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Home My WebLink AboutDAQ-2024-007473 DAQE-AN116910015-24 {{$d1 }} Chris King Mondi Bags USA, LLC 2357 South 900 West Salt Lake City, UT 84119 chris.king@mondigroup.com Dear Mr. King: Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN116910013-20 for a Reduction in Air Pollutants under R307-401-12 Project Number: N116910015 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on January 8, 2024. Mondi Bags USA, LLC must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Dungan Adams, who can be contacted at (385) 290-2474 or dunganadams@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:DA:jg cc: Salt Lake 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 SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director March 25, 2024 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN116910015-24 Administrative Amendment to Approval Order DAQE-AN116910013-20 for a Reduction in Air Pollutants under R307-401-12 Prepared By Dungan Adams, Engineer (385) 290-2474 dunganadams@utah.gov Issued to Mondi Bags USA, LLC - Salt Lake City Bag Manufacturing Plant Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality March 25, 2024 TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 4 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 6 PERMIT HISTORY ..................................................................................................................... 7 ACRONYMS ................................................................................................................................. 8 DAQE-AN116910015-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Mondi Bags USA, LLC Mondi Bags USA, LLC - Salt Lake City Bag Manufacturing Plant Mailing Address Physical Address 2357 South 900 West 2357 South 900 West Salt Lake City, UT 84119 Salt Lake, UT 84119 Source Contact UTM Coordinates Name: Chris King 422,600 m Easting Phone: (801) 514-0615 4,508,000 m Northing Email: chris.king@mondigroup.com Datum NAD83 UTM Zone 12 SIC code 2759 (Commercial Printing, NEC) SOURCE INFORMATION General Description Mondi Bags USA, LLC (Mondi) operates a multiwall bag manufacturing facility in Salt Lake City. The facility receives raw printing materials, including printing stock and plastic film. An outer layer of paper is printed with water-based inks, adhesives, and lacquers applied through a flexographic printing press before it is laminated, perforated, and formed into tubes. Adhesive is applied before the tubes are sent to a bottomer that forms a bag. This final product is then palletized, stored, and shipped to customers. NSR Classification Administrative Amendment Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA Salt Lake County Airs Source Size: B Applicable Federal Standards None DAQE-AN116910015-24 Page 4 Project Description Mondi has requested to replace their Windmoeller & Hoelscher Astraflex Printing Press with a Soma Optima 2 Printing Press. Mondi has also requested to remove the 18 MMBtu/hr natural gas-fired boiler emissions from the site-wide potential to emit (PTE) as the boiler is non-operational. These equipment updates will reduce all site-wide emissions and qualify for a reduction in air pollutants under R307-401-12. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent -9958 1693.00 Carbon Monoxide -6.93 1.18 Nitrogen Oxides -8.25 1.41 Particulate Matter - PM10 -0.63 0.10 Particulate Matter - PM2.5 -0.63 0.10 Sulfur Dioxide -0.05 0.01 Volatile Organic Compounds -0.46 10.87 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Acrylic Acid (CAS #79107) 0 42 Generic HAPs (CAS #GHAPS) -320 46 Glycol Ethers (CAS #EDF109) 0 360 Hydroquinone (CAS #123319) 0 412 Methanol (CAS #67561) 0 154 Methyl Methacrylate (CAS #80626) 0 16 Styrene (CAS #100425) 0 26 Vinyl Acetate (CAS #108054) 0 2884 Change (TPY) Total (TPY) Total HAPs -0.16 1.97 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] DAQE-AN116910015-24 Page 5 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 UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Bag Printing Facility II.A.2 One (1) Flexographic Printing Press Make: Soma Model: Optima 2 1300-1270-8 WGM One (1) attached burner rated 0.4 MMBtu/hr II.A.3 One (1) Flexographic Printing Press Make: Windmoeller & Hoelscher Model: Miraflex Eight (8) color printers Three (3) attached dryers rated 0.2, 0.4 and 0.6 MMBtu/hr each. II.A.4 Two (2) Ancillary Equipment Lines Ancillary equipment includes tubers with inline tail-end printers. II.A.5 One (1) Flexographic Plate Machine Controls: integrated catalytic oxidizer II.A.6 One (1) Natural Gas-Fired Boiler Non-operational Rating: 18 MMBtu/hr *listed for informational purposes only II.A.7 Various Boilers and Heaters Fuel: Natural Gas Rating: <5MMBtu/hr Each *listed for informational purposes only DAQE-AN116910015-24 Page 6 SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site Wide Conditions II.B.1.a Visible emissions from any stationary point or fugitive emission source associated with the source shall not exceed 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from a stationary source shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [40 CFR 60 Subpart A] II.B.2 VOC & HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 10.81 tons per rolling 12-month period of VOCs. 1.44 tons per rolling 12-month period of Vinyl Acetate. 