DAQ-2025-002915

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DAQC-532-25
Site ID 10917 (B1)
MEMORANDUM

TO: FILE – COMPASS MINERALS (Formerly Great Salt Lake Minerals)

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: June 2, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Weber County,
FRS ID# UT0000004905700001

INSPECTION DATE: May 20, 2025

SOURCE ADDRESS: 765 North 10500 West, Ogden, Weber County

MAILING ADDRESS: 765 North 10500 West, Ogden, UT 84404-1190

SOURCE CONTACT: Ian Wright, Environmental Manager - 801-732-3011

OPERATING STATUS: Operating

PROCESS DESCRIPTION:

Brines from the north arm of the Great Salt Lake are pumped into the Great Salt Lake Minerals (GSLM)
pond system. Forty thousand acres of ponds are filled to a depth of 4 to 10 inches and separation of
minerals occurs via solar evaporation. It usually takes a year for the first mineral, sodium chloride, to
precipitate in the first series of ponds. Brines are then pumped into the next series of ponds to await
precipitation of potassium and magnesium compounds during the second year. These salts of potassium
and magnesium are harvested and fed to processing plants for washing, drying, screening, and packaging.

Sodium Chloride Plant (NaCl):
The salt plant dries, cools, screens, and either bags or bulk loads product for customers using it for water
softening, animal feed, road salting, and industrial chemical plants. The salt plant emits particulate matter
and deminimus levels of HAPs.

Potassium Sulfate Plant (K2SO4):
The potash plant uses a water leach process with thickeners and a crystallizer to convert harvested salt
deposits into sulfate of potash (SOP). The product is dried, screened, stored, and bagged or bulk loaded
for customers using it for specialty fertilizers with low chloride content. The potash plant emits particulate
matter and deminimus levels of HAPs.

Magnesium Chloride Plant (MgCl2 Liquid Solution and MgCl2~6 H2O Flake Hexahydrate):
The magnesium chloride plant stores and bulk loads liquid magnesium chloride liquid solution and
bagged flake product for customers using it for dust control, highway anti-icing, sugar refining, catalyst,
desiccant, drilling fluid, fire retardant, and synthetic sea salt ingredient. The magnesium chloride plant
emits insignificant particulate and deminimus levels of HAPs. 0 8
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APPLICABLE
REGULATIONS: Title V Operating permit 5700001004, June 10, 2021, revised December
15, 2023
40 CFR 60 Subpart A-General Provisions,
40 CFR 60 Subpart Db-Standards of Performance for Industrial-
Commercial-Institutional Steam Generating Units,
40 CFR 60 Subpart IIII-Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
40 CFR 60 Subpart JJJJ-Standards of Performance for Stationary Spark
Ignition Internal Combustion Engines,
40 CFR 63 Subpart A-General Provisions,
40 CFR 63 Subpart ZZZZ-National Emission Standards for Hazardous
Air Pollutants for Stationary Reciprocating Internal Combustion Engines,
40 CFR 63 Subpart DDDDD-National Emission Standards for
Hazardous Air Pollutants for Major Sources: Industrial, Commercial,
Institutional Boilers and Process Heaters, and
Utah State Implementation Plan, Section IX, Part H.1.g.
All regulations are listed in or commented on in Permit
Approval Order DAQE-AN109170049-24, Dated May 8, 2024.

SOURCE INSPECTION
EVALUATION:
SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: This is a statement of fact and not an inspection item.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))
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I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: This permit expires July 10, 2026. The renewal application is due December 10, 2025.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: This permit expires July 10, 2026. The renewal application is due December 10, 2025.
Company is aware of the date.

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I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: This is a statement of fact and not an inspection item.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements. (R307-415-
6c(2)(d))

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I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: Inspection was allowed. No confidentiality claims made. Inspections also done during stack
test of units. In compliance.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: Submitted reports have included the certification statement and required signature. In
compliance.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

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I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director: (R307-415-
6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: The annual certification was submitted on June 6, 2024 (due June 24, 2024), and covered the
period June 1, 2023, to May 31, 2024. All required items were included, and reviewed reports
are in the main source file. In compliance.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: This is a statement of fact and not an inspection item.

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I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two
working days of the time when emission limitations were exceeded due to the
emergency. This notice must contain a description of the emergency, any steps
taken to mitigate emissions, and corrective actions taken. This notice fulfills the
requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: No emergencies have been reported by the source since the previous inspection.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: This is a statement of fact and not an inspection item.

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

Status: This is a statement of fact and not an inspection item.

I.Q Administrative Permit Amendments.

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Administrative permit amendments are governed by R307-415-7e.

Status: This is a statement of fact and not an inspection item.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: This is a statement of fact and not an inspection item.

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable: (R307-415-
6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit. (R307-415-
6a(3)(c)(i)
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I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventative
measures taken. Prompt, as used in this condition, shall be defined as written
notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to
breakdowns shall be reported in accordance with the provisions of R307-107.
(R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch (mail code 8ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: Monitoring reports have been submitted by the source and reviewed by DAQ staff. Completed
reports and reviews are in the main source file. In compliance.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

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I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions. (R307-415-
7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit. (R307-415-
7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: This is a statement of fact and not an inspection item.
SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 SALT: Salt Production Plant
Unit includes the salt plant.
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II.A.3 SALT: AH-500 Salt Plant Circuit
A mechanically aided wet scrubber (AH-500) at the salt plant controls emissions from the following
units: bins, hoppers, conveyors, coolers, crushers, grinders, feeders, baggers, mixers, presses, and rail
loading.

II.A.4 SALT: AH-502 Salt Plant Circuit
A mechanically aided wet scrubber (AH-502) at the salt plant controls emissions from the following
units: bins, hoppers, conveyors, elevators, and screens.

II.A.5 SALT: AH-513 Salt Dryer (D-501)
Salt plant natural gas fired dryer (D-501) with exhaust directed into a wet cyclone and cyclonic
mechanically aided, with variable frequency drive (VFD), wet scrubber (AH-513).

II.A.6 SALT: BH-501 Salt Cooler
A baghouse (BH-501) at the salt plant controls emissions from the fluidized bed cooler.

II.A.7 SALT: BH-502 Salt Bulk Load-out
A baghouse (BH-502) at the salt plant controls emissions from the following units at the salt bulk load-
out area: bins, hoppers, elevators, and truck loading operations.

II.A.8 SALT: BH-503 Salt Special Products Circuit
A baghouse (BH-503) at the salt plant controls emissions from material handling in the salt special
products system.

II.A.9 SALT: BH-505 Salt Packing
A baghouse (BH-505) at the salt plant controls emissions from material handling in the salt packing area.
BH-505 is equipped with a HEPA filter. BH-505 shall vent indoors at all times the unit is operating.

II.A.10 SALT: Partially Enclosed Conveyors
Salt plant conveyor ID's: OC503.

II.A.11 SOP: SOP Production Plant
Unit includes the sulfate of potash (SOP) plant including dome silos 12, 13, and 14.

II.A.12 SOP: AH-1555 SOP Plant
A mechanically aided, with VFD, wet scrubber (AH-1555) at the SOP plant controls emissions from the
following units: bins, hoppers, conveyors, and elevators.

II.A.13 SOP: BH-001 SOP Bulk Load-Out Circuit
A baghouse (BH-001) at the SOP plant controls emissions from the following units: bins, hoppers,
screens, and truck and rail loading operations.

II.A.14 SOP: BH-002 SOP Plant
A baghouse (BH-002) at the SOP plant controls emissions from the following units: bins, hoppers,
conveyors, elevators, and screens.

II.A.15 SOP: BH-008 SOP Plant-Compaction Dryer (D-1545)
A baghouse (BH-008) with cyclone controls emissions from the following units: conveyor, and SOP
plant-compaction natural gas fired dryer (D-1545).

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II.A.16 SOP: BH-1400 SOP Dryer (D-1400)
A baghouse (BH-1400) with cyclones at the SOP plant controls emissions from the following units: bins,
hoppers, conveyors, elevators, screens, and SOP plant natural gas fired dryer (D-1400).

II.A.17 SOP: BH-1505 Bin Vent Filter
The baghouse (BH-1505) at the SOP plant controls emissions from bins and hoppers.

II.A.18 SOP: BH-1516 SOP Plant
A baghouse (BH-1516) at the SOP plant controls emissions from the following units: bins, hoppers,
conveyors, elevators, and screens.

II.A.19 SOP: Silo Building
The SOP silo building includes 11 storage silos controlled by 15 internally vented dust torit cartridge
filters.

II.A.20 SOP: SOP Submerged Combustion Process
SOP plant submerged combustion system consisting of a water process tank and four (4) natural gas
fired burners. This unit includes two SOP Plant Submerged Combustion Water Heaters: SC-450, SC-
460.

II.A.21 SOP: Fully Enclosed Conveyors
SOP plant conveyor ID's: OC014, OC015, OC1404, OC1405, OC1406, OC1501, OC1550A, OC283,
OC284, OC294, OC298, OF012, OF013.

II.A.22 SOP: Partially Enclosed Conveyors
SOP plant conveyor ID's: OC276, OC277/214, OC279, OC280, OC281.

II.A.23 MgCl: MgCl Production Plant
Unit includes the magnesium chloride (MgCl) plant.

II.A.24 MgCl: AH-692 Magnesium Chloride Plant
A venturi wet scrubber (AH-692) at the mag chloride plant controls emissions from the following units:
bins, hoppers, conveyors, crushers, grinders, elevators, feeders, baggers, and screens.

II.A.25 MgCl: Magnesium Chloride Evaporators
Two sets of two magnesium chloride evaporators, four evaporators total, used for heating brine solution
at the mag chloride plant. Each set has one primary and one secondary evaporator.

II.A.26 Cooling Towers
Cooling water for the SOP plant and the mag chloride plant is provided by three cooling towers: CT-003
and CT-004 at the SOP plant have a recirculation rate of 1500 gpm each, CT-639 at the mag chloride
plant has a recirculation rate of 212 gpm.

II.A.27 MgCl: AH-696 Magnesium Chloride Flake Cooling Belt Fan
The flaking process at the mag chloride plant uses a water-cooled belt equipped with an externally
vented fan (AH-696).

II.A.28 Boilers: Natural Gas-fired Boilers
Two natural gas-fired watertube boilers rated at 108.11 MMBtu/hr each. Each boiler is equipped with an
Ultra Low-NOx burner, internal flue gas recirculation, and a continuous oxygen trim system that
maintains an optimum air to fuel ratio.
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II.A.29 ENGINES-D: Diesel-fired Emergency Generators
Four diesel fired emergency generators: unit GN-007 rated at 235 hp, unit GN-100 rated at 610 hp fire
pump engine, unit GN-1200 rated at 402 hp, and unit GN-1300 rated at 161 hp. The permittee shall use
the emergency generator engines for electricity-producing operations only during the periods when
electric power from the public utilities is interrupted.

II.A.30 ENGINES-P: Propane-fired Emergency Generators
Three propane-fired emergency generator engines: unit GN-500 rated at less than 100 hp, GN-200 rated
at 41 hp, and GN-300 rated at 41 hp. The permittee shall only use propane as fuel in the propane-fired
engines on site. The permittee shall use the emergency generator engines for electricity-producing
operations only during the periods when electric power from the public utilities is interrupted.

II.A.31 BLAST: Abrasive Blast Machine
Abrasive blasting machine with a capacity of 50 lb/hr used as part of maintenance on metal parts.

II.A.32 ROADS: Roads and Unpaved Operational Areas
Various roads and disturbed, unpaved areas.

II.A.33 TANKS: Petroleum Storage Tanks
Three above ground fuel storage tanks: one 6,000-gallon gasoline storage tank (Tank 3), and two 10,000-
gallon (each) diesel storage tanks (Tank 4, Tank 5).

II.A.34 MISC: Miscellaneous Emissions
Source-wide emission sources: various conveyors and bucket elevators, various bins and hoppers,
various screens, grinders, and crushers, main office boiler, pallet plant operations, degreasing stations,
architectural coating operations.

Status: This is the most recent list for new Title V. No unapproved equipment was noted. Some new
equipment was added with most recent AO. See below. II.A.31 – Abrasive Blast Machine no longer
in use. In compliance.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Conditions on Permitted Source (Source-wide).

II.B.1.a Condition:

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.
[Origin: 40 CFR 82]. [40 CFR 82.150(b)]

II.B.1.a.1 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 F.

14
II.B.1.a.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.a.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.

Status: Compass confirms compliance with this condition in the annual certification. An outside
contractor is used for building units. In compliance.

II.B.1.b Condition:

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. [Origin:
40 CFR 82]. [40 CFR 82.30(b)]

II.B.1.b.1 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.b.2 Recordkeeping:

All records required in 40 CFR 82, Subpart B shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.b.3 Reporting:

All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: Compass confirms compliance with this condition in the annual certification. Motor Vehicle
service is done in-house. In compliance.

II.B.1.c Condition:

The permittee shall use only pipeline quality natural gas as a fuel source for all boilers and burners.
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.1.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.c.2 Recordkeeping:

An operating log will be maintained to document any period when plant equipment is operated
using any fuel other than natural gas. Records shall be maintained in accordance with Provision
I.S.1 of this permit.
15
II.B.1.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All burners are equipped to operate on natural gas only (except for approved emergency
generators). No alternative fuels were observed. In compliance.

II.B.1.d Condition:

Unless otherwise specified, at all times, including periods of startup, shutdown, and malfunction, the
permittee shall, to the extent practicable, maintain and operate any affected emission units, 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. [Origin: DAQE-AN109170044-23]. [40 CFR 60.11(d), R307-
401-8, R307-401-4]

II.B.1.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.d.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.B.1.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: At the time of this inspection the affected emission units, including associated air pollution control
equipment, appeared to be maintained and operated in a manner consistent with good air
pollution control practice for minimizing emissions. Records were made available via a
computerized maintenance system. No excess emissions were noted from any point during the
inspection. In compliance.

II.B.1.e Condition:

Unless otherwise specified in this permit, visible emissions from any stationary or fugitive emission
source shall not exceed 10 percent opacity. This includes, but is not limited to, all wet scrubbers and all
baghouses. [Origin: DAQE-AN109170044-23]. [R307-305-3, R307-401-8]

II.B.1.e.1 Monitoring:

a) Except as noted in b) through d) below, a visual opacity survey of each affected emission
unit shall be performed on a monthly basis while the unit is operating. For baghouses
subject to 40 CFR Part 64, the permittee shall designate one of the weekly opacity surveys
to demonstrate compliance with the monthly survey requirement in this condition. The
16
visual opacity survey shall be performed by an individual trained on the observation
procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed
water vapor are observed from an emission unit, an opacity determination of that emission
unit shall be performed by a certified observer within 24 hours of the initial survey. The
opacity determination shall be performed in accordance with 40 CFR 60, Appendix A,
Method 9, or other EPA-approved testing method, as acceptable to the Director, for point
sources, and in accordance with 40 CFR 51 Appendix M, Method 203A, or other EPA-
approved testing method, as acceptable to the Director, for fugitive sources.
b) For intermittent sources, opacity observations shall be performed on a monthly basis while
the unit is operating in accordance with 40 CFR 60, Appendix A, Method 9, however, the
requirement for observations to be made at 15-second intervals over a six-minute period
shall not apply. The number of observations and the time period shall be determined by the
length of the intermittent source operation.
c) For emission units located within a building, the requirements of paragraph a) apply to each
affected emission unit located within a building or for the building itself. If visible
emissions from a building are monitored, the requirements of paragraph a) apply to each
side, roof, and vent of the building. The affected emission unit(s) shall be operating when
monitoring is performed on the unit located within a building or on the building itself.
d) The permittee is not required to perform monthly surveys on natural gas combustion
sources, cooling towers, magnesium chloride evaporators, and petroleum storage tanks.

II.B.1.e.2 Recordkeeping:

The permittee shall keep a log of the visual opacity survey(s) containing the following
information: date and time visual emissions observed, emission point location and description,
time and date of opacity test, and percent opacity. If an opacity determination is performed, a
notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix
A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA-approved testing
method, as acceptable to the Director, shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.1.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All required points are included in the VEO log maintained by the compliance manager. This log
shows source ID, process, opacity limit, permit citation, date/time observed, unit operating status,
visible emission noted, method nine completed, and a note section. The log is broken out by
process. The compliance manager does the monthly readings and is method nine certified, so most
method nine readings are done at the time of the observation. No excess emissions were noted
during this inspection or numerous stack tests during the fiscal year. Review of the records shows
readings done correctly and timely. The VEO does note which weekly baghouse inspection is used
for monthly observation. In compliance.

II.B.1.f Condition:

The permittee shall submit a fugitive dust control plan to the Director in accordance with R307-309-6.
Activities regulated by R307-309 shall not commence before the fugitive dust control plan is approved
by the director. If site modifications result in emission changes, the permittee shall submit an updated
fugitive dust control plan. At a minimum, the fugitive dust control plan shall include the requirements in
17
R307-309-6(4) as applicable. The fugitive dust control plan shall include contact information, site
address, total area of disturbance, expected start and completion dates, identification of dust suppressant
and plan certification by signature of a responsible person. [Origin: R307-309]. [R307-309-5(2), R307-
309-6]

II.B.1.f.1 Monitoring:

Adherence to the most recently approved fugitive dust control plan shall be monitored to
demonstrate that appropriate measures are being implemented to control fugitive dust. At least
once every three years, the fugitive dust control plan shall be reviewed and evaluated. If site
modifications that result in emission changes have been made, an updated fugitive dust control
plan shall be submitted as required by R307-309-6(3).

