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DAQE-IN107060043-14

October 9, 2014


Audy Snodgrass
Dugway Proving Ground
Department of the Army
IMDU-ZA
Dugway, UT 84022-5000

Dear Mr. Snodgrass :

Re: Intent to Approve: New Jack Rabbit Research and Development Program at the Dugway Proving
Ground
Project Number: N10706-0043

The attached document is the Intent to Approve for the above-referenced project. The Intent to Approve
is subject to public review. Any comments received shall be considered before an Approval Order is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an Approval Order. An invoice will follow upon issuance of the final
Approval Order.

Future correspondence on this Intent to Approve 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,



Martin D. Gray, Manager
New Source Review Section

MDG:NM:kw

cc: Mike Owens
Tooele County 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

GARY R. HERBERT
Governor

SPENCER J. COX
Lieutenant Governor


Department of
Environmental Quality

Amanda Smith
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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STATE OF UTAH

Department of Environmental Quality

Division of Air Quality



INTENT TO APPROVE: New Jack Rabbit Research and
Development Program at the Dugway Proving Ground



Prepared by: Nando Meli Jr., Engineer
Phone: (801) 536-4052
Email: nmeli@utah.gov



INTENT TO APPROVE NUMBER

DAQE-IN107060043-14



Date: October 9, 2014



Dugway Proving Ground
U.S. Army-Dugway Proving Ground
Source Contact:
Jeffrey Elkins
Phone: (435) 831-3218





Martin D. Gray, Manager
New Source Review Section

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ABSTRACT

Dugway Proving Ground (DPG), a United States Army installation, is responsible for testing chemical
and biological defense systems. DPG is requesting approval to conduct the Jack Rabbit Research and
Development (R&D) program. This program will study the rapid large-scale release of pressurized,
liquefied toxic inhalation hazard (TIH) gases from railcar or other similar transports. The testing duration
will be approximately two years. The goal of the Jack Rabbit R&D program is to 1) improve the
understanding of rapid large-scale releases of pressurized liquefied TIH gases from railcar or other
transports, 2) study a mock urban environment to measure how much of the chemical infiltrates buildings,
cars, and military vehicles, 3) calibrate and refine predictive air models with near-real time data, 4) look
at reactivity with soil and vegetation, and 5) update Emergency Responders Guidelines.

DPG is located in the portion of Tooele County that is classified as an attainment area for all criteria
pollutants. The NSPS 40 CFR 60 Subpart A, and IIII, and the MACT 40 CFR 63 Subpart A, ZZZZ
regulations apply to DPG and stationary engines at the Jack Rabbit R&D test site. Title V of the 1990
Clean Air Act Amendments applies to this source. Within 12 months after becoming a major HAP source
for the Jack Rabbit R&D, DPG will be required to submit a Title V application for the Jack Rabbit R&D
program. The increase in standalone PTE emissions for the Jack Rabbit R&D program are as follows in
TPY: PM
10
(including PM
2.5
) = 5.0, PM
2.5
= 2.5, NO
x
= 10.0, SO
2
= 1.5, CO = 8.5, CO
2
e = 5,467.00,
VOC = 1.0 and HAPs = 370.15.

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director of the Utah
Division of Air Quality.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Tooele Transcript on October 16, 2014. During the public
comment period the proposal and the evaluation of its impact on air quality will be available for the
public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as
practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.

Name of Permittee:

Dugway Proving Ground
Department of the Army
IMDU-ZA
Dugway, UT 84022-5000
Permitted Location:

U.S. Army-Dugway Proving Ground
Department of the Army
IMDU-ZA
Dugway, UT 84022-5000


UTM coordinates: 288,070 m Easting, 4,445,670 m Northing, UTM Zone 12
SIC code: 9711 (National Security)




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DAQE-IN107060043-14
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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 Director or Director's representative upon request,
and the records shall include the five-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 five (5) years. [R307-401-8]

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 Director
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: Breakdowns.
[R307-107]

Section II: SPECIAL PROVISIONS

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

II.A.1 Dugway Proving Ground

Jack Rabbit Test Site/Release Points

II.A.2 Generators

A. Diesel-Fired Generators

Four diesel-fired generators with a maximum rating of 25 kw each

One diesel-fired generator with a maximum rating of 125 kw

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B. Gasoline-Fired Generators

25 gasoline-fired generators with a maximum rating of 5 kw each

II.A.3 Miscellaneous Equipment

Poppers with a maximum capacity of 5.0 gallons for wildlife avoidance
Solar powered monitoring equipment
Site preparation equipment

This equipment is listed for informational purposes only.

