State of Utah 

GARY R. HERBERT 

Governor 

GREG BELL 

Lieutenant Governor

Department of 

Environmental Quality 

Amanda Smith 

Executive Director 

DIVISION OF AIR QUALITY 

Cheryl Heying 

Director 

 

DAQE-AN0104230012-10 

December 1, 2010 

Gerry Gunning 

Interstate Brick Company 

9780 South 5200 West 

West Jordan, UT 84081-5625 

Dear Mr. Gunning: 

Re: Approval Order: Modification to the Primary Crusher Emission Limit in Approval Order DAQEAN0104230008-08 

 Project Number: N010423-0012 

The attached document is the Approval Order for the above-referenced project. Future correspondence 

on this Approval Order should include the engineer's name as well as the DAQE number as shown on the 

upper right-hand corner of this letter. The project engineer for this action is Nando Meli Jr. , who may be 

reached at (801) 536-4052. 

Sincerely, 

M. Cheryl Heying, Executive Secretary 

Utah Air Quality Board 

MCH:NM:sa 

cc: Mike Owens 

 Salt Lake Valley Health Department 

195 North 1950 West • Salt Lake City, UT 

Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 

Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 

www.deq.utah.gov 

Printed on 100% recycled paper 
STATE OF UTAH 

Department of Environmental Quality 

Division of Air Quality 

APPROVAL ORDER: Modification to the Primary Crusher 

Emission Limit in Approval Order 

DAQE-AN0104230008-08 

Prepared By: Nando Meli Jr., Engineer 

Phone: (801) 536-4052 

Email: nmeli@utah.gov 

APPROVAL ORDER NUMBER 

DAQE-AN0104230012-10 

Date: December 1, 2010 

Interstate Brick Company 

Brick Manufacturing Plant 

Source Contact: 

Mr. Joseph Eck 

Phone: (801) 280-5215 

M. Cheryl Heying 

Executive Secretary 

Utah Air Quality Board
Abstract

Interstate Brick Company (ISB) operates a brick and tile manufacturing plant in West Jordan City, Salt 

Lake County, Utah. ISB has requested an increase in the PM10 emissions limit on the Primary Crusher 

Baghouse (PCB). The facility operates under AO number DAQE-AN0104230008-08 issued November 

12, 2008, which was for the replacement of the primary crusher and baghouse. The old primary crusher 

had a 120 tons/hour maximum throughput limit and the replacement crusher is 100 tons/hour. The limits 

for the replacement baghouse remained the same as the previous limits (0.016 grains/dscf and 0.12 lb/hr). 

In March 2009 a stack test was performed on the PCB and the test result was above the limit for the 

baghouse. The replacement baghouse controls two additional conveyor drop points and handles a higher 

airflow than the previous baghouse. ISB has requested an increase in their stack limit to adjust for the 

actual emissions from the baghouse. 

ISB is a Title V major source and is subject to the requirements of the State Implementation Plan (SIP). 

This AO modification will not affect the existing SIP limits. Salt Lake County is a nonattainment area of 

the NAAQS for PM10, PM2.5, and SO2, and is a maintenance area for ozone. ISB is a minor HAP source 

and the MACT standards for brick manufacturers are not applicable. There are no NSPS or NESHAP 

standards that apply. The emission rate limit for the PCB will be permitted at the actual rate measured in 

the March 2009 source test, plus 25% for process variability, resulting in a new limit of 0.20 lb/hour. ISB 

has removed the line #5 dryer and baghouse to offset the increase. The potential to emit totals, in tons per 

year, will remain as follows: PM10/PM2.5 = 200.2, NOx = 121.1, SO2 = 90.1, CO = 312.8, VOC = 166.1 

and HAPs = 18.2.

