DAQ-2024-011071

DAQE-AN104850001-24

{{$d1 }}

Sarah Smart
E.T. Technologies Incorporated
6030 West California Avenue
Salt Lake City, UT 84104
[e-mail]

Dear Ms. Smart:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-764-95 for a 10-Year
Review and Permit Updates
Project Number: N104850001

The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a
10-year administrative review of this source and its respective AO. E.T. Technologies Incorporated
must comply with the requirements of this AO, all applicable state requirements (R307), and Federal
Standards.

The project engineer for this action is Dungan Adams, 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:DA:jg

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

September 10, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
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APPROVAL ORDER
DAQE-AN104850001-24
Administrative Amendment to Approval Order DAQE-764-95 for a
10-Year Review and Permit Updates

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
E.T. Technologies Incorporated - Soils Regeneration Site

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

September 10, 2024
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.................................................................................................................. 3
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 5
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 8

DAQE-AN104850001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
E.T. Technologies Incorporated E.T. Technologies Incorporated - Soils Regeneration Site

Mailing Address Physical Address
6030 West California Avenue 6400 West 1300 South
Salt Lake City, UT 84104 Salt Lake City, UT 84104

Source Contact UTM Coordinates
Name: Sarah Smart 411,301 m Easting
Phone: [phone],510,550 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 4953 (Refuse Systems)

SOURCE INFORMATION
General Description
E.T. Technologies Incorporated (E.T. Technologies) operates a soil regeneration site for the Salt Lake
Valley Landfill in Salt Lake County. The facility combines select liquid, semi-solid, and solid waste with
native soil to reduce contaminants over time. Waste streams processed at the facility include industrial
wastes, petroleum wastes, wastewater solids, and contaminated soil. The soil at the facility is kept at a
high moisture content and aerated periodically. Once the treatment procedure is complete, the regenerated
soil mixture is used at the Salt Lake Valley Landfill.

NSR Classification
10-Year Review

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
None
Project Description
This is a 10-Year Review for E.T. Technologies' soil regeneration site to update permit conditions,
format, and rule applicability.
DAQE-AN104850001-24
Page 4

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 27000.00
Carbon Monoxide 1.50
Nitrogen Oxides 3.80
Particulate Matter - PM10 2.30
Particulate Matter - PM2.5 2.30
Sulfur Dioxide 0.30
Volatile Organic Compounds 40.00

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 200
Change (TPY) Total (TPY)
Total HAPs 0.10

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]
DAQE-AN104850001-24
Page 5

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Soil Regeneration Site
II.A.2 Soil Processing Cells
Total Size: 60 acres

II.A.3 Various Mobile Equipment Includes: haul trucks, water trucks, loaders, and track mounted mobile equipment.

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-wide Requirements II.B.1.a The owner/operator shall post a copy of the AO on site. [R307-401-8]
II.B.1.b The owner/operator shall notify the director in writing if the company is sold or changes its name. The owner/operator shall submit notification within 30 days of such action. [R307-401-8] II.B.1.c The owner/operator shall not process more than 40,000 tons of hydrocarbon contaminated soil per rolling 12-month period. The average hydrocarbon-contamination of the soil shall not exceed 3,000 mg/kg. [R307-401-8]
II.B.1.c.1 The owner/operator shall: A. Determine the quantity of processed soil from daily receiving records. B. Record the quantity of processed soil on a daily basis. C. Use the processed soil data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep records of processed soil for all periods the facility is in operation. [R307-401-8] II.B.1.d The owner/operator shall not operate the facility more than the following amounts: A. Eleven (11) hours per day. B. 310 days per year. [R307-401-8]
DAQE-AN104850001-24
Page 6

II.B.1.d.1 The owner/operator shall: A. Determine hours of operation by supervisor monitoring and maintaining of an operations log. B. Record hours of operation daily. C. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]
II.B.1.e Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20% opacity. [R307-305-3]
II.B.1.e.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3]
II.B.2 Haul Roads and Fugitive Dust Requirements
II.B.2.a The owner/operator shall comply with all applicable fugitive dust requirements in R307-309. [R307-309]
II.B.2.b The owner/operator shall not allow visible emissions from the following fugitive dust sources on
site to exceed the following values.
A. Storage piles - 10% opacity.
B. Haul roads - 20% opacity.

