DAQ-2025-002623

1

DAQC-510-25
Site ID 10726 (B4)

MEMORANDUM

TO: STACK TEST FILE – MORTON SALT INC.

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: May 23, 2025

SUBJECT: Source: Sulzer Vibrating Fluidized Bed Salt Dryer Wet Scrubber, North Mill Wet
Scrubber, South Mill Wet Scrubber, and Pellet Mill Wet Scrubber,
(II.A.9, II.A.10, II.A.11, II.A.12)
Location: Grantsville, Tooele County, Utah
Contact: Rachel Hahn: 801-933-4420
Tester: Montrose Air Quality Services, LLC.
Site ID #: 10726
AO #: DAQE-AN107260022-18, dated November 26, 2018
Subject: Review of Pretest Protocol received April 22, 2025

On April 22, 2025, the Utah Division of Air Quality (DAQ) received a protocol for testing of the Sulzer
Vibrating Fluidized Bed Salt Dryer Wet Scrubber, North Mill Wet Scrubber, South Mill Wet Scrubber,
and Pellet Mill Wet Scrubber in Grantsville, Tooele County, Utah. Testing will be performed on June 3-6,
2025, to determine compliance with the PM10 emission limits found in condition II.B.2.b of
DAQE-AN107260022-18.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sampling and velocity traverse: OK
2. RM 2 used to determine stack velocity and flow rate: OK
3. RM 3/3A used to determine gas analysis: OK
4. RM 4 used to determine moisture content: OK
5. RM 5 used to determine particulate emissions: OK
6. RM 202 used to determine back-half condensable of PM10 emissions: OK
7. RM 9 used to determine visible emissions opacity: OK

DEVIATIONS: No deviations noted.

CONCLUSION: The protocol appears to be acceptable.

* ) ) * - $ % * 2 . & $
2

RECOMMENDATION: The methods proposed in the pretest protocol are sufficient to determine
particulate matter emissions from the wet scrubbers. It is recommended
that the pretest protocol be determined as acceptable.

ATTACHMENTS: Copy of Morton Salt Inc.’ pretest protocol
Source Test Plan for 2025 PM10 and VEs
Compliance Testing
Scrubber, North Mill Production Area Wet
Scrubber, South Mill Production Area Wet
Scrubber, Pellet Mill Wet Scrubber, and Sulzer
Vibrating Fluidized Bed Salt Dryer Wet
Morton Salt, Inc.
Salt Processing Center
Grantsville, UT
Prepared For:
Morton Salt, Inc.
1794 W Solar Rd.
Grantsville, UT 84074
Prepared By:
Montrose Air Quality Services, LLC
6823 South 3600 West
Spanish Fork, UT 84660
For Submission To:
Utah Department of Environmental Quality, Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116
Document Number: GP081AS--PP-981
Proposed Test Date: Week of June 2, 2025
Test Plan Submittal Date: , 2025
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Review and Certification
I certify that, to the best of my knowledge, the information contained in this document is
complete and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature: Date: , 2025
Name: Beckie Hawkins Title: District Manager
I have reviewed, technically and editorially, details and other appropriate written materials
contained herein. I hereby certify that to the best of my knowledge the presented material
is authentic and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature: Date:
Name: Joby Dunmire Title: Reporting/QC Specialist IV
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Table of Contents
Section Page
1.0 Introduction ........................................................................................................ 5
1.1 Summary of Test Program.............................................................................5
1.2 Applicable Regulations and Emission Limits......................................................7
1.3 Key Personnel..............................................................................................8
2.0 Plant and Sampling Location Descriptions.............................................................. 10
2.1 Process Description, Operation, and Control Equipment ................................... 10
2.2 Flue Gas Sampling Locations ........................................................................ 10
2.3 Operating Conditions and Process Data ......................................................... 11
2.4 Plant Safety ............................................................................................... 11
2.4.1 Safety Responsibilities ........................................................................ 11
2.4.2 Safety Program and Requirements ....................................................... 12
3.0 Sampling and Analytical Procedures ..................................................................... 14
3.1 Test Methods ............................................................................................. 14
3.1.1 EPA Method 1 .................................................................................... 14
3.1.2 EPA Method 2 .................................................................................... 14
3.1.3 EPA Methods 3/3A ............................................................................. 15
3.1.4 EPA Method 4 .................................................................................... 15
3.1.5 EPA Methods 5 and 202 ...................................................................... 16
3.1.6 EPA Method 9 .................................................................................... 17
3.2 Process Test Methods .................................................................................. 18
4.0 Quality Assurance and Reporting .......................................................................... 19
4.1 QA Audits .................................................................................................. 19
4.2 Quality Control Procedures ..........................................................................19
4.2.1 Equipment Inspection and Maintenance................................................19
4.2.2 Audit Samples ................................................................................... 19
4.3 Data Analysis and Validation ........................................................................ 19
4.4 Sample Identification and Custody ................................................................ 20
4.5 Quality Statement ...................................................................................... 20
4.6 Reporting .................................................................................................. 20
4.6.1 Example Report Format ...................................................................... 21
4.6.2 Example Presentation of Test Results ................................................... 21
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List of Appendices
Appendix A Supporting Information ........................................................................... 23
Appendix A.1 Units and Abbreviations .................................................................. 24
Appendix A.2 Accreditation Information/Certifications............................................33
Appendix A.3 Stack Schematics ..........................................................................35
Appendix A.4 UDEQ Approval Order DAQE-AN107260022-18..................................
Appendix “S” Field Work Safety Plan ..........................................................................
List of Tables
Table 1-1 Summary of Test Program and Proposed Schedule .......................................... 6
Table 1-2 Reporting Units and Emission Limits .............................................................. 7
Table 1-3 Test Personnel and Responsibilities ............................................................... 9
Table 2-1 Sampling Locations ................................................................................... 10
Table 4-1 Example Particulate Matter Emissions Results - North Mill Production Area Wet
Scrubber Exhaust ............................................................................................... 22
List of Figures
Figure 3-1 US EPA Method 5/202 Sampling Train ........................................................ 18
Figure 4-1 Typical Report Format .............................................................................. 21
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1.0 Introduction
1.1 Summary of Test Program
Morton Salt contracted Montrose Air Quality Services, LLC (Montrose) to perform a
compliance emissions test program on the following sources/units at the facility located in
Grantsville, UT: North Mill Production Area Wet Scrubber, South Mill Production Area Wet
Scrubber, Pellet Mill Wet Scrubber, and Sulzer Vibrating Fluidized Bed Salt Dryer Wet
Scrubber. The tests will be conducted to determine compliance with Permit Conditions II.B.1
(Site-Wide Requirements) and II.B.2 (Scrubber Requirements) contained in Approval Order
DAQE-AN107260022-18 issued by the Utah Department of Environmental Quality (UDEQ)
on November 26, 2018, as well as applicable requirements contained in 40 CFR Part 60,
Subpart OOO.
The specific objectives are to:
Measure emissions of particulate matter less than 10 micrometers in
aerodynamic diameter (PM10) from the outlets of (4) four sources operating
at the facility.
Visually determine the opacity of emissions (VEs) from the outlets of (4)
four sources operating at the facility.
Conduct the test program with a focus on safety.
Montrose will provide the test personnel and the necessary equipment to measure emissions
as outlined in this test plan. Facility personnel will provide the process and production data
to be included in the final report. A summary of the test program and proposed schedule is
presented in Table 1-1.