II.B Requirements and Limitations

II.B.1 Conditions on permitted sources (Source wide)

II.B.1.a Conditions on All Approved Installations

A. Sulfur content of any diesel burned shall be no greater than 15 ppm.

B. DPG shall abide by the most current fugitive dust control plan approved by the
Director for control of all dust sources associated with the Jack Rabbit R&D
Program. This plan shall contain sufficient controls to prevent an increase in
PM
10
emissions above those modeled for this AO. The limitations and conditions
in the fugitive dust control plan shall not be changed without prior approval.

C. All unpaved roads and other unpaved operational areas that are used by mobile
equipment shall be water sprayed and/or chemically treated in accordance with
the fugitive dust control plan. Records of treatment shall be kept on a test day basis.

[R307-401-8]

II.B.1.b Conditions on Diesel-Fired Generators

A. Visible emissions shall be no greater than 20 percent opacity.

B. The consumption of diesel for diesel-fired generators at the Jack Rabbit R&D site
shall be no greater than 1,000 gallons per rolling 12-month period for all emission
units.

[R307-401-8]

II.B.1.c Conditions on Gasoline-Fired Generators

For each affected emission unit, DPG shall not allow, cause or permit the emissions of visible
contaminants except for stationary operation not exceeding 3 minutes in any hour. [R307-401-
8]


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DAQE-IN107060043-14
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II.B.1.d Conditions on Chlorine Testing

A. The Chlorine releases shall be initiated at least 15 km from the boundary of
property comprising DPG or federal land where DPG has an Interservice support
agreement.

B. DPG shall submit a monitoring plan before each calendar year of testing. The
monitoring plan shall include the approximate location of each release monitor.

C. Testing of chlorine shall be only be allowed under the following conditions:

1) Surface wind direction at Jack Rabbit R&D site is less than or equal to
195 degrees or more than 135 degrees

2) Forecasted and measured wind speed greater than or equal to 2 meters per
second (m/s) and

3) Forecasted and measured wind speed less than or equal to 6 m/s.

D. DPG shall submit a weekly test summary (which may include up to
four releases) within 14 days after a release has been concluded.

The results shall include the following:

1) Location of each monitoring station,

2) Summary of the concentrations of chlorine measured (including location
of the sensor measuring the maximum concentration),

3) Wind speed and direction from monitoring stations.

E. If the monitoring test results are greater than or equal to the modeled concentrations
at any monitoring test site located in an area where DPG does not have an
Interagency Agreement for the Jack Rabbit R & D program, then approval from
the Director is required before another test is performed.

F. The maximum release of any chlorine test shall not exceed 90 tons per test.

G. During 2015, no tests shall be performed with a release greater than 10 tons of
chlorine.

H. During 2016, DPG may increase the release amounts if the measured
concentrations from preceding release at each off property monitoring station is
less than 0.02 ppm Cl.





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DAQE-IN107060043-14
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I . DPG shall record the date on which it emits, or has the potential to emit, 10 tons per
year or more of chlorine. DPG shall submit this information along with the weekly
summary required in paragraph (D) of this condition.

[R307-401-8]

Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal
programs have been found to apply to this installation. This AO in no way releases the owner or
operator from any liability for compliance with all other applicable federal, state, and local
regulations including UAC R307.

NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Title V (Part 70) major source


PERMIT HISTORY

The final AO will be based on the following documents:

Incorporates Additional Information dated September 22, 2014
Incorporates Additional Information dated September 10, 2014
Incorporates Additional Information dated August 12, 2014
Incorporates Additional Information dated July 12, 2014
Incorporates Additional Information dated May 29, 2014
Incorporates Additional Information dated May 8, 2014
Incorporates Additional Information dated May 7, 2014
Is Derived From NOI dated April 3, 2014

ADMINISTRATIVE CODING

The following information is for UDAQ internal classification use only:

Tooele County
CDS A
MACT (Part 63), Title V (Part 70) major source, Attainment Area, NSPS (Part 60),

DAQE-IN107060043-14
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ACRONYMS

The following lists commonly used acronyms 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
CMS Continuous monitoring system
CO Carbon monoxide
CO
2
Carbon Dioxide
CO
2
e 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
FDCP Fugitive Dust Control Plan
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
NO
x
Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM
10
Particulate matter less than 10 microns in size
PM
2.5
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
SO
2
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
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