DAQ-2024-007886

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DAQC-CI104280003-24
Site ID 10428 (B1)

MEMORANDUM

TO: FILE – GREENFIBER SALT LAKE CITY INCORPORATED – Cellulose
Insulation Production Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Irene Tucker, Environmental Scientist

DATE: April 16, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: April 4, 2024

SOURCE LOCATION: 3061 South 3600 West
West Valley City, UT 84119

SOURCE CONTACT: Garrett Humphreys, Plant Manager, 801-972-6551 Ext. 5103
[e-mail]

OPERATING STATUS: GreenFiber was conducting a Planned Maintenance activity at
the time of this inspection.

PROCESS DESCRIPTION: Produces a fire retardant cellulose insulation. The process
consists of mixing borax and other fire retardant materials to
shredded paper.

Trucks deliver recycled newspaper/cardboard which is
off-loaded onto a cement floor inside the building. A front-end
loader lifts the paper/cardboard into a hopper where a conveyer
belt delivers the paper to a pre-shredder. The shredded paper is
augured to the hammer mill for grinding. The ground-up paper
then goes into a gravity-fed surge bin and through an attrition
mill. Fire retardant chemicals are transferred from storage silos
into a hopper and augured through a metering device and blown
into the hammer mill for impregnation with the paper by heat
and friction. A fan then blows the insulation to the bagger
machine for packaging into twenty and thirty pound plastic bags.
The bagged product is hand palletized and moved by forklifts to
transport trucks and trailers.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN104280011-21, dated
August 25, 2021

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

GreenFiber Salt Lake City Incorporated
Cellulose Insulation Production Plant

3061 South 3600 West 3061 South 3600 West
West Valley City, UT 84119 West Valley City, UT 84119

SIC Code: 2679: (Converted Paper & Paperboard Products, NEC)

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 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]

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]

Status: In Compliance. GreenFiber did not exceed any limits set forth by this AO.
GreenFiber maintains records for at least two years and also records of maintenance
activities performed on equipment approved by this AO. GreenFiber indicated that there
has been no breakdown of equipment resulting in an emissions event. According to the
SLEIS Database, GreenFiber is not required to submit an Emissions Inventory Record at
this time.

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SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Cellulose Insulation Production Plant:

II.A.2 Front End Loaders
Listed for informational purposes only

II.A.3 One (1) Paper Hopper

II.A.4 One (1) Pre-shredder Hammer Mill

II.A.5 One (1) Hammer Mill

II.A.6 Cyclone Separator #1
Venting though Baghouse #1, #2, and #3

II.A.7 Cyclone Separator #2
Venting through Baghouse #4 and #5

II.A.8 Two (2) Collection/Metering Bins

II.A.9 Two (2) Attrition Mills

II.A.10 One (1) Bagger

II.A.11 One (1) Conveyor

II.A.12 Two (2) Metering Hoppers

II.A.13 Two (2) Blenders

II.A.14 One (1) Grinder

II.A.15 Seven (7) Storage Silos
Each vented to its own dedicated bin vent baghouse

II.A.16 Baghouse #1
Description: Cyclone #1 Baghouse
Location: North side of building #1

II.A.17 Baghouse #2
Description: Cyclone #1 Baghouse
Location: North side of building #1

II.A.18 Baghouse #3
Description: Cyclone #1 Baghouse
Location: North side of building #1

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II.A.19 Baghouse #4
Description: Cyclone #2 Baghouse
Location: North side of building #2

II.A.20 Baghouse #5
Description: Cyclone #2 Baghouse
Location: North side of building #2

II.A.21 Baghouse #6
Description: Fire Retarde System Baghouse
Location: East side of building #1

II.A.22 Bin Vent #1
Description: Material Storage Silo #1 Bin Vent
Location: On top of silo #1

II.A.23 Bin Vent #2
Description: Material Storage Silo #2 Bin Vent
Location: On top of silo #2

II.A.24 Bin Vent #3
Description: Material Storage Silo #3 Bin Vent
Location: On top of silo #3

II.A.25 Bin Vent #4
Description: Material Storage Silo #4 Bin Vent
Location: On top of silo #4

II.A.26 Bin Vent #5
Description: Material Storage Silo #5 Bin Vent
Location: On top of silo #5

II.A.27 Bin Vent #6
Description: Material Storage Silo #6 Bin Vent
Location: On top of silo #6

II.A.28 Bin Vent #7
Description: Material Storage Silo #7 Bin Vent
Location: On top of silo #7

Status: In Compliance. There was no new or unapproved equipment observed onsite
during this inspection. GreenFiber was conducting Planned Maintenance and noted
that Cyclone #1 Baghouse in AO Condition II.A.16 and Baghouse #6 in AO Condition
II.A.21 have not been in operation for a while.

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Cellulose Insulation Production Plant:
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II.B.1.a The owner/operator shall not produce more than 87,000 tons of cellulose insulation per rolling
12-month period. [R307-401-8]

II.B.1.a.1 The owner/operator shall:

A. Determine production by production tracking logs and/or billing records

B. Record production on a daily basis

C. Use the production data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months. [R307-401-8]

Status: In Compliance. In a rolling 12-month from April 2023 to March 2024, 28,896.37
tons of cellulose insulation were produced. The production was determined from
production tracking logs and from daily production records. See the attachment for
additional information.

