DAQ-2025-000281

DAQE-AN105320006-25

{{$d1 }}

Suzy Smith
Western Metals Recycling
4201 West 700 South
Salt Lake City, UT 84104
[e-mail]

Dear Ms. Smith:

Re: Approval Order: Administrative Amendment of Approval Order DAQE-AN105320005-23 to
Lower Tank Height Limits in the Scrubbing Water Storage Tank
Project Number: N105320006

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August 8,
2024. Western Metals Recycling must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Mr. Tim DeJulis, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:TD:jg

cc: Salt Lake County Health Department

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

January 15, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN105320006-25
Administrative Amendment of Approval Order
DAQE-AN105320005-23 to Lower Tank Height Limits
in the Scrubbing Water Storage Tank

Prepared By
Mr. Tim DeJulis, Engineer
[phone]
[e-mail]

Issued to
Western Metals Recycling - Metal Shredder Recovery

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

January 15, 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 ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12

DAQE-AN105320006-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Western Metals Recycling Western Metals Recycling - Metal Shredder Recovery

Mailing Address Physical Address
4201 West 700 South 4201 West 700 South
Salt Lake City, UT 84104 Salt Lake City, UT 84104

Source Contact UTM Coordinates
Name: Suzy Smith 416,364 m Easting
Phone: [phone],511,898 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 5093 (Scrap & Waste Materials)

SOURCE INFORMATION
General Description
Western Metals Recycling (WMR) is a wholly owned venture of Cincinnati-based The David J. Joseph
Company (DJJ). WMR conducts metal shredding in addition to cutting, hand torching, and sorting of
ferrous and non-ferrous materials. Emissions from the Salt Lake City facility will primarily consist of
fugitive emissions of PM10, PM2.5, and VOCs from shredding operations. The facility operates an
air-sifting process to clean the materials of loose dirt and fibers. A cyclone/scrubber system is operated to
control the emissions from the air-sifting process. A foam injection system is utilized on the shredder and
provides PM control. Storage tanks collect the gasoline fuel from the cars being shredded.

NSR Classification
Administrative Amendment

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
DAQE-AN105320006-25
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

Project Description
WMR has requested an administrative amendment to AO DAQE-AN105320005-23, dated May 18, 2023,
for a new lower settling tank height requirement in the AO for the process. Currently in the AO, the
settling tank is limited by condition II.B.2.d: "The settling tank volume shall not be less than 7,410
gallons for more than five minutes in any 60-minute period." The total storage tank capacity of the storage
tank is 7,410 gallons; therefore, the operation of the settling tank is functionally unworkable in practice,
as there isn't any room in storage tank height for more than 7,410 gallons. WMR has requested a change
to condition II.B.2.d to say, "The settling tank volume shall not be less than 6,500 gallons for more than
five minutes in any 60-minute period." No other changes to the operations or the emissions will take
place.

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 0 321.00
Carbon Monoxide 0 0.11
Nitrogen Oxides 0 0.28
Particulate Matter - PM10 0 29.56
Particulate Matter - PM2.5 0 24.05
Volatile Organic Compounds 0 39.06

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 616
Cumene (CAS #98828) 0 64
Ethyl Benzene (CAS #100414) 0 618
Generic HAPs (CAS #GHAPS) 0 80
Hexane (CAS #110543) 0 1192
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 193
Methyl Methacrylate (CAS #80626) 0 21
Methylene Chloride (Dichloromethane) (CAS #75092) 0 20
Naphthalene (CAS #91203) 0 51
Styrene (CAS #100425) 0 272
Toluene (CAS #108883) 0 2672
Trichloroethylene (CAS #79016) 0 21
Xylenes (Isomers And Mixture) (CAS #1330207) 0 2980
Change (TPY) Total (TPY)
Total HAPs 0 4.40
DAQE-AN105320006-25
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 Metal Shredder Recovery II.A.2 One (1) Electric Shredder Control: Foam injection operation combined with two (2) cyclones and two (2) wet scrubbers in two (2) collection systems.
II.A.3 Shredded Materials Separation System Magnetic drum separator and air sifting/z-box II.A.4 Welding and Torch Cutting Activities
II.A.5 Conveyors
DAQE-AN105320006-25
Page 6

II.A.6 One (1) Emergency Generator Engine Fuel: Diesel Rating: 99 kW (132 hp) NSPS Subpart IIII MACT Subpart ZZZZ II.A.7 Various Fuel Storage Tanks
One (1) Storage Tank Fuel: Diesel Capacity: 2,000 gallons
Two (2) Storage Tanks Fuel: Gasoline
Capacity: 500 gallons and 1,000 gallons
MACT Subpart CCCCCC

II.A.8 Various Support Equipment Shears, choppers, balers, non-ferrous metal receiving, cranes, and front-end loaders. Listed for informational purposes only.