1.95 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]. HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] DAQE-AN116910015-24 Page 7 II.B.2.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material. B. The maximum percent by weight of VOCs and each HAP in each material used. C. The density of each material used. D. The volume of each VOC- and HAP-emitting material used. E. The amount of VOCs and the amount of each HAP emitted from each material. F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material. G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] II.B.2.b The owner/operator shall use only water-based inks and water-based lacquers in the flexographic printing presses and ancillary equipment lines. [R307-351, R307-401-8] II.B.2.c The facility shall comply with all applicable requirements in R307-351 Graphic Arts. [R307-351] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN116910013-20 dated April 23, 2020 Is Derived From NOI dated January 8, 2024 Incorporates Additional Information dated January 31, 2024 Incorporates Additional Information dated February 27, 2024 DAQE-AN116910015-24 Page 8 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 Environmental Protection Agency 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 CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year 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 VOC Volatile organic compounds DAQE- RN116910015 March 12, 2024 Chris King Mondi Bags USA, LLC 2357 South 900 West Salt Lake City, UT 84119 chris.king@mondigroup.com Dear Chris King, Re: Engineer Review - Administrative Amendment: Administrative Amendment to DAQE-AN116910013-20 for a Reduction in Air Pollutants under R307-401-12 Project Number: N116910015 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. Mondi Bags USA, LLC should complete this review within 10 business days of receipt. Mondi Bags USA, LLC should contact Dungan Adams at (385) 290-2474 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dungan Adams at dunganadams@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If Mondi Bags USA, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Mondi Bags USA, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) 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) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Engineer Review N116910015: Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant March 12, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N116910015 Owner Name Mondi Bags USA, LLC Mailing Address 2357 South 900 West Salt Lake City, UT, 84119 Source Name Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant Source Location 2357 South 900 West South Salt Lake, UT 84119 UTM Projection 422,600 m Easting, 4,508,000 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2759 (Commercial Printing, NEC) Source Contact Chris King Phone Number (801) 514-0615 Email chris.king@mondigroup.com Billing Contact Chris King Phone Number (801) 514-0615 Email chris.king@mondigroup.com Project Engineer Dungan Adams, Engineer Phone Number (385) 290-2474 Email dunganadams@utah.gov Notice of Intent (NOI) Submitted January 8, 2024 Date of Accepted Application February 1, 2024 Engineer Review N116910015: Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant March 12, 2024 Page 2 SOURCE DESCRIPTION General Description Mondi Bags USA (Mondi) operates a multiwall bag manufacturing facility in Salt Lake City. The facility receives raw printing materials including printing stock and plastic film. An outer layer of paper is printed with water-based inks, adhesives, and lacquers applied through a flexographic printing press, before it is laminated, perforated, and formed into tubes. Adhesive is applied before the tubes are sent to a bottomer that forms a bag. This final product is then palletized, stored, and shipped to customers. NSR Classification: Administrative Amendment Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, and Salt Lake County SO2 NAA Salt Lake County Airs Source Size: B Applicable Federal Standards None Project Proposal Administrative Amendment to DAQE-AN116910013-20 for a Reduction in Air Pollutants under R307-401-12 Project Description Mondi Bags USA, LLC (Mondi) has requested to replace their Windmoeller & Hoelscher Astraflex Printing Press with a Soma Optima 2 Printing Press. Mondi has also requested