This air quality AO authorizes the project with the following conditions and failure to comply with any of 

the conditions may constitute a violation of this order. This AO is issued to, and applies to the following: 

Name of Permittee:

Interstate Brick Company 

9780 South 5200 West 

West Jordan, UT 84081-5625 

Permitted Location:

Brick Manufacturing Plant 

9780 S. 5200 W. 

West Jordan, UT 84081-5625 

 

UTM coordinates: 413,500 m Easting, 4,491,500 m Northing, UTM Zone 12 

SIC code: 3251 (Brick & Structural Clay Tile) 

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in 

the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions 

refer to those rules. [R307-101] 

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] 

I.3 Modifications to the equipment or processes approved by this AO that could affect the 

emissions covered by this AO must be reviewed and approved. [R307-401-1] 

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by 

the owner/operator, shall be made available to the Executive Secretary or Executive Secretary's 

representative upon request, and the records shall include the two-year period prior to the date of 

the request. Unless otherwise specified in this AO or in other applicable state and federal rules, 

records shall be kept for a minimum of two (2) years. [R307-401-8] 
DAQE-AN0104230012-10 

Page 3

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators 

shall, to the extent practicable, maintain and operate any equipment approved under this AO, 

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 Executive Secretary which may include, but is not limited to, monitoring results, opacity 

observations, review of operating and maintenance procedures, and inspection of the source. 

All maintenance performed on equipment authorized by this AO shall be recorded. 

[R307-401-4] 

I.6 The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. 

[R307-150] 

I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Unavoidable 

Breakdowns. [R307-107] 

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment: 

II.A.1 Brick and Tile Manufacturing Plant 

The operation includes raw materials (clays) storage, crushing/blending operations, and three 

natural gas-fired kilns used to fire the products. 

II.A.2 Line #1 

Tunnel Kiln #1 

II.A.3 Line #3 

A. Line #3 kiln with packed tower scrubber and mist eliminator 

 Scrubber air flow - 60,000 Actual Cubic Feet per Minute (ACFM) 

B. Line 3 baghouse - MikroPul 

II.A.4 Line #4 

A. Line #4 kiln 

 Wet scrubber and mist eliminator 

 Scrubber air flow - 89,800 ACFM 

B. Line #4 vacuum cleaner 

C. Line #4 shapes dryer 

D. Line #4 baghouse - MikroPul 
DAQE-AN0104230012-10 

Page 4

II.A.5 Grizzly Hopper 

II.A.6 Primary and Secondary Crushers 

A. Primary crusher with baghouse 

 Crusher manufacturer - Stedman 

 Crusher capacity rating - 100 ton per hour 

 Baghouse manufacturer - MikroPul 

 Baghouse type - Pulse jet 

 Filter media - 16 oz. Polyester felt or polytetrafluoroethylene (PTFE) membrane 

 or equivalent 

 Maximum Air-to-Cloth ratio - 8:1 

 Minimum pressure drop for polyester felt - 2" water gage (w.g.) 

 Minimum pressure drop for PTFE membrane- 0.4" w.g. 

B. Secondary crusher/grinding 

C. Screens 

II.A.7 Silos 

Two lime silos 

II.A.8 Clay Storage Piles 

II.A.9 Miscellaneous Diesel Equipment 

II.A.10 Miscellaneous Equipment 

Extruder Vacuum Pumps, Storage Tanks, Vehicle Fueling Tanks, Space Heaters. This 

equipment is listed for informational purposes only. 

II.B Requirements and Limitations 

II.B.1 Limitations and Test Procedures

II.B.1.a The primary crusher building shall be controlled by the primary crusher baghouse at all times 

when the crushing process is being operated. All air from the crusher building shall be routed 

through the baghouse before being exhausted to the atmosphere. [R307-401-8] 

II.B.1.b ISB shall not operate Kiln #1 until the replacement scrubber for Kiln #1 has been approved. 

[R307-401-8] 

II.B.1.c All exhaust air from Kiln #3 shall be routed through the wet scrubber before being vented to 

the atmosphere. [R307-401-8] 
DAQE-AN0104230012-10 

Page 5

II.B.1.d The Kiln #4 wet scrubber shall control process streams from Kiln #4. All exhaust air from 

Kiln #4 shall be routed through the wet scrubber before being vented to the atmosphere. 

