DAQ-2024-007314

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-292-24
Site ID 10725 (B5)

William Simmons, Facility GM III
Clean Harbors Aragonite, LLC
P.O. Box 1339
Grantsville, UT 84029-1339

Dear Mr. Simmons:

Re: Clean Harbors Aragonite, LLC (Clean Harbors) – Pretest Protocol for Carbon Monoxide
(CO), Carbon Dioxide (CO2), Flow, Nitrogen Oxides (NOx), Oxygen (O2), Sulfur
Dioxide (SO2), and Total Hydrocarbons (THC) Relative Accuracy Test – Tooele County

The Utah Division of Air Quality (DAQ) reviewed Clean Harbors pretest protocol dated March
19, 2024. The proposed test shall be performed under the following conditions:

Clean Harbors monitoring system to be certified:

Main Stack
Channel Manufacturer Model # Monitor SN
NOx #1 Thermo Scientific 42i - HL 0614216782
CO Low #1 Servomex XENTRA 4900 653204
O2 #1 Servomex XENTRA 4900 4021
CO2 #1 Servomex XENTRA 4900 653204
THC #1 Thermo Scientific 51i-HT 1434964304
SO2 #1 Servomex XENTRA 4900 4021

NOx #2 Thermo Scientific 42i - HL 0614216783
CO low #2 Servomex XENTRA 4900 653305
O2 #2 Servomex XENTRA 4900 4022
CO2 #2 Servomex XENTRA 4900 653305
THC #2 Thermo Scientific 51i-HT 1203299856
SO2 #2 Servomex XENTRA 4900 4022
/ % Û à Û Ù Û Ý
DAQC-292-24
Page 2

Main Stack
Channel Manufacturer Model # Monitor SN

NOx #2b Thermo Scientific 42i - HL 0836633949
CO low #2b Servomex XENTRA 4900 653205
O2 #2b Servomex XENTRA 4900 652525
CO2 #2b Servomex XENTRA 4900 653205
THC #2b Thermo Scientific 51i-HTa 1203299855
SO2 #2b Servomex XENTRA 4900 652525

Alliance Technical Group will conduct a relative accuracy/performance specification test on
Clean Harbors continuous monitoring system.

Relative accuracy must be determined in the units of the emission standard or equivalent units of
the emission standard, i.e., tons/year shall be tested in pounds/hour.

The DAQ understands that Alliance Source Testing’s staff will conduct testing as follows:

Test Date Point
Source Parameter EPA Reference Method
May 7, 2024 Main
Stack
CO, CO2, NOx, O2, SO2, and
THC
1, 2, 3A, 4, 6 or 6C, 7E, 10,
and 25A

• Reference Method 1 – Sample and Velocity Traverses for Stationary Point Sources
as outlined in 40 CFR 60 Appendix A shall be used to determine the location and
number of sampling points as applicable.

• Reference Method 2 – Determination of Stack Gas Velocity and Volumetric Flow
Rate – (Type S Pitot Tube) as outlined in 40 CFR 60 Appendix A.

• Reference Method 3A – Determination of Oxygen and Carbon Dioxide
Concentrations in Emissions from Stationary Point Sources – (Instrumental
Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.

• Reference Method 4 – Determination of Moisture Content in Stack Gases as
outlined in 40 CFR 60 Appendix A shall be used to determine the stack gas
moisture content.

• Reference Method 6 – Determination of Sulfur Dioxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60
Appendix A.

DAQC-292-24
Page 3

• Reference Method 7E – Determination of Nitrogen Oxide Emissions from
Stationary Point Sources - (Instrumental Analyzer Procedure) as outlined in 40
CFR 60 Appendix A.

• Reference Method 10 – Determination of Carbon Monoxide Emissions from
Stationary Point Sources – (NDIR Instrumental Procedure) as outlined in 40 CFR
60 Appendix A.

• Reference Method 25A – Determination of Total Gaseous Organic Concentration
Using a Flame Ionization Analyzer as outlined in 40 CFR 60 Appendix A. Zero
drift and calibration drift checks are required at the beginning and end of each run.

• Deviations – The Division of Air Quality must be notified of and approve
deviations of the Reference Method test. Any deviation from these conditions
without approval from the DAQ may constitute rejection of these tests.

Acceptance of a protocol does not relieve the owner/operator and the testing
contractor from strict adherence to all applicable EPA methods, DAQ policies,
Utah Air Quality Rules (UAQR), and methods approved by the Director. Any
deviation from EPA methods, DAQ policies, UAQR, and methods approved by the
Director must be addressed separately and express written consent given prior to
commencement of testing.

• Field data (Point Source emission data and test data) shall be turned over to the
DAQ in a timely manner for review.

• The Director will determine the relative accuracy of each monitoring system based
on Point Source continuous emission monitoring data and test data acquired by the
staff member of the DAQ during the test.

• All test reports must be submitted to the Director no later than 60 days after
completion of the test.

• The test report shall include all raw calibration data and raw emission data with
date and time stamps.

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number.

2. Raw stack test data and continuous monitor data with date and time stamps.

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

DAQC-292-24
Page 4

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

2. During testing, the Point Source combusted fuels, used raw materials, and
maintained process conditions representative of normal operations, and operated
under such other relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements
and information contained in the report are true, accurate, and complete.

Should you have any questions concerning this matter, contact me at [phone] or by email
at [e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

HB:RL:jl

cc: Tooele County Health Department
Alliance Technical Group
* $ . # ( ) - — - A D v A ? A C @ C w D G ˜
Rob Leishman Jr