HomeMy WebLinkAboutDAQ-2025-0026291
DAQC-517-25
Site ID 11767 (B2)
MEMORANDUM
TO: FILE – GENPAK
THROUGH: Harold Burge, Major Source Compliance Section Manager
FROM: Joseph Randolph, Environmental Scientist
DATE: May 28, 2025
SUBJECT: Title V Annual Compliance Certification Receipt/Review,
FRS ID # UT0000004902100036
REPORT RECEIVED/DUE DATE: April 14, 2025 (email)/April 15, 2024
May 27, 2025, revised copy
TITLE V PERMIT #: 2100036004, February 12, 2020
2100036005, February 24, 2025, renewal
DATE OF LAST PERMIT REVISION: February 24, 2025
CERTIFICATION PERIOD: March 31, 2024, to March 31, 2025
FACILITY REPORTED
COMPLIANCE STATUS: Intermittent
REPORT EVALUATION:
● Was the report submitted on time? Yes
● Did the report contain the method to determine compliance? Yes
● Was the compliance status marked as continuous or intermittent? Yes
● Did the report identify the status of compliance of each term or condition? Yes
● Was the report signed and properly certified by a responsible official? Yes
● Were exceedances/excursions reported? Yes
● Were deviations reported? Yes
II.B.3.a. Thermal oxidizer below 1,360 F as required. October 10, 2024 and October 18, 2024.
Deviation reports submitted. NFA.
Note: Original certification had intermittent and deviation dates for condition I.B but not condition
II.B.3.a. This was corrected and certification resubmitted.
CURRENT RECOMMENDATION:
The report appears to meet the requirements of Title V operating permit condition I.L.
ATTACHMENT:
Annual Compliance Certification Report
0 8
Section 1: GENERAL PROVISIONS
To: Director, Utah Air Quality Board
From: Genpak, LLC
2791 West Highway 56
Cedar City, UT 84720
Re: Annual Compliance Certification fbr Permit #: 2100036004
Date: April30,2025
DEPARTMENT OF
ENVIRONMEMTAL OUATJTY
MAY - I 2025
ovtsroil (r An qnuw
In accordance with Operating Permit provision I.L. and Utah Administrative Code (UAC) R307-415-6c(5),
the following compliance certification is submitted.
This certification covers operations from 31 March 2024 to 31 March 2025. This is a revision to update the
operating permit number.
I.B. Was the source operated in compliance with the operating permit?
I.C.3 Did the permittee furnish information requested by the Executive Secretary?
Complionce Status:Compliance Type:Re os on (s) for No n-C o mpl ia nce
/ In comoliance y' Intermittent
C o mn liance De mo nstratio n Meth o d :Records Review
Compliance Status:Compliance Type:Reaso n (s) fo r No n-Co mp I ian c e
/ In compliance / Continuous
Compliance Demonstration Method :Review of Records
Issued l2 February 2020 1'litle V Opcrating l)crmit # 21000-16004
Compliance Status:Compliance Type:Re aso n (s) for No n-C o mp I iance
In comoliance / Continuous
Co mn I iance De monstratio n Meth o d :Review of Records
I.G.l Did the permittee pay the annual emission fee?
I.G.2 Was the fee paid on time?
I.K. Were all application forms, reports and certifications submitted pursuant to the permit properly
certified by a responsible official?
I.L.1 Did the permittee submit this compliance certification complete and on time?
I.L.2 Did the permittee also send all compliance certifications to EPA?
I.S.1.a Did the permittee properly retain all records required by the permit?