II.B.1.f.2 Recordkeeping:

Records that demonstrate compliance with this condition shall be available to the director upon
request. [R307-309-12]

Records required by the most recently approved fugitive dust control plan shall be maintained in
accordance with the plan and section I.S.1 of this permit.

II.B.1.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The most recent dust plan is dated February 2020. A revised copy was submitted and approved on
April 24, 2020. Road dust logs are maintained. Compass was adhering to the dust plan during this
inspection. No excessive fugitive dust was observed during the inspection. In compliance.

II.B.1.g Condition:

If the permittee owns, operates or maintains a new or existing material storage, handling or hauling
operation, the permittee shall prevent, to the maximum extent possible, material from being deposited
onto any paved road other than a designated deposit site. If materials are deposited that may create
fugitive dust on a public or private paved road, the permittee shall clean the road promptly. [Origin:
R307-309]. [R307-309-7]

II.B.1.g.1 Monitoring:

Adherence to the most recently approved fugitive dust control plan shall be monitored to
demonstrate compliance with this condition. Records required for this permit condition will also
serve as monitoring.

II.B.1.g.2 Recordkeeping:

Records that demonstrate compliance with this condition and records required by the most
recently approved fugitive dust control plan shall be maintained in accordance with the plan and
section I.S.1 of this permit.

18
II.B.1.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The most recent dust plan is dated February 2020. A revised copy was submitted and approved on
April 24, 2020. Road dust logs are maintained. Compass was adhering to the dust plan during this
inspection. No excessive fugitive dust during the inspection. In compliance.

II.B.1.h Condition:

Each baghouse shall operate within the static pressure range recommended by the manufacturer for
normal operations. The static pressure range shall be clearly labeled on each baghouse such that an
inspector/operator can safely read the range at any time. For baghouses that monitor pressure drop to
demonstrate compliance with 40 CFR Part 64, the requirements in this condition shall not apply. [Origin:
DAQE-AN109170044-23]. [R307-401-8]

II.B.1.h.1 Monitoring:

Manometer or magnehelic pressure gauges shall be installed to measure the differential pressure
across each of the baghouses. The pressure gauges shall be located such that an
inspector/operator can safely read the indicator at any time. The pressure gauges of each
baghouse shall be calibrated in accordance with the manufacturer's instructions or
recommendations at least once every 12 months. Records required for this permit condition will
also serve as monitoring.

II.B.1.h.2 Recordkeeping:

Pressure drop readings from each baghouse shall be recorded at least once during each day of
operation. Records documenting these inspections shall be kept in a log and shall include the
following:
A. Unit identification;
B. Manufacturer recommended pressure drop for the unit;
C. Daily pressure drop readings; and
D. Date of bag replacements.
Documentation of calibrations shall be maintained for all periods the plant is in operation.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

19
II.B.1.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All baghouses have continuous monitors and are read on the tracking system which can be
accessed in the control rooms and on the compliance managers computer. System had alarms for
Dp range. The system does have an alarm based on set points and sends alarm plus email for any
out-of-range readings. There is a running list of alarms and emails which can be readily viewed.
Spot check of system does show alarms are set to correct limits. Compliance person checks daily
against limit at 6am and records to a daily sheet. Dp limits are also written on each baghouse gage.
Bag replacements and calibrations are tracked in the maintenance system and reported in six
month monitoring report if excursions occur. Calibrations are done in the fall quarter. Last
calibrations were done September to December 2024. Data base readings provided on site during
inspection. Dp inches readings were: BH1 – 2.83, BH2- 3.80, BH008 – 2.50, BH502- 1.40,
BH501- 3.6, BH505- OOS ( this unit vent indoors), BH1516- 2.98, and BH1401/1402 – 3.6/3.4.
Review of trends show these to be normal operations. In compliance.

II.B.2 Conditions on SALT: Salt Production Plant

II.B.2.a Condition:

The following production limits shall not be exceeded:
i. 1,685,000 tons of salt harvested from ponds per rolling 12-month period
ii. 700,000 tons of road salt produced per rolling 12-month period
iii. 960,000 tons of dried salt produced per rolling 12-month period
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.2.a.1 Monitoring:

The permittee shall demonstrate compliance with the rolling 12-month total for each production
limit. The permittee shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months.

II.B.2.a.2 Recordkeeping:

Records of production shall be kept on a daily basis for all periods when the plant is in operation.
Production records shall be determined by examination of sales, billing records or operation
logs. Records and results of monitoring shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.2.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records are kept in the spreadsheet which shows monthly and twelve-month totals. The review of
spreadsheet shows correct calculations. The 12-month totals as of April 30, 2025, were, 192,333
tons harvest salt, 66,200 tons road salt, and 192,333 tons of dried salt. Spreadsheet shows limits in
comparison to production numbers. In compliance.

20
II.B.2.b Condition:

Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity:
i. All loading operations
ii. All conveyor drop points
iii. All conveyor transfer points
iv. All bin vents
v. All storage piles
vi. All partially enclosed conveyance systems
vii. All material handling operations which includes the following: bins, hoppers, screens, crushers,
grinders, and presses
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.2.b.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis
while the unit is operating. The visual opacity survey shall be performed by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other
than condensed water vapor are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey.
The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A,
Method 9, or other EPA-approved testing method, as acceptable to the Director, for point
sources, and in accordance 40 CFR 51 Appendix M, Method 203A, or other EPA-approved
testing method, as acceptable to the Director, for fugitive sources.

For intermittent sources, opacity observations shall be performed on a monthly basis while the
unit is operating in accordance with 40 CFR 60, Appendix A, Method 9, however, the
requirement for observations to be made at 15 second intervals over a six-minute period shall not
apply. The number of observations and the time period shall be determined by the length of the
intermittent source operation.

II.B.2.b.2 Recordkeeping:

The permittee shall keep a log of the visual opacity survey(s) containing the following
information: date and time visual emissions observed, emission point location and description,
time and date of opacity test, and percent opacity. If an opacity determination is performed, a
notation of the determination will be made in the log. Records and all data required by 40 CFR
60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA-
approved testing method, as acceptable to the Director, shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.2.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The monthly VEO tracking form shows outdoor operations and includes comments on what this
includes and reading methods. The forms are available for review. In compliance.

21
II.B.3 Conditions on SALT: AH-500 Salt Plant Circuit

II.B.3.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 1.61 lb/hr
PM2.5: 1.61 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.01 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.3.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference shall
be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or
other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5, resulting
in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing
analytical methods, such as: x-ray diffraction, scanning electron microscopy, or
electron microprobe analysis may be used to determine particle sizing, as
acceptable to the Director. The back half condensable particulate emissions shall
also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved
testing method as acceptable to the Director.

22
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing shall
be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the previous
12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110% of
the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is
successful. This process may be repeated until the maximum permitted production
rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Scrubber liquid flow rate shall be measured using a flow meter.
(b) Indicator No. 2: Fan speed shall be monitored. Either output from the variable
frequency drive (VFD) or electronic overload relay in the fan shall be monitored
and used to calculate fan speed, or a tachometer shall be used to monitor fan speed.
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as an average scrubber liquid flow rate
over a one-hour period that is less than 131 gallons per minute (gpm).
(b) Indicator No. 2: An excursion is defined as a fan speed less than 520 RPM during
a 24-hour period.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The scrubber liquid flow rate shall be measured using a flow
meter located on the scrubber liquid line. The scrubber liquid flow rate shall
be accurate to five (5) gpm or as approved by the Director. Flow rate meters
shall be located such that an inspector/operator can safely read the indicators
at any time.
(2) Indicator No. 2: VFDs or electronic overload relays, if used, shall be installed
in accordance with the manufacturer's recommendations and shall be located
such that an inspector/operator can safely read the output at any time. A
tachometer, if used, shall be operated according to the manufacturer's
recommendations.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The flow meter shall be calibrated according to the
manufacturer's recommendations or at least annually. The scrubber shall
operate within the liquid flow rate range recommended by the manufacturer
23
for normal operations. This range shall be clearly labeled on each scrubber
such that an inspector/operator can safely read the parameters at any time.
The data acquisition system shall be operated and maintained according to the
manufacturer's recommendations.
(2) Indicator No. 2: The scrubber shall operate within the fan speed range
recommended by the manufacturer for normal operations. This range shall be
clearly labeled on each scrubber such that an inspector/operator can safely
read the parameters at any time. Tachometers, if used on the scrubber, shall
be calibrated according to the manufacturer's recommendations or at least
annually.
(c) Monitoring Frequency:
(1) Indicator No. 1: The scrubber liquid flow rate shall be measured
continuously.
(2) Indicator No. 2: Fan speed shall be monitored daily. Once each day, either
output from the variable frequency drive (VFD) or electronic overload relay
in the fan shall be monitored and used to calculate fan speed, or a tachometer
shall be used to monitor fan speed.
(d) Data Collection Procedure:
(1) Indicator No. 1: An average scrubber liquid flow rate shall be calculated
during each hour of operation. The hourly average shall be recorded for
comparison to the excursion level.
(2) Indicator No. 2: Fan speed shall be calculated or measured each day the unit
operates. The daily fan speed shall be recorded for comparison to the
excursion level.
(e) Averaging Period:
(1) Indicator No. 1: One hour
(2) Indicator No. 2: N/A
(40 CFR 64.6(c))
C. 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.B.3.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

The permittee shall maintain a file of activities for installation of the scrubber liquid flow meter
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

24
Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

II.B.3.a.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.3.a.1.C.

Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
AH-500 10/24/24 5/201a PM2.5 0.001 gr/dscf 0.01 gr/dscf
AH-500 10/24/24 5/201a PM2.5 0.36 lb/hr 1.61 lb/hr
AH-500 10/24/24 5/201a PM10 0.36 lb/hr 1.61 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which includes flow and fan speed exceedances. The real time readings done during the inspection
were 128.05 and 33.15 GPM with readings shown on shared tracking system. Trend lines show
these to be normal readings. In compliance.

II.B.4 Conditions on SALT: AH-502 Salt Plant Circuit

II.B.4.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 1.12 lb/hr
PM2.5: 0.74 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.04 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

25
II.B.4.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then
the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d,
5i, or other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5,
resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate
particle sizing analytical methods, such as: x-ray diffraction, scanning electron
microscopy, or electron microprobe analysis may be used to determine particle
sizing, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or
other EPA-approved testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous 12 months (365 days).
26
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Scrubber liquid flow rate shall be measured using a flow meter.
(b) Indicator No. 2: Fan speed shall be monitored. Either output from the variable
frequency drive (VFD) or electronic overload relay in the fan shall be monitored
and used to calculate fan speed, or a tachometer shall be used to monitor fan
speed.
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as an average scrubber liquid flow rate
over a one-hour period that is less than 47 gallons per minute (gpm).
(b) Indicator No. 2: An excursion is defined as a fan speed less than 935 RPM during
a 24-hour period.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The scrubber liquid flow rate shall be measured using a
flow meter located on the scrubber liquid line. The scrubber liquid flow rate
shall be accurate to five (5) gpm or as approved by the Director. Flow rate
meters shall be located such that an inspector/operator can safely read the
indicators at any time.
(2) Indicator No. 2: VFDs or electronic overload relays, if used, shall be
installed in accordance with the manufacturer's recommendations and shall
be located such that an inspector/operator can safely read the output at any
time. A tachometer, if used, shall be operated according to the
manufacturer's recommendations.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The flow meter shall be calibrated according to the
manufacturer's recommendations or at least annually. The scrubber shall
operate within the liquid flow rate range recommended by the manufacturer
for normal operations. This range shall be clearly labeled on each scrubber
such that an inspector/operator can safely read the parameters at any time.
The data acquisition system shall be operated and maintained according to
the manufacturer's recommendations.
(2) Indicator No. 2: The scrubber shall operate within the fan speed range
recommended by the manufacturer for normal operations. This range shall
be clearly labeled on each scrubber such that an inspector/operator can
safely read the parameters at any time. Tachometers, if used on the scrubber,
shall be calibrated according to the manufacturer's recommendations or at
least annually.
(c) Monitoring Frequency:
(1) Indicator No. 1: The scrubber liquid flow rate shall be measured
continuously.
27
(2) Indicator No. 2: Fan speed shall be monitored daily. Once each day, either
output from the variable frequency drive (VFD) or electronic overload relay
in the fan shall be monitored and used to calculate fan speed, or a tachometer
shall be used to monitor fan speed.
(d) Data Collection Procedure:
(1) Indicator No. 1: An average scrubber liquid flow rate shall be calculated
during each hour of operation. The hourly average shall be recorded for
comparison to the excursion level.
(2) Indicator No. 2: Fan speed shall be calculated or measured each day the unit
operates. The daily fan speed shall be recorded for comparison to the
excursion level.
(e) Averaging Period:
(1) Indicator No. 1: One hour
(2) Indicator No. 2: N/A
(40 CFR 64.6(c))
C. 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.B.4.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

The permittee shall maintain a file of activities for installation of the scrubber liquid flow meter
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

II.B.4.a.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
28
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.4.a.1.C.

Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
AH-502 10/17-18/24 5/201a PM2.5 0.0003
gr/dscf 0.04 gr/dscf
AH-502 10/17-18/24 5/201a PM2.5 0.03 lb/hr 0.74 lb/hr
AH-502 10/17/18/24 5/201a PM10 0.03 lb/hr 1.12 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which includes flow and fan speed exceedances. The real time readings done during the inspection
were 68.01 GPM with readings shown on shared tracking system. Trend lines show these to be
normal readings. In compliance.

II.B.5 Conditions on SALT: AH-513 Salt Dryer (D-501)

II.B.5.a Condition:

NOx emissions to the atmosphere from the dryer (D-501) shall not exceed 20 ppm at 3% O2. [Origin:
DAQE-AN109170044-23]. [R307-401-8]

II.B.5.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested at least once every three years. The Director may
require testing at any time. If an existing source is modified, a compliance test is required
on the modified emission point that has an emission rate limit.
(b) Notification. At least 30 days prior to conducting any required emission testing, the source
shall notify the Director of the date, time, and place of testing and provide a copy of the test
protocol. The source test protocol shall be approved by the Director prior to performing the
test(s). The source test protocol shall outline the proposed test methodologies, stack to be
tested, and procedures to be used. A pretest conference shall be held, if directed by the
Director.
(c) Methods.
(i) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. An Occupational Safety and Health Administration (OSHA)
or Mine Safety and Health Administration (MSHA) approved access shall be provided
to the test location.
(ii) NOx emissions shall be determined using 40 CFR 60, Appendix A, Method 7E, or
other EPA-approved testing method, as acceptable to the Director.
29
(iii) 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.
(iv) Compliance with the limit shall be based on an average of 3 test runs.
(d) Calculations. To determine mass emission rates (lb/hr) the pollutant concentration as
determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director, to
give the results in the specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be
no less than 90% of the permitted production rate. If the maximum permitted production
rate has not been achieved at the time of the test, the following procedure shall be followed:
(i) Testing shall be at no less than 90% of the production rate achieved in the previous
three years.
(ii) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This
new allowable maximum production rate shall remain in effect until successfully tested
at a higher rate.
(iii) Testing at no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is successful.
This process may be repeated until the maximum permitted production rate is
achieved.

II.B.5.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

II.B.5.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: Stack testing was last conducted October 19, 2022. The DAQ reported results were 3.37 ppmdv
3% O2. Next test is due in 2025. In compliance.

II.B.5.b Condition:

Emissions to the atmosphere from the scrubber (AH-513) shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg).
PM10: 1.49 lb/hr
PM2.5: 1.49 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.0114 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.5.b.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
30
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then
the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d,
5i, or other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5,
resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate
particle sizing analytical methods, such as: x-ray diffraction, scanning electron
microscopy, or electron microprobe analysis may be used to determine particle
sizing, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or
other EPA-approved testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous 12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
31
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Scrubber liquid flow rate shall be measured using a flow meter.
(b) Indicator No. 2: Fan speed shall be monitored. Either output from the variable
frequency drive (VFD) or electronic overload relay in the fan shall be monitored
and used to calculate fan speed, or a tachometer shall be used to monitor fan
speed.
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as an average scrubber liquid flow rate
over a one-hour period that is less than 89 gallons per minute (gpm).
(b) Indicator No. 2: An excursion is defined as a fan speed less than 593 RPM during
a 24-hour period.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The scrubber liquid flow rate shall be measured using a
flow meter located on the scrubber liquid line. The scrubber liquid flow rate
shall be accurate to five (5) gpm or as approved by the Director. Flow rate
meters shall be located such that an inspector/operator can safely read the
indicators at any time.
(2) Indicator No. 2: VFDs or electronic overload relays, if used, shall be
installed in accordance with the manufacturer's recommendations and shall
be located such that an inspector/operator can safely read the output at any
time. A tachometer, if used, shall be operated according to the
manufacturer's recommendations.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The flow meter shall be calibrated according to the
manufacturer's recommendations or at least annually. The scrubber shall
operate within the liquid flow rate range recommended by the manufacturer
for normal operations. This range shall be clearly labeled on each scrubber
such that an inspector/operator can safely read the parameters at any time.
The data acquisition system shall be operated and maintained according to
the manufacturer's recommendations.
(2) Indicator No. 2: The scrubber shall operate within the fan speed range
recommended by the manufacturer for normal operations. This range shall
be clearly labeled on each scrubber such that an inspector/operator can
safely read the parameters at any time. Tachometers, if used on the scrubber,
shall be calibrated according to the manufacturer's recommendations or at
least annually.
(c) Monitoring Frequency:
(1) Indicator No. 1: The scrubber liquid flow rate shall be measured
continuously.
(2) Indicator No. 2: Fan speed shall be monitored daily. Once each day, either
output from the variable frequency drive (VFD) or electronic overload relay
in the fan shall be monitored and used to calculate fan speed, or a tachometer
shall be used to monitor fan speed.
32
(d) Data Collection Procedure:
(1) Indicator No. 1: An average scrubber liquid flow rate shall be calculated
during each hour of operation. The hourly average shall be recorded for
comparison to the excursion level.
(2) Indicator No. 2: Fan speed shall be calculated or measured each day the unit
operates. The daily fan speed shall be recorded for comparison to the
excursion level.
(e) Averaging Period:
(1) Indicator No. 1: One hour
(2) Indicator No. 2: N/A
(40 CFR 64.6(c))
C. 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.B.5.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

The permittee shall maintain a file of activities for installation of the scrubber liquid flow meter
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

II.B.5.b.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.5.b.1.C.
33
Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
AH-513 10/2-23/24 201a/202 PM2.5 0.0031
gr/dscf
0.0114
gr/dscf
AH-513 10/22-23/24 201a/202 PM2.5 0.46 lb/hr 1.49 lb/hr
AH-513 10/22-23/24 201a/202 PM10 1.24 lb/hr 1.49 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which includes flow and fan speed exceedances. The real time readings done during the inspection
were 66.50 GPM with readings shown on shared tracking system. Trend lines show these to be
normal readings. In compliance.