to remove the 18 MMBtu/hr natural gas-fired boiler emissions from the side-wide potential to emit (PTE) as the boiler is non-operational. These equipment updates will reduce all site-wide emissions and qualify for a Reduction in Air Pollutants under R307-401-12. EMISSION IMPACT ANALYSIS No emissions will increase from this equipment replacement. All criteria pollutants are below the modeling thresholds contained in R307-410-4. All HAP emissions are below their respective emission threshold values in R307-410-5. Therefore, no modeling is required for this amendment. [Last updated February 22, 2024] Engineer Review N116910015: Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant March 12, 2024 Page 3 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent -9958 1693.00 Carbon Monoxide -6.93 1.18 Nitrogen Oxides -8.25 1.41 Particulate Matter - PM10 -0.63 0.10 Particulate Matter - PM2.5 -0.63 0.10 Sulfur Dioxide -0.05 0.01 Volatile Organic Compounds -0.46 10.87 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Acrylic Acid (CAS #79107) 0 42 Generic HAPs (CAS #GHAPS) -320 46 Glycol Ethers (CAS #EDF109) 0 360 Hydroquinone (CAS #123319) 0 412 Methanol (CAS #67561) 0 154 Methyl Methacrylate (CAS #80626) 0 16 Styrene (CAS #100425) 0 26 Vinyl Acetate (CAS #108054) 0 2884 Change (TPY) Total (TPY) Total HAPs -0.16 1.97 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N116910015: Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant March 12, 2024 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding Mondi Bags Salt Lake City Bag Manufacturing Plant The project does not increase the potential to emit of any air pollutant or cause emissions of any new air pollutant. Therefore, BACT analysis is not required. [Last updated February 1, 2024] SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): 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 UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307- 150] Engineer Review N116910015: Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant March 12, 2024 Page 5 SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Bag Printing Facility II.A.2 One (1) Flexographic Printing Press Make: Soma Model: Optima 2 1300-1270-8 WGM One (1) attached burner rated 0.4 MMBtu/hr II.A.3 One (1) Flexographic Printing Press Make: Windmoeller & Hoelscher Model: Miraflex Eight (8) color printers Three (3) attached dryers rated 0.2, 0.4 and 0.6 MMBtu/hr each. II.A.4 Two (2) Ancillary Equipment Lines Ancillary equipment includes tubers with inline tail-end printers. II.A.5 One (1) Flexographic Plate Machine Controls: integrated catalytic oxidizer II.A.6 NEW One (1) Natural Gas-Fired Boiler Non-operational Rating: 18 MMBtu/hr *listed for informational purposes only II.A.7 Various Boilers and Heaters Fuel: Natural Gas Rating: <5MMBtu/hr Each *listed for informational purposes only SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site Wide Conditions II.B.1.a Visible emissions from any stationary point or fugitive emission source associated with the source shall not exceed 10% opacity. [R307-401-8] Engineer Review N116910015: Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant March 12, 2024 Page 6 II.B.1.a.1 Opacity observations of emissions from a stationary source shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [40 CFR 60 Subpart A] II.B.2 VOC & HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 10.81 tons per rolling 12-month period of VOCs 1.44 tons per rolling 12-month period of Vinyl Acetate 1.95 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] II.B.2.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] II.B.2.b The owner/operator shall use only water-based inks and water-based lacquers in the flexographic printing presses and ancillary equipment lines. [R307-351, R307-401-8] II.B.2.c The facility shall comply with all applicable requirements in R307-351 Graphic Arts. [R307- 351] Engineer Review N116910015: Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant March 12, 2024 Page 7 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN116910013-20 dated April 23, 2020 Is Derived From NOI dated January 8, 2024 Incorporates Additional Information dated January 31, 2024 Incorporates Additional Information dated February 27, 2024 REVIEWER COMMENTS 1. Comment regarding Reduction in Air Pollutants: The source initially requested a Replacement-in-Kind to replace the Windmoeller & Hoelscher Astraflex printing press with a Soma Optima 2 printing press. The new Soma printing press will have burners with a lower heat input than the printing press it is replacing. This will decrease combustion emissions from the press. However, the Soma press has a greater printing rate than the old press, meaning it could have a greater individual PTE for VOCs and HAPs. Since the potential to emit of the new process equipment is not the same or