C. Property boundary - 10% opacity.
D. All other points - 20% opacity.
[R307-309-5, R307-401-8]

II.B.2.b.1 Opacity observations of fugitive dust from intermittent sources shall be conducted according to 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. The number of observations and the time period shall be determined by the length of the intermittent source. For fugitive dust generated by mobile sources, visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-309-5] II.B.2.c The owner/operator shall not exceed an unpaved haul road length of 3,110 feet (0.57 miles). The
owner/operator shall not exceed a vehicle speed of 5 miles per hour on unpaved haul roads.
[R307-401-8]

II.B.2.d The owner/operator shall apply water or chemical suppressant to all unpaved haul roads and other unpaved operational areas, other than the soil processing cells. The owner/operator shall apply water and chemical suppressant to prevent visible emissions from exceeding the opacity limits listed in this AO. The owner/operator may stop applying water when the temperature is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. [R307-205, R307-401-8]
DAQE-AN104850001-24
Page 7

II.B.2.d.1 The owner/operator shall keep records of water application on unpaved haul roads and unpaved operational areas for all periods when the plant is in operation. The records shall include the following items: A. Date and time of treatments. B. Number of treatments made and quantity of water applied. C. Rainfall amount received, if any. [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-764-95 dated August 29, 1995 Incorporates Additional Information dated July 22, 2024

DAQE-AN104850001-24
Page 8

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-

RN104850001 August 30, 2024 Sarah Smart
E.T. Technologies Incorporated 6030 West California Ave. Salt Lake City, UT 84104
[e-mail] Dear Sarah Smart,
Re: Engineer Review - 10-Year Review and Permit Updates: Administrative Amendment to Approval Order DAQE-764-95 for a 10-Year Review and Permit Updates Project Number: N104850001 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. E.T. Technologies Incorporated should complete this review within 10 business days of receipt. E.T. Technologies Incorporated should contact Dungan Adams at [phone] if there are questions
or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dungan Adams 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 E.T. Technologies Incorporated does not respond to this letter within 10 business days, the project will move forward without source concurrence. If E.T. Technologies Incorporated has concerns that cannot
be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.
Approval Signature
9/9/2024_____________________________________________________________
(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 N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N104850001 Owner Name E.T. Technologies Incorporated Mailing Address 6030 West California Ave.
Salt Lake City, UT, 84104 Source Name E.T. Technologies Incorporated- Soils Regeneration Site
Source Location 6400 West 1300 South Salt Lake City, UT 84104
UTM Projection 411,301 m Easting, 4,510,550 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4953 (Refuse Systems) Source Contact Sarah Smart Phone Number [phone] Email [e-mail] Billing Contact Sarah Smart Phone Number [phone]
Email [e-mail] Project Engineer Dungan Adams, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 19, 2024 Date of Accepted Application July 30, 2024

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 2
SOURCE DESCRIPTION General Description
E.T. Technologies Incorporated (E.T. Technologies) operates a soil regeneration site for the Salt Lake Valley Landfill in Salt Lake County. The facility combines select liquid, semi-solid, and solid waste with native soil to reduce contaminants over time. Waste streams processed at the
facility include industrial wastes, petroleum wastes, wastewater solids, and contaminated soil. The soil at the facility is kept at a high moisture content and aerated periodically. Once the treatment procedure is complete, the regenerated soil mixture is used at the Salt Lake Valley Landfill. NSR Classification: 10 Year Review 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 None
Project Proposal Administrative Amendment to Approval Order DAQE-764-95 for a 10-Year Review and Permit Updates Project Description 10-Year Review for E.T. Technologies' soil regeneration site to update permit conditions, format,
and rule applicability. EMISSION IMPACT ANALYSIS
This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore, modeling is not required. [Last updated July 23, 2024]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 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 27000.00 Carbon Monoxide 1.50
Nitrogen Oxides 3.80
Particulate Matter - PM10 2.30
Particulate Matter - PM2.5 2.30
Sulfur Dioxide 0.30
Volatile Organic Compounds 40.00 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 200
Change (TPY) Total (TPY)
Total HAPs 0.10

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

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding Soil Regeneration Site
This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore, a BACT analysis is not required. [Last updated August 5, 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] 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]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 5
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 NEW Soil Regeneration Site
II.A.2 NEW Soil Processing Cells Total Size: 60 acres
II.A.3
NEW
Various Mobile Equipment
Includes: Haul trucks, water trucks, loaders, and track mounted mobile equipment
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 NEW Site-wide Requirements
II.B.1.a
NEW
The owner/operator shall post a copy of the AO on site. [R307-401-8]

II.B.1.b NEW The owner/operator shall notify the director in writing if the company is sold or changes its name. The owner/operator shall submit notification within 30 days of such action. [R307-401-8]
II.B.1.c NEW The owner/operator shall not process more than 40,000 tons of hydrocarbon contaminated soil per rolling 12-month period. The average hydrocarbon contamination of the soil shall not exceed 3,000 mg/kg. [R307-401-8]
II.B.1.c.1
NEW
The owner/operator shall:
A. Determine the quantity of processed soil from daily receiving records. B. Record the quantity of processed soil on a daily basis. C. Use the processed soil data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months. D. Keep records of processed soil for all periods the facility is in operation. [R307-401-8]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 6
II.B.1.d NEW The owner/operator shall not operate the facility more than the following amounts:
A. 11 hours per day.
B. 310 days per year. [R307-401-8]
II.B.1.d.1 NEW The owner/operator shall:
A. Determine hours of operation by supervisor monitoring and maintaining of an
operations log. B. Record hours of operation daily.
C. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]