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-wide Requirements
II.B.1.a The owner/operator shall not process more than 320,000 tons of scrap metal through the shredding machine per rolling 12-month period. [R307-401-8]
II.B.1.a.1 The owner/operator shall:

A. Determine scrap metal processed with process scales and inventory records
B. Record scrap metal processed on a monthly basis
C. Use the scrap metal processed data to calculate a new 12-month total by the 20th day of
each month using data from the previous 12 months
D. Keep the scrap metal processed records for all periods the plant is in operation.

[R307-401-8]
II.B.1.b The owner/operator shall not operate: A. The shredding device more than 13 hours per 24-hour period B. Any operations not associated with the shredder before 6:00 am and after 7:00 pm each day. [R307-401-8]
DAQE-AN105320006-25
Page 7

II.B.1.b.1 The owner/operator shall keep and maintain the following records of operations for the shredding device and the operations not associated with the shredder at this facility: A. Time the shredding operations begin each day B. Time operations not associated with the shredder begin each day C. Time the shredding operations end each day D. Time operations not associated with the shredder end each day. [R307-401-8] II.B.1.c The owner/operator shall control all emissions from the z-box and the shredding machine with
the cyclone/scrubber. The owner/operator shall control the emissions from the z-box and shredding machine with foam injection as needed to maintain the opacity limits in the permit.
[R307-401-8]

II.B.1.d The owner/operator shall not exceed visible emissions from the following emission points: A. Each scrubber exhaust - 15% opacity B. Electric shredding machine - 15% opacity C. Diesel engines - 20% opacity D. All other points - 20% opacity. [R307-305-3]
II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.e The owner/operator shall comply with R307-328-5 for the gasoline storage tanks. [R307-328-5, R307-401-8]
II.B.2 Stack Testing Requirements
II.B.2.a The owner/operator shall not emit more than the following rates and concentrations from VENTURI SCRUBBER STACKS: Pollutant lb/hr grains/dscf Filterable PM10 4.98 (each scrubber) 0.02 (each scrubber) [R307-401-8]
II.B.2.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-165-2, R307-401-8]

II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]
II.B.2.b.1 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]

DAQE-AN105320006-25
Page 8

II.B.2.b.2 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.2.b.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the
date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]
II.B.2.b.4 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] II.B.2.b.5 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8]

II.B.2.b.6 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]
II.B.2.c Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]
II.B.2.c.1 Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.2.c.2 Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10. [R307-401-8]

DAQE-AN105320006-25
Page 9

II.B.2.d The owner/operator shall maintain the following operating parameters within the indicated ranges for each scrubber: A. The pressure drop shall not be less than 3.6 inches of water (minimum) for more than five (5) minutes in any 60-minute period B. The liquid flow rate shall not be less than 3,750 gallons/hour for more than five (5) minutes in any 60-minute period C. The settling tank volume shall not be less than 6,500 gallons for more than five (5) minutes in any 60-minute period Items A, B, and C of this section shall be monitored with equipment located such that an inspector/operator can safely read the output anytime. The readings shall be accurate to within the following ranges: D. The manometer - plus or minus 5% E. The flow meters - plus or minus 5% Flow meters shall be calibrated against a primary standard, at least once every year. The primary standard shall be established by the company and shall be submitted to the Director for approval. The manometer shall be calibrated against a primary standard which will be a second manometer. The manometer shall be calibrated against the primary standard at least once a year. [R307-401-8] II.B.2.d.1 The owner/operator shall install, calibrate, maintain, and operate each monitoring device certified
by the manufacturer. Calibration shall be on an annual basis according to the manufacturer's
instructions. Daily records of reading shall be maintained. [R307-401-8]
II.B.3 Fugitive Dust and Haul Road Requirements
II.B.3.a An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit
Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the FDCP for
control of all fugitive dust sources associated with the metal shredding facility. [R307-309-6]