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Table 1-1
Summary of Test Program and Proposed Schedule1
Proposed
Test Dates
Unit ID/
Source Name Activity/Parameters Test
Methods
No. of
Runs
Duration
(Minutes)
June 3, 2025
North Mill
Production Area
Wet Scrubber
Perform testing for PM10Emissions
EPA 1, 2,
3/3A, 4, and
5/202
3 60
Perform VEs
observations EPA 9 1 6
June 4, 2025
South Mill
Production Area Wet Scrubber
Perform testing for PM10
Emissions
EPA 1, 2,
3/3A, 4, and
5/202
3 60
Perform VEs
observations EPA 9 1 6
June 5, 2025 Pellet Mill Wet
Scrubber
Perform testing for PM10
Emissions
EPA 1, 2,
3/3A, 4, and
5/202
3 60
Perform VEs
observations EPA 9 1 6
June 6, 2025
Sulfur Vibrating Fluidized Bed
Salt Dryer Wet
Scrubber
Perform testing for PM10Emissions
EPA 1, 2,
3/3A, 4, and
5/202
3 60
Perform VEs
observations EPA 9 1 6
To simplify this test plan, a list of Units and Abbreviations is included in Appendix A.
Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not
defined. Please refer to the list for specific details.
1 The test schedule is subject to change, based on process operation and availability.
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1.2 Applicable Regulations and Emission Limits
The results from this test program are presented in units consistent with those listed in the
applicable regulations or requirements. The reporting units and emission limits are
presented in Table 1-2.
Table 1-2
Reporting Units and Emission Limits
Unit ID/
Source Name Parameters Reporting Units Emission
Limit
Emission Limit
Reference
North Mill
Production Area
Wet Scrubber
PM10 gr/dscf 0.014
AO DAQE-
AN107260022-
18, §II.B.2.b.
and 40 CFR Part
60, Subpart
OOO
VEs % 10
AO DAQE-
AN107260022-
18, §II.B.1.a.B.
South Mill
Production Area Wet Scrubber
PM10
lb/hr 3.25 AO DAQE-
AN107260022-
18, §II.B.2.b. gr/dscf 0.016
VEs %10
AO DAQE-
AN107260022-
18, §II.B.1.a.B.
Pellet Mill Wet
Scrubber
PM10 gr/dscf 0.014
AO DAQE-
AN107260022-
18, §II.B.2.b.
and 40 CFR Part
60, Subpart
OOO
VEs %10
AO DAQE-
AN107260022-
18, §II.B.1.a.B.
Sulfur Vibrating
Fluidized Bed Salt
Dryer Wet
Scrubber
PM10
lb/hr 12.15 AO DAQE-AN107260022-
18, §II.B.2.b. gr/dscf 0.015
VEs %10
AO DAQE-
AN107260022-
18, §II.B.1.a.B.

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1.3 Key Personnel
A list of project participants is included below:
Facility Information
Source Location: Morton Salt, Inc.
Salt Processing Plant
1794 W Solar Rd.
Grantsville, UT 84074
Project Contact: Rachel Hahn
Role: Environmental Coordinator
Company: Morton Salt, Inc.
Telephone: [phone]
Email: [e-mail]
Agency Information
Regulatory Agency: Utah Department of Environmental Quality, Division of Air Quality
Agency Contact: Chad Gilgen
Telephone: [phone]
Email: [e-mail]
Testing Company Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Beckie Hawkins
Title: District Manager
Telephone: [phone]
Email: [e-mail]
Laboratory Information
Laboratory: MAQS Spanish Fork

City, State: Spanish Fork, UT
Method: EPA Methods 5 and 202
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Table 1-3 details the roles and responsibilities of the test team.
Table 1-3
Test Personnel and Responsibilities
Role Primary Assignment Additional Responsibilities
Client Project Manager Coordinate Project Post-test follow up
Field Project Manager Operate mobile lab Facility interface, test crew coordination
Field Technician Execute stack platform
responsibilities Preparation, support PM

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2.0 Plant and Sampling Location Descriptions
2.1 Process Description, Operation, and Control
Equipment
Morton Salt harvests salt from the Great Salt Lake, processing this material into various
products, at the Grantsville Salt Plant, located in Tooele County. The facility consists of
various crushers, conveyors, presses, dryers, and load-out facilities. Emissions from these
processes are controlled by low NOx burners, wet scrubbers, and baghouses. The facility
also maintains three emergency internal combustion generator engines.
2.2 Flue Gas Sampling Locations
Actual stack measurements, number of traverse points, and location of traverse points will
be evaluated in the field as part of the test program. Table 2-1 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
Table 2-1
Sampling Locations
Sampling
Location
Stack Inside
Diameter
(in.) or
Inside
Dimensions
(in. x in.)
Distance from Nearest
Disturbance
Number of Traverse
Points
Downstream
EPA “B”
(in./dia.)
Upstream EPA
“A” (in./dia.)
North Mill
Production Area
Wet Scrubber
43 272 / 6.3 84 / 2.0 Isokinetic: 16 (2/port)
Flow: 16 (2/port)
South Mill
Production Area
Wet Scrubber
38 121 / 3.2 240 / 6.3 Isokinetic: 24 (12/port)
Flow: 24 (12/port)
Pellet Mill Wet
Scrubber 51 206 / 4.0 26 / 0.5 Isokinetic: 24 (12/port)
Flow: 24 (12/port)
Sulzer Vibrating
Fluidized Bed
Salt Dryer Wet
Scrubber
16 x 19 62.5 / 3.6 27.5 / 1.6 Isokinetic: 27 (9/port)
Flow: 27 (9/port)
Sample location(s) are verified in the field to conform to EPA Method 1. Acceptable cyclonic
flow conditions are confirmed prior to testing using EPA Method 1, Section 11.4. Appendix A
presents stack schematics.
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2.3 Operating Conditions and Process Data
Emission tests are performed while the source/units and air pollution control devices are
operating at the conditions required by the permit. As per §II.B.2.b.1 of the UDEQ AO
DAQE-AN107260022-18, “…For an existing source/emission point, the production rate
during all compliance testing shall be no less than 90% of the maximum production
achieved in the previous three (3) years.”
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters:
Scrubber pressure drop, measured in units of inches water column, gauge
pressure
Scrubber liquid flow rate, measured in units of gallons per minute (gpm)
Production rate, measured in units of tons per hour (tph)
2.4 Plant Safety
Montrose will comply with all safety requirements at the facility. The facility Client Sponsor,
or designated point of contact, is responsible for ensuring routine compliance with plant
entry, health, and safety requirements. The Client Sponsor has the authority to impose or
waive facility restrictions. The Montrose test team leader has the authority to negotiate any
deviations from the facility restrictions with the Client Sponsor. Any deviations must be
documented.
2.4.1 Safety Responsibilities
Planning
Montrose must complete a field review with the Client Sponsor prior to the
project date. The purpose of the review is to develop a scope of work that
identifies the conditions, equipment, methods, and physical locations that will
be utilized along with any policies or procedures that will affect our work.
We must reach an agreement on the proper use of client emergency services
and ensure that proper response personnel are available, as needed.
The potential for chemical exposure and actions to be taken in case of
exposure must be communicated to Montrose. This information must include
expected concentrations of the chemicals and the equipment used to identify
the substances.
Montrose will provide a list of equipment being brought to the site, if required
by the client.

