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HomeMy WebLinkAboutDAQ-2025-002772Tooele Transcript-Bulletin Publication Name: Tooele Transcript-Bulletin Publication URL: www.tooeletranscript.com Publication City and State: Tooele, UT Publication County: Tooele Notice Popular Keyword Category: Notice Keywords: broken arrow Notice Authentication Number: 202505010918026799929 2273419277 Notice URL: Back Notice Publish Date: Wednesday, April 23, 2025 Notice Content PUBLIC NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Broken Arrow Inc. Location: Broken Arrow Inc. - Broken Arrow Flux Operations 2600 North Ellerbeck Rd., Grantsville, UT Project Description: Broken Arrow Inc. operates a salt processing plant located near Grantsville in Tooele County. The process dries, screens, and loads salt harvested from the Great Salt Lake for shipment to customers. The plant produces up to 500,000 tons of salt annually. The company also dries liquid magnesium chloride concentrate. The magnesium chloride concentrate is brought in to the plant by the tanker trucks and dried by a new natural gas- fired burner. The plant processes up to 21 million gallons of magnesium chloride concentrate a year. Broken Arrow has requested a modification to Approval Order (AO) DAQE-AN130290007-25 to replace the 40 MMBtu/hr dryer with a new rotary dryer rated at 75 MMBtu/hr. The burner is an ultra-low-NOx burner. Emissions from the drying processes are controlled with a venturi wet scrubber. Annual natural gas consumption, which is used to estimate emissions, will remain unchanged; therefore, there will be no annual emission changes as a result of the replacement. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before May 23, 2025, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at ehe@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: April 23, 2025 (Published in the Tooele Transcript Bulletin April 23, 2025) Back DAQE-IN130290008-25 April 17, 2025 Ladislao Garcia Broken Arrow Inc. 8960 North Clinton Landing Lake Point, UT 84074 lgarcia@brokenarrowusa.com Dear Mr. Garcia: Re: Intent to Approve: Modification to Approval Order DAQE-AN130290007-25 to Replace Equipment Project Number: N130290008 The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is subject to public review. Any comments received shall be considered before an Approval Order (AO) is issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO. Future correspondence on this ITA should include the engineer's name, Mr. Enqiang He, as well as the DAQE number as shown on the upper right-hand corner of this letter. Mr. Enqiang He, can be reached at (801) 556-1580 or ehe@utah.gov, if you have any questions. Sincerely, {{$s }} Alan D. Humpherys, Manager New Source Review Section ADH:EH:jg cc: Tooele County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN130290008-25 Modification to Approval Order DAQE-AN130290007-25 to Replace Equipment Prepared By Mr. Enqiang He, Engineer (801) 556-1580 ehe@utah.gov Issued to Broken Arrow Inc. - Broken Arrow Flux Operations Issued On April 17, 2025 {{$s }} New Source Review Section Manager Alan D. Humpherys {{#s=Sig_es_:signer1:signature}} TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 PUBLIC NOTICE STATEMENT............................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 12 ACRONYMS ............................................................................................................................... 13 DAQE-IN130290008-25 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Broken Arrow Inc. Broken Arrow Inc. - Broken Arrow Flux Operations Mailing Address Physical Address 8960 North Clinton Landing 2600 North Ellerbeck Road Lake Point, UT 84074 Grantsville, UT 84029 Source Contact UTM Coordinates Name: Ladislao Garcia 368,170 m Easting Phone: (435) 840-4723 4,504,450 m Northing Email: lgarcia@brokenarrowusa.com Datum NAD83 UTM Zone 12 SIC code 1474 (Potash, Soda, & Borate Minerals) SOURCE INFORMATION General Description Broken Arrow Inc. operates a salt processing plant located near Grantsville in Tooele County. The process dries, screens, and loads salt harvested from the Great Salt Lake for shipment to customers. The plant produces up to 500,000 tons of salt annually. The company also dries liquid magnesium chloride concentrate. The magnesium chloride concentrate is brought to the plant by the tanker trucks and dried by a natural gas-fired burner. The plant processes up to 21 million gallons of magnesium chloride concentrate a year. NSR Classification Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Tooele County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions DAQE-IN130290008-25 Page 4 MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Description Broken Arrow has requested a modification to AO DAQE-AN130290007-25 to replace the 40 MMBtu/hr dryer with a new rotary dryer rated at 75 MMBtu/hr. The burner is an ultra-low-NOx burner. Emissions from the drying processes are controlled with a venturi wet scrubber. The new dryer will share the workload with the existing dyers, and the natural gas consumption will remain unchanged. Emissions as a result of the replacement will also remain the same. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 16114.00 Carbon Monoxide 0 35.20 Nitrogen Oxides 0 11.54 Particulate Matter - PM10 0 38.02 Particulate Matter - PM2.5 0 36.77 Sulfur Dioxide 0 0.08 Volatile Organic Compounds 0 4.38 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 540 Change (TPY) Total (TPY) Total HAPs 0 0.27 PUBLIC NOTICE STATEMENT The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Tooele Transcript on April 23, 2025. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received. DAQE-IN130290008-25 Page 5 SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT II.A.1 Broken Arrow Salt Broken Arrow Flux Operations DAQE-IN130290008-25 Page 6 II.A.2 Two (2) Salt Dryers Design Capacity: Rated at 70, 75 MMBtu/hr Fuel: Natural gas II.A.3 One (1) Salt Dryer - new Design Capacity: Rated at 75 MMBtu/hr Fuel: Natural gas Burner: Ultra-Low-NOx burner II.A.4 Venturi Wet Scrubber - new Controls: new 75 MMBtu/hr dryer in II.A.3 with a screen Stack Height: 30' Stack Inside Dimension: 2.5' x 2.5' II.A.5 Baghouse 2 Controls: 70 MMBtu/hr dryer Flow Rate: 50,000 acfm Bag Diameter: 4.6" Bag Length: 12' Number of Bags: 494 Stack Height: 45' Stack Inside Dimension: 4' x 4' II.A.6 Baghouse 3 Controls: 75 MMBtu/hr dryer in II.A.2 Flow Rate: 80,000 acfm Bag Diameter: 4.5" Bag Length: 10' Number of Bags: 960 Stack Height: 45' Stack Inside Diameter: 5' II.A.7 One (1) Magnesium Chloride Dryer Design Capacity: 10 MMBtu/hr Fuel: Natural gas Burner: Low NOx burner II.A.8 Five (5) Screens Design Capacity: One (1) rated at 50 tons/hr; two (2) rated at 150 tons/hr each; two (2) rated at 300 tons/hr each II.A.9 Seven (7) Storage Buildings Storage Capacities: 500, 500, 2,000, 2,500, 4,500, 15,000, and 20,000 tons II.A.10 Miscellaneous Equipment Associated conveyors, electric motors, front-end loaders and haul trucks II.A.11 One (1) Diesel Storage Tank Capacity: 10,000 gallons II.A.12 One (1) Emergency Generator Engine Maximum Rated Capacity: 1,474 hp (1,100 kW) Tier 4 certified Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ DAQE-IN130290008-25 Page 7 II.A.13 One (1) Emergency Generator Engine Maximum Rated Capacity: 201 hp (150 kW) Fuel: Natural gas or propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Plant-Wide Requirements and Limitations II.B.1.a The owner/operator shall not allow visible emissions to exceed the following limits: A. The screens - 7% opacity B. All conveyor transfer points - 7% opacity C. Conveyor drop points - 15% opacity D. The sodium chloride dryer stacks (through a baghouse or a scrubber) - 10% opacity E. The magnesium chloride dryer stack - 10% opacity F. The diesel-fired emergency generator engine - 20% opacity G. The natural gas/propane fired emergency generator engine - 10% opacity H. All other points - 15% opacity. [R307-309, R307-312-4, R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall not exceed the following production and consumption limits: A. 500,000 tons of sodium chloride salt processed per rolling 12-month period B. 21 million gallons of magnesium chloride concentrate processed per rolling 12-month period C. 272,000 MMBtu of natural gas consumed per rolling 12-month period. [R307-401-8] DAQE-IN130290008-25 Page 8 II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months B. Determine production by scale house records or vendor receipts C. Keep the records of production on a daily basis D. Determine natural gas consumption by billing statements from a utility company. The records of billing statements shall be kept on a monthly basis E. Keep the records of production and natural gas consumption for all periods when the plant is in operation. [R307-401-8] II.B.1.c The owner/operator shall install partial enclosures on all outdoor screening operations that sort material that has been processed by the sodium chloride salt dryers. The enclosures must be installed in a way to maintain the opacity limits set in this AO. [R307-401-8] II.B.2 Sodium Chloride Salt Dryer Requirements II.B.2.a The owner/operator shall only use natural gas as fuel in the sodium chloride salt dryers. [R307-401-8] II.B.2.b The owner/operator shall install a low NOx burner in the 75 MMBtu/hr sodium chloride salt dryer (II.A.2) that is certified to meet a NOx emission concentration of 30 ppm corrected to 3% oxygen. [R307-401-8] II.B.2.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration for the 75 MMBtu/hr sodium chloride salt dryer (II.A.2) on site. The record shall be kept for the life of the equipment. [R307-401-8] II.B.2.c The owner/operator shall install an ultra-low-NOx burner in the new 75 MMBtu/hr sodium chloride salt dryer (II.A.3) that is certified to meet a NOx emission concentration of 9 ppm or lower corrected to 3% oxygen. [R307-401-8] II.B.2.c.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration for the new 75 MMBtu/hr sodium chloride salt dryer (II.A.3) on site. The record shall be kept for the life of the equipment. [R307-401-8] II.B.3 Venturi Wet Scrubber Requirements II.B.3.a The owner/operator shall use the venturi wet scrubber to control process streams from the new sodium chloride salt dryer (II.A.3). All exhaust air from the dryer shall be routed through the scrubber before being vented to the atmosphere. [R307-401-8] II.B.3.b The owner/operator shall maintain the following operating parameters within the ranges below: A. The pressure drop at the throat of the venturi between 20 and 25 inches of water column B. The exhaust gas flow rate between 20,000 and 35,000 CFM C. The water flow rate between 144 and 300 GPM. [R307-401-8] DAQE-IN130290008-25 Page 9 II.B.3.b.1 The owner/operator shall install the pressure gauge and the flow meters such that an inspector/operator can safely read the indicators at any time. The owner/operator shall maintain and calibrate the indicators according to the manufacturers' instructions at least once every 12 months. Recording of the readings is required on a daily basis when the venturi wet scrubber operates. [R307-401-8] II.B.3.c The owner/operator shall install and operate a venturi wet scrubber that is guaranteed to achieve at least 99% control efficiency for particulate control. [R307-401-8] II.B.3.c.1 The owner/operator shall keep a record of the manufacture's guarantee of the control efficiency. The record shall be kept for the life of the equipment. [R307-401-8] II.B.4 Baghouse Requirements II.B.4.a The owner/operator shall use the baghouses to control process streams from their designated sodium chloride salt dryers. All exhaust air from the sodium chloride salt dryers (II.A.2) shall be routed through the baghouses before being vented to the atmosphere. [R307-401-8] II.B.4.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The static pressure differential across each baghouse shall be between 2.0 to 5.0 inches of water column. The monitoring device shall be accurate within plus or minus one inch of water column. [R307-401-8] II.B.4.b.1 Pressure drop readings shall be recorded daily while the baghouse is operating. Records documenting the pressure drop shall be kept in a log and shall include the following: A. Date of reading B. Unit identification C. Manufacturer-recommended pressure drop for the unit (if applicable) D. Daily pressure drop readings. [R307-401-8] II.B.4.b.2 Each pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.4.b.3 The instrument shall be calibrated in accordance with the manufacturer's instructions or recommendations or replaced at least once every 12 months. Documentation of calibrations or replacements shall be maintained. [R307-401-8] II.B.4.c The owner/operator shall install a baghouse that is certified to meet a PM10 emission concentration of 0.005 grains/dscf to control the 75 MMBtu/hr sodium chloride salt Dryer (II.A.2). [R307-401-8] II.B.4.c.