II.B.1.b The owner/operator shall not allow visible emissions from any stationary point or fugitive
emission source associated with the source or with the control facilities to exceed 10% opacity.
[R307-201-3]

II.B.1.b.1 Opacity observations of emission from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9. [40 CFR 60 Subpart A, R307-401-8]

Status: Compliance Undetermined. During this inspection, GreenFiber was conducting a
Planned Maintenance activity.

II.B.2 Baghouses & Bin Vents

II.B.2.a The owner/operator shall ensure that each cyclone separator or fabric filter baghouse shall
control the process streams as indicated in Section II.A of this AO. All exhaust air from each
process stream shall be routed through the identified fabric filter baghouse before being vented to
the atmosphere. [R307-401-8]

Status: In Compliance. GreenFiber confirmed that when the plant is in operation, each
cyclone separator or fabric filter baghouse control the process streams as indicated in
Section II.A of this AO. In addition, all exhaust air from each process stream is routed
through the identified fabric filter baghouse before being vented to the atmosphere.

II.B.2.a.1 The owner/operator shall ensure that the fabric filters installed in each baghouse have a porosity
of 0.5 micrometers or use equivalent technology as determined by the Director. [R307-401-8]

Status: In Compliance. GreenFiber confirmed that the fabric filters installed in each
baghouse meets the manufacturer’s required porosity of 0.5 micrometers as required by
this AO Condition.

II.B.2.b The owner/operator shall ensure that all bin vent and baghouse exhaust stacks discharge
vertically, unrestricted by any attachment. [R307-401-8]

Status: In Compliance. During this inspection, the bin vent and baghouse exhaust stacks
were observed to be vertical and unrestricted.
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II.B.2.b.1 Each bin vent exhaust stack exit shall be at least 50 feet in elevation and each baghouse exhaust
stack exit shall be at least 35 feet in elevation, as measured from ground level. [R307-401-8]

Status: In Compliance. During this inspection, GreenFiber confirmed that each bin vent
exhaust stack exit and each baghouse exhaust stack exit met the elevation requirements of
this AO Condition.

II.B.2.c The owner/operator shall install a manometer or magnehelic pressure gauge on each baghouse to
measure the differential pressure across its fabric filters. [R307-401-8]

II.B.2.d The owner/operator shall ensure that the static pressure differential across the fabric filters is
between 2 to 6 inches of water column. [R307-401-8]

II.B.2.d.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. The reading shall be accurate to within plus or minus 1.0 inches of water column.
The instrument shall be calibrated against a primary standard annually. The primary standard
shall be established by the company, and shall be submitted to the Director for approval.
Intermittent recording of the reading is required on a once per operational day basis.
[R307-401-8]

Status: In Compliance. Four Magnehelic Gauges were observed during this inspection.
Because GreenFiber was conducting Planned Maintenance, all four gauges read zero.
Differential pressure readings recorded when the plant is in operation, indicated
compliance with this AO Condition. The Annual Calibration for the Magnehelic Gauges
were conducted on May 15, 2023. See the attachment for additional information.

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.

Status: Not Applicable. There are no Federal rules applicable to the processes of this facility.

AREA SOURCE RULES EVALUATION

The following Area Source Rules were evaluated during this inspection:

R307-305:Nonattainment and Maintenance Areas for PM10: Emission Standards

Status: Compliance Undetermined. During this inspection, GreenFiber was conducting a Planned
Maintenance activity.

R307-309: Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive
Dust

Status: Compliance Undetermined. During this inspection, GreenFiber was conducting a Planned
Maintenance activity.
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R307-325: Ozone Nonattainment and Maintenance Areas: General Requirements

Status: In Compliance. During this inspection, GreenFiber was conducting a Planned
Maintenance activity with no operation of processes or process equipment. GreenFiber has a
Safety Kleen Parts-Washer. During this inspection the Parts-Washer was closed. According to
GreenFiber, the Safety Kleen Premium Solvent is used to clean metal parts. The spent solvent is
transported for offsite disposal by Safety Kleen. See the SDS in the attachment.

R307-335:Degreasing

Status: In Compliance. During this inspection, GreenFiber was conducting a Planned
Maintenance activity with no operation of processes or process equipment. GreenFiber has a
Safety Kleen Parts-Washer. During this inspection the Parts-Washer was closed.

EMISSION INVENTORY:

Status: Not Applicable. According to the SLEIS Database, GreenFiber is not required to submit an
Emissions Inventory Record at this time.

The emissions listed below are an estimate of the total potential emissions (PTE) from GreenFiber Salt
Lake City Incorporated- Cellulose Insulation Production Plant on the Approval Order (AO)
DAQE-AN104280011-21, dated August 25, 2021. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
Particulate Matter - PM10 4.50
Particulate Matter - PM2.5 4.50

Hazardous Air Pollutant PTE lbs/yr

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: GreenFiber is in compliance with the conditions of the Approval
Order (AO) DAQE-AN104280011-21, dated August 25, 2021.
GreenFiber maintains good housekeeping practices. GreenFiber
is aware of the Small Source Exemption criteria since the PTE of
this AO is less than 5 tons/year, but would like to leave things as
they are for now.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Required PPE includes Steel-Toe Boots,
Reflective Safety Vest, Ear Plugs, and Safety Glasses.

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NSR RECOMMENDATIONS: Consider adding the Parts Washer to the equipment list.

Evaluate for removal from the Equipment List Cyclone #1
Baghouse in AO Condition II.A.16 and Baghouse #6 in AO
Condition II.A.21 from this AO, as they are no longer
operational.

ATTACHMENTS: Applicable Supporting Documentation Included