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Project Day
Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate.
Our team will meet daily to review the Project Scope, Job Hazard Assessment,
and Work Permits. The Client Sponsor and Operations Team are invited to
participate.
Montrose will provide equipment that can interface with the client utilities
previously identified in the planning phase and only work with equipment that
our client has made ready and prepared for connection.
We will follow client direction regarding driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area.
As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the
following provisions at each sample location:
o Sampling ports, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tight.
o Safe sampling platforms.
o Safe access to the platforms and test ports, including any scaffolding or
man lifts.
o Sufficient utilities to perform all necessary testing.
Montrose will use the client communication system, as directed, in case of
plant or project emergency.
Any adverse conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site.
Montrose will clean up our work area to the same condition as it was prior to
our arrival.
We will ensure that all utilities, connection points or equipment have been
returned to the pre-project condition or as stated in the safe work permit. In
addition, we will walk out the job completion with Operations and the Client
Sponsor if required by the facility.
2.4.2 Safety Program and Requirements
Montrose has a comprehensive health and safety program that satisfies State and Federal
OSHA requirements. The program includes an Illness and Injury Prevention Program, site-
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specific safety meetings, and training in safety awareness and procedures. The basic
elements include:
All regulatory required policies/procedures and training for OSHA, EPA,
FMCSA, and MSHA
Medical monitoring, as necessary
Use of Personal Protective Equipment (PPE) and chemical detection equipment
Hazard communication
Pre-test and daily toolbox meetings
Continued evaluation of work and potential hazards
Near-miss and incident reporting procedures as required by Montrose and the
Client
Montrose will provide standard PPE to employees. The PPE will include but is not limited to;
hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand
protections, and fall protection. In addition, our trailers are equipped with four gas detectors
to ensure that workspace has no unexpected equipment leaks or other ambient hazards.
The detailed Site Safety Plan for this project is attached to this test plan in Appendix “S”.
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3.0 Sampling and Analytical Procedures
3.1 Test Methods
The test methods for this test program have been presented in Table 1-1. Additional
information regarding specific applications or modifications to standard procedures is
presented below.
3.1.1 EPA Method 1, Sample and Velocity Traverses for Stationary
Sources
EPA Method 1 is used to assure that representative measurements of volumetric flow rate
are obtained by dividing the cross-section of the stack or duct into equal areas, and then
locating a traverse point within each of the equal areas. Acceptable sample locations must
be located at least two stack or duct equivalent diameters downstream from a flow
disturbance and one-half equivalent diameter upstream from a flow disturbance.
3.1.2 EPA Method 2, Determination of Stack Gas Velocity and
Volumetric Flow Rate (Type S Pitot Tube)
EPA Method 2 is used to measure the gas velocity using an S-type pitot tube connected to a
pressure measurement device, and to measure the gas temperature using a calibrated
thermocouple connected to a thermocouple indicator. Typically, Type S (Stausscheibe) pitot
tubes conforming to the geometric specifications in the test method are used, along with an
inclined manometer. The measurements are made at traverse points specified by EPA
Method 1. The molecular weight of the gas stream is determined from independent
measurements of O2, CO2, and moisture. The stack gas volumetric flow rate is calculated
using the measured average velocity head, the area of the duct at the measurement plane,
the measured average temperature, the measured duct static pressure, the molecular
weight of the gas stream, and the measured moisture.
Pertinent information regarding the performance of the method is presented below:
Method Options:
o S-type pitot tube coefficient is 0.84.
o Shortridge multimeter is used to measure velocity.
o Flow rate measurements are performed as part of the pollutant
sample trains.
o A dry molecular weight of 29.0 lb/lb-mol is utilized in flow rate
calculations for processes that emit essentially air.
The typical sampling system is detailed as part of the EPA Methods 5 and 202 sampling train
in Figure 3-1.
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3.1.3 EPA Methods 3/3A – Gas Analysis for the Determination of
Dry Molecular Weight
Procedures found in EPA Methods 3 and 3A are used to measure the oxygen (O2) and
carbon dioxide (CO2) concentrations in the gas stream. These values are used in the
determination of the dry molecular weight of the stack gas. The balance of the stack gas is
assumed to be nitrogen (N2) for this calculation, since the other components in the gas are
insignificant for the determination of dry molecular weight (e.g., carbon monoxide). The
molecular weight is used, along with the values obtained from the EPA Methods 2 and 4
(EPA Methods 5 and 202) testing, to calculate the gas volumetric flow rate through the test
location.
An integrated gas sample (IGS) is collected into a Tedlar bag from the back of the EPA
Methods 5 and 202 sample train for the duration of each test run. Analysis of the IGS bag
contents for the determination of O2 and CO2 is performed using a calibrated paramagnetic
O2 gas analyzer and an infrared CO2 analyzer. The analyzers are calibrated using EPA
Protocol 1 calibration gases.
3.1.4 EPA Method 4, Determination of Moisture Content in Stack
Gas
EPA Method 4 is used to measure the moisture content of gas streams. Gas is sampled
through a probe and impinger train. Moisture is removed using a series of pre-weighed
impingers containing methodology-specific liquids and silica gel immersed in an ice water
bath. The impingers are weighed after each run to determine the percent moisture.
Pertinent information regarding the performance of the method is presented below:
o Condensed water is measured gravimetrically.
o Moisture sampling is performed as part of the pollutant (EPA Methods
5 and 202) sample trains. In these cases, gas is sampled at an
isokinetic rate, not constant.
o Since it is theoretically impossible for measured moisture to be higher
than psychrometric moisture, the psychrometric moisture is also
calculated, and the lower moisture value is used in the calculations--
this is anticipated to be the case for all three exhaust sampling
locations.
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o Method Options:
o EPA Approved Alternative Method 009 (ALT-009) is used as an
alternative to a two-point post-test meter box calibration. This
procedure uses a calculation to check the meter box calibration
factor rather than requiring a physical post-test meter box
calibration using a standard dry gas meter. The average calculated
meter box percent (%) error must result in a percent error within
±5% of Y. If not, a full calibration is performed, and the results are
presented using the Y factor that yields the highest emissions.
o EPA Approved Alternative Method 011 (ALT-011) is used as an
alternative to the EPA Method 2 two-point thermocouple
calibration. This procedure involves a single-point in-field check
using a reference thermometer to confirm that the thermocouple