lower as the old process equipment, this does not qualify as a Replacement-in-Kind under R307-401-11. However, since site-wide VOC and HAP emissions are limited by requirement II.B.2.a, they will not increase due to the replacement. Because the combustion emissions are lower for the new press, site-wide emissions will decrease slightly. The equipment replacement does not increase the potential to emit of any air pollutant or cause emissions of any new air pollutant and qualifies as a Reduction in Air Pollutants under R307-401-12. The Astraflex Printing Press (Condition II.A.3) is replaced by the new Soma Optima 2 Printing Press. The site-wide emission decreases are a result of the Astraflex having three (3) attached dryers rated 0.34, 0.42, and 0.85 MMBtu/hr and the Optima 2 only having one burner rated 0.40 MMBtu/hr. Using AP-42 Tables 1.4-1. 1.4-2, 1.4-3, and 1.4-4, the printing press replacement results in the following PTE reduction (in tons per year): NOx -0.52, CO -0.44, PM -0.04, VOCs -0.03, HAPs - 0.01, CO2e -628. The 18 MMBtu/hr natural gas-fired boiler (Condition II.A.6) is no longer operational and will not be used in the future. The non-operational boiler is still on site and listed in the approved equipment list for informational purposes only. The PTE of the boiler is considered to be zero for all emissions. Using AP-42 Tables 1.4-1. 1.4-2, 1.4-3, and 1.4-4, the non-operational boiler results in the following PTE reduction (in tons per year): NOx -7.73, CO -6.49, PM -0.59, SO2 -0.05, VOCs -0.43, HAPs - 0.15, CO2e -9330.00. [Last updated March 12, 2024] 2. Comment regarding HAPs from Combustion Sources: The previous Approval Order (AO) DAQE-AN116910013-20, dated April 23, 2020, did not account for HAPs from combustion sources. Using AP-42 Tables 1.4-3, and 1.4-4, Generic HAP emissions were calculated for each combustion source: 18 MMBtu/hr boiler: 0.15 tons per year (TPY). Dryers for Astraflex Press: 0.01 TPY. Engineer Review N116910015: Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant March 12, 2024 Page 8 Dryers for Miraflex Press: 0.01 TPY. 1.675 MMBtu/hr boiler: 0.01 TPY. Of the 0.18 TPY of HAP emissions that were unaccounted for in the previous AO, 0.15 TPY is being removed from the non-operational 18 MMBtu/hr boiler and 0.01 TPY is being removed from the printing press replacement. The net decrease in Generic HAP PTE is 0.16 TPY or 320 lbs/yr. The Generic HAPs PTE is 0.02 TPY or 40 lbs/yr greater than what was listed in the previous AO. This is a result of the HAP emissions from the combustion sources now being accurately included in the AO, not from any change to process, production, or equipment. [Last updated March 12, 2024] 3. Comment regarding NSPS and MACT Applicability: 40 CFR 63 (MACT) Subpart KK applies to each new and existing facility at which publication rotogravure, product and packaging rotogravure, or wide-web flexographic printing presses are operated at area source of HAPs. The flexographic printing presses at this facility do not meet the definition of a wide-web flexographic printing press according to this subpart, therefore, this subpart does not apply. [Last updated March 12, 2024] 4. Comment regarding Title V Requirements: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR 60 (NSPS), 40 CFR 61 (NESHAP), or 40 CFR 63 (MACT) regulations. There are no other reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not apply to this facility. [Last updated March 12, 2024] Engineer Review N116910015: Mondi Bags USA, LLC- Salt Lake City Bag Manufacturing Plant March 12, 2024 Page 9 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 CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality 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 LB/YR Pounds per year 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 VOC Volatile organic compounds 2/28/24, 10:54 AM State of Utah Mail - Mondi Bags Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5759422384789757371&simpl=msg-a:r-36335249728840…1/4 Dungan Adams <dunganadams@utah.gov> Mondi Bags Printing Press Replacement-in-Kind 12 messages Dungan Adams <dunganadams@utah.gov>Tue, Feb 27, 2024 at 11:19 AM To: chris.king@mondigroup.com Hi Chris, My name is Dungan Adams and I work for the Utah Department of Air Quality. I have been working with Jeff Vincent to replace a printing press for Mondi Bags and update their Approval Order (DAQE-AN116910013-20). About a week ago I received messages saying that my emails couldn't be delivered to Jeff. I was hoping you could provide me with a new contact or an updated email address for him. The address I had been using is jeff.vincent@mondigroup.com Thanks, Dungan -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov King Chris (US, Salt Lake City) <chris.king@mondigroup.com>Tue, Feb 27, 2024 at 12:18 PM To: Dungan Adams <dunganadams@utah.gov> Yes, you