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration. The record shall be kept for the life of the equipment. [R307-401-8] II.B.5 Magnesium Chloride Salt Dryer Requirements II.B.5.a The owner/operator shall only use natural gas as fuel in the magnesium chloride salt dryer. [R307-401-8] II.B.5.b The owner/operator shall install a low-NOx burner in the magnesium chloride salt dryer that is certified to meet a NOx emission concentration of 30 ppm and a CO emission concentration of 100 ppm or less. [R307-401-8] DAQE-IN130290008-25 Page 10 II.B.5.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentrations. The record shall be kept for the life of the equipment. [R307-401-8] II.B.6 Road and Fugitive Dust II.B.6.a The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas to exceed 15% opacity on site and 10% opacity at the property boundary. [R307-309-4, R307-309-5] II.B.6.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-4, R307-401-8] II.B.6.b The owner/operator shall not allow the total length of the haul roads to exceed: A. 0.90 miles of unpaved haul roads for the tanker trucks transporting magnesium chloride concentrate. The owner/operator shall pave no less than 0.1 miles of haul road B. 0.81 miles of unpaved haul roads for the haul trucks transporting sodium chloride salt. The owner/operator shall pave no less than 300 feet of haul road. [R307-401-8] II.B.6.c The owner/operator shall apply water sprays and/or chemical suppressants to all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain the opacity limit in the AO. [R307-309, R307-401-8] II.B.6.c.1 Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of treatment B. Number of treatments made, dilution ratio, and quantity C. Rainfall received if any, and approximate amount D. Time of day treatments were made E. Records of temperature if the temperature was below freezing. [R307-401-8] II.B.6.d The owner/operator shall periodically sweep or spray clean the paved haul road to maintain the opacity limit in the AO. [R307-401-8] II.B.6.d.1 Records of cleaning the paved haul roads shall be kept for all periods the plant is in operation. [R307-401-8] II.B.6.e The owner/operator shall comply with all applicable requirements of R307-309 for fugitive emission and fugitive dust sources. [R307-309] DAQE-IN130290008-25 Page 11 II.B.7 Emergency Generator Engine Requirements II.B.7.a The owner/operator shall install and operate the following emergency generator engines: A. One (1) diesel-fired engine rated up to 1,474 hp (1,100 kW). The engine shall comply with the following Tier 4 standards: HC = 0.14 g/hp-hr, NOx = 0.5 g/hp-hr, and PM = 0.02 g/hp-hr B. One (1) natural gas/propane-fired engine rated up to 201 hp (150 kW). The engine shall comply with the following standards: NOx = 2.0 g/hp-hr, CO = 4.0 g/hp-hr, and VOC = 1.0 g/hp-hr. [40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, R307-401-8] II.B.7.a.1 To demonstrate compliance with the above requirements, the owner/operator shall keep records of the manufacturer's certifications of the emission rates. The records shall be kept for the life of the equipment. [R307-401-8] II.B.7.b The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.7.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.7.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ] II.B.7.c The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 1,474-hp (1,100-kW) emergency generator engine and natural gas or propane in the 201-hp (150-kW) emergency generator engine. [R307-401-8] II.B.7.c.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.7.c.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] II.B.7.d The owner/operator shall not test the emergency generator engines at the same time. [R307-410-4] DAQE-IN130290008-25 Page 12 II.B.7.d.1 To comply with the above requirement, the owner/operator shall: A. Identify the engine to be tested B. Record the engine testing date C. Record the time the testing began and ended D. Keep the above records for all periods the plant is in operation. [R307-410-4] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN130290007-25 dated January 8, 2025 Incorporates NOI dated January 8, 2025 Incorporates Additional information dated January 10, 2025 Incorporates Additional information dated January 22, 2025 Incorporates Additional information dated January 27, 2025 DAQE-IN130290008-25 Page 13 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds DAQE-NN130290008-25 April 17, 2025 Tooele Transcript Legal Advertising Dept. 58 N Main Tooele, UT 84074 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Tooele Transcript on April 23, 2025. Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any questions, contact Jeree Greenwood, who may be reached at (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Tooele County cc: Wasatch Front Regional Council 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director DAQE-NN130290008-25 Page 2 NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Broken Arrow Inc. Location: Broken Arrow Inc. - Broken Arrow Flux Operations – 2600 North Ellerbeck Rd., Grantsville, UT Project Description: Broken Arrow Inc. operates a salt processing plant located near Grantsville in Tooele County. The process dries, screens, and loads salt harvested from the Great Salt Lake for shipment to customers. The plant produces up to 500,000 tons of salt annually. The company also dries liquid magnesium chloride concentrate. The magnesium chloride concentrate is brought in to the plant by the tanker trucks and dried by a new natural gas-fired burner. The plant processes up to 21 million gallons of magnesium chloride concentrate a year. Broken Arrow has requested a modification to Approval Order (AO) DAQE-AN130290007-25 to replace the 40 MMBtu/hr dryer with a new rotary dryer rated at 75 MMBtu/hr. The burner is an ultra-low-NOx burner. Emissions from the drying processes are controlled with a venturi wet scrubber. Annual natural gas consumption, which is used to estimate emissions, will remain unchanged; therefore, there will be no annual emission changes as a result of the replacement. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before May 23, 2025, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at ehe@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: April 23, 2025 {{#s=Sig_es_:signer1:signature}} DAQE- RN130290008 April 8, 2025 Ladislao Garcia Broken Arrow Inc. 8960 North Clinton Landing Lake Point, UT 84074 lgarcia@brokenarrowusa.com Dear Ladislao Garcia, Re: Engineer Review: Modification to AO DAQE-AN130290007-25 to Replace Equipment Project Number: N130290008 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Broken Arrow Inc. should complete this review within 10 business days of receipt. Broken Arrow Inc. should contact Mr. Enqiang He at (801) 556-1580 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Enqiang He at ehe@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Broken Arrow Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Broken Arrow Inc. has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N130290008 Owner Name Broken Arrow Inc. Mailing Address 8960 North Clinton Landing Lake Point, UT 84074 Source Name Broken Arrow Inc. - Broken Arrow Flux Operations Source Location 2600 North Ellerbeck Rd. Grantsville, UT 84029 UTM Projection 368,170 m Easting, 4,504,450 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1474 (Potash, Soda, & Borate Minerals) Source Contact Ladislao Garcia Phone Number (435) 840-4723 Email lgarcia@brokenarrowusa.com Billing Contact Ladislao Garcia Phone Number (435) 840-4723 Email lgarcia@brokenarrowusa.com Project Engineer Mr. Enqiang He, Engineer Phone Number (801) 556-1580 Email ehe@utah.gov Notice of Intent (NOI) Submitted January 7, 2025 Date of Accepted Application January 30, 2025 Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 2 SOURCE DESCRIPTION General Description Broken Arrow Inc. operates a salt processing plant located near Grantsville in Tooele County. The process dries, screens, and loads salt harvested from the Great Salt Lake for shipment to customers. The plant produces up to 500,000 tons of salt annually. The company also dries liquid magnesium chloride concentrate. The magnesium chloride concentrate is brought to the plant by the tanker trucks and dried by a natural gas-fired burner. The plant processes up to 21 million gallons of magnesium chloride concentrate a year. NSR Classification: Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Tooele County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal Modification to AO DAQE-AN130290007-25 to Replace Equipment Project Description Broken Arrow has requested a modification to AO DAQE-AN130290007-25 to replace the 40 MMBtu/hr dryer with a new rotary dryer rated at 75 MMBtu/hr. The burner is an ultra-low-NOx burner. Emissions from the drying processes are controlled with a venturi wet scrubber. The new dryer will share the workload with the existing dyers, and the natural gas consumption will remain unchanged. Emissions as a result of the replacement will also remain the same. EMISSION IMPACT ANALYSIS The source is not required to model for any criteria pollutants and HAPs because the emissions remain unchanged as a result of this modification. [Last updated January 30, 2025] Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 3 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 16114.00 Carbon Monoxide 0 35.20 Nitrogen Oxides 0 11.54 Particulate Matter - PM10 0 38.02 Particulate Matter - PM2.5 0 36.77 Sulfur Dioxide 0 0.08 Volatile Organic Compounds 0 4.38 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 540 Change (TPY) Total (TPY) Total HAPs 0 0.27 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding the new 75 MMBtu/hr dryer The source has proposed to replace the existing 40 MMBtu/hr natural gas-fired dryer with the new 75 MMBtu/hr natural gas-fired dryer. The new dryer will allow the source to maintain production capacity during maintenance periods. The source has not proposed to increase natural gas consumption or salt production; therefore, emissions will not increase from the equipment replacement. The dryer is equipped with an ultra-low-NOx burner with NOx emission concentrations at 9 ppm or less. The venturi wet scrubber will control particulate emissions from the dryer. The scrubber will provide a 99% or better control efficiency for salt particles. Visible emissions from the scrubber are limited to 10% opacity. The minor NSR Section considers the ultra-low-NOx burner, the scrubber, and opacity limit as BACT. [Last updated February 6, 2025] SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 5 I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Broken Arrow Salt Broken Arrow Flux Operations II.A.2 Two (2) Salt Dryers Design Capacity: Rated at 70, 75 MMBtu/hr Fuel: Natural gas II.A.3 NEW One (1) Salt Dryer - new Design Capacity: Rated at 75 MMBtu/hr Fuel: Natural gas Burner: Ultra-Low-NOx burner II.A.4 NEW Venturi Wet Scrubber - new Controls: new 75 MMBtu/hr dryer in II.A.3 with a screen Stack Height: 30' Stack Inside Dimension: 2.5' x 2.5' II.A.5 Baghouse 2 Controls: 70 MMBtu/hr dryer Flow Rate: 50,000 acfm Bag Diameter: 4.6" Bag Length: 12' Number of Bags: 494 Stack Height: 45' Stack Inside Dimension: 4' x 4' Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 6 II.A.6 Baghouse 3 Controls: 75 MMBtu/hr dryer in II.A.2 Flow Rate: 80,000 acfm Bag Diameter: 4.5" Bag Length: 10' Number of Bags: 960 Stack Height: 45' Stack Inside Diameter: 5' II.A.7 One (1) Magnesium Chloride Dryer Design Capacity: 10 MMBtu/hr Fuel: Natural gas Burner: Low NOx burner II.A.8 Five (5) Screens Design Capacity: One (1) rated at 50 tons/hr; two (2) rated at 150 tons/hr each, two (2) rated at 300 tons/hr each II.A.9 Seven (7) Storage Buildings Storage Capacities: 500, 500, 2,000, 2,500, 4,500, 15,000, and 20,000 tons II.A.10 Miscellaneous Equipment Associated conveyors, electric motors, front-end loaders and haul trucks II.A.11 One (1) Diesel Storage Tank Capacity: 10,000 gallons II.A.12 One (1) Emergency Generator Engine Maximum Rated Capacity: 1,474 hp (1,100 kW) Tier 4 certified Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.13 One (1) Emergency Generator Engine Maximum Rated Capacity: 201 hp (150 kW) Fuel: Natural gas or propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Plant-Wide Requirements and Limitations Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 7 II.B.1.a NEW The owner/operator shall not allow visible emissions to exceed the following limits: A. The screens - 7% opacity B. All conveyor transfer points - 7% opacity C. Conveyor drop points - 15% opacity D. The sodium chloride dryer stacks (through a baghouse or a scrubber) - 10% opacity E. The magnesium chloride dryer stack - 10% opacity F. The diesel-fired emergency generator engine - 20% opacity G. The natural gas/propane fired emergency generator engine - 10% opacity H. All other points - 15% opacity. [R307-309, R307-312-4, R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall not exceed the following production and