II.B.6 Conditions on SALT: BH-501 Salt Cooler

II.B.6.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 1.30 lb/hr
PM2.5: 1.15 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.01 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.6.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
34
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then
the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d,
5i, or other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5,
resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate
particle sizing analytical methods, such as: x-ray diffraction, scanning electron
microscopy, or electron microprobe analysis may be used to determine particle
sizing, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or
other EPA-approved testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr) the pollutant concentration as
determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous 12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Pressure drop across the baghouse shall be measured using a
differential pressure gauge.
(b) Indicator No. 2: Visible emissions from the baghouse exhaust shall be monitored
by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9.
(c) Indicator No. 3: An internal inspection of the baghouse including a dye test shall
be performed to identify damaged bags and required maintenance.
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
35
(a) Indicator No. 1: An excursion is defined as an average differential pressure
outside the range of 1 to 6 inches of water column during a 24-hour period.
(b) Indicator No. 2: An excursion is defined as the presence of visible emissions.
(c) Indicator No. 3: An excursion is defined as a failure to perform the semi-annual
baghouse internal inspection as specified below.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The differential pressure gauge shall measure pressure drop
with pressure taps located at the baghouse inlet and outlet. The minimum
accuracy of the gauge shall be +/- 0.5 inches of water column. The pressure
gauges shall be located such that an inspector/operator can safely read the
indicator at any time.
(2) Indicator No. 2: Visible emissions shall be monitored at the stack exhaust
while the baghouse is operating.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test to identify damaged bags and required maintenance.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The pressure gauge shall be calibrated according to the
manufacturer's recommendations or at least annually. Pressure taps shall be
checked for plugging monthly. Each baghouse shall operate within the static
pressure range recommended by the manufacturer for normal operations.
The static pressure range shall be clearly labeled on each baghouse such that
an inspector/operator can safely read the range at any time. The data
acquisition system shall be operated and maintained according to the
manufacturer's recommendations.
(2) Indicator No. 2: Visible emissions from the baghouse exhaust shall be
monitored by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9.
(3) Indicator No. 3: The internal baghouse inspection and dye test shall be
performed by personnel trained on proper baghouse operation and
preventive maintenance.
(c) Monitoring Frequency:
(1) Indicator No. 1: Pressure drop shall be monitored continuously.
(2) Indicator No. 2: Once each week, a visual opacity survey shall be performed
on the baghouse exhaust, while the unit is operating, by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test semi-annually to identify damaged bags and required
maintenance.
(d) Data Collection Procedure:
(1) Indicator No. 1: The average pressure drop shall be displayed each minute at
the baghouse location. Using the minute averages, the data acquisition
system shall calculate an average pressure drop each day the unit operates.
The daily average shall be recorded for comparison to the excursion level.
(2) Indicator No. 2: Results of the visual opacity survey shall be recorded each
week for comparison to the excursion level.
(3) Indicator No. 3: Results of baghouse inspections including the dye test and
documentation of any required maintenance shall be recorded semi-annually.
(e) Averaging Period:
(1) Indicator No. 1: 24-hour period
(2) Indicator No. 2: N/A
36
(3) Indicator No. 3: N/A
(40 CFR 64.6(c))
C. 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.B.6.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

The permittee shall maintain a file of activities for installation of the differential pressure gauge
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

II.B.6.a.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.6.a.1.C.

37
Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
BH-501 10/24/24 201a/202 PM2.5 0.0044
gr/dscf 0.01 gr/dscf
BH-501 10/24/24 201a/202 PM2.5 0.56 lb/hr 1.15 lb/hr
BH-501 10/24/24 201a/202 PM10 0.58 lb/hr 1.30 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which include any Dp excursions and bag house inspection dates. The operating parameters were
being monitored during this inspection. The real time readings are reported in the general
requirements section above. In compliance.

II.B.7 Conditions on SALT: BH-502 Salt Bulk Load-out

II.B.7.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 0.20 lb/hr
PM2.5: 0.06 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.0053 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.7.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
38
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then
the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d,
5i, or other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5,
resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate
particle sizing analytical methods, such as: x-ray diffraction, scanning electron
microscopy, or electron microprobe analysis may be used to determine particle
sizing, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or
other EPA-approved testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr) the pollutant concentration as
determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous 12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Pressure drop across the baghouse shall be measured using a
differential pressure gauge.
(b) Indicator No. 2: Visible emissions from the baghouse exhaust shall be monitored
by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9.
(c) Indicator No. 3: An internal inspection of the baghouse including a dye test shall
be performed to identify damaged bags and required maintenance.
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
39
(a) Indicator No. 1: An excursion is defined as an average differential pressure
outside the range of 1 to 6 inches of water column during a 24-hour period.
(b) Indicator No. 2: An excursion is defined as the presence of visible emissions.
(c) Indicator No. 3: An excursion is defined as a failure to perform the semi-annual
baghouse internal inspection as specified below.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The differential pressure gauge shall measure pressure drop
with pressure taps located at the baghouse inlet and outlet. The minimum
accuracy of the gauge shall be +/- 0.5 inches of water column. The pressure
gauges shall be located such that an inspector/operator can safely read the
indicator at any time.
(2) Indicator No. 2: Visible emissions shall be monitored at the stack exhaust
while the baghouse is operating.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test to identify damaged bags and required maintenance.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The pressure gauge shall be calibrated according to the
manufacturer's recommendations or at least annually. Pressure taps shall be
checked for plugging monthly. Each baghouse shall operate within the static
pressure range recommended by the manufacturer for normal operations.
The static pressure range shall be clearly labeled on each baghouse such that
an inspector/operator can safely read the range at any time. The data
acquisition system shall be operated and maintained according to the
manufacturer's recommendations.
(2) Indicator No. 2: Visible emissions from the baghouse exhaust shall be
monitored by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9.
(3) Indicator No. 3: The internal baghouse inspection and dye test shall be
performed by personnel trained on proper baghouse operation and
preventive maintenance.
(c) Monitoring Frequency:
(1) Indicator No. 1: Pressure drop shall be monitored continuously.
(2) Indicator No. 2: Once each week, a visual opacity survey shall be performed
on the baghouse exhaust, while the unit is operating, by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test semi-annually to identify damaged bags and required
maintenance.
(d) Data Collection Procedure:
(1) Indicator No. 1: The average pressure drop shall be displayed each minute at
the baghouse location. Using the minute averages, the data acquisition
system shall calculate an average pressure drop each day the unit operates.
The daily average shall be recorded for comparison to the excursion level.
(2) Indicator No. 2: Results of the visual opacity survey shall be recorded each
week for comparison to the excursion level.
(3) Indicator No. 3: Results of baghouse inspections including the dye test and
documentation of any required maintenance shall be recorded semi-annually.
(e) Averaging Period:
(1) Indicator No. 1: 24-hour period
(2) Indicator No. 2: N/A
40
(3) Indicator No. 3: N/A
(40 CFR 64.6(c))
C. 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.B.7.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

The permittee shall maintain a file of activities for installation of the differential pressure gauge
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

II.B.7.a.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.7.a.1.C.

41
Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
BH-502 10/22-25/23 5/201a PM2.5 0.0007
gr/dscf
0.0053
gr/dscf
BH-502 10/22-25/23 5/201a PM2.5 0.04 lb/hr 0.06 lb/hr
BH-502 10/22/25/23 5/201a PM10 0.04 lb/hr 0.20 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which include any Dp excursions and bag house inspection dates. The operating parameters were
being monitored during this inspection. The real time readings are reported in the general
requirements section above. In compliance.

II.B.8 Conditions on SALT: BH-503 Salt Special Products Circuit

II.B.8.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 1.54 lb/hr
PM2.5: 0.23 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.01 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.8.a.1 Monitoring:

Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is required
on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the source
shall notify the Director of the date, time, and place of testing and provide a copy of the test
protocol. The source test protocol shall be approved by the Director prior to performing the
test(s). The source test protocol shall outline the proposed test methodologies, stack to be
tested, and procedures to be used. A pretest conference shall be held, if directed by the
Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. An Occupational Safety and Health Administration (OSHA)
or Mine Safety and Health Administration (MSHA) approved access shall be provided
to the test location.
42
(b) For stacks in which no liquid drops are present, the following methods shall be used:
40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing method, as
acceptable to the Director. The back half condensable particulate emissions shall also
be tested using 40 CFR 51, Appendix M, Method 202, or other EPA-approved testing
method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or
other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5, resulting in
PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing
analytical methods, such as: x-ray diffraction, scanning electron microscopy, or
electron microprobe analysis may be used to determine particle sizing, as acceptable to
the Director. The back half condensable particulate emissions shall also be tested using
40 CFR 51, Appendix M Method 202, or other EPA-approved testing method as
acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and shall
include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr) the pollutant concentration as
determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director to
give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing shall be
no less than 90% of the permitted production rate. If the maximum permitted production
rate has not been achieved at the time of the test, the following procedure shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the previous 12
months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This
new allowable maximum production rate shall remain in effect until successfully tested
at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is successful.
This process may be repeated until the maximum permitted production rate is
achieved.

II.B.8.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

43
II.B.8.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: Baghouse 503 vents to the inside of the product circuit building. No testing is required unless the
stack is changed to vent to the outside. On site review shows this unit vents indoors. In compliance.

II.B.9 Conditions on SOP: SOP Production Plant

II.B.9.a Condition:

The following production and operation limits shall not be exceeded:
i. 5,300,000 tons of potash harvested from ponds per rolling 12-month period
ii. 1,680,000 tons of SOP produced per rolling 12-month period
iii. 432,000 tons of KCl used per rolling 12-month period
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.9.a.1 Monitoring:

The permittee shall demonstrate compliance with the rolling 12-month total for each production
limit. The permittee shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months.

II.B.9.a.2 Recordkeeping:

Records of production shall be kept daily for all periods when the plant is in operation.
Production records shall be determined by operation logs. Records and results of monitoring
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.9.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records are kept in the spreadsheet which shows monthly and twelve-month totals. Review of the
spreadsheet shows correct calculations. The 12-month totals as of April 30, 2025, were: 576,345
tons of potash, 59,199 tons of SOP, and 6,531 tons of KCl. In compliance.

II.B.9.b Condition:

Visible emissions from all outdoor storage silos shall not exceed 10% opacity. Egress points to the dome
silos shall remain closed at all times, except when mobile equipment is actively entering or exiting the
silo during loading or unloading operations. [Origin: DAQE-AN109170044-23]. [R307-401-8]

44
II.B.9.b.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis
while loading or unloading operations are occurring at the silo. The visual opacity survey shall
be performed by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9. If visible emissions are observed from an emission unit, an opacity determination of
that emission unit shall be performed by a certified observer within 24 hours of the initial survey.
The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A,
Method 9, or other EPA-approved testing method, as acceptable to the Director, while loading or
unloading operations are occurring at the silo.

II.B.9.b.2 Recordkeeping:

The permittee shall keep a log of the visual opacity survey(s) containing the following
information: date and time visual emissions observed, emission point location and description,
time and date of opacity test, and percent opacity. If an opacity determination is performed, a
notation of the determination will be made in the log. Documentation of maintenance performed
on the silos to ensure they operate as fully-enclosed structures when egress points are closed
shall also be kept in the log. Records and all data required by 40 CFR 60, Appendix A, Method
9, or other EPA-approved testing method, as acceptable to the Director, shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.9.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The monthly VEO tracking form shows outdoor operations, dome silos, and includes comments on
what this includes and reading methods. The forms are available for review. In compliance.

II.B.9.c Condition:

Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity:
i. All loadout operations
ii. All conveyor drop points
iii. All conveyor transfer points
iv. All storage piles
v. All partially enclosed conveyance systems
vi. All material handling operations which includes the following: bins, hoppers, screens, crushers,
grinders, and presses
vii. All bin vents
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.9.c.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis
while the unit is operating. The visual opacity survey shall be performed by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other
than condensed water vapor are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey.
The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A,
45
Method 9, or other EPA-approved testing method, as acceptable to the Director, for point
sources, and in accordance with 40 CFR 51 Appendix M, Method 203A, or other EPA-approved
testing method, as acceptable to the Director, for fugitive sources.

For intermittent sources, opacity observations shall be performed on a monthly basis while the
unit is operating in accordance with 40 CFR 60, Appendix A, Method 9, however, the
requirement for observations to be made at 15 second intervals over a six-minute period shall not
apply. The number of observations and the time period shall be determined by the length of the
intermittent source operation.

All partially enclosed conveyance systems shall be clearly labeled on each conveyor such that an
inspector/operator can safely identify equipment at any time.

II.B.9.c.2 Recordkeeping:

The permittee shall keep a log of the visual opacity survey(s) containing the following
information: date and time visual emissions observed, emission point location and description,
time and date of opacity test, and percent opacity. If an opacity determination is performed, a
notation of the determination will be made in the log. Records and all data required by 40 CFR
60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA-
approved testing method, as acceptable to the Director, shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.9.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The monthly VEO tracking form shows outdoor operations, dome silos, and includes comments on
what this includes and reading methods. The forms are available for review. In compliance.

II.B.10 Conditions on SOP: AH-1555 SOP Plant

II.B.10.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 2.61 lb/hr
PM2.5: 0.39 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.01 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.10.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
46
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a copy
of the test protocol. The source test protocol shall be approved by the Director prior to
performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference shall
be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or
other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5, resulting
in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing
analytical methods, such as: x-ray diffraction, scanning electron microscopy, or
electron microprobe analysis may be used to determine particle sizing, as
acceptable to the Director. The back half condensable particulate emissions shall
also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved
testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director to
give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing shall
be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the previous
12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110% of
the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is
47
successful. This process may be repeated until the maximum permitted production
rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Scrubber liquid flow rate shall be measured using a flow meter.
(b) Indicator No. 2: Fan speed shall be monitored. Either output from the variable
frequency drive (VFD) or electronic overload relay in the fan shall be monitored
and used to calculate fan speed, or a tachometer shall be used to monitor fan speed.
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as an average scrubber liquid flow rate
over a one-hour period that is less than 31 gallons per minute (gpm).
(b) Indicator No. 2: An excursion is defined as a fan speed less than 1,484 RPM
during a 24-hour period.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The scrubber liquid flow rate shall be measured using a flow
meter located on the scrubber liquid line. The scrubber liquid flow rate shall
be accurate to five (5) gpm or as approved by the Director. Flow rate meters
shall be located such that an inspector/operator can safely read the indicators
at any time.
(2) Indicator No. 2: VFDs or electronic overload relays, if used, shall be installed
in accordance with the manufacturer's recommendations and shall be located
such that an inspector/operator can safely read the output at any time. A
tachometer, if used, shall be operated according to the manufacturer's
recommendations.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The flow meter shall be calibrated according to the
manufacturer's recommendations or at least annually. The scrubber shall
operate within the liquid flow rate range recommended by the manufacturer
for normal operations. This range shall be clearly labeled on each scrubber
such that an inspector/operator can safely read the parameters at any time.
The data acquisition system shall be operated and maintained according to the
manufacturer's recommendations.
(2) Indicator No. 2: The scrubber shall operate within the fan speed range
recommended by the manufacturer for normal operations. This range shall be
clearly labeled on each scrubber such that an inspector/operator can safely
read the parameters at any time. Tachometers, if used on the scrubber, shall
be calibrated according to the manufacturer's recommendations or at least
annually.
(c) Monitoring Frequency:
(1) Indicator No. 1: The scrubber liquid flow rate shall be measured
continuously.
(2) Indicator No. 2: Fan speed shall be monitored daily. Once each day, either
output from the variable frequency drive (VFD) or electronic overload relay
in the fan shall be monitored and used to calculate fan speed, or a tachometer
shall be used to monitor fan speed.
(d) Data Collection Procedure:
48
(1) Indicator No. 1: An average scrubber liquid flow rate shall be calculated
during each hour of operation. The hourly average shall be recorded for
comparison to the excursion level.
(2) Indicator No. 2: Fan speed shall be calculated or measured each day the unit
operates. The daily fan speed shall be recorded for comparison to the
excursion level.
(e) Averaging Period:
(1) Indicator No. 1: One hour
(2) Indicator No. 2: N/A
(40 CFR 64.6(c))
C. 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.B.10.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

The permittee shall maintain a file of activities for installation of the scrubber liquid flow meter
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

II.B.10.a.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.10.a.1.C.