II.B.3.b The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas to exceed 20% opacity at any point in plant and 10% opacity at the property boundary. [R307-309-5] II.B.3.b.1 Visible emission determinations shall use procedures similar to Method 9. The normal
requirement for observations to be made at 15-second intervals over a six-minute period,
however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height
of the vehicle. [R307-309-5]

II.B.3.c The owner/operator shall use chemical suppressants as needed on all the unpaved haul roads and water on the paved haul roads on site to maintain opacity limits listed in this AO. If the temperature is below freezing or if the haul roads are covered with snow or ice, the owner/operator may stop using water on the unpaved and paved haul roads. [R307-401-8]
DAQE-AN105320006-25
Page 10

II.B.3.c.1 Records of water application and chemical suppressant application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of chemical suppressants/water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature was below freezing. [R307-401-8] II.B.4 Emergency Engine Requirements
II.B.4.a The owner/operator shall install one (1) 99 kW generator engine certified to meet a CO emission rate of 5.0 g/kW-hr or less. [R307-401-8]
II.B.4.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the
manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8]

II.B.4.b The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.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.4.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.4.c The owner/operator shall not exceed the production limits:
A. 2,000-gallon diesel fuel storage tank - 120,000 gallons per rolling 12-month period

B. 500-gallon gasoline fuel storage tank - 7,000 gallons per rolling 12-month period

C. 1,000-gallon gasoline storage tank - 31,000 gallons per rolling 12-month period.

[R307-401-8]

II.B.4.c.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 fuel throughput in the three (3) fuel storage tanks shall be by examination of fuel distribution receipts for each tank. [R307-401-8]
DAQE-AN105320006-25
Page 11

II.B.4.d 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.4.d.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.4.d.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN105320005-23 dated May 18, 2023 Is Derived From NOI dated August 8, 2024

DAQE-AN105320006-25
Page 12

ACRONYMS

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

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

DAQE-

RN105320006
November 19, 2024

Suzy Smith
Western Metals Recycling
4201 West 700 South
Salt Lake City, UT 84104
[e-mail]

Dear Suzy Smith,

Re: Engineer Review - Administrative Amendment of Approval Order DAQE-
AN105320005-23 to Lower Tank Height Limits in the Scrubbing Water Storage Tank.
Project Number: N105320006

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 (NSR) permitting program. Western
Metals Recycling should complete this review within 10 business days of receipt.

Western Metals Recycling should contact Mr. Tim DeJulis at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email
Mr. Tim DeJulis at [e-mail] the signed cover letter. Upon receipt of the signed cover letter,
the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director.

If Western Metals Recycling does not respond to this letter within 10 business days, the project will
move forward without source concurrence. If Western Metals Recycling has concerns that cannot be
resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction.

Approval Signature _________________1/8/25____________________________________________
(Signature & Date)

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

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
DAQE-

RN105320006 November 19, 2024 Suzy Smith Western Metals Recycling 4201 West 700 South
Salt Lake City, UT 84104 [e-mail]
Dear Suzy Smith, Re: Engineer Review - Administrative Amendment of Approval Order DAQE-
AN105320005-24 to Lower Tank Height Limits in the Scrubbing Water Storage Tank. Project Number: N105320006 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 (NSR) permitting program. Western Metals Recycling should complete this review within 10 business days of receipt. Western Metals Recycling should contact Mr. Tim DeJulis at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Tim DeJulis at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director.
If Western Metals Recycling does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Western Metals Recycling has concerns that cannot be
resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.
Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N105320006: Western Metals Recycling- Metal Shredder Recovery November 19, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N105320006 Owner Name Western Metals Recycling Mailing Address 4201 West 700 South
Salt Lake City, UT, 84104 Source Name Western Metals Recycling- Metal Shredder Recovery
Source Location 4201 West 700 South Salt Lake City, UT 84104
UTM Projection 416,364 m Easting, 4,511,898 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 5093 (Scrap & Waste Materials) Source Contact Suzy Smith Phone Number [phone] Email [e-mail] Billing Contact Suzy Smith Phone Number [phone]
Email [e-mail] Project Engineer Mr. Tim DeJulis, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted August 8, 2024 Date of Accepted Application August 14, 2024