Compliance Status:Compliance Type:Re as o n (s) fo r No n-Co mp I ianc e
/ In compliance / Continuous
Comoliance Demonstration Method:Review of Records
Compliance Status:Compliance Type:Re a s o n (s) fo r No n-C o mp I ianc e
/ In comoliance y' Continuous
Co mo lianc e De monstrati o n M eth o d :Review of Records
Compliance Status:Compliance Type:Rea s o n (s) fo r No n-C o mp I ia nce
In comoliance / Continuous
Co mo lionce De monstratio n Meth o d :Review of Records
Compliance Status:Compliance Type:Reaso n (s) for No n-C o mp I iance
/ In comoliance / Continuous
C omo I iance De mo nstratio n Met h od :Review of Records
Compliance Status:Compliance Type:Re as o n (s) fo r No n-C o mp lianc e
/ In comoliance / Continuous
Co molia nc e De mo nstratio n Meth o d :Review of Records
lssued l2 February 2020 2'I'irle V Ope rating l)ermit # ? I0()016004
Compliance Status:Compliance Type:Re ason (s) fo r No n-C o mp I ianc e
/ In compliance / Continuous
Comnliance Demonstratio n Method :Review of Records
I.S.l.b Did the permittee include all applicable information in records of monitoring required by the
permit?
I.S.2.a Did the permittee submit monitoring reports every six months, or more frequently if specified
in Section II and were all instances of deviation from permit requirements clearly identified in the
monitoring reports?
I.S.2.c Did the permittee promptly notiff the Director of all deviations from permit requirements?
I.U. Did the permittee submit the inventory required by R307-150 in accordance with the
requirements of that rule?
Compliance Status:Compliance Type:Reoso n (s) fo r No n-C o mp I ianc e
/ In comoliance / Continuous
Comoliance Demonstration Method:Review of Records
Compliance Status:Compliance Type:Re as o n (s) fo r No n-C o mp I ianc e
r' In comoliance / Continuous
Co moliance De monstration Method :Review of Records
Compliance Status:Complionce Type:Rea so n (s) for No n-C ompl ia nc e
/ In comoliance / Continuous
Comoliance Demonstration Method :Review of Records
Issued l2 l:ebruary 2020 3Title V Operating Perrnit # 2100036004
Section II: SPECIAL PROVISIONS
II.B. Requirements and Limitations.
The following emission limitations, standards, and operational limitations apply to the permitted facility as
indicated:
II.B.l Conditions on rrermitted source (Source-wide)
II.B.1.a
A Risk Management Plan (RMP) developed in accordance w'ith 40 CFR Part 68 shall be submitted to the
United States Environmental Protection Agency not later than the applicable date in 40 CFR 68.10(a).
[Authority granted under 40 CFR 68: condition originated in 40 CFR Part 68]
II.B. l.a.l Monitoring:
A copy of the Risk Management Plan shall be available upon request along with a copy of the transmittal
letter to the EPA.
II.B. 1.a.2 Recordkeeping:
A copy of the Risk Management Plan shall be available to the Director upon request along with a copy of the
transmittal letter to the EPA.
II.8.1.a.3 Reporting:
There are no reporting requirements fbr this provision except those specified in Section I of this permit.
Compliance Status:Compliance Type:Rea so n (s) fo r No n-C o mp I iance
/ In comoliance / Continuous
Comoliance De monstration Method :Review of Records
Compliance Status:Compliance Type:Reaso n (s) fo r No n-Co mpl ia nc e
/ In comoliance "/ Continuous
Co mp I iance De monstrati o n Meth o d :Review of Records
Compliance Status:Compliance Type:Re as o n (s) fo r No n-C o mp I ia nce
/ In comoliance / Continuous
C o mpliance De mo nstrotio n Meth o d :Review of Records
lssued l2 trebruary 2020 4-litlc V Opcrating Permit # 2100016004
II.B.1.b
At all times, including periods of start-up, shut-down, and malfunction, the permittee shall to the extent
practicable, maintain and operate any permitted plant equipment, 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. [Authority
granted under R307-401-8(2); condition originated in DAQE-AN0117670014-181
II.B.1.b.l Monitoring:
Records required for this permit condition will serve as monitoring.
II.B.l.b.2 Recordkeeping:
Permittee shall document activities performed to assure proper operation and maintenance. Records shall be
maintained in accordance with Provision I.S.1 of this permit.
II.8.1.b.3 Reporting:
There are no reporting requirements forthis provision except those specified in Section I of this permit.
