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Home My WebLink AboutDAQ-2024-008090 DAQE-AN109170049-24 {{$d1 }} Kenneth Potts Compass Minerals Ogden Incorporated 9900 West 109th Street Overland Park, KS 66210 HurstH@compassminerals.com Dear Mr. Potts: Re: Approval Order: Modification to Approval Order DAQE-AN109170044-23 to Remove Salt Harvesting Limit and add Fortress Equipment Project Number: N109170049 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on February 12, 2024. Compass Minerals Ogden Incorporated must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is John Jenks, who can be contacted at (385) 306-6510 or jjenks@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:JJ:jg cc: Weber-Morgan Health Department EPA Region 8 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director May 8, 2024 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN109170049-24 Modification to Approval Order DAQE-AN109170044-23 to Remove Salt Harvesting Limit and add Fortress Equipment Prepared By John Jenks, Engineer (385) 306-6510 jjenks@utah.gov Issued to Compass Minerals Ogden Incorporated - Production Plant Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality May 8, 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.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ..................................................................................... 9 PERMIT HISTORY ................................................................................................................... 27 ACRONYMS ............................................................................................................................... 28 DAQE-AN109170049-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Compass Minerals Ogden Incorporated Compass Minerals Ogden Incorporated - Production Plant Mailing Address Physical Address 9900 West 109th Street 765 North 10500 West Overland Park, KS 66210 Ogden, UT 84404 Source Contact UTM Coordinates Name: Holly Hurst 396,869 m Easting Phone: (801) 732-3251 4,570,651 m Northing Email: HurstH@compassminerals.com Datum NAD83 UTM Zone 12 SIC code 2819 (Industrial Inorganic Chemicals, NEC) SOURCE INFORMATION General Description Compass Minerals Ogden Incorporated (Compass) harvests and processes salt and minerals from the Great Salt Lake to produce sulfate of potash (SOP), salt, and magnesium chloride. NSR Classification Minor Modification at Major Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Weber County Airs Source Size: A Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Db: Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines DAQE-AN109170049-24 Page 4 MACT (Part 63), DDDDD: National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters Title V (Part 70) Major Source Project Description Compass has requested a change to its current AO DAQE-AN109170044-23. The current salt harvesting throughput limit is redundant with the two (2) limits on processed salt products. Although the potential exists for additional salt harvesting, the material contains residual magnesium chloride (a dust suppressant) and maintains a high moisture content (further limiting or eliminating fugitive dust emissions). Condition II.B.2.a(A), which limits the total salt harvest amount, is unnecessary and is being removed. As part of this project, Compass also wishes to include a previously submitted project. This other project involves the inclusion of equipment and processes from Fortress North America, which was recently acquired by Compass. Harvested magnesium chloride from the existing Compass processes and converts it to a fire retardant. The magnesium chloride will be loaded into two (2) sealed tanks where it will be blended with additives. The additives are introduced by a vacuum pump, which pulls the powdered additives from the bottom of the hoppers using a negative pressure zone and deposits them into the bottom of the mixing tanks. Emissions from the two (2) hoppers are processed by a baghouse. Inside the tanks, the magnesium chloride is mixed with the additives. The viscous fluid will then be transported to a holding tank to await loadout. 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) Ammonia 0 6.02 CO2 Equivalent 0 225583.00 Carbon Monoxide 0 161.36 Nitrogen Oxides 0 38.66 Particulate Matter - PM10 0 285.60 Particulate Matter - PM10 (Fugitives) 0 79.76 Particulate Matter - PM2.5 0 131.75 Particulate Matter - PM2.5 (Fugitives) 0 9.71 Sulfur Dioxide 0 2.88 Volatile Organic Compounds 0 51.47 Volatile Organic Compounds - Fugitive 0 10.87 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Benzene (Including Benzene From Gasoline) (CAS #71432) 0 8 Cadmium (CAS #7440439) 0 4 Chlorine (CAS #7782505) 0 6132 Chloroform (CAS #67663) 0 43832 Chromium Compounds (CAS #CMJ500) 0 5 DAQE-AN109170049-24 Page 5 Formaldehyde (CAS #50000) 0 4313 Generic HAPs (CAS #GHAPS) 0 4 Hexane (CAS #110543) 0 6774 Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 58867 Manganese Compounds (CAS #MAR500) 0 1 Methanol (CAS #67561) 0 6432 Naphthalene (CAS #91203) 0 2 Nickel Compounds (CAS #NDB000) 0 8 Toluene (CAS #108883) 0 13 Change (TPY) Total (TPY) Total HAPs 0 63.20 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 five-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 five (5) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director every 18 months from the date of this AO until construction is completed to demonstrate reasonable construction progress. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] DAQE-AN109170049-24 Page 6 SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Production Plant Salt, Magnesium Chloride, and SOP II.A.2 Dryer 501 (D-501) Location: Salt Plant Capacity: 51 MMBtu/hr Fuel Type: Natural Gas Controlled by wet scrubber (AH-513) II.A.3 Dryer 1400 (D-1400) Location: SOP Plant Capacity: 51 MMBtu/hr Fuel Type: Natural Gas Controlled by baghouse (BH-1400) II.A.4 Dryer 1545 (D-1545) Location: SOP Plant - Compaction Capacity: 30 MMBtu/hr Fuel Type: Natural Gas Controlled by baghouse (BH-008) II.A.5 Wet Scrubber (AH-500) Location: Salt Plant Controls: Coolers, Bins and Hoppers, Conveyors, Crushers and Grinders, Feeders and Baggers, Mixers, Presses, and Rail Loading Mechanically Aided II.A.6 Baghouse (BH-501) Location: Salt Plant Controls: Fluidized bed cooler II.A.7 Wet Scrubber (AH-502) Location: Salt Plant Controls: Bins and Hoppers, Conveyors, Elevators, and Screens Mechanically Aided II.A.8 Baghouse (BH-502) Location: Salt Plant Controls: Bins and Hoppers, Elevators, and truck loading operations II.A.9 Baghouse (BH-503) Location: Salt Plant Controls: Material handling in the salt special products system II.A.10 Baghouse (BH-505) Location: Salt Plant Controls: Material handling in the salt packing area Equipped with HEPA Filter and vented indoors. DAQE-AN109170049-24 Page 7 II.A.11 Wet Scrubber with Cyclone (AH-513) Location: Salt Plant Controls: Salt Dryer (D-501) Mechanically Aided with Variable Frequency Drive (VFD) II.A.12 Venturi Wet Scrubber (AH-692) Location: Magnesium Chloride Plant Controls: Bins and Hoppers, Conveyors, Crushers and Grinders, Elevators, Feeders and Baggers, and Screens II.A.13 Baghouse (BH-001) Location: SOP Plant Controls: Bins and Hoppers, Screens, and Truck and Rail Loading Operations II.A.14 Baghouse (BH-002) Location: SOP Plant Controls: Bins and Hoppers, Conveyors, Elevators, and Screens II.A.15 Baghouse with Cyclone (BH-008) Location: SOP Plant Controls: Conveyor and SOP Compaction Dryer (D-1545) II.A.16 Baghouse with Cyclones (BH-1400) Location: SOP Plant Controls: Bins and Hoppers, Conveyors, Elevators, Screens, and SOP Dryer (D-1400) II.A.17 Bin Vent Filter (BH-1505) Location: SOP Plant Controls: Bins and Hoppers II.A.18 Baghouse (BH-1516) Location: SOP Plant Controls: Bins and Hoppers, Conveyors, Elevators, and Screens II.A.19 Wet Scrubber (AH-1555) Location: SOP Plant Controls: Bins and Hoppers, Conveyors, and Elevators Mechanically Aided with VFD II.A.20 Two (2) Boilers Capacity: 108.11 MMBtu/hr (each) Fuel Type: Natural Gas Installed Controls: Ultra-Low NOx Burner and Flue Gas Re-circulation Monitoring: Continuous Emission Monitoring System (CEMS) NSPS Applicability: Subpart Db II.A.21 Submerged Combustion Water Heater (SC-450) Location: SOP Plant Capacity: 30 MMBtu/hr Fuel: Natural Gas II.A.22 Submerged Combustion Water Heater (SC-460) Location: SOP Plant Capacity: 60 MMBtu/hr Fuel: Natural Gas DAQE-AN109170049-24 Page 8 II.A.23 Four (4) Magnesium Chloride Evaporators Two (2) operating units with one (1) primary and one (1) secondary evaporator each Location: Magnesium Chloride Plant II.A.24 Two (2) Cooling Towers (CT-003 and CT-004) Location: SOP Plant Re-circulation rate: 1500 gpm II.A.25 Cooling Tower (CT-639) Location: Magnesium Chloride Plant Re-circulation rate: 212 gpm II.A.26 Abrasive Blasting Capacity: 50 lb/hr II.A.27 Emergency Generator Engine (GN-100) Rating: 610 hp Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.28 Emergency Generator Engines (GN-200 and GN-300) Quantity: Two (2) Rating: 41 hp Fuel: Propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.29 Emergency Generator Engine (GN-1200) Rating: 402 hp Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.30 Emergency Generator Engine (GN-1300) Rating: 161 hp Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.31 Emergency Generator Engine (GN-007) Rating: 235 hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.32 Emergency Generator Engine (GN-500) Rating: less than 100 hp Fuel: Propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.33 Cooling Belt Fan (AH-696) Location: Magnesium Chloride Plant DAQE-AN109170049-24 Page 9 II.A.34 Fuel Tanks Fuel: Gasoline Quantity: One (1) Capacity: 6,000 gallons Fuel: Diesel Quantity: Two (2) Capacity: 10,000 gallons (each) II.A.35 SOP Silo Building Various Storage Silos Quantity: 11 Location: SOP Plant Controls: Fifteen dust torit cartridge filters; internally vented II.A.36 Dome Silos (12, 13, and 14) Location: SOP Plant II.A.37 Fully Enclosed Conveyors Location: SOP Plant ID's: OC014, OC015, OC1404, OC1405, OC1406, OC1501, OC1550A, OC283, OC284, OC294, OC298, OF012, and OF013 II.A.38 Partially Enclosed Conveyors Location: SOP Plant ID: OC276, OC277/214, OC279, OC280, and OC281 Location: Salt Plant ID: OC503 II.A.39 Various Conveyors and Bucket Elevators Location: Facility-Wide II.A.40 Various Bins and Hoppers Location: Facility-Wide II.A.41 Various Screens, Grinders, and Crushers II.A.42 Fortress Equipment Two (2) hoppers controlled by the baghouse Two (2) mixing tanks Two (2) holding tanks SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site Wide Requirements II.B.1.a Unless otherwise specified in this AO, visible emissions from any stationary and fugitive emission source shall not exceed 10 percent opacity. This includes, but is not limited to, all wet scrubbers and all baghouses. [R307-401-8] DAQE-AN109170049-24 Page 10 II.B.1.a.1 Monitoring: A. Except as noted in B through D below, a visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. For baghouses subject to 40 CFR Part 64, the owner/operator shall designate one (1) of the weekly opacity surveys to demonstrate compliance with the monthly survey requirement in this condition. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. B. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. C. For emission units located within a building, the requirements of paragraph A apply to each affected emission unit located within a building or for the building itself. If visible emissions from a building are monitored, the requirements of paragraph A apply to each side, roof, and vent of the building. The affected emission unit(s) shall be operating when monitoring is performed on the unit located within a building or on the building itself. D. The owner/operator is not required to perform monthly surveys on natural gas combustion sources, cooling towers, magnesium chloride evaporators, and petroleum storage tanks. [R307-401-8] II.B.1.a.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time of visual emissions observed, emission point location and description, time and date of the opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, and/or 40 CFR 51, Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.2 Salt Plant Requirements II.B.2.a The following production limits shall not be exceeded: A. 700,000 tons of road salt produced per rolling 12-month period. B. 960,000 tons of dried salt produced per rolling 12-month period. [R307-401-8] DAQE-AN109170049-24 Page 11 II.B.2.a.1 The owner/operator shall demonstrate compliance with the rolling 12-month total for each production limit. 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 of production shall be kept for all periods when the plant is in operation. Production records shall be determined by examination of sales, billing records, or operation logs. The records of production shall be kept on a daily basis. [R307-401-8] II.B.2.b Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity: A. All loading operations. B. All conveyor drop points. C. All conveyor transfer points. D. All bin vents. E. All storage piles. F. All partially enclosed conveyance systems. G. All material handling operations, which include the following: bins and hoppers, screens, crushers, grinders, and presses. [R307-401-8] II.B.2.b.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance with 40 CFR 51, Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. [R307-401-8] II.B.2.b.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, and/or 40 CFR 51, Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] DAQE-AN109170049-24 Page 12 II.B.2.c Emissions to the atmosphere from the baghouses and wet scrubbers located at the Salt Plant for PM10 and PM2.5 shall not exceed the following rates and concentrations: Compliance with the limits shall be based on an average of three (3) test runs and shall include both filterable and condensable emissions (standardized at 68 °F, 29.92 in Hg): Emission Point PM10 Emission Rate PM2.5 Emission Rate PM2.5 Concentration (lb/hr) (lb/hr) (grains/dscf) AH-500 1.61 1.61 0.01 AH-502 1.12 0.74 0.04 AH-513 1.49 1.49 0.0114 BH-501 1.30 1.15 0.01 BH-502 0.20 0.06 0.0053 BH-503 1.54 0.23 0.01 [R307-401-8] II.B.2.c.1 Testing Frequency: Compliance testing shall be done on each emission source at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-401-8] II.B.2.c.2 Notification: The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.2.c.3 Sample Location: The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] II.B.2.c.4 Calculations: To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] DAQE-AN109170049-24 Page 13 II.B.2.c.5 Source Operation: The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days). B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.2.c.6 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing methods acceptable to the Director. [R307-165] II.B.2.c.7 PM10/PM2.5: For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201a, or other EPA-approved testing method, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or other EPA-approved testing methods as acceptable to the Director. When demonstrating compliance with the PM10 and PM2.5 limits above, all filterable particulate emissions captured using Method 5 shall be considered PM2.5, resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing analytical methods, such as: x-ray diffraction, scanning electron microscopy, or electron microprobe analysis, may be used to determine particle sizing, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-165] II.B.2.c.8 Results: The results of stack testing shall be submitted to the Director within 60 days of the completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.2.d The owner/operator shall vent Baghouse 505 (BH-505) indoors at all times during operation. [R307-401-8] DAQE-AN109170049-24 Page 14 II.B.3 Magnesium Chloride Plant Requirements II.B.3.a The following production limits shall not be exceeded: A. 1,000,000 tons of magnesium chloride liquid produced from ponds per rolling 12-month period. B. 70,080 tons of magnesium chloride flake produced per rolling 12-month period. [R307-401-8] II.B.3.a.1 The owner/operator shall demonstrate compliance with the rolling 12-month total for each production limit. 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 of production shall be kept for all periods when the plant is in operation. Production records shall be determined by examination of sales, billing records, or operation logs. The records of production shall be kept on a daily basis. [R307-401-8] II.B.3.b Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity: A. All loading operations. B. All conveyor drop points. C. All conveyor transfer points. D. All storage piles. E. All partially enclosed conveyance systems. F. All material handling operations, which include the following: bins and hoppers, screens, crushers, grinders, and presses. [R307-401-8] II.B.3.b.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance with 40 CFR 51, Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. [R307-401-8] DAQE-AN109170049-24 Page 15 II.B.3.b.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, and/or 40 CFR 51, Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.3.c With the exception of periods of startup, shutdown and maintenance, the owner/operator shall only operate one (1) set of two (2) evaporators at any one (1) time. [R307-401-8] II.B.3.d The owner/operator shall not exceed 8,760 hours of operation combined from the two (2) sets of evaporators per rolling 12-month period. Periods of startup, steady-state, and shutdown are to be included in this limit. Steam cleaning operations, where no chlorine is being added to the evaporators, are not considered part of this operational limit. [R307-401-8] II.B.3.d.1 The owner/operator shall demonstrate compliance with the rolling 12-month total by tracking the hours of operation for each set of evaporators. 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 of the hours of operation shall be kept for all periods when the plant is in operation. The records of operation shall be kept on a daily basis and include startup, steady-state, and shutdown operational times. [R307-401-8] II.B.3.e Emissions to the atmosphere from the wet scrubber located at the Magnesium Chloride Plant for PM10 and PM2.5 shall not exceed the following rates and concentrations. Compliance with the limits shall be based on an average of 3 test runs and shall include both filterable and condensable emissions (standardized at 68 °F, 29.92 in Hg): Emission Point PM10 Emission Rate PM2.5 Emission Rate PM2.5 Concentration (lb/hr) (lb/hr) (grains/dscf) AH-692 0.15 0.12 0.01 Combined emissions to the atmosphere from each set of two (2) Magnesium Chloride Plant Evaporators for VOC and HCl shall not exceed the following rates. Compliance with the limit shall be based on an average of three (3) test runs: Emission Point VOC Emission Rate HCl Emission Rate (lb/hr) (lb/hr) MgCl2 Evaporators 6.18 6.40 [R307-401-8] II.B.3.e.1 Testing Frequency: Compliance testing for AH-692 shall be performed at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. Compliance testing for both VOC and HCl shall be performed at least once every three (3) years for each train of the Magnesium Chloride Evaporators. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-165] DAQE-AN109170049-24 Page 16 II.B.3.e.2 Notification: The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stacks to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.3.e.3 Sample Location: The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] II.B.3.e.4 Calculations: To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.3.e.5 Source Operation: The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days) for the AH-692 scrubber or the previous three (3) years for the magnesium chloride evaporators. B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.3.e.6 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods acceptable to the Director. [R307-165] DAQE-AN109170049-24 Page 17 II.B.3.e.7 PM10/PM2.5: For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201a, or other EPA-approved testing method, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or other EPA-approved testing methods as acceptable to the Director. When demonstrating compliance with the PM10 and PM2.5 limits above, all filterable particulate emissions captured using Method 5 shall be considered PM2.5, resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing analytical methods, such as x-ray diffraction, scanning electron microscopy, or electron microprobe analysis, may be used to determine particle sizing, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-165] II.B.3.e.8 Volatile Organic Compounds (VOCs): VOC emissions shall be determined using 40 CFR 60, App. A, Method 25A, using a flame ionization analyzer equipped with a methane separator. If such an analyzer is unavailable, VOC emissions shall be determined simultaneously using two (2) analyzers, with one (2) configured to read only methane. The difference between the total organic detector and the methane detector shall constitute the VOC measurement. [R307-165] II.B.3.e.9 HCl: HCl emissions shall be determined using 40 CFR 60, Appendix A, Method 26, or 26A, or other EPA-approved testing method, acceptable to the Director. [R307-401-8] II.B.3.e.10 Results: The results of stack testing shall be submitted to the Director within 60 days of the completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.4 SOP Plant Requirements II.B.4.a The following production and operation limits shall not be exceeded: A. 5,300,000 tons of potash harvested from ponds per rolling 12-month period. B. 1,680,000 tons of SOP produced per rolling 12-month period. C. 432,000 tons of KCl used per rolling 12-month period. [R307-401-8] II.B.4.a.1 The owner/operator shall demonstrate compliance with the rolling 12-month total for each production limit. 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 of production shall be kept for all periods when the plant is in operation. Production records shall be determined by operation logs. The records of production shall be kept on a daily basis. [R307-401-8] DAQE-AN109170049-24 Page 18 II.B.4.b Visible emissions from all outdoor storage silos shall not exceed 10% opacity. Egress points to the dome silos shall remain closed at all times, except when mobile equipment is actively entering or exiting the silo during loading or unloading operations. [R307-401-8] II.B.4.b.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis while loading or unloading operations are occurring at the silo. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director. The opacity determination shall be performed while loading or unloading operations are occurring at the silo. [R307-401-8] II.B.4.b.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. Documentation of maintenance performed on the silos to ensure they operate as fully enclosed structures when egress points are closed shall also be kept in the log. [R307-401-8] II.B.4.c Visible emissions from all outdoor fully enclosed conveyance systems shall not exceed 5% opacity. At all times, the owner/operator shall operate and maintain each affected emission unit as a fully enclosed conveyance system. Each fully enclosed conveyance system shall be fully enclosed on all sides, top, and bottom. All fully enclosed conveyance systems shall be clearly labeled on each conveyor such that an inspector/operator can safely identify equipment at any time. [R307-401-8] DAQE-AN109170049-24 Page 19 II.B.4.c.1 Monitoring: The owner/operator shall conduct a Method 22 performance test or other EPA-approved testing method, as acceptable to the Director, according to the following requirements for each affected emission unit: A. Conduct a weekly 10-minute visible emissions test of each affected emission unit in accordance with Method 22 of 40 CFR 60 Appendix A, or other EPA-approved testing method, as acceptable to the Director. The performance test shall be conducted while the unit is in operation. B. If any visible emissions are observed from an emission unit, the owner/operator shall inspect the affected emission unit to determine the cause of visible emissions and initiate corrective action within one (1) hour of the initial survey. C. If no visible emissions are observed during four (4) consecutive weekly tests, the owner/operator may decrease the frequency of the visible emissions test required in paragraph (A) from weekly to monthly. If visible emissions are observed during any monthly test, the owner/operator shall resume the weekly visible emissions test required in paragraph (A) and maintain that schedule until no visible emissions are observed in four (4) consecutive weekly tests. [R307-401-8] II.B.4.c.2 Recordkeeping: The owner/operator shall keep a log of the visible emissions tests that contains the following information: time and date of the test, emission point location and description, time of visible emissions, if observed, results of inspections, time and date of corrective actions initiated, and corrective actions taken. All data required by 40 CFR 60, Appendix A, Method 22, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.4.d Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity: A. All loadout operations. B. All storage piles. C. All material handling operations, which include the following: bins and hoppers, screens, crushers, grinders, and presses. D. All partially enclosed conveyance systems. E. All conveyor drop points. F. All conveyor transfer points. G. All bin vents. [R307-401-8] DAQE-AN109170049-24 Page 20 II.B.4.d.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance with 40 CFR 51, Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. [R307-401-8] II.B.4.d.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, and/or 40 CFR 51, Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.4.e All partially enclosed conveyance systems shall be clearly labeled on each conveyor so that an inspector/operator can safely identify equipment at any time. [R307-401-8] II.B.4.f Emissions to the atmosphere from the baghouses and wet scrubbers located at the SOP Plant for PM10 and PM2.5 shall not exceed the following rates and concentrations: Compliance with the limits shall be based on an average of three (3) test runs and shall include both filterable and condensable emissions (standardized at 68 °F, 29.92 in Hg): Emission Point PM10 Emission Rate PM2.5 Emission Rate PM2.5 Concentration (lb/hr) (lb/hr) (grains/dscf) AH-1555 2.61 0.39 0.01 BH-001 0.37 0.37 0.01 BH-002 0.65 0.47 0.01 BH-008 4.25 4.25 0.01 BH-1400 2.78 2.78 0.02 BH-1516 1.46 0.22 0.01 [R307-401-8] II.B.4.f.1 Testing Frequency: Compliance testing shall be done on each emission source at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-401-8] DAQE-AN109170049-24 Page 21 II.B.4.f.2 Notification: The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.4.f.3 Sample Location: The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] II.B.4.f.4 Calculations: To determine mass emission rates (lb/hr, etc.,) the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.4.f.5 Source Operation: The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days). B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.4.f.6 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods acceptable to the Director. [R307-165] DAQE-AN109170049-24 Page 22 II.B.4.f.7 PM10/PM2.5: For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201a, or other EPA-approved testing method, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or other EPA-approved testing methods as acceptable to the Director. When demonstrating compliance with the PM10 and PM2.5 limits above, all filterable particulate emissions captured using Method 5 shall be considered PM2.5, resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing analytical methods, such as x-ray diffraction, scanning electron microscopy, or electron microprobe analysis, may be used to determine particle sizing, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-165] II.B.4.f.8 Results: The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.5 Boiler Requirements II.B.5.a NOx emissions to the atmosphere from each of the two (2) boilers on site shall not exceed the following rates and concentrations: Rate (lbs/hr) Concentration (ppm) 1.30 9.0 Compliance with the limit shall be based on an average of three (3) test runs. [R307-401-8] II.B.5.a.1 Testing Frequency: Compliance testing shall be done on each emission source at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. I f an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-401-8] II.B.5.a.2 Notification: The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.5.a.3 Sample Location: The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] DAQE-AN109170049-24 Page 23 II.B.5.a.4 Calculations: To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.5.a.5 Source Operation: The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days). B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.5.a.6 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods acceptable to the Director. [R307-165] II.B.5.a.7 Nitrogen Oxides: NOx emissions shall be determined using 40 CFR 60 Appendix A, Method 7E, or other EPA-approved testing method, acceptable to the Director. [R307-165] II.B.5.a.8 Results: The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.6 Dryer Requirements II.B.6.a Emissions to the atmosphere from each of the three (3) dryers on site (D-501, D-1400, and D-1545) for NOx shall not exceed 20 ppm at 3% O2. Compliance with the limits shall be based on an average of three (3) test runs. [R307-401-8] II.B.6.a.1 Testing Frequency: Compliance testing shall be done on each emission source at least once every three (3) years. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-165] II.B.6.a.2 Notification: The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] DAQE-AN109170049-24 Page 24 II.B.6.a.3 Sample Location: The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] II.B.6.a.4 Calculations: To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director to give the results in the specified units of the emission limitation. [R307-165] II.B.6.a.5 Source Operation: The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous three (3) years. B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.6.a.6 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing methods acceptable to the Director. [R307-165] II.B.6.a.7 Nitrogen Oxides: NOx emissions shall be determined using 40 CFR 60 Appendix A, Method 7E, or other EPA-approved testing method, acceptable to the Director. [R307-165] II.B.6.a.8 Results: The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.7 Baghouse and Wet Scrubber Requirements II.B.7.a Each baghouse shall operate within the static pressure range recommended by the manufacturer for normal operations. The static pressure range shall be clearly labeled on each baghouse such that an inspector/operator can safely read the range at any time. Manometer or magnehelic pressure gauges shall be installed to measure the differential pressure across each of the baghouses. The pressure gauges shall be located such that an inspector/operator can safely read the indicator at any time. For baghouses that monitor pressure drop to demonstrate compliance with 40 CFR Part 64, the requirements in this condition shall not apply. [R307-401-8] DAQE-AN109170049-24 Page 25 II.B.7.a.1 Pressure drop readings from each baghouse shall be recorded at least once during each day of operation. Records documenting these inspections shall be kept in a log and shall include the following: A. Unit identification; B. Manufacturer recommended pressure drop for the unit; C. Daily pressure drop readings; and D. Date of bag replacements. [R307-401-8] II.B.7.a.2 The pressure gauges in each baghouse shall be calibrated in accordance with the manufacturer's instructions or recommendations at least once every 12 months. Documentation of calibrations shall be maintained for all periods the plant is in operation. [R307-401-8] II.B.7.b Each wet scrubber shall operate within the static pressure range and liquid flow rate recommended by the manufacturer for normal operations. These parameters shall be clearly labeled on each scrubber such that an inspector/operator can safely read the parameters at any time. Manometer or magnehelic pressure gauges shall be installed to measure the differential pressure across the wet scrubber. Flow rate meters shall be installed to measure the liquid flow rate in the scrubber. The pressure gauge and flow rate meters shall be located such that an inspector/operator can safely read the indicators at any time. For scrubbers that are subject to 40 CFR Part 64, the requirements in this condition shall not apply. [R307-401-8] II.B.7.b.1 Pressure drop and liquid flow rate readings from each wet scrubber shall be recorded at least once during each day of operation. Records documenting these inspections shall be kept in a log and shall include the following: A. Unit identification; B. Manufacturer recommended pressure drop and liquid flow rate for the unit; C. Daily pressure drop readings; and D. Daily liquid flow rate readings. [R307-401-8] II.B.7.b.2 The gauges and meters on each wet scrubber shall be calibrated in accordance with the manufacturer's instructions or recommendations at least once every 12 months. Documentation of calibrations shall be maintained for all periods the plant is in operation. For scrubbers that monitor liquid flow rate to demonstrate compliance with 40 CFR Part 64, the liquid flow rate requirements in this condition shall not apply. All other requirements in this condition remain applicable. [R307-401-8] DAQE-AN109170049-24 Page 26 II.B.8 Engine Requirements II.B.8.a Visible emissions from diesel-fired emergency generator engines shall not exceed 20% opacity. [R307-401-8] II.B.8.a.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a quarterly basis while the unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than steam are observed from an emission unit, a 6-minute opacity determination of that emission unit shall be performed by a certified observer within one (1) hour of the initial survey. The opacity determination shall be performed while the unit is operating in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director. If the generator(s) continue to operate on consecutive days following the initial observation, a 6-minute opacity determination shall be performed by a certified observer on a daily basis while the unit is operating, in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director. [R307-401-8] II.B.8.a.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.8.b Visible emissions from propane-fired emergency generator engines shall not exceed 10% opacity. [R307-401-8] II.B.8.b.1 Monitoring: In lieu of monitoring via visible emission observations, records shall be kept for any period that a fuel other than propane is used in the affected emission unit. [R307-401-8] II.B.8.b.2 Recordkeeping: Records shall be kept in a log that is kept in a readily accessible location onsite. [R307-401-8] II.B.8.c The owner/operator shall use the emergency generator engines for electricity-producing operations only during periods when electric power from the public utilities is interrupted. [R307-401-8] II.B.8.d The owner/operator shall track hours of operation for each emergency generator engine as required to comply with all applicable federal subparts. [40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.9 Fuel Requirements II.B.9.a The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel oil additives) in the diesel-fired engines on site. All diesel burned shall contain no more than 15 ppm sulfur. [R307-401-8] II.B.9.a.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the sulfur requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8] II.B.9.b The owner/operator shall only use propane as fuel in the propane-fired engines on site. [R307-401-8] DAQE-AN109170049-24 Page 27 II.B.9.c The owner/operator shall use only pipeline-quality natural gas as a fuel source for all boilers and burners. [R307-401-8] II.B.10 Haul Roads and Fugitive Dust Requirements II.B.10.a The owner/operator shall comply with all applicable requirements of R307-309 for PM10 and PM2.5 non-attainment areas for fugitive emissions and fugitive dust sources. At least once every three (3) years, the fugitive dust control plan shall be reviewed and evaluated. If site modifications that result in emission changes have been made, an updated fugitive dust control plan shall be submitted as required by R307-309-6(3). [R307-309, R307-401-8] II.B.10.b Visible emissions in disturbed, operational areas, and unpaved haul roads from haul trucks and other mobile equipment shall not exceed 20% opacity at any point. [R307-401-8] II.B.10.b.1 In lieu of monitoring via visible emissions observations, adherence to the most recently approved fugitive dust control plan shall be monitored to demonstrate that the opacity limit is not exceeded and that appropriate measures are being implemented to control fugitive dust. [R307-309, R307-401-8] II.B.10.c Vehicle speeds shall be limited to 30 miles per hour on haul roads and 15 miles per hour in off-road areas. The vehicle speed limits shall be clearly visible and posted, at a minimum, on site at the entrance to off-road areas and the beginning of the haul road. [R307-401-8] II.B.10.d The owner/operator shall spray all unpaved haul roads with water, brine, or a chemical suppressant to control fugitive dust and maintain the opacity limit listed in this AO. [R307-401-8] II.B.10.d.1 Records of water or chemical treatment shall be kept for all periods when the plant is in operation. The owner/operator may stop applying suppressants when the temperature is below freezing. The records shall include the following: A. Date. B. Location of treatment. C. Rainfall received, if any, and approximate amount. D. Records of temperature if the temperature is below freezing. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN109170044-23 dated March 2, 2023 Is Derived from NOI dated February 12, 2024 IS Derived from NOI dated February 20, 2024 DAQE-AN109170049-24 Page 28 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-IN109170049-24 April 1, 2024 Kenneth Potts Compass Minerals Ogden Incorporated 9900 West 109th Street Overland Park, KS 66210 taylorjo@compassminerals.com Dear Mr. Potts: Re: Intent to Approve: Modification to Approval Order DAQE-AN109170044-23 to Remove Salt Harvesting Limit and Add Fortress Equipment Project Number: N109170049 The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is subject to public review. Any comments received shall be considered before an Approval Order (AO) is issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO. Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306- 6510 or jjenks@utah.gov, if you have any questions. Sincerely, {{$s }} Jon L. Black, Manager New Source Review Section JLB:JJ:jg cc: Weber-Morgan Health Department DJ Law, EPA Region 8 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director * ) ' & — - A E v A ? A C @ B w D E ˜ STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN109170049-24 Modification to Approval Order DAQE-AN109170044-23 to Remove Salt Harvesting Limit and Add Fortress Equipment Prepared By John Jenks, Engineer (385) 306-6510 jjenks@utah.gov Issued to Compass Minerals Ogden Incorporated - Production Plant Issued On April 1, 2024 {{$s }} New Source Review Section Manager Jon L. Black {{#s=Sig_es_:signer1:signature}} * ) ' & — - A E v A ? A C @ B w D E ˜ TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 PUBLIC NOTICE STATEMENT............................................................................................... 5 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ................................................................................... 10 PERMIT HISTORY ................................................................................................................... 29 ACRONYMS ............................................................................................................................... 30 DAQE-IN109170049-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Compass Minerals Ogden Incorporated Compass Minerals Ogden Incorporated - Production Plant Mailing Address Physical Address 9900 West 109th Street 765 North 10500 West Overland Park, KS 66210 Ogden, UT 84404 Source Contact UTM Coordinates Name: Jordan Taylor 396,869 m Easting Phone: (913) 344-9225 4,570,651 m Northing Email: taylorjo@compassminerals.com Datum NAD83 UTM Zone 12 SIC code 2819 (Industrial Inorganic Chemicals, NEC) SOURCE INFORMATION General Description Compass Minerals Ogden Incorporated (Compass) harvests and processes salt and minerals from the Great Salt Lake to produce sulfate of potash (SOP), salt, and magnesium chloride. NSR Classification Minor Modification at Major Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Weber County Airs Source Size: A Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Db: Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines MACT (Part 63), DDDDD: National Emission Standards for Hazardous Air Pollutants for DAQE-IN109170049-24 Page 4 Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters Title V (Part 70) Major Source Project Description Compass has requested a change to its current AO DAQE-AN109170044-23. The current salt harvesting throughput limit is redundant with the two (2) limits on processed salt products. Although the potential exists for additional salt harvesting, the material contains residual magnesium chloride (a dust suppressant) and maintains a high moisture content, (further limiting or eliminating fugitive dust emissions). Condition II.B.2.a(A), which limits the total salt harvest amount, is unnecessary and is being removed. As part of this project, Compass also wishes to include a previously submitted project. This other project involves the inclusion of equipment and processes from Fortress North America, which was recently acquired by Compass. Harvested magnesium chloride from the existing Compass Minerals processes and converts it to a fire retardant. The magnesium chloride will be loaded into two (2) sealed tanks where it is blended with additives. The additives are introduced by a vacuum pump, which pulls the powdered additives from the bottom of the hoppers using a negative pressure zone and deposits them into the bottom of the mixing tanks. Emissions from the two (2) hoppers are processed by a baghouse. Inside the tanks, the magnesium chloride is mixed with the additives. The viscous fluid will then be transported to a holding tank to await loadout. 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) Ammonia 0 6.02 CO2 Equivalent 0 225583.00 Carbon Monoxide 0 161.36 Nitrogen Oxides 0 38.66 Particulate Matter - PM10 0 285.60 Particulate Matter - PM10 (Fugitives) 0 79.76 Particulate Matter - PM2.5 0 131.75 Particulate Matter - PM2.5 (Fugitives) 0 9.71 Sulfur Dioxide 0 2.88 Volatile Organic Compounds 0 51.47 Volatile Organic Compounds - Fugitive 0 10.87 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Benzene (Including Benzene From Gasoline) (CAS #71432) 0 8 Cadmium (CAS #7440439) 0 4 Chlorine (CAS #7782505) 0 6132 Chloroform (CAS #67663) 0 43832 Chromium Compounds (CAS #CMJ500) 0 5 Formaldehyde (CAS #50000) 0 4313 Generic HAPs (CAS #GHAPS) 0 4 DAQE-IN109170049-24 Page 5 Hexane (CAS #110543) 0 6774 Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 58867 Manganese Compounds (CAS #MAR500) 0 1 Methanol (CAS #67561) 0 6432 Naphthalene (CAS #91203) 0 2 Nickel Compounds (CAS #NDB000) 0 8 Toluene (CAS #108883) 0 13 Change (TPY) Total (TPY) Total HAPs 0 63.20 PUBLIC NOTICE STATEMENT The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Ogden Standard Examiner on April 3, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received. SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the five-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 five (5) years. [R307-401-8] DAQE-IN109170049-24 Page 6 I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director every 18 months from the date of this AO until construction is completed to demonstrate reasonable construction progress. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT II.A.1 Production Plant Salt, Magnesium Chloride, and SOP II.A.2 Dryer 501 (D-501) Location: Salt Plant Capacity: 51 MMBtu/hr Fuel Type: Natural Gas Controlled by wet scrubber (AH-513) II.A.3 Dryer 1400 (D-1400) Location: SOP Plant Capacity: 51 MMBtu/hr Fuel Type: Natural Gas Controlled by baghouse (BH-1400) II.A.4 Dryer 1545 (D-1545) Location: SOP Plant - Compaction Capacity: 30 MMBtu/hr Fuel Type: Natural Gas Controlled by baghouse (BH-008) DAQE-IN109170049-24 Page 7 II.A.5 Wet Scrubber (AH-500) Location: Salt Plant Controls: Coolers, Bins & Hoppers, Conveyors, Crushers & Grinders, Feeders & Baggers, Mixers, Presses, and Rail Loading Mechanically Aided II.A.6 Baghouse (BH-501) Location: Salt Plant Controls: Fluidized bed cooler II.A.7 Wet Scrubber (AH-502) Location: Salt Plant Controls: Bins & Hoppers, Conveyors, Elevators, and Screens Mechanically Aided II.A.8 Baghouse (BH-502) Location: Salt Plant Controls: Bins & Hoppers, Elevators, and truck loading operations II.A.9 Baghouse (BH-503) Location: Salt Plant Controls: Material handling in the salt special products system II.A.10 Baghouse (BH-505) Location: Salt Plant Controls: Material handling in the salt packing area Equipped with HEPA Filter and vented indoors. II.A.11 Wet Scrubber with Cyclone (AH-513) Location: Salt Plant Controls: Salt Dryer (D-501) Mechanically Aided with Variable Frequency Drive (VFD) II.A.12 Venturi Wet Scrubber (AH-692) Location: Magnesium Chloride Plant Controls: Bins & Hoppers, Conveyors, Crushers & Grinders, Elevators, Feeders & Baggers, and Screens II.A.13 Baghouse (BH-001) Location: SOP Plant Controls: Bins & Hoppers, Screens, and Truck and Rail loading operations II.A.14 Baghouse (BH-002) Location: SOP Plant Controls: Bins & Hoppers, Conveyors, Elevators, and Screens II.A.15 Baghouse with Cyclone (BH-008) Location: SOP Plant Controls: Conveyor and SOP Compaction Dryer (D-1545) II.A.16 Baghouse with Cyclones (BH-1400) Location: SOP Plant Controls: Bins & Hoppers, Conveyors, Elevators, Screens, and SOP Dryer (D-1400) II.A.17 Bin Vent Filter (BH-1505) Location: SOP Plant Controls: Bins & Hoppers DAQE-IN109170049-24 Page 8 II.A.18 Baghouse (BH-1516) Location: SOP Plant Controls: Bins & Hoppers, Conveyors, Elevators, and Screens II.A.19 Wet Scrubber (AH-1555) Location: SOP Plant Controls: Bins & Hoppers, Conveyors, and Elevators Mechanically Aided with VFD II.A.20 Two (2) Boilers Capacity: 108.11 MMBtu/hr (each) Fuel Type: Natural Gas Installed Controls: Ultra-Low NOx burner and flue gas re-circulation Monitoring: Continuous Emission Monitoring System (CEMS) NSPS Applicability: Subpart Db II.A.21 Submerged Combustion Water Heater (SC-450) Location: SOP Plant Capacity: 30 MMBtu/hr Fuel: Natural Gas II.A.22 Submerged Combustion Water Heater (SC-460) Location: SOP Plant Capacity: 60 MMBtu/hr Fuel: Natural Gas II.A.23 Four (4) Magnesium Chloride Evaporators Two (2) operating units with one (1) primary and one (1) secondary evaporator each Location: Magnesium Chloride Plant II.A.24 Two (2) Cooling Towers (CT-003 & CT-004) Location: SOP Plant Re-circulation rate: 1500 gpm II.A.25 Cooling Tower (CT-639) Location: Magnesium Chloride Plant Re-circulation rate: 212 gpm II.A.26 Abrasive Blasting Capacity: 50 lb/hr II.A.27 Emergency Generator Engine (GN-100) Rating: 610 hp Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.28 Emergency Generator Engines (GN-200 & GN-300) Quantity: Two (2) Rating: 41 hp Fuel: Propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ DAQE-IN109170049-24 Page 9 II.A.29 Emergency Generator Engine (GN-1200) Rating: 402 hp Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.30 Emergency Generator Engine (GN-1300) Rating: 161 hp Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.31 Emergency Generator Engine (GN-007) Rating: 235 hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.32 Emergency Generator Engine (GN-500) Rating: less than 100 hp Fuel: Propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.33 Cooling Belt Fan (AH-696) Location: Magnesium Chloride Plant II.A.34 Fuel Tanks Fuel: Gasoline Quantity: One (1) Capacity: 6,000 gallons Fuel: Diesel Quantity: Two (2) Capacity: 10,000 gallons (each) II.A.35 SOP Silo Building Various Storage Silos Quantity: Eleven (11) Location: SOP Plant Controls: Fifteen (15) dust torit cartridge filters; internally vented II.A.36 Dome Silos (12, 13, and 14) Location: SOP Plant II.A.37 Fully Enclosed Conveyors Location: SOP Plant ID's: OC014, OC015, OC1404, OC1405, OC1406, OC1501, OC1550A, OC283, OC284, OC294, OC298, OF012, OF013 II.A.38 Partially Enclosed Conveyors Location: SOP Plant ID: OC276, OC277/214, OC279, OC280, OC281 Location: Salt Plant ID: OC503 II.A.39 Various Conveyors and Bucket Elevators Location: Facility Wide DAQE-IN109170049-24 Page 10 II.A.40 Various Bins and Hoppers Location: Facility Wide II.A.41 Various Screens, Grinders, and Crushers II.A.42 Fortress Equipment Two (2) hoppers controlled by baghouse Two (2) mixing tanks Two (2) holding tanks SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site Wide Requirements II.B.1.a Unless otherwise specified in this AO, visible emissions from any stationary and fugitive emission source shall not exceed 10 percent opacity. This includes, but is not limited to, all wet scrubbers and all baghouses. [R307-401-8] DAQE-IN109170049-24 Page 11 II.B.1.a.1 Monitoring: A. Except as noted in B through D below, a visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. For baghouses subject to 40 CFR Part 64, the owner/operator shall designate one (1) of the weekly opacity surveys to demonstrate compliance with the monthly survey requirement in this condition. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. B. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. C. For emission units located within a building, the requirements of paragraph A apply to each affected emission unit located within a building or for the building itself. If visible emissions from a building are monitored, the requirements of paragraph A apply to each side, roof, and vent of the building. The affected emission unit(s) shall be operating when monitoring is performed on the unit located within a building or on the building itself. D. The owner/operator is not required to perform monthly surveys on natural gas combustion sources, cooling towers, magnesium chloride evaporators, and petroleum storage tanks. [R307-401-8] II.B.1.a.2 Recordkeeping The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.2 Salt Plant Requirements II.B.2.a The following production limits shall not be exceeded: A. 700,000 tons of road salt produced per rolling 12-month period. B. 960,000 tons of dried salt produced per rolling 12-month period. [R307-401-8] DAQE-IN109170049-24 Page 12 II.B.2.a.1 The owner/operator shall demonstrate compliance with the rolling 12-month total for each production limit. 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 of production shall be kept for all periods when the plant is in operation. Production records shall be determined by examination of sales, billing records, or operation logs. The records of production shall be kept on a daily basis. [R307-401-8] II.B.2.b Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity: A. All loading operations. B. All conveyor drop points. C. All conveyor transfer points. D. All bin vents. E. All storage piles. F. All partially enclosed conveyance systems. G. All material handling operations, which include the following: bins and hoppers, screens, crushers, grinders, and presses. [R307-401-8] II.B.2.b.1 Monitoring A visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance with 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. [R307-401-8] II.B.2.b.2 Recordkeeping The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] DAQE-IN109170049-24 Page 13 II.B.2.c Emissions to the atmosphere from the baghouses and wet scrubbers located at the Salt Plant for PM10 and PM2.5 shall not exceed the following rates and concentrations. Compliance with the limits shall be based on an average of 3 test runs and shall include both filterable and condensable emissions (standardized at 68 °F, 29.92 in Hg): Emission Point PM10 Emission Rate PM2.5 Emission Rate PM2.5 Concentration (lb/hr) (lb/hr) (grains/dscf) AH-500 1.61 1.61 0.01 AH-502 1.12 0.74 0.04 AH-513 1.49 1.49 0.0114 BH-501 1.30 1.15 0.01 BH-502 0.20 0.06 0.0053 BH-503 1.54 0.23 0.01 [R307-401-8] II.B.2.c.1 Testing Frequency Compliance testing shall be done on each emission source at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-401-8] II.B.2.c.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.2.c.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] II.B.2.c.4 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] DAQE-IN109170049-24 Page 14 II.B.2.c.5 Source Operation The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days). B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.2.c.6 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods acceptable to the Director. [R307-165] II.B.2.c.7 PM10/PM2.5 For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201a, or other EPA-approved testing method, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or other EPA-approved testing methods as acceptable to the Director. When demonstrating compliance with the PM10 and PM2.5 limits above, all filterable particulate emissions captured using Method 5 shall be considered PM2.5, resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing analytical methods, such as x-ray diffraction, scanning electron microscopy, or electron microprobe analysis, may be used to determine particle sizing, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-165] II.B.2.c.8 Results The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.2.d The owner/operator shall vent Baghouse 505 (BH-505) indoors at all times during operation. [R307-401-8] DAQE-IN109170049-24 Page 15 II.B.3 Magnesium Chloride Plant Requirements II.B.3.a The following production limits shall not be exceeded: A. 1,000,000 tons of magnesium chloride liquid produced from ponds per rolling 12-month period. B. 70,080 tons of magnesium chloride flake produced per rolling 12-month period. [R307-401-8] II.B.3.a.1 The owner/operator shall demonstrate compliance with the rolling 12-month total for each production limit. 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 of production shall be kept for all periods when the plant is in operation. Production records shall be determined by examination of sales, billing records, or operation logs. The records of production shall be kept on a daily basis. [R307-401-8] II.B.3.b Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity: A. All loading operations. B. All conveyor drop points. C. All conveyor transfer points. D. All storage piles. E. All partially enclosed conveyance systems. F. All material handling operations which includes the following: bins and hoppers, screens, crushers, grinders, and presses. [R307-401-8] II.B.3.b.1 Monitoring A visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance with 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. [R307-401-8] DAQE-IN109170049-24 Page 16 II.B.3.b.2 Recordkeeping The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time of the visual emissions observed, emission point location and description, time and date of the opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.3.c With the exception of periods of startup, shutdown and maintenance, the owner/operator shall only operate one (1) set of two (2) evaporators at any one (1) time. [R307-401-8] II.B.3.d The owner/operator shall not exceed 8,760 hours of operation combined from the two (2) sets of evaporators per rolling 12-month period. Periods of startup, steady-state, and shutdown are to be included in this limit. Steam cleaning operations, where no chlorine is being added to the evaporators, are not considered part of this operational limit. [R307-401-8] II.B.3.d.1 The owner/operator shall demonstrate compliance with the rolling 12-month total by tracking the hours of operation for each set of evaporators. 