DAQ-2025-002611

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DAQC-CI141870001-25
Site ID 14187 (B1)

MEMORANDUM

TO: FILE – THE DAVID J. JOSEPH COMPANY DBA WESTERN METALS
REYCYLING, LLC

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: May 5, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Box Elder County

INSPECTION DATE: February 5, 2025

SOURCE LOCATION: 7400 West 21200 North
Plymouth, UT 84330
DIRECTIONS: I-15 North bound Exit 392. The facility is located north of Nucor
Steel.

SOURCE CONTACTS: Suzy Smith, Environmental Engineer
801-386-4233 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Western Metals Recycling, LLC (WMR) conducts metal
shredding in addition to cutting, hand torching, and sorting of
ferrous and non-ferrous materials. The operation includes a
granulator system controlled by two cyclones, a dust collection
filter system, a bin feeder, and conveyor belts. The feeder and
the conveyors are enclosed and the dust generated during
material transfers is routed to the dust collector. A diesel fired
emergency generator has been installed for backup power when
electricity is not available.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN141870004-23, dated March
22, 2023
MACT (Part 63) CCCCCC: National Emission Standards for
Hazardous Air Pollutants for Source Category: Gasoline
Dispensing Facilities,
MACT (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

The David J. Joseph Company dba Western
Metals Recycling, LLC

4201 West 700 South 7400 West 21200 North
Salt Lake City, UT 84104 Plymouth, UT 84330

SIC Code: 5093: (Scrap & Waste Materials)

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. No limits set forth in this AO appear to have been exceeded. The source stated that there have been no modifications to the equipment or processes. The equipment appeared to be properly operated and maintained according to manufacturer recommendations. Records are kept as required and were made available after the
inspection. No breakdowns have been reported since the previous inspection. An emissions inventory is not required at this time.
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]
Status: In Compliance. Notification was submitted on October 9, 2023, via email. See the attachments below for a copy of this notification. The source was reminded to direct any future notifications to the NSR Section. See the attached email correspondence.

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Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Western Metals Recycling Plymouth Scrap Metal Recycling Plant
II.A.2 One (1) Electric Shredder Control: water injection system
II.A.3 Metals Recovery Process Includes: trommels, screens, and conveyors
II.A.4 Shredded Materials Separation System Includes: magnetic drum separator, eddy current separators, and screens
II.A.5 Wire Chopper Includes: screens and conveyors
II.A.6 Nonferrous Finder Separation System Includes: screens and an internally vented baghouse
II.A.7 Welding and Torch Cutting Activities
II.A.8 Various Conveyors Control: water sprays
II.A.9 Granulator System Including front-end loader, a bin feeder, a granulator, a debulking box, an air classifier, destoners, a roll screen, and various conveyors. The system is controlled with two (2) cyclones and one (1) fabric filter dust collector
II.A.10 One (1) Emergency Generator Engine Fuel: diesel Rating: 396 kW (530 hp) Manufactured in 2000 MACT Subpart ZZZZ
II.A.11 Various Fuel Storage Tanks Two (2) storage tanks Fuel: diesel fuel Capacity: 2,000 gallons each One (1) storage tank Fuel: diesel fuel Capacity: 5,000 gallons One (1) storage tank Fuel: gasoline Capacity: 500 gallons Control: submerged filling MACT Subpart CCCCCC

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II.A.12 Various Support Equipment Includes: shears, choppers, balers, non-ferrous metal receiving, cranes, and front-end loaders. Listed for informational purposes only.
Status: In Compliance. No unapproved equipment was observed at the time of inspection. The equipment in Condition II.A.4 was replaced in 2024, in a replacement-in-kind. See DAQE-GN141870005-24 for more details. The generator in Condition II.A.10 is rated at 320 kW, and the generator engine is rated at 530 hp.

