be revegetated. Repeatedly disturbed areas shall be chemically treated or water sprayed as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] DAQE-AN117930014-25 Page 9 II.B.3.f In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, New Source Performance Standards (NSPS) Subpart A, 40 CFR 60.1 to 60.18, and Subpart Y, 40 CFR 60.250 to 60.254 (Standards of Performance for Coal Preparation Plants), apply to this installation. The owner/operator must operate in accordance with the most current version of 40 CFR 60 applicable to this source. The following emission points are subject to Subpart Y: A. All crushers (above ground) B. All screens (above ground) C. All conveyors (above ground) D. Storage silo stack. [40 CFR 60 Subpart Y] II.B.4 Petroleum Products Transloading Requirements II.B.4.a The owner/operator shall not conduct any liquid petroleum product transloading operations after January 1, 2026. [R307-401-8] II.B.4.b The owner/operator shall not transload more than 4,380,000 barrels of all petroleum products combined per rolling 12-month period. [R307-401-8] II.B.4.b.1 The owner/operator shall: A. Determine the petroleum products throughput with truck scales B. Record the throughput of petroleum products each day C. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the petroleum products throughput records for all periods when the facility is in operation. [R307-401-8] II.B.4.c The owner/operator shall not transload any petroleum products with a true vapor pressure greater than 2.0 psia. [R307-401-8] II.B.4.c.1 The owner/operator shall keep and maintain records of true vapor pressures of all petroleum products transloaded on site. The records shall be kept for all periods when the facility is in operation. [R307-401-8] II.B.5 Vapor Balance and Carbon Capture Requirements II.B.5.a During railcar loading of petroleum products, the owner/operator shall route vapors from the pressure balance lines to the vapor capture systems equipped with carbon capture barrels prior to venting to the atmosphere. [R307-401-8] II.B.5.b The owner/operator shall maintain the carbon canisters per the manufacturer’s specifications and replace the carbon canisters using the colorimetric breakthrough detector in accordance with the manufacturer's recommendations. [R307-401-8] II.B.5.b.1 Records of each carbon canister replacement shall be kept on site for all times the plant is in operation. Canister replacement records shall record the date of replacement and the reason and shall be kept in an operations log maintained by the operator. [R307-401-8] DAQE-AN117930014-25 Page 10 II.B.6 Magnesium Hydroxide and M-I WATE Transloading Requirements II.B.6.a The owner/operator shall not transload more than the following: A. 12,000 tons of magnesium hydroxide per rolling 12-month period B. 27,000 tons of M-I WATE per rolling 12-month period. [R307-401-8] II.B.6.a.1 The owner/operator shall: A. Determine the amount of magnesium hydroxide and M-I WATE transloaded with truck scales B. Record the amount of magnesium hydroxide and M-I WATE transloaded each day C. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep all records when the plant is in operation. [R307-401-8] II.B.6.b The owner/operator shall use a baghouse to control air streams from the magnesium hydroxide and M-I WATE transloading operations. All air streams from these processes shall vent to the baghouse before being vented to the atmosphere. [R307-401-8] II.B.7 Haul Road Requirements II.B.7.a The owner/operator shall prevent visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas from exceeding 20% opacity. [R307-205] II.B.7.a.1 Visible emissions determinations for fugitive sources 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. Six (6) points, distributed along the length of the haul road or in the operational area, shall be chosen by the Director or the Director's representative. An opacity reading shall be made at each point when a vehicle passes the selected points. Opacity readings shall be made at a point not less than one half the vehicle length behind the vehicle and not less than one half the height of the vehicle. The accumulated six (6) readings shall be averaged for the compliance value. [R307-205] II.B.7.b The owner/operator shall water flush or broom sweep the paved haul roads as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] DAQE-AN117930014-25 Page 11 II.B.7.b.1 Records of water flushing and/or sweeping shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of water flushing and/or sweeping B. Number of sweeping and quantity of water used C. Rainfall received, if any, and approximate amount D. Time of day water flushing and/or sweeping were made E. Records of temperature if the temperature is below freezing. [R307-401-8] II.B.7.c The owner/operator shall water spray or chemically treat all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Water spray and chemical treatment shall be of sufficient frequency and quantity to prevent visible emissions from exceeding the opacity limits in this AO unless it is below freezing. [R307-401-8] II.B.7.c.1 Records of water 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 is below freezing. [R307-401-8] II.B.8 Emergency Generator Engine Requirements II.B.8.a The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8] II.B.8.a.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.8.b The owner/operator shall not operate the emergency generator engine on site for more than 100 hours per calendar year for maintenance checks and readiness testing. The emergency generator engine on site may be operated for up to 50 hours per calendrer year in non-emergency situations. Any operation in non-emergency situations shall be counted as part of the 100 hours per calendar year for maintenance and testing. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] DAQE-AN117930014-25 Page 12 II.B.8.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 the 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.8.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.8.b.3 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] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN117930013-24 dated July 3, 2024 Incorporates NOI dated October 28, 2024 DAQE-AN117930014-25 Page 13 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-IN117930014-24 November 21, 2024 William Kaiser Savage Services Corporation 901 West Legacy Center Way Midvale, UT 84047 WilliamKaiser@savageservices.com Dear Mr. Kaiser: Re: Intent to Approve: Modification to Approval Order DAQE-AN117930013-24 to Increase the Throughput Limit of M-I WATE Project Number: N117930014 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, Christine Bodell, as well as the DAQE number as shown on the upper right-hand corner of this letter. Christine Bodell, can be reached at (385) 290-2690 or cbodell@utah.gov, if you have any questions. Sincerely, {{$s }} Alan D. Humpherys, Manager New Source Review Section ADH:CB:jg cc: Southeastern Utah District Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN117930014-24 Modification to Approval Order DAQE-AN117930013-24 to Increase the Throughput Limit of M-I WATE Prepared By Christine Bodell, Engineer (385) 290-2690 cbodell@utah.gov Issued to Savage Services Corporation - Savage Energy Terminal Issued On November 21, 2024 {{$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............................................................................................... 5 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 13 ACRONYMS ............................................................................................................................... 