49
Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
AH-1555 10/21/24 5/201a PM2.5 0.0017
gr/dscf 0.01 gr/dscf
AH-1555 10/2124 5/201a PM2.5 0.21 lb/hr 0.39 lb/hr
AH-1555 10/21/24 5/201a PM10 0.21 lb/hr 2.61 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which includes flow and fan speed exceedances. The real time readings done during the test were
44.21 GPM based on two meters combined total with readings shown on shared tracking system.
Trend lines show these to be normal readings. In compliance.

II.B.11 Conditions on SOP: BH-001 SOP Bulk Load-Out Circuit

II.B.11.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 0.37 lb/hr
PM2.5: 0.37 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.01 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.11.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
50
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then
the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d,
5i, or other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5,
resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate
particle sizing analytical methods, such as: x-ray diffraction, scanning electron
microscopy, or electron microprobe analysis may be used to determine particle
sizing, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or
other EPA-approved testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous 12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Pressure drop across the baghouse shall be measured using a
differential pressure gauge.
(b) Indicator No. 2: Visible emissions from the baghouse exhaust shall be monitored
by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9.
(c) Indicator No. 3: An internal inspection of the baghouse including a dye test shall
be performed to identify damaged bags and required maintenance.
51
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as an average differential pressure
outside the range of 1 to 6 inches of water column during a 24-hour period.
(b) Indicator No. 2: An excursion is defined as the presence of visible emissions.
(c) Indicator No. 3: An excursion is defined as a failure to perform the semi-annual
baghouse internal inspection as specified below.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The differential pressure gauge shall measure pressure drop
with pressure taps located at the baghouse inlet and outlet. The minimum
accuracy of the gauge shall be +/- 0.5 inches of water column. The pressure
gauges shall be located such that an inspector/operator can safely read the
indicator at any time.
(2) Indicator No. 2: Visible emissions shall be monitored at the stack exhaust
while the baghouse is operating.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test to identify damaged bags and required maintenance.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The pressure gauge shall be calibrated according to the
manufacturer's recommendations or at least annually. Pressure taps shall be
checked for plugging monthly. Each baghouse shall operate within the static
pressure range recommended by the manufacturer for normal operations.
The static pressure range shall be clearly labeled on each baghouse such that
an inspector/operator can safely read the range at any time. The data
acquisition system shall be operated and maintained according to the
manufacturer's recommendations.
(2) Indicator No. 2: Visible emissions from the baghouse exhaust shall be
monitored by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9.
(3) Indicator No. 3: The internal baghouse inspection and dye test shall be
performed by personnel trained on proper baghouse operation and
preventive maintenance.
(c) Monitoring Frequency:
(1) Indicator No. 1: Pressure drop shall be monitored continuously.
(2) Indicator No. 2: Once each week, a visual opacity survey shall be performed
on the baghouse exhaust, while the unit is operating, by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test semi-annually to identify damaged bags and required
maintenance.
(d) Data Collection Procedure:
(1) Indicator No. 1: The average pressure drop shall be displayed each minute at
the baghouse location. Using the minute averages, the data acquisition
system shall calculate an average pressure drop each day the unit operates.
The daily average shall be recorded for comparison to the excursion level.
(2) Indicator No. 2: Results of the visual opacity survey shall be recorded each
week for comparison to the excursion level.
(3) Indicator No. 3: Results of baghouse inspections including the dye test and
documentation of any required maintenance shall be recorded semi-annually.
(e) Averaging Period:
52
(1) Indicator No. 1: 24-hour period
(2) Indicator No. 2: N/A
(3) Indicator No. 3: N/A
(40 CFR 64.6(c))
C. 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.B.11.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

The permittee shall maintain a file of activities for installation of the differential pressure gauge
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

II.B.11.a.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.11.a.1.C.

53
Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
BH-001 10/17/24 5/201a PM2.5 0.0003
gr/dscf 0.01 gr/dscf
BH-001 10/17/24 5/201a PM2.5 0.04 lb/hr 0.37 lb/hr
BH-001 10/17/24 5/201a PM10 0.12 lb/hr 0.37 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which include any Dp excursions and bag house inspection dates. The operating parameters were
being monitored during this inspection. The real time readings are reported in the general
requirements section above. In compliance.

II.B.12 Conditions on SOP: BH-002 SOP Plant

II.B.12.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 0.65 lb/hr
PM2.5: 0.47 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.01 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.12.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
54
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, 5i, or
other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5, resulting
in PM10 emissions equal to that of PM2.5. Alternatively, appropriate particle sizing
analytical methods, such as: x-ray diffraction, scanning electron microscopy, or
electron microprobe analysis may be used to determine particle sizing, as
acceptable to the Director. The back half condensable particulate emissions shall
also be tested using 40 CFR 51, Appendix M Method 202, or other EPA-approved
testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the previous
12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110% of
the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is
successful. This process may be repeated until the maximum permitted production
rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Pressure drop across the baghouse shall be measured using a
differential pressure gauge.
(b) Indicator No. 2: Visible emissions from the baghouse exhaust shall be monitored
by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9.
(c) Indicator No. 3: An internal inspection of the baghouse including a dye test shall
be performed to identify damaged bags and required maintenance.
55
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as an average differential pressure outside
the range of 1 to 5 inches of water column during a 24-hour period.
(b) Indicator No. 2: An excursion is defined as the presence of visible emissions.
(c) Indicator No. 3: An excursion is defined as a failure to perform the semi-annual
baghouse internal inspection as specified below.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The differential pressure gauge shall measure pressure drop
with pressure taps located at the baghouse inlet and outlet. The minimum
accuracy of the gauge shall be +/- 0.5 inches of water column. The pressure
gauges shall be located such that an inspector/operator can safely read the
indicator at any time.
(2) Indicator No. 2: Visible emissions shall be monitored at the stack exhaust
while the baghouse is operating.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test to identify damaged bags and required maintenance.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The pressure gauge shall be calibrated according to the
manufacturer's recommendations or at least annually. Pressure taps shall be
checked for plugging monthly. Each baghouse shall operate within the static
pressure range recommended by the manufacturer for normal operations. The
static pressure range shall be clearly labeled on each baghouse such that an
inspector/operator can safely read the range at any time. The data acquisition
system shall be operated and maintained according to the manufacturer's
recommendations.
(2) Indicator No. 2: Visible emissions from the baghouse exhaust shall be
monitored by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9.
(3) Indicator No. 3: The internal baghouse inspection and dye test shall be
performed by personnel trained on proper baghouse operation and preventive
maintenance.
(c) Monitoring Frequency:
(1) Indicator No. 1: Pressure drop shall be monitored continuously.
(2) Indicator No. 2: Once each week, a visual opacity survey shall be performed
on the baghouse exhaust, while the unit is operating, by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test semi-annually to identify damaged bags and required
maintenance.
(d) Data Collection Procedure:
(1) Indicator No. 1: The average pressure drop shall be displayed each minute at
the baghouse location. Using the minute averages, the data acquisition system
shall calculate an average pressure drop each day the unit operates. The daily
average shall be recorded for comparison to the excursion level.
(2) Indicator No. 2: Results of the visual opacity survey shall be recorded each
week for comparison to the excursion level.
(3) Indicator No. 3: Results of baghouse inspections including the dye test and
documentation of any required maintenance shall be recorded semi-annually.
(e) Averaging Period:
56
(1) Indicator No. 1: 24-hour period
(2) Indicator No. 2: N/A
(3) Indicator No. 3: N/A
(40 CFR 64.6(c))
C. 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.B.12.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

The permittee shall maintain a file of activities for installation of the differential pressure gauge
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

II.B.12.a.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.12.a.1.C.

57
Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
BH-002 10/15-16/24 5/201a PM2.5 0.0028
gr/dscf 0.01 gr/dscf
BH-002 10/15-16/24 5/201a PM2.5 0.44 lb/hr 0.47 lb/hr
BH-002 10/15-16/24 5/201a PM10 0.56 lb/hr 0.65 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which include any Dp excursions and bag house inspection dates. The operating parameters were
being monitored during this inspection. The real time readings are reported in the general
requirements section above. The 365 day stack test frequency was changed in most recent AO to
yearly in same quarter. In compliance.

II.B.13 Conditions on SOP: BH-008 SOP Plant-Compaction Dryer (D-1545)

II.B.13.a Condition:

Emissions to the atmosphere from the baghouse shall not exceed the following rates and concentrations
(standardized at 68 degrees F, 29.92 in Hg).
PM10: 4.25 lb/hr
PM2.5: 4.25 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.01 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.13.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
58
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then
the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d,
5i, or other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5,
resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate
particle sizing analytical methods, such as: x-ray diffraction, scanning electron
microscopy, or electron microprobe analysis may be used to determine particle
sizing, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or
other EPA-approved testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous 12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Pressure drop across the baghouse shall be measured using a
differential pressure gauge.
(b) Indicator No. 2: Visible emissions from the baghouse exhaust shall be monitored
by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9.
(c) Indicator No. 3: An internal inspection of the baghouse including a dye test shall
be performed to identify damaged bags and required maintenance.
59
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as an average differential pressure
outside the range of 1 to 7 inches of water column during a 24-hour period.
(b) Indicator No. 2: An excursion is defined as the presence of visible emissions.
(c) Indicator No. 3: An excursion is defined as a failure to perform the semi-annual
baghouse internal inspection as specified below.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The differential pressure gauge shall measure pressure drop
with pressure taps located at the baghouse inlet and outlet. The minimum
accuracy of the gauge shall be +/- 0.5 inches of water column. The pressure
gauges shall be located such that an inspector/operator can safely read the
indicator at any time.
(2) Indicator No. 2: Visible emissions shall be monitored at the stack exhaust
while the baghouse is operating.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test to identify damaged bags and required maintenance.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The pressure gauge shall be calibrated according to the
manufacturer's recommendations or at least annually. Pressure taps shall be
checked for plugging monthly. Each baghouse shall operate within the static
pressure range recommended by the manufacturer for normal operations.
The static pressure range shall be clearly labeled on each baghouse such that
an inspector/operator can safely read the range at any time. The data
acquisition system shall be operated and maintained according to the
manufacturer's recommendations.
(2) Indicator No. 2: Visible emissions from the baghouse exhaust shall be
monitored by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9.
(3) Indicator No. 3: The internal baghouse inspection and dye test shall be
performed by personnel trained on proper baghouse operation and
preventive maintenance.
(c) Monitoring Frequency:
(1) Indicator No. 1: Pressure drop shall be monitored continuously.
(2) Indicator No. 2: Once each week, a visual opacity survey shall be performed
on the baghouse exhaust, while the unit is operating, by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test semi-annually to identify damaged bags and required
maintenance.
(d) Data Collection Procedure:
(1) Indicator No. 1: The average pressure drop shall be displayed each minute at
the baghouse location. Using the minute averages, the data acquisition
system shall calculate an average pressure drop each day the unit operates.
The daily average shall be recorded for comparison to the excursion level.
(2) Indicator No. 2: Results of the visual opacity survey shall be recorded each
week for comparison to the excursion level.
(3) Indicator No. 3: Results of baghouse inspections including the dye test and
documentation of any required maintenance shall be recorded semi-annually.
(e) Averaging Period:
60
(1) Indicator No. 1: 24-hour period
(2) Indicator No. 2: N/A
(3) Indicator No. 3: N/A
(40 CFR 64.6(c))
C. 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.B.13.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

The permittee shall maintain a file of activities for installation of the differential pressure gauge
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

II.B.13.a.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.13.a.1.C.

61
Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
BH-008 10/21/24 201a/202 PM2.5 0.01 gr/dscf 0.01 gr/dscf
BH-008 10/21/24 201a/202 PM2.5 1.02 lb/hr 4.25 lb/hr
BH-008 10/21/24 201a/202 PM10 1.10 lb/hr 4.25 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which include any Dp excursions and bag house inspection dates. The operating parameters were
being monitored during this inspection. The real time readings are reported in the general
requirements section above. In compliance.

II.B.13.b Condition:

NOx emissions to the atmosphere from the dryer (D-1545) shall not exceed 20 ppm at 3% O2. [Origin:
DAQE-AN109170044-23]. [R307-401-8]

II.B.13.b.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested at least once every three years. The Director may
require testing at any time. If an existing source is modified, a compliance test is required
on the modified emission point that has an emission rate limit.
(b) Notification. At least 30 days prior to conducting any required emission testing, the source
shall notify the Director of the date, time, and place of testing and provide a copy of the test
protocol. The source test protocol shall be approved by the Director prior to performing the
test(s). The source test protocol shall outline the proposed test methodologies, stack to be
tested, and procedures to be used. A pretest conference shall be held, if directed by the
Director.
(c) Methods.
(i) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. An Occupational Safety and Health Administration (OSHA)
or Mine Safety and Health Administration (MSHA) approved access shall be provided
to the test location.
(ii) NOx emissions shall be determined using 40 CFR 60, Appendix A, Method 7E, or
other EPA-approved testing method, as acceptable to the Director.
(iii) 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.
(iv) Compliance with the limit shall be based on an average of 3 test runs.
(d) Calculations. To determine mass emission rates (lb/hr) the pollutant concentration as
determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director, to
give the results in the specified units of the emission limitation.
62
(e) Production Rate During Testing. The production rate during all compliance testing shall be
no less than 90% of the permitted production rate. If the maximum permitted production
rate has not been achieved at the time of the test, the following procedure shall be followed:
(i) Testing shall be at no less than 90% of the production rate achieved in the previous
three years.
(ii) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This
new allowable maximum production rate shall remain in effect until successfully tested
at a higher rate.
(iii) Testing at no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is successful.
This process may be repeated until the maximum permitted production rate is
achieved.

II.B.13.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

II.B.13.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: Stack testing was last conducted November 9, 2022. DAQ calculated results were 3.33 ppmdv
@3% O2. The next test is due in 2025. In compliance.

II.B.14 Conditions on SOP: BH-1400 SOP Dryer (D-1400)

II.B.14.a Condition:

NOx emissions to the atmosphere from the dryer (D-1400) shall not exceed 20 ppm at 3% O2. [Origin:
DAQE-AN109170044-23]. [R307-401-8]

II.B.14.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested at least once every three years. The Director may
require testing at any time. If an existing source is modified, a compliance test is required
on the modified emission point that has an emission rate limit.
(b) Notification. At least 30 days prior to conducting any required emission testing, the source
shall notify the Director of the date, time, and place of testing and provide a copy of the test
protocol. The source test protocol shall be approved by the Director prior to performing the
test(s). The source test protocol shall outline the proposed test methodologies, stack to be
tested, and procedures to be used. A pretest conference shall be held, if directed by the
Director.
(c) Methods.
(i) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing
63
method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(ii) NOx emissions shall be determined using 40 CFR 60, Appendix A, Method 7E, or
other EPA-approved testing method, as acceptable to the Director.
(iii) 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.
(iv) Compliance with the limit shall be based on an average of 3 test runs.
(d) Calculations. To determine mass emission rates (lb/hr) the pollutant concentration as
determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director, to
give the results in the specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be
no less than 90% of the permitted production rate. If the maximum permitted production
rate has not been achieved at the time of the test, the following procedure shall be followed:
(i) Testing shall be at no less than 90% of the production rate achieved in the previous
three years.
(ii) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This
new allowable maximum production rate shall remain in effect until successfully
tested at a higher rate.
(iii) Testing at no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is successful.
This process may be repeated until the maximum permitted production rate is
achieved.

II.B.14.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

II.B.14.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: Stack testing was last conducted November 16-17, 2022. DAQ calculated results were 16.0 ppmdv
@3% O2. The next test is due in 2025. In compliance.