Engineer Review N105320006: Western Metals Recycling- Metal Shredder Recovery November 19, 2024 Page 2
SOURCE DESCRIPTION General Description
Western Metals Recycling, LLC (WMR) is a wholly-owned venture of Cincinnati-based, The David J. Joseph Company (DJJ). WMR conducts metal shredding in addition to cutting, hand torching; and sorting of ferrous and non-ferrous materials. Emissions from the Salt Lake City
facility will primarily consist of fugitive emissions of PM10, PM2.5, and VOCs from shredding operations. The facility operates an air sifting process to clean the materials of loose dirt and fibers. A cyclone/scrubber system is operated to control the emissions from the air sifting process. A foam injection system is utilized on the shredder and provides PM control. Storage tanks collect the gasoline fuel from the cars being shredded. NSR Classification: Administrative Amendment Source Classification Located in , Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County
SO2 NAA, Salt Lake County Airs Source Size: B
Applicable Federal Standards NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines 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 Project Proposal Administrative Amendment of Approval Order DAQE-AN105320005-24 to Lower Tank Height Limits in the Scrubbing Water Storage Tank. Project Description Western Metals Recycling, LLC (WMR) has requested an administrative amendment to DAQE-
AN105320005-23, dated May 18, 2023 for a new lower settling tank height requirement in the AO for the process. Currently in the AO the settling tank is limited by condition II.B.2.d "The settling tank volume shall not be less than 7,410 gallons for more than five minutes in any 60-
minute period." The total storage tank capacity of the storage tank is 7,410 gallons; therefore, the operation of the settling tank is functionally unworkable in practice as there isn't any room in storage tank height for more than 7,410 gallons. WMR has requested a change to condition
II.B.2.d to say "The settling tank volume shall not be less than 6,500 gallons for more than five minutes in any 60-minute period." No other changes to the operations or the emissions will take place.
EMISSION IMPACT ANALYSIS Emissions will remain unchanged as a result of the administrative amendment; therefore, modeling is not
required at this time. [Last updated August 9, 2024]

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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 0 321.00 Carbon Monoxide 0 0.11
Nitrogen Oxides 0 0.28
Particulate Matter - PM10 0 29.56
Particulate Matter - PM2.5 0 24.05
Volatile Organic Compounds 0 39.06
Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Benzene (Including Benzene From Gasoline) (CAS #71432) 0 616
Cumene (CAS #98828) 0 64
Ethyl Benzene (CAS #100414) 0 618
Generic HAPs (CAS #GHAPS) 0 80
Hexane (CAS #110543) 0 1192
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 193 Methyl Methacrylate (CAS #80626) 0 21 Methylene Chloride (Dichloromethane) (CAS #75092) 0 20
Naphthalene (CAS #91203) 0 51
Styrene (CAS #100425) 0 272
Toluene (CAS #108883) 0 2672
Trichloroethylene (CAS #79016) 0 21 Xylenes (Isomers And Mixture) (CAS #1330207) 0 2980 Change (TPY) Total (TPY)
Total HAPs 0 4.40

Note: Change in emissions indicates the difference between previous AO and proposed modification.
Review of BACT for New/Modified Emission Units 1. BACT review regarding Process Equipment
This is an administrative amendment; therefore, a BACT analysis is not required. [Last updated August 9, 2024]

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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]

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]

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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 Metal Shredder Recovery
II.A.2 One (1) Electric Shredder Control: Foam injection operation combined with two (2) cyclones and two (2) wet scrubbers in two (2) collection systems.
II.A.3 Shredded Materials Separation System Magnetic drum separator and air sifting/z-box
II.A.4 Welding and Torch Cutting Activities
II.A.5 Conveyors
II.A.6 One (1) Emergency Generator Engine Fuel: Diesel Rating: 99 kW (132 hp)
NSPS Subpart IIII MACT Subpart ZZZZ II.A.7 Various Fuel Storage Tanks One (1) Storage Tank Fuel: Diesel
Capacity: 2,000 gallons Two (2) Storage Tanks Fuel: Gasoline Capacity: 500 gallons and 1,000 gallons
MACT Subpart CCCCCC
II.A.8 Various Support Equipment Shears, chopper, balers, non-ferrous metal receiving, cranes, and front-end loaders. Listed for informational purposes only.

