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Status: OKFile #: 10725 (B2) Comment: Deviation notice, received April 11, 2024, regarding this report has been retracted.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