II.B.1.e NEW Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20% opacity. [R307-305-3] II.B.1.e.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3]
II.B.2 NEW Haul Roads and Fugitive Dust Requirements
II.B.2.a NEW The owner/operator shall comply with all applicable fugitive dust requirements in R307-309. [R307-309]
II.B.2.b NEW The owner/operator shall not allow visible emissions from the following fugitive dust sources on site to exceed the following values. A. Storage piles - 10% opacity
B. Haul roads - 20% opacity
C. Property boundary - 10% opacity
D. All other points - 20% opacity. [R307-309-5, R307-401-8]
II.B.2.b.1
NEW
Opacity observations of fugitive dust from intermittent sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. The number of observations and the time period shall be determined by the length of the intermittent source. For fugitive dust generated by mobile sources, visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-309-5]
II.B.2.c NEW The owner/operator shall not exceed an unpaved haul road length of 3,110 feet (0.57 miles). The owner/operator shall not exceed a vehicle speed 5 miles per hour on unpaved haul roads. [R307-401-8]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 7
II.B.2.d NEW The owner/operator shall apply water or chemical suppressant to all unpaved haul roads and other unpaved operational areas, other than the soil processing cells. The owner/operator shall apply water and chemical suppressant to prevent visible emissions from exceeding the opacity
limits listed in this AO. The owner/operator may stop applying water when the temperature is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. [R307-205, R307-401-8]

II.B.2.d.1 NEW The owner/operator shall keep records of water application on unpaved haul roads and unpaved operational areas for all periods when the plant is in operation. The records shall include the following items: A. Date and time of treatments. B. Number of treatments made and quantity of water applied. C. Rainfall amount received, if any. [R307-401-8]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 8
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-764-95 dated August 29, 1995
Is Derived From NOI dated June 19, 2024 Incorporates Additional Information dated July 22, 2024
REVIEWER COMMENTS 1. Comment regarding Emission Estimates for PM2.5 and CO2e: Emission estimates for PM2.5 and CO2e were not included in Approval Order (AO) DAQE-764-95 dated August 29, 1995. PM2.5 is conservatively estimated to be equal to PM10. Soil regeneration emission rates for CO2e are not found in AP-42 and are not easily determined without sampling pollution concentrations of the regenerated soil. In order to collect accurate pollution concentrations, various testing would be required from the source. Because this is a 10-year review, initiated by the Utah Division of Air Quality (DAQ), the source is not required to conduct this testing. To provide an estimate of CO2e emissions from this soil regeneration site, the DAQ has used emission levels from "A Review of Life Cycle Greenhouse Gas (GHG) Emissions of
Commonly Used Ex-situ Soil Treatment Technologies" (Amponsah, Wang, Zhao, 2018). The journal article discusses various soil remediation technologies. Of the discussed technologies, bioremediation most closely describes the process at the facility. Of the twelve bioremediation sites evaluated, the average normalized GHG emitted was 0.22 tons of CO2e per cubic meter for the life cycle of the project. E.T Technologies operates on a 60 acres tract of land which is equivalent to 242,800 square meters. For the purpose of estimation, it is conservatively assumed that half of the tract is actively used for remediation at any given time. It is also assumed the remediated soil extends 1 meter into the ground for the entire land tract. Using the volume of 121,400 cubic meters of remediated soil and the average emission level of 0.22 tons of CO2e per cubic meter, the 60 acres tract would emit roughly
27,000 tons of CO2e per lifecycle. The lifecycle of different bioremediation projects varies, some projects taking months and others taking several years. A 1-year lifecycle is used for this estimation. The Summary of Emissions has been updated to include 2.3 TPY of PM2.5 and 27,000 TPY of CO2e. [Last updated August 5, 2024]
2. Comment regarding Fuel Requirements in DAQE-764-95: DAQE-764-95 contained a condition limiting the sulfur content of any fuel oil burned to 0.5% by weight or 5000 ppm. DAQE-764-95 did not list any stationary combustion equipment and the source still does not use any stationary combustion equipment on site; therefore, it is assumed that this condition was included for mobile equipment. Mobile sources of air pollution are not permitted by the Utah Division of Air Quality (DAQ) and fall under EPA jurisdiction. Because the condition included in DAQE-764-95 does not relate to a stationary source, it has been removed during the 10-year review permit update. Diesel fuel regulations for mobile sources are outlined in 40 CFR 80. [Last updated August 22, 2024]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 9
3. Comment regarding Federal Subpart Applicability: NSPS
40 CFR 60 Subpart WWW (Standards of Performance for Municipal Solid Waste Landfills That Commenced Construction, Reconstruction, or Modification on or After May 30, 1991, but Before July 18, 2014) applies to municipal solid waste landfills that commenced construction, reconstruction, or modification on or after May 30, 1991, but before July 18, 2014. According to the subpart, this facility does not meet the definition of landfill because it is a land application unit. Therefore, Subpart WWW does not apply to the source. [Last updated August 22, 2024] 4. 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 source is not a major source, is not a Title IV source, is not subject to 40 CFR 60, 40 CFR 61, or 40 CFR 63 requirements. Therefore, Title V does not apply to the source. [Last updated August 22, 2024]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 10
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
DAQE-