[R307-401-8] 

II.B.1.e Emissions to the atmosphere from the indicated emission point shall not exceed the following 

rates and concentrations: 

A. Scrubber Emissions - Tunnel Kiln #3: 

 Pollutant Limits 

 PM10

 (1-hr average) 24.0 lb/hr 

 Annual average* 8.0 lb/hr 

 SO2

 1-hr average 12.0 lb/hr 

 Annual average 6.0 lb/hr 

 NOx

 1-hr average 25.8 lb/hr 

 Annual average 8.6 lb/hr 

 Fluorides 

 1-hr average 5.28 lb/hr 

 Annual average 1.76 lb/hr 

B. Scrubber Emissions - Tunnel Kiln #4: 

 Pollutant Limits 

 PM10

 1-hour average 38.13 lb/hr 

 Annual average * 12.71 lb/hr 

 SO2

 1-hr average 18.0 lbs/hr 

 Annual average 9.0 lbs/hr 

 NOx

 1-hr average 12.48 lbs/hr 

 Annual average 4.16 lbs/hr 

 Fluorides 

 1-hr average 7.2 lbs/hr 

 Annual average 2.4 lbs/hr 
DAQE-AN0104230012-10 

Page 6

* PM10 emission rates expressed as annual averages above for the scrubbers for 

 Kilns #3, and #4 shall be demonstrated by a 3-hr stack test. Should PM10 emissions 

 test at a higher rate than the limits expressed above, ISB shall provide documentation 

 which demonstrates that the limits are being met, on an annual average basis, within 

 30 days of the date of the stack test. The method provided in the documentation shall 

 be verifiable. 

C. Line 3 Baghouse 

 Pollutant Limits 

 PM10 0.16 lbs/hr 0.016 grains/dscf 

D. Line 4 Baghouse 

 Pollutant Limits 

 PM10 0.12 lbs/hr 0.016 grains/dscf 

E. Primary Crusher Baghouse Vent 

 Pollutant Limits 

 PM10/PM2.5 0.20 lbs/hr 0.010 grains/dscf. [R307-401-8] 

II.B.1.f Stack testing to show compliance with the emission limitations stated in the above condition 

(excluding annual average emission rates for SO2) shall be performed as specified below: 

Emission Point Pollutant Testing Test 

 Status Frequency 

Scrubber, Kiln #3 

 PM10 ** @ 

 SO2 ** # 

 NOx ** @ 

 Fluorides ** @ 

Scrubber, Kiln #4 

 PM10 ** @ 

 SO2 ** # 

 NOx ** @ 

 Fluorides ** @ 

Primary Crusher Baghouse 

 PM10 *** @ 

Line 3 Baghouse 

 PM10 * @ 

Line 4 Baghouse 

 PM10 * @ 
DAQE-AN0104230012-10 

Page 7

Testing Status (To be applied above) 

* Initial compliance testing has been performed. 

** Initial compliance testing was performed on August 23-25, 2005. If the packing type 

and/or quantity of packing used in each scrubber is changed, then an initial 

compliance test shall be performed within 60 days of the change. 

 If the clay type and/or clay source is changed, then the initial compliance testing shall 

 be performed within 60 days of the change. 

*** A compliance test shall be performed as soon as possible and in no case later than 

 180 days after the date of this AO. The Executive Secretary shall be notified at least 

 30 days prior to conducting any testing. A source test protocol shall be submitted to 

 DAQ when the testing notification is submitted to the Executive Secretary. If the 

 filter media type used in the baghouse is changed, then an initial compliance 

 test shall be performed within 60 days of the change. 

 The source test protocol shall be approved by the Executive Secretary 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 Executive Secretary. 

@ Test every five years. 

# Test required every year after initial compliance test. [R307-401-8] 

A. Notification 

 The applicant shall provide a notification of the test date at least 30 days before 

 the test. A pretest conference shall be held if directed by the Executive Secretary. 

 It shall be held at least 15 days before the test between ISB, the tester, and the 

 Executive Secretary. The emission point shall be designed to conform to the 

 requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety and 

 Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) 

 approvable access shall be provided to the test location. 

B. PM10 emission limits shall use the following methods: 

 For stacks in which no liquid drops are present, the following methods shall be used: 

 40 CFR 51, Appendix M, Methods 201 or 201a. The back half condensibles shall also

 be tested using the method specified by the Executive Secretary. All particulate 

 captured shall be considered PM10. 