II.B.14.b Condition:

Emissions to the atmosphere from the baghouse shall not exceed the following rates and concentrations
(standardized at 68 degrees F, 29.92 in Hg).
PM10: 2.78 lb/hr
PM2.5: 2.78 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.02 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

64
II.B.14.b.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then
the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d,
5i, or other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5,
resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate
particle sizing analytical methods, such as: x-ray diffraction, scanning electron
microscopy, or electron microprobe analysis may be used to determine particle
sizing, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or
other EPA-approved testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous 12 months (365 days).
65
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Pressure drop across the baghouse shall be measured using a
differential pressure gauge.
(b) Indicator No. 2: Visible emissions from the baghouse exhaust shall be monitored
by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9.
(c) Indicator No. 3: An internal inspection of the baghouse including a dye test shall
be performed to identify damaged bags and required maintenance.
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as an average differential pressure
outside the range of 1 to 6 inches of water column during a 24-hour period.
(b) Indicator No. 2: An excursion is defined as the presence of visible emissions.
(c) Indicator No. 3: An excursion is defined as a failure to perform the semi-annual
baghouse internal inspection as specified below.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The differential pressure gauge shall measure pressure drop
with pressure taps located at the baghouse inlet and outlet. The minimum
accuracy of the gauge shall be +/- 0.5 inches of water column. The pressure
gauges shall be located such that an inspector/operator can safely read the
indicator at any time.
(2) Indicator No. 2: Visible emissions shall be monitored at the stack exhaust
while the baghouse is operating.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test to identify damaged bags and required maintenance.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The pressure gauge shall be calibrated according to the
manufacturer's recommendations or at least annually. Pressure taps shall be
checked for plugging monthly. Each baghouse shall operate within the static
pressure range recommended by the manufacturer for normal operations.
The static pressure range shall be clearly labeled on each baghouse such that
an inspector/operator can safely read the range at any time. The data
acquisition system shall be operated and maintained according to the
manufacturer's recommendations.
(2) Indicator No. 2: Visible emissions from the baghouse exhaust shall be
monitored by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9.
(3) Indicator No. 3: The internal baghouse inspection and dye test shall be
performed by personnel trained on proper baghouse operation and
preventive maintenance.
66
(c) Monitoring Frequency:
(1) Indicator No. 1: Pressure drop shall be monitored continuously.
(2) Indicator No. 2: Once each week, a visual opacity survey shall be performed
on the baghouse exhaust, while the unit is operating, by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test semi-annually to identify damaged bags and required
maintenance.
(d) Data Collection Procedure:
(1) Indicator No. 1: The average pressure drop shall be displayed each minute at
the baghouse location. Using the minute averages, the data acquisition
system shall calculate an average pressure drop each day the unit operates.
The daily average shall be recorded for comparison to the excursion level.
(2) Indicator No. 2: Results of the visual opacity survey shall be recorded each
week for comparison to the excursion level.
(3) Indicator No. 3: Results of baghouse inspections including the dye test and
documentation of any required maintenance shall be recorded semi-annually.
(e) Averaging Period:
(1) Indicator No. 1: 24-hour period
(2) Indicator No. 2: N/A
(3) Indicator No. 3: N/A
(40 CFR 64.6(c))
C. 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.B.14.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

The permittee shall maintain a file of activities for installation of the differential pressure gauge
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator range and excursion levels. The permittee shall maintain
records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

67
II.B.14.b.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.14.b.1.C.

Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
BH-1400 10/16/24 201a/202 PM2.5 0.006 gr/dscf 0.02 gr/dscf
BH-1400 10/16/24 201a/202 PM2.5 0.82 lb/hr 2.78 lb/hr
BH-1400 10/16/24 201a/202 PM10 10.6 lb/hr 2.78 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which include any Dp excursions and bag house inspection dates. The operating parameters were
being monitored during this inspection. The real time readings are reported in the general
requirements section above. In compliance.

II.B.15 Conditions on SOP: BH-1516 SOP Plant

II.B.15.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 1.46 lb/hr
PM2.5: 0.22 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.01 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.15.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
68
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then
the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d,
5i, or other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5,
resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate
particle sizing analytical methods, such as: x-ray diffraction, scanning electron
microscopy, or electron microprobe analysis may be used to determine particle
sizing, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or
other EPA-approved testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on the average of three test runs and
shall include both filterable and condensable emissions.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr) the pollutant concentration as
determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous 12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
69
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.
B. At all times the affected emission unit is operating, the following indicators shall be
monitored as specified below and as approved by the Director.
i) Measurement Approach
(a) Indicator No. 1: Pressure drop across the baghouse shall be measured using a
differential pressure gauge.
(b) Indicator No. 2: Visible emissions from the baghouse exhaust shall be monitored
by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9.
(c) Indicator No. 3: An internal inspection of the baghouse including a dye test shall
be performed to identify damaged bags and required maintenance.
ii) Indicator Range: Excursions are defined as follows. Each excursion triggers an
inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as an average differential pressure
outside the range of 1 to 6 inches of water column during a 24-hour period.
(b) Indicator No. 2: An excursion is defined as the presence of visible emissions.
(c) Indicator No. 3: An excursion is defined as a failure to perform the semi-annual
baghouse internal inspection as specified below.
iii) Performance Criteria
(a) Data Representativeness:
(1) Indicator No. 1: The differential pressure gauge shall measure pressure drop
with pressure taps located at the baghouse inlet and outlet. The minimum
accuracy of the gauge shall be +/- 0.5 inches of water column. The pressure
gauges shall be located such that an inspector/operator can safely read the
indicator at any time.
(2) Indicator No. 2: Visible emissions shall be monitored at the stack exhaust
while the baghouse is operating.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test to identify damaged bags and required maintenance.
(b) QA/QC Practices and Criteria:
(1) Indicator No. 1: The pressure gauge shall be calibrated according to the
manufacturer's recommendations or at least annually. Pressure taps shall be
checked for plugging monthly. Each baghouse shall operate within the static
pressure range recommended by the manufacturer for normal operations.
The static pressure range shall be clearly labeled on each baghouse such that
an inspector/operator can safely read the range at any time. The data
acquisition system shall be operated and maintained according to the
manufacturer's recommendations.
(2) Indicator No. 2: Visible emissions from the baghouse exhaust shall be
monitored by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9.
(3) Indicator No. 3: The internal baghouse inspection and dye test shall be
performed by personnel trained on proper baghouse operation and
preventive maintenance.
(c) Monitoring Frequency:
(1) Indicator No. 1: Pressure drop shall be monitored continuously.
70
(2) Indicator No. 2: Once each week, a visual opacity survey shall be performed
on the baghouse exhaust, while the unit is operating, by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9.
(3) Indicator No. 3: The permittee shall conduct an internal baghouse inspection
including a dye test semi-annually to identify damaged bags and required
maintenance.
(d) Data Collection Procedure:
(1) Indicator No. 1: The average pressure drop shall be displayed each minute at
the baghouse location. Using the minute averages, the data acquisition
system shall calculate an average pressure drop each day the unit operates.
The daily average shall be recorded for comparison to the excursion level.
(2) Indicator No. 2: Results of the visual opacity survey shall be recorded each
week for comparison to the excursion level.
(3) Indicator No. 3: Results of baghouse inspections including the dye test and
documentation of any required maintenance shall be recorded semi-annually.
(e) Averaging Period:
(1) Indicator No. 1: 24-hour period
(2) Indicator No. 2: N/A
(3) Indicator No. 3: N/A
(40 CFR 64.6(c))
C. 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.B.15.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

The permittee shall maintain a file of activities for installation of the differential pressure gauge
and data acquisition system. The permittee shall maintain records of test data from the most
recent stack test and any calculations used to establish, evaluate, or revise the indicator ranges
and excursion levels.

The permittee shall keep copies of Director approval of the monitoring including, but not limited
to, the most recently approved indicator ranges and excursion levels. The permittee shall
maintain records of all verifications, calibration checks, adjustments and maintenance.

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 monitoring
maintenance or corrective actions).

Records and results of monitoring shall be maintained in accordance with 40 CFR 64.9(b) and
Provision I.S.1 of this permit.

71
II.B.15.a.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit,
(a) Monitoring reports shall include, at a minimum, the following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions
taken; (40 CFR 64.9(a)(2)(i))
(ii) 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). (40 CFR 64.9(a)(2)(ii))
(b) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. Reports shall include test data and any calculations used to evaluate or
revise the indicator ranges and excursion levels as specified in II.B.15.a.1.C.

Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
BH-1516 10/15-16/24 201a/202 PM2.5 0.0013
gr/dscf 0.01 gr/dscf
BH-1516 10/15-16/24 201a/202 PM2.5 0.05 lb/hr 0.22 lb/hr
BH-1516 10/15-16/24 201a/202 PM10 0.06 lb/hr 1.46 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which include any Dp excursions and bag house inspection dates. The operating parameters were
being monitored during this inspection. The real time readings are reported in the general
requirements section above. In compliance.

II.B.16 Conditions on SOP: Fully Enclosed Conveyors

II.B.16.a Condition:

Visible emissions from all outdoor fully-enclosed conveyance systems shall not exceed 5% opacity. At
all times, the permittee shall operate and maintain each affected emission unit as a fully-enclosed
conveyance system. Each fully-enclosed conveyance system shall be fully-enclosed on all sides, top, and
bottom. All fully-enclosed conveyance systems shall be clearly labeled on each conveyor such that an
inspector/operator can safely identify equipment at any time. [Origin: DAQE-AN109170044-23]. [R307-
401-8]

II.B.16.a.1 Monitoring:

The permittee shall conduct a Method 22 performance test, or other EPA-approved testing
method, as acceptable to the Director, according to the following requirements for each affected
emission unit.
72
(a) Conduct a weekly 10-minute visible emissions test of each affected emission unit in
accordance with Method 22 of 40 CFR 60 Appendix A, or other EPA-approved testing
method, as acceptable to the Director. The performance test shall be conducted while the
unit is in operation.
(b) If any visible emissions are observed from an emission unit, the permittee shall inspect the
affected emission unit to determine the cause of visible emissions and initiate corrective
action within one hour of the initial survey.
(c) If no visible emissions are observed during four consecutive weekly tests, the permittee may
decrease the frequency of the visible emissions test required in paragraph (a) from weekly
to monthly. If visible emissions are observed during any monthly test, the permittee shall
resume the weekly visible emissions test required in paragraph (a) and maintain that
schedule until no visible emissions are observed in four (4) consecutive weekly tests.

II.B.16.a.2 Recordkeeping:

The permittee shall keep a log of the visible emissions tests that contains the following
information: time and date of test, emission point location and description, time of visible
emissions, if observed, results of inspections, time and date corrective actions initiated, and
corrective actions taken. Records and all data required by 40 CFR 60, Appendix A, Method 22,
or other EPA-approved testing method, as acceptable to the Director, shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.16.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: These units are included on the monthly VEO tracking forms. See section above for specific status:
In compliance.

II.B.17 Conditions on MgCl: MgCl Production Plant

II.B.17.a Condition:

The following production limits shall not be exceeded:
i. 1,000,000 tons of magnesium chloride liquid produced from ponds per rolling 12-month period
ii. 70,080 tons of magnesium chloride flake produced per rolling 12-month period
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.17.a.1 Monitoring:

The permittee shall demonstrate compliance with the rolling 12-month total for each production
limit. The permittee shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months.

II.B.17.a.2 Recordkeeping:

Records of production shall be kept daily for all periods when the plant is in operation.
Production records shall be determined by examination of sales, billing records or operation
logs. Records and results of monitoring shall be maintained in accordance with Provision I.S.1 of
this permit.
73
II.B.17.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Records are kept in a spreadsheet which shows monthly and twelve-month totals. Review of
spreadsheet shows correct calculations. The 12-month totals as of April 30, 2025, were: 349,519
tons MgCl liquid and 8,527 tons of MgCl flake. In compliance.

II.B.17.b Condition:

Visible emissions from the following outdoor operations and equipment shall not exceed 10% opacity:
i. All loading operations
ii. All conveyor drop points
iii. All conveyor transfer points
iv. All storage piles
v. All partially enclosed conveyance systems
vi. All material handling operations which includes the following: bins, hoppers, screens, crushers,
grinders, and presses
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.17.b.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis
while the unit is operating. The visual opacity survey shall be performed by an individual trained
on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other
than condensed water vapor are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial survey.
The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A,
Method 9, or other EPA-approved testing method, as acceptable to the Director, for point
sources, and in accordance with 40 CFR 51 Appendix M, Method 203A, or other EPA-approved
testing method, as acceptable to the Director, for fugitive sources.

For intermittent sources, opacity observations shall be performed on a monthly basis while the
unit is operating in accordance with 40 CFR 60, Appendix A, Method 9, however, the
requirement for observations to be made at 15 second intervals over a six-minute period shall not
apply. The number of observations and the time period shall be determined by the length of the
intermittent source operation.

II.B.17.b.2 Recordkeeping:

The permittee shall keep a log of the visual opacity survey(s) containing the following
information: date and time visual emissions observed, emission point location and description,
time and date of opacity test, and percent opacity. If an opacity determination is performed, a
notation of the determination will be made in the log. Records and all data required by 40 CFR
60, Appendix A, Method 9 and/or 40 CFR 51 Appendix M, Method 203A, or other EPA-
approved testing method, as acceptable to the Director, shall be maintained in accordance with
Provision I.S.1 of this permit.

74
II.B.17.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: These units are included on the monthly VEO tracking forms. See section above for specific status:
In compliance.

II.B.18 Conditions on MgCl: AH-692 Magnesium Chloride Plant

II.B.18.a Condition:

Emissions to the atmosphere shall not exceed the following rates and concentrations (standardized at 68
degrees F, 29.92 in Hg).
PM10: 0.15 lb/hr
PM2.5: 0.12 lb/hr [State-only Requirement]
PM2.5 Concentration: 0.01 grains/dscf [State-only Requirement]
Process emissions shall be routed through operating controls prior to being emitted to the atmosphere.
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.18.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every calendar year and in the same
calendar quarter in which the most recent stack test was performed. The Director may
require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Method 201a, or other EPA-approved testing
method, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M, Method 202, or
other EPA-approved testing method as acceptable to the Director.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then
the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d,
5i, or other EPA approved testing methods, as acceptable to the Director. When
demonstrating compliance with the PM10 and PM2.5 limits above, all filterable
particulate emissions captured using Method 5 shall be considered PM2.5,
75
resulting in PM10 emissions equal to that of PM2.5. Alternatively, appropriate
particle sizing analytical methods, such as: x-ray diffraction, scanning electron
microscopy, or electron microprobe analysis may be used to determine particle
sizing, as acceptable to the Director. The back half condensable particulate
emissions shall also be tested using 40 CFR 51, Appendix M Method 202, or
other EPA-approved testing method as acceptable to the Director.
(c) Compliance with the limits shall be based on an average of three (3) test runs and
shall include both filterable and condensable emissions.
(d) Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2, or other EPA-
approved testing method, as acceptable to the Director.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous 12 months (365 days).
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.

II.B.18.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

II.B.18.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

76
Status: Stack testing was reported in DAQC 025-25.

Source Test Date Test
Method Pollutant DAQ Results Limits
AH-692 10/23/24 5/201a PM2.5 0.0002
gr/dscf 0.01 gr/dscf
AH-692 10/23/24 5/201a PM2.5 0.01 lb/hr 0.12 lb/hr
AH-692 10/23/24 5/201a PM10 0.01 lb/hr 0.15 lb/hr

CAM has been performed as required and is reviewed through semi-annual summary reports,
which includes flow and fan speed exceedances. The real time readings done during the inspection
were 108.50 GPM and 7.62 Dp with readings shown on shared tracking system. Trend lines show
these to be normal readings. In compliance.

II.B.18.b Condition:

The venturi wet scrubber shall operate within the static pressure range and liquid flow rate recommended
by the manufacturer for normal operations. These parameters shall be clearly labeled on the scrubber
such that an inspector/operator can safely read the parameters at any time. [Origin: DAQE-
AN109170044-23]. [R307-401-8]

II.B.18.b.1 Monitoring:

a) Manometer or magnehelic pressure gauges shall be installed to measure the differential
pressure across the wet scrubber.
b) Flow rate meters shall be installed to measure the liquid flow rate in the scrubber.
c) The pressure gauges and flow rate meters shall be located such that an inspector/operator can
safely read the indicators at any time.
d) The gauges and meters shall be calibrated in accordance with the manufacturer's instructions
or recommendations at least once every 12 months.
Records required for this permit condition will also serve as monitoring.

II.B.18.b.2 Recordkeeping:

a) Pressure drop and liquid flow rate readings from the venturi wet scrubber shall be recorded at
least once during each day of operation.
b) Records documenting these inspections shall be kept in a log and shall include the following:
i. Unit identification;
ii. Manufacturer recommended pressure drop and liquid flow rate for the unit;
iii. Daily pressure drop readings;
iv. Daily liquid flow rate readings.
c) Documentation of calibrations shall be maintained for all periods the plant is in operation.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

77
II.B.18.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: CAM has been performed as required and is reviewed through semi-annual summary reports,
which includes flow and fan speed exceedances. The real time readings done during the records
virtual meeting were 108.50 GPM and 7.62 Dp with readings shown on shared tracking system.
Trend lines show these to be normal readings. In compliance.

II.B.19 Conditions on Magnesium Chloride Evaporators

II.B.19.a Condition:

Combined emissions to the atmosphere from each set of two evaporators shall not exceed the following
rate.
VOC: 6.18 lb/hr [State-only Requirement]
[Origin: DAQE-AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.19.a.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every three years. Compliance
testing shall be performed at least once every three (3) years for each train of the
magnesium chloride evaporators. The Director may require testing at any time. If an
existing source is modified, a compliance test is required on the modified emission
point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - The emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) VOC emissions shall be determined using 40 CFR 60, Appendix A, Method 25A
using a flame ionization analyzer equipped with a methane separator. If such an
analyzer is unavailable, VOC emissions shall be determined simultaneously using
two analyzers, with one configured to read only methane. The difference between
the total organic detector and the methane detector shall constitute the VOC
measurement.
(c) Compliance with the limit shall be based on the average of three test runs.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
78
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous three years.
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.

II.B.19.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

II.B.19.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: Stack testing was last conducted November 21, 2022 (South Evaporator), and November 17-18,
2022 (North Evaporator). DAQ calculated results were 1.33 lbs/hr South unit combined and 1.40
lbs/hr North unit combined. The next test is due in 2025. In compliance.