system is operating properly. The temperatures of the
thermocouple and reference thermometers shall agree to within ±2
°F.
The typical sampling system is detailed as part of the EPA Methods 5 and 202
sampling train in Figure 3-1.
3.1.5 EPA Methods 5 and 202, Determination of Particulate Matter
Emissions from Stationary Sources and Dry Impinger Method
for Determining Condensable Particulate Emissions from
Stationary Sources
EPA Methods 5 and 202 are manual, isokinetic methods used to measure FPM and CPM
emissions. FPM is withdrawn isokinetically from the source and collected on a glass fiber
filter maintained at a temperature of 120 ± 14 °C (248 ± 25 °F) or such other temperature
as specified by an applicable subpart of the standards or approved by the Administrator for
a particular application. The FPM mass, which includes any material that condenses at or
above the filtration temperature, is determined gravimetrically after the removal of
uncombined water.
CPM is collected in dry impingers after filterable PM has been collected on a filter maintained
as specified in Method 5. The organic and aqueous fractions of the impingers and an out-of-
stack CPM filter are then taken to dryness and weighed. The total of the impinger fractions
and the CPM filter represents the CPM.
Pertinent information regarding the performance of the method is presented below:
Method Options:
o Glass sample nozzles and probe liners are used.
o Stainless steel sample nozzles and glass probe liners are used.
o As an alternative to baking glassware, a field train proof blank sample
is recovered.
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o The post-test nitrogen purge is performed using the sampling system
meter box and vacuum pump.
o The post-test nitrogen purge is performed by passing nitrogen
through the train under pressure.
Method Exceptions:
o Stainless steel probe liners are used.
o A heated flexible probe extension is used to connect the sample probe
to the impinger box.
o Single-point isokinetic sampling is performed at this stack due to
space restrictions.
o The sum of the filterable PM (via Method 5) and CPM (via Method
202) are used as a surrogate for PM10 and/or for PM2.5.
Target and/or Minimum Required Sample Duration: 60 minutes
Analytical Laboratory: MAQS, Spanish Fork, Utah
The typical sampling system is detailed in Figure 3-2.
3.1.6 EPA Method 9, Visual Determination of the Opacity of
Emissions
EPA Method 9 is used to observe the visual opacity of emissions (opacity). The observer
stands at a distance sufficient to provide a clear view of the emissions with the sun oriented
in the 140° sector to their back. The line of vision is perpendicular to the plume direction
and does not include more than one plume diameter. Observations are recorded at 15-
second intervals and are made to the nearest 5% opacity. The qualified observer is certified
according to the requirements of EPA Method 9, section 3.1.
Pertinent information regarding the performance of the method is presented below:
o Observations are attempted to be made 30 minutes before, during, or
within 30 minutes after each concurrent particulate run, unless weather
conditions are unfavorable.
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Figure 3-1
US EPA Method 5/202 Sampling Train
3.2 Process Test Methods
The applicable regulations do not require process samples to be collected during this test
program.
FILTER HOLDERTHERMOCOUPLE
Empty
(modified / no tip)
Empty(modified / no tip)
WATER BATH
WATERIN
200-300g
Silica Gel
(modified / no tip)
VACUUM
LINE
ADAPTOR
VACUUM
LINE
ICEBATH
100 ml H2O(modified / no tip)
MANOMETER
BY-PASS VALVE(fine adjust)
AIR TIGHT
PUMP
VACUUM GAUGE
MAIN
VALVE
(coarse adjust)
THERMOCOUPLES
DRY GAS
METER
ORIFICE
GAS
EXIT
WATEROUTCONDENSER
THERMOCOUPLE
THERMOCOUPLE
FILTERHOLDER
HEATED
AREA
THERMOCOUPLE
HEATED PROBENOZZLE
THERMOCOUPLE
SAMPLE LINE
MANOMETER
TYPE “S”PITOT
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4.0 Quality Assurance and Reporting
4.1 QA Audits
Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality
assurance audits are performed as part of the test program to ensure that the results are
calculated using the highest quality data available. This program ensures that the emissions
data we report are as accurate as possible. The procedures included in the cited reference
methods are followed during preparation, sampling, calibration, and analysis. Montrose is
responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose
will also perform the sampling, sample recovery, storage, and shipping. Approved contract
laboratories may perform some of the preparation and sample analyses, as needed.
4.2 Quality Control Procedures
Montrose calibrates and maintains equipment as required by the methods performed and
applicable regulatory guidance. Montrose follows internal procedures to prevent the use of
malfunctioning or inoperable equipment in test programs. All equipment is operated by
trained personnel. Any incidence of nonconforming work encountered during testing is
reported and addressed through the corrective action system.
4.2.1 Equipment Inspection and Maintenance
Each piece of field equipment that requires calibration is assigned a unique identification
number to allow tracking of its calibration history. All field equipment is visually inspected
prior to testing and includes pre-test calibration checks as required by the test method or
regulatory agency.
4.2.2 Audit Samples
When required by the test method and available, Montrose obtains EPA TNI SSAS audit
samples from an accredited provider for analysis along with the samples. Currently, the
SSAS program has been suspended pending the availability of a second accredited audit
sample provider. If the program is reinstated, the audit samples will be ordered. If required
as part of the test program, the audit samples are stored, shipped, and analyzed along with
the emissions samples collected during the test program. The audit sample results are
reported along with the emissions sample results.
4.3 Data Analysis and Validation
Montrose converts the raw field, laboratory, and process data to reporting units consistent
with the permit or subpart. Calculations are made using proprietary computer spreadsheets
or data acquisition systems. One run of each test method is also verified using a separate
example calculation. The example calculations are checked against the spreadsheet results
and are included in the final report. The “Standard Conditions” for this project are 29.92
inches of mercury and 68 °F.
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4.4 Sample Identification and Custody
The on-site Field Project Manager will assume or assign the role of sample and data
custodian until relinquishing custody. The sample custodian will follow proper custody
procedures before departing from the test site including:
Assign the unique sample identification number to each sample.
Attach sample labels and integrity seals to all samples.
Complete COC form(s), ensuring that the sample identification numbers on
the samples match the sample identification numbers on the COC.
Pack and store samples in accordance with the test method requirements in
appropriate transport containers for protection from breakage, contamination,
or loss.
Keep samples in a secure locked area if not in the direct presence of Montrose
staff.
The sample custodian will follow proper custody procedures upon arriving at the Montrose
office including:
Remove samples and COC documents from vehicles and check into
designated secure sample holding areas.
Store samples requiring additional measures such as refrigeration or dry ice
appropriately.
4.5 Quality Statement
Montrose is qualified to conduct this test program and has established a quality
management system that led to accreditation with ASTM Standard D7036-04 (Standard
Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual
functional assessments for conformance with D7036-04 which are conducted by the
American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose
is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04
Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the
documented limits in the test methods are met by using approved test protocols for each
project as defined in D7036-04 Sections 7.2.1 and 12.10. Additional quality assurance
information is included in the appendices. The content of this test plan is modeled after the
EPA Emission Measurement Center Guideline Document (GD-042).
4.6 Reporting
Montrose will prepare a final report to present the test data, calculations/equations,
descriptions, and results. Prior to release by Montrose, each report is reviewed and certified
by the project manager and their supervisor, or a peer. Source test reports will be
submitted to the facility or appropriate regulatory agency (upon customer approval) within
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60 days of the completion of the field work. The report will include a series of appendices to
present copies of the intermediate calculations and example calculations, raw field data,
laboratory analysis data, process data, and equipment calibration data.
4.6.1 Example Report Format
The report is divided into various sections describing the different aspects of the source
testing program. Figure 4-1 presents a typical Table of Contents for the final report.
Figure 4-1
Typical Report Format
Cover Page
Certification of Report
Table of Contents
Section
1.0 Introduction
2.0 Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
4.0 Test Discussion and Results
5.0 Internal QA/QC Activities
Appendices
A Field Data and Calculations
B Facility Process Data
C Laboratory Analysis Data
D Quality Assurance/Quality Control
E Regulatory Information
4.6.2 Example Presentation of Test Results
Table 4-1 presents the typical tabular format that is used to summarize the results in the
final source test report. Separate tables will outline the results for each target analyte and
compare them to their respective emissions limits.
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Table 4-1
Example Particulate Matter Emissions Results -
North Mill Production Area Wet Scrubber Exhaust
Parameter/Units Run 1 Run 2 Run 3 Average
Date XX XX XX
Time XX XX XX
Sampling & Flue Gas Parameters
O2, % volume dry XX XX XX XX
CO2, % volume dry XX XX XX XX
stack gas temperature, °F XX XX XX XX
moisture content, % volume XX XX XX XX
volumetric flow rate, dscfm XX XX XX XX
isokinetic sampling ratio, % XX XX XX XX
Process Information
material throughput rate, tph XX XX XX XX
scrubber pressure drop, in. w.c.XX XX XX XX
scrubber liquid flow rate, gpm XX XX XX XX
Filterable PM (FPM) Results
gr/dscf XX XX XX XX
lb/hr XX XX XX XX
lb/ton material throughput XX XX XX XX
Condensable PM (CPM) Results
gr/dscf XX XX XX XX
lb/hr XX XX XX XX
lb/ton material throughput XX XX XX XX
Total PM (TPM = FPM + CPM) Results
gr/dscf XX XX XX XX
lb/hr XX XX XX XX
lb/ton material throughput XX XX XX XX
Opacity Results
maximum opacity, % -- -- -- XX
minimum opacity, % -- -- -- XX
average opacity, % -- -- -- XX
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Appendix A
Supporting Information
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Appendix A.1
Units and Abbreviations
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UNITS OF MEASUREMENT
@ X% O2 corrected to X% oxygen (corrected for dilution air)
|CC| absolute value of the confidence coefficient
|d| absolute value of the mean differences
ºC degrees Celsius
ºF degrees Fahrenheit
ºR degrees Rankine
" H2O inches of water column
13.6 specific gravity of mercury
pressure drop across orifice meter, inches H2O
velocity head of stack gas, inches H2O
total sampling time, minutes
µg microgram
a density of acetone, mg/ml
w density of water, 0.9982 g/ml or 0.002201 lb/ml
acfm actual cubic feet of gas per minute at stack conditions
An cross-sectional area of nozzle, ft2
As cross-sectional area of stack, square feet (ft2)
Btu British thermal unit
Bws proportion by volume of water vapor in gas stream
Ca particulate matter concentration in stack gas, gr/acf
CAvg average unadjusted gas concentration, ppmv
CDir measured concentration of calibration gas, ppmv
cf or ft3 cubic feet
cfm cubic feet per minute
CGas average gas concentration adjusted for bias, ppmv
CM average of initial and final system bias check responses from upscale
calibration gas, ppmv
cm or m3 cubic meters
CMA actual concentration of the upscale calibration gas, ppmv
CO average of initial and final system bias check responses from low-level
calibration gas, ppmv
Cp pitot tube coefficient
Cs particulate matter concentration in stack gas, gr/dscf
CS calibration span, % or ppmv
CS measured concentration of calibration gas, ppmv
CV manufactured certified concentration of calibration gas, ppmv
D drift assessment, % of span
dcf dry cubic feet
dcm dry cubic meters
Dn diameter of nozzle, inches
Ds diameter of stack, inches
dscf dry standard cubic feet
dscfm dry standard cubic feet per minute
dscm dry standard cubic meters
Fd F-factor, dscf/MMBtu of heat input
fpm feet per minute
fps feet per second
ft feet
ft2 square feet
g gram
gal gallons
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gr grains (7000 grains per pound)
gr/dscf grains per dry standard cubic feet
hr hour
I percent of isokinetic sampling
in inch
k kilo or thousand (metric units, multiply by 10
3)
K kelvin (temperature)
K3 conversion factor 0.0154 gr/mg
K4 conversion factor 0.002668 ((in. Hg)(ft3))/((ml)(°R))
kg kilogram
Kp pitot tube constant (85.49 ft/sec)
kwscfh thousand wet standard cubic feet per hour
l liters
lb/hr pounds per hour
lb/MMBtu pounds per million Btu
lpm liters per minute
m meter or milli
M thousand (English units) or mega (million, metric units)
m3 cubic meters
ma mass of residue of acetone after evaporation, mg
Md molecular weight of stack gas; dry basis, lb/lb-mole
meq milliequivalent
mg milligram
Mg megagram (106 grams)
min minute
ml or mL milliliter
mm millimeter
MM million (English units)
MMBtu/hr million Btu per hour
mn total amount of particulate matter collected, mg
mol mole
mol. wt. or MW molecular weight
Ms molecular weight of stack gas; wet basis, lb/lb-mole
MW molecular weight or megawatt
n number of data points
ng nanogram
nm nanometer
Nm3 normal cubic meter
Pbar barometric pressure, inches Hg
pg picogram
Pg stack static pressure, inches H2O
Pm barometric pressure of dry gas meter, inches Hg
ppb parts per billion
ppbv parts per billion, by volume
ppbvd parts per billion by volume, dry basis
ppm parts per million
ppmv parts per million, by volume
ppmvd parts per million by volume, dry basis
ppmvw parts per million by volume, wet basis
Ps absolute stack gas pressure, inches Hg
psi pounds per square inch
psia pounds per square inch absolute
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psig pounds per square inch gauge
Pstd standard absolute pressure, 29.92 inches Hg
Qa volumetric flow rate, actual conditions, acfm
Qs volumetric flow rate, standard conditions, scfm
Qstd volumetric flow rate, dry standard conditions, dscfm
R ideal gas constant 21.85 ((in. Hg) (ft3))/((°R) (lbmole))
SBfinal post-run system bias check, % of span
SBi pre-run system bias check, % of span
scf standard cubic feet
scfh standard cubic feet per hour
scfm standard cubic feet per minute
scm standard cubic meters
scmh standard cubic meters per hour
sec second
sf, sq. ft., or ft2 square feet
std standard
t metric ton (1000 kg)
T 0.975 t-value
Ta absolute average ambient temperature, ºR (+459.67 for English)
Tm absolute average dry gas meter temperature, ºR (+459.67 for English)
ton or t ton = 2000 pounds
tph or tons/hr tons per hour