 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, or 5e 

 as appropriate. The back half condensibles shall also be tested using the method 

 specified by the Executive Secretary. The portion of the front half of the catch 

 considered PM10 shall be based on information in AP-42, Appendix C or other 

 data acceptable to the Executive Secretary. 
DAQE-AN0104230012-10 

Page 8

 The back half condensibles shall not be used for compliance demonstration but 

 shall be used for inventory purposes. 

C. PM2.5 emission limits shall use the following methods: 

 For stacks in which no liquid drops are present, the following methods shall be used: 

 40 CFR 51, Appendix M, Methods 201a or other methods approved by the Executive 

 Secretary. The back half condensibles shall also be tested using the method 

 specified by the Executive Secretary. All particulate captured shall be considered 

 PM2.5. 

 The back half condensibles shall not be used for compliance demonstration but 

 shall be used for inventory purposes. 

D. SO2

 40 CFR 60, Appendix A, Method 6, 6A, 6B or 6C 

E. NOx

 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D or 7E 

F. Fluorides (as Total Fluorides) 

 40 CFR 60, Appendix A, Method 13B 

G. Volumetric Flow Rate 

 40 CFR 60, Appendix A, Method 2 

H. Calculations 

 To determine mass emission rates (lbs/hr, etc.), the pollutant concentration 

 as determined by the appropriate methods above shall be multiplied by the 

 volumetric flow rate and any necessary conversion factors determined by 

 the Executive Secretary to give the results in the specified units of the 

 emission limitation. [R307-401-8] 

I. New Source Operation 

 For a new source/emission point, the production rate during all compliance testing 

 shall be no less than 90% of the production rate listed in this AO. If the maximum 

 AO allowable production rate has not been achieved at the time of the test, the 

 following procedure shall be followed: 

 1) Testing shall be at no less than 90% of the production rate achieved to date. 

 2) If the test is passed, the new maximum allowable production rate shall be 

 110% of the tested achieved rate. This new allowable maximum production 

 rate shall remain in effect until successfully tested at a higher rate. 
DAQE-AN0104230012-10 

Page 9

 3) ISB shall request a higher production rate when necessary. 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 AO 

 production rate is achieved. 

J. Existing Source Operation 

 For a source/emission point, the production rate during compliance testing shall be 

 no less than 90% of the maximum allowable production rate listed in this AO. If 

 the maximum allowable production rate cannot be achieved at the time of the test, 

 the following procedure shall be followed: 

 1) Testing shall be at no less than 90% of the anticipated annual production rate. 

 2) If the test demonstrates compliance with the limits listed in Condition 

 II.B.1.e, the maximum allowable production rate shall be 110% of the 

 rate achieved during the latest test. 

 3) If a higher production rate is necessary, upon notification to the Executive 

 Secretary, ISB may increase production to 110% of the highest tested 

 rate that demonstrates compliance with the limits listed in Condition 

 II.B.1.e. [R307-401-8] 

II.B.1.g Compliance with annual average limitations listed in Condition II.B.1.e for SO2, and total 

fluorides (fluorides) shall be determined through a method of mass balance. If ISB submits 

any additional revised mass balance methods for determining annual emissions to the 

Executive Secretary for approval, the plan shall include, at a minimum, the following: 

A. Proposed test methods and test frequency for determining the weight of the elemental 

 sulfur and fluorides contained in the clays used to manufacture brick 

B. Proposed test methods and test frequency for determining the weight of the elemental 

 sulfur and fluorides contained in the finished product 

C. A method of determining scrubber efficiencies as an annual average 

D. Calculation method of determining annual emissions of SO2 and total fluorides which 

 will demonstrate compliance with the annual average emission rate(s) listed in 

 Condition #II.B.1.e of this AO. 

Calculations of SO2, and fluoride emissions shall be determined on an annual basis. Annual 

emission calculations of SO2 and fluorides shall be submitted to the Executive Secretary by 

February 28th of the following year. 

ISB shall determine the annual SO2 and fluoride emissions using the most current approved 

mass balance plan. A copy of the mass balance plan that has been approved by DAQ is 

attached to the NOI information submitted to DAQ on October 13, 2009. 
DAQE-AN0104230012-10 

Page 10

ISB shall provide a notification of the scrubber efficiency test date at least 30 days before the 

tests are performed for the mass balance plan. A pretest conference shall be held if directed by 

the Executive Secretary. It shall be held at least 15 days before the test and involve ISB, the 

tester, and the Executive Secretary or the Executive Secretary's designated representative. The 

emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, 

Method 1, and OSHA or MSHA approvable access shall be provided to the test location. 