II.B.19.b Condition:

Combined emissions to the atmosphere from each set of two evaporators shall not exceed the following
rate.
HCl: 6.40 lb/hr
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.19.b.1 Monitoring:

A. Stack testing shall be performed as specified below:
i) Frequency. Emissions shall be tested at least once every three years. Compliance
testing shall be performed at least once every three (3) years for each train of the
magnesium chloride evaporators. The Director may require testing at any time. If an
existing source is modified, a compliance test is required on the modified emission
point that has an emission rate limit.
ii) Notification. At least 30 days prior to conducting any required emission testing, the
source shall notify the Director of the date, time, and place of testing and provide a
copy of the test protocol. The source test protocol shall be approved by the Director
79
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Director.
iii) Methods.
(a) Sample Location - The emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(b) HCl emissions shall be determined using 40 CFR 60, Appendix A, Method 26, or
26A or other EPA-approved testing method, acceptable to the Director.
(c) Compliance with the limit shall be based on the average of three test runs.
(d) 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.
iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration
as determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director
to give the results in the specified units of the emission limitation.
v) Production Rate During Testing. The production rate during all compliance testing
shall be no less than 90% of the permitted production rate. If the maximum permitted
production rate has not been achieved at the time of the test, the following procedure
shall be followed:
(a) Testing shall be at no less than 90% of the production rate achieved in the
previous three years.
(b) If the test is passed, the new maximum allowable production rate shall be 110%
of the tested achieved rate, but not more than the maximum allowable production
rate. This new allowable maximum production rate shall remain in effect until
successfully tested at a higher rate.
(c) Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum permitted
production rate is achieved.

II.B.19.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

II.B.19.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: Stack testing was last conducted November 21, 2022 (South Evaporator), and November 17-18,
2022 (North Evaporator). DAQ calculated results were 0.56 lbs/hr South unit combined and 2.24
lbs/hr North unit combined. The next test is due in 2025. In compliance.

80
II.B.19.c Condition:

The permittee shall not exceed 8,760 hours of operation combined from the two sets of evaporators per
rolling 12-month period. With the exception of periods of startup, shutdown and maintenance, the
permittee shall only operate one set of two evaporators at any one time. Steam cleaning operations,
where no chlorine is being added to the evaporators, are not considered part of this operational limit.
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.19.c.1 Monitoring:

The permittee shall demonstrate compliance with the rolling 12-month total by tracking the
hours of operation for each set of evaporators. The permittee shall calculate a new 12-month
total by the 20th day of each month using data from the previous 12 months.

II.B.19.c.2 Recordkeeping:

Records of the hours of operation shall be kept daily for all periods when the plant is in
operation. Records shall include startup, steady-state, and shutdown operational times. Records
and results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.19.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The 12-month rolling total as of April 30, 2025, was 4,125 hours. Hours are tracked on
spreadsheet. Review of spreadsheet shows formulas are correct. Normal operation is one unit runs
with the other in standby. In compliance.

II.B.20 Conditions on Boilers: Natural Gas-fired Boilers

II.B.20.a Condition:

NOx emissions to the atmosphere from each of the two boilers on site shall not exceed the following
rates and concentrations: 1.30 pounds per hour and 9.0 ppm. [State-only Requirement] [Origin: DAQE-
AN109170044-23, SIP Section IX.H.12.e]. [R307-401-8]

II.B.20.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested on each boiler at least once every calendar year and in
the same calendar quarter in which the most recent stack test was performed. The Director
may require testing at any time. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
(b) Notification. At least 30 days prior to conducting any required emission testing, the source
shall notify the Director of the date, time, and place of testing and provide a copy of the test
protocol. The source test protocol shall be approved by the Director prior to performing the
test(s). The source test protocol shall outline the proposed test methodologies, stack to be
tested, and procedures to be used. A pretest conference shall be held, if directed by the
Director.
(c) Methods.
81
(i) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing
method, as acceptable to the Director. An Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(ii) NOx emissions shall be determined using 40 CFR 60, Appendix A, Method 7E, or
other EPA-approved testing method, as acceptable to the Director.
(iii) Compliance with the limits shall be based on the average of three test runs.
(iv) 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.
(d) Calculations. To determine mass emission rates (lb/hr) the pollutant concentration as
determined by the appropriate methods specified herein shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the Director, to
give the results in the specified units of the emission limitation.
(e) Production Rate During Testing. The production rate during all compliance testing shall be
no less than 90% of the permitted production rate. If the maximum permitted production
rate has not been achieved at the time of the test, the following procedure shall be followed:
(i) Testing shall be at no less than 90% of the production rate achieved in the previous 12
months (365 days).
(ii) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This
new allowable maximum production rate shall remain in effect until successfully
tested at a higher rate.
(iii) Testing at no less than 90% of the higher rate shall be conducted. A new maximum
production rate (110% of the new rate) will then be allowed if the test is successful.
This process may be repeated until the maximum permitted production rate is
achieved.

II.B.20.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

II.B.20.a.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: Stack testing was last conducted October 23 (Boiler 1) and October 17 (Boiler 2) 2024, as part of
RATA. Review is pending. In compliance.

II.B.20.b Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN109170044-23].
[R307-401-8]

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II.B.20.b.1 Monitoring:

In lieu of monitoring via visible emission observations, records required for this permit condition
will serve as monitoring.

II.B.20.b.2 Recordkeeping:

Records shall be kept for any period that a fuel other than pipeline quality natural gas is used in
the affected emission unit. The records shall be recorded in a log that is kept in a readily
accessible location onsite. All records shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.20.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Natural gas is the only fuel used in the boilers. No other connections were noted. Logs show NG
use. VEO of unit two was done during inspection with 0 percent observation. In compliance.

II.B.20.c Condition:

Only pipeline quality natural gas with a potential SO2 emission rate of 0.32 lb/MMBtu (140 ng/J) heat
input or less shall be used as fuel for the boilers. [Origin: 40 CFR 60 Subpart Db]. [40 CFR
60.42b(k)(2)]

II.B.20.c.1 Monitoring:

Records required for this permit condition will serve as monitoring. [40 CFR 60.45b(j), 40 CFR
60.45b(k), 40 CFR 60.47b(f)]

II.B.20.c.2 Recordkeeping:

The permittee shall either:
(a) Obtain and maintain on site fuel receipts (such as a current, valid purchase contract, tariff
sheet, or transportation contract) from the fuel supplier that certify that the gaseous fuel
meets the definition of natural gas as defined in 40 CFR 60.41b and the applicable sulfur
limit; or
(b) Develop a site-specific fuel analysis plan for review and approval. Each fuel analysis plan
shall include a minimum initial requirement of weekly testing and each analysis report shall
contain, at a minimum, the information required in 40 CFR 60.49b(r).
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.20.c.3 Reporting:

The permittee shall submit either:
(a) Reports certifying that only natural gas as specified in 40 CFR 60.49b(r) was combusted in
the boilers during the reporting period; or
(b) A site-specific fuel analysis plan as specified in 40 CFR 60.49b(r) for review and approval
no later than 60 days before the compliance demonstration date.
83
There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: Natural gas records are kept, and the tariff sheet is available from the gas provider. In compliance.

II.B.20.d Condition:

At all times, including periods of startup, shutdown, or malfunction, emissions of NOx (expressed as
NO2) shall be no greater than 0.20 lb/MMBtu (86 ng/J) heat input in any gases discharged into the
atmosphere from each boiler. [Origin: 40 CFR 60 Subpart Db]. [40 CFR 60.44b(a), 40 CFR 60.44b(h)]

II.B.20.d.1 Monitoring:

The permittee shall install, calibrate, maintain, and operate a CEMS for measuring NOx and O2
(or CO2) emissions discharged to the atmosphere in accordance with 40 CFR 60.48b(e) and
R307-170 and shall record the output of the system. The CEMS shall be operated and data
recorded during all periods of operation except for CEMS breakdowns and repairs. Data shall be
recorded during calibration checks, and zero and span adjustments. When NOx emission data are
not obtained because of CEMS breakdowns, repairs, calibration checks and zero and span
adjustments, emission data shall be obtained in accordance with 40 CFR 48b(f).

The 1-hour average NOx emission rates measured by the continuous NOx monitor shall be
expressed in ng/J or lb/MMBtu heat input and shall be used to calculate the average emission
rates in accordance with 40 CFR 60.48b(d). The procedures under 40 CFR 60.13 shall be
followed for installation, evaluation, and operation of the continuous monitoring system in
accordance with 40 CFR 60.48b(e).

Compliance with the emission limits shall be determined on a 30-day rolling average basis.

The permittee shall upon request determine compliance with the NOX standards through the use
of a 30-day performance test. During periods when performance tests are not requested, NOX
emissions data collected pursuant to 40 CFR 60.48b(g)(1) shall be used to calculate a 30-day
rolling average emission rate on a daily basis and used to prepare excess emission reports, but
will not be used to determine compliance with the NOX emission standards. A new 30-day
rolling average emission rate shall be calculated each steam generating unit operating day as the
average of all of the hourly NOX emission data for the preceding 30 steam generating unit
operating days.

II.B.20.d.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit and R307-170.
Additionally, the permittee shall record and maintain records as specified in 40 CFR 60.49b(d)
and (g).

II.B.20.d.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the notification and reporting requirements specified in 40 CFR 60.49b(h), (i), (v), and (w).

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. The reports are considered prompt notification of permit deviation required in
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Provision I.S.2.c of this permit, if all information required by Provision I.S.2.c is included in the
report.

Status: CEMs units are installed on both boilers. Quarterly reports are submitted and reviewed by DAQ
staff. These reports and reviews are in the main source files. In compliance.

II.B.20.e Condition:

The permittee shall conduct a tune-up of each affected emission unit as specified in 40 CFR 63.7540.
[Origin: 40 CFR 63 Subpart DDDDD]. [40 CFR 63.7500(a), 40 CFR 63.7500(e), 40 CFR 63 Subpart
DDDDD Table 3]

II.B.20.e.1 Monitoring:

The permittee shall demonstrate continuous compliance as specified in 40 CFR 63.7540(a)(10).

The permittee shall conduct a tune-up of each affected emission unit every 5 years as specified
in 40 CFR 63.7540(a)(10)(i)-(vi) to demonstrate continuous compliance. Each 5-year tune-up
shall be conducted no more than 61 months after the previous tune-up. Burner inspection may be
delayed until the next scheduled or unscheduled unit shutdown but the permittee shall inspect
each burner at least once every 72 months. The permittee shall set the oxygen level no lower
than the oxygen concentration measured during the most recent tune-up. If the unit is not
operating on the required date for a tune-up, the tune-up shall be conducted within 30 calendar
days of startup.
[40 CFR 63.7515(d), 40 CFR 63.7540(a)(10), 40 CFR 63.7540(a)(12), 40 CFR 63.7540(a)(13)].

II.B.20.e.2 Recordkeeping:

Records shall be kept as specified in 40 CFR 63.7555. All records shall be maintained in
accordance with 40 CFR 63.7560 and Provision I.S.1 of this permit.

II.B.20.e.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the notification and reporting requirements specified in 40 CFR 63.7495(d), 40 CFR
63.7545(a), and 40 CFR 63.7550. [40 CFR 63 Subpart DDDDD Table 9].

Status: The tune up was done on April 26, 2022, for both boilers. Next tune up is due in 2027. In
compliance.

II.B.20.f Condition:

At all times, the permittee shall operate and maintain each affected emission unit, including associated
air pollution control equipment and monitoring equipment, in a manner consistent with safety and good
air pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance procedures are being used will be based on information available to the Director that may
include, but is not limited to, monitoring results, review of operation and maintenance procedures,
review of operation and maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart
DDDDD]. [40 CFR 63.7500(a)(3)]

85
II.B.20.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.20.f.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be kept as specified in 40 CFR 63.7555(d)(7) and maintained in accordance with
40 CFR 63.7560 and Provision I.S.1 of this permit.

II.B.20.f.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.7550.

Status: The units appeared to be operating properly at the time of the inspection. Maintenance records are
kept, and reports are submitted. In compliance.

II.B.21 Conditions on ENGINES-D: Diesel-Fired Emergency Generators

II.B.21.a Condition:

Visible emissions shall be no greater than 20 percent opacity. [Origin: DAQE-AN109170044-23].
[R307-305-3, R307-401-8]

II.B.21.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a quarterly basis
while the unit is operating by an individual trained on the observation procedures of 40 CFR 60,
Appendix A, Method 9. If visible emissions other than steam are observed from an emission
unit, a 6-minute opacity determination of that emission unit shall be performed by a certified
observer within 1 hour of the initial survey. The opacity determination shall be performed while
the unit is operating in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-
approved testing method, as acceptable to the Director. If the generator(s) continue to operate on
consecutive days following the initial observation, a 6-minute opacity determination shall be
performed by a certified observer on a daily basis, while the unit is operating, in accordance with
40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the
Director.

II.B.21.a.2 Recordkeeping:

The permittee shall keep a log of the visual opacity survey(s) containing the following
information: date and time visual emissions observed, emission point location and description,
time and date of opacity test, and percent opacity. If an opacity determination is performed, a
notation of the determination will be made in the log. Records and all data required by 40 CFR
60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director,
shall be maintained in accordance with Provision I.S.1 of this permit.

86
II.B.21.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Logs are kept of VEOs and if follow on readings are required. All required information is included
on the forms. In compliance.

II.B.21.b Condition:

For the 235 hp emergency generator:
The permittee shall comply with the following at all times.
1. The permittee shall operate the emergency affected emission unit according to the requirements in
paragraphs 1.a through 1.c. In order for the engine to be considered an emergency stationary RICE
under 40 CFR 63 Subpart ZZZZ, any operation other than as described in 40 CFR 63.6640(f) is
prohibited. If the engine is not operated according to the requirements in 40 CFR 63.6640(f), it will
not be considered an emergency engine and shall meet all requirements for non-emergency engines.
a. There is no time limit on the use of emergency stationary RICE in emergency situations.
b. Emergency stationary RICE may be operated for the purpose specified in 40 CFR
63.6640(f)(2)(i) for a maximum of 100 hours per calendar year. Any operation for non-
emergency situations as allowed by 40 CFR 63.6640(f)(3) counts as part of the 100 hours per
calendar year allowed by this paragraph.
(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
authority and transmission operator, or the insurance company associated with the engine. A
petition for approval of additional hours to be used for maintenance checks and readiness
testing is not required if the permittee maintains records indicating that federal, state, or
local standards require maintenance and testing of emergency RICE beyond 100 hours per
calendar year.
c. The permittee may operate the affected emission unit up to 50 hours per calendar year in non-
emergency situations as specified in 40 CFR 63.6640(f)(3).
2. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 500 hours of operation or annually, whichever comes first;
b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and
replace as necessary;
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup the permittee shall minimize the engine's time spent at idle and minimize
the engine's startup time to a period needed for appropriate and safe loading of the engine, not to
exceed 30 minutes, after which time the non-startup emission limitations apply.
3. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
[Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6602, 40 CFR 63.6605(a), 40 CFR 63.6625(h), 40 CFR
63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2c, 40 CFR 63 Subpart ZZZZ Table 8]

II.B.21.b.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed. [40 CFR
63.6625(f)]

87
If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the work practice requirements on the required schedule or if
performing the work practice on the required schedule would otherwise pose an unacceptable
risk under federal, state, or local law, the work practice can be delayed until the emergency is
over or the unacceptable risk under federal, state, or local law has abated. The work practice
shall be performed as soon as practicable after the emergency has ended or the unacceptable risk
under federal, state, or local law has abated. [40 CFR 63 Subpart ZZZZ Table 2c Footnote 1]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and
operation of the engine in a manner consistent with good air pollution control practice for
minimizing emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ
Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(i).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.21.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep the records required in 40 CFR 63.6655(f).

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that federal, state, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per calendar year. [40 CFR 63.6640(f)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

88
II.B.21.b.3 Reporting:

The permittee shall report any failure to perform the work practice on the schedule required and
the federal, state or local law under which the risk was deemed unacceptable. [40 CFR 63
Subpart ZZZZ Table 2c Footnote 1]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665] The permittee shall also
report each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: The unit is listed as GN-007 and operates for emergency use only. All maintenance activities are
completed, and hours are based on non-resettable meter. Use log shows 12-month total as 10 hours
as of April 30, 2025. Last PM was done in May 2025 and list all required items. In compliance.

II.B.21.c Condition:

For the 235 hp emergency generator:
At all times the permittee shall operate and maintain the affected emission unit, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation 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, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR
63.6605(b)]

II.B.21.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.21.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)] The permittee shall document activities performed to assure proper operation
and maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and
Provision I.S.1 of this permit.

II.B.21.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The unit appears to be in good condition and maintenance records show all required and
preventative maintenance is performed. In compliance.

89
II.B.21.d Condition:

For the 610 hp emergency fire pump engine:
Affected emission units with a displacement of less than 30 liters per cylinder shall comply with the
emission standards in Table 4 of 40 CFR 60 Subpart IIII, for all pollutants. If the permittee conducts
performance tests in-use on emergency stationary CI ICE with a displacement of less than 30 liters per
cylinder they shall meet the not-to-exceed (NTE) standards as indicated in 40 CFR 60.4212. [Origin: 40
CFR 60 Subpart IIII]. [40 CFR 60.4205(c), 40 CFR 60.4205(e), 40 CFR 63 Subpart ZZZZ]

II.B.21.d.1 Monitoring:

For affected emission units that are manufactured during or after the applicable model years for
fire pump engine power rating in Table 3 of 40 CFR 60 Subpart IIII, the permittee shall comply
by purchasing an engine certified to the emission standards in 40 CFR 60.4205(c) for the same
model year and maximum (or in the case of fire pumps, NFPA nameplate) engine power. The
engine must be installed and configured according to the manufacturer's emission-related
specifications, except as permitted below. (Origin: 40 CFR 60.4211(c))

If the permittee does not install, configure, operate, and maintain affected emission units and
control devices according to the manufacturer's emission-related written instructions, or changes
emission-related settings in a way that is not permitted by the manufacturer, the permittee shall
demonstrate compliance as follows:
(a) For affected emission units greater than 500 HP:
i. Keep a maintenance plan and records of conducted maintenance; and
ii. To the extent practicable, maintain and operate the engine in a manner consistent with
good air pollution control practice for minimizing emissions; and
iii. Conduct an initial performance test to demonstrate compliance with the applicable
emission standards within 1 year of startup, or within 1 year after an engine and control
device is no longer installed, configured, operated, and maintained in accordance with
the manufacturer's emission-related written instructions, or within 1 year after changing
emission-related settings in a way that is not permitted by the manufacturer. The
permittee shall conduct subsequent performance testing every 8,760 hours of engine
operation or 3 years, whichever comes first, thereafter to demonstrate compliance with
the applicable emission standards.
(Origin: 40 CFR 60.4211(g)).

