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HomeMy WebLinkAboutDAQ-2024-007384Clean Harbors Aragonite, LLC I 1600 North Aptus Road Aragonite, UT 84029 435.884.8100 www.cleanharbors.com April8,2024 Sent Via FedEx: 8181 5400 5844 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 6l 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 61 Subpart V Report and 40 CFR 63 Subpart DD Pressure Relief Device Periodic Report. These reports cover the time period of June 2023 through November 2023. For the Semi Annual 40 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. -UTAH DEPARruENT OFENVtRoNMENrnr. ouer.rrv Ap,t 11 2r,?l DIV'SION OF AIR QUALTTY "People and Technologt Creating a Better Environment" REVIEWEDInitials: Date: Apri 12, 2024Compliance Status: OKFile #: 10725 (B2) Comment: Deviation notice, received April 11, 2024, regarding this report has been retracted. 5.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: 1. 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(cX2Xi) 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 1 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 certifu 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 beliel 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 conceming this matter, please call me at the number below. Sincerely, ?Z*t* Aa--* Kenneth Banks Senior Environmental Compliance Manager Clean Harbors Aragonite, LLC 11600 North Aptus Road PO Box 1339 Grantsville, Utah 84029-1339 (o) 435.884.8233 @) a35.57e.51e3 Banks.kenneth@cleanharbors. com www.cleanharbors.com cc: Environmental Protection Agency, Region VIII, Air Permiuing and Monitoring Branch UTAr i-t DE|TAR 1 MEI{T Ot- E T,IVI RONI'IENTAL QUALITY DIVISION OF AIR OUALITY APit 11?02d i Semi Annual 40 CFR 61 Subpart V Report Process Unit Identifi cation A process unit is defined is 40 CFR 61.241 as: " Process Unit 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 if supplied with sfficient feed." CHA does not operate any equipment that meets this definition. Monitoring of Valves and Pumps o June 2023 o Valves: Two (2) valves were found visually leaking and no delay in repairs was needed' Manual valve (sz-MV083) was found to have a visual leak on 61812023. The valve was replaced, and the leak repaired on 61812023. A Manual Valve (DC-MV060) was found to have a visual leak on 612012023. The leak was determined to be coming from a nipple, not the valve assembly. Appropriate actions were implemented to repair the leak on 612012023. o Pumps: No leaks were detected as indicated by no visual leaks or instrument readings of 10,000 ppm or greater. . July 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. August 2023 o Valves: Two (2) valves were found visually leaking and no delay in repairs was needed.. A Manual Valve (SI-MV018) was found to have a visual leak on 811812023. The piping for the inlet and discharge of the valve were replaced, and the leak repaired on812112023.. A Manual Valve (DE-MY002) was found to have a visual leak on 812112023. The valve was replaced, and the leak repaired onBl2ll2023. o Pumps: One (1) pump was found visually leaking and no delay in repairs was needed. . P-411 was found to have a visual leak on 811912023. The seal on the pump was replaced and the leak repaired on8ll9l2023. September 2023 o Valves: Valves: No leaks were detected, as indicated 10,000 ppm or greater. o Pumps: No leaks were detected as indicated by no readings of 10,000 ppm or greater. by an instrument reading of visual leaks or instrument October 2023 o Yalves: No leaks were detected, as ppm or greater. o Pumps: No leaks were detected as readings of 10,000 ppm or greater. indicated by an instrument reading of 10,000 indicated by no visual leaks or instrument o November 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 are not any process shutdown dates to report. 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 altemative standards for valves as found in section X and 40 CFR 61.243-1. CHA is still below 2oh leaks 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)(2Xi) any instrument reading of 500 ppm above background or greater detected 5 days after the pressure release. There were no pressure reliefdevices that had a reading of500 ppm above background or greater detected 5 days after apressure release. Pressure Release Information There was no pressure releases for applicable pressure relief values during this period of time. Tag Number 3"d Ouarter 2023 4th Ouarter2023 Date Result (nom)Date Result (nnm) COR-DSOOl 71t012023 2.30 r0tr1t2023 0.70 FW-DSOO1 7t20t2023 1.80 10t19t2023 2.20 FW-DS002 7t1lt2023 1.00 r\t17t2023 1.10 HV-RDOOI 8t1t2023 0.40 rU4/2023 1.40 HV-RDOO2 8t1t2023 0.50 rU4t2023 r.20 HV.RDOO3 8t1t2023 0.70 1U412023 r.20 SL-DSOOI 7tst2023 1.10 1011212023 0.30