II.B Requirements and Limitations
II.B.1 Plant-Wide Requirements II.B.1.a The owner/operator shall not process more than 320,000 tons of scrap metal through the shredding machine per rolling 12-month period. [R307-401-8] II.B.1.a.1 The owner/operator shall: A. Determine scrap metal processed with process scales and inventory records B. Record scrap metal processed on a monthly basis C. Use the scrap metal processed data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the scrap metal processed records for all periods the plant is in operation. [R307-401-8] Status: In Compliance. Scrap metal is weighed as it is processed as there is a belt scale on the shredder. The weights are electronically recorded and are available by at least the 20th day of each month. For the rolling 12-month period from January 2024 - December 2024, a total of 252,794 tons of scrap metal were processed. See attachments for more information. II.B.1.b The owner/operator shall control all emissions from the shredding system with a water spray system. [R307-401-8] Status: In Compliance. Water sprays have been installed at the appropriate points on the shredder system. II.B.1.c Unless otherwise noted, the owner/operator shall not allow visible emissions to exceed the following opacities from the following emission points: A. Screens - 10 % opacity B. Conveyor transfer points - 10% opacity C. Electric shredding machine - 15% opacity D. Conveyor drop points - 20% opacity E. The granulator system fabric filter dust collector - 10% opacity F. Diesel engines - 20% opacity G. All other points - 20% opacity. [R307-305-3]
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II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point at the time of inspection. Method 9 was utilized to verify opacity limits. See attached VEO form. II.B.1.d The owner/operator shall comply with R307-328-5 for the gasoline storage tank. [R307-328-5, R307-401-8] Status: In Compliance. Gasoline is purchased and stored on site for miscellaneous trucks and off-road vehicles. A total of 2,986.5 gallons of gasoline were purchased between January 2024, and December 2024. Western Metals Recycling is compliant with the Subpart CCCCCC requirements that have been incorporated into R307-307-328 for facilities with a monthly throughput of less than 10,000 gallons. All gasoline spills are minimized and cleaned as quickly as possible. The gasoline tanks have fill-pipes with gasketed seals, no wasted gasoline has yet necessitated sending materials to gasoline reclamation, records of consumption are kept as required, and portable containers are self-sealing. See attachments for more information. II.B.2 Fugitive Dust and Haul Road Requirements II.B.2.a The owner/operator shall comply with the most recent FDCP submitted to the DAQ for control of all fugitive dust sources associated with the metal shredding facility. [R307-309-6] Status: In Compliance. A Fugitive Dust Control Plan is in use at the source. See the attached FDCP. II.B.2.b The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas to exceed 20% opacity at any point in plant and 10% at the property boundary. [R307-309-4] II.B.2.b.1 Visible emission determinations shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-4] Status: In Compliance. No visible fugitive dust was observed during the inspection. See the attached VEO form. II.B.2.c The owner/operator shall use chemical suppressants on all the unpaved haul roads and use water with sweeping and vacuuming on all the paved haul roads on site to maintain opacity limits listed in this AO. If the temperature is below freezing or if the haul roads are covered with snow or ice, the owner/operator may stop using water on the paved haul roads. [R307-401-8] II.B.2.c.1 Records of treatments shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of chemical suppressant/water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature was below freezing. [R307-401-8] Status: In Compliance. Water truck and sweeping records are kept on site and can be viewed in binders in the main office. Chemical suppressant is not used at this time. See the attached watering logs below.
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II.B.3 Emergency Engine Requirements II.B.3.a The owner/operator shall install and operate one (1) 395 kW generator engine certified to meet a CO emission rate of 11.4 g/kW-hr or less. [R307-401-8] II.B.3.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8] Status: In Compliance. The generator is EPA certified to meet a CO emission rate of 11.4 g/kW-hr. See the attached Emissions Data certification. II.B.3.b The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.3.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.3.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. Emergency and testing operations are kept on a log and then transferred to a spreadsheet. The engine is equipped with a non-resettable hour meter. For the rolling 12-month period from January 2024 - December 2024, a total of 15 hours were logged for the diesel generator. See attachments for more information. II.B.3.c The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8] II.B.3.c.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.3.c.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In Compliance. Only #2 diesel is used for the emergency engine. See the attached invoice from RelaDyne dated December 6, 2024.