II.B.21.d.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.21.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: This is listed as GN-100. A certificate was on site. Maintenance records show all required and
preventative maintenance is performed. The manufacturer’s requirements are met. Total hours as
of April 30, 2025, were 14 and last PM was done in September 2024 and had all required items. In
compliance.

90
II.B.21.e Condition:

For the 402 hp and 161 hp emergency engines:
The permittee shall comply with paragraphs (1) through (2).
(1) After December 31, 2008, the permittee shall not install affected emission units (excluding fire
pump engines) that do not meet the applicable requirements for 2007 model year engines.
(2) The permittee shall not import affected emission units with a displacement of less than 30 liters per
cylinder that do not meet the applicable requirements specified in paragraphs (1) of this condition
after the date specified in paragraphs (1) of this condition.
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4208, 40 CFR 63 Subpart ZZZZ]

II.B.21.e.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.21.e.2 Recordkeeping:

The permittee shall keep records of the install date of each affected emission unit and the
applicable requirements under 40 CFR 60 Subpart IIII for the respective model year engine.
Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.21.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: These are listed as GN-1200 402 hp and GN01300 161 hp. A certificate was on site. Maintenance
records show all required and preventative maintenance is performed. The manufacturer’s
requirements are met. Total hours as of April 30, 2025, were 117 (Gn1200) and 31 (Gn-1300) and
last PMs were done in March 2025 for both units. In compliance.

II.B.21.f Condition:

For the 402 hp and 161 hp emergency engines:
2007 model year and later emergency affected emission units with a displacement of less than 30 liters
per cylinder that are not fire pump engines shall comply with the emission standards for new nonroad CI
ICE in 40 CFR 60.4202, for all pollutants, for the same model year and maximum engine power for their
2007 model year and later emergency stationary CI ICE. If the permittee conducts performance tests in-
use on emergency stationary CI ICE with a displacement of less than 30 liters per cylinder they shall
meet the not-to-exceed (NTE) standards as indicated in 40 CFR 60.4212. [Origin: 40 CFR 60 Subpart
IIII]. [40 CFR 60.4205(b), 40 CFR 60.4205(e), 40 CFR 63 Subpart ZZZZ]

II.B.21.f.1 Monitoring:

The permittee shall comply by purchasing an engine certified to the emission standards in 40
CFR 60.4205(b) for the same model year and maximum engine power. The engine must be
installed and configured according to the manufacturer's emission-related specifications, except
as permitted below. (Origin: 40 CFR 60.4211(c))

91
If the permittee does not install, configure, operate, and maintain affected emission units and
control devices according to the manufacturer's emission-related written instructions, or changes
emission-related settings in a way that is not permitted by the manufacturer, the permittee shall
demonstrate compliance as follows:
(a) For affected emission units greater than or equal to 100 HP and less than or equal to 500
HP:
i. Keep a maintenance plan and records of conducted maintenance; and
ii. To the extent practicable, maintain and operate the engine in a manner consistent with
good air pollution control practice for minimizing emissions; and
iii. Conduct an initial performance test to demonstrate compliance with the applicable
emission standards within 1 year of startup, or within 1 year after an engine and
control device is no longer installed, configured, operated, and maintained in
accordance with the manufacturer's emission-related written instructions, or within 1
year after changing emission-related settings in a way that is not permitted by the
manufacturer.
(Origin: 40 CFR 60.4211(g)).

II.B.21.f.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.21.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: A certificate was on site. Maintenance records show all required and preventative maintenance is
performed. The manufacturer’s requirements are met. In compliance.

II.B.21.g Condition:

For the 610 hp emergency fire pump engine and the 402 hp and 161 hp emergency engines:
The permittee shall operate and maintain affected emission units that achieve the emission standards as
required in 40 CFR 60.4205 over the entire life of the engine. The permittee shall do all of the following,
except as permitted in II.B.21.g.1(b):
(1) Operate and maintain the stationary CI ICE and control device according to the manufacturer's
emission-related written instructions;
(2) Change only those emission-related settings that are permitted by the manufacturer; and
(3) Meet the requirements of 40 CFR part 1068, as applicable.
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4206, 40 CFR 60.4211(a), 40 CFR 63 Subpart ZZZZ]

II.B.21.g.1 Monitoring:

(a) The permittee shall document activities performed to assure proper operation and
maintenance.
(b) If the permittee does not install, configure, operate, and maintain affected emission units
and control devices according to the manufacturer's emission-related written instructions, or
changes emission-related settings in a way that is not permitted by the manufacturer, the
permittee shall demonstrate compliance as follows:
(1) For affected emission units greater than or equal to 100 HP and less than or equal to
500 HP:
92
a. Keep a maintenance plan and records of conducted maintenance; and
b. To the extent practicable, maintain and operate the engine in a manner consistent
with good air pollution control practice for minimizing emissions; and
c. Conduct an initial performance test to demonstrate compliance with the applicable
emission standards within 1 year of startup, or within 1 year after an engine and
control device is no longer installed, configured, operated, and maintained in
accordance with the manufacturer's emission-related written instructions, or within
1 year after changing emission-related settings in a way that is not permitted by the
manufacturer.
(2) For affected emission units greater than 500 HP:
a. Keep a maintenance plan and records of conducted maintenance; and
b. To the extent practicable, maintain and operate the engine in a manner consistent
with good air pollution control practice for minimizing emissions; and
c. Conduct an initial performance test to demonstrate compliance with the applicable
emission standards within 1 year of startup, or within 1 year after an engine and
control device is no longer installed, configured, operated, and maintained in
accordance with the manufacturer's emission-related written instructions, or within
1 year after changing emission-related settings in a way that is not permitted by the
manufacturer. The permittee shall conduct subsequent performance testing every
8,760 hours of engine operation or 3 years, whichever comes first, thereafter to
demonstrate compliance with the applicable emission standards.
(Origin: 40 CFR 60.4211(g)).

II.B.21.g.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.21.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: A certificate was on site. Maintenance records show all required and preventative maintenance is
performed. The manufacturer’s requirements are met. In compliance.

II.B.21.h Condition:

For the 610 hp emergency fire pump engine and the 402 hp and 161 hp emergency engines:
The permittee of affected emission units with a displacement of less than 30 liters per cylinder shall use
diesel fuel that meets the requirements of 40 CFR 1090.305 for nonroad diesel fuel. [Origin: 40 CFR 60
Subpart IIII]. [40 CFR 60.4207(b), 40 CFR 63 Subpart ZZZZ]

II.B.21.h.1 Monitoring:

Records required for this permit condition will serve as monitoring.

93
II.B.21.h.2 Recordkeeping:

For each fuel load received, the permittee shall maintain either fuel receipt records or other
documentation showing fuel meets the specifications of ASTM D975 for the cetane index and
sulfur content for Grades No. 1-D S15 or 2-D S15 diesel. The permittee shall maintain
documentation demonstrating compliance with the condition. These records shall be maintained
in accordance with Provision I.S.1. of this permit.

II.B.21.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The company complies by purchasing ULS fuel with delivery bills noting ULS fuel. In compliance.

II.B.21.i Condition:

For the 610 hp emergency fire pump engine and the 402 hp and 161 hp emergency engines:
The permittee shall operate the emergency affected emission unit according to the requirements in
paragraphs (1) through (3). In order for the engine to be considered an emergency stationary ICE under
40 CFR 60 Subpart IIII, any operation other than as described in 40 CFR 60.4211(f), is prohibited. If the
engine is not operated according to the requirements in 40 CFR 60.4211(f), it will not be considered an
emergency engine and shall meet all requirements for non-emergency engines.
(1) There is no time limit on the use of emergency stationary ICE in emergency situations.
(2) Emergency stationary ICE may be operated for the purpose specified in 40 CFR 60.4211(f)(2)(i) for
a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed
by 40 CFR 60.4211(f)(3) counts as part of the 100 hours per calendar year allowed by this
paragraph.
(a) Emergency stationary ICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
authority and transmission operator, or the insurance company associated with the engine. A
petition for approval of additional hours to be used for maintenance checks and readiness
testing is not required if the permittee maintains records indicating that federal, state, or local
standards require maintenance and testing of emergency ICE beyond 100 hours per calendar
year.
(3) The permittee may operate the emergency stationary ICE up to 50 hours per calendar year in non-
emergency situations as specified in 40 CFR 60.4211(f)(3).
[Origin: 40 CFR 40 CFR 60 Subpart IIII]. [40 CFR 60.4211(f), 40 CFR 63 Subpart ZZZZ]

II.B.21.i.1 Monitoring:

If an emergency affected emission unit does not meet the standards applicable to non-emergency
engines, the permittee shall install a non-resettable hour meter prior to startup of the engine.
[origin: 40 CFR 60.4209(a)] Records required for this permit condition will also serve as
monitoring.

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II.B.21.i.2 Recordkeeping:

Records of each affected emission unit shall be kept on a monthly basis in an operation and
maintenance log. Records shall distinguish between maintenance-related hours and emergency
use-related hours. If additional hours are to be used for maintenance checks and readiness
testing, the permittee shall maintain records indicating that federal, state, or local standards
require maintenance and testing of emergency ICE beyond 100 hours per calendar year. (Origin:
40 CFR 60.4211(f))

Starting with the model years in Table 5 of 40 CFR 60 Subpart IIII, if an affected emission unit
does not meet the standards applicable to non-emergency engines in the applicable model year,
the permittee shall keep records of the operation of the engine in emergency and non-emergency
service that are recorded through the non-resettable hour meter. The permittee shall record the
time of operation of the engine and the reason the engine was in operation during that time.
(Origin: 40 CFR 60.4214(b))

Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.21.i.3 Reporting:

If emergency stationary CI ICE with a maximum engine power more than 100 HP operate for
the purpose specified in 40 CFR 60.4211(f)(3)(i), the permittee shall submit an annual report
according to the requirements in 40 CFR 60.4214(d). There are no additional reporting
requirements for this provision except those specified in Section I of this permit.

Status: A certificate was on site. Maintenance records show all required and preventative maintenance is
performed. The manufacturer’s requirements are met. In compliance.

II.B.21.j Condition:

The permittee shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the diesel-fired
engines on site. All diesel burned shall contain no more than 15 ppm sulfur. [Origin: DAQE-
AN109170044-23]. [R307-401-8]

II.B.21.j.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.21.j.2 Recordkeeping:

To demonstrate compliance with the diesel fuel requirements, the permittee shall keep and
maintain fuel purchase invoices for any diesel fuel purchased. The fuel purchase invoices shall
indicate the diesel fuel meets the sulfur requirements or the permittee shall obtain certification of
sulfur content from the fuel supplier. Records shall be maintained in accordance with Provision
I.S.1 of this permit.

95
II.B.21.j.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The company complies by purchasing ULS fuel with delivery bills noting ULS fuel. In compliance.

II.B.22 Conditions on ENGINES-P: Propane-fired Emergency Generators

II.B.22.a Condition:

Visible emissions from propane-fired emergency generator engines shall not exceed 10% opacity.
[Origin: DAQE-AN109170044-23]. [R307-401-8]

II.B.22.a.1 Monitoring:

In lieu of monitoring via visible emission observations, records required for this permit condition
will serve as monitoring.

II.B.22.a.2 Recordkeeping:

Records shall be kept for any period that a fuel other than propane is used in the affected
emission unit. The records shall be recorded in a log that is kept in a readily accessible location
on site. All records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.22.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: No fuel other than propane was used. Fuel use records are kept as needed. In compliance.

II.B.22.b Condition:

(a) For each affected emission unit where construction commenced (i.e., date the affected emission unit
is ordered by the Permittee) after June 12, 2006, with a maximum engine power:
(1) Less than or equal to 19 KW (25 HP) manufactured on or after July 1, 2008, the Permittee shall
comply with the emission standards in 40 CFR 60.4231(a) (origin 40 CFR 60.4233(a));
(2) Greater than 19 KW (25 HP) and less than 75 KW (100 HP) the permittee shall comply with
the emission standards in Table 1 of 40 CFR 60 Subpart JJJJ. (origin 40 CFR 60.4233(d))
(b) Deadline for importing or installing affected emission units produced in previous model years:
(1) After July 1, 2010, the Permittee shall not install affected emission units with a maximum
engine power of less than 500 HP that do not meet the applicable requirements in section (a) of
this condition. (origin 40 CFR 60.4236(a))
(2) For affected emission units with a maximum engine power of greater than 19 KW (25 HP), the
permittee shall not install engines that do not meet the applicable requirements in section (a) of
this condition after January 1, 2011. (origin 40 CFR 60.4236(c))
(3) In addition to the requirements specified in 40 CFR 60.4231 and 40 CFR 60.4233, it is
prohibited to import affected emission units less than or equal to 19 KW (25 HP), that do not
meet the applicable requirements specified in paragraph (1) this section, after the date specified
in paragraph (1) of this section. (origin 40 CFR 60.4236(d))
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(c) The Permittee shall operate and maintain affected emission units that achieve the emission standards
as required in this condition over the entire life of the engine (origin 40 CFR 60.4234)
(d) The air-to-fuel ratio (AFR) controller, if used, shall be maintained and operated appropriately by the
Permittee in order to ensure proper operation of affected emission units and control device to
minimize emissions at all times. (origin 40 CFR 60.4243(g))
[Origin: 40 CFR 60 Subpart JJJJ]. [40 CFR 60.4233, 40 CFR 60.4234, 40 CFR 60.4236, 40 CFR
60.4243, 40 CFR 63 Subpart ZZZZ]

II.B.22.b.1 Monitoring:

(a) For affected emission units manufactured after July 1, 2008 with a maximum engine power
less than or equal to 19 KW (25 HP), the permittee shall demonstrate compliance by
purchasing an engine certified to the emission standards in 40 CFR 60.4231(a) for the same
engine class and maximum engine power. In addition, the permittee shall meet one of the
requirements specified in (a)(1) and (2) of this section.
(1) If the Permittee operates and maintains the certified stationary SI internal combustion
engine and control device according to the manufacturer's emission-related written
instructions, the Permittee shall keep records of conducted maintenance to demonstrate
compliance, but no performance testing is required for the Permittee. The Permittee
shall also meet the requirements as specified in 40 CFR part 1068, subparts A through
D, as they apply. If the Permittee adjusts engine settings according to and consistent
with the manufacturer's instructions, the affected emission unit will not be considered
out of compliance.
(2) If the Permittee does not operate and maintain the certified stationary SI internal
combustion engine and control device according to the manufacturer's emission-related
written instructions, the engine will be considered a non-certified engine, and the
Permittee shall demonstrate compliance according to (a)(2)(i) of this section.
(i) If the affected emission unit is less than 100 HP, the Permittee shall keep a
maintenance plan and records of conducted maintenance to demonstrate
compliance and shall, to the extent practicable, maintain and operate the engine in
a manner consistent with good air pollution control practice for minimizing
emissions, but no performance testing is required for the Permittee.
(Origin: 40 CFR 60.4243(a))
(b) For affected emission units greater than 19 KW (25 HP) and less than 75 KW (100 HP)
subject to the emission standards in 40 CFR 60.4233(d), the permittee shall demonstrate
compliance by purchasing an engine certified according to procedures specified in 40 CFR
60 Subpart JJJJ, for the same model year and demonstrating compliance according to one of
the methods specified in (a)(1) and (2) of this section.
(Origin: 40 CFR 60.4243(b)).

II.B.22.b.2 Recordkeeping:

(a) For each affected emission unit, the Permittee shall keep records of the information in
paragraphs (a)(1) through (4) of this section.
(1) All notifications submitted to comply with this condition and all documentation
supporting any notification.
(2) Maintenance conducted on each affected emission unit.
(3) If the affected emission unit is a certified engine, documentation from the
manufacturer that the affected emission unit is certified to meet the emission standards
and information as required in 40 CFR parts 1048, 1054, and 1060, as applicable.
97
(4) If the affected emission unit is not a certified engine or is a certified engine operating
in a non-certified manner and subject to 40 CFR 60.4243(a)(2), documentation that the
engine meets the emission standards.
(Origin: 40 CFR 60.4245(a))
(b) The permittee shall keep records of the install date of each affected emission unit and the
applicable requirements under 40 CFR 60 Subpart JJJJ for the respective model year engine.
(c) Records and results of monitoring shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.22.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: These are units GN200 (41 hp), and GN300 (41hp). GN500 (<100hp) has been removed from site.
A certificate was on site for each engine. Maintenance records show all required and preventative
maintenance is performed. Manufacturer’s requirements are met. Hours as of April 30, 2025,
were: GN-200 0 and GN-300 0. Last PM was September 2024 for both units. All required items are
included in the PM list. Generators are run for maintenance once per year for less than one hour.
In compliance.

II.B.22.c Condition:

The permittee shall operate the affected emission units according to the requirements in paragraphs (1)
through (3). In order for the engine to be considered an emergency stationary ICE under 40 CFR 60
Subpart JJJJ, any operation other than as described in 40 CFR 60.4243(d) is prohibited. If the engine is
not operated according to the requirements in 40 CFR 60.4243(d), it will not be considered an
emergency engine and shall meet all requirements for non-emergency engines.
(1) There is no time limit on the use of emergency stationary ICE in emergency situations.
(2) Emergency stationary ICE may be operated for the purpose specified in 40 CFR 60.4243(d)(2)(i) for
a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed
by 40 CFR 60.4243(d)(3) counts as part of the 100 hours per calendar year allowed by this
paragraph.
(a) Emergency stationary ICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
authority and transmission operator, or the insurance company associated with the engine. A
petition for approval of additional hours to be used for maintenance checks and readiness
testing is not required if the permittee maintains records indicating that federal, state, or local
standards require maintenance and testing of emergency ICE beyond 100 hours per calendar
year.
(3) The permittee may operate the emergency stationary ICE up to 50 hours per calendar year in non-
emergency situations as specified in 40 CFR 60.4243(d)(3).
[Origin: 40 CFR 60 Subpart JJJJ]. [40 CFR 60.4243(d), 40 CFR 63 Subpart ZZZZ]

II.B.22.c.1 Monitoring:

Records required for this permit condition will serve as monitoring. Additionally, for affected
emission units less than 130 HP, built on or after July 1, 2008, that do not meet the standards
applicable to non-emergency engines, the permittee shall install a non-resettable hour meter
upon startup of the affected emission unit. (Origin: 40 CFR 60.4237(c)).
98
II.B.22.c.2 Recordkeeping:

For each affected emission unit greater than 25 HP and less than 130 HP manufactured on or
after July 1, 2008, that does not meet the standards applicable to non-emergency engines, the
permittee shall keep records of the hours of operation of the affected emission unit that are
recorded through the non-resettable hour meter. The permittee shall document how many hours
are spent for emergency operation, including what classified the operation as emergency and
how many hours are spent for non-emergency operation. (Origin: 40 CFR 60.4245(b))

Records of each affected emission unit shall be kept on a monthly basis in an operation and
maintenance log. Records shall distinguish between maintenance-related hours and emergency
use-related hours. If additional hours are to be used for maintenance checks and readiness
testing, the permittee shall maintain records indicating that federal, state, or local standards
require maintenance and testing of emergency ICE beyond 100 hours per calendar year. (Origin:
40 CFR 60.4243(d))

Records demonstrating compliance with the condition shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.22.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Units are listed and operate for emergency use only. All maintenance activities are completed, and
hours are based on non-resettable meter. All units run less than 100 hours unless emergency use or
malfunctions which were logged and reported. In compliance.

II.B.23 Conditions on BLAST: Abrasive Blast Machine.

II.B.23.a Condition:

(1) Except as provided in (2) below, visible emissions from abrasive blasting operations shall not
exceed 20% opacity except for an aggregate period of three minutes in any one hour.
(2) If the abrasive blasting operation complies with the performance standards in R307-306-6, visible
emissions from the operation shall not exceed 40% opacity, except for an aggregate period of 3
minutes in any one hour.
[Origin: R307-306]. [R307-306-4]

II.B.23.a.1 Monitoring:

(a) Visible emissions shall be measured at least monthly using EPA Method 9, or other EPA-
approved testing method, as acceptable to the Director, if the affected emission unit was
operated during the month. Visible emissions from intermittent sources shall use procedures
similar to Method 9, but the requirement for observations to be made at 15 second intervals
over a six-minute period shall not apply.
(b) Visible emissions from unconfined blasting shall be measured at the densest point of the
emission after a major portion of the spent abrasive has fallen out, at a point not less than
five feet nor more than twenty-five feet from the impact surface from any single abrasive
blasting nozzle.
99
(c) An unconfined blasting operation that uses multiple nozzles shall be considered a single
source unless it can be demonstrated by the permittee that each nozzle, measured separately,
meets the emission and performance standards provided in R307-306-4.
(d) Visible emissions from confined blasting shall be measured at the densest point after the air
contaminant leaves the enclosure.

II.B.23.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.23.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: This unit is included in the monthly VEO form but has not been used in several years.

II.B.24 Conditions on ROADS: Roads and Unpaved Operational Areas.

II.B.24.a Condition:

1) Visible emissions in disturbed, operational areas, and unpaved haul roads from haul trucks and other
mobile equipment shall not exceed 20% opacity at any point.
2) Visible emissions caused by fugitive dust shall not exceed 10% at the property boundary. The 10%
opacity shall not apply when the wind speed exceeds 25 miles per hour if the permittee has
implemented, and continues to implement, the accepted fugitive dust control plan and administers at
least one of the following contingency measures:
(a) Pre-event watering;
(b) Hourly watering;
(c) Additional chemical stabilization;
(d) Cease or reduce fugitive dust producing operations;
(e) Other contingency measure approved by the director.
[Origin: DAQE-AN109170044-23, R307-309]. [R307-309-5, R307-309-6, R307-401-8]

II.B.24.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, adherence to the most recently
approved fugitive dust control plan shall be monitored to demonstrate that the opacity limits are
not exceeded and that appropriate measures are being implemented to control fugitive dust.
Wind speed may be measured by a hand-held anemometer or equivalent device.

Vehicle speeds shall be limited to 30 miles per hour on haul roads and 15 miles per hour in off-
road areas. The vehicle speed limits shall be clearly visible and posted, at a minimum, on site at
the entrance to off-road areas and the beginning of the haul road.

The permittee shall spray all unpaved haul roads with water, brine, or a chemical suppressant to
control fugitive dust and maintain the opacity limits listed in this condition.

100
II.B.24.a.2 Recordkeeping:

Records of water or chemical treatment shall be kept for all periods when the plant is in
operation. The permittee may stop applying suppressants when the temperature is below
freezing. The records shall include the following:
A. Date
B. Location of treatment
C. Rainfall received, if any, and approximate amount
D. Records of temperature if the temperature is below freezing.

If wind speeds are measured to establish an exception from the 10% opacity limit, records of the
administered contingency measures and the wind speed measurements shall be maintained.

Records that demonstrate compliance with this condition shall be available to the director upon
request. [R307-309-12] Records required by the most recently approved fugitive dust control
plan shall be maintained in accordance with the plan and section I.S.1 of this permit.

II.B.24.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The most recent dust plan is dated February 2020. A revised copy was submitted and approved on
April 24, 2020. Road dust logs are maintained. Compass was adhering to the dust plan during this
inspection. No excessive fugitive dust during the inspection. In compliance.

II.B.24.b Condition:

i) If the permittee is responsible for construction or maintenance of any existing road or has right-of-
way easement or possesses the right to use the same whose activities result in fugitive dust from the
road, the permittee shall minimize fugitive dust to the maximum extent possible. If materials are
deposited that may create fugitive dust on a public or private paved road, the permittee shall clean
the road promptly.
ii) Unpaved Roads. If the permittee is responsible for construction or maintenance of any new or
existing unpaved road, the permittee shall prevent, to the maximum extent possible, the deposit of
material from the unpaved road onto any intersecting paved road during construction or
maintenance. If materials are deposited that may create fugitive dust on a public or private paved
road, the permittee shall clean the road promptly.
[Origin: R307-309]. [R307-309-9]

II.B.24.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.24.b.2 Recordkeeping:

Records that demonstrate compliance with this condition and records required by the most
recently approved fugitive dust control plan shall be maintained in accordance with the plan and
section I.S.1 of this permit.

101
II.B.24.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The most recent dust plan is dated February 2020. A revised copy was submitted and approved on
April 24, 2020. Road dust logs are maintained. Compass was adhering to the dust plan during this
inspection. No excessive fugitive dust during the inspection. In compliance.

II.B.25 Conditions on TANKS: Petroleum Storage Tanks

II.B.25.a Condition:

For the gasoline storage tank, the permittee shall maintain records of the average monthly storage
temperature, the type of liquid, throughput quantities, and the maximum true vapor pressure. [Origin:
R307-327-4]. [R307-327-4]

II.B.25.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.25.a.2 Recordkeeping:

The permittee shall maintain records of the average monthly storage temperature, the type of
liquid, throughput quantities, and the maximum true vapor pressure in accordance with Provision
I.S.1 of this permit.

II.B.25.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The company has several above ground tanks. Throughput records are based on purchase records,
temps are based on avg readings, type of fuel does not change but is on form and TVP is kept. In
compliance.

II.B.26 Conditions on MISC: Miscellaneous Emissions

II.B.26.a Condition:

The permittee shall not operate a degreasing or solvent cleaning operation unless the following
conditions are met.
(1) A cover shall be installed which shall remain closed except during actual loading, unloading or
handling of parts in cleaner. The cover shall be designed so that it can be easily operated with one
hand if:
(a) The volatility of the solvent is greater than 2 kPa (15 mm Hg or 0.3 psi) measured at 38
degrees C (100 degrees F),
(b) The solvent is agitated, or
(c) The solvent is heated.

102
(2) An internal draining rack for cleaned parts shall be installed on which parts shall be drained until all
dripping ceases. If the volatility of the solvent is greater than 4.3 kPa (32 mm Hg at 38 degrees C
(100 degrees F)), the drainage facility must be internal, so that parts are enclosed under the cover
while draining. The drainage facility may be external for applications where an internal type cannot
fit into the cleaning system.
(3) Waste or used solvent shall be stored in covered containers.
(4) Tanks, containers and all associated equipment shall be maintained in good operating condition, and
leaks shall be repaired immediately or the degreaser shall be shutdown.
(5) Written procedures for the operation and maintenance of the degreasing or solvent cleaning
equipment shall be permanently posted in an accessible and conspicuous location near the
equipment.
(6) If the solvent volatility is greater than 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38 degrees C (100
degrees F), or if solvent is heated above 50 degrees C (120 degrees F), then one of the following
control devices shall be used:
(a) Freeboard that gives a freeboard ratio greater than 0.7;
(b) Water cover if the solvent is insoluble in and heavier than water); or
(c) Other systems of equivalent control, such as a refrigerated chiller or carbon adsorption.
(7) If used, the solvent spray shall be a solid fluid stream at a pressure that does not cause excessive
splashing and may not be a fine, atomized or shower type spray.
[Origin: R307-335]. [R307-335-4]

II.B.26.a.1 Monitoring:

A visual inspection shall be made at least once each quarter to demonstrate compliance with this
condition. Records required for this permit condition will also serve as monitoring.

II.B.26.a.2 Recordkeeping:

Documentation of the visual inspections and records demonstrating compliance with this
condition shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.26.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The company uses only water-based solvents in the four cleaning units on site. Quarterly
inspections are done by compliance staff. In compliance.

II.B.26.b Condition:

1. Except as provided in R307-361-4, the permittee shall not blend, or repackage, supply, solicit for
application or apply within the counties in R307-361-2 any architectural coating with a VOC content
in excess of the corresponding limit specified in Table 1 of R307-361-5.
2. If a coating is recommended for use in more than one of the specialty coating categories listed in
Table 1, the most restrictive (lowest) VOC content limit shall apply.
a. This requirement applies to usage recommendations that appear anywhere on the coating
container, anywhere on any label or sticker affixed to the container, or in any sales, advertising,
or technical literature supplied by a manufacturer or anyone acting on their behalf.
b. R307-361-5(2) does not apply to the coating categories listed in R307-361-5(2)(b).
103
3. Sell-through of coatings. A coating manufactured before January 1, 2015, may be applied at any
time. R307-361-5(3) does not apply to any coating that does not display the date or date code
required by R307-361-6(1)(a).
4. Painting practices. All architectural coating containers used when applying the contents therein to a
surface directly from the container by pouring, siphoning, brushing, rolling, padding, ragging or
other means, shall be closed when not in use. These architectural coating containers include, but are
not limited to, drums, buckets, cans, pails, trays or other application containers. Containers of any
VOC-containing materials used for thinning and cleanup shall also be closed when not in use.
5. Thinning. The permittee shall not apply or solicit the application of any architectural coating that is
thinned to exceed the applicable VOC limit specified in Table 1.
6. Rust preventative coatings. The permittee shall not apply or solicit the application of any rust
preventative coating manufactured before January 1, 2015 for industrial use, unless such a rust
preventative coating complies with the industrial maintenance coating VOC limit specified in Table
1.
7. Coatings not listed in Table 1. For any coating that does not meet any of the definitions for the
specialty coatings categories listed in Table 1, the VOC content limit shall be determined by
classifying the coating as a flat, non-flat, or non-flat/high gloss coating, based on its gloss, as defined
in R307-361-3 and the corresponding flat, non-flat, or non-flat/high gloss coating VOC limit in Table
1 shall apply.
8. The coatings described in R307-361-4(1) through (3) are exempt from the requirements of R307-361.
[Origin: R307-361]. [R307-361]

II.B.26.b.1 Monitoring:

The permittee shall use the following test methods.
(a) Determination of VOC content.
(i) For the purpose of determining compliance with the VOC content limits in Table 1, the
VOC content of a coating shall be calculated by following the appropriate formula
found in the definitions of VOC actual, VOC content, and VOC regulatory found in
R307-361-3.
(ii) The VOC content of a tint base shall be determined without colorant that is added after
the tint base is manufactured.
(iii) If the manufacturer does not recommend thinning, the VOC content shall be calculated
for the product as supplied.
(iv) If the manufacturer recommends thinning, the VOC content shall be calculated
including the maximum amount of thinning solvent recommended by the
manufacturer.
(v) If the coating is a multi-component product, the VOC content shall be calculated as
mixed or catalyzed.
(vi) The coating contains silanes, siloxanes, or other ingredients that generate ethanol or
other VOC during the curing process, the VOC content shall include the VOCs emitted
during curing.
(R307-361-8)

II.B.26.b.2 Recordkeeping:

Records demonstrating compliance with this condition shall be maintained in accordance with
Provision I.S.1 of this permit.

104
II.B.26.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The company uses a third-party contractor to do coatings on the site equipment. No coatings are
stored on site. The company has MSD sheets and states compliance with coating rules and
requirements. In compliance.

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.
SECTION III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with
Provision I.M, Permit Shield:

III.A. 40 CFR 60 Subpart UUU (Standards of Performance for Calciners and Dryers in Mineral Industries)

This regulation is not applicable to the Permitted Source for the following reason(s): neither the salt
plant nor the SOP plant meets the definition of mineral processing plant given in 40 CFR 60.731.
Although the magnesium chloride plant could meet the definition of mineral processing plant, there
is no calciner or dryer at the magnesium chloride plant. Calciners and dryers are the only affected
facilities subject to Subpart UUU according to 40 CFR 60.730. [10/22/2008] [Last updated January
22, 2020]

III.B. 40 CFR 60 Subpart OOO (Standards of Performance for Nonmetallic mineral processing plants)

This regulation is not applicable to the Permitted Source for the following reason(s): the only
material processed by the facility which is subject to 40 CFR Subpart OOO is sodium chloride,
however, all affected facilities commenced construction, reconstruction or modification prior to
August 31, 1983. [06/24/2002] [Last updated January 22, 2020]

105
SECTION IV: ACID RAIN PROVISIONS

This source is not subject to Title IV. This section is not applicable.

Approval Order DAQE-AN109170049-24, Dated May 8, 2024.
Project Description
Compass has requested a change to its current AO DAQE-AN109170044-23. The current salt harvesting
throughput limit is redundant with the two (2) limits on processed salt products. Although the potential
exists for additional salt harvesting, the material contains residual magnesium chloride (a dust
suppressant) and maintains a high moisture content (further limiting or eliminating fugitive dust
emissions). Condition II.B.2.a(A), which limits the total salt harvest amount, is unnecessary and is being
removed.

As part of this project, Compass also wishes to include a previously submitted project. This other project
involves the inclusion of equipment and processes from Fortress North America, which was recently
acquired by Compass. Harvested magnesium chloride from the existing Compass processes and converts
it to a fire retardant. The magnesium chloride will be loaded into two (2) sealed tanks where it will be
blended with additives. The additives are introduced by a vacuum pump, which pulls the powdered
additives from the bottom of the hoppers using a negative pressure zone and deposits them into the
bottom of the mixing tanks. Emissions from the two (2) hoppers are processed by a baghouse. Inside the
tanks, the magnesium chloride is mixed with the additives. The viscous fluid will then be transported to a
holding tank to await loadout.

The salt harvest limit is covered under Title V condition above and removed by statement.

The Fortress system has not completed but has not been put into service as company needs have changed.
No determination could be made.

EMISSIONS INVENTORY: From 2023 emissions inventory: (2024 inventory is under review)
Pollutant Total without
tailpipe
Tailpipe Total
PM10 115.90 9.48 125.38
PM2.5 43.81 9.03 52.83
SO2 1.28 2.46 3.73
NOx 10.56 103.72 114.28
VOC 16.13 9.60 25.72
CO 71.27 88.46 159.73
NH3 2.71 2.71
CHCL3 10.12
Hexane 1.52
HCL 6.71
Methanol 1.49

106
PREVIOUS ENFORCEMENT
ACTIONS: AH-513 failed October 2023 stack test and was retested in February
2024, with results within allowed limits. Signed Settlement Agreement
(SSA) received May 13, 2024.

COMPLIANCE STATUS &
RECOMMENDATIONS: None for this inspection.

HPV STATUS: No.

COMPLIANCE
ASSISTANCE: Discussed new (pending) Approval Orders and equipment list and new
requirements.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect with new Approval Order/Title V Permit.

ATTACHMENT: VEO Form.