RN104850001 August 30, 2024 Sarah Smart
E.T. Technologies Incorporated 6030 West California Ave. Salt Lake City, UT 84104
[e-mail] Dear Sarah Smart,
Re: Engineer Review - 10-Year Review and Permit Updates: Administrative Amendment to Approval Order DAQE-764-95 for a 10-Year Review and Permit Updates Project Number: N104850001 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. E.T. Technologies Incorporated should complete this review within 10 business days of receipt. E.T. Technologies Incorporated should contact Dungan Adams at [phone] if there are questions
or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dungan Adams 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 E.T. Technologies Incorporated does not respond to this letter within 10 business days, the project will move forward without source concurrence. If E.T. Technologies Incorporated 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 N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N104850001 Owner Name E.T. Technologies Incorporated Mailing Address 6030 West California Ave.
Salt Lake City, UT, 84104 Source Name E.T. Technologies Incorporated- Soils Regeneration Site
Source Location 6400 West 1300 South Salt Lake City, UT 84104
UTM Projection 411,301 m Easting, 4,510,550 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4953 (Refuse Systems) Source Contact Sarah Smart Phone Number [phone] Email [e-mail] Billing Contact Sarah Smart Phone Number [phone]
Email [e-mail] Project Engineer Dungan Adams, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 19, 2024 Date of Accepted Application July 30, 2024

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 2
SOURCE DESCRIPTION General Description
E.T. Technologies Incorporated (E.T. Technologies) operates a soil regeneration site for the Salt Lake Valley Landfill in Salt Lake County. The facility combines select liquid, semi-solid, and solid waste with native soil to reduce contaminants over time. Waste streams processed at the
facility include industrial wastes, petroleum wastes, wastewater solids, and contaminated soil. The soil at the facility is kept at a high moisture content and aerated periodically. Once the treatment procedure is complete, the regenerated soil mixture is used at the Salt Lake Valley Landfill. NSR Classification: 10 Year Review 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 None
Project Proposal Administrative Amendment to Approval Order DAQE-764-95 for a 10-Year Review and Permit Updates Project Description 10-Year Review for E.T. Technologies' soil regeneration site to update permit conditions, format,
and rule applicability. EMISSION IMPACT ANALYSIS
This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore, modeling is not required. [Last updated July 23, 2024]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 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 27000.00 Carbon Monoxide 1.50
Nitrogen Oxides 3.80
Particulate Matter - PM10 2.30
Particulate Matter - PM2.5 2.30
Sulfur Dioxide 0.30
Volatile Organic Compounds 40.00 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 200
Change (TPY) Total (TPY)
Total HAPs 0.10

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

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding Soil Regeneration Site
This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore, a BACT analysis is not required. [Last updated August 5, 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] 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]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 5
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 NEW Soil Regeneration Site
II.A.2 NEW Soil Processing Cells Total Size: 60 acres
II.A.3
NEW
Various Mobile Equipment
Includes: Haul trucks, water trucks, loaders, and track mounted mobile equipment
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 NEW Site-wide Requirements
II.B.1.a
NEW
The owner/operator shall post a copy of the AO on site. [R307-401-8]

II.B.1.b NEW The owner/operator shall notify the director in writing if the company is sold or changes its name. The owner/operator shall submit notification within 30 days of such action. [R307-401-8]
II.B.1.c NEW The owner/operator shall not process more than 40,000 tons of hydrocarbon contaminated soil per rolling 12-month period. The average hydrocarbon contamination of the soil shall not exceed 3,000 mg/kg. [R307-401-8]
II.B.1.c.1
NEW
The owner/operator shall:
A. Determine the quantity of processed soil from daily receiving records. B. Record the quantity of processed soil on a daily basis. C. Use the processed soil data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months. D. Keep records of processed soil for all periods the facility is in operation. [R307-401-8]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 6
II.B.1.d NEW The owner/operator shall not operate the facility more than the following amounts:
A. 11 hours per day.
B. 310 days per year. [R307-401-8]
II.B.1.d.1 NEW The owner/operator shall:
A. Determine hours of operation by supervisor monitoring and maintaining of an
operations log. B. Record hours of operation daily.
C. Keep hours of operation records for all periods the plant is in operation. [R307-401-8]