14 DAQE-IN117930014-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Savage Services Corporation Savage Services Corporation - Savage Energy Terminal Mailing Address Physical Address 901 West Legacy Center Way 2025 East 5000 South Midvale, UT 84047 Price, UT 84501 Source Contact UTM Coordinates Name: William Kaiser 519,150 m Easting Phone: (801) 424-7272 4,375,880 m Northing Email: WilliamKaiser@savageservices.com Datum NAD83 UTM Zone 12 SIC code 5171 (Petroleum Bulk Stations & Terminals) SOURCE INFORMATION General Description Savage Services Corporation (Savage) operates the Savage Energy Terminal located in Price in Carbon County. Savage operates terminals to transload coal and crude oil. Coal is trucked in, crushed, screened, stored in piles, and transloaded to railcars. Crude oil is transloaded via submerged loading with a vapor balance line using mobile transfer racks that pump crude oil between trucks and railcars. Annual coal and crude oil transloaded are limited to 7 million tons and 4.38 million bbls, respectively. Savage is not permitted to transload crude oil after 2025. In addition, Savage transloads up to 12,000 and 27,000 tons per year of magnesium hydroxide and M-I WATE, respectively. NSR Classification Minor Modification at Minor Source Source Classification Located in Attainment Area Carbon County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for DAQE-IN117930014-24 Page 4 Stationary Reciprocating Internal Combustion Engines MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities Title V (Part 70) Area Source Project Description Savage is permitted to transload up to 18,000 tons of M-I WATE per year under Approval Order DAQE- AN117930013-24, issued July 3, 2024. Savage is requesting to increase the permitted throughput of M-I WATE by 9,000 tons per year, for a total of 27,000 tons of M-I WATE annually. Savage operates the Savage Energy Terminal located in Price in Carbon County. Savage operates terminals to transload coal and crude oil. Coal is trucked in, crushed, screened, stored in piles, and transloaded to railcars. Crude oil is transloaded via submerged loading with a vapor balance line using mobile transfer racks that pump crude oil between trucks and railcars. Annual coal and crude oil transloaded are limited to 7 million tons and 4.38 million bbls, respectively. Savage is not permitted to transload crude oil after 2025. In addition, Savage transloads up to 12,000 tons of magnesium hydroxide. Savage is also permitted to transload up to 18,000 tons of M-I WATE per year under Approval Order DAQE-AN117930013-24, issued July 3, 2024. Savage is requesting to increase the permitted throughput of M-I WATE by 9,000 tons per year, for a total of 27,000 tons of M-I WATE annually. 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 0 6305.00 Carbon Monoxide 0 3.88 Nitrogen Oxides 0 7.07 Particulate Matter - PM10 0.08 45.38 Particulate Matter - PM2.5 0.01 5.71 Sulfur Dioxide 0 0.28 Volatile Organic Compounds 0 70.23 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Benzene (Including Benzene From Gasoline) (CAS #71432) 0 580 Hexane (CAS #110543) 0 10120 Toluene (CAS #108883) 0 200 Xylenes (Isomers And Mixture) (CAS #1330207) 0 50 Change (TPY) Total (TPY) Total HAPs 0 5.48 DAQE-IN117930014-24 Page 5 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 ETV News (Emery Telcom) 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. 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] DAQE-IN117930014-24 Page 6 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 Savage Energy Terminal (Price) II.A.2 Four (4) Coal Truck Unloading Facilities Control: Enclosed receiving hoppers equipped with water sprays II.A.3 Five (5) Stacking Tubes With associated coal stockpiles II.A.4 Two (2) Radial Stackers Control: Covered II.A.5 One (1) Sampling Crusher Capacity: 2 tph Control: Enclosed in the building II.A.6 Two (2) Underpile Reclaim Systems II.A.7 One (1) Underground Reclaim II.A.8 One (1) Wash Plant With associated conveyor II.A.9 One (1) Radial Conveyor 36" X 100' Radial stock conveyor Control: Covered II.A.10 One (1) Belt Conveyor 36" 150' conveyor to load out belt Control: Covered II.A.11 One (1) Silo Capacity: 10,000 tons Control: Enclosed extendable chute for railcar loading II.A.12 Three (3) Diesel Fuel Tanks Capacity: Less than 42,000 gallons each II.A.13 Three (3) Storage Tanks Capacity: One (1) 10,000 gal; Two (2) 20,000 gal Contents: Antifreeze -Listed for informational purposes only- II.A.14 One (1) Gasoline Fuel Dispensing Station Gravity Fed Capacity: 500 gallons MACT Applicability: Subpart CCCCCC DAQE-IN117930014-24 Page 7 II.A.15 Four (4) Oil Transloading Racks Rating: 260 bbl/hr II.A.16 Four (4) Condensate Collectors Capacity: 5 gal (each) II.A.17 Four (4) Vapor Capture Systems Activated-Carbon (55 gal each) II.A.18 One (1) Emergency Generator Rating: 350 hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.19 One (1) Boiler Capacity: 10.5 MMBtu/hr Fuel: Natural Gas NSPS Applicability: Subpart Dc II.A.20 Haul Roads Control: Water sprayed and chemically treated II.A.21 Mobile Loading Conveyors *Listed for informational purposes II.A.22 Magnesium Hydroxide/M-I WATE Transloading One (1) electric blower (for information only) and (1) baghouse 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 Site-Wide Requirements DAQE-IN117930014-24 Page 8 II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All crushers - 15% opacity B. All screens - 10% opacity C. All conveyor transfer points - 10% opacity D. All diesel engines - 20% opacity E. Conveyor drop points - 10% opacity F. Silo - 10% opacity G. All baghouses - 10% opacity H. All other points - 20% opacity. [R307-401-8] II.B.1.b Opacity observations of emissions from stationary sources shall be conducted while in operation in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 Coal Transloading Requirements II.B.2.a The owner/operator shall not exceed the following: A. 7,000,000 tons of total coal throughput per rolling 12-month period B 1,000,000 tons of coal processed (crushed and screened) per rolling 12-month period. [R307-401-8] II.B.2.a.1 The owner/operator shall: A. Determine the coal throughput with truck scales B. Determine the coal processed (crushed and screened) by supervisor monitoring of an operations log C. Record the coal throughput and coal processed (crushed and screened) each day D. Calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months E. Keep all the records for all periods when the plant is in operation. [R307-401-8] DAQE-IN117930014-24 Page 9 II.B.3 Coal Transfer and Crushing Requirements II.B.3.a The owner/operator shall enclose the following transfer points: A. Each conveyor transfer or drop point B. Reclaim conveyor from the primary coal stockpile to the stacking tube C. All wash plants with associated screens, crushers, and conveyors. [R307-401] II.B.3.b The owner/operator shall cover all above-ground conveyors. All reclaim points for the primary coal storage shall be beneath the stockpile. [R307-401] II.B.3.c The owner/operator shall operate water sprays and/or chemical treatment to control fugitive dust emissions from storage piles. Water sprays and/or chemical treatment shall operate as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401] II.B.3.c.1 Records of water or chemical treatment shall be kept for all periods when the plant is in operation. [R307-401-8] II.B.3.d The owner/operator shall install and operate water sprays or chemical dust suppression sprays at the following points to control fugitive emissions: A. All crushers B. All screens The sprays shall operate as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] II.B.3.e The owner/operator shall control the disturbed or stripped areas at all times (24 hours per day every day) for the duration of the project/operation until the area is reclaimed. Areas disturbed during construction of the facility and not subjected to repeated disturbance shall be revegetated. Repeatedly disturbed areas shall be chemically treated or water sprayed as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] II.B.3.f In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, New Source Performance Standards (NSPS) Subpart A, 40 CFR 60.1 to 60.18, and Subpart Y, 40 CFR 60.250 to 60.254 (Standards of Performance for Coal Preparation Plants) apply to this installation. The owner/operator must operate in accordance with the most current version of 40 CFR 60 applicable to this source. The following emission points are subject to Subpart Y: A. All crushers (above ground) B. All screens (above ground) C. All conveyors (above ground) D. Storage silo stack. [40 CFR 60 Subpart Y] DAQE-IN117930014-24 Page 10 II.B.4 Petroleum Products Transloading Requirements II.B.4.a The owner/operator shall not conduct any liquid petroleum product transloading operations after January 1, 2026. [R307-401-8] II.B.4.b The owner/operator shall not transload more than 4,380,000 barrels of all petroleum products combined per rolling 12-month period. [R307-401-8] II.B.4.b.1 The owner/operator shall: A. Determine the petroleum products throughput with truck scales B. Record the throughput of petroleum products each day C. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the petroleum products throughput records for all periods when the facility is in operation. [R307-401-8] II.B.4.c The owner/operator shall not transload any petroleum products with a true vapor pressure greater than 2.0 psia. [R307-401-8] II.B.4.c.1 The owner/operator shall keep and maintain records of true vapor pressures of all petroleum products transloaded on site. The records shall be kept for all periods when the facility is in operation. [R307-401-8] II.B.5 Vapor Balance and Carbon Capture Requirements II.B.5.a During rail car loading of petroleum products, the owner/operator shall rout vapors from the pressure balance lines to the vapor capture systems equipped with carbon capture barrels prior to venting to the atmosphere. [R307-401-8] II.B.5.b The owner/operator shall maintain the carbon canisters per the manufacture specifications and replace the carbon canisters using the colorimetric breakthrough detector in accordance with the manufacturer's recommendations. [R307-401-8] II.B.5.b.1 Records of each carbon canister replacement shall be kept on site for all times the plant is in operation. Canister replacement records shall record the date of replacement and the reason, and shall be kept in an operations log maintained by the operator. [R307-401-8] II.B.6 Magnesium Hydroxide and M-I WATE Transloading Requirements II.B.6.a The owner/operator shall not transload more than the following: A. 12,000 tons of magnesium hydroxide per rolling 12-month period B. 27,000 tons of M-I WATE per rolling 12-month period. [R307-401-8] DAQE-IN117930014-24 Page 11 II.B.6.a.1 The owner/operator shall: A. Determine the amount of magnesium hydroxide and M-I WATE transloaded with truck scales B. Record the amount of magnesium hydroxide and M-I WATE transloaded each day C. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep all records when the plant is in operation. [R307-401-8] II.B.6.b The owner/operator shall use a baghouse to control air streams from the magnesium hydroxide and M-I WATE transloading operations. All air streams from these processes shall vent to the baghouse before being vented to the atmosphere. [R307-401-8] II.B.7 Haul Road Requirements II.B.7.a The owner/operator shall prevent visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas from exceeding 20% opacity. [R307-205] II.B.7.a.1 Visible emissions determinations for fugitive sources 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. Six points, distributed along the length of the haul road or in the operational area, shall be chosen by the Director or the Director's representative. An opacity reading shall be made at each point when a vehicle passes the selected points. Opacity readings shall be made at a point not less than one half the vehicle length behind the vehicle and not less than one half the height of the vehicle. The accumulated six readings shall be averaged for the compliance value. [R307-205] II.B.7.b The owner/operator shall water flush or broom sweep the paved haul roads as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] II.B.7.b.1 Records of water flushing and/or sweeping shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of water flushing and/or sweeping B. Number of sweeping and quantity of water used C. Rainfall received, if any, and approximate amount D. Time of day water flushing and/or sweeping were made E. Records of temperature if the temperature is below freezing. [R307-401-8] II.B.7.c The owner/operator shall water spray or chemically treat all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Water spray and chemical treatment shall be of sufficient frequency and quantity to prevent visible emissions from exceeding the opacity limits in this AO unless it is below freezing. [R307-401-8] DAQE-IN117930014-24 Page 12 II.B.7.c.1 Records of water 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 is below freezing. [R307-401-8] II.B.8 Emergency Generator Engine Requirements II.B.8.a The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8] II.B.8.a.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.8.b The owner/operator shall not operate the emergency generator engine on site for more than 100 hours per calendar year for maintenance checks and readiness testing. The emergency generator engine on site may be operated for up to 50 hours per calendar year in non-emergency situations. Any operation in non-emergency situations shall be counted as part of the 100 hours per calendar year for maintenance and testing. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.8.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 the 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.8.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.8.b.3 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] DAQE-IN117930014-24 Page 13 PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN117930013-24 dated July 3, 2024 Incorporates NOI dated October 28, 2024 DAQE-IN117930014-24 Page 14 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 Emery Telcom Publication Name: Emery Telcom Publication URL: www.etv10news.com Publication City and State: Price, UT Publication County: Carbon Notice Popular Keyword Category: Notice Keywords: savage Notice Authentication Number: 202411271136435938201 1761527881 Notice URL: Back Notice Publish Date: Wednesday, November 27, 2024 Notice Content NOTICE OF INTENT A Notice of Intent for the following projhelect submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Savage Services Corporation Location: Savage Services Corporation - Savage Energy Terminal – 2025 East 5000 South, Price, UT Project Description: Savage Services Corporation (Savage) operates the Savage Energy Terminal located in Price in Carbon County. Savage operates terminals to transload coal and crude oil. Coal is trucked in, crushed, screened, stored in piles, and transloaded to railcars. Crude oil is transloaded via submerged loading with a vapor balance line using mobile transfer racks that pump crude oil between trucks and railcars. Annual coal and crude oil transloaded are limited to 7 million tons and 4.38 million bbls, respectively. Savage is not permitted to transload crude oil after 2025. In addition, Savage transloads up to 12,000 tons of magnesium hydroxide. Savage is also permitted to transload up to 18,000 tons of M-I WATE per year under Approval Order DAQE-AN117930013-24, issued July 3, 2024. Savage is requesting to increase the permitted throughput of M-I WATE by 9,000 tons per year, for a total of 27,000 tons of M-I WATE annually. 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 cbodell@utah.gov. 