can use me for reference for now. Thanks From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, February 27, 2024 11:19 AM To: King Chris (US, Salt Lake City) <chris.king@mondigroup.com> Subject: Mondi Bags Printing Press Replacement-in-Kind EXTERNAL SENDER 2/28/24, 10:54 AM State of Utah Mail - Mondi Bags Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5759422384789757371&simpl=msg-a:r-36335249728840…2/4 [Quoted text hidden] This e-mail as well as any files transmitted with it is confidential and may well contain information which is legally privileged. It is intended solely for the use of the individual or the entity to whom it is addressed. If you are not the intended recipient of this e-mail, you are hereby on notice of this status. Any disclosure, copying, distribution, dissemination or publication of the information contained therein is strictly prohibited, unless you have been permitted thereto by the sender, and might be a breach of confidence. If you are not the intended recipient, please return this e-mail immediately to the sender and then delete this message from your system. The sender is not liable for the proper transmission of this information nor for any delay in its receipt. Dungan Adams <dunganadams@utah.gov>Tue, Feb 27, 2024 at 12:23 PM To: "King Chris (US, Salt Lake City)" <chris.king@mondigroup.com> Chris, Great, thanks. Our compliance department wanted me to ask about the 18 MMBtu/hr boiler on site. The most recent compliance review from July 2021 states that the boiler was out of service and there were plans to replace it. Can you provide an update on the status of the boiler? Thanks, Dungan [Quoted text hidden] King Chris (US, Salt Lake City) <chris.king@mondigroup.com>Tue, Feb 27, 2024 at 12:29 PM To: Dungan Adams <dunganadams@utah.gov> Dungan we have discontinued all boilers for this plant. [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Tue, Feb 27, 2024 at 12:49 PM To: "King Chris (US, Salt Lake City)" <chris.king@mondigroup.com> Okay. Now could be a good opportunity to remove the 18 MMBtu/hr boiler from your Approval Order if you have no plans to use it or other boilers in the future. I would just need you to confirm that the boiler is no longer on site and then I can remove it from the equipment list and its emissions from the PTE summary. Thanks, Dungan [Quoted text hidden] King Chris (US, Salt Lake City) <chris.king@mondigroup.com>Tue, Feb 27, 2024 at 12:52 PM To: Dungan Adams <dunganadams@utah.gov> Cc: "Louder Rodney (US, Salt Lake City)" <Rodney.Louder@mondigroup.com>, "Pappas Jamie (US, Salt Lake City)" <jamie.pappas@mondigroup.com>, "Dziewit Tomasz (US, Salt Lake City)" <Tomasz.Dziewit@mondigroup.com> Ok I’m assuming that you need a site visit to verify. [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Tue, Feb 27, 2024 at 12:59 PM To: "King Chris (US, Salt Lake City)" <chris.king@mondigroup.com> I don't think that a visit is necessary--if the boiler is removed from the Approval Order and it isn't actually removed from the site, then this would be a compliance violation whenever the facility is next inspected. Thanks, Dungan [Quoted text hidden] 2/28/24, 10:54 AM State of Utah Mail - Mondi Bags Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5759422384789757371&simpl=msg-a:r-36335249728840…3/4 King Chris (US, Salt Lake City) <chris.king@mondigroup.com>Tue, Feb 27, 2024 at 1:03 PM To: Dungan Adams <dunganadams@utah.gov> Yes understood, the Boiler has been removed from our site. Sent from my iPhone On Feb 27, 2024, at 12:59 PM, Dungan Adams <dunganadams@utah.gov> wrote: EXTERNAL SENDER [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Tue, Feb 27, 2024 at 1:06 PM To: "King Chris (US, Salt Lake City)" <chris.king@mondigroup.com> Great. I will remove the 18 MMBtu/hr boiler from the Approval Order (AO). I should have the updated AO for you to review in a few days. Thanks, Dungan [Quoted text hidden] King Chris (US, Salt Lake City) <chris.king@mondigroup.com>Tue, Feb 27, 2024 at 1:15 PM To: Dungan Adams <dunganadams@utah.gov> Ok thanks Sent from my iPhone [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Wed, Feb 28, 2024 at 9:41 AM To: "King Chris (US, Salt Lake City)" <chris.king@mondigroup.com> Hi Chris, Could you provide me with your work phone number? I need this contact information as you are the new source contact. Thanks, Dungan [Quoted text hidden] King Chris (US, Salt Lake City) <chris.king@mondigroup.com>Wed, Feb 28, 2024 at 9:58 AM To: Dungan Adams <dunganadams@utah.gov> Cc: "Dziewit Tomasz (US, Salt Lake City)" <Tomasz.Dziewit@mondigroup.com>, "Pappas Jamie (US, Salt Lake City)" <jamie.pappas@mondigroup.com> Chris King 2/28/24, 10:54 AM State of Utah Mail - Mondi Bags Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5759422384789757371&simpl=msg-a:r-36335249728840…4/4 Mondi Printing/CI/Planning Salt Lake City 