II.B.1.c
Emissions of the blowing agent (Non-HAP VOC's) shall not exceed 191.92 tons per rolling l2-month
period. This includes the VOC emissions resulting from up to l0 days of maintenance and repair time during
which the thermal oxidizer may be inoperable. The blowing agents are isopentane and butane. [Authority
granted under R307-40 I -8; condition originated in DAQE-AN I 1 76700 1 4- I 8l
Compliance Status:Compliance Type:Re as o n (s) fo r No n-C o mp lia nce
/ In compliance / Continuous
C omol ian ce De mon stratio n Met ho d :Work Practice
Compliance Status:Compliance Type:Reaso n (s) fo r No n-C o mpl iance
/ In compliance r' Continuous
Co molia n ce De mo nstratio n Metho d :Recordkeepinq and Review of Records
Compliance Stutus:Compliance Type:Reaso n (s) fo r No n-C o mp I iance
/ [n compliance / Continuous
C o mp liance De mo nstration M eth o d :Review of Records
lssued l2 lrebruary 2020 5'l itlc V Operating I)e rrnit # 2 100036004
II.B. 1.c.1 Monitoring:
The amount of blowing agent (Non-HAP VOC) emitted shall be calculated as37.4"/" of total blowing agent
consumed. Consumption records shall be maintained fbr all periods of operation. By the twentieth (20th)
day of each month, a new rolling l2-month total shall be calculated using data from the previous l2-months.
Calculations of emissions from the thermal oxidizer shall includ e 80%o ol' emissions fiom the two repelletizer
lines, S-7a and S-7b, and the vents from two white fluff silos, S-5o and S-5p, using a destruction efficiency
of 98.5oh.
II.B.l.c.2 Recordkeeping:
Results of monitoring shall be maintained as described in Provision LS.1 of this permit.
II.8.1.c.3 Reporting:
There are no reporting requirements for this Provision except those specifled in Section I of this permit.
II.B.1.d
Visible emissions shall be no greater than20 percent opacity. [Authority granted under R307-401-8;
condition originated in DAQE-ANl 17670014-1 8l
II.8.1.d.1 Monitoring:
A visual opacity survey of each affected emission unit shall be perfbrmed on a monthly basis by an
individual trained on the observation procedures of 40 CFR Part 60, Appendix A, Method 9. If visible
emissions other than steam are observed from an emission unit, an opacity determination of that emission
unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity
determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-
approved testing method, as acceptable to the Director, fbr point sources, and in accordance 58 FR 61640
Method 203A, or other EPA-approved testing method, as acceptable to the Director, for fugitive sources.
Compliance Status:Compliance Type:Reaso n (s) fo r No n-C o mp I ianc e
/ In compliance r' Continuous
Compliance Demonstratio n Method :Review of Records
Compliance Status:Compliance Type:Re as o n (s) fo r No n-C o mp I ia nce
/ In compliance / Continuous
C ompliance De mo n st ratio n Met h od :Review of Records
Compliance Stotus:Compliance Type:Rea so n (s) fo r No n-Co mp I ia nce
/ In comoliance / Continuous
Co molianc e De mo n stratio n Meth od :Review of Records
lssued l2 Fehruarv 2020 6'l itle V Operating l'ermit # 2100036004
II.B. 1.d.2 Recordkeeping:
Results of monitoring shall be maintained as described in Provision I.S.1 of this permit.
II.8.1.d.3 Reporting:
There are no reporting requirements for this provision except those specified in Section I of this permit.
II.B.l.e
The permittee shall comply with the applicable requirements for recycling and emission reduction for class I
and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction. [Authority
granted under 40 CFR 82.150(b); condition originated in 40 CFR Part 82 Subpart Fl
Compliance Status:Compliance Type:Re as on (s) fo r No n-Co mp I ia nc e
In comoliance y' Continuous
Comoliance Demonstration Method :Review of Records
II.B. l.e. I Monitoring:
The permittee shall certify,
compliance status with the
in the annual compliance statement required in Section I of this permit, its
requirements of 40 CFR 82, Subpart F.