II.B.1.e NEW Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 20% opacity. [R307-305-3] II.B.1.e.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-305-3]
II.B.2 NEW Haul Roads and Fugitive Dust Requirements
II.B.2.a NEW The owner/operator shall comply with all applicable fugitive dust requirements in R307-309. [R307-309]
II.B.2.b NEW The owner/operator shall not allow visible emissions from the following fugitive dust sources on site to exceed the following values. A. Storage piles - 10% opacity
B. Haul roads - 20% opacity
C. Property boundary - 10% opacity
D. All other points - 20% opacity. [R307-309-5, R307-401-8]
II.B.2.b.1
NEW
Opacity observations of fugitive dust from intermittent sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. The number of observations and the time period shall be determined by the length of the intermittent source. For fugitive dust generated by mobile sources, visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-309-5]
II.B.2.c NEW The owner/operator shall not exceed an unpaved haul road length of 3,110 feet (0.57 miles). The owner/operator shall not exceed a vehicle speed 5 miles per hour on unpaved haul roads. [R307-401-8]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 7
II.B.2.d NEW The owner/operator shall apply water or chemical suppressant to all unpaved haul roads and other unpaved operational areas, other than the soil processing cells. The owner/operator shall apply water and chemical suppressant to prevent visible emissions from exceeding the opacity
limits listed in this AO. The owner/operator may stop applying water when the temperature is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. [R307-205, R307-401-8]

II.B.2.d.1 NEW The owner/operator shall keep records of water application on unpaved haul roads and unpaved operational areas for all periods when the plant is in operation. The records shall include the following items: A. Date and time of treatments. B. Number of treatments made and quantity of water applied. C. Rainfall amount received, if any. [R307-401-8]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 8
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-764-95 dated August 29, 1995
Is Derived From NOI dated June 19, 2024 Incorporates Additional Information dated July 22, 2024
REVIEWER COMMENTS 1. Comment regarding Emission Estimates for PM2.5 and CO2e: Emission estimates for PM2.5 and CO2e were not included in Approval Order (AO) DAQE-764-95 dated August 29, 1995. PM2.5 is conservatively estimated to be equal to PM10. Soil regeneration emission rates for CO2e are not found in AP-42 and are not easily determined without sampling pollution concentrations of the regenerated soil. In order to collect accurate pollution concentrations, various testing would be required from the source. Because this is a 10-year review, initiated by the Utah Division of Air Quality (DAQ), the source is not required to conduct this testing. To provide an estimate of CO2e emissions from this soil regeneration site, the DAQ has used emission levels from "A Review of Life Cycle Greenhouse Gas (GHG) Emissions of
Commonly Used Ex-situ Soil Treatment Technologies" (Amponsah, Wang, Zhao, 2018). The journal article discusses various soil remediation technologies. Of the discussed technologies, bioremediation most closely describes the process at the facility. Of the twelve bioremediation sites evaluated, the average normalized GHG emitted was 0.22 tons of CO2e per cubic meter for the life cycle of the project. E.T Technologies operates on a 60 acres tract of land which is equivalent to 242,800 square meters. For the purpose of estimation, it is conservatively assumed that half of the tract is actively used for remediation at any given time. It is also assumed the remediated soil extends 1 meter into the ground for the entire land tract. Using the volume of 121,400 cubic meters of remediated soil and the average emission level of 0.22 tons of CO2e per cubic meter, the 60 acres tract would emit roughly
27,000 tons of CO2e per lifecycle. The lifecycle of different bioremediation projects varies, some projects taking months and others taking several years. A 1-year lifecycle is used for this estimation. The Summary of Emissions has been updated to include 2.3 TPY of PM2.5 and 27,000 TPY of CO2e. [Last updated August 5, 2024]
2. Comment regarding Fuel Requirements in DAQE-764-95: DAQE-764-95 contained a condition limiting the sulfur content of any fuel oil burned to 0.5% by weight or 5000 ppm. DAQE-764-95 did not list any stationary combustion equipment and the source still does not use any stationary combustion equipment on site; therefore, it is assumed that this condition was included for mobile equipment. Mobile sources of air pollution are not permitted by the Utah Division of Air Quality (DAQ) and fall under EPA jurisdiction. Because the condition included in DAQE-764-95 does not relate to a stationary source, it has been removed during the 10-year review permit update. Diesel fuel regulations for mobile sources are outlined in 40 CFR 80. [Last updated August 22, 2024]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 9
3. Comment regarding Federal Subpart Applicability: NSPS
40 CFR 60 Subpart WWW (Standards of Performance for Municipal Solid Waste Landfills That Commenced Construction, Reconstruction, or Modification on or After May 30, 1991, but Before July 18, 2014) applies to municipal solid waste landfills that commenced construction, reconstruction, or modification on or after May 30, 1991, but before July 18, 2014. According to the subpart, this facility does not meet the definition of landfill because it is a land application unit. Therefore, Subpart WWW does not apply to the source. [Last updated August 22, 2024] 4. 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 source is not a major source, is not a Title IV source, is not subject to 40 CFR 60, 40 CFR 61, or 40 CFR 63 requirements. Therefore, Title V does not apply to the source. [Last updated August 22, 2024]