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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 process more than 320,000 tons of scrap metal through the shredding machine per rolling 12-month period. [R307-401-8]
II.B.1.a.1 The owner/operator shall:
A. Determine scrap metal processed with process scales and inventory records B. Record scrap metal processed on a monthly basis C. Use the scrap metal processed data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months
D. Keep the scrap metal processed records for all periods the plant is in operation. [R307-401-8]
II.B.1.b The owner/operator shall not operate:
A. The shredding device more than 13 hours per 24-hour period
B. Any operations not associated with the shredder before 6:00 am and after 7:00 pm
each day. [R307-401-8] II.B.1.b.1 The owner/operator shall keep and maintain the following records of operations for the shredding device and the operations not associated with the shredder at this facility:
A. Time the shredding operations begin each day B. Time operations not associated with the shredder begin each day C. Time the shredding operations end each day D. Time operations not associated with the shredder end each day. [R307-401-8] II.B.1.c The owner/operator shall control all emissions from the z-box and the shredding machine with the cyclone/scrubber. The owner/operator shall control the emissions from the z-box and
shredding machine with foam injection as needed to maintain the opacity limits in the permit. [R307-401-8]

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II.B.1.d The owner/operator shall not exceed visible emissions from the following emission points:
A. Each scrubber exhaust - 15% opacity
B. Electric shredding machine - 15% opacity C. Diesel engines - 20% opacity D. All other points - 20% opacity. [R307-305-3]
II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.e The owner/operator shall comply with R307-328-5 for the gasoline storage tanks. [R307-328-
5, R307-401-8] II.B.2 Stack Testing Requirements
II.B.2.a The owner/operator shall not emit more than the following rates and concentrations from VENTURI SCRUBBER STACKS: Pollutant lb/hr grains/dscf Filterable PM10 4.98 (each scrubber) 0.02 (each scrubber). [R307-401-8]

II.B.2.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8]
II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]
II.B.2.b.1 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]
II.B.2.b.2 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.2.b.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

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II.B.2.b.4 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8] II.B.2.b.5 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.2.b.6 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8] II.B.2.c Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved
test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
II.B.2.c.1 Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.2.c.2 Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. [R307-401-8]

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II.B.2.d NEW The owner/operator shall maintain the following operating parameters within the indicated ranges for each scrubber: A. The pressure drop shall not be less than 3.6 inches of water (minimum) for more than five minutes in any 60-minute period. B. The liquid flow rate shall not be less than 3,750 gallons/hour for more than five minutes in any 60-minute period.
C. The settling tank volume shall not be less than 6,500 gallons for more than five minutes in any 60-minute period.
Items A, B, and C of this section shall be monitored with equipment located such that an
inspector/operator can safely read the output anytime. The readings shall be accurate to within the following ranges: D. The manometer- plus or minus 5% E. The flow meters- plus or minus 5% Flow meters shall be calibrated against a primary standard at least once every year. The primary standard shall be established by the company and shall be submitted to the Director for approval.
The manometer shall be calibrated against a primary standard which will be a second manometer. The manometer shall be calibrated against the primary standard at least once a year. [R307-401-8] II.B.2.d.1 The owner/operator shall install, calibrate, maintain, and operate each monitoring device certified by the manufacturer. Calibration shall be on an annual basis according to the manufacturer's instructions. Daily records of reading shall be maintained. [R307-401-8] II.B.3 Fugitive Dust and Haul Road Requirements II.B.3.a An electronic FDCP can be completed through the Utah DEQ Fugitive Dust Plan Permit Application Website. If a written FDCP is completed, it shall be submitted to the Director, attention: Compliance Branch, for approval. The owner/operator shall comply with the FDCP for control of all fugitive dust sources associated with the metal shredding facility. [R307-309-6]

II.B.3.b The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas to exceed 20% opacity at any point in plant and 10% opacity at the property boundary. [R307-309-5]
II.B.3.b.1 Visible emission determinations shall use procedures similar to Method 9. The normal
requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2
the height of the vehicle. [R307-309-5]

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II.B.3.c The owner/operator shall use chemical suppressants as needed on all the unpaved haul roads and water on the paved haul roads on site to maintain opacity limits listed in this AO. If the temperature is below freezing or if the haul roads are covered with snow or ice, the
owner/operator may stop using water on the unpaved and paved haul roads. [R307-401-8] II.B.3.c.1 Records of water application and chemical suppressant application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of chemical suppressants/water applied C. Rainfall amount received, if any
D. Records of temperature, if the temperature was below freezing. [R307-401-8]