Compliance Status:Compliance Type:Reaso n (s) fo r No n-Co mp I ia nc e
/ In compliance r' Continuous
Comolionce De monstrstion Method :Review of Records
II.B.1.e.2 Recordkeeping:
All reports required in 40 CFR 82, Subpart F shall be maintained consistent with the requirements of
Provision S.l in Section I of this permit.
II.8.1.e.3 Reporting:
All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no additional
reporting requirements except as outlined in Section I of this permit.
Compliance Status:Compliance Type:Reason (s) fo r N o n-C o mp I ia nce
/ In comoliance y' Continuous
Compliance Demonstration Method:Review of Records
lssued l2 February 2020 7'litle V Ope rating l)ermit # 2 100036004
II.B.1.f
The permittee shall comply with the applicable requirements for servicing of motor vehicle air conditioners
pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle Air Conditioners. fAuthority granted under
40 CFR 82.30(b); condition originated in 40 CFR 821
II.B.1.f.l Monitoring:
The permittee shall certify, in the annual compliance statement required in Section I of this permit, its
compliance status with the requirements of 40 CFR 82, Subpart B.
II.B. 1.f.2 Recordkeeping:
All reports required in 40 CFR 82, Subpart B shall be maintained consistent with the requirements of
Provision S.l in Section I of this permit.
II.8.1.f.3 Reporting:
All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are no reporting
requirements for this provision except those specified in Section I of this permit.
II.B.1.g
Visible emissions shall be no greater than 10 percent opacity from each natural gas fuel combustion exhaust
point. [Authority granted under R307-401-8; condition originated in DAQE-AN117670014-l8l
II.B.1.g.l Monitoring:
Records required for this permit condition will serve as monitoring.
Compliance Status:Compliance Type:Reoso n (s) fo r No n-C o mp I iance
ln comoliance Continuous We do not service automobile air conditioners
Comoliance Demonstration Method :Review of Records
Compliance Status:Compliance Type:Reaso n (s) fo r No n-Co mp I ianc e
In compliance Continuous We do not service automobile air conditroners
C o mp I iance De mo nstratio n Meth o d :Review of Records
Compliance Status:Compliance Type:Reaso n (s) fo r No n-C o mp I ia nce
ln comoliance / Continuous
C o moliance De mo nstratio n Meth o d :Review of Records
lssued l2 lrebruary 2020 8Titlc V ()perating l)crnrrt f 21000.i600.1
II.B. 1.g.2 Recordkeeping:
In lieu of visible emissions observations, records of fuel usage shall be maintained consistent with the
requirements of Provision I.S.l of this permit to demonstrate that only natural gas is being burned.
II.8.1.g.3 Reporting:
There are no reporting requirements for this provision except those specified in Section I of this permit.
II.B.2 Conditions on Fifteen (15) Storaee Silos
II.B.2.a
Visible emissions shall be no greater than 10 percent opacity fiom each baghouse. [Authority granted under
R307-40 I -8; condition originated in DAQE-ANl I 7 670014-181
II.B.2.a.l Monitoring:
A visual opacity survey of each aflbcted emission unit shall be performed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix. Method 9. If visible emissions
other than steam are observed from an emission unit, an opacity determination of that emission unit shall be
performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be
performed in accordance with 40 CFR 60, Appendix A, Method 9.
11.8.2.a.2 Recordkeepin g:
Results of monitoring shall be maintained as described in Provision I.S.1 of this permit.
II.8.2.a.3 Reporting:
There are no reporting requirements for this provision except those specified in Section I of this permit.
II.B.3 Conditions on Thermal Oxidizer
II.B.3.a
Compliance Status:Compliance Type:Re aso n (s) fo r No n-Co mp I iu nc e
In compliance / Continuous
Co mo lianc e De mo nst ratio n Metho d :Review of Records
Compliance Status:Compliance Type:Reaso n (s) fo r No n-Co mp I iance
/ In compliance r' Continuous
C omp liance De mo nstratio n Metho d :Review of Records
lssued l2 Irebruary 2020 gTitle V Operating Pernrit # 2100036001
Operating temperature shall be no less than 1,360 degrees F. fAuthority granted under R307-401-8;
condition originated in DAQE-ANl 17670014-l 8l
II.B.3.a.l Monitoring:
The operating temperature shall be continuously monitored and recorded. The monitoring equipment shall be
located such that an inspector can at any time safely read the output. All instruments shall be calibrated
against a certified primary standard at least once a year.