tpy or tons/yr tons per year
Ts absolute average stack gas meter temperature, ºR (+459.67 for English)
Tstd absolute temperature at standard conditions
V volt
Va volume of acetone blank, ml
Vaw volume of acetone used in wash, ml
Vlc total volume H2O collected in impingers and silica gel, grams
Vm volume of gas sampled through dry gas meter, ft3
Vm(std)volume of gas measured by the dry gas meter, corrected to standard
conditions, dscf
Vma stack gas volume sampled, acf
Vn volume collected at stack conditions through nozzle, acf
Vs average stack gas velocity, feet per second
Vwc(std) volume of water vapor condensed, corrected to standard conditions, scf
Vwi(std)volume of water vapor in gas sampled from impingers, scf
Vwsg(std)volume of water vapor in gas sampled from silica gel, scf
W watt
Wa weight of residue in acetone wash, mg
Wimp total weight of impingers, grams
Wsg total weight of silica gel, grams
Y dry gas meter calibration factor, dimensionless
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ABBREVIATIONS
AAS atomic absorption spectroscopy
ACDP air contaminant discharge permit
ACE analyzer calibration error, percent of span
AD absolute difference
ADL above detection limit
AETB Air Emissions Testing Body
AS applicable standard (emission limit)
ASTM American Society for Testing and Materials
BACT best achievable control technology
BDL below detection limit
BHP brake horsepower
BIF boiler and industrial furnace
BLS black liquor solids
CC confidence coefficient
CD calibration drift
CE calibration error
CEM continuous emissions monitor
CEMS continuous emissions monitoring system
CERMS continuous emissions rate monitoring system
CET calibration error test
CFR Code of Federal Regulations
CGA cylinder gas audit
CHNOS elemental analysis for determination of C, H, N, O, and S content in fuels
CNCG concentrated non-condensable gas
CO catalytic oxidizer
COC chain of custody
COMS continuous opacity monitoring system
CPM condensable particulate matter
CPMS continuous parameter monitoring system
CT combustion turbine
CTM conditional test method
CTO catalytic thermal oxidizer
CVAAS cold vapor atomic absorption spectroscopy
De equivalent diameter
DE destruction efficiency
Dioxins polychlorinated dibenzo-p-dioxins (PCDDs)
DLL detection level limited
DNCG dilute non-condensable gas
ECD electron capture detector
EIT Engineer in Training
ELCD electrolytic conductivity detector (hall detector)
EMPC estimated maximum possible concentration
EPA US Environmental Protection Agency
EPRI Electric Power Research Institute
ES emission standard (applicable limit)
ESP electrostatic precipitator
EU emission unit
FCCU fluid catalytic cracking unit
FGD flue gas desulfurization
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FI flame ionization
FIA flame ionization analyzer
FID flame ionization detector
FPD flame photometric detector
FPM filterable particulate matter
FTIR Fourier-transform infrared spectroscopy
FTPB field train proof blank
FTRB field train recovery blank
Furans polychlorinated dibenzofurans (PCDFs)
GC gas chromatography
GC/MS gas chromatography/mass spectroscopy
GFAAS graphite furnace atomic absorption spectroscopy
GFC gas filter correlation
GHG greenhouse gas
HAP hazardous air pollutant
HC hydrocarbons
HHV higher heating value
HPLC high performance liquid chromatography
HRGC/HRMS high-resolution gas chromatography/high-resolution mass spectroscopy
HRSG heat recovery steam generator
IC ion chromatography
ICAP inductively-coupled argon plasma emission spectroscopy
ICPCR ion chromatography with a post-column reactor
ICP-MS inductively coupled plasma-mass spectroscopy
IR infrared radiation
ISO International Standards Organization
kW kilowatts
LFG landfill gas
LHV lower heating value
LPG liquified petroleum gas
MACT maximum achievable control technology
MDI methylene diphenyl diisocyanate
MDL method detection limit
MNOC maximum normal operating conditions
MRL method reporting limit
MS mass spectrometry
NA not applicable or not available
NCASI National Council for Air and Steam Improvement
NCG non-condensable gases
ND not detected
NDIR non-dispersive infrared
NESHAP National Emissions Standards for Hazardous Air Pollutants
NG natural gas
NIOSH National Institute for Occupational Safety and Health
NIST National Institute of Standards and Technology
NMC non-methane cutter
NMOC non-methane organic compounds
NMVOC non-methane volatile organic compounds
NPD nitrogen phosphorus detector
NSPS New Source Performance Standards
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OSHA Occupational Safety and Health Administration
PAH polycyclic aromatic hydrocarbons
PCB polychlorinated biphenyl compounds
PCWP plywood and composite wood products
PE Professional Engineer
PFAS per- and polyfluoroalkyl substances (PFAS)
PI photoionization
PID photoionization detector
PM particulate matter
PM10 particulate matter less than 10 microns in aerodynamic diameter
PM2.5 particulate matter less than 2.5 microns in aerodynamic diameter
POM polycyclic organic matter
PS performance specification
PSD particle size distribution
PSEL plant site emission limits
PST performance specification test
PTE permanent total enclosure
PTM performance test method
QA/QC quality assurance and quality control
QI Qualified Individual
QSTI Qualified Source Testing Individual
RA relative accuracy
RAA relative accuracy audit
RACT reasonably available control technology
RATA relative accuracy test audit
RCTO rotary concentrator thermal oxidizer
RICE stationary reciprocating internal combustion engine
RM reference method
RTO regenerative thermal oxidizer
SAM sulfuric acid mist
SCD sulfur chemiluminescent detector
SCR selective catalytic reduction system
SD standard deviation
Semi-VOST semi-volatile organic compounds sample train
SRM standard reference material
TAP toxic air pollutant
TBD to be determined
TCA thermal conductivity analyzer
TCD thermal conductivity detector
TGNENMOC total gaseous non-ethane non-methane organic compounds
TGNMOC total gaseous non-methane organic compounds
TGOC total gaseous organic compounds
THC total hydrocarbons
TIC tentatively identified compound
TO thermal oxidizer
TO toxic organic (as in EPA Method TO-15)
TPM total particulate matter
TSP total suspended particulate matter
TTE temporary total enclosure
ULSD ultra-low sulfur diesel
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UV ultraviolet radiation range
VE visible emissions
VOC volatile organic compounds
VOST volatile organic sample train
WC water column
WWTP waste water treatment plant
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CHEMICAL NOMENCLATURE
Ag silver NOx nitrogen oxides
As arsenic O2 oxygen
Ba barium P phosphorus
Be beryllium Pb lead
C carbon PCDD polychlorinated dibenzo-p-dioxins
Cd cadmium PCDF polychlorinated dibenzofurans
CdS cadmium sulfide Sb antimony
CH2O formaldehyde SO2 sulfur dioxide
CH3CHO acetaldehyde SO3 sulfur trioxide
CH3OH methanol SOx sulfur oxides
CH4 methane TCDD tetrachlorodibenzodioxin
C2H4O ethylene oxide TCDF tetrachlorodibenzofuran
C2H6 ethane TGOC total gaseous organic concentration
C3H4O acrolein THC total hydrocarbons
C3H6O propionaldehyde Tl thallium
C3H8 propane TRS total reduced sulfur compounds
C6H5OH phenol Zn zinc
Cl2 chlorine
ClO2 chlorine dioxide
CO carbon monoxide
Co cobalt
CO2 carbon dioxide
Cr chromium
Cu copper
EtO ethylene oxide
EtOH ethyl alcohol (ethanol)
H2 hydrogen
H2O water
H2O2 hydrogen peroxide
H2S hydrogen sulfide
H2SO4 sulfuric acid
HCl hydrogen chloride
Hg mercury
IPA isopropyl alcohol
MDI methylene diphenyl diisocyanate
MeCl2 methylene chloride
MEK methyl ethyl ketone
MeOH methanol
Mn manganese
N2 nitrogen
NH3 ammonia
Ni nickel
NO nitric oxide
NO2 nitrogen dioxide
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Appendix A.2
Accreditation Information/Certifications
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35