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 of the hours of operation shall be kept for all periods when the plant is in operation. The records of operation shall be kept on a daily basis and include startup, steady-state, and shutdown operational times. [R307-401-8] II.B.3.e Emissions to the atmosphere from the wet scrubber located at the Magnesium Chloride Plant for PM10 and PM2.5 shall not exceed the following rates and concentrations: Compliance with the limits shall be based on an average of three (3) test runs and shall include both filterable and condensable emissions (standardized at 68 °F, 29.92 in Hg): Emission Point PM10 Emission Rate PM2.5 Emission Rate PM2.5 Concentration (lb/hr) (lb/hr) (grains/dscf) AH-692 0.15 0.12 0.01 Combined emissions to the atmosphere from each set of two (2) Magnesium Chloride Plant Evaporators for VOC and HCl shall not exceed the following rates: Compliance with the limit shall be based on an average of three (3) test runs: Emission Point VOC Emission Rate HCl Emission Rate (lb/hr) (lb/hr) MgCl2 Evaporators 6.18 6.40 [R307-401-8] II.B.3.e.1 Testing Frequency Compliance testing for AH-692 shall be performed at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. Compliance testing for both VOC and HCl shall be performed at least once every three (3) years for each train of the Magnesium Chloride Evaporators. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-165] DAQE-IN109170049-24 Page 17 II.B.3.e.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.3.e.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] II.B.3.e.4 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.3.e.5 Source Operation The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days) for the AH-692 scrubber, or the previous three (3) years for the magnesium chloride evaporators. B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.3.e.6 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods acceptable to the Director. [R307-165] DAQE-IN109170049-24 Page 18 II.B.3.e.7 PM10/PM2.5 For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201a, or other EPA-approved testing method, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or other EPA-approved testing methods as acceptable to the Director. When demonstrating compliance with the PM10 and PM2.5 limits above, all filterable particulate emissions captured using Method 5 shall be considered PM2.5, resulting in PM10 emissions equal to those of PM2.5. Alternatively, appropriate particle sizing analytical methods, such as x-ray diffraction, scanning electron microscopy, or electron microprobe analysis, may be used to determine particle sizing, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-165] II.B.3.e.8 Volatile Organic Compounds (VOCs) VOC emissions shall be determined using 40 CFR 60, App. A, Method 25A, using a flame ionization analyzer equipped with a methane separator. If such an analyzer is unavailable, VOC emissions shall be determined simultaneously using two (2) analyzers, with one (1) configured to read only methane. The difference between the total organic detector and the methane detector shall constitute the VOC measurement. [R307-165] II.B.3.e.9 HCl HCl emissions shall be determined using 40 CFR 60, Appendix A, Method 26, or 26A or other EPA-approved testing method acceptable to the Director. [R307-401-8] II.B.3.e.10 Results The results of stack testing shall be submitted to the Director within 60 days of the completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.4 SOP Plant Requirements II.B.4.a The following production and operation limits shall not be exceeded: A. 5,300,000 tons of potash harvested from ponds per rolling 12-month period. B. 1,680,000 tons of SOP produced per rolling 12-month period. C. 432,000 tons of KCl used per rolling 12-month period. [R307-401-8] II.B.4.a.1 The owner/operator shall demonstrate compliance with the rolling 12-month total for each production limit. 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 of production shall be kept for all periods when the plant is in operation. Production records shall be determined by operation logs. The records of production shall be kept on a daily basis. [R307-401-8] DAQE-IN109170049-24 Page 19 II.B.4.b Visible emissions from all outdoor storage silos shall not exceed 10% opacity. Egress points to the dome silos shall remain closed at all times, except when mobile equipment is actively entering or exiting the silo during loading or unloading operations. [R307-401-8] II.B.4.b.1 Monitoring A visual opacity survey of each affected emission unit shall be performed on a monthly basis while loading or unloading operations are occurring at the silo. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director. The opacity determination shall be performed while loading or unloading operations are occurring at the silo. [R307-401-8] II.B.4.b.2 Recordkeeping The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. Documentation of maintenance performed on the silos to ensure they operate as fully enclosed structures when egress points are closed shall also be kept in the log. [R307-401-8] II.B.4.c Visible emissions from all outdoor, fully enclosed conveyance systems shall not exceed 5% opacity. At all times, the owner/operator shall operate and maintain each affected emission unit as a fully enclosed conveyance system. Each fully enclosed conveyance system shall be fully enclosed on all sides, top, and bottom. All fully enclosed conveyance systems shall be clearly labeled on each conveyor such that an inspector/operator can safely identify equipment at any time. [R307-401-8] DAQE-IN109170049-24 Page 20 II.B.4.c.1 Monitoring The owner/operator shall conduct a Method 22 performance test, or other EPA-approved testing method, as acceptable to the Director, according to the following requirements for each affected emission unit. A. Conduct a weekly 10-minute visible emissions test of each affected emission unit in accordance with Method 22 of 40 CFR 60 Appendix A, or other EPA-approved testing method, as acceptable to the Director. The performance test shall be conducted while the unit is in operation. B. If any visible emissions are observed from an emission unit, the owner/operator shall inspect the affected emission unit to determine the cause of visible emissions and initiate corrective action within 1 hour of the initial survey. C. If no visible emissions are observed during four (4) consecutive weekly tests, the owner/operator may decrease the frequency of the visible emissions test required in paragraph (A) from weekly to monthly. If visible emissions are observed during any monthly test, the owner/operator shall resume the weekly visible emissions test required in paragraph (A) and maintain that schedule until no visible emissions are observed in four (4) consecutive weekly tests. [R307-401-8] II.B.4.c.2 Recordkeeping The owner/operator shall keep a log of the visible emissions tests that contains the following information: time and date of the test, emission point location and description, time of visible emissions, if observed, results of inspections, time and date of corrective actions initiated, and corrective actions taken. All data required by 40 CFR 60, Appendix A, Method 22, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.4.d Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity: A. All loadout operations. B. All storage piles. C. All material handling operations, which include the following: bins and hoppers, screens, crushers, grinders, and presses. D. All partially enclosed conveyance systems. E. All conveyor drop points. F. All conveyor transfer points. G. All bin vents. [R307-401-8] DAQE-IN109170049-24 Page 21 II.B.4.d.1 Monitoring A visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. [R307-401-8] II.B.4.d.2 Recordkeeping The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, and/or 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.4.e All partially enclosed conveyance systems shall be clearly labeled on each conveyor such that an inspector/operator can safely identify equipment at any time. [R307-401-8] II.B.4.f Emissions to the atmosphere from the baghouses and wet scrubbers located at the SOP Plant for PM10 and PM2.5 shall not exceed the following rates and concentrations: Compliance with the limits shall be based on an average of 3 test runs and shall include both filterable and condensable emissions (standardized at 68 °F, 29.92 in Hg): Emission Point PM10 Emission Rate PM2.5 Emission Rate PM2.5 Concentration (lb/hr) (lb/hr) (grains/dscf) AH-1555 2.61 0.39 0.01 BH-001 0.37 0.37 0.01 BH-002 0.65 0.47 0.01 BH-008 4.25 4.25 0.01 BH-1400 2.78 2.78 0.02 BH-1516 1.46 0.22 0.01 [R307-401-8] II.B.4.f.1 Testing Frequency Compliance testing shall be done on each emission source at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-401-8] DAQE-IN109170049-24 Page 22 II.B.4.f.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stacks to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.4.f.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] II.B.4.f.4 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.4.f.5 Source Operation The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days). B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.4.f.6 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods acceptable to the Director. [R307-165] DAQE-IN109170049-24 Page 23 II.B.4.f.7 PM10/PM2.5 For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201a, or other EPA-approved testing method, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or other EPA-approved testing methods as acceptable to the Director. When demonstrating compliance with the PM10 and PM2.5 limits above, all filterable particulate emissions captured using Method 5 shall be considered PM2.5, resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing analytical methods, such as x-ray diffraction, scanning electron microscopy, or electron microprobe analysis, may be used to determine particle sizing, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-165] II.B.4.f.8 Results The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] DAQE-IN109170049-24 Page 24 II.B.5 Boiler Requirements II.B.5.a NOx emissions to the atmosphere from each of the two (2) boilers on site shall not exceed the following rates and concentrations: Rate (lbs/hr) Concentration (ppm) 1.30 9.0 Compliance with the limit shall be based on an average of three (3) test runs. [R307-401-8] II.B.5.a.1 Testing Frequency Compliance testing shall be done on each emission source at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-401-8] II.B.5.a.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stacks to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.5.a.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] II.B.5.a.4 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.5.a.5 Source Operation The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days). B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] DAQE-IN109170049-24 Page 25 II.B.5.a.6 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods acceptable to the Director. [R307-165] II.B.5.a.7 Nitrogen Oxides NOx emissions shall be determined using 40 CFR 60 Appendix A, Method 7E, or other EPA-approved testing method, acceptable to the Director. [R307-165] II.B.5.a.8 Results The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.6 Dryer Requirements II.B.6.a Emissions to the atmosphere from each of the three (3) dryers on site (D-501, D-1400, and D- 1545) for NOx shall not exceed 20 ppm at 3% O2. Compliance with the limits shall be based on an average of 3 test runs. [R307-401-8] II.B.6.a.1 Testing Frequency Compliance testing shall be done on each emission source at least once every three (3)years. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-165] II.B.6.a.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stacks to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.6.a.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165] II.B.6.a.4 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director to give the results in the specified units of the emission limitation. [R307-165] DAQE-IN109170049-24 Page 26 II.B.6.a.5 Source Operation The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous three (3) years. B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.6.a.6 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2 or other EPA-approved testing methods acceptable to the Director. [R307-165] II.B.6.a.7 Nitrogen Oxides NOx emissions shall be determined using 40 CFR 60 Appendix A, Method 7E, or other EPA-approved testing method, acceptable to the Director. [R307-165] II.B.6.a.8 Results The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.7 Baghouse and Wet Scrubber Requirements II.B.7.a Each baghouse shall operate within the static pressure range recommended by the manufacturer for normal operations. The static pressure range shall be clearly labeled on each baghouse such that an inspector/operator can safely read the range at any time. Manometer or magnehelic pressure gauges shall be installed to measure the differential pressure across each of the baghouses. The pressure gauges shall be located such that an inspector/operator can safely read the indicator at any time. For baghouses that monitor pressure drop to demonstrate compliance with 40 CFR Part 64, the requirements in this condition shall not apply. [R307-401-8] II.B.7.a.1 Pressure drop readings from each baghouse shall be recorded at least once during each day of operation. Records documenting these inspections shall be kept in a log and shall include the following: A. Unit identification; B. Manufacturer recommended pressure drop for the unit; C. Daily pressure drop readings; and D. Date of bag replacements. [R307-401-8] DAQE-IN109170049-24 Page 27 II.B.7.a.2 The pressure gauges of each baghouse shall be calibrated in accordance with the manufacturer's instructions or recommendations at least once every 12 months. Documentation of calibrations shall be maintained for all periods the plant is in operation. [R307-401-8] II.B.7.b Each wet scrubber shall operate within the static pressure range and liquid flow rate recommended by the manufacturer for normal operations. These parameters shall be clearly labeled on each scrubber such that an inspector/operator can safely read the parameters at any time. Manometer or magnehelic pressure gauge shall be installed to measure the differential pressure across the wet scrubber. Flow rate meters shall be installed to measure the liquid flow rate in the scrubber. The pressure gauges and flow rate meters shall be located such that an inspector/operator can safely read the indicators at any time. For scrubbers that are subject to 40 CFR Part 64, the requirements in this condition shall not apply. [R307-401-8] II.B.7.b.1 Pressure drop and liquid flow rate readings from each wet scrubber shall be recorded at least once during each day of operation. Records documenting these inspections shall be kept in a log and shall include the following: A. Unit identification; B. Manufacturer recommended pressure drop and liquid flow rate for the unit; C. Daily pressure drop readings; and D. Daily liquid flow rate readings. [R307-401-8] II.B.7.b.2 The gauges and meters on each wet scrubber shall be calibrated in accordance with the manufacturer's instructions or recommendations at least once every 12 months. Documentation of calibrations shall be maintained for all periods the plant is in operation. For scrubbers that monitor liquid flow rate to demonstrate compliance with 40 CFR Part 64, the liquid flow rate requirements in this condition shall not apply. All other requirements in this condition remain applicable. [R307-401-8] II.B.8 Engine Requirements II.B.8.a Visible emissions from diesel-fired emergency generator engines shall not exceed 20% opacity. [R307-401-8] II.B.8.a.1 Monitoring A visual opacity survey of each affected emission unit shall be performed on a quarterly basis while the unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than steam are observed from an emission unit, a 6-minute opacity determination of that emission unit shall be performed by a certified observer within 1 hour of the initial survey. The opacity determination shall be performed while the unit is operating in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director. If the generator(s) continue to operate on consecutive days following the initial observation, a 6-minute opacity determination shall be performed by a certified observer on a daily basis while the unit is operating, in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director. [R307-401-8] DAQE-IN109170049-24 Page 28 II.B.8.a.2 Recordkeeping The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.8.b Visible emissions from propane-fired emergency generator engines shall not exceed 10% opacity. [R307-401-8] II.B.8.b.1 Monitoring In lieu of monitoring via visible emission observations, records shall be kept for any period that a fuel other than propane is used in the affected emission unit. [R307-401-8] II.B.8.b.2 Recordkeeping Records shall be kept in a log that is kept in a readily accessible location onsite. [R307-401-8] II.B.8.c The owner/operator shall use the emergency generator engines for electricity-producing operations only during the periods when electric power from the public utilities is interrupted. [R307-401-8] II.B.8.d The owner/operator shall track hours of operation for each emergency generator engine as required to comply with all applicable federal subparts. [40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.9 Fuel Requirements II.B.9.a The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the diesel fired engines on site. All diesel burned shall contain no more than 15 ppm sulfur. [R307-401-8] II.B.9.a.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the sulfur requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8] II.B.9.b The owner/operator shall only use propane as fuel in the propane fired engines on site. [R307-401-8] II.B.9.c The owner/operator shall use only pipeline quality natural gas as a fuel source for all boilers and burners. [R307-401-8] II.B.10 Haul Roads and Fugitive Dust Requirements II.B.10.a The owner/operator shall comply with all applicable requirements of R307-309 for PM10 and PM2.5 non-attainment areas for fugitive emissions and fugitive dust sources. At least once every three (3) years, the fugitive dust control plan shall be reviewed and evaluated. If site modifications that result in emission changes have been made, an updated fugitive dust control plan shall be submitted as required by R307-309-6(3). [R307-309, R307-401-8] II.B.10.b Visible emissions in disturbed, operational areas, and unpaved haul roads from haul trucks and other mobile equipment shall not exceed 20% opacity at any point. [R307-401-8] II.B.10.b.1 In lieu of monitoring via visible emissions observations, adherence to the most recently approved fugitive dust control plan shall be monitored to demonstrate that the opacity limit is not exceeded and that appropriate measures are being implemented to control fugitive dust. [R307-309, R307-401-8] DAQE-IN109170049-24 Page 29 II.B.10.c Vehicles speeds shall be limited to 30 miles per hour on haul roads and 15 miles per hour in off-road areas. The vehicle speed limits shall be clearly visible and posted, at a minimum, on site at the entrance to off-road areas and the beginning of the haul road. [R307-401-8] II.B.10.d The owner/operator shall spray all unpaved haul roads with water, brine, or a chemical suppressant to control fugitive dust and maintain the opacity limit listed in this AO. [R307-401-8] II.B.10.d.1 Records of water or chemical treatment shall be kept for all periods when the plant is in operation. The owner/operator may stop applying suppressants when the temperature is below freezing. The records shall include the following: A. Date. B. Location of treatment. C. Rainfall received, if any, and approximate amount. D. Records of temperature if the temperature is below freezing. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN109170044-23 dated March 2, 2023 Is Derived From Source Submitted NOI dated February 12, 2024 Is Derived From Source Submitted NOI dated February 20, 2024 DAQE-IN109170049-24 Page 30 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- NN109170049-24 April 1, 2024 Ogden Standard Examiner Legal Advertising Dept. Standard Way P.O. Box 12790332 Ogden, UT 84412 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Ogden Standard Examiner (Account Number: 100331)on April 3, 2024. Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any questions, contact Jeree Greenwood, who may be reached at (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Weber County cc: Wasatch Front Regional Council 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director DAQE-NN109170049-24 Page 2 NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Compass Minerals Ogden Incorporated Location: Compass Minerals Ogden Incorporated - Production Plant – 765 North 10500 West, Ogden, UT Project Description: Compass Minerals (Compass) has requested a change to its current Approval Order DAQE-AN109170044-23. The current salt harvesting throughput limit is redundant with the two (2) limits on processed salt products. Although the potential exists for additional salt harvesting, the material contains residual magnesium chloride (a dust suppressant) and maintains a high moisture content, (further limiting or eliminating fugitive dust emissions). Condition II.B.2.a(A), which limits the total salt harvest amount, is unnecessary and is being removed. As part of this project, Compass also wishes to include a previously submitted project. This other project involves the inclusion of equipment and processes from Fortress North America, which was recently acquired by Compass. Harvested magnesium chloride from the existing Compass Minerals processes and converts it to a fire retardant. The magnesium chloride will be loaded into two (2) sealed tanks where it is blended with additives. The additives are introduced by a vacuum pump, which pulls the powdered additives from the bottom of the hoppers using a negative pressure zone and deposits them into the bottom of the mixing tanks. Emissions from the two (2) hoppers are processed by a baghouse. Inside the tanks, the magnesium chloride is mixed with the additives. The viscous fluid will then be transported to a holding tank to await loadout. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before May 3, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at jjenks@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: April 3, 2024 {{#s=Sig_es_:signer1:signature}} 4/3/24, 9:28 AM utahlegals.com/(S(5ledariamq0m3ckpvotkvcgu))/DetailsPrint.aspx?SID=5ledariamq0m3ckpvotkvcgu&ID=182029 https://www.utahlegals.com/(S(5ledariamq0m3ckpvotkvcgu))/DetailsPrint.aspx?SID=5ledariamq0m3ckpvotkvcgu&ID=182029 1/1 Standard Examiner Publication Name: Standard Examiner Publication URL: www.standard.net Publication City and State: Ogden, UT Publication County: Weber Notice Popular Keyword Category: Notice Keywords: compass Notice Authentication Number: 202404031028194117290 3429962642 Notice URL: Back Notice Publish Date: Wednesday, April 03, 2024 Notice Content NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Compass Minerals Ogden Incorporated Location: Compass Minerals Ogden Incorporated - Production Plant - 765 North 10500 West, Ogden, UT Project Description: Compass Minerals (Compass) has requested a change to its current Approval Order DAQE-AN109170044-23. The current salt harvesting throughput limit is redundant with the two (2) limits on processed salt products. Although the potential exists for additional salt harvesting, the material contains residual magnesium chloride (a dust suppressant) and maintains a high moisture content, (further limiting or eliminating fugitive dust emissions). Condition II.B.2.a(A), which limits the total salt harvest amount, is unnecessary and is being removed. As part of this project, Compass also wishes to include a previously submitted project. This other project involves the inclusion of equipment and processes from Fortress North America, which was recently acquired by Compass. Harvested magnesium chloride from the existing Compass Minerals processes and converts it to a fire retardant. The magnesium chloride will be loaded into two (2) sealed tanks where it is blended with additives. The additives are introduced by a vacuum pump, which pulls the powdered additives from the bottom of the hoppers using a negative pressure zone and deposits them into the bottom of the mixing tanks. Emissions from the two (2) hoppers are processed by a baghouse. Inside the tanks, the magnesium chloride is mixed with the additives. The viscous fluid will then be transported to a holding tank to await loadout. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before May 3, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at jjenks@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: April 3, 2024 Legal Notice 12704 Published in the Standard Examiner on April 3, 2024 Back DAQE- RN109170049 March 18, 2024 Kenneth Potts Compass Minerals Ogden Inc. 9900 W 109th St. Overland Park, KS 66210 taylorjo@compassminerals.com Dear Kenneth Potts, Re: Engineer Review: Modification to Approval Order DAQE-AN109170044-23 to Remove Salt Harvesting Limit and add Fortress Equipment Project Number: N109170049 Please review and sign this letter and attached Engineer Review (ER) within 10 business days. For this document to be considered as the application for a Title V administrative amendment, a Title V Responsible Official must sign the next page. Please contact John Jenks at (385) 306-6510 if you have any questions or concerns about the ER. If you accept the contents of this ER, please email this signed cover letter to John Jenks at jjenks@utah.gov. After receipt of the signed cover letter, the DAQ will prepare an Intent to Approve (ITA) for a 30-day public comment period. When the public comment period ends, the DAQ will consider any comments received and will issue the Approval Order. If you do not respond to this letter within 10 business days, the project will move forward without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 1 OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be considered as an application to administratively amend your Title V Permit, the Responsible Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY OPTIONAL. If you do not want the Engineer Review to be considered as an application to administratively amend your Operating Permit only the approval signature above is required. Failure to have the Responsible Official sign below will not delay the Approval Order, but will require submittal of a separate Operating Permit Application to revise the Title V permit in accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document: Title V Operating Permit Application Due Dates clarifies the required due dates for Title V operating permit applications and can be viewed at: https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality “Based on information and belief formed after reasonable inquiry, I certify that the statements and information provided for this Approval Order are true, accurate and complete and request that this Approval Order be considered as an application to administratively amend the Operating Permit.” Responsible Official _________________________________________________ (Signature & Date) Print Name of Responsible Official _____________________________________ Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 2 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N109170049 Owner Name Compass Minerals Ogden Inc. Mailing Address 9900 W 109th St. Overland Park, KS, 66210 Source Name Compass Minerals Ogden Inc. - Production Plant Source Location 765 N 10500 W Ogden, UT 84404-0000 UTM Projection 396,869 m Easting, 4,570,651 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2819 (Industrial Inorganic Chemicals, NEC) Source Contact Jordan Taylor Phone Number (913) 344-9225 Email taylorjo@compassminerals.com Billing Contact Kenneth Potts Phone Number (801) 732-3312 Email pottsk@compassminerals.com Project Engineer John Jenks, Engineer Phone Number (385) 306-6510 Email jjenks@utah.gov Notice of Intent (NOI) Submitted February 20, 2024 Date of Accepted Application March 8, 2024 Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 3 SOURCE DESCRIPTION General Description Compass Minerals Ogden Inc. (Compass) harvests and processes salt and minerals from the Great Salt Lake to produce sulfate of potash (SOP), salt, and magnesium chloride. NSR Classification: Minor Modification at Major Source Source Classification Located in , Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Weber County Airs Source Size: A Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Db: Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines MACT (Part 63), DDDDD: National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters Title V (Part 70) Major Source Project Proposal Modification to Approval Order DAQE-AN109170044-23 to Remove Salt Harvesting Limit and add Fortress Equipment Project Description Compass Minerals (Compass) has requested a change to its current AO DAQE-AN109170044- 23. The current salt harvesting throughput limit is redundant with the two limits on processed salt products. Although the potential exists for additional salt harvesting, the material contains residual magnesium chloride (a dust suppressant) and maintains a high moisture content (further limiting or eliminating fugitive dust emissions). Condition II.B.2.a(A), which limits the total salt harvest amount, is unnecessary and is being removed. As part of this project, Compass also wishes to include a previously submitted project. This other project involves the inclusion of equipment and processes from Fortress North America, which was recently acquired by Compass. Harvested magnesium chloride from the existing Compass Minerals processes and converts it to a fire retardant. The magnesium chloride will be loaded into two sealed tanks where it is blended with additives. The additives are introduced by a vacuum pump which pulls the powdered additives from the bottom of the hoppers using a negative pressure zone and deposits them into the bottom of the mixing tanks. Emissions from the two hoppers are processed by a baghouse. Inside the tanks, the magnesium chloride is mixed with the additives. The viscous fluid will then be transported to a holding tank to await loadout. Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 4 EMISSION IMPACT ANALYSIS The total change in emissions from this project is 0.003 tpy of particulates (PM, PM10 and PM2.5). This increase is not subject to modeling under R307-410-4. [Last updated March 18, 2024] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 5 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) Ammonia 0 6.02 CO2 Equivalent 0 225583.00 Carbon Monoxide 0 161.36 Nitrogen Oxides 0 38.66 Particulate Matter - PM10 0 285.60 Particulate Matter - PM10 (Fugitives) 0 79.76 Particulate Matter - PM2.5 0 131.75 Particulate Matter - PM2.5 (Fugitives) 0 9.71 Sulfur Dioxide 0 2.88 Volatile Organic Compounds 0 51.47 Volatile Organic Compounds - Fugitive 0 10.87 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Benzene (Including Benzene From Gasoline) (CAS #71432) 0 8 Cadmium (CAS #7440439) 0 4 Chlorine (CAS #7782505) 0 6132 Chloroform (CAS #67663) 0 43832 Chromium Compounds (CAS #CMJ500) 0 5 Formaldehyde (CAS #50000) 0 4313 Generic HAPs (CAS #GHAPS) 0 4 Hexane (CAS #110543) 0 6774 Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 58867 Manganese Compounds (CAS #MAR500) 0 1 Methanol (CAS #67561) 0 6432 Naphthalene (CAS #91203) 0 2 Nickel Compounds (CAS #NDB000) 0 8 Toluene (CAS #108883) 0 13 Change (TPY) Total (TPY) Total HAPs 0 63.20 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 6 Review of BACT for New/Modified Emission Units 1. BACT review regarding combined project BACT For the removal of the salt harvesting throughput, there is no physical change or change in the method of operation of any of the equipment; thus no review of BACT is required. Although the removal of the salt harvesting limit could potentially allow for additional fugitive dust, the harvested salt is inherently low emitting, and no additional controls have been identified for control of fugitive dusts. For the inclusion of the Fortress North America equipment, Compass has proposed the use of a baghouse to control particulate emissions from the two additives hoppers. As all other equipment associated with this process is the blending, storage and conveying of non-volatile liquid materials, no other emissions have been identified. The small amount of particulate emissions from the hoppers (less than 0.003 tpy) are most appropriately controlled by a baghouse. UDAQ agrees with these conclusions. [Last updated March 18, 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 five-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 five (5) years. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 7 I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307- 401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307- 150] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Production Plant Salt, Magnesium Chloride, and SOP II.A.2 Dryer 501 (D-501) Location: Salt Plant Capacity: 51 MMBtu/hr Fuel Type: Natural Gas Controlled by wet scrubber (AH-513) II.A.3 Dryer 1400 (D-1400) Location: SOP Plant Capacity: 51 MMBtu/hr Fuel Type: Natural Gas Controlled by baghouse (BH-1400) II.A.4 Dryer 1545 (D-1545) Location: SOP Plant - Compaction Capacity: 30 MMBtu/hr Fuel Type: Natural Gas Controlled by baghouse (BH-008) Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 8 II.A.5 Wet Scrubber (AH-500) Location: Salt Plant Controls: Coolers, Bins & Hoppers, Conveyors, Crushers & Grinders, Feeders & Baggers, Mixers, Presses, and Rail Loading Mechanically Aided II.A.6 Baghouse (BH-501) Location: Salt Plant Controls: Fluidized bed cooler II.A.7 Wet Scrubber (AH-502) Location: Salt Plant Controls: Bins & Hoppers, Conveyors, Elevators, and Screens Mechanically Aided II.A.8 Baghouse (BH-502) Location: Salt Plant Controls: Bins & Hoppers, Elevators, and truck loading operations II.A.9 Baghouse (BH-503) Location: Salt Plant Controls: Material handling in the salt special products system II.A.10 Baghouse (BH-505) Location: Salt Plant Controls: Material handling in the salt packing area Equipped with HEPA Filter and vented indoors. II.A.11 Wet Scrubber with Cyclone (AH-513) Location: Salt Plant Controls: Salt Dryer (D-501) Mechanically Aided with Variable Frequency Drive (VFD) II.A.12 Venturi Wet Scrubber (AH-692) Location: Magnesium Chloride Plant Controls: Bins & Hoppers, Conveyors, Crushers & Grinders, Elevators, Feeders & Baggers, and Screens II.A.13 Baghouse (BH-001) Location: SOP Plant Controls: Bins & Hoppers, Screens, and Truck and Rail loading operations II.A.14 Baghouse (BH-002) Location: SOP Plant Controls: Bins & Hoppers, Conveyors, Elevators, and Screens II.A.15 Baghouse with Cyclone (BH-008) Location: SOP Plant Controls: Conveyor and SOP Compaction Dryer (D-1545) Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 9 II.A.16 Baghouse with Cyclones (BH-1400) Location: SOP Plant Controls: Bins & Hoppers, Conveyors, Elevators, Screens, and SOP Dryer (D-1400) II.A.17 Bin Vent Filter (BH-1505) Location: SOP Plant Controls: Bins & Hoppers II.A.18 Baghouse (BH-1516) Location: SOP Plant Controls: Bins & Hoppers, Conveyors, Elevators, and Screens II.A.19 Wet Scrubber (AH-1555) Location: SOP Plant Controls: Bins & Hoppers, Conveyors, and Elevators Mechanically Aided with VFD II.A.20 Two Boilers Capacity: 108.11 MMBtu/hr (each) Fuel Type: Natural Gas Installed Controls: Ultra-Low NOx burner and flue gas re-circulation Monitoring: Continuous Emission Monitoring System (CEMS) NSPS Applicability: Subpart Db II.A.21 Submerged Combustion Water Heater (SC-450) Location: SOP Plant Capacity: 30 MMBtu/hr Fuel: Natural Gas II.A.22 Submerged Combustion Water Heater (SC-460) Location: SOP Plant Capacity: 60 MMBtu/hr Fuel: Natural Gas II.A.23 Four Magnesium Chloride Evaporators Two operating units with one primary and one secondary evaporator each Location: Magnesium Chloride Plant II.A.24 Two Cooling Towers (CT-003 & CT-004) Location: SOP Plant Re-circulation rate: 1500 gpm II.A.25 Cooling Tower (CT-639) Location: Magnesium Chloride Plant Re-circulation rate: 212 gpm II.A.26 Abrasive Blasting Capacity: 50 lb/hr Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 10 II.A.27 Emergency Generator Engine (GN-100) Rating: 610 hp Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.28 Emergency Generator Engines (GN-200 & GN-300) Quantity: Two Rating: 41 hp Fuel: Propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.29 Emergency Generator Engine (GN-1200) Rating: 402 hp Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.30 Emergency Generator Engine (GN-1300) Rating: 161 hp Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.31 Emergency Generator Engine (GN-007) Rating: 235 hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.32 Emergency Generator Engine (GN-500) Rating: less than 100 hp Fuel: Propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.33 Cooling Belt Fan (AH-696) Location: Magnesium Chloride Plant II.A.34 Fuel Tanks Fuel: Gasoline Quantity: One Capacity: 6,000 gallons Fuel: Diesel Quantity: Two Capacity: 10,000 gallons (each) Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 11 II.A.35 SOP Silo Building Various Storage Silos Quantity: 11 Location: SOP Plant Controls: Fifteen dust torit cartridge filters; internally vented II.A.36 Dome Silos (12, 13, and 14) Location: SOP Plant II.A.37 Fully Enclosed Conveyors Location: SOP Plant ID's: OC014, OC015, OC1404, OC1405, OC1406, OC1501, OC1550A, OC283, OC284, OC294, OC298, OF012, OF013 II.A.38 Partially Enclosed Conveyors Location: SOP Plant ID: OC276, OC277/214, OC279, OC280, OC281 Location: Salt Plant ID: OC503 II.A.39 Various Conveyors and Bucket Elevators Location: Facility Wide II.A.40 Various Bins and Hoppers Location: Facility Wide II.A.41 Various Screens, Grinders, and Crushers II.A.42 NEW Fortress Equipment Two hoppers controlled by baghouse Two mixing tanks Two holding tanks 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 Unless otherwise specified in this AO, visible emissions from any stationary and fugitive emission source shall not exceed 10 percent opacity. This includes, but is not limited to, all wet scrubbers and all baghouses. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 12 II.B.1.a.1 Monitoring: A. Except as noted in B through D below, a visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. For baghouses subject to 40 CFR Part 64, the owner/operator shall designate one of the weekly opacity surveys to demonstrate compliance with the monthly survey requirement in this condition. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. B. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. C. For emission units located within a building, the requirements of paragraph A apply to each affected emission unit located within a building or for the building itself. If visible emissions from a building are monitored, the requirements of paragraph A apply to each side, roof, and vent of the building. The affected emission unit(s) shall be operating when monitoring is performed on the unit located within a building or on the building itself. D. The owner/operator is not required to perform monthly surveys on natural gas combustion sources, cooling towers, magnesium chloride evaporators, and petroleum storage tanks. [R307-401-8] II.B.1.a.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA- approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.2 Salt Plant Requirements Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 13 II.B.2.a NEW The following production limits shall not be exceeded: A. 700,000 tons of road salt produced per rolling 12-month period B. 960,000 tons of dried salt produced per rolling 12-month period [R307-401-8] II.B.2.a.1 The owner/operator shall demonstrate compliance with the rolling 12-month total for each production limit. 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 of production shall be kept for all periods when the plant is in operation. Production records shall be determined by examination of sales, billing records, or operation logs. The records of production shall be kept on a daily basis. [R307-401-8] II.B.2.b Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity: A. All loading operations B. All conveyor drop points C. All conveyor transfer points D. All bin vents E. All storage piles F. All partially enclosed conveyance systems G. All material handling operations which includes the following: bins & hoppers, screens, crushers, grinders, and presses [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 14 II.B.2.b.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. [R307-401-8] II.B.2.b.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA- approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.2.c Emissions to the atmosphere from the baghouses and wet scrubbers located at the Salt Plant for PM10 and PM2.5 shall not exceed the following rates and concentrations. Compliance with the limits shall be based on an average of 3 test runs and shall include both filterable and condensable emissions (standardized at 68 °F, 29.92 in Hg): Emission Point PM10 Emission Rate PM2.5 Emission Rate PM2.5 Concentration (lb/hr) (lb/hr) (grains/dscf) AH-500 1.61 1.61 0.01 AH-502 1.12 0.74 0.04 AH-513 1.49 1.49 0.0114 BH-501 1.30 1.15 0.01 BH-502 0.20 0.06 0.0053 BH-503 1.54 0.23 0.01 [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 15 II.B.2.c.1 Testing Frequency Compliance testing shall be done on each emission source at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-401-8] II.B.2.c.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.2.c.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-165] II.B.2.c.4 Calculations To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 16 II.B.2.c.5 Source Operation The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days). B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.2.c.6 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods acceptable to the Director. [R307-165] II.B.2.c.7 PM10/PM2.5 For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201a, or other EPA-approved testing method, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or other EPA approved testing methods as acceptable to the Director. When demonstrating compliance with the PM10 and PM2.5 limits above, all filterable particulate emissions captured using Method 5 shall be considered PM2.5, resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing analytical methods, such as: x-ray diffraction, scanning electron microscopy, or electron microprobe analysis may be used to determine particle sizing, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-165] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 17 II.B.2.c.8 Results The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.2.d The owner/operator shall vent Baghouse 505 (BH-505) indoors at all times during operation. [R307-401-8] II.B.3 Magnesium Chloride Plant Requirements II.B.3.a The following production limits shall not be exceeded: A. 1,000,000 tons of magnesium chloride liquid produced from ponds per rolling 12-month period B. 70,080 tons of magnesium chloride flake produced per rolling 12-month period [R307-401-8] II.B.3.a.1 The owner/operator shall demonstrate compliance with the rolling 12-month total for each production limit. 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 of production shall be kept for all periods when the plant is in operation. Production records shall be determined by examination of sales, billing records, or operation logs. The records of production shall be kept on a daily basis. [R307-401-8] II.B.3.b Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity: A. All loading operations B. All conveyor drop points C. All conveyor transfer points D. All storage piles E. All partially enclosed conveyance systems F. All material handling operations which includes the following: bins & hoppers, screens, crushers, grinders, and presses [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 18 II.B.3.b.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. [R307-401-8] II.B.3.b.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA- approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.3.c With the exception of periods of startup, shutdown and maintenance, the owner/operator shall only operate one set of two evaporators at any one time. [R307-401-8] II.B.3.d The owner/operator shall not exceed 8,760 hours of operation combined from the two sets of evaporators per rolling 12-month period. Periods of startup, steady-state, and shutdown are to be included in this limit. Steam cleaning operations, where no chlorine is being added to the evaporators, are not considered part of this operational limit. [R307-401-8] II.B.3.d.1 The owner/operator shall demonstrate compliance with the rolling 12-month total by tracking the hours of operation for each set of evaporators. 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 of the hours of operation shall be kept for all periods when the plant is in operation. The records of operation shall be kept on a daily basis, and include startup, steady-state, and shutdown operational times. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 19 II.B.3.e Emissions to the atmosphere from the wet scrubber located at the Magnesium Chloride Plant for PM10 and PM2.5 shall not exceed the following rates and concentrations. Compliance with the limits shall be based on an average of 3 test runs and shall include both filterable and condensable emissions (standardized at 68 °F, 29.92 in Hg): Emission Point PM10 Emission Rate PM2.5 Emission Rate PM2.5 Concentration (lb/hr) (lb/hr) (grains/dscf) AH-692 0.15 0.12 0.01 Combined emissions to the atmosphere from each set of two Magnesium Chloride Plant Evaporators for VOC and HCl shall not exceed the following rates. Compliance with the limit shall be based on an average of 3 test runs: Emission Point VOC Emission Rate HCl Emission Rate (lb/hr) (lb/hr) MgCl2 Evaporators 6.18 6.40 [R307-401-8] II.B.3.e.1 Testing Frequency Compliance testing for AH-692 shall be performed at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. Compliance testing for both VOC and HCl shall be performed at least once every three years for each train of the Magnesium Chloride Evaporators. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-165] II.B.3.e.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.3.e.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-165] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 20 II.B.3.e.4 Calculations: To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.3.e.5 Source Operation: The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days) for the AH-692 scrubber, or the previous three (3) years for the magnesium chloride evaporators. B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.3.e.6 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods acceptable to the Director. [R307-165] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 21 II.B.3.e.7 PM10/PM2.5 For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201a, or other EPA-approved testing method, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or other EPA approved testing methods as acceptable to the Director. When demonstrating compliance with the PM10 and PM2.5 limits above, all filterable particulate emissions captured using Method 5 shall be considered PM2.5, resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing analytical methods, such as: x-ray diffraction, scanning electron microscopy, or electron microprobe analysis may be used to determine particle sizing, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-165] II.B.3.e.8 Volatile Organic Compounds (VOCs) VOC emissions shall be determined using 40 CFR 60, App. A, Method 25A using a flame ionization analyzer equipped with a methane separator. If such an analyzer is unavailable, VOC emissions shall be determined simultaneously using two analyzers, with one configured to read only methane. The difference between the total organic detector and the methane detector shall constitute the VOC measurement. [R307-165] II.B.3.e.9 HCl HCl emissions shall be determined using 40 CFR 60, Appendix A, Method 26, or 26A or other EPA-approved testing method, acceptable to the Director. [R307-401-8] II.B.3.e.10 Results The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.4 SOP Plant Requirements Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 22 II.B.4.a The following production and operation limits shall not be exceeded: A. 5,300,000 tons of potash harvested from ponds per rolling 12-month period B. 1,680,000 tons of SOP produced per rolling 12-month period C. 432,000 tons of KCl used per rolling 12-month period [R307-401-8] II.B.4.a.1 The owner/operator shall demonstrate compliance with the rolling 12-month total for each production limit. 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 of production shall be kept for all periods when the plant is in operation. Production records shall be determined by operation logs. The records of production shall be kept on a daily basis. [R307-401-8] II.B.4.b Visible emissions from all outdoor storage silos shall not exceed 10% opacity. Egress points to the dome silos shall remain closed at all times, except when mobile equipment is actively entering or exiting the silo during loading or unloading operations. [R307-401-8] II.B.4.b.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis while loading or unloading operations are occurring at the silo. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director. The opacity determination shall be performed while loading or unloading operations are occurring at the silo. [R307-401-8] II.B.4.b.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. Documentation of maintenance performed on the silos to ensure they operate as fully enclosed structures when egress points are closed shall also be kept in the log. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 23 II.B.4.c Visible emissions from all outdoor fully enclosed conveyance systems shall not exceed 5% opacity. At all times, the owner/operator shall operate and maintain each affected emission unit as a fully enclosed conveyance system. Each fully enclosed conveyance system shall be fully enclosed on all sides, top, and bottom. All fully enclosed conveyance systems shall be clearly labeled on each conveyor such that an inspector/operator can safely identify equipment at any time. [R307-401-8] II.B.4.c.1 Monitoring: The owner/operator shall conduct a Method 22 performance test, or other EPA-approved testing method, as acceptable to the Director, according to the following requirements for each affected emission unit. A. Conduct a weekly 10-minute visible emissions test of each affected emission unit in accordance with Method 22 of 40 CFR 60 Appendix A, or other EPA-approved testing method, as acceptable to the Director. The performance test shall be conducted while the unit is in operation. B. If any visible emissions are observed from an emission unit, the owner/operator shall inspect the affected emission unit to determine the cause of visible emissions and initiate corrective action within 1 hour of the initial survey. C. If no visible emissions are observed during four consecutive weekly tests, the owner/operator may decrease the frequency of the visible emissions test required in paragraph (A) from weekly to monthly. If visible emissions are observed during any monthly test, the owner/operator shall resume the weekly visible emissions test required in paragraph (A) and maintain that schedule until no visible emissions are observed in four consecutive weekly tests. [R307-401-8] II.B.4.c.2 Recordkeeping: The owner/operator shall keep a log of the visible emissions tests that contains the following information: time and date of test, emission point location and description, time of visible emissions, if observed, results of inspections, time and date corrective actions initiated, and corrective actions taken. All data required by 40 CFR 60, Appendix A, Method 22, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 24 II.B.4.d Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity: A. All loadout operations B. All storage piles C. All material handling operations which includes the following: bins & hoppers, screens, crushers, grinders, and presses D. All partially enclosed conveyance systems E. All conveyor drop points F. All conveyor transfer points G. All bin vents [R307-401-8] II.B.4.d.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis while the unit is operating. The visual opacity survey shall be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources. For intermittent sources, opacity observations shall be performed on a monthly basis while the unit is operating in accordance with 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 operation. [R307-401-8] II.B.4.d.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA- approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 25 II.B.4.e All partially enclosed conveyance systems shall be clearly labeled on each conveyor such that an inspector/operator can safely identify equipment at any time. [R307-401-8] II.B.4.f Emissions to the atmosphere from the baghouses and wet scrubbers located at the SOP Plant for PM10 and PM2.5 shall not exceed the following rates and concentrations. Compliance with the limits shall be based on an average of 3 test runs and shall include both filterable and condensable emissions (standardized at 68 °F, 29.92 in Hg): Emission Point PM10 Emission Rate PM2.5 Emission Rate PM2.5 Concentration (lb/hr) (lb/hr) (grains/dscf) AH-1555 2.61 0.39 0.01 BH-001 0.37 0.37 0.01 BH-002 0.65 0.47 0.01 BH-008 4.25 4.25 0.01 BH-1400 2.78 2.78 0.02 BH-1516 1.46 0.22 0.01 [R307-401-8] II.B.4.f.1 Testing Frequency Compliance testing shall be done on each emission source at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-401-8] II.B.4.f.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.4.f.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-165] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 26 II.B.4.f.4 Calculations: To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.4.f.5 Source Operation: The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days). B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.4.f.6 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods acceptable to the Director. [R307-165] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 27 II.B.4.f.7 PM10/PM2.5 For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201a, or other EPA-approved testing method, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or other EPA approved testing methods as acceptable to the Director. When demonstrating compliance with the PM10 and PM2.5 limits above, all filterable particulate emissions captured using Method 5 shall be considered PM2.5, resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing analytical methods, such as: x-ray diffraction, scanning electron microscopy, or electron microprobe analysis may be used to determine particle sizing, as acceptable to the Director. The back half condensable particulate emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-165] II.B.4.f.8 Results The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.5 Boiler Requirements II.B.5.a NOx emissions to the atmosphere from each of the two boilers on site shall not exceed the following rates and concentrations: Rate (lbs/hr) Concentration (ppm) 1.30 9.0 Compliance with the limit shall be based on an average of 3 test runs. [R307-401-8] II.B.5.a.1 Testing Frequency Compliance testing shall be done on each emission source at least once every calendar year and in the same calendar quarter in which the most recent stack test was performed. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 28 II.B.5.a.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.5.a.