[R307-401-8] 

II.B.1.h The following limitations shall not be exceeded: 

A. Plant wide production/consumption limits 

 1) 2,880 tons raw clay consumption per 24-hours 

 2) 512,582 tons of brick produced per rolling 12-month period. 

B. Tunnel Kiln #1 (Not operational until scrubber is online) 

 13.62 tons per hour averaged over a rolling 24-hour period 

C. Tunnel Kiln #3 

 17.92 tons per hour averaged over a rolling 24-hour period 

D. Tunnel Kiln #4 

 26.97 tons per hour averaged over a rolling 24-hour period 

E. Clay Prep for Line 3 not Including Kiln # 3 

 6,240 hours of operation per rolling 12-month period 

F. Clay Prep for Line 4 not Including Kiln # 4 

 6,240 hours of operation per rolling 12-month period 

To determine compliance with a rolling 12-month total ISB shall calculate a new 12-month 

total by the twentieth day of each month using data from the previous 12 months. Records of 

consumption, production and or hours of operation shall be kept for all periods when the plant 

is in operation. Production/consumption shall be determined by operator logs. The records of 

consumption/production shall be kept on a daily basis. Hours of operation shall be determined 

by monitoring and maintaining an operations log. [R307-401-8] 

II.B.1.i Visible emissions from the following emission points shall not exceed the following values: 

A. All screens - 10% opacity 

B. All conveyor transfer points - 10% opacity 

C. All baghouses - 10% opacity 

D. All buildings enclosing crushers - 10% opacity 
DAQE-AN0104230012-10 

Page 11

E. All crushers - 15% 

F. All other points - 20% opacity 

Opacity observations of emissions from stationary sources shall be conducted according to 40 

CFR 60, Appendix A, Method 9. 

For sources that are subject to NSPS, opacity shall be determined by conducting observations 

in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. [R307-401-8] 

II.B.1.j The moisture content of the clay shall be maintained at an average of no less than 4.0% by 

weight. The moisture content shall be tested if directed by the Executive Secretary using the 

appropriate ASTM method. [R307-401-8] 

II.B.1.k The storage piles shall be watered to minimize generation of fugitive dusts as dry conditions 

warrant or as determined necessary by the Executive Secretary. [R307-401-8] 

II.B.2 Fuels

II.B.2.a ISB shall use natural gas as a fuel and propane as a backup fuel in the kilns. [R307-401-8] 

II.B.3 Monitoring - General Process

II.B.3.a ISB shall install, calibrate, maintain, and operate a monitoring device for the continuous 

measurement of the change in pressure of the gas stream through the baghouse and scrubbers. 

A. The minimum pressure drop in inches/w.g., for the baghouse and scrubbers 

 shall be as follows: 

 1) Primary crusher baghouse 

 with polyester felt 2.0 

 with PTFE membrane 0.4 

 2) Kiln 3 scrubber 0.1 

 3) Kiln 4 scrubber 2.0 

 The monitoring device must be certified by the manufacturer to be accurate within 

 plus or minus five percent of the w.g. design measuring device and must be calibrated 

 on an annual basis in accordance with the manufacturer's instructions. When the 

 scrubber(s) are in operation, the pressure drop shall be within the limits specified 

 above except during start-up and shut-down of the scrubber(s). When the primary 

 crusher baghouse is in operation, the pressure drop shall be within the limits 

 specified above, except during a period of ten crusher operating days following the 

 filter media replacement. 
DAQE-AN0104230012-10 

Page 12

B. Monitoring 

 Once per operating day for each scrubber, ISB shall verify that the differential 

 pressure is within the permitted range. All pressure gauges shall be located such 

 that an inspector/operator can safely read the indicator at any time. 

C. Record Keeping 

 Results of the change in pressure shall be recorded on a daily basis. Continuous 

 recording for the monitoring device is not required. [R307-401-8] 

II.B.3.b ISB shall install, calibrate, maintain, and operate a monitoring device for the continuous 

measurement of the pH of the scrubbing solution of the gas stream through each scrubber. 