o
f

6
7
GP
0
8
1
A
S
-
0
5
3
8
9
6
-
P
P
-
9
8
1
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Appendix A.3
Stack Schematics
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Appendix A.4
UDEQ Approval Order DAQE-AN107260022-18
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Appendix “S”
Field Work Safety Plan
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SITE SAFETY PLAN BOOKLET
Project: _____________________
Customer: ___________________
Location: ____________________
Units: _______________________
Client Project Manager: ______________________
Revision Date:June 29th, 2023
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PROJ-053896
Morton Salt
Granstville, Utah
Four (4) Wet Scrubber Units
Cheyney Guymon/Austin Tramell
Page 1 of 2
Site Safety Plan and JHA Purpose and Instructions

Purpose
Employee safety is the top priority of Montrose Environmental Group. All employees must be
trained to assess and mitigate hazards. The District Manager and Project Manager are
responsible to ensure all hazards have been properly identified and managed. All employees
have Stop Work Authority in all situations where an employee feels they or their co-worker
cannot perform a job safely or if there is a task for which they have not been adequately trained.
The Site Safety Plan (SSP) has been developed to help assist Montrose test crews with
identifying physical and health hazards and determining how the hazards will be managed.
Additionally, the SSP will help each crew manage the safety of the employees by providing
emergency procedures and information. The booklet contains a several safety forms that may
be required in the field.
Instructions
The SSP consists of the following:

communicated to all employees, signed, and posted.
Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed,
CPM will maintain a roster and be responsible for accounting for all employees. The Job
to work commencing. In the event of an emergency situation/ evacuation, the Job Supervisor/
emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior
the Emergency Action Plan form and ensure that all employees are familiar with the facility
4. Emergency Action Plan -The Job Supervisor/ Client Project Manager (CPM) will complete
observed plus applicable PPE that may be required.
administrative controls that a crew can use to reduce or eliminate the hazards they have
3. Hazard Control Matrix - contains useful information on both engineering and
with the toolbox topic and signatures can be added to the SSP packet.
the hazard analysis is required daily for the duration of the test. An additional sheet of paper
modified when conditions change. A toolbox meeting with a daily topic in addition to a review of
sign on the Job Hazard Analysis form in agreement and sign in Section 10. The JHA is to be
Each team member has the option to discuss making changes or adding to the JHA and must
Section 9 will require at least three tasks, hazards and controls be identified for the project.
form for accuracy, making any corrections required and complete the remainder of the JHA.
complete the JHA form through section 8. Upon arrival at the test site, the team will review the
daily hazard review with sign off by the team. The client Project Manager is responsible to
and controls. The form also includes a daily toolbox topic and
2. A Job Hazard Analysis is a standardized, two-page, fillable form that is used to evaluated the
prior to the test.
1. A Pre-Mobilization Test Plan
AQS-FRM-1.13R1
Extended Hours Formc.
Heat Stress Prevention Form Based on Heat Indexb.
MEWP Lift Inspection Forma.
Additional Forms, as applicable5.
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Page 2 of 2
Site Safety Plan and JHA Purpose and Instructions

The SSP is a living document. The Project Manager should continually update their SSPs as
new information and conditions change or if new hazards are presented.
Each completed SSP should be maintained with the Test Plan in the office for a period of 3
years. There will be an audit process developed for the Site Safety Plans.
AQS-FRM-1.13R1
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Page 1 of 2
PRE-MOBILIZATION TEST INFORMATION
Source Type: New Source: ____ Revisit: ____ Prj#/Date/Tech: __________________________
Coal Fired Electric Utility: ____ Ethanol Plant: ____ Chemical Mfg. of _________________________
Cement/Lime Kiln Plant: ____ Specialty Mfg. of: ___________ Other: _______________
Anticipated Effluent Composition check all that apply and fill in expected concentration in ppm/%
CO NOX SO2 VOC other
If other, explain: _______________________________________________________
Flammable: _______ Toxic: ________ Corrosive: _______ Dust: __________
Engineering Controls to be Implemented:
______________________________________________________________________________________
__________________________________________________________________________________
Additional Safety Equipment Required:
Personal gas monitors: ____
Respiratory Protection:
Half Face____ Full Face____ HEPA Filters____ Supplied Air: _____ (Safety Dept. Approval)
Approximate Flue Gas Temperatures, (F)
below 210 210 to 450 450 to 950 above 950 other
If other, explain: _______________________________________________________
Approximate Duct Pressure, (iwg):
below -3 -3 to +3 +3 to +7 above +7 other
If other, explain: _______________________________________________________
PROJECT NAME/LOCATION: ______________________ PROJECT #: ____________________
TEST DATE: ______________________ PROJECT MANAGER: ___________________
TEST SCOPE: _________________________________________________________________
SITE CONTACT: Name: _____________________ Contact Phone: _________________________
AQS-FRM-1.17
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Page 2 of 2
PRE-MOBILIZATION TEST INFORMATION
Sampling Location: Stack Port ____ Duct Port ____
Approximate Sampling Platform Height, (ft)