Engineer Review N104850001: E.T. Technologies Incorporated- Soils Regeneration Site August 30, 2024 Page 10
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
DAQC-1570-21
Site ID 10485 (B1)
MEMORANDUM
TO: FILE — E.T. TECHNOLOGIES, INC.
fi3THROUGH: Rik Ombach, Minor Source Compliance Section Manager
FROM: Jared James, Environmental Scientist az
JJ
DATE: December 13, 2021
SUBJECT: Full Compliance Evaluation (FCE), minor, Salt Lake County
INSPECTION DATE: November 22, 2021
SOURCE LOCATION: 6030 West California Avenue
Salt Lake City, UT 84104
The office is in a trailer directly west of the Salt Lake County
Landfill offices. The soil remediation activities are conducted
.5 mile west of the office.
SOURCE CONTACT: Ted H. Sonnenburg — Vice President
Office — 801-973-2065
[e-mail]
OPERATING STATUS: Operating normally at the time of inspection.
PROCE
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E.T. Technologies, Inc. has been permitted by, and contracted
with, the Salt Lake County Health Department, to operate a soil
regeneration site for the County owned Salt Lake Valley
Landfill. This is a non-hazardous hydrocarbon contaminated soil
processing and treatment facility only accepting materials that
are not acutely plant toxic (such as pesticides). Liquid, semi-
solid, and solid wastes are selectively blended with indigenous
soils. Waste streams processed at the facility include; petroleum
refining tank bottoms and sludge, wastewater treatment sludge,
wastes from industrial sand and grease traps, and soil from
leaking underground petroleum storage tank sites. The various
wastes are transported to the Salt Lake Valley Landfill and
weighed. Trucks then move the waste about 1 mile to the soil
regeneration site where it is unloaded into the appropriate cell.
The storage area is divided up into ten cells, each of which may
be at various stages of biodegradation when in use. The native
soil is mixed with a combination of sewage sludge, and non-
hazardous hydrocarbon contaminated soil. The cells are kept at
a high moisture content (30% to 50% moisture) to promote
bioremediation of the hydrocarbon contaminants. The high
moisture content and the bioremediation reduce the volatile
organic compounds and PM10 emissions. The soil, in the cells, is
1
l
turned over periodically with a backhoe to increase the oxygen
content in the soil. Once the processing and treatment procedure
is complete, the regenerated soil mixture is used as daily cover,
road base, or fmal cover material at the Salt Lake Valley
Landfill.
APPLICABLE REGULATIONS: Approval Order DAQE-764-95, dated August 29, 1995.
SOURCE EVALUATION:
1. This AO applies to the following company:
E. T. Technologies, Inc.
6030 West 1300 South
Salt Lake City, Utah 84104
Phone: [phone]
Fax: [phone]
The equipment listed in Condition #5 of this AO shall be operated at the following
location:
PLANT LOCATION:
6400 West 1300 South
Salt Lake County
UTM: 4,510,200 m Northing; 411,800 m Easting
Status: In compliance. The source has not changed location but the address is now known as 6030
West California Avenue.
2. E.T. Technologies, Inc. shall install and operate the soil regeneration site facility according to this
AO as requested in the information submitted in the Notice of Intent dated May 10, 1990, and
additional information submitted to the Executive Secretary dated April 16, 1992, June 18, 1992
and March 27, 1995.
Status: In compliance. The source is familiar with the requirements of this condition and
confirmed they operate accordingly.
3. A copy of this AO shall be posted on site. The AO shall be available to the employees who
operate the air emission producing equipment. These employees shall receive instruction as to
their responsibilities in operating the equipment in compliance with all of the relevant conditions
listed below.
Status: In compliance. The source is familiar with the requirements of this condition and
confirmed they operate accordingly.
4. This AO shall replace the AO dated November 9, 1992 (DAQE-1062-92).
Status: In compliance. This AO was used to determine compliance.
5. The approved installations shall consist of the f llowing equipment:
2
1. 60 acre tract of land divided into cells to use for processing contaminated soils to
create soil that will support plant growth
2. Associated equipment used to operate the facility
3. Number of haul trucks on site will vary
Status: In compliance as follows:
1. The land tract is now nine cells across 40 acres. Salt Lake City has taken 20
acres as part of a landfill expansion.
2. Equipment observed at the source was front-end loaders, dozers, and a
water truck.
3. Not a compliance issue.
6. The Executive Secretary shall be notified in writing if the company is sold or changes its name.
The notification shall be submitted within 30 days of such action.
Status: Not applicable. The source has not changed their name.
7. Visible emissions from the following emission points shall not exceed the following values:
1. Storage piles - 10% opacity
2. All other points - 20% opacity
Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9.
Visible emissions from haul road traffic shall not exceed 20% opacity. Visible emissions
determinations for traffic sources shall use procedures similar to Method 9, but the requirement
for observations to be made at 15-second intervals over a six-minute period shall not apply. Six
points, distributed along the length of the haul road, shall be chosen by the Executive Secretary or
his representative. An opacity reading shall be made at each point when a vehicle passes the
selected points. Opacity readings shall be made 1/2 vehicle length or greater behind the vehicle.
The accumulated six readings shall be averaged for the compliance value.
Status: In compliance. No visible emissions were observed during the inspection. A water truck is
maintained at the source location and used as needed to maintain opacity limits.
8. The following processing limits for hydrocarbon contaminated soil shall not be exceeded without
prior approval in accordance with R307-1-3.1, UAC:
1. 40,000 tons per 12-month period (average hydrocarbon contamination of 3000
mg/kg)
2. 310 days of operation per year
3. 11 hours per day
Compliance with the annual limitations shall be determined on a rolling 12-month total. Based
on the first day of each month a new 12-month total shall be calculated using the previous 12