consumption limits: A. 500,000 tons of sodium chloride salt processed per rolling 12-month period B. 21 million gallons of magnesium chloride concentrate processed per rolling 12-month period C. 272,000 MMBtu of natural gas consumed per rolling 12-month period. [R307-401-8] II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months B. Determine production by scale house records or vendor receipts C. Keep the records of production on a daily basis D. Determine natural gas consumption by billing statements from a utility company. The records of billing statements shall be kept on a monthly basis E. Keep the records of production and natural gas consumption for all periods when the plant is in operation. [R307-401-8] Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 8 II.B.1.c The owner/operator shall install partial enclosures on all outdoor screening operations that sort material that has been processed by the sodium chloride salt dryers. The enclosures must be installed in a way to maintain the opacity limits set in this AO. [R307-401-8] II.B.2 Sodium Chloride Salt Dryer Requirements II.B.2.a The owner/operator shall only use natural gas as fuel in the sodium chloride salt dryers. [R307-401-8] II.B.2.b The owner/operator shall install a low NOx burner in the 75 MMBtu/hr sodium chloride salt dryer (II.A.2) that is certified to meet a NOx emission concentration of 30 ppm corrected to 3% oxygen. [R307-401-8] II.B.2.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration for the 75 MMBtu/hr sodium chloride salt dryer on site (II.A.2). The record shall be kept for the life of the equipment. [R307-401-8] II.B.2.c NEW The owner/operator shall install an ultra-low-NOx burner in the new 75 MMBtu/hr sodium chloride salt dryer (II.A.3) that is certified to meet a NOx emission concentration of 9 ppm or lower corrected to 3% oxygen. [R307-401-8] II.B.2.c.1 NEW The owner/operator shall keep a record of the manufacturer's certification of the emission concentration for the new 75 MMBtu/hr sodium chloride salt dryer (II.A.3) on site. The record shall be kept for the life of the equipment. [R307-401-8] II.B.3 NEW Venturi Wet Scrubber Requirements II.B.3.a NEW The owner/operator shall use the venturi wet scrubber to control process streams from the new sodium chloride salt dryer (II.A.3). All exhaust air from the dryer shall be routed through the scrubber before being vented to the atmosphere. [R307-401-8] II.B.3.b NEW The owner/operator shall maintain the following operating parameters within the ranges below: A. The pressure drop at the throat of the venturi between 20 and 25 inches of water column B. The exhaust gas flow rate between 20,000 and 35,000 CFM C. The water flow rate between 144 and 300 GPM. [R307-401-8] II.B.3.b.1 NEW The owner/operator shall install the pressure gauge and the flow meters such that an inspector/operator can safely read the indicators at any time. The owner/operator shall maintain and calibrate the indicators according to the manufacturers' instructions at least once every 12 months. Recording of the readings is required on a daily basis when the venturi wet scrubber operates. [R307-401-8] Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 9 II.B.3.c NEW The owner/operator shall install and operate a venturi wet scrubber that is guaranteed to achieve at least 99% control efficiency for particulate control. [R307-401-8] II.B.3.c.1 NEW The owner/operator shall keep a record of the manufacture's guarantee of the control efficiency. The record shall be kept for the life of the equipment. [R307-401-8] II.B.4 NEW Baghouse Requirements II.B.4.a NEW The owner/operator shall use the baghouses to control process streams from their designated sodium chloride salt dryers. All exhaust air from the sodium chloride salt dryers (II.A.2) shall be routed through the baghouses before being vented to the atmosphere. [R307-401-8] II.B.4.b NEW The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The static pressure differential across each baghouse shall be between 2.0 to 5.0 inches of water column. The monitoring device shall be accurate within plus or minus one inch of water column. [R307-401-8] II.B.4.b.1 NEW Pressure drop readings shall be recorded daily while the baghouse is operating. Records documenting the pressure drop shall be kept in a log and shall include the following: A. Date of reading B. Unit identification C. Manufacturer recommended pressure drop for the unit (if applicable) D. Daily pressure drop readings. [R307-401-8] II.B.4.b.2 NEW Each pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.4.b.3 NEW The instrument shall be calibrated in accordance with the manufacturer's instructions or recommendations or replaced at least once every 12 months. Documentation of calibrations or replacements shall be maintained. [R307-401-8] II.B.4.c NEW The owner/operator shall install a baghouse that is certified to meet a PM10 emission concentration of 0.005 grains/dscf to control the 75 MMBtu/hr sodium chloride salt dryer (II.A.2). [R307-401-8] II.B.4.c.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration. The record shall be kept for the life of the equipment. [R307-401-8] II.B.5 Magnesium Chloride Salt Dryer Requirements II.B.5.a The owner/operator shall only use natural gas as fuel in the magnesium chloride salt dryer. [R307-401-8] Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 10 II.B.5.b The owner/operator shall install a low NOx burner in the magnesium chloride salt dryer that is certified to meet a NOx emission concentration of 30 ppm and a CO emission concentration of 100 ppm or less. [R307-401-8] II.B.5.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentrations. The record shall be kept for the life of the equipment. [R307-401-8] II.B.6 Road and Fugitive Dust II.B.6.a The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas to exceed 15% opacity on site and 10% opacity at the property boundary. [R307-309-4, R307-309-5] II.B.6.