II.B.4 Emergency Engine Requirements
II.B.4.a NEW The owner/operator shall install one (1) 99 kW generator engines certified to meet a CO emission rate of 5.0 g/kW-hr or less. [R307-401-8] II.B.4.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of
the equipment. [R307-401-8] II.B.4.b The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.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.4.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.4.c NEW The owner/operator shall not exceed the production limits: A. 2,000-gallon diesel fuel storage tank - 120,000 gallons per rolling 12-month period. B. 500-gallon gasoline fuel storage tank - 7,000 gallons per rolling 12-month period. C. 1,000-gallon gasoline storage tank - 31,000 gallons per rolling 12-month period. [R307-401-8]

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II.B.4.c.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 fuel throughput in the three (3) fuel storage tanks shall be by
examination of fuel distribution receipts for each tank. [R307-401-8] II.B.4.d 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.4.d.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.4.d.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]

PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN105320005-23 dated May 18, 2023
Is Derived From NOI dated August 8, 2024
REVIEWER COMMENTS

1. Comment regarding Emissions Estimates: Emission Estimates The following emission estimates are calculated as follows:
The emissions from the shredding (fugitive) machine is by the General Iron of Chicago emission
factors. The emissions from the material screening and handling (fugitive) is by AP-42, Section 11.19.2. The emissions from the material drop points (fugitive) is by AP-42, Section 13.2.4.
The emissions from the torch cutting (fugitive) is by AP-42, Section 12.5.1.4 and the Institute of Scrap Metal Recycling Industries. The emissions from the welding (fugitive) is by AP-42, Section 12.19.
The emissions from the stockpiles (fugitive) is by AP-42, Section 8.19. The emissions from the haul roads (fugitive) is by AP-42, Section 13.2.2. The emissions from the emergency generator engine (non-fugitive) is by the manufacturer for PM10/PM2.5, NOx, CO, and VOC; and the SO2 by AP-42 Section 3.4. CO2e by AP-42 Tables 1.3-3, 1.3-8, 1.3-12, and 40 CFR Part 98, Subpart A, Table A-1 and Subpart C, Table C-1. The diesel and gasoline storage tanks are by AP-42 Chapter 7. [Last updated September 26, 2024]

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2. Comment regarding NSPS and MACT Standards`: NSPS & MACT
40 CFR 60 (NSPS) 40 CFR 60 Subpart IIII applies to owner and operators of CI ICE with a displacement of less than 30 liters per cylinder where the model is 2007 and beyond, or has been reconstructed, modified after 07/11/2005. NSPS Subpart IIII will apply to this plant. 40 CFR 63 (MACT) 40 CFR 63 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 plant. A new or reconstructed stationary RICE located at an area source must meet the requirements of MACT Subpart ZZZZ by meeting the requirements of 40 CFR 60 NSPS Subpart IIII. No further requirements apply for such engines under
MACT Subpart ZZZZ. 40 CFR 63 Subpart CCCCCC applies to owner/operator of gasoline storage tanks. The gasoline storage tank capacities are 500-gallons and 1,000-gallons. The throughput of gasoline in both tanks combined is less than 10,000-gallons per month. MACT Subpart CCCCCC applies to the SLC plant. The owner/operator shall comply with the Emission Limitations and Management Practices in 40 CFR 63.11115 and 40 CFR 63.11116.. [Last updated August 9, 2024] 3. Comment regarding Title V Requirements: 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 major source and is not a Title IV source. The facility is subject to 40 CFR 60 (NSPS) Subpart A and Subpart IIII and 40 CFR 63 (MACT) Subpart A and Subpart ZZZZ regulations. The facility is not subject to 40 CFR 61 (NESHAP). However, Title V does not apply because NSPS Subpart IIII and MACT Subpart ZZZZ and Subpart CCCCCC exempt sources from
the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. There are no other reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not apply to this facility as per R307-415-4(2)(c). [Last updated August 9, 2024] 4. Comment regarding Changes to the Height Limits in Requirement II.B.2.d: WMR has requested a change to requirement II.B.2.d, item C. Currently the settling tank requirement is 7,410 gallons. This is the limit of the height of the tank; therefore, the limit is
unworkable in practice because it is impossible to go above this. The new limit for this settling tank is 6,500 gallons. [Last updated November 6, 2024]