II.8.3.a.2 Recordkeeping:
Records of monitoring and calibration shall be maintained as described in provision I.S.1 of this permit.
II.B.3.a.3 Reporting:
There are no reporting requirements for this provision except those specified in Section I of this permit.
II.B.3.b
Emissions of Volatile Organic Compounds (VOC) shall be not greater than 1.05 lb/hr. [Authority granted
under R307-401-8; condition originated in DAQE-ANl 17670014-18)
Compliance Status:Compliance Type:Reaso n (s) fo r No n-C o mp I ia nc e
r' In compliance r' Continuous
Co mol ia nc e De mo n strutio n Meth o d :Review of Records
Compliance Status:Compliance Type:Reason (s) fo r No n-C o mp I iance
/ In comoliance / Continuous
C o mpliance De mo nstratio n Met h o d :Review of Records
Compliance Status:Compliance Type:Re as o n (s) for No n-C o mpliance
/ In compliance / Continuous
Compliance Demo nstration Method:Recordkeepins and Review of Records
Compliance Status:Compliance Type:Reason (s) fo r No n-C o mp I iance
/ In compliance r' Continuous
C omp I iance De mo nstratio n Met ho d :Stack Test and Review of Records
Issued l2 February 2020 I 0 l'itlc V Operating ['e rmit # 2 10003600.1
II.B.3.b. I Monitoring:
(a) Stack testing to show compliance with the VOC emission limitations shall be performed as specified
below:
(1) Testing and Frequency. Emissions shall be tested every five years based on the date of the last
stack test. The source may also be tested at any time if directed b1, the Director.
(2) Notification. The Director shall be notified at least 30 days prior to conducting any required
emission testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The source test protocol shall be approved by the Director prior to
performing the test(s). the source test protocol shall outline the proposed test methodologies, stack to
be tested, and procedures to be used. A pretest confbrence shall be held, if directed by the Director,
between the owner/operator, the tester, and the Director.
(3) Methods.
(A) Sample location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA)
approved access shall be provided to the test location.
(B) 40 CFR 60, Appendix A, Method 25 or 25A, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine volatile organic compounds emission
rate.
(C) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as acceptable
to the Director, shall be used to determine the volumetric flow rate.
(4) Calculations. To determine mass emission rates (lb/hr. etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any
necessary conversion factors determined by the Director to give the results in the specified units of
the emission limitation.
(5) Production Rate During Testing. The production rate during all compliance testing shall be no
less than 90% of the maximum production achieved in the previous three (3) years.
(b) The permittee shall monitor the thermal oxidizer temperature and work practice standards as indicators to
provide reasonable assurance of compliance with the VOC emission limitation.
(l ) Measurement Approach:
Complionce Status:Compliance Type:Reas on (s) fo r No n-C o mpl ia n ce
In compliance / Continuous
C o mpliance De mo nstratio n Meth o d :Review of Records
Issued l2 February 2020 I l Title V Operating l)ermit # 210003600.1
(A) Primary Indicator: The permittee shall continuously measure the thermal oxidizer
chamber temperature by a thermocouple.
(B) Secondary Indicator: The permittee shall follow good work practices, including daily,
weekly, and annual inspections of the thermal oxidizer.
(2) Indicator Range:
(A) Primary Indicator: An excursion is deflned as a temperature less than 1,410 degrees F that
is outside the range as approved by the executive secretary. Excursions trigger an inspection,
corrective action to return the operating temperature to 1,410 degrees F or more, and a
reporting requirement.
(B) Secondary Indicator: An excursion is defined as an omission to perfbrm the daily
inspection of the chart recorder, weekly inspection of the thermal oxidizer and replacement of
the circular chart, and annual inspections of the thermal oxidizer. Excursions trigger an
inspection, corrective action, and a reporting requirement.