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. Published in the ETV Newspaper November 27, 2024. Back DAQE-NN117930014-24 November 21, 2024 ETV News (Emery Telcom) Legal Advertising Department 625 East 100 North Price, UT 84501 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the ETV News (Emery Telcom) 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 (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Southeastern Association of Governments cc: Carbon County 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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-NN117930014-24 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: Savage Services Corporation Location: Savage Services Corporation - Savage Energy Terminal – 2025 East 5000 South, Price, UT Project Description: Savage Services Corporation (Savage) operates the Savage Energy Terminal located in Price in Carbon County. Savage operates terminals to transload coal and crude oil. Coal is trucked in, crushed, screened, stored in piles, and transloaded to railcars. Crude oil is transloaded via submerged loading with a vapor balance line using mobile transfer racks that pump crude oil between trucks and railcars. Annual coal and crude oil transloaded are limited to 7 million tons and 4.38 million bbls, respectively. Savage is not permitted to transload crude oil after 2025. In addition, Savage transloads up to 12,000 tons of magnesium hydroxide. Savage is also permitted to transload up to 18,000 tons of M-I WATE per year under Approval Order DAQE-AN117930013-24, issued July 3, 2024. Savage is requesting to increase the permitted throughput of M-I WATE by 9,000 tons per year, for a total of 27,000 tons of M-I WATE annually. 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 cbodell@utah.gov. 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- November 20, 2024 RN117930014 November 11, 2024 William Kaiser Savage Services Corporation 901 West Legacy Center Way Midvale, UT 84047 WilliamKaiser@savageservices.com Dear William Kaiser, Re: Engineer Review: Modification to Approval Order DAQE-AN117930013-24 to Increase the Throughput Limit of M-I WATE Project Number: N117930014 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. Savage Services Corporation should complete this review within 10 business days of receipt. Savage Services Corporation should contact Christine Bodell at (385) 290-2690 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Christine Bodell at cbodell@utah.gov 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 Savage Services Corporation does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Savage Services Corporation 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 (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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 N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N117930014 Owner Name Savage Services Corporation Mailing Address 901 West Legacy Center Way Midvale, UT, 84047 Source Name Savage Services Corporation - Savage Energy Terminal Source Location 2025 East 5000 South Price, UT 84501 UTM Projection 519,150 m Easting, 4,375,880 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 5171 (Petroleum Bulk Stations & Terminals) Source Contact William Kaiser Phone Number (801) 424-7272 Email WilliamKaiser@savageservices.com Billing Contact William Kaiser Phone Number (801) 424-7272 Email WilliamKaiser@savageservices.com Project Engineer Christine Bodell, Engineer Phone Number (385) 290-2690 Email cbodell@utah.gov Notice of Intent (NOI) Submitted October 28, 2024 Date of Accepted Application November 11, 2024 Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 2 SOURCE DESCRIPTION General Description Savage Services Corporation (Savage) operates the Savage Energy Terminal located in Price in Carbon County. Savage operates terminals to transload coal and crude oil. Coal is trucked in, crushed, screened, stored in piles, and transloaded to railcars. Crude oil is transloaded via submerged loading with a vapor balance line using mobile transfer racks that pump crude oil between trucks and railcars. Annual coal and crude oil transloaded are limited to 7 million tons and 4.38 million bbls, respectively. Savage is not permitted to transload crude oil after 2025. In addition, Savage transloads up to 12,000 and 27,000 tpy of magnesium hydroxide and M-I WATE, respectively. NSR Classification: Minor Modification at Minor Source Source Classification Located in Attainment Area Carbon County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities Title V (Part 70) Area Source Project Proposal Modification to Approval Order DAQE-AN117930013-24 to Increase the Throughput Limit of M-I WATE Project Description Savage is permitted to transload up to 18,000 tons of M-I WATE per year under Approval Order DAQE-AN117930013-24, issued July 3, 2024. Savage is requesting to increase the permitted throughput of M-I WATE by 9,000 tons per year, for a total of 27,000 tons of M-I WATE, annually. EMISSION IMPACT ANALYSIS Savage does not exceed emission increases in any criteria pollutant or HAPs modeling thresholds outlined in R307-410-4 and R307-410-5, respectively. Therefore, no modeling is required at this time. [Last updated November 4, 2024] Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 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 0 6305.00 Carbon Monoxide 0 3.88 Nitrogen Oxides 0 7.07 Particulate Matter - PM10 0.08 45.38 Particulate Matter - PM2.5 0.01 5.71 Sulfur Dioxide 0 0.28 Volatile Organic Compounds 0 70.23 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Benzene (Including Benzene From Gasoline) (CAS #71432) 0 580 Hexane (CAS #110543) 0 10120 Toluene (CAS #108883) 0 200 Xylenes (Isomers And Mixture) (CAS #1330207) 0 50 Change (TPY) Total (TPY) Total HAPs 0 5.48 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding Increase in M-I WATE Throughput M-I WATE will be pneumatically loaded via a hose between railcars and trucks. A baghouse will be used to control particulate emissions. Visible emissions from the baghouse are limited to 10% opacity. The Minor NSR Section considers the baghouse and the opacity limit as BACT for the M-I WATE transloading operations. Note that the baghouse is an existing approved equipment currently used during current M-I WATE transloading operations. The increase in M-I WATE transloading operations will also increase haul road emissions. The expected increase is 0.08 tpy of PM10 and 0.01 tpy of PM2.5. The BACT to reduce emissions from haul roads is maintaining visible emissions below 20% opacity and best management practices. Best management practices include water flushing or broom sweeping the paved haul roads and water spraying or chemically treating the unpaved roads as needed to prevent visible emissions from exceeding the 20% opacity limit. Note that the source is already required to perform these operations. [Last updated November 11, 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 N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 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] 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 Savage Energy Terminal (Price) II.A.2 Four (4) Coal Truck Unloading Facilities Control: Enclosed receiving hoppers equipped with water sprays II.A.3 Five (5) Stacking Tubes With associated coal stockpiles II.A.4 Two (2) Radial Stackers Control: Covered II.A.5 One (1) Sampling Crusher Capacity: 2 tph Control: Enclosed in the building II.A.6 Two (2) Underpile Reclaim Systems II.A.7 One (1) Underground Reclaim II.A.8 One (1) Wash Plant With associated conveyor Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 6 II.A.9 One (1) Radial Conveyor 36" X 100' Radial stock conveyor Control: Covered II.A.10 One (1) Belt Conveyor 36" X 150' conveyor to load out belt Control: Covered II.A.11 One (1) Silo Capacity: 10,000 tons Control: Enclosed extendable chute for railcar loading II.A.12 Three (3) Diesel Fuel Tanks Capacity: Less than 42,000 gallons each II.A.13 Three (3) Storage Tanks Capacity: One (1) 10,000 gal; Two (2) 20,000 gal Contents: Antifreeze -Listed for informational purposes only- II.A.14 One (1) Gasoline Fuel Dispensing Station Gravity Fed Capacity: 500 gallons MACT Applicability: Subpart CCCCCC II.A.15 Four (4) Oil Transloading Racks Rating: 260 bbl/hr II.A.16 Four (4) Condensate Collectors Capacity: 5 gal (each) II.A.17 Four (4) Vapor Capture Systems Activated-Carbon (55 gal each) II.A.18 One (1) Emergency Generator Rating: 350 hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.19 