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-165] II.B.5.a.4 Calculations: To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.5.a.5 Source Operation: The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous 12 months (365 days). B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 29 II.B.5.a.6 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods acceptable to the Director. [R307-165] II.B.5.a.7 Nitrogen Oxides NOx emissions shall be determined using 40 CFR 60 Appendix A, Method 7E, or other EPA- approved testing method, acceptable to the Director. [R307-165] II.B.5.a.8 Results The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.6 Dryer Requirements II.B.6.a Emissions to the atmosphere from each of the three dryers on site (D-501, D-1400, and D- 1545) for NOx shall not exceed 20 ppm at 3% O2. Compliance with the limits shall be based on an average of 3 test runs. [R307-401-8] II.B.6.a.1 Testing Frequency Compliance testing shall be done on each emission source at least once every three years. The Director may require testing at any time. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. [R307-165] II.B.6.a.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 30 II.B.6.a.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other EPA approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-165] II.B.6.a.4 Calculations: To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods specified herein shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165] II.B.6.a.5 Source Operation: The production rate during all compliance testing shall be no less than 90% of the permitted production rate. If the maximum permitted production rate has not been achieved at the time of the test, the following procedure shall be followed: A. Testing shall be at no less than 90% of the production rate achieved in the previous three (3) years. B. If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. C. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum permitted production rate is achieved. [R307-165] II.B.6.a.6 Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods acceptable to the Director. [R307-165] II.B.6.a.7 Nitrogen Oxides NOx emissions shall be determined using 40 CFR 60 Appendix A, Method 7E, or other EPA- approved testing method, acceptable to the Director. [R307-165] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 31 II.B.6.a.8 Results The results of stack testing shall be submitted to the Director within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. [R307-165] II.B.7 Baghouse and Wet Scrubber Requirements II.B.7.a Each baghouse shall operate within the static pressure range recommended by the manufacturer for normal operations. The static pressure range shall be clearly labeled on each baghouse such that an inspector/operator can safely read the range at any time. Manometer or magnehelic pressure gauges shall be installed to measure the differential pressure across each of the baghouses. The pressure gauges shall be located such that an inspector/operator can safely read the indicator at any time. For baghouses that monitor pressure drop to demonstrate compliance with 40 CFR Part 64, the requirements in this condition shall not apply. [R307- 401-8] II.B.7.a.1 Pressure drop readings from each baghouse shall be recorded at least once during each day of operation. Records documenting these inspections shall be kept in a log and shall include the following: A. Unit identification; B. Manufacturer recommended pressure drop for the unit; C. Daily pressure drop readings; and D. Date of bag replacements. [R307-401-8] II.B.7.a.2 The pressure gauges of each baghouse shall be calibrated in accordance with the manufacturer's instructions or recommendations at least once every 12 months. Documentation of calibrations shall be maintained for all periods the plant is in operation. [R307-401-8] II.B.7.b Each wet scrubber shall operate within the static pressure range and liquid flow rate recommended by the manufacturer for normal operations. These parameters shall be clearly labeled on each scrubber such that an inspector/operator can safely read the parameters at any time. Manometer or magnehelic pressure gauges shall be installed to measure the differential pressure across the wet scrubber. Flow rate meters shall be installed to measure the liquid flow rate in the scrubber. The pressure gauges and flow rate meters shall be located such that an inspector/operator can safely read the indicators at any time. For scrubbers that are subject to 40 CFR Part 64, the requirements in this condition shall not apply. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 32 II.B.7.b.1 Pressure drop and liquid flow rate readings from each wet scrubber shall be recorded at least once during each day of operation. Records documenting these inspections shall be kept in a log and shall include the following: A. Unit identification; B. Manufacturer recommended pressure drop and liquid flow rate for the unit; C. Daily pressure drop readings; and D. Daily liquid flow rate readings. [R307-401-8] II.B.7.b.2 The gauges and meters on each wet scrubber shall be calibrated in accordance with the manufacturer's instructions or recommendations at least once every 12 months. Documentation of calibrations shall be maintained for all periods the plant is in operation. For scrubbers that monitor liquid flow rate to demonstrate compliance with 40 CFR Part 64, the liquid flow rate requirements in this condition shall not apply. All other requirements in this condition remain applicable. [R307-401-8] II.B.8 Engine Requirements II.B.8.a Visible emissions from diesel-fired emergency generator engines shall not exceed 20% opacity. [R307-401-8] II.B.8.a.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a quarterly basis while the unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than steam are observed from an emission unit, a 6-minute opacity determination of that emission unit shall be performed by a certified observer within 1 hour of the initial survey. The opacity determination shall be performed while the unit is operating in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director. If the generator(s) continue to operate on consecutive days following the initial observation, a 6-minute opacity determination shall be performed by a certified observer on a daily basis, while the unit is operating, in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 33 II.B.8.a.2 Recordkeeping: The owner/operator shall keep a log of the visual opacity survey(s) containing the following information: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, shall be maintained. [R307-401-8] II.B.8.b Visible emissions from propane-fired emergency generator engines shall not exceed 10% opacity. [R307-401-8] II.B.8.b.1 Monitoring: In lieu of monitoring via visible emission observations, records shall be kept for any period that a fuel other than propane is used in the affected emission unit. [R307-401-8] II.B.8.b.2 Recordkeeping: Records shall be kept in a log that is kept in a readily accessible location onsite. [R307-401-8] II.B.8.c The owner/operator shall use the emergency generator engines for electricity-producing operations only during the periods when electric power from the public utilities is interrupted. [R307-401-8] II.B.8.d The owner/operator shall track hours of operation for each emergency generator engine as required to comply with all applicable federal subparts. [40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.9 Fuel Requirements II.B.9.a The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the diesel fired engines on site. All diesel burned shall contain no more than 15 ppm sulfur. [R307-401-8] II.B.9.a.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the sulfur requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8] II.B.9.b The owner/operator shall only use propane as fuel in the propane fired engines on site. [R307- 401-8] II.B.9.c The owner/operator shall use only pipeline quality natural gas as a fuel source for all boilers and burners. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 34 II.B.10 Haul Roads and Fugitive Dust Requirements II.B.10.a The owner/operator shall comply with all applicable requirements of R307-309 for PM10 and PM2.5 non-attainment areas for fugitive emissions and fugitive dust source. At least once every three years, the fugitive dust control plan shall be reviewed and evaluated. If site modifications that result in emission changes have been made, an updated fugitive dust control plan shall be submitted as required by R307-309-6(3). [R307-309, R307-401-8] II.B.10.b Visible emissions in disturbed, operational areas, and unpaved haul roads from haul trucks and other mobile equipment shall not exceed 20% opacity at any point. [R307-401-8] II.B.10.b.1 In lieu of monitoring via visible emissions observations, adherence to the most recently approved fugitive dust control plan shall be monitored to demonstrate that the opacity limit is not exceeded and that appropriate measures are being implemented to control fugitive dust. [R307-309, R307-401-8] II.B.10.c Vehicles speeds shall be limited to 30 miles per hour on haul roads and 15 miles per hour in off-road areas. The vehicle speed limits shall be clearly visible and posted, at a minimum, on site at the entrance to off-road areas and the beginning of the haul road. [R307-401-8] II.B.10.d The owner/operator shall spray all unpaved haul roads with water, brine, or a chemical suppressant to control fugitive dust and maintain the opacity limit listed in this AO. [R307- 401-8] II.B.10.d.1 Records of water or chemical treatment shall be kept for all periods when the plant is in operation. The owner/operator may stop applying suppressants when the temperature is below freezing. The records shall include the following: A. Date B. Location of treatment C. Rainfall received, if any, and approximate amount D. Records of temperature if the temperature is below freezing. [R307-401-8] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 35 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Is Derived From Source Submitted NOI dated February 12, 2024 Is Derived From Source Submitted NOI dated February 12, 2024 Supersedes DAQE-AN109170044-23 dated March 2, 2023 REVIEWER COMMENTS 1. Comment regarding No change in emissions from removal of salt harvesting throughput: The removal of the salt harvesting throughput limit will not result in an increase in emissions. The harvested salt is inherently low (zero) emitting, as it maintains a higher moisture content and contains residual magnesium chloride - which is a chemical dust suppressant. The source is already limited in total processed salt products. Thus UDAQ agrees that no increase in emissions is expected. [Last updated March 18, 2024] 2. Comment regarding Changes in conditions: Only two conditions are being changed by this project. I.8 is being removed as it is no longer applicable. This condition required notification of construction on a replacement conveyor (authorized in DAQE-AN109170042-22). This condition has been satisfied and is no longer required. II.B.2.a.A This subparagraph lists the limit on total salt harvesting. This subparagraph is being removed and subparagraphs B and C will be renumbered. [Last updated March 8, 2024] 3. Comment regarding inclusion of Fortress equipment: The Fortress North America equipment consists of two hoppers, controlled by a baghouse, two mixing tanks and two storage tanks. The hoppers store the fire retardant additives to be blended with liquid magnesium chloride. Material from the hoppers is vacuum fed to the mixing tanks, and the combined material is then pneumatically conveyed to the two storage tanks. The only source of emissions associated with this process is the baghouse exhaust. Total emissions from this process are estimated at less than 0.04 lb/hr or 0.003 tpy. [Last updated March 18, 2024] Engineer Review N109170049: Compass Minerals Ogden Inc. - Production Plant March 18, 2024 Page 36 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 UTAH DIVISION OF AIR QUALITY - NOTICE OF INTENT INCLUSION OF FORTRESS NORTH AMERICA COMPASS MINERALS Compass Minerals - Ogden, UT Prepared By: TRINITY CONSULTANTS 4525 Wasatch Boulevard Suite 200 Salt Lake City, UT 84124 (801) 272-3000 February 2024 Project 244502.0003 Trinity Consultants TABLE OF CONTENTS 1. EXCECUTIVE SUMMARY 2. GENERAL INFORMATION 2.1. Description of Facility 2.2. Fees... 2.3. Forms...... 3. DESCRIPTION OF PROJECT AND PROCESS 3.1. Description of Project ........ 3.2. Description of the Location.. 4. EMISSIONS RELATED INFORMATION 4.1. Baghouse... 5. CHARACTERIZATION OF THE SOURCE AND PROJECT 5.1. Area Attainment Status 5.2. Comparison to Significant Emissions Rates (SERS) and Air Dispersion Modeling Thresholds......... 5.3. Comparison to HAP Major Source Thresholds 6. BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS 6.1. Fortress Skid Particulate Matter (PM10, and PM2.5) BACT...... Fortress Skid PM10 and PM2.5 Step 1 - Identify All Control Technologies Fortress Skid PM10 and PM2.5 Step 2 - Eliminate Technically Infeasible Options....... Fortress Skid PM10 and PM2.5 Step 3 - Rank Remaining Control Technologies by Control Effectiveness... Fortress Skid PM10 and PM2.5 Steps 4 and 5-Select BACT. 7. APPLICABLE REGULATIONS 7.1. UDAQ Applicable Rules 1-1 2-1 2-1 2-1 2-1 3-1 3-1 3-1 4-1 4-1 5-1 5-1 5-1 ------➖➖➖➖ 5-2 6-1 6-1 6-1 6-1 6-2 6-2 7-1 7-1 7-1 .7-1 7-1 7.2. Federal Rules: National Emission Standards for Hazardous Air Pollutants.... 7.3. Federal Rules: New Source Performance Standards NSPS Subpart LL-Standards of Performance for Metallic Mineral Processing Plants....... NSPS Subpart 000-Standards of Performance for Nonmetallic Mineral Processing Plants........ 7-1 APPENDIX A: FORMS APPENDIX B: EMISSIONS CALCULATIONS Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants A-1 B-1 i 1. EXCECUTIVE SUMMARY This Notice of Intent (NOI) air permit application is being submitted to the Utah Division of Air Quality (UDAQ) by Compass Minerals Ogden Incorporated - Production Plant (Compass Minerals) to permit additional proposed operations at their existing Ogden facility in Weber County, Utah. The Ogden Plant is located within an area that is in attainment for all criteria pollutants with exception to 2006 24-hour PM2.5 and its precursors (NOx, SO2, VOC, and ammonia (NH3)) for which it is serious nonattainment and the 2015 8-hour Ozone (precursors NOx and VOC) for which it is moderate nonattainment. Compass Minerals is permitted as a major source under Utah approval order (AO) (i.e., air permit) No. DAQE- AN109170044-23. Compass Minerals has recently acquired Fortress North America (Fortress), a producer of next- generation fire retardants. Fortress uses magnesium chloride derived from the previously permitted Compass Minerals processes and manufactures it into a fire retardant. The processing utilizes a range of equipment including a hopper, blender, and storage tank. Compass Minerals is seeking to incorporate all emitting equipment from Fortress' operations into their current approval order. The emissions associated with inclusion of Fortress exclusively come from the use of a baghouse to control particulate emissions. This NOI air permit application has been developed pursuant to UAC R307-401-5 and Utah's NOI air permit application guidance. It includes required supporting information for a modification to its approval order which includes: NOI Forms and Fees; Process Description; ► Site Plan; ► Potential Emission Calculations; Best Available Control Technology (BACT) Analysis; ► Applicable Regulatory Requirements; and ► Emission Impact Analysis Applicability. Trinity Consultants 1-1 2. GENERAL INFORMATION The following section contains the information requested under the "Source Identification Information" section of UDAQ Form 1 Notice of Intent (NOI) Application Checklist. ► Company Name: ► Address: ► County: ► UTM Coordinates: ► Primary SIC Code: Source Size Determination: ► Permit No.: ► Area Designation: 2.1. Description of Facility Compass Minerals Ogden Incorporated. 765 North 10500 West, Ogden, UT 84404 Weber County Easting: 396,782 m, Northing: 4,570,085 m, Zone 12 2819 (Industrial Inorganic Chemicals, Not Elsewhere Classified) Major source - AOP 5700001004 DAQE AN109170044-23 PM2.5 Serious Nonattainment (NA), Ozone (O3) Moderate NA All correspondence regarding this submission should be addressed to: ► Contact: Title: Office: Email: Vikrant (Vik) Chavan Manager, Environmental- Ogden 801-732-3011 chavanv@compassminerals.com 2.2. Fees Compass Minerals will use the UDAQ's Payment Portal to prepay the following UDAQ NOI air permit application fees associated with this submittal: ► "Application Filing Fee" for the "Major or Minor Modification" category = $500 ► "Application Review Fee" for the "Existing major source with a minor modification" category in maintenance or non-attainment areas = $2,300 ► Total UDAQ fees = $2,800 Compass Minerals understands that the total permit review fee is based on the total actual time spent by UDAQ staff processing this NOI air permit application, and that, if the total review time is more than 20 standard hours, UDAQ will invoice Compass Minerals at $115 per hour for the additional time above 20 standard hours. 2.3. Forms The following UDAQ forms are included in Appendix A to this application: Form 1 - Notice of Intent Application Checklist; Form 2 - Source Identification Information; Form 4 - Project Information; ► Form 5 - Emissions Information; and Form 10 - Baghouse. Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants 2-1 3. DESCRIPTION OF PROJECT AND PROCESS 3.1. Description of Project Fortress utilizes liquid magnesium chloride from the existing Compass Minerals processes and converts it to a fire retardant. The magnesium chloride will be loaded into two sealed tanks where it is blended with additives. The additives are introduced by a vacuum pump which pulls the powdered additives from the bottom of the hoppers using a negative pressure zone and deposits them into the bottom of the mixing tanks. Emissions from the two hoppers are processed by a baghouse. Inside the tanks, the magnesium chloride is mixed with the additives. The viscous fluid will then be transported to a holding tank to await loadout. A process flow diagram has been developed and its associated emissions and controls have been provided in the figure below. Figure 3-1. Fortress Project Process Flow Diagram Magnesium Chloride Liquid Additives Hopper Mixing Tank Holding Tank PM, PM10,PM25 Baghouse Hopper ↑ Mixing Tank Holding Tank Additives Magnesium Chloride Liquid 3.2. Description of the Location Fortress is within the Compass Minerals existing production facility. More specifically, this process will be located on the eastern side of the property as pictured in Figure 3-2 below. Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants 3-1 Figure 3-2. Fortress Location - Site Plan Fortress Plant Magnesium Chloride Plant Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants 3-2 4. EMISSIONS RELATED INFORMATION This section details the methodology used to calculate controlled and uncontrolled emissions for all criteria pollutants associated with the addition of the Fortress equipment, as regulated by R307-401- 5(2)(b). Detailed emission calculation tables are included in Attachment B. Emissions from the proposed baghouse will be exclusively PM, PM10, and PM2.5. 