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II.B.4 The Granulator System Requirements II.B.4.a The owner/operator shall not process more than 39,420 tons of material per rolling 12-month period in the granulator system. [R307-401-8] II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall A. Determine the materials processed by maintaining an operations log B. Record the weight of materials processed in tons each day C. Calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep all the records for all periods when the plant is in operation. [R307-401-8] Status: In Compliance. Processed material is weighed as it occurs and will be recorded by the 20th day of each month. For the rolling 12-month period from January 2024 - December 2024, a total of 2,557 tons of material were processed in the granulator system. II.B.4.b The owner/operator shall install and operate two cyclones and one fabric filter dust collector to control emissions from the granulator and the debulking box. All air streams from the granulator and the debulking box shall be vented to the cyclones followed by the fabric filter dust collector before being vented to the atmosphere. [R307-401-8] Status: In Compliance. The granulator system reportedly operates as described and all air streams are processed by the cyclones and dust collector prior to being vented to the atmosphere. The fabric filters are manufactured by US Filtration. II.B.4.c The owner/operator shall enclose the material conveyance and transfer operations. The owner/operator shall vent the air streams from the conveyance and transfer operations to the fabric filter dust collector. All air streams collected from the conveyance and transfer operations shall be vented to the fabric filter dust collector before being vented to the atmosphere. [R307-401-8] Status: In Compliance. The transfer lines and conveyors are enclosed and the airstreams capture the emissions to be vented to the cyclones and the collector. The enclosures can be viewed at the process buildings. II.B.4.d The owner/operator shall maintain and replace the fabric filters in accordance with the manufacturer's instructions and/or recommendations. [R307-401-8] Status: In Compliance. Fabric filters are replaced approximately every 40 hours of use or as needed.

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Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

MACT (Part 63) CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category:
Gasoline Dispensing Facilities

Status: In Compliance. Gasoline invoice records show that a total of 2,986.5 gallons of gasoline had been
used during the 12-month period from January 2024 - December 2024. The gasoline storage tank's
maximum capacity is 500 gallons. The facility is compliant with Subpart CCCCCC 63.11116
requirements for sources with monthly throughputs of less than 10,000 gallons, which include
minimizing spills expeditious cleanups, fill-pipe and gasketed seals on the tanks, reclamation when
necessary, sealed portable containers, and record keeping requirements. See Condition II.B.1.d above.

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

Status: In Compliance. The emergency generator is operated for testing and maintenance for under 100
hours during any 12-month period and a non-resettable meter has been installed. Maintenance occurs
as per the manufacturer's instructions. Only certified Ultra Low Sulfur Diesel fuel is used.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]
Status: In Compliance. Only #2 diesel is used for the emergency engine. See the attached invoice
from RelaDyne dated December 6, 2024.
National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirement MACT (Part 63) Subparts ZZZZ, and CCCCCC. See Section III above for more
information.

Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. Western Metals Recycling submitted an on-line Fugitive Dust Control Plan in
October of 2023. Dust is minimized by water applications and a sweeper. No significant road or
operation area dust was observed during the inspection. See the attached FDCP.

Davis and Salt Lake Counties and Ozone Nonattainment Areas: Gasoline Transfer and Storage [R307-328]

Status: In Compliance. Gasoline transfer and storage requirements for facilities with a monthly
throughput of under 10,000 gallons are met. See Condition II.B.1.d and the Federal Requirements
Section for MACT Subpart CCCCCC.