One (1) Boiler Capacity: 10.5 MMBtu/hr Fuel: Natural Gas NSPS Applicability: Subpart Dc II.A.20 Haul Roads Control: Water sprayed and chemically treated II.A.21 Mobile Loading Conveyors *Listed for informational purposes Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 7 II.A.22 Magnesium Hydroxide/M-I WATE Transloading One (1) electric blower (for information only) and (1) baghouse 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 Site-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All crushers - 15% opacity B. All screens - 10% opacity C. All conveyor transfer points - 10% opacity D. All diesel engines - 20% opacity E. Conveyor drop points - 10% opacity F. Silo - 10% opacity G. All baghouses - 10% opacity H. All other points - 20% opacity . [R307-401-8] II.B.1.b Opacity observations of emissions from stationary sources shall be conducted while in operation in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 Coal Transloading Requirements II.B.2.a The owner/operator shall not exceed the following: A. 7,000,000 tons of total coal throughput per rolling 12-month period B 1,000,000 tons of coal processed (crushed and screened) per rolling 12-month period . [R307-401-8] Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 8 II.B.2.a.1 The owner/operator shall: A. Determine the coal throughput with truck scales B. Determine the coal processed (crushed and screened) by supervisor monitoring of an operations log C. Record the coal throughput and coal processed (crushed and screened) each day D. Calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months E. Keep all the records for all periods when the plant is in operation . [R307-401-8] II.B.3 Coal Transfer and Crushing Requirements II.B.3.a The owner/operator shall enclose the following transfer points: A. Each conveyor transfer or drop point B. Reclaim conveyor from the primary coal stockpile to the stacking tube C. All wash plants with associated screens, crushers, and conveyors . [R307-401] II.B.3.b The owner/operator shall cover all above-ground conveyors. All reclaim points for the primary coal storage shall be beneath the stockpile. [R307-401] II.B.3.c The owner/operator shall operate water sprays and/or chemical treatment to control fugitive dust emissions from storage piles. Water sprays and/or chemical treatment shall operate as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401] II.B.3.c.1 Records of water or chemical treatment shall be kept for all periods when the plant is in operation. [R307-401-8] II.B.3.d The owner/operator shall install and operate water sprays or chemical dust suppression sprays at the following points to control fugitive emissions: A. All crushers B. All screens The sprays shall operate as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 9 II.B.3.e The owner/operator shall control the disturbed or stripped areas at all times (24 hours per day every day) for the duration of the project/operation until the area is reclaimed. Areas disturbed during construction of the facility and not subjected to repeated disturbance shall be revegetated. Repeatedly disturbed areas shall be chemically treated or water sprayed as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] II.B.3.f In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, New Source Performance Standards (NSPS) Subpart A, 40 CFR 60.1 to 60.18 and Subpart Y, 40 CFR 60.250 to 60.254 (Standards of Performance for Coal Preparation Plants) apply to this installation. The owner/operator must operate in accordance with the most current version of 40 CFR 60 applicable to this source. The following emission points are subject to Subpart Y: A. All crushers (above ground) B. All screens (above ground) C. All conveyors (above ground) D. Storage silo stack. . [40 CFR 60 Subpart Y] II.B.4 Petroleum Products Transloading Requirements II.B.4.a The owner/operator shall not conduct any liquid petroleum product transloading operations after January 1, 2026. [R307-401-8] II.B.4.b The owner/operator shall not transload more than 4,380,000 barrels of all petroleum products combined per rolling 12-month period. [R307-401-8] II.B.4.b.1 The owner/operator shall: A. Determine the petroleum products throughput with truck scales B. Record the throughput of petroleum products each day C. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the petroleum products throughput records for all periods when the facility is in operation. . [R307-401-8] II.B.4.c The owner/operator shall not transload any petroleum products with a true vapor pressure greater than 2.0 psia. [R307-401-8] II.B.4.c.1 The owner/operator shall keep and maintain records of true vapor pressures of all petroleum products transloaded on site. The records shall be kept for all periods when the facility is in operation. [R307-401-8] Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 10 II.B.5 Vapor Balance and Carbon Capture Requirements II.B.5.a During rail car loading of petroleum products, the owner/operator shall rout vapors from the pressure balance lines to the vapor capture systems equipped with carbon capture barrels prior to venting to the atmosphere. [R307-401-8] II.B.5.b The owner/operator shall maintain the carbon canisters per the manufacture specifications and replace the carbon canisters using the colorimetric breakthrough detector in accordance with the manufacturer's recommendations. [R307-401-8] II.B.5.b.1 Records of each carbon canister replacement shall be kept on site for all times the plant is in operation. Canister replacement records shall record the date of replacement and the reason, and shall be kept in an operations log maintained by the operator. [R307-401-8] II.B.6 Magnesium Hydroxide and M-I WATE Transloading Requirements II.B.6.a NEW The owner/operator shall not transload more than the following: A. 12,000 tons of magnesium hydroxide per rolling 12-month period B. 27,000 tons of M-I WATE per rolling 12-month period . [R307-401-8] II.B.6.a.1 The owner/operator shall: A. Determine the amount of magnesium hydroxide and M-I WATE transloaded with truck scales B. Record the amount of magnesium hydroxide and M-I WATE transloaded each day C. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep all records when the plant is in operation. . [R307-401-8] II.B.6.b The owner/operator shall use a baghouse to control air streams from the magnesium hydroxide and M-I WATE transloading operations. All air streams from these processes shall vent to the baghouse before being vented to the atmosphere. [R307-401-8] II.B.7 Haul Road Requirements II.B.7.a The owner/operator shall prevent visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas from exceeding 20% opacity. [R307-205] Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 11 II.B.7.a.1 Visible emissions determinations for fugitive sources 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. Six points, distributed along the length of the haul road or in the operational area, shall be chosen by the Director or the Director's representative. An opacity reading shall be made at each point when a vehicle passes the selected points. Opacity readings shall be made at a point not less than one half the vehicle length behind the vehicle and not less than one half the height of the vehicle. The accumulated six readings shall be averaged for the compliance value. [R307-205] II.B.7.b The owner/operator shall water flush or broom sweep the paved haul roads as necessary to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8] II.B.7.b.1 Records of water flushing and/or sweeping shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of water flushing and/or sweeping B. Number of sweeping and quantity of water used C. Rainfall received, if any, and approximate amount D. Time of day water flushing and/or sweeping were made E. Records of temperature if the temperature is below freezing. . [R307-401-8] II.B.7.c The owner/operator shall water spray or chemically treat all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Water spray and chemical treatment shall be of sufficient frequency and quantity to prevent visible emissions from exceeding the opacity limits in this AO unless it is below freezing. [R307-401-8] II.B.7.c.1 Records of water 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 is below freezing . [R307-401-8] II.B.8 Emergency Generator Engine Requirements II.B.8.a The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8] Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 12 II.B.8.a.