Effluent Chemical Regulatory Limits
Gas Name Chemical
Formula
Cal OSHA PEL1
(ppm)
Cal OSHA
STEL2
(ppm)
NIOSH REL
TWA3 (ppm)
Cal OSHA
Ceiling
(ppm)
IDLH4
(ppm)
Carbon Monoxide CO 25 200 35 200 1,200
Nitric Oxide NOx 25 ND5 25 ND 100
Sulfur Dioxide SO2 2 5 2 ND 100
Hydrogen Chloride HCl 0.3 2 ND 2 50
Hydrogen Sulfide H2S 10 15 10 (10 min.)C 50 100
1: California Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) based on an 8-hour shift;
2: Cal OSHA Short-term Exposure Limit (STEL) based on a 15-minute period;
3: National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) Time-weighted Average (TWA) based
on an 8-hour shift;
4: Immediately Dangerous to Life or Health (IDLH);
5: Not Defined (ND);
C: Ceiling Limit - Maximum allowable human exposure limit for an airborne or gaseous substance, which is not to be exceeded, even momentarily.
Prepared by: Date:
Reviewed by: Date:
______________________________________________________________________________
______________________________________________________________________________
Additional Information:
______________________________________________________________________________
______________________________________________________________________________
Describe how equipment will be mobilized to the sampling location:
Other:_____________________________________________________________________________
Guardrails: ____ Toe plate: ____ Engineered Tie Off Points: ____ Heat Shield: ____
Elevators: ____ Ladders: ____ MEWP Lift: ____ Scaffold: ____ Equipment Hoist: ____
Access and Protection:
If other, explain: _______________________________________________________
below 6 6 to 50 50 to 100 above 100 other
AQS-FRM-1.17
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1.
Job Preparation
2. Facility Information/Emergency Preparedness
If non-emergency medical attention is needed, call: AXIOM #: 877-502-9466.
Source Information: (list type):
3. Error Risk
4. Physical Hazards Hazard Controls
Potential Hazards for Consideration
See also Sect. 7
See also Sect. 8
5. Required PPE
If the heat index is expected to be above 91°, fill out the Heat Stress Prevention Form.
All hazards and mitigation steps must be documented.
If this JHA does not cover all the hazards identified,
use Section 9 to document that information.
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Additional Work Place Hazards
6.Critical Procedures *
7. Working From Heights
8.Other Considerations
Environmental Hazards - Weather Forecast
Electrical Safety Planning
List of Hazardous Chemicals Other Chemicals:
Wildlife/Fauna in Area
9. Observed Hazards and Mitigation Steps
Task Potential Hazard(s)Steps for Mitigation
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10.JHA REVIEW: Crew Names & Signatures
11.Daily JHA Meeting & Review
Items to review:
Printed Name Signature
2
Discussion TopicDay
Initialing demonstrates that site conditions and hazards have not changed from the original SSP. If changes did occur, make the
necessary updates to this JHA and add notes as applicable in Section 9.
Initials
9
8
7
6
3
Date Printed Name Signature Date
5
4
11
10
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1
2
3
4
5
6 Local Hospital/ Clinic Telephone Number:
7
8
9
10
11
12
13
14
15
16
17
MEG Job Supervisor/ CPM's Telephone Number:
Plant's #1 Contact Person's Name:
Plant's #1 Contact Person's Telephone Number:
MEG Job Safety Supervisor's Telephone Number:
Plant's Emergency Telephone Number:
Emergency Ops Radio Channel:
The Fire Extinguisher is Located:
Eye Wash and Safety Shower Location:
The First Aid Kit is Located:
Page 1 of 2
The Job Supervisor/ Client Project Manager (CPM) will ensure that all employees are familiar with the facility emergency and evacuation
procedures, assembly/ rally points, alert systems, and signals prior to work commencing. In the event of an emergency situation/
evacuation, the Job Supervisor/ CPM will maintain a roster and be responsible for accounting for all employees. The Job Supervisor/
CPM will ensure that this Emergency Action Plan Form is completed, communicated to all employees, and posted.
CALL 911 IMMEDIATELLY
If non-emergency medical attention is needed, call AXIOM Medical number: 877-502-9466.
EMERGENCY ACTION PLAN FORM
MEG Job Supervisor/ CPM's Name:
MEG Job Safety Supervisor (if applicable):
Evacuation Routes:
Severe Weather Shelter Location:
Plant's #2 Contact Person's Name:
Plant's #2 Contact Person's Telephone Number:
Designated Assembly Point Location:
AQS-FRM-1.11
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1
2
4
5
Signature: Date: Printed Name: Signature: Date:
EVACUATE:____________________________________;
OTHER:_______________________________________;
Alarm Tones:
EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBLY MAP REVIEW: Crew Names and Signatures
Printed Name:
Draw the evacuation and assembly map here
Page 2 of 2
EMERGENCY EVACUATION AND ASSEMBLY MAP
3
Designated Shelter(s) Description:
Designated Assembly Point(s) Description:
YES or NO
Facility Name:
Facility Alarm (Circle):
FIRE:_________________________________________;
CHEMICAL/ GAS:_______________________________;
SHELTER-IN-PLACE:_____________________________;
AQS-FRM-1.11
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Serial Number:
Make: Rented or Owned:
Check if an item is adequate, operational, and safe.
Yes No N/A

2. Hydraulic fluid level is sufficient, with the platform fully lowered
3. Hydraulic system pressure (see manufacturer specs) is acceptable.
If the pressure is low, determine cause and repair in accordance with accepted procedures
as outlined in service manual.

4. Tires and wheel lug nuts (for tightness)
5. Hoses and cables (i.e. worn areas or chafing)
6. Platform rails and safety gate (no damage present)
7. Pivot pins secure
8. Welds are not cracked and structural members are not bent or broken
9. Warning and instructional labels are legible and secure, and load capacity is clearly marked.
10
11. Base controls (switches and push buttons) can be properly operated
12. Platform conditions are safe (i.e. not slippery)
13. Fire extinguisher is present, mounted and fully charged, located inside the bucket
14. Headlights, safety strobe light and back-up alarm are functional
15. Workplace is free of hazards (overhead powerlines, obstructions, level surface, high winds,
etc.) *Do not operate if winds are 20 mph, unless otherwise specified by manufacturer
recommendations.

Operator Name & Signature Location Date
Ground Control Name & Signature Location Date
Harness Inspections:
Printed Name Signature Date
Printed Name Signature Date
Printed Name Signature Date
Daily MEWP Lift Inspection Form
Page 1 of 1
atthe beginning of each shift or following 6 to 8 hours of use.
All checks must be completed prior to each work shift, before operation of the MEWP lift. This checklist must be used
MEWP Lift Model #:
loose hoses, etc.)if something can be easily loosened by hand then it is not sufficient.
1.All MEWP lift components are in working condition (i.e. no loose or missing parts, torn or
Items to be Inspected
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Extended Hours Safety Audit
1.Hold test crew meeting Test crew initials:
3.Contact the client
Final Outcome:
Approver:
Notify DM or RVP2.
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001AS-SAFETY-FM-5

Heat Stress Prevention Form

This form is to be used when the Expected Heat Index is above 91° F, and is to be kept with project
documentation.

Project Manager (PM): Expected High Temp:
Date(s): Expected Heat Index:

1. Review the signs of Heat Exhaustion and Heat Stroke

2. If Heat Index is above 91° F:
Provide cold water and/or sports drinks to all field staff (avoid caffeinated drinks and energy
drinks which can increase core temperature).
o Bring no less than one gallon of water per employee
If employee(s) are dehydrated, on blood pressure medication or not acclimated to heat,
ensure they are aware of the heightened risk for heat illness
Provide cool head bands/vests/etc.
Have ice available to employees
Implement work shift rotations and breaks, particularly for employees working in direct
sunlight.
Provide as much shade at the jobsite as possible, including tarps, tents or other acceptable
temporary structures.
PM should interview each field staff periodically to evaluate for signs of heat illness

3. If Heat Index is above 103° F:
Employees must stop for drinks and breaks every hour (about 4 cups/hour)
Employees are not permitted to work alone for more than one hour at a time without a
break offering shade and drinks
Employees should wear cool bands and vests if working outside more than one hour at a
time
PM should interview each field staff every 2 hours to evaluate for signs of heat illness

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Morton Salt Inc. Salt Processing Plant, Four (4) Sources for PM10 and VEs Testing
2025 Compliance Source Test Plan, Grantsville, UT
This is the Last Page of This Document
If you have any questions, please contact one of the following
individuals by email or phone.
Name: Beckie Hawkins
Title: District Manager
Region: USA - Stack - Great Plains - Operations
Email: [e-mail]
Phone: [phone]
Name: Cheyney Guymon
Title: Client Project Manager
Region: Great Plains Region, Utah Office
Email: [e-mail]
Phone: [phone]
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