801-514-0615 801-978-3831 [Quoted text hidden] 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:1789627054914261…1/13 Dungan Adams <dunganadams@utah.gov> FW: FW: Printing Press Replacement-in-Kind 3 messages Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com>Wed, Jan 31, 2024 at 10:15 AM To: Dungan Adams <dunganadams@utah.gov> Adam, See attached and below comments regarding your question. Jeff From: kazan@soma.cz <kazan@soma.cz> Sent: Wednesday, January 31, 2024 9:53 AM To: 'Garrett Taylor' <taylor@soma-eng.com>; King Chris (US, Salt Lake City) <chris.king@mondigroup.com>; Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com>; Johnson James (US, Salt Lake City) <james.johnson@mondigroup.com>; Louder Rodney (US, Salt Lake City) <Rodney.Louder@mondigroup.com>; Dziewit Tomasz (US, Salt Lake City) <Tomasz.Dziewit@mondigroup.com> Subject: RE: FW: Printing Press Replacement-in-Kind EXTERNAL SENDER Hello, See info below: 1. The burner we use is Eclipse Thermjet TJ040 ( see attachment for data sheet ) Medium/ high velocity max output 400 000 BTU ( 106 kW ) Min output 40 000 BTU ( 11 kW ) Natural gas requirement: Volume 20 Nm3/h Pressure 50 – 200 mBar Exhaust: Max volume: 10500 m3/h Pressure: 250 Pa Since the machine is water based there is no floor sweep nor Corona on this unit so the max volume of exhausted air is final. Please find more Installation parameter on page 13 of the technical specification 2. Please see attachment for the concrete pressure points. 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:1789627054914261…2/13 Juraj (George) Kazan Regional service manager, SOMA North America +1 516-817-4927 | kazan@soma.cz 380 B. Smetany, Lanskroun 56301, Czech Republic www.soma-eng.com Date:Mon, 29 Jan 2024 18:05:25 +0000 From:King Chris (US, Salt Lake City) <chris.king@mondigroup.com> To:Garrett Taylor <taylor@soma-eng.com> CC:Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com>, Dziewit Tomasz (US, Salt Lake City) <Tomasz.Dziewit@mondigroup.com>, Johnson James (US, Salt Lake City) <james.johnson@mondigroup.com>, Louder Rodney (US, Salt Lake City) <Rodney.Louder@mondigroup.com> Good morning, Garrett. We need to follow up items listed below answered if possible. 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:1789627054914261…3/13 1. Questions for updating the VOC air permit for the New Press. If you can please supply information to questions listed below. 2. Rodney would like the Updated Drawings by Wednesday. We have the Floor/Foundation Engineer coming this week to evaluate the floor. 3. We have the Printing plates ready to ship to SOMA for the FAT Evaluation. Need shipping information so we can ship the plates this week. Thanks Chris King Mondi Printing/CI/Planning Salt Lake City 801-514-0615 801-978-3831 From: Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> Sent: Wednesday, January 24, 2024 8:16 PM To: King Chris (US, Salt Lake City) <chris.king@mondigroup.com> Subject: Fwd: Printing Press Replacement-in-Kind Let’s talk. Sent from my iPhone 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:1789627054914261…4/13 Begin forwarded message: From: Dungan Adams <dunganadams@utah.gov> Date: January 23, 2024 at 3:15:50 PM MST To: "Vincent Jeff (US, Salt Lake City)" <jeff.vincent@mondigroup.com> Subject: Re: Printing Press Replacement-in-Kind EXTERNAL SENDER Hi Jeff, I tried multiplying the gas heating power by the volume of exhausted area from the drying loop and then converting to MMBtu/hr, but this did not lead to a reasonable value. I cannot confirm this press qualifies for a replacement-in-kind without knowing the size of its combustion source. If it is not listed in any specification sheet, I would suggest reaching out to the manufacturer. Thanks, Dungan On Tue, Jan 23, 2024 at 2:24 PM Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> wrote: Hope this answers your question. 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:1789627054914261…5/13 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, January 23, 2024 11:21 AM To: Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> Subject: Re: Printing Press Replacement-in-Kind EXTERNAL SENDER Jeff, 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:1789627054914261…6/13 What is the size of the dryer (in MMBtu/hr) for the Soma Press? As for the larger printing rate for the new press, this should be okay. The 12-month rolling limits for VOCs and HAPs in the active Approval Order will remain the same, so you will have to run the new press at the same rate as the previous press or adjust production rates to keep VOCs and HAPs below their respective limits. Thanks, Dungan On Thu, Jan 18, 2024 at 11:13 AM Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> wrote: When we received all our printing presses in the facility we used the machine max run rate for our air quality permit, even though