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.8.b The owner/operator shall not operate the emergency generator engine on site for more than 100 hours per calendar year for maintenance checks and readiness testing. The emergency generator engine on site may be operated for up to 50 hours per calendrer year in non-emergency situations. Any operation in non-emergency situations shall be counted as part of the 100 hours per calendar year for maintenance and testing. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.8.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 the 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.8.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.8.b.3 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] Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 13 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN117930013-24 dated July 3, 2024 Incorporates NOI dated October 28, 2024 REVIEWER COMMENTS 1. Comment regarding Source Emission Estimates and DAQ Acceptance: The increase from 18,000 tons per year of M-I WATE throughput to 27,000 tons per year will increase PM10 and PM2.5 emissions. Baghouse Emissions: Emission estimates were based on the baghouse flow rate of 675 dscf per minute and a grain loading of 0.01 grains/dscf. It is assumed that 7,000 grains weight 1 lb. The emissions from the baghouse are independent of annual M-I WATE throughput. Haul Road Emissions: Emissions estimations from haul roads were calculated from AP-42, Chapter 13.2.2 (Paved Roads) and Chapter 13.2.1 (Unpaved Haul Roads). The average unpaved and paved loop distance traveled per truck load is 1.14 miles and 0.12 miles, respectively. [Last updated November 5, 2024] 2. Comment regarding NSPS & MACT Applicability: 40 CFR 60 NSPS Subpart Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. This subpart applies to each steam generating unit for which construction, modification, or reconstruction is commenced after June 9, 1989 and that has a maximum design heat input capacity of 29 megawatts (MW) (100 million British thermal units per hour (MMBtu/h)) or less, but greater than or equal to 2.9 MW (10 MMBtu/h). This subpart applies to the natural-gas fired boiler rated at 10.5 MMBtu/hr. There is no specific limit for the boiler to comply with. Recordkeeping for natural gas consumption is the only requirement. 40 CFR 60 NSPS Subpart Y: Standards of Performance for Coal Preparation and Processing Plant. The source crushes, screens, and load the coal for more than 200 tons of coal per day. Therefore, this subpart applies. 40 CFR 60 NSPS Subpart IIII applies to owners and operators of stationary CI ICE that commence construction after July 11, 2005, where the stationary CI ICE are manufactured on or after April 1, 2006. This facility has an engine that was manufactured before April 1, 2006 and as such, this subpart does not apply to this facility. 40 CFR 63 MACT Subpart ZZZZ applies to owners and operators of stationary RICE at a major or area source of HAP emissions. Since this source will have a stationary RICE at an area source of HAP emissions, MACT Subpart ZZZZ will apply to this facility. 40 CFR 63 MACT Subpart CCCCCC applies to owners and operators at gasoline dispensing facilities. There is a gasoline storage tank on site. MACT Subpart CCCCCC will apply to this facility. 40 CFR 63 MACT Subpart JJJJJJ applies to owners and operators of industrial, commercial, or Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 14 institutional boilers. This site has a boiler within its property boundaries, however the boiler is fired on natural gas, a fuel source that exempts it from the requirements of MACT Subpart JJJJJJ, as such this subpart does not apply to this facility. . [Last updated November 4, 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, 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 facility is not a Title IV source or a major source. The facility is not subject to 40 CFR 61(NESHAP) regulations. It is subject to 40 CFR 60 (NSPS) Subparts A, Dc and Y and to 40 CFR 63 (MACT) Subparts A, ZZZZ, and CCCCCC. MACT Subparts ZZZZ and CCCCCC each exempt sources from the obligation to obtain a Title V permit provided that the source is not required to obtain the permit for any other reason. NSPS Subpart Dc does not include this exemption. However, the facility is only subject to record-keeping requirements under NSPS Subpart Dc, and is not subject to a standard or limitation. NSPS Subpart Y does not include either of the above exemptions. Therefore, Title V applies to this facility as an area source. [Last updated November 11, 2024] Engineer Review N117930014: Savage Services Corporation - Savage Energy Terminal November 11, 2024 Page 15 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 M-I Wate Loading Flow Rate (scf/m) Emission Rate (gr/scf) Increase M-I WATE (tons) Controlled PM10/PM2.5 (lb/yr) Controlled PM10/PM2. (tpy) 675 0.01 9000 506.83 0.25 *7000 grains per lb **Methodology is independant of M-I WATE loading throughouts. Therefore, emissions are not inc this is consistent with how emissions were estimated in previous AO versions Controlled PM10/PM2. (lb/hr) 0.06 creasing for loading operations Production RatesHourly Rates 1 tons/hour Annual Production 9,000 tons/year *source has 0.7 miles total haul roads 90% of which are unpaved*treating all roads as unpaved Truck InformationEmpty Truck Weight 20 tons Weight of Load 42 tonsLoaded Truck Weight 62 tons Haul Road Information Haul Road One-Way Length 5,000 feetHourly Vehicle Miles Traveled 0.0 miles Annual Vehicle Miles Traveled 406 miles Type of Control Pollutant Uncontrolled Emission Factor (lb/VMT) Controlled Emission Factor (lb/VMT) EmissionRate (lbs/hr) EmissionTotal (tons/year)ReferencePM102.13 0.64 0.03 0.13PM2.5 0.213 0.064 0.00 0.01 Haul Roads Basic Watering - (70% control) AP-42 13.2.2 & DAQ Haul Road Guidance Page 3 of Version 1.0 November 29, 2018 Pollutant Increase (tpy)Permitted (tpy)New PTE (tpy) PM10 0.13 45.30 45.43 PM2.5 0.01 5.70 5.71 *matched submission within tolerance, difference due to rounding Page 1 of 1 Company___________________________ Site _____________________________ Form 5 Emissions Information Criteria/GHGs/ HAP’s Utah Division of Air Quality New Source Review Section Potential to Emit* Criteria Pollutants & GHGs Criteria Pollutants Permitted Emissions (tons/yr) Emissions Increases (tons/yr) Proposed Emissions (tons/yr) PM10 Total PM10 Fugitive PM2.5 NOx SO2 CO VOC VOC Fugitive NH3 Greenhouse Gases CO2e CO2e CO2e CO2 CH4 N2O HFCs PFCs SF6 Total CO2e *Potential to emit to include pollution control equipment as defined by R307-401-2. Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act ) Hazardous Air Pollutant*** Permitted Emissions (tons/yr) Emission Increase (tons/yr) Proposed Emission (tons/yr) Emission Increase (lbs/hr) Total HAP *** Use additional sheets for pollutants if needed Jccumonl Dcjlc: 02/28/2018 Savage Services Corporation • 901 W. Legacy Center Way • Midvale, Utah 84047 • 801-944-6600 • www.savageservices.com October 23, 2024 Attn: Permitting Utah Division of Air Quality 195 North 1950 West Salt Lake City, Utah 84116 Project Number: 120.021769.00001 Subject: Notice of Intent Approval Order Modification: AN117930011-24 Savage Services Corporation Savage Energy Terminal Price, Utah To the Agency: Savage Services Corporation (Savage) is submitting this Notice of Intent to modify Approval Order DAQE- AN117930011-24. The facility currently is a minor source and will remain a minor source after the modification. The intent of this application is to modify existing operations at this facility to authorize the increase of M-I WATE loading throughput from 18,000 to 27,000 tons per year. If you have any questions regarding this submittal or require additional information, please feel free to contact me at WilliamKaiser@savageservices.com, (801) 424-7272. Sincerely, William Kaiser PMP, CHMM, REM, CSP, CESCO Environmental Director Attachments Savage Services Corporation Savage Energy Terminal Notice of Intent Approval Order Modification: AN117930011-24 Prepared for: Savage Services Prepared by: SLR International Corporation SLR Project No.: 120.021769.00001 October 2024 Savage Services Corporation Savage Energy Terminal Notice of Intent Approval Order Modification: AN117930011-24 October 2024 SLR Project No.: 120.021769.00001 ii Table of Contents 1.0 Introduction ...................................................................................................................... 1 1.1 Background ........................................................................................................................ 1 1.2 Process Description ........................................................................................................... 1 2.0 Area Maps ......................................................................................................................... 3 3.0 Plot Plan ............................................................................................................................ 1 4.0 Emission Rate Estimation Methodologies ...................................................................... 1 4.1 Solid loading Operations .................................................................................................... 1 4.2 Haul Road Emissions ......................................................................................................... 1 5.0 Best Available Control Technology Review ................................................................... 2 5.1 BACT for Solids Transloading ............................................................................................ 2 5.2 BACT for Haul Road Emissions .......................................................................................... 2 6.0 Regulatory Applicability Analysis ................................................................................... 3 6.1 State regulations ................................................................................................................ 3 6.2 Federal Regulations ............................................................ Error! Bookmark not defined. 7.0 Closure .............................................................................................................................. 3 Figures in Text Figure 1-1 Process Flow Diagram .............................................................................................. 2 Figure 2-1 Area Map ................................................................... Error! Bookmark not defined. Figure 3-1 Plot Plan .................................................................... Error! Bookmark not defined. Appendices Appendix A UDEQ Forms Appendix B Emission Calculations Savage Services Corporation Savage Energy Terminal Notice of Intent Approval Order Modification: AN117930011-24 October 2024 SLR Project No.: 120.021769.00001 1 1.0 Introduction 1.1 Background Savage Services Corporation (Savage) is submitting this Notice of Intent Approval Order Modification application to the Utah Department of Environmental Quality (UDEQ) to modify existing operations at the Savage Energy Terminal currently authorized under AN117930011-24 located in Price, Utah (the Site). Modification will be an increase in throughput from 18,000 to 27,000 tons of bulk solids per year. 1.2 Process Description The process at the Site includes bulk solid loading operations from trucks into rail cars. Trucks arrive at the site and use a conveyor to transfer bulk solids into rail cars. Emissions will be controlled using a dust collector. The trucks will use paved and unpaved haul roads, and the truck traffic will generate particulate emissions. Savage Services Corporation Savage Energy Terminal Notice of Intent Approval Order Modification: AN117930011-24 October 2024 SLR Project No.: 120.021769.00001 2 Figure 1-1 Process Flow Diagram There will be no change to Process flow diagram from the previous application. Savage Services Corporation Savage Energy Terminal Notice of Intent Approval Order Modification: AN117930011-24 October 2024 SLR Project No.: 120.021769.00001 3 2.0 Area Maps There will be no change to the area maps from the previous application. Savage Services Corporation Savage Energy Terminal Notice of Intent Approval Order Modification: AN117930011-24 October 2024 SLR Project No.: 120.021769.00001 1 3.0 Plot Plan There will be no change to the plot plan from the previous application. Savage Services Savage Services Corporation October 2024 SLR Project No.: 120.021769.00001 1 4.0 Emission Rate Estimation Methodologies Emission estimates for this application were prepared in accordance with AP-42 methodologies, and equipment specific emissions factors as described in the following sections for each source type. Detailed emissions estimates are provided in Appendix B. A summary of sitewide uncontrolled and controlled emissions are included as Table B-1. There was no change in emission estimation methodology from previous applications, only an increase in solids throughput and truck traffic. 4.1 Solid loading Operations Emissions of particulate matter (PM10/PM2.5) from loading bulk solids from trucks to rail cars were estimated using dust collector flow rate, dust collector outlet particulate loading, and the assumption that 15% of PM10 is PM2.5. Uncontrolled emissions were calculated based on the assumption of a 99% control efficiency for the associated dust collector. Detailed emissions estimates are represented in Table B-2. The total throughput for the bulk solid loading operations will be increasing to 27,000 tons per year. 4.2 Haul Road Emissions Particulate emissions from the paved haul roads and unpaved haul roads were estimated using emission factors from AP-42, Chapters 13.2.1 and 13.2.2 for industrial roads, the maximum number of trucks that would be unloaded hourly and annually, the average truck weight, and round-trip driving distance per truck. For the unpaved roads, dust suppressants were used to reduce emissions, with a control efficiency of 0.7 included in the calculations. Table B-3 of Appendix B provides details of these emissions estimates. Savage Services Savage Services Corporation October 2024 SLR Project No.: 120.021769.00001 2 5.0 Best Available Control Technology Review Savage has completed a Best Available Control Technology (BACT) analysis for the operations being authorized with this notice of intent. This analysis was conducted according to regulation UAC R307-401-5. 5.1 BACT for Solids Transloading Bulk solid transloading operations will use dust collectors to control emissions, reducing emissions by 99%. Savage is proposing their use as BACT. This level of control is comparable to other similar bulk solids loading operations. 5.2 BACT for Haul Road Emissions Savage is proposing the use of a combination of dirt roads with dust suppressant chemicals and paved roads as BACT. Savage Services Savage Services Corporation October 2024 SLR Project No.: 120.021769.00001 3 6.0 Regulatory Applicability Analysis 6.1 Federal and State regulations The increase in throughput for bulk solid loading and road traffic did not change state or federal regulatory requirements. Emissions are still below major source thresholds. 