(3) Performance Criteria:
(A) Data Representatives:
(i) Primary Indicator: The thermal oxidizer temperature shall be measured using a
thermocouple located in the oxidizer chamber. The minimum tolerance of the
thermocouple is + 10.5" F or + 0.75oh. The minimum chart recorder sensitivity (minor
division) is 20o F or as approved by the Director.
(ii) Secondary Indicator: No applicable.
(B) QA/QC Practices and Criteria: The accuracy of the thermocouple shall be verified
annually by a third party supplier with the calibration perfbrmed according to the
manufacturer's recommendation. The data acquisition system shall be operated and
maintained according to the manufacturer's recommendations.
(C) Monitoring Frequency :
(i) Primary Indicator: The thermal oxidizer temperature shall be measured
continuously.
(ii) Secondary Indicator: Daily inspection of the temperature chart recorder. Weekly
inspection of the thermal oxidizer. Annual inspection of the thermal oxidizer.
(D) Data Collection Procedure:
(i) Primary Indicator: Record continuously on a circular chart recorder.
lssued l2 Irchruarv 2020 I 2'l itle V Opcrating l)crnrit # 2l(XX)1600-l
(ii) Secondary Indicator: Record results of daily and weekly inspections; Record
results of annual inspection by a third party supplier. Preventive maintenance records
by the maintenance department on the thermal oxidizer log book.
(E) Averaging Period:
(i) Primary Indicator: t hour block average
(ii) Secondary Indicator: Not Applicable
(c) Once every five years, during the stack test required in (a) above, the permittee shall acquire new test data
to evaluate or update the indicator range and excursion level for the indicators. Any resultant changes to the
monitoring shall be addressed in accordance with 40 CFR 64.7(e).
II.8.3.b.2 Recordkeeping:
In addition to the recordkeeping requirement described in Provision I.S.l of this permit,
testing and all other infbrmation required by permit(a) The permittee shall maintain a flle of all stack
provision I.S.l.
Compliance Status:Compliance Type:Rea s on (s) fo r No n-C o mp I ia nce
/ In compliance / Continuous
Compliance Demonstration Method :Review of Records
Compliance Status:Compliance Type:Re as o n (s) fo r No n-C o mp I ia nce
In comnliance y' Continuous
C o mp liance De mo nstratio n Meth o d :Review of Records
Compliance Status:Compliance Type:Reaso n (s) fo r No n-C o mp I io nce
/ In compliance y' Continuous
C o mp lianc e De mo nstratio n Met hod :Review of Records
(b) The permittee shall
testing measurements,
maintenance.
maintain a file of continuous monitor measurenlents,
all performance evaluations, all calibration checks, all
including performance
adjustments and
Compliance Status: I Compliance Type: I Reoson(s) for Non-Compliance
lssued l2 Februarv 2020 1 3f itlo V Ope rating I)ernrit # 2 1000-i6004
In comoliance r' Continuous
Comoliance Demonstration Method :Review of Records
(c) The permittee shall maintain a file of the occurrence and duration of any excursion, corrective
actions taken, and any other supporting information required to be maintained under 40 CFR 64 (such
as data used to document the adequacy of monitoring, or records of mentoring maintenance or
corrective actions). Instead of paper records, the permittee may maintain records on alternative
media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of
such altemative media allows for expeditious inspection and review, and does not conflict with other
applicable recordkeeping requirements. (40 CFR 64.9(b)).
II.8.3.b.3 Reporting:
(a) The monitoring report required in Provision I.S.2 of this permit shall include, at a minimum, the
following information, as appl icable :
(1) Summary information on the number, duration and cause (including unknown cause, if
applicable) ofexcursions or exceedances, as applicable, and the corrective action taken; (40
CFR 64.e(ax2Xi)).
(2) Summary information on the number, duration and cause (including unknown cause, if
applicable) for monitor downtime incidents (other than downtime associated with zero and
span or other daily calibration checks, if applicable). (a0 CFR 64.9(a)(2Xii)).
(b) The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identifu results as compared to permit limits and indicate compliance
status.