A. The pH range for the scrubbers shall be as follows: 

 1) Kiln 3 5-9 

 2) Kiln 4 5-9 

 The monitoring device must be certified by the manufacturer to be accurate within 

 plus or minus five percent of the design pH and must be calibrated on an annual 

 basis in accordance with the manufacturer's instructions. When the scrubber(s) 

 are in operation, the pH shall be within the ranges specified above except during 

 start-up and shut-down of the scrubber(s). 

B. Monitoring 

 Once per operating day for each scrubber, ISB shall verify that the pH is within 

 the permitted range. If a meter is used, it shall be located such that an 

 inspector/operator can safely read the indicator at any time. 

C. Record Keeping 

 Results of the pH shall be recorded on a daily basis. Continuous recording for 

 the monitoring device is not required. [R307-401-8] 

II.B.3.c ISB shall install, calibrate, maintain, and operate a monitoring device for the continuous 

measurement of the flow rate of the scrubbing solution of the gas stream through each 

scrubber. 

A. The minimum scrubbing liquid flow rate in gallons per minute (gpm), for the 

scrubbers shall be as follows: 

 1) Kiln 3 200 

 2) Kiln 4 600 
DAQE-AN0104230012-10 

Page 13

 The monitoring device must be certified by the manufacturer to be accurate within 

 plus or minus five percent of the design scrubbing liquid flow rate and must be 

 calibrated on an annual basis in accordance with the manufacturer's instructions. 

 When the scrubber(s) are in operation, the scrubbing liquid flow rate shall be no less 

 than the flow rates specified above except during start-up and shut-down of the 

 scrubber(s). 

B. Monitoring 

 Once per operating day for each scrubber, ISB shall verify that the liquid flow rate 

 is within the permitted range. All flow gauges shall be located such that an 

 inspector/operator can safely read the indicator at any time. 

C. Record Keeping 

 Results of the scrubbing liquid flow rate shall be recorded on a daily basis. 

 Continuous recording for the monitoring device is not required. [R307-401-8] 

II.B.4 VOC and HAP Limitations

II.B.4.a The plant-wide emissions of VOCs from the brick manufacturing plant and associated 

operations shall not exceed 150.9 tons per rolling 12-month period for VOCs. 

Compliance with the limitation shall be determined on a rolling 12-month total. Based on the 

twentieth day of each month, a new 12-month total shall be calculated using data from the 

previous 12 months. 

The VOC emissions shall be determined by maintaining a record of VOC-emitting materials 

used each month. The record shall include the following data for each material used: 

A. Name of the VOC-emitting material, such as: paint, adhesive, solvent, thinner, 

 reducers, chemical compounds, toxics, isocyanates, etc. 

B. Density of each material used (pounds per gallon) 

C. Percent by weight of all VOC in each material used 

D. Gallons of each VOC-emitting material used 

E. The amount of VOC emitted monthly by each material used shall be calculated by 

 the following procedure: 

 VOC = % VOC by Weight x [Density ( lb )] x Gal Consumed x 1 ton 

 (100) (gal) 2000 lb 

F. The amount of VOC emitted monthly from all materials used. 
DAQE-AN0104230012-10 

Page 14

G. The amount of VOCs reclaimed for the month shall be similarly quantified and 

 subtracted from the quantities calculated above to provide the monthly total 

 VOC emissions. [R307-401-8] 

II.B.4.b The plant-wide emissions of HAPs from the brick manufacturing plant and associated 

operations shall not exceed: 

7.2 tons per rolling 12-month period for HCl 

6.7 tons per rolling 12-month period for HF 

7.0 tons per rolling 12-month period for miscellaneous HAPs 

18.2 tons per rolling 12-month period for all HAPs combined 

Compliance with the limitation shall be determined on a rolling 12-month total. Based on the 

twentieth day of each month, a new 12-month total shall be calculated using data from the 

previous 12 months. 