7.0 Closure Notice of Intent Approval Modification Application Savage Services Savage Services Corporation October 2024 SLR Project No.: 120.021769.00001 4 Prepared for: Savage Services Savage Energy Terminal This document has been prepared by SLR International Corporation (SLR). The material and data in this report were prepared under the supervision and direction of the undersigned. Deever Bradley, P.E. Senior Principal Conor Braman Senior Engineer Appendix A UDEQ Forms 1 of 1 Form 2 Date ____________ Company Information/Notice of Intent (NOI) Utah Division of Air Quality New Source Review Section Application for: □ Initial Approval Order □Approval Order Modification General Owner and Source Information 1.Company name and mailing address: ____________________________ ____________________________ ____________________________ Phone No.: ( ) Fax No.: ( ) 2.Company** contact for environmental matters: ____________________________ Phone no.: ( ) Email: _______________________ ** Company contact only; consultant or independent contractor contact information can be provided in a cover letter 3.Source name and physical address (if different from above):____________________________ ____________________________ ____________________________ Phone no.: ( ) Fax no.: ( ) 4.Source Property Universal Transverse Mercator coordinates (UTM), including System and Datum: UTM:_________________________ X:____________________________ Y:____________________________ 5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC) __ __ __ __ 7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____ 8.Brief (50 words or less) description of process. Electronic NOI 9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black (jlblack@utah.gov) or Alan Humpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal Electronic Copy Submittal □ Both Authorization/Signature I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on reasonable inquiry made by me and to the best of my knowledge and belief. Signature: Title: _______________________________________ Name (Type or print) Telephone Number: ( ) Email: Date: DAO 2018 002272 Page 1 of 1 Form 4 Company____________________________ Project Information Site ______________________________ Utah Division of Air Quality New Source Review Section Process Data - For Modification/Amendment ONLY 1. Permit Number_______________________________ If submitting a new permit, then use Form 3 Requested Changes 2. Name of process to be modified/added: _______________________________ End product of this process: _______________________________ 3. Permit Change Type: New Increase* Equipment Process Condition Change ____________________ Other ______________________________ Other ______________________________ Other ______________________________ 4. Does new emission unit affect existing permitted process limits? Yes No 5. Condition(s) Changing: 6. Description of Permit/Process Change** 7. New or modified materials and quantities used in process. ** Material Quantity Annually 8. New or modified process emitting units ** Emitting Unit(s) Capacity(s) Manufacture Date(s) *If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an emissions increase and a public comment period. **If additional space is required, please generate a document to accommodate and attach to form. Doc.uim:i'ii D^lc: 02/28/2018 DAQ 2018-002274 Page 1 of 1 Company___________________________ Site _____________________________ Form 5 Emissions Information Criteria/GHGs/ HAP’s Utah Division of Air Quality New Source Review Section Potential to Emit* Criteria Pollutants & GHGs Criteria Pollutants Permitted Emissions (tons/yr) Emissions Increases (tons/yr) Proposed Emissions (tons/yr) PM10 Total PM10 Fugitive PM2.5 NOx SO2 CO VOC VOC Fugitive NH3 Greenhouse Gases CO2e CO2e CO2e CO2 CH4 N2O HFCs PFCs SF6 Total CO2e *Potential to emit to include pollution control equipment as defined by R307-401-2. Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act ) Hazardous Air Pollutant*** Permitted Emissions (tons/yr) Emission Increase (tons/yr) Proposed Emission (tons/yr) Emission Increase (lbs/hr) Total HAP *** Use additional sheets for pollutants if needed Jccumonl Dcjlc: 02/28/2018 Appendix B Emission Calculations Permitted Emissions (lb/hr)(tpy)(lb/hr)(tpy)(lb/hr)(tpy)(lb/hr)(tpy) Bulk Solid Loading M-I WATELOAD 0.058 0.25 0.009 0.038 0.058 0.25 0.009 0.038 Haul Roads HAUL 0.037 0.16 0.0038 0.017 0.055 0.24 0.01 0.024 0.095 0.41 0.0126 0.055 0.11 0.49 0.01 0.06 Permitted Emissions (lb/hr)(tpy)(lb/hr)(tpy)(lb/hr)(tpy)(lb/hr)(tpy) Bulk Solid Loading M-I WATELOAD 5.79 25.34 0.88 3.84 5.79 25.34 0.87 3.80 Haul Roads HAUL 0.12 0.53 0.012 0.054 0.18 0.80 0.02 0.08 5.91 25.87 0.892 3.894 5.97 26.14 0.89 3.88 TABLE B-1 Emissions Summary Savage Energy Terminal Price, Utah PM10 PM2.5 Source Name Total PM2.5 Potential Emissions Uncontrolled Emissions Controlled Emissions Potential Emissions PM10 PM2.5 Total Source Name EPN EPN PM10 PM10 PM2.5 TABLE B-2 Bulk Solids Loading (FIN/EPN M-I WATELOAD) Savage Energy Terminal Price, Utah Hours/year:8,760 min/hr 60 0.0001 lb/grain Emission Basis:Air Pollution Engineering Manual, A&WMA, 2000 Controlled Controlled Uncontrolled Uncontrolled (lb/hr)(tpy)(lb/hr)(tpy) Criteria PM10  0.06 0.25 5.79 25.34 PM2.5 0.01 0.038 0.87 3.80 (a) Assumed control efficiency of 99%  Chystalline Silica Throughput (ton/yr) 27,000 Reference: Air Pollution Engineering Manual, A&WMA, 2000, Page 100 Flowrate (acfm) (a)675 Emission Rate (gr/dscf) (b)0.01 Emissions (lb/hr) PM10 0.06 PM2.5 0.01 a Diversified Storage Systems specification sheet for Air Max 225 Dust Collector  b Air Pollution Engineering Manual, A&WMA, 2000, Page 100 Pollutant Controlled Emissions - Material Drops MI WATE Railcar Loading Estimated Emissions (a)Estimated Emissions Emission Calculations Assumptions Pollutant TABLE B-3Haul Road Emissions (FIN/EPN HAULROAD)Savage Energy Terminal Price, Utah Hours/year: 8,760Emission Basis:Emissions from the use of paved and unpaved haul roads are estimated based on unpaved (§13.2.2) and paved (§13.2.1) emission factors Estimated EmissionsUncontrolled Uncontrolled Controlled Controlled(lb/hr)(tpy)(lb/hr)(tpy)CriteriaPM10 0.18 0.80 0.05 0.24 PM2.5 0.02 0.08 0.01 0.02 Unpaved Haul Roads Assumptions Avg unpaved loop distance traveled per truck load (mi) 1.14 Avg paved loop distance traveled per truck load (mi) 0.12Amount of solids a truck can haul (tons) 42 Amount of solids a truck can haul (tons) 42Potential Solids throughput (ton/yr)27,000 Potential Solids throughput (ton/yr) 27,000Trucks per year solids 643 Trucks per year solids 643Total trucks per year 643 Total trucks per year 643 Annual vehicle miles traveled (VMT/yr) 733 Annual vehicle miles traveled (VMT/yr) 77 Emissions - Unpaved Haul Roads Emissions - Paved Haul Roads Trucks per day, ADT 1Emission Factor(a),(c)=k (s/12)^a(W/3)^b E [(365‐P)/365 ]Emission Factor(f) = kL^(0.91) W^(1.02) (1‐P/(365*4))constant k (lb/VMT) for PM10 1.5 k for PM10 (lb/VMT) 0.0022 constant k (lb/VMT) for PM2.5 0.15 k for PM2.5 (lb/VMT) 0.00054Silt content of road surface material(b) (%), s 4.8 No. precipitation days with 0.01" or more of precipitation/yr(g), P 80Constant a for PM10 0.9 Avg. total vehicle weight, W (tons) 42.75Constant a for PM2.5 0.9 Months where mean temperature is below 32F 4constant b for PM10 0.45 Ubiquitious Winter Baseline Multiplier 4constant b for PM2.5 0.45 Silt loading for ADT < 500(g), L (g/m^2) 1.2Moisture ratio, M 5Water control efficiency (d) 0.7 Uncontrolled Emissions Pollutant Emission Factor Emissions Pollutant Emission Factor Emissions(lb/VMT) (tpy) (lb/VMT) (tpy)PM10 2.17 0.80 PM10 0.11 0.00008 PM2.5 0.22 0.08 PM2.5 0.03 0.00002 Controlled Emissions Emissions (tpy) PM10 0.24 There are no controls for paved roads PM2.5 0.02 NOTES: NOTES: a.) Combination of equations 1a and 2 from AP42 Chapter 13 §13.2.2 e.) On the paved roads, there are both oil trucks and coal trucks. b.) Emission Factors for Paved and Unpaved Haul Roads," UDAQ, Nov 3, 2008 f.) Equation 2 from AP42 §13.2.1 where N=365 c.) Constants and ratings for Equation 1a provided by Tables 13.2.2‐2 and 13.2.2‐3 of g.) AP42 Chapter 13 Figure 13.2.1‐2 d.) AP42 Chapter 13 Figure 13.2.2‐2 Pollutant Pollutant Assumptions Paved Haul Roads Uncontrolled Emissions Controlled Emissions