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

ADMINISTRATIVE AMENDMENT REQUEST
4525 Wasatch Blvd, Ste 200, Salt Lake City, UT 84124 P 801.272.3000 / F 801.272.3040

To: Tim DeJulis, Utah Division of Air Quality
cc: Suzy Smith, Western Metals Recycling
Alan Humphreys, Utah Division of Air Quality
Irene Tucker, Utah Division of Air Quality
Chad Gilgen, Utah Division of Air Quality
From: Johnathan Price, Trinity Consultants
Date: August 8, 2024
RE: Western Metals Recycling, Salt Lake City, UT - Administrative Amendment Request to Settling Tank Volume in Approval Order DAQE-AN105320005-23

Dear Tim DeJulis,

Western Metals Recycling (WMR) recently received a compliance advisory following a site visit conducted by
the Utah Division of Air Quality (UDAQ) on February 14, 2024. In the compliance advisory, UDAQ stated that
WMR may be in violation of condition II.B.2.d-C under Approval Order (AO) DAQE- AN105320005-23.

Condition II.B.2.d-C pertains to a settling tank that catches water as it exits from the scrubbers on the
shredder. Particulate matter (PM) from the shredder that is controlled by the scrubbers enters the settling
tank in the expelled water. The PM settles to the bottom of the settling tank and is removed by a drag
chain.

The settling tank’s operation predates WMR’s procurement of the WSL Facility, having been installed by
Atlas Steel prior to WMR’s formation in 1996. WMR’s earliest-recorded AO for the WSL Facility was issued by
the Utah Division of Air Quality (UDAQ) on September 4, 1998. Based on historic AO records, under II.B.2.d-
C the settling tank has been addressed so that it requires the following:

“The settling tank volume shall not be less than 7,410 gallons for more than five minutes in any 60-minute
period.”

WMR’s understanding is and has always been that the listed volume of 7,410 gallons is the operating
volume of the tank. At Irene’s request, WMR made an inquiry with the settling tank’s manufacturer to obtain
the settling tank’s total volume, which was done on October 6, 2022. The manufacturer informed WMR that
the actual total volume of the settling tank is 7,410 gallons and that the operating volume is 6,500 gallons.

The manufacturer informed WMR that 12 to 18 inches of freeboard above the water level is required for
correct settling tank operation. Additionally, sufficient freeboard is required to maintain the structural and
operational integrity of the settling tank, as well as to maintain safe operating conditions. With this new
information, it has now come to WMR’s attention that sufficient freeboard was apparently not accounted for
in the calculations done for the 1998 AO, but rather, the total volume of the settling tank was incorrectly
listed as the operating volume. Had the calculations been done correctly by accounting for a safe amount of
freeboard, the condition would have listed the total volume of the tank as 7,410 gallons and the operating
volume as 6,500 gallons.

WMR WSL Facility
August 8, 2024 Administrative Amendment to AO DAQE-AN105320005-23 Page 2 of 2

4525 Wasatch Blvd, Ste 200, Salt Lake City, UT 84124 P 801.272.3000 / F 801.272.3040
WMR operates the settling tank in such a manner so as to maintain proper scrubber operation that
facilitates sufficient air pollution control. This can be shown by reviewing the WSL Facility’s records of the
scrubbers’ flow rates and pressure drops. These records show that the scrubbers operated in accordance
with the listed flow rate and pressure drop parameters given as conditional limits in the AO. It has always
been WMR’s intent to comply with the WSL Facility’s AO, and they have operated under the assumption that
they have been doing so since the AO was issued in 1998.

A monitoring device is installed to ensure that the operating level of the settling tank is at the level
previously believed to be 7,410 gallons, i.e., the level necessary for correct plant operation. The monitoring
device has both audio and visual alarms that alert operators when the water level falls below the necessary
operating volume. Supplemental water is available near the settling tank to immediately bring the operating
volume back to its required level.

Given the information provided, WMR requests the following changes to II.B.2.d-C of its AO (additions
requested are highlighted in red italics and proposed removals are presented in red strikethrough):

► Condition II.B.2.d-C: The settling tank volume shall not be less than 6500 gallons 7,410 gallons for more
than five minutes in any 60-minute period

WMR is only requesting modification to the above condition and no other changes to their AO. If you have
further questions about the administrative amendment, please reach out to me at
[e-mail].

Sincerely,

Johnathan Price
Trinity Consultants