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-4, R307-401-8] II.B.6.b The owner/operator shall not allow the total length of the haul roads to exceed: A. 0.90 miles of unpaved haul roads for the tanker trucks transporting magnesium chloride concentrate. The owner/operator shall pave no less than 0.1 miles of haul road. B. 0.81 miles of unpaved haul roads for the haul trucks transporting sodium chloride salt. The owner/operator shall pave no less than 300 feet of haul road. [R307-401-8] II.B.6.c The owner/operator shall apply water sprays and/or chemical suppressant to all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain the opacity limit in the AO. [R307-309, R307-401-8] II.B.6.c.1 Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of treatment B. Number of treatments made, dilution ratio, and quantity C. Rainfall received if any, and approximate amount D. Time of day treatments were made E. Records of temperature if the temperature was below freezing. [R307-401-8] Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 11 II.B.6.d The owner/operator shall periodically sweep or spray clean the paved haul road to maintain the opacity limit in the AO. [R307-401-8] II.B.6.d.1 Records of cleaning the paved haul roads shall be kept for all periods the plant is in operation. [R307-401-8] II.B.6.e The owner/operator shall comply with all applicable requirements of R307-309 for fugitive emission and fugitive dust sources. [R307-309] II.B.7 Emergency Generator Engine Requirements II.B.7.a The owner/operator shall install and operate the following emergency generator engines: A. One (1) diesel-fired engine rated up to 1,474 hp (1,100 kW). The engine shall comply with the following Tier 4 standards: HC = 0.14 g/hp-hr, NOx = 0.5 g/hp-hr, and PM = 0.02 g/hp-hr B. One (1) natural gas/propane fired engine rated up to 201 hp (150 kW). The engine shall comply with the following standards: NOx = 2.0 g/hp-hr, CO = 4.0 g/hp-hr, and VOC = 1.0 g/hp-hr. [40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, R307-401-8] II.B.7.a.1 To demonstrate compliance with the above requirements, the owner/operator shall keep records of the manufacturer's certifications of the emission rates. The records shall be kept for the life of the equipment. [R307-401-8] II.B.7.b The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.7.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.7.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ] Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 12 II.B.7.c The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 1,474-hp (1,100-kW) emergency generator engine, and natural gas or propane in the 201-hp (150-kW) emergency generator engine. [R307-401-8] II.B.7.c.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.7.c.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] II.B.7.d The owner/operator shall not test the emergency generator engines at the same time. [R307-410-4] II.B.7.d.1 To comply with the above requirement, the owner/operator shall: A. Identify the engine to be tested B. Record the engine testing date C. Record the time the testing began and ended D. Keep the above records for all periods the plant is in operation. [R307-410-4] Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 13 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN130290007-25 dated January 8, 2025 Incorporates NOI dated January 8, 2025 Incorporates Additional information dated January 10, 2025 Incorporates Additional information dated January 22, 2025 Incorporates Additional information dated January 27, 2025 REVIEWER COMMENTS 1. Comment regarding stack testing requirement on the new dryer: The following factors were considered for not requiring stack testing on the new dryer: 1. On an annual basis, the salt production and natural gas consumption will not increase; the new venturi wet scrubber provides 99% particulate control efficiency. Therefore, emissions from this new dryer will stay unchanged. 2. The source is located in the PM2.5 serious nonattainment area with a major source threshold of 70 tpy PM2.5. The sitewide PM2.5 PTE is 36.77 tpy, far from triggering the major source threshold. 3. Modeling would be required if certain emission increases exceed the thresholds stipulated under R307-410-4, Table 1. Because there are no emission increases as a result of the replacement, modeling will not be triggered. 4. Venturi wet scrubbers are proven technology for particulate control. Salt particles are readily captured and dissolved in the water mists. The scrubber manufacturer guarantees its performance under the conditions in II.B.3.b of the ER. Based on these considerations, the Minor NSR Section does not require stack testing on the new dryer. [Last updated April 8, 2025] 2. Comment regarding NSPS and MACT Applicability: 40 CFR 60 (NSPS) Subpart OOO applies to nonmetallic mineral processing plants. Sodium Chloride (salt) is defined as a nonmetallic mineral in 60.671, however this site does not crush or grind minerals. Therefore, Subpart OOO does not apply to this source. 40 CFR 60 (NSPS) Subpart Dc applies to facilities that operate steam generating units for which construction, modification, or reconstruction commenced after June 9, 1989 and that has a maximum heat input capacity of 100 MMBTU/h or less, but greater than or equal to 10 MMBTU/h. This source does not operate any steam generating units. Therefore, Subpart Dc does not apply to this source. 40 CFR 60 (NSPS) Subpart IIII applies to the 1,474-hp (1,100-kW) diesel-fired engine. 40 CFR 60 (NSPS) Subpart JJJJ applies to the 201-hp (150-kW) natural gas/propane fired engine. Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 14 40 CFR 60 (NSPS) Subpart UUU applies to each calciner and dryer at a mineral processing plant. The facility does not operate any calciner that removes chemically bounded water; The dryers onsite do not process minerals as defined in 60.731. Therefore, this standard does not apply to this source. 40 CFR 63 (MACT) Subpart BBBBBBB applies to owners and operators of chemical preparation facilities. This source only processes salt which is not a "target-HAP'' as defined in 63.11588; therefore, Subpart BBBBBBB does not apply to this source. 40 CFR 63 (MACT) Subpart BBBBBBB applies to owners and operators of chemical preparation facilities. This source only processes salt which is not a "target-HAP'' as defined in 63.11588; therefore, Subpart BBBBBBB does not apply to this source. 