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EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from The David J.
Joseph Company dba Western Metals Recycling, LLC on the Approval Order (AO)
DAQE-AN141870004-23, dated March 22, 2023. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 344.20
Carbon Monoxide 0.60
Nitrogen Oxides 0.65
Particulate Matter - PM10 4.23
Particulate Matter - PM2.5 1.83
Sulfur Dioxide 0.00
Volatile Organic Compounds 38.98

Hazardous Air Pollutant PTE lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 620
Cumene (CAS #98828) 60
Ethyl Benzene (CAS #100414) 620
Generic HAPs (CAS #GHAPS) 62
Hexane (CAS #110543) 1180
Methyl Chloroform (1,1,1-Trichloroethane) (CAS #71556) 20
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 200
Methyl Methacrylate (CAS #80626) 20
Methylene Chloride (Dichloromethane) (CAS #75092) 20
Naphthalene (CAS #91203) 60
Styrene (CAS #100425) 280
Toluene (CAS #108883) 2660
Xylenes (Isomers And Mixture) (CAS #1330207) 2980

PREVIOUS ENFORCEMENT
ACTIONS: Western Metals Recycling, Inc. was found to be out of
compliance with Condition II.B.2.c of this AO during a previous
inspection on July 31, 2023. No compliance action was
recommended at that time. See DAQC-CI141870001-23 for
more details.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN141870004-23,
dated March 22, 2023, the overall status is: In Compliance. The
source appears to be well-maintained and operated. Required
records were provided following the inspection.

HPV STATUS: Not Applicable.

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RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual maintaining the same targeting frequency.
Notify the source that any records required by this AO cannot be
noted as “Confidential Business Information”.

NSR RECOMMENDATIONS: Clarify kw vs hp rating on generator in Condition II.A.10

ATTACHMENTS: VEO form, email correspondence, ULSD verification, rolling
totals, 1.8 notification, generator certification, watering records,
FDCP
Daniel Riddle <[e-mail]>
14187 - Follow up to air quality inspection
11 messages
Daniel Riddle <[e-mail]>Wed, Feb 5, 2025 at 2:26 PM
To: [e-mail], [e-mail]
Suzy and Jardee,
Thank you for taking the time to meet today for your air quality inspection. As discussed, here are the records I require to complete my
inspection report:
From AO DAQE-AN141870004-23 (attached):
Condition I.8 - official construction status notification for the equipment listed on this AO
Condition II.B.1.a - tons of scrap metal processed (Jan 2024 - Dec 2024)
Condition II.B.1.d - total gasoline purchased (Jan 2024 - Dec 2024)
Condition II.B.2.a - copy of your most recent Fugitive Dust Control Plan
Condition II.B.2.c.1 - record of any sweeping or vacuuming, chemical suppression, or watering on haul roads for purposes of dust control
Condition II.B.3.a.1 - manufacturer's certification of CO emission rate for the 395 kW generator
Condition II.B.3.b - hours of usage for non-emergency purposes for generator (Jan 2024 - Dec 2024)
Condition II.B.3.c - verification of ULSD fuel
Condition II.B.4.a - tonnage of material processed in granulator system (Jan 2024 - Dec 2024)
Please provide these records by February 12, 2025. Thanks and let me know if you have any questions.
Best,
Daniel
14187 AO.pdf
565K
Smith, Suzy (WMR) <[e-mail]>Mon, Feb 10, 2025 at 3:31 PM
To: "[e-mail]" <[e-mail]>
Daniel,

Please see requested records attached.

Total Gasoline purchased in 2024 was 2,986.5 gallons.

Quick question on Condition II.B.2.c.1.D. If I were to just say the Temperature is below freezing, yes or no (instead of listing the freezing
temperature), would that meet the requirement?

Regards,
Suzy Smith, P.E.
(Licensed in UT, CO, TX)
Environmental Engineer
Phone: [phone]

From: Daniel Riddle <[e-mail]>
Sent: Wednesday, February 5, 2025 2:26 PM
5/6/25, 8:42 AM State of Utah Mail - 14187 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-8427510014076360668&simpl=msg-a:r31084877191181…1/8
You don't often get email from [e-mail]. Learn why this is important
To: Steed, Jardee (WMR) <[e-mail]>; Smith, Suzy (WMR) <[e-mail]>
Subject: [EXT] 14187 - Follow up to air quality inspecon

This message came from outside of Nucor.
-
[Quoted text hidden]
CONFIDENTIALITY NOTICE
This e-mail contains privileged and confidential information, which is the property of Nucor, intended only for the use of the intended
recipient(s). Unauthorized use or disclosure of this information is prohibited. If you are not an intended recipient, please immediately notify
Nucor and destroy any copies of this email. Receipt of this e-mail shall not be deemed a waiver by Nucor of any privilege or the confidential
nature of the information.
7 attachments
2023.10.09 WMR Plymouth - Status of Construction.pdf
207K
WMR Fugitive Dust Control Plan.pdf
115K
2024.12.06 ULSD Invoice.pdf
143K
2023.06.07 Emerg Gen Emission Data.pdf
162K
2024 Monthly Rolling Totals.pdf
95K
WaterTruck2024.pdf
8466K
2024 Rain Temp.pdf
129K
Daniel Riddle <[e-mail]>Tue, Feb 11, 2025 at 9:46 AM
To: "Smith, Suzy (WMR)" <[e-mail]>
Thanks Suzy, I'll review these records and get back to you.
Regarding II.B.2.c.1.d, just saying yes or no is sufficient. What we really want to see is that watering or other dust control measures are
taking place on days when temperatures are high enough to cause dust issues.
[Quoted text hidden]
Daniel Riddle <[e-mail]>Tue, Apr 1, 2025 at 12:05 PM
To: "Smith, Suzy (WMR)" <[e-mail]>
Suzy,
Could you provide me with the hp for the current engine on your diesel generator as well as the year of manufacture? In your permit, it lists
these numbers as 396 kW / 530 hp and manufactured in 2000, but I have in my notes that the generator is 320 kW and that matches the
name plate I looked at as well. To determine the hp you might need to reach out to the manufacturer or look at the manual for the engine.
5/6/25, 8:42 AM State of Utah Mail - 14187 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-8427510014076360668&simpl=msg-a:r31084877191181…2/8
Thanks,
Daniel
[Quoted text hidden]
Smith, Suzy (WMR) <[e-mail]>Tue, Apr 1, 2025 at 2:11 PM
To: Daniel Riddle <[e-mail]>
Daniel,

Here is the engine spec-sheet that shows the 530 HP and the build date in 2000.

5/6/25, 8:42 AM State of Utah Mail - 14187 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-8427510014076360668&simpl=msg-a:r31084877191181…3/8

Here is the generator information showing 320 kW:

A consultant explained the difference in these numbers to me as the 320 kW rating is accurate for the generator, i.e., that is the
electrical power rating; and the 530 hp rating is accurate for the generator’s engine, i.e., the mechanical power required to produce 320
5/6/25, 8:42 AM State of Utah Mail - 14187 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-8427510014076360668&simpl=msg-a:r31084877191181…4/8
You don't often get email from [e-mail]. Learn why this is important
kW of electrical power.

Please let me know if you have additional concerns.

Thanks,
Suzy Smith, P.E.
(Licensed in UT, CO, TX)
Environmental Engineer
Phone: [phone]

From: Daniel Riddle <[e-mail]>
Sent: Tuesday, April 1, 2025 12:05 PM
To: Smith, Suzy (WMR) <[e-mail]>
Subject: Re: [EXT] 14187 - Follow up to air quality inspecon

Suzy,

Could you provide me with the hp for the current engine on your diesel generator as well as the year of manufacture? In your permit, it lists
these numbers as 396 kW / 530 hp and manufactured in 2000, but I have in my notes that the generator is 320 kW and that matches the name
plate I looked at as well. To determine the hp you might need to reach out to the manufacturer or look at the manual for the engine.

5/6/25, 8:42 AM State of Utah Mail - 14187 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-8427510014076360668&simpl=msg-a:r31084877191181…5/8

Thanks,
Daniel
[Quoted text hidden]
[Quoted text hidden]
Daniel Riddle <[e-mail]>Wed, Apr 2, 2025 at 10:52 AM
To: "Smith, Suzy (WMR)" <[e-mail]>
Okay, thank you for the clarification!
[Quoted text hidden]
Daniel Riddle <[e-mail]>Thu, Apr 17, 2025 at 11:06 AM
To: "Smith, Suzy (WMR)" <[e-mail]>
Suzy - some notes after review of my memo from my manager:
The I.8 notification that you sent to Bryce Bird on October 9, 2023... was that sent through snail mail or via email?
Some of your production tables are labeled as "Confidential Business Information". My manager wants me to make sure you know that it will
be a public record once I complete my report. All records required by the AO are public information. If you want to claim CBI, that has to be
done during the permitting process.
Let me know if you have any questions.
Daniel
[Quoted text hidden]
Smith, Suzy (WMR) <[e-mail]>Fri, Apr 18, 2025 at 7:49 AM
To: Daniel Riddle <[e-mail]>
It was sent via email.
5/6/25, 8:42 AM State of Utah Mail - 14187 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-8427510014076360668&simpl=msg-a:r31084877191181…6/8
[Quoted text hidden]
[Quoted text hidden]
Daniel Riddle <[e-mail]>Wed, Apr 23, 2025 at 11:42 AM
To: "Smith, Suzy (WMR)" <[e-mail]>
Thank you for clarifying. We could not find it in the source file, so it is possible that the email was misplaced when it was sent. We appreciate
you submitting it well before the 18-month window.
On any future AO modification that requires I.8 notification, please be sure to follow this guideline "To ensure proper credit when notifying the
Director, send the documentation to the Director, attn.: NSR Section." The NSR manager is Alan Humpherys ([e-mail]).
Please cc him on any letter to Bryce.
You could also cc my manager, Chad Gilgen ([e-mail]) or myself. We would also ensure that it is properly added to your file.
Please confirm receipt of this email, and then I will submit my memorandum.
Thank you,
Daniel
[Quoted text hidden]
Smith, Suzy (WMR) <[e-mail]>Wed, Apr 23, 2025 at 12:54 PM
To: Daniel Riddle <[e-mail]>
Understood. I have attached the email if that is helpful. Susan had conducted an inspection shortly before we sent this and
informed me I only needed to email it to her.

I will follow the provided guidance in the future.
[Quoted text hidden]
[Quoted text hidden]
---------- Forwarded message ----------
From: "Smith, Suzy (WMR)" <[e-mail]>
To: "'[e-mail]'" <[e-mail]>
Cc: "'Susan Weisenberg'" <[e-mail]>, "Steed, Jardee (WMR)" <[e-mail]>, "Rampton, Cliff (WMR)"
<[e-mail]>, "'Chase Peterson'" <[e-mail]>
Bcc:
Date: Mon, 9 Oct 2023 16:12:29 +0000
Subject: Status of Construction DAQE-AN141870004-23
Mr. Bird,
Please see attached for a letter of documentation of the status of construction for the Western Metals Recycling, Plymouth facility – DAQE-
AN141870004-23.
Regards,
Suzy Smith, P.E.
(Licensed in Utah, Colorado)
Environmental Engineer
Western Metals Recycling | Texas Port Recycling
4201 W 700 S • Salt Lake City, UT 84104
Phone: [phone]
Cell: 801.386.4233
[e-mail]
5/6/25, 8:42 AM State of Utah Mail - 14187 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-8427510014076360668&simpl=msg-a:r31084877191181…7/8
2 attachments
2023.10.09 WMR Plymouth - Status of Construction.pdf
207K
Status of Construction DAQE-AN141870004-23.eml
311K
Daniel Riddle <[e-mail]>Wed, Apr 23, 2025 at 1:28 PM
To: "Smith, Suzy (WMR)" <[e-mail]>
Thank you for understanding and for sending that over.
[Quoted text hidden]
5/6/25, 8:42 AM State of Utah Mail - 14187 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-8427510014076360668&simpl=msg-a:r31084877191181…8/8