3
months. Records of processed soil shall be kept for all periods when the plant is in operation.
Records of processed soil shall be made available to the Executive Secretary or his representative
upon request and shall include a period of two years ending with the date of the request.
Quantities of processed soil shall be determined by examination of daily receiving records. The
records shall be kept on a daily basis. Hours of operation shall be determined by supervisor
monitoring and maintaining of an operations log.
Status: In compliance as follows:
1. The source received 8,226 tons of contaminated soil for the rolling 12-month
reporting period through October 2021, with an average hydrocarbon
contamination content of 367144 mg/kg.
2. The source operates less than 310 days per calendar year as they are
restricted by the operating days of the Salt Lake County Landfill.
3. The source only operates dming the Salt Lake County Landfill hours which
are 7:00 am — 5:00 pm, Monday through Saturday.
9. All unpaved roads and other unpaved operationftl areas, other than the process cells, which are
used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive
dust. The application of water or chemically treated shall be sufficient frequency and quantity to
maintain the surface material in a damp/moist conditions such that the opacity limitation shall not
exceed 20% opacity during all times the areas are in use or unless it is below freezing. If
chemical treatment is to be used, the plan must be approved by the Executive Secretary. Records
of water treatment shall be kept for all periods when the plant is in operation. The records shall
include the following items:
1. Date
2. Number of treatments made, dilution ratio, and quantity
3. Rainfall received, if any, and approximate amount
4. Time of day treatments were made
Records of treatment shall be made available to the Executive Secretary upon request and shall
include a period of two years ending with the date of the request.
Status: In compliance. The source maintains a water truck at the location. Required water records
were made available for review at the time of inspection.
10. The haul road shall not exceed 0.57 miles in length without prior approval in accordance with
R307-1-3.1, UAC. The vehicle speed on the unpaved roads shall not exceed 5 miles_per hour
without prior approval in accordance with R307-1-3.1, UAC.
Status: In compliance. The haul road does not exceed 0.57 miles. A 5 mph sign is clearly posted at
the entrance.
11. The sulfur content of any fuel oil burned shall not exceed 0.5% by weight as determined by
ASTM Method D-4294-89 or approved equivalent. The sulfur content shall be tested if directed
by the Executive Secretary.
Status: In compliance. Ultra-low sulfur diesel fuel is purchased through Torn Randle Distributing.
4
12. All records referenced in this AO which are required to be kept by the owner/operator, shall be
made available to the Executive Secretary or his representative upon request.
Status: In compliance. All requested records were provided during the inspection.
13. The owner/operator shall comply with R307-1-3.5, UAC. This rule addresses emission inventory
reporting requirements.
Status: In compliance. The source submitted an emissions inventory for 2020 which can be found
in the SLEIS database.
14. The owner/operator shall comply with R307-1-4.7, UAC. This rule addresses unavoidable
breakdown reporting requirements. The owner/operator shall calculate/estimate the excess
emissions whenever a breakdown occurs. All excess emissions shall immediately be reported to
the Executive Secretary. The total of excess emissions shall be reported to the Executive
Secretary as directed for each calendar year.
Status: In compliance. No breakdowns have occurred since the previous compliance inspection.
15. The Executive Secretary shall be notified in writing upon start-up of the installation, as an initial
compliance inspection is required. Eighteen months from the date of this AO the Executive
Secretary shall be notified in writing of the status of construction/installation if
construction/installation is not completed. At that time the Executive Secretary shall require
documentation of the continuous construction/installation of the operation and may revoke the
AO in accordance with R307-1-3.1.5, UAC.
Status: In compliance. The source has been in operation at this location since 1989 and operating
under a DAQ Approval Order since 1992.
AREA SOURCE RULES
R307-309. Fugitive Emissions. Fugitive Dust.
Status: In compliance. No visible emissions were observed during the inspection.
EMISSION INVENTORY:
The 2020 Emission Inventory can be found in the SLEIS data base. The emissions for the 2020 calendar
year are as follows:
Pollutant Tons/year
Carbon Monoxide 0.582
Nitrogen Oxides 1.468
Particulate Matter (PM io) 0.787
Sulfur Dioxide 0.017
Volatile Organic Compounds 11.103
PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.
5
COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with the conditions of AO DAQE-764-95, dated
August 29, 1995. The Facility appeared to be well maintained
and properly operated.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect at norrnal frequency.
ATTACHMENTS: VEO form.
Title: tfieic ertsi
I have received a copy of these observations:
s.- SIGNATURE: 2.4,746
Printed Name: -reef „c„,,rien
Distrib: white nary- or; pink-owner/operator
Sun 0- Wind O' Emission Point with Plume Cy-1
Observer Position x
Observer's Signature:
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY Page _ of — DIVISION OF AIR QUALITY
EPA METHOD 9 - VISIBLE EMISSION OBSERVATION FORM
Source Name: er_redierritaair Street Address: 030
City/County: (542.0
'Phone:
Site ID: /09g5-
Facility:
Equipment/Process:
Control Equipment:
Emission Point:
Sky Conditions: Clear [ ] Partly Cloudy [ ] Overcast [ ]
Precipitation: No [ ] Yes [ ]
Wind: Direction: Speed: mph
Ambient Temp: -F RH:
Height Relative to Observer:
Distance From Observer:
Condensed Water Vapor Present: No [ ] Yes [ ]
Attached [ ] Detached [ )
Length of Condensed Water Vapor Plume:
Background:
Sketch process unit: indicate observer position relative to
source; indicate potential emission points and/or actual
emission points.
OBSERVATION DATE: ///2Z/Z/
Stop time:
sec min 0 15
, ,
411
1
30
,..,,....„.„„.„

