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HomeMy WebLinkAboutDAQ-2024-007379Clean Harbors Aragonite, LLC 11600 North Aptus Road Aragonite, UT 84029 435.884.8100 www.cleanharbors.com May 30,2023 Sent Via FedEx: 7722 8774 9197 Mr. Bryce Bird, Director Division of Air Quality Department of Environmental Quality 195 North 1950 West Salt Lake City, Utah 84116 RE: Semi-Annual40 CFR 61 Subpart V and 40 CFR 63 Subpart DD Reports Clean Harbors Aragonite, LLC Title V Operating Permit #4500048004 Dear Mr. Bird, In accordance with Title V Operating Permit Condition II.B.3.b.3 and requirements found in 40 CFR 61 .247(b) and 40 CFR 63.697(a)(5), Clean Harbors Aragonite, LLC is submitting the Semi- Annual 40 CFR 6l Subpart V Report and 40 CFR 63 Subpart DD Pressure Relief Device Periodic Report. These reports cover the time period of December 2022 through May 2023. For the Semi Annual40 CFR 61 Subpart V Report the following information is addressed: 1. Process unit identification 2. For each month during the semiannual reporting period, i. Number of valves for which leaks were detected as described in paragraph (b) of Section VII of this condition. ii. Number of Valves for which leaks were not repaired as required in paragraph (b) of Section VII of this condition. iii. Number of pumps for which leaks were detected a described in paragraph (b) section III of this condition. iv. Number of pumps for which leaks were not repaired as required in paragraph (c) section III of this condition. v. The facts that explain any delay in repairs and, where appropriate, why a process unit shutdown was technically infeasible. 3. Dates of process unit shutdowns which occurred within the semiannual reporting period. 4. Revisions to items reported according to paragraph (a) of 40 CFR 61.247 if changes have occurred since initial report or subsequent revisions to the initial report. "People and Technologt Creating a Better Environment" REVIEWEDInitials: Date: March 27, 2024Compliance Status: OKFile #: 10725 (B2) 5. The results of all performance tests and monitoring to determine compliance with no detectable emissions with sections X and XI of this condition conducted within the semiannual reporting period. See the attached report with the required information. For the 40 CFR 63 Subpart DD Pressure Relief Device Periodic Report the following information is addressed : l. Monitoring results during the monitoring period of pressure relief devices in off-site material service subject to 63.961(c). 2. For pressure relief devices in gas/vapor service subject to 63.691(cx2)(i) any instrument reading of 500 ppm above background or greater detected 5 days after the pressure release. 3. For pressure relief devices in off-site material service subject to 63.691(c)(3) any pressure release to the atmosphere including: a. The source, nature, and cause ofthe pressure release. b. Date, time, and duration of the pressure release c. An estimate of the quantity of HAP listed in Table I of this subpart emitted during the pressure release and the method used for determining this quantity. d. The actions taken to prevent this pressure release. e. The measures adopted to prevent future such pressure releases. See the attached report with the required information. In accordance with Permit Condition I.K and Utah Administrative Code R307-415-5d, I certiff under penalty of law that this document and all attachments were prepared under my direct supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based upon my inquiry of persons or persons who manage the system, or those persons directly responsible for gathering the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of imprisonment for known violations. Should you have any questions concerning this matter, please call me at the number below. Sincerely,F H,,,* Tyson Hone Senior Environmental Compliance Manager Clean Harbors Aragonite, LLC 11600 North Aptus Road PO Box 1339 Grantsville, Utah 84029 -1339 (o) 435.884.8122 @) a35.579.s389 hone.ty son@cleanharbors. com www.cleanharbors.com cc: Environmental Protection Agency, Region VIII, Air Permitting and Monitoring B REVIEWEDInitials: Date: March 27, 2024Compliance Status: OKFile #: 10725 (B2) Semi Annual 40 CFR 61 Subpart V Report Process Unit Identilication A process unit is defined is 40 CFR 61.24I as: "Process (Jnit means equipment assembled to produce a volatile hazardous air pollutant (VHAP) or its derivates as intermediates or final products, or equipment assemble to use a VHAP in the production of a product. A process unit can operate independently f supplied with sufficient feed. " CHA does not operate any equipment that meets this definition. Monitoring of Valves and Pumps o December 2022 o Valves: No leaks were detected, as indicated by an instrument reading of 10,000 ppm or greater. o Pumps: No leaks were detected as indicated by no visual leaks or instrument readings of 10,000 ppm or greater. . January2023 o Valves: No leaks were detected, as indicated by an instrument reading of 10,000 ppm or greater. o Pumps: No leaks were detected as indicated by no visual leaks or instrument readings of 10,000 ppm or greater. o February2023 o Valves: No leaks were detected, as indicated by a, instrument reading of 10,000 ppm or greater. o Pumps: One (1) pump was found visually leaking and no delay in repairs was "tt"o'r-010 was found to have a visual leak on 2lgl2023.The seal on the pump was replaced and the leak repaired on2ll0l2023. o March 2023 o Valves: Valves: No leaks were detected, as indicated by an instrument reading of 10,000 ppm or greater. o Pumps: No leaks were detected as indicated by no visual leaks or instrument readings of 10,000 ppm or greater. o April2023 o Valves: No leaks were detected, as indicated by an instrument reading of 10,000 ppm or greater. o Pumps: No leaks were detected as indicated by no visual leaks or instrument readings of 10,000 ppm or greater. o N[ay 2023 o Valves: No leaks were detected, as indicated by an instrument reading of 10,000 ppm or greater. o Pumps: No leaks were detected as indicated by no visual leaks or instrument readings of 10,000 ppm or greater Dates of Process Shutdown CHA does not have any equipment that meets the process unit definition so there process shutdown dates to report. are not any Revisions to items reported according to paragraph (a) of 40 CFR 61.247 since initial report or revision. There have been no revisions to items reported according to paragraph a) of 40 CFR 61.247 since the initial report or revision. Results of all performance tests and monitoring to determine compliance with no detectable emissions with sections X and XI. CHA did not perform any performance tests to meet the alternative standards for valves as found in section X and 40 CFR 61.243-1. CHA is still below 2Yoleaks detected for valves during the semi-annual reporting period. The facility, however, monitors all valves on a quarterly basis. 40 CFR 63 Subpart DD Pressure Relief Device Periodic Report Monitoring results during the monitoring period of pressure relief devices in off-site material service subject to 63.961(c). CHA has seven (7) pressure relief devices at the facility that meet this definition. These devices are monitored quarterly using Method 21. Monitoring information can be found in the table below: For pressure relief devices in gas/vapor service subject to 63.691(c)(2)(i) any instrument reading of 500 ppm above background or greater detected 5 days after the pressure release. There were no pressure relief devices that had a reading of 500 ppm above background or greater detected 5 days after a pressure release. Pressure Release Information There was no pressure releases for applicable pressure relief values during this period of time. Tag Number ['t Ouarter 2023 2trd Ouarter 2023 , Date Result (ppm)Date Result (dpm) COR-DSOOI U612023 2.30 411412023 0.70 FW-DS0Ol U2012023 1.70 412y2023 1.00 FW-DS002 U17t2023 1.40 412112023 0.30 HV.RDOOl 21812023 2.40 51t812023 0.70 HV-RDOO2 2121203 1.30 5tr8t2023 0.70 HV.RDOO3 2/812023 2.20 5n8t2023 0.90 SL-DSOO1 U412023 3.90 4n9t2023 0.70 REVIEWEDInitials: Date: March 27, 2024Compliance Status: OKFile #: 10725 (B2)