Compliance with HF and HCl limitations listed above shall be determined through a method of 

mass balance. The mass balance plan approved by the Executive Secretary was submitted by 

ISB on October 22, 2009. If ISB submits any additional revised mass balance methods for 

determining annual emissions to the Executive Secretary for approval, the plan shall include, 

at a minimum, the following: 

A. Proposed test methods and test frequency for determining the weight of the 

 elemental fluorine contained in the clays used to manufacture brick 

B. Proposed test methods and test frequency for determining the weight of the 

 elemental fluorine contained in the finished product 

C. Calculation method of determining emissions of HCL and HF which will 

 demonstrate compliance with the HCl and HF emission limitations listed above. 

The miscellaneous HAP emissions shall be determined by maintaining a record of HAPemitting materials used each month. The record shall include the following data for each 

material used: 

D. Name of the HAP-emitting material, such as: paint, adhesive, solvent, thinner, 

 reducers, chemical compounds, toxics, isocyanates, etc. 

E. Density of each material used (pounds per gallon) 

F. Percent by weight of all HAP in each material used 

G. Gallons of each HAP-emitting material used 

H. The amount of HAP emitted monthly by each material used shall be calculated by 

 the following procedure: 

 HAP = % HAP by Weight x [Density ( lb )] x Gal Consumed x 1 ton 

 (100) (gal) 2000 lb 
DAQE-AN0104230012-10 

Page 15

I. The amount of HAPs emitted monthly from all materials used. 

J. The amount of HAPs reclaimed for the month shall be similarly quantified and 

 subtracted from the quantities calculated above to provide the monthly total VOC 

 emissions. [R307-401-8] 

PERMIT HISTORY

This AO is based on the following documents: 

Incorporates Additional Information dated August 26, 2010 

Incorporates Additional Information dated June 28, 2010 

Incorporates Additional Information dated May 20, 2010 

Incorporates Additional Information dated May 4, 2010 

Incorporates Additional Information dated March 8, 2010 

Incorporates Additional Information dated January 12, 2010 

Incorporates Additional Information dated November 19, 2009 

Incorporates Additional Information dated October 13, 2009 

Incorporates Additional Information dated October 7, 2009 

Incorporates Additional Information dated September 8, 2009 

Incorporates Additional Information dated August 6, 2009 

Incorporates Notice of Intent dated July 2, 2009 

Supersedes DAQE-AN0104230008-08 dated November 12, 2008 

ADMINISTRATIVE CODING

The following information is for UDAQ internal classification use only: 

Salt Lake County 

CDS A 

Nonattainment or Maintenance Area, PM10 SIP / Maint Plan, Title V (Part 70) Major source 
DAQE-AN0104230012-10 

Page 16

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this 

document: 

40 CFR Title 40 of the Code of Federal Regulations 

AO Approval Order 

BACT Best Available Control Technology 

CAA Clean Air Act 

CAAA Clean Air Act Amendments 

CDS Classification Data System (used by EPA to classify sources by size/type) 

CEM Continuous emissions monitor 

CEMS Continuous emissions monitoring system 

CFR Code of Federal Regulations 

CO Carbon monoxide 

CO2 Carbon Dioxide 

CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 

COM Continuous opacity monitor 

DAQ Division of Air Quality (typically interchangeable with UDAQ) 

DAQE This is a document tracking code for internal UDAQ use 

EPA Environmental Protection Agency 

GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) 

GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) 

HAP or HAPs Hazardous air pollutant(s) 

ITA Intent to Approve 

LB/HR Pounds per hour 

MACT Maximum Achievable Control Technology 

MMBTU Million British Thermal Units 

NAA Nonattainment Area 

NAAQS National Ambient Air Quality Standards 

NESHAP National Emission Standards for Hazardous Air Pollutants 

NOI Notice of Intent 

NOx Oxides of nitrogen 

NSPS New Source Performance Standard 

NSR New Source Review 

PM10 Particulate matter less than 10 microns in size 

PM2.5 Particulate matter less than 2.5 microns in size 

PSD Prevention of Significant Deterioration 

PTE Potential to Emit 

R307 Rules Series 307 

R307-401 Rules Series 307 - Section 401 

SO2 Sulfur dioxide 

Title IV Title IV of the Clean Air Act 

Title V Title V of the Clean Air Act 

TPY Tons per year 

UAC Utah Administrative Code 

UDAQ Utah Division of Air Quality (typically interchangeable with DAQ) 

VOC Volatile organic compounds