4.1. Baghouse Potential filterable PM, PM10, and PM2.5 emissions were conservatively assumed to be equal. These emissions were determined using the design exhaust flow rate (516 acfm) and outlet grain loading rate (0.01 gr/dscf) for the baghouse. Baghouse annual operating time was calculated to equal the operational time necessary to control the proposed maximum annual throughput of 7.5 MMgallons of fire- retardant concentrate per year. The design exhaust flow rate was converted from actual cubic feet per minute to dry standard cubic feet per minute using the monthly average ambient temperature and pressure in Ogden, Utah for 2013- 2024 and the meteorological data obtained from the Utah Climate Center website. The calculation methodology for annual filterable PM, PM10, and PM2.5 emissions is presented below: PM, PM10, PM2.5 Annual Emission Rates (tpy) gr 1 lb = Exhaust Flow Rate (dscfm) × Grain Loading Rate dscf. 60 min X X 7,000 gr 1 hr lb × Operating Hours ÷ 2,000 yr ton/ Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants 4-1 5. CHARACTERIZATION OF THE SOURCE AND PROJECT 5.1. Area Attainment Status The Ogden Plant is located within an area that is in attainment for all criteria pollutants with exception to 2006 24-hour PM2.5 and its precursors (NOx, SO2, VOC, and ammonia (NH3)) for which it is serious nonattainment and the 2015 8-hour Ozone (precursors NOx and VOC) for which it is moderate nonattainment. 5.2. Comparison to Significant Emissions Rates (SERS) and Air Dispersion Modeling Thresholds The Ogden Plant is an existing major source for prevention of significant deterioration (PSD) and nonattainment new source review (NANSR). The addition of a new baghouse demonstrates emissions increases to the facility less than Significant Emission Rates (SERs). The proposed project increases have been compared to both the pollutants in attainment and nonattainment as demonstrated in Table 5- 1 and Table 5-2, respectively.1 Table 5-1 Comparison to SERS for Pollutants in Attainment1 Equipment Current Permitted PTE2 Project Totals New PTE SERS Exceeding SERS? PM 10 (tpy) 285.60 2.99E-03 285.60 15 No 1 Weber County is designated attainment for PM10, NO2, CO, and SO2. 2 Emission totals represent the limit in DAQE-AN109170044-23. 1 Since GHG emissions are only evaluated as an "anyway source” and all proposed project emission rates are less than the SERS no GHG evaluation was completed. Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants 5-1 Table 5-2 Comparison for Pollutants in Nonattainment Equipment PM2.5 Current Permitted PTE1 131.75 Project Totals 2.99E-03 New PTE 131.75 SERS Exceeding SERs? 10 No 1 Emission totals represent the limit in DAQE-AN109170044-23. UDAQ's modeling thresholds are generally consistent with the SERS established. Since the SERS have not been exceeded, criteria pollutant modeling is not required under UAC R307-410-4. Appendix Table B-1 compares criteria pollutant total proposed emissions to applicable modeling thresholds contained in R307- 403-4 through 7, and R307-410-4. 5.3. Comparison to HAP Major Source Thresholds As defined in the National Emission Standards for Hazardous Air Pollutants (NESHAP) the major source threshold for HAP is 10 tpy for an individual HAP and 25 tpy for any combination of HAP.2 As currently permitted, the Ogden Plant's total HAPS that are greater than 25 tpy. Thus, the Ogden Plant is considered a major source of HAP. Fortress operations do not generate any HAPS emissions. 2 40 CFR 63.2 "Major source" Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants 5-2 6. BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS In the State of Utah, under R307-401-5(2)(d), Notice of Intent, every facility, operation, or process that proposes any activity that would emit an air contaminant into the air, must consider BACT for a proposed new source or modification.3 The below BACT analysis only addresses units which will be modified, installed, or otherwise addressed in this NOI. Control technologies were identified from a search based on the following references: California Air Resource Board (CARB) Database; ► Texas Commission for Environmental Quality (TCEQ); and ‣ Search of the RACT/BACT/LAER Clearinghouse (RBLC). 6.1. Fortress Skid Particulate Matter (PM10, and PM2.5) BACT Fortress Skid PM10 and PM2.5 Step 1 - Identify All Control Technologies Control technologies identified for PM10 and PM2.5 emissions from hopper are as follows: Best Management/Operation Practices Baghouse/Fabric Filter Cyclone Fortress Skid PM10 and PM2.5 Step 2 - Eliminate Technically Infeasible Options Best Management/Operation Practices Management practices during material movement will minimize PM2.5 and PM10 emissions and will be implemented in this project. Best operating practices, such as regular inspection and maintenance, will be implemented as well. Baghouse/Fabric Filter Fabric filters or baghouses are used for medium and low gas-flow streams with high particulate concentrations. PM-laden air is routed through ductwork to a fabric filter that traps PM in its fibers and allows cleaned air to be vented to the atmosphere. The typical fabric filter has a control efficiency between 95% to 99.9%. Fabric filters are considered technically feasible. Cyclone A cyclone separator (cyclone) operates on the principle of centrifugal separation. Exhaust enters the inlet and spirals around towards the outlet. As particles proceed through the cyclone, heavier materials hit the outside walls and drop out where they are collected. The cleaned gas escapes through an inner tube. Cyclones are generally used to reduce dust loading and collect large particles. 3 UAC R307-401-4 4 From EPA Air Pollution Control Technology Fact Sheet for baghouses, EPA-452/F-03-025. Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants 6-1 A high-efficiency cyclone designed specifically for PM2.5 and PM10 removal is likely to achieve between 20% to 70% removal for PM2.5 and 60% to 95% removal for PM10.5 A cyclone is considered technically feasible. Fortress Skid PM10 and PM2.5 Step 3 - Rank Remaining Control Technologies by Control Effectiveness Table 6-1. PM10 and PM2.5 Control for the Hopper Control Technologies Rank Percent Control Feasible Baghouse/Fabric Filter 1 95-99.9% Cyclone 2 20-95% Yes Yes Best Management/Operational Practices 3 Variable Yes Fortress Skid PM10 and PM2.5 Steps 4 and 5 - Select BACT Compass Minerals proposes BACT to be a baghouse/fabric filter and best management/operational practices. Best management/operational practices have been implemented throughout the design of the system. Inspection and maintenance operations will be conducted as necessary. 5 From Air Pollution Control Technology Fact Sheet for cyclones, EPA-452/F-03-005 Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants 6-2 7. APPLICABLE REGULATIONS 7.1. UDAQ Applicable Rules Compass Minerals has evaluated the applicability of each rule under the Utah Administrative Code (UAC) Title R307. Rules generally applicable to Compass Minerals but not affected by this project have not been addressed. Compass did not identify any UAC rules that would apply specifically to this project. 7.2. Federal Rules: National Emission Standards for Hazardous Air Pollutants The NESHAP federal regulations found in Title 40 Parts 61 and 63 of the CFR are emission standards for HAPs. The inclusion of Fortress operations generates no HAPS, and thus poses no changes to Compass Minerals' major source determination under US EPA's NESHAP program. As such, there are no NESHAP applicable to this project. 7.3. Federal Rules: New Source Performance Standards NSPS require new, modified, or reconstructed sources to control emissions to the level achievable by the best demonstrated technology as specified in the applicable provisions. Moreover, any source subject to an NSPS is also subject to the general provisions of NSPS Subpart A, except as noted. The following sections detail the applicability of NSPS regulations to the facility's operations. NSPS Subpart LL-Standards of Performance for Metallic Mineral Processing Plants NSPS Subpart LL, Standards of Performance for Metallic Mineral Processing Plants, applies to metallic mineral process plants. The definition of metallic mineral concentrate does not include magnesium and thus this rule does not apply.6 NSPS Subpart 000-Standards of Performance for Nonmetallic Mineral Processing Plants NSPS Subpart 000, Standards of Performance for Nonmetallic Mineral Processing Plants, applies to a list of minerals and mixtures as listed within the subpart. Magnesium compounds are not included within this list and therefore this subpart does not apply. 6 40 CFR 60.381 "Metallic mineral concentrate" 7 40 CFR 60.671 "Nonmetallic mineral" Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants 7-1 Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants APPENDIX A: FORMS A-1 DEPARTMENT OF ENVIRONA NMENTAL Form 1 Date February 2024 Notice of Intent (NOI) Application Checklist Company Compass Minerals, Inc. UTAN QUALITY AIR QUALITY Utah Division of Air Quality New Source Review Section Source Identification Information [R307-401-5] 1. Company name, mailing address, physical address and telephone number 2. Company contact (Name, mailing address, and telephone number) 3. Name and contact of person submitting NOI application (if different than 2) 4. Source Universal Transverse Mercator (UTM) coordinates 5. Source Standard Industrial Classification (SIC) code 6. Area designation (attainment, maintenance, or nonattainment) 7. Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.) 8. Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers NOI Application Information: [R307-401] 1. Detailed description of the project and source process 2. Discussion of fuels, raw materials, and products consumed/produced 3. Description of equipment used in the process and operating schedule 4. Description of changes to the process, production rates, etc. 5. Site plan of source with building dimensions, stack parameters, etc. 6. Best Available Control Technology (BACT) Analysis [R307-401-8] A. BACT analysis for all new and modified equipment 7. Emissions Related Information: [R307-401-2(b)] A. Emission calculations for each new/modified unit and site-wide (Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs) B. References/assumptions, SDS, for each calculation and pollutant C. All speciated HAP emissions (list in lbs/hr) 8. Emissions Impact Analysis - Approved Modeling Protocol [R307-410] A. Composition and physical characteristics of effluent (emission rates, temperature, volume, pollutant types and concentrations) 9. Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403] A. NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements B. Alternative site analysis, Major source ownership compliance certification 10. Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406] A. Air quality analysis (air model, met data, background data, source impact analysis) B. Visibility impact analysis, Class I area impact 11. Signature on Application Note: The Division of Air Quality will not accept documents containing confidential information or data. Documents containing confidential information will be returned to the Source submitting the application. N/A Ν/Α Ε N/A N/A NT OF AYMENT DEPART UTAM ENVIR QUALITY AIR QUALITY Form 2 Company Information/Notice of Intent (NOI) Utah Division of Air Quality New Source Review Section Application for: Initial Approval Order Date February 2024 Approval Order Modification General Owner and Source Information 1.Company name and mailing address: Compass Minerals 765 North 10500 West Ogden, UT 84648 Phone No.: Fax No.: 3. Source name and physical address (if different from above): Phone no.: Fax no.: 5. The Source is located in: Weber 2. Company** contact for environmental matters: Vikrant Chavan Phone no.: (801) 732-3011 Email: chavanv@compassminerals.com 會與 *Company contact only; consultant or independent contractor contact information can be provided in a cover letter 4. Source Property Universal Transverse Mercator coordinates (UTM), including System and Datum: UTM: Zone 12 X: Easting: 396,869m y: Northing: 4,570,651m County 7. If request for modification, AO# to be modified: DAQE # 6. Standard Industrial Classification Code (SIC) 28 19 AN109170044-23 DATED: 03 02/23 8. Brief (50 words or less) description of process. Addition of Fortress North America, a recent aquisition, to the Compass Minerals Ogden Incorporated Production Plant. Electronic NOI 9. A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black (jiblack@utah.gov) or Alan Humpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal Electronic Copy Submittal Authorization/Singnature Both I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on reasonable inquiry made by me and to the best of my knowledge and belief. Signature: Jordan Taylor Name (Type or print) Vice President- Utah Operations Title: Telephone Number: Date: 913-344-9225 Email: taylorjo@compassminerals.com 19 FEB202Y 1 of 1 RTMENT DEPART UTAN OF RONMEN ENVIRO NMENTAL QUALITY AIR QUALITY Form 4 Project Information Utah Division of Air Quality New Source Review Section Company Compass Minerals Site Ogden, UT 1. Process Data For Modification/Amendment ONLY Permit Number DAQE-AN109170044-23 If submitting a new permit, then use Form 3 2. Name of process to be modified/added: Requested Changes 3. Permit Change Type: Equipment New Increase* End product of this process: Fire Retardent 4. Does new emission unit affect existing permitted process limits? Yes No✔ 6. Description of Permit/Process Change** Process Condition Change Add Equipment to AO Other Other Other 5. Condition(s) Changing: 7. New or modified materials and quantities used in process. Material See Application 8. New or modified process emitting units ** Emitting Unit(s) See Application ** Quantity Annually Capacity(s) Manufacture Date(s) *If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an emissions increase and a public comment period. **If additional space is required, please generate a document to accommodate and attach to form. Page 1 of 1 DEPARTMENT UTAH OF ENVIRONMENT LITY AIR QUALITY Form 5 Emissions Information Criteria/GHGs/ HAP's Utah Division of Air Quality New Source Review Section Criteria Pollutants Company Compass Minerals Site Ogden, UT Potential to Emit* Criteria Pollutants & GHGs Permitted Emissions (tons/yr) Emissions Increases (tons/yr) Proposed Emissions (tons/yr) PM10 Total PM10 Fugitive PM2.5 NOX SO2 CO VOC VOC Fugitive NH3 Greenhouse Gases CO2e CO2 CH4 N20 HFCS PFCs SF6 Total CO2e See Attached for Emission Information CO2e See Attached for Emission Information *Potential to emit to include pollution control equipment as defined by R307-401-2. Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act) Hazardous Air Pollutant*** Permitted Emissions (tons/yr) Emission Increase (tons/yr) Proposed Emission (tons/yr) See Attached for Emission Information Total HAP Use additional sheets for pollutants if needed Page 1 of 1 CO2e Emission Increase (lbs/hr) DEPARTMENT OF UTAH QUALITY ENVIRONMENTAL Utah Division of Air Quality New Source Review Section Form 10 Fabric Filters (Baghouses) Company Compass Minerals, Inc. Site/Source Ogden Date February 2024 Baghouse Description 1. Briefly describe the process controlled by this baghouse: Control emissions from two hoppers. Gas Stream Characteristics 2. Flow Rate (acfm): 516 3. Water Vapor Content of Effluent Stream. (lb. water/lb. dry air) 4. Particulate Loading (grain/scf) Design Max Average Expected Inlet Outlet 0.01 5. Pressure Drop (inches H2O) High Low 6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min) Equipment Information and Filter Characteristics 8. Manufacturer and Model Number: 9. Bag Material: 10. Bag Diameter 11. Bag Length (ft.) 12. Number of Bags: (in.) 13. Stack Height 2 Filters feet Nomex nylon ☐ Polyester Acrylics Filter Dimensions: 11.4 x 14.4 Oval x 26.00 Long Stack Inside Diameter inches Fiber glass 14. Filtering ☐ Cotton Efficiency Rating: ☐ Teflon % 15. Air to Cloth Ratio: 1 16. Hours of Operation: Max Per day Max Per year 104 17. Cleaning Mechanism: Reverse Air Shaker ✔ Pulse Jet Other: 18. Calculated emissions for this device Emissions Calculations (PTE) PM 10 NOx CO HAPS Lbs/hr Lbs/hr Tons/yr Tons/yr PM2.5 SOX Lbs/hr Tons/yr VOC _Lbs/hr (speciate). _Tons/yr (speciate) Submit calculations as an appendix. Lbs/hr Tons/yr Lbs/hr Tons/yr Lbs/hr Tons/yr See Attached for Emission Information Page 1 of 2 APPENDIX B: EMISSIONS CALCULATIONS Compass Minerals, Inc. | Air Permit Application to Include Fortress North America Trinity Consultants B-1 Table 1. Emissions Summary Baghouse Potential Annual Emissions (tpy) Equipment NOx CO PM10 PM2.5 SO2 VOC Total HAP 2.99E-03 2.99E-03 Current Permitted PTE1 Project Totals New PTE 38.66 161.36 285.60 131.75 2.88 51.47 2.99E-03 2.99E-03 63.20 38.66 161.36 285.60 131.75 2.88 51.47 63.20 Major Source Thresholds 100 100 100 70 70 70 25/10 Exceeding Major Source Thresholds?2,3 No Yes Yes Yes No No No SERS⭑ 40 15 10 40 - Exceeding SERS? No No No No No No No 1. These emission totals represent the limit given in DAQE-AN109170044-23 2. Major Source thresholds are defined by 40 CFR 51.165(a)(1)(iv)(A) and 40 CFR 52.21(b)(1)(i)(b) 3. Total HAP Threshold is stated in 40 CFR Section 63.2 under definition of a Major Source. 4. Modeling Limit is stated in UDAQ Emissions Impact Assessment Guidelines under Table 1: Total Controlled Emission Rates for New Sources. Table 2. Dust Collector Summary Location Hoppers Exhaust Flow Rate1 Equipment Dust Collector dscfm 446.17 Grain Loading Rate (gr/dscf) 0.01 PM Potential Emissions3 Ib/hr tpy 3.82E-02 2.99E-03 3,4,5 PM 10 Potential Emissions3,4,5 PM2.5 Potential Emissions 3,4,5 tpy acfm 516 lb/hr 3.82E-02 tpy 2.99E-03 Ib/hr 3.82E-02 1. Flow Rate (dscfm) = Flow Rate (acfm) x (Standard Temperature (Rankine) / Actual Exhaust Temperature (Rankine)) x (Actual Pressure (in Hg) / Standard Pressure (in Hg)) x (1 - Moisture of Ambient Air (%)) a) Monthly averages for temperature, moisture content, and pressure in Ogden, UT for 2013-2024. Meteorological data obtained using the Utah Climate Center website. Actual Exhaust Temperature: 2.99E-03 513.4 Rank Standard Temperature: 529.7 Rank Actual Pressure: Standard Pressure: 12.66 psi 14.70 psi Moisture Content: 2.7% % 0.015 (psi/mbar) b) Conversions 2. The Maximum Outlet Grain Loading rate for all baghouses and wet scrubbe need 3. Conservatively assumed that PM-PM10-PM2.5 emissions. 4. Annual PM emissions calculated using proposed maximum annual throughput provided by Compass Minerals. Max Throughput: 5. Conversions 7,500,000 (gal/yr) 60 7000 (min/hr) (grain/lb) 2000 (Ib/ton)