40 CFR 63 (MACT) Subpart ZZZZ applies to the emergency generator engines. [Last updated January 30, 2025] 3. Comment regarding Title V applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This source is not a major source, nor a Title IV affected source. NSPS Subparts IIII and JJJJ, and MACT Subpart ZZZZ specifically exempt the source from the obligation to obtain a Title V Operating Permit if the source is not required for the permit for a reason other than being subject to these standards. There are no other reasons why this source would be required to obtain a Title V permit; therefore, Title V does not apply to this facility. [Last updated January 30, 2025] Engineer Review N130290008: Broken Arrow Inc. - Broken Arrow Flux Operations April 8, 2025 Page 15 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds DAQE-AN130290007-25 {{$d1 }} Ladislao Garcia Broken Arrow Inc. 8960 North Clinton Landing Lake Point, UT 84074 lgarcia@brokenarrowusa.com Dear Mr. Garcia: Re: Approval Order: Modification to Approval Order DAQE-AN130290006-23 to Add Emergency Generator Engines Project Number: N130290007 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on July 9, 2024. Broken Arrow Inc. must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Mr. Enqiang He, who can be contacted at (801) 556-1580 or ehe@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:EH:jg cc: Tooele County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director January 8, 2025 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN130290007-25 Modification to Approval Order DAQE-AN130290006-23 to Add Emergency Generator Engines Prepared By Mr. Enqiang He, Engineer (801) 556-1580 ehe@utah.gov Issued to Broken Arrow Inc. - Broken Arrow Flux Operations Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality January 8, 2025 TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 4 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 11 ACRONYMS ............................................................................................................................... 12 DAQE-AN130290007-25 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Broken Arrow Inc. Broken Arrow Inc. - Broken Arrow Flux Operations Mailing Address Physical Address 8960 North Clinton Landing 2600 North Ellerbeck Road Lake Point, UT 84074 Grantsville, UT 84029 Source Contact UTM Coordinates Name: Ladislao Garcia 368,170 m Easting Phone: (435) 840-4723 4,504,450 m Northing Email: lgarcia@brokenarrowusa.com Datum NAD83 UTM Zone 12 SIC code 1474 (Potash, Soda, & Borate Minerals) SOURCE INFORMATION General Description Broken Arrow Inc. (Broken Arrow) operates a salt processing plant located near Grantsville in Tooele County. The process dries, screens, and loads salt harvested from the Great Salt Lake for shipment to customers. The plant produces up to 500,000 tons of salt annually. The company also dries liquid magnesium chloride concentrate. The magnesium chloride concentrate is brought to the plant by the tanker trucks and dried by a new natural gas-fired burner. The plant processes up to 21 million gallons of magnesium chloride concentrate a year. NSR Classification Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Tooele County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions DAQE-AN130290007-25 Page 4 MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Description Broken Arrow has requested a modification to AO DAQE-AN130290006-23 to add two (2) new emergency generator engines. The diesel-fired generator engine is rated up to 1,474 hp (1,100 kW) and will support the salt drying operations during emergencies. The natural gas/propane-fired generator engine is rated up to 201 hp (150 kW) and will provide power to the magnesium chloride drying operations during emergencies. Emissions from each of the emergency generator engines are calculated based on 100 hours of operations per year and are added to the sitewide totals. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 96 16114.00 Carbon Monoxide 0.43 35.20 Nitrogen Oxides 0.37 11.54 Particulate Matter - PM10 0 38.02 Particulate Matter - PM2.5 0 36.77 Sulfur Dioxide 0 0.08 Volatile Organic Compounds 0.03 4.38 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 20 540 Change (TPY) Total (TPY) Total HAPs 0.01 0.27 SECTION I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] DAQE-AN130290007-25 Page 5 I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Broken Arrow Salt Broken Arrow Flux Operations II.A.2 Three (3) Salt Dryers Design Capacity: Rated at 40, 70, and 75 MMBtu/hr Fuel: Natural gas II.A.3 Baghouse 1 Controls: 40 MMBtu/hr dryer Flow Rate: 13,000 acfm Bag Diameter: 6" Bag Length: 9' Number of Bags: 140 Stack Height: 30' Stack Inside Dimension: 2.5' x 2.5' DAQE-AN130290007-25 Page 6 II.A.4 Baghouse 2 Controls: 70 MMBtu/hr dryer Flow Rate: 50,000 acfm Bag Diameter: 4.6" Bag Length: 12' Number of Bags: 494 Stack Height: 45' Stack Inside Dimension: 4' x 4' II.A.5 Baghouse 3 Controls: 75 MMBtu/hr dryer Flow Rate: 80,000 acfm Bag Diameter: 4.5" Bag Length: 10' Number of Bags: 960 Stack Height: 45' Stack Inside Diameter: 5' II.A.6 One (1) Magnesium Chloride Dryer Design Capacity: 10 MMBtu/hr Fuel: Natural gas Burner: Low NOx burner II.A.7 Five (5) Screens Design Capacity: One (1) rated at 50 tons/hr; two (2) rated at 150 tons/hr each, two (2) rated at 300 tons/hr each II.A.8 Seven (7) Storage Buildings Storage Capacities: 500, 500, 2,000, 2,500, 4,500, 15,000, and 20,000 tons II.A.9 Miscellaneous Equipment Associated conveyors, electric motors, front-end loaders, and haul trucks II.A.10 One (1) Diesel Storage Tank Capacity: 10,000 gallons II.A.11 One (1) Emergency Generator Engine - New Maximum Rated Capacity: 1,474 hp (1,100 kW) Tier 4 certified Fuel: Diesel NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.12 One (1) Emergency Generator Engine - New Maximum Rated Capacity: 201 hp (150 kW) Fuel: Natural gas or propane NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ DAQE-AN130290007-25 Page 7 SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Plant-Wide Requirements and Limitations II.B.1.a The owner/operator shall not allow visible emissions to exceed the following limits: A. The screens - 7% opacity B. All conveyor transfer points - 7% opacity C. Conveyor drop points - 15% opacity D. The sodium chloride dryer baghouse stacks - 10% opacity E. The magnesium chloride dryer stack - 10% opacity F. The diesel-fired emergency generator engine - 20% opacity G. The natural gas/propane-fired emergency generator engine - 10% opacity H. All other points - 15% opacity. [R307-309, R307-312-4, R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall not exceed the following production and consumption limits: A. 500,000 tons of sodium chloride salt processed per rolling 12-month period B. 21 million gallons of magnesium chloride concentrate processed per rolling 12-month period C. 272,000 MMBtu of natural gas consumed per rolling 12-month period. [R307-401-8] II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months B. Determine production by scale house records or vendor receipts C. Keep the records of production on a daily basis D. Determine natural gas consumption by billing statements from a utility company. The records of billing statements shall be kept on a monthly basis E. Keep the records of production and natural gas consumption for all periods when the plant is in operation. [R307-401-8] DAQE-AN130290007-25 Page 8 II.B.1.c The owner/operator shall install partial enclosures on all outdoor screening operations that sort material that has been processed by the sodium chloride salt dryers. The enclosures must be installed in a way to maintain the opacity limits set in this AO. [R307-401-8] II.B.2 Sodium Chloride Salt Dryer Requirements II.B.2.a The owner/operator shall only use natural gas as fuel in the salt dryers. [R307-401-8] II.B.2.b The owner/operator shall install a low NOx burner in the 75 MMBtu/hr salt dryer that is certified to meet a NOx emission concentration of 30 ppm corrected to 3% oxygen. [R307-401-8] II.B.2.