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COMMENTS:
ea4e195
- PAIS 4F froGe650 6,4171,11AMtEt. Sda.
1/- - Nese-L. Sutr-weezmz•Ir 1,7 *
Start time:
Dungan Adams <[e-mail]>
10-Year Reviews
1 message
Alan Humpherys <[e-mail]>Wed, Jun 19, 2024 at 11:26 AM
To: Dungan Adams <[e-mail]>
Dungan,
Here are some 10-year reviews.
Site #1: 12134-0002
Started by John Persons (I switched you in the WAL)
Peer: Christine
Old AO: DAQE-649-98, 10-1-98
Site #2: 10149
Peer: EQ
Site #3: 10485
Peer: Tim
Old AO: DAQE-764-95, 8-29-95
Company: Garkane Energy
Figure out which ones have AO's or are actual sites.
Site #4: 11399
Peer: Christine
Old AO: DAQE-774-94, 9-15-94
Site #5: 11400
Peer: Christine
Site #6: 12546
Peer: Christine
Site #7: 14062
Peer: Christine
Thanks,
Alan
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
8/2/24, 4:46 PM State of Utah Mail - 10-Year Reviews
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1802311296986744832&simpl=msg-f:1802311296986744832 1/1
Dungan Adams <[e-mail]>
Utah Division of Air Quality Permit Update for E.T. Technologies
4 messages
Dungan Adams <[e-mail]>Mon, Jul 22, 2024 at 11:40 AM
To: [e-mail]
Hi Sarah,
My name is Dungan Adams and I am an environmental engineer for the Utah Division of Air Quality (DAQ). One of the
DAQ's goals is to update old air permits so they align with current state and federal rules and so that contact
information and formatting can be accurately updated. This is a free process that was implemented primarily to check if
old sources were still operating and if any contact information needed to be changed.
I am reaching out about E.T. Technologies' air permit (DAQE-764-95) from August 29, 1995. Please let me know if any of
the following needs to be updated:
Mailing Address:
E.T. Technologies, Inc.
6030 West 1300 South
Salt Lake City, Utah 84104
Plant Location:
6400 West 1300 South
Salt Lake City, Utah 84104
Ted Sonnenburg was the old source contact for E.T. Technologies, but I was not able to reach him at [e-mail]. Are
you a good person to update as the source contact?
I pulled your email from the ETSRS website, but if there is someone else who is better suited to help confirm this
information, could you please pass along this email to them?
Let me know if you have any questions.
Thanks for your help,
Dungan
--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
Sarah Smart <[e-mail]>Mon, Jul 22, 2024 at 11:41 AM
To: Dungan Adams <[e-mail]>
8/2/24, 4:45 PM State of Utah Mail - Utah Division of Air Quality Permit Update for E.T. Technologies
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7224694104407989522&simpl=msg-a:r-401975871299525…1/2
Nope! Everything is still the same!

Thank you!
Sarah
[Quoted text hidden]
Sarah Smart <[e-mail]>Mon, Jul 22, 2024 at 11:42 AM
To: Dungan Adams <[e-mail]>
Yes, I’m the contact now, Ted works for the government now.

From: Dungan Adams <[e-mail]>
Sent: Monday, July 22, 2024 11:41 AM
To: Sarah Smart <[e-mail]>
Subject: Utah Division of Air Quality Permit Update for E.T. Technologies

Hi Sarah,
[Quoted text hidden]
Dungan Adams <[e-mail]>Mon, Jul 22, 2024 at 12:20 PM
To: Sarah Smart <[e-mail]>
Great, thank you very much!
Thanks,
Dungan
[Quoted text hidden]
8/2/24, 4:45 PM State of Utah Mail - Utah Division of Air Quality Permit Update for E.T. Technologies
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r7224694104407989522&simpl=msg-a:r-401975871299525…2/2