Compliance Status:Compliance Type:Reoson (s) fo r No n-C o mp I ia nc e
N/A/ In compliance r' Continuous
Co mp liance De mo nstratio n Meth o d :Review of Records
Compliance Status:Compliance Type:Rea so n (s) fo r No n-C o mp I ianc e
In comoliance r' Continuous
Comoliance Demonstration Method:Review of Records
Compliance Status:Compliance Type:Reoso n (s) fo r No n-Co mp I ia n ce
/ In compliance r' Continuous
Co mplia nce De mo n stratio n Meth o d :Review of Records
Issued l2 F'ebruary 2020 I 4't'itle V Operating I)ermit # 2 1000.1(1004
Compliance Status:Compliance Type:Re as o n (s) fo r No n-C o mp I ian c e
/ In compliance / Continuous
C o mp I ianc e Demo nstration Met hod :Review of Records
II.B.3.c
Visible emissions shall be no greater than 10 percent opacity. [Authority granted under R307-401-8'
condition originated in DAQE-ANl I 7670014-1 8l
II.B.3.c. I Monitoring:
A visual opacity survey of each affected emission unit shall be performed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, or other EPA-
approved testing method, as acceptable to the Director. If visible emissions other than condensed water
vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed
by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in
accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to
the Director, for point sources, and in accordance 58 FR 61640 Method 2034, or other EPA-approved testing
method, as acceptable to the Director, tbr fugitive sources.
II.8.3.c.2 Recordkeeping:
A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.l of this permit. If
an opacity determination is indicted, a notation of the determination will be made in the log. All data
required by 40 CFR 60, Appendix A, Method 9 or 58 FR 61640 Method 203A, or other EPA-approved
testing method, as acceptable to the Director, shall be maintained in accordance with the requirements of
Provision I.S.l of this permit.
Compliance Status:Compliance Type:Re aso n (s) fo r No n-C o mp I ia nce
/ In compliance / Continuous
Compliance Demonstration Method :Review of Records
II.8.3.c.3 Reporting:
There are no reporting requirements for this provision except those specifled in Section I of this permit.
II.B.4 Condition on Grinder
II.B.4.a
Visible emissions shall be no greater than l0 percent opacity. [Authority granted under R307-401-8'
condition originated in DAQE-ANl 17670014-l 8l
lssued l2 February 2020 I 5'l'itle V Operating l)ernrit # 2100036004
Compliance Status:Compliance Type:Re aso n (s) fo r No n-Co mp I ia nce
/ In comoliance r' Continuous
C o mo liance De mo nstratio n Metho d :Review of Records
Compliance Status:Compliance Type:Re aso n (s) fo r No n-C o mp I ia nc e
/ In comnliance / Continuous
Comoliance Demo nstration Method :Review of Records
II.8.4.a.1 Monitoring:
A visual opacity survey of each aflbcted emission unit shall be perfbrmed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, or other EPA-
approved testing method, as acceptable to the Director. If visible emissions other than condensed water
vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed
by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in
accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to
the Director, for point sources, and in accordance 58 FR 61640 Method 203A, or other EPA-approved testing
method, as acceptable to the Director, for fugitive sources.
11.8.4.a.2 Recordkeepin g:
A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.l of this permit. If
an opacity determination is indicted, a notation of the determination will be made in the log. All data
required by 40 CFR 60, Appendix A. Method 9 or 58 FR 61640 Method 203A, or other EPA-approved
testing method, as acceptable to the Director, shall be maintained in accordance with the requirements of
Provision I.S.l of this permit.
II.B.4.a.3 Reporting:
There are no reporting requirements for this provision except those specified in Section I of this permit.
II.B.5 Condition on Scrap Silos
II.B.5.a
Visible emissions shall be no greater than l0 percent opacity. [Authority granted under R307-401-8'
condition originated in DAQE-AN I I 7670014- I 8l
Compliance Status:Compliance Type:Reaso n (s) fo r No n-C o mp I ia nce
y' In compliance / Continuous
C o mp lianc e De mo nst ratio n Metho d :Review of Records
Issued l2 February 2020 I 6 l'itlc V Operating Permit # 2l()00-1600.1
II.B.5.a. I Monitoring:
A visual opacity survey of each afl-ected emission unit shall be perfbrmed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A. Method 9, or other EPA-
approved testing method, as acceptable to the Director. If visible emissions other than condensed water
vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed
by a cemified observer within 24 hours of the initial survey. The opacity determination shall be performed in
accordance with 40 CFR 60, Appendix A, Method 9. or other EPA-approved testing method, as acceptable to
the Director, fbr point sources, and in accordance 58 FR 61640 Method 203A, or other EPA-approved testing
method, as acceptable to the Director, for fugitive sources.
II.B.5.a.2 Recordkeeping:
A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.l of this permit. If
an opacity determination is indicted, a notation of the determination will be made in the log. All data
required by 40 CFR 60, Appendix A, Method 9 or 58 FR 61640 Method 203A, or other EPA-approved
testing method, as acceptable to the Director, shall be maintained in accordance with the requirements of
Provision I.S.l of this permit.
II.8.5.a.3 Reporting:
There are no reporting requirements for this provision except those specifred in Section I of this permit.
II.8.6 Condition on Fluff Silos
II.B.6.a
Visible emissions shall be no greater than 10 percent opacity. [Authority granted under R307-401-8'
condition originated in DAQE-AN I I 7670014- 1 8l
II.B.6.a. I Monitoring:
A visual opacity survey of each aff'ected emission unit shall be performed on a monthly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A. Method 9, or other EPA-
approved testing method, as acceptable to the Director. If visible emissions other than condensed water
Compliance Status:Compliance Type:Reaso n (s) fo r No n-C o mp lianc e
/ In compliance y' Continuous
Comolia nc e De mo n stratio n Met h od :Review of Records
Compliance Status:Compliance Type:Re as o n (s) fo r No n-C o mpl ia nce
/ In compliance / Continuous
C o mp lianc e De mo nstratio n M et h o d :Review of Records
Issued l2 February 2020 I 7'l'irle v operaring Permit # 2l()00i(1004
vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed
by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in
accordance with 40 CFR 60, Appendix A, Method 9. or other EPA-approved testing method, as acceptable to
the Director, fbr point sources, and in accordance 58 FR 61640 Method 203A, or other EPA-approved testing
method, as acceptable to the Director, for f-ugitive sources.
11.8.6.a.2 Reco rdkeepin g:
A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.l of this permit. If
an opacity determination is indicted, a notation of the determination will be made in the log. All data
required by 40 CFR 60, Appendix A" Method 9 or 58 FR 61640 Method 203,4, or other EPA-approved
testing method, as acceptable to the Director, shall be maintained in accordance with the requirements of
Provision I.S.l of this permit.
II.8.6.a.3 Reporting:
There are no reporting requirements for this provision except those specified in Section I of this permit.
II.C. Emissions Trading. (R307-415-6a(10))
Not applicable to this source
II.D. Alternative Operating Scenarios. (R307'415-6a(9))
Not applicable to this source.
II. E
Not applicable to this source.
III.A.
A permit shield was not granted for any specific requirements.
Section IV: ACID RAIN PROVISIONS
This source is not subject to title IV. This section is not applicable.
Compliance Status:Compliance Type:Re as o n (s) fo r No n-Co mp liance
/ In compliance / Continuous
Complionce Demonstration Method :Review of Records
lssued l2 February 2020 I 8 l itle V Operating Pernrit # 2100036001
CERTIFICATION
In accordance with Operating Permit provision I.K and UAC R307-415-5d, and based on information and
belief formed after reasonable inquiry, I certifu that the statements and information in this document are true,
accurate, and complete.
Signature of a Responsible Official for the Source
Eric Scott
Genpak Utah West Plant Manager
UTAH DEPARTMENT OF
0510v2025
Date
ENVIRqNMENTAL QUALITY
DIVISION OF AIR OUALITY
Issued 12 February 2020 I gTitle V Operating Permit # 2100036004