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration for the 75 MMBtu/hr dryer on site. The record shall be kept for the life of the equipment. [R307-401-8] II.B.3 Requirements on the Baghouse II.B.3.a The owner/operator shall use the baghouses to control process streams from their designated dryers. All exhaust air from the sodium chloride dryers shall be routed through the baghouses before being vented to the atmosphere. [R307-401-8] II.B.3.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The static pressure differential across each baghouse shall be between 2.0 to 5.0 inches of water column. [R307-401-8] II.B.3.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of the reading is required on a daily basis when the dryer, the baghouse controls, operates. [R307-401-8] II.B.3.c The owner/operator shall install a baghouse that is certified to meet a PM10 emission concentration of 0.005 grains/dscf to control the 75 MMBtu/hr dryer. [R307-401-8] II.B.3.c.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentration. The record shall be kept for the life of the equipment. [R307-401-8] II.B.4 Magnesium Chloride Salt Dryer Requirements II.B.4.a The owner/operator shall only use natural gas as fuel in the magnesium chloride salt dryer. [R307-401-8] II.B.4.b The owner/operator shall install a low NOx burner in the magnesium chloride salt dryer that is certified to meet a NOx emission concentration of 30 ppm and a CO emission concentration of 100 ppm or less. [R307-401-8] II.B.4.b.1 The owner/operator shall keep a record of the manufacturer's certification of the emission concentrations. The record shall be kept for the life of the equipment. [R307-401-8] II.B.5 Road and Fugitive Dust II.B.5.a The owner/operator shall not allow visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas to exceed 15% opacity on site and 10% opacity at the property boundary. [R307-309-4, R307-309-5] DAQE-AN130290007-25 Page 9 II.B.5.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-4, R307-401-8] II.B.5.b The owner/operator shall not allow the total length of the haul roads to exceed: A. 0.90 miles of unpaved haul roads for the tanker trucks transporting magnesium chloride concentrate. The owner/operator shall pave no less than 0.1 miles of haul road B. 0.81 miles of unpaved haul roads for the haul trucks transporting sodium chloride salt. The owner/operator shall pave no less than 300 feet of haul road. [R307-401-8] II.B.5.c The owner/operator shall apply water sprays and/or chemical suppressants to all unpaved roads and other unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain the opacity limit in the AO. If chemical treatment is to be used, the chemical treatment plan must be approved by the Director. [R307-309, R307-401-8] II.B.5.c.1 Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of treatment B. Number of treatments made, dilution ratio, and quantity C. Rainfall received, if any, and approximate amount D. Time of day treatments were made E. Records of temperature if the temperature was below freezing. [R307-401-8] II.B.5.d The owner/operator shall periodically sweep or spray clean the paved haul road to maintain the opacity limit in the AO. [R307-401-8] II.B.5.d.1 Records of cleaning the paved haul roads shall be kept for all periods the plant is in operation. [R307-401-8] II.B.5.e The owner/operator shall comply with all applicable requirements of R307-309 for fugitive emission and fugitive dust sources. [R307-309] DAQE-AN130290007-25 Page 10 II.B.6 Emergency Generator Engine Requirements II.B.6.a The owner/operator shall install and operate the following emergency generator engines: A. One (1) diesel-fired engine rated up to 1,474 hp (1,100 kW). The engine shall comply with the following Tier 4 standards: HC = 0.14 g/hp-hr, NOx = 0.5 g/hp-hr, and PM = 0.02 g/hp-hr B. One (1) natural gas/propane-fired engine rated up to 201 hp (150 kW). The engine shall comply with the following standards: NOx = 2.0 g/hp-hr, CO = 4.0 g/hp-hr, and VOC = 1.0 g/hp-hr [40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, R307-401-8] II.B.6.a.1 To demonstrate compliance with the above requirements, the owner/operator shall keep records of the manufacturer's certifications of the emission rates. The records shall be kept for the life of the equipment. [R307-401-8] II.B.6.b The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.6.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 60 Subpart ZZZZ, R307-401-8] II.B.6.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ] II.B.6.c The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 1,474-hp (1,100-kW) emergency generator engine and natural gas or propane in the 201-hp (150-kW) emergency generator engine. [R307-401-8] II.B.6.c.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.6.c.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] II.B.6.d The owner/operator shall not test the emergency generator engines at the same time. [R307-410-4] DAQE-AN130290007-25 Page 11 II.B.6.d.1 To comply with the above requirement, the owner/operator shall: A. Identify the engine to be tested B. Record the engine testing date C. Record the time the testing began and ended D. Keep the above records for all periods the plant is in operation. [R307-410-4] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN130290006-23 dated July 31, 2023 Incorporates NOI dated July 9, 2024 Incorporates Additional information dated August 2, 2024 Incorporates DAQE-MN130290007-24 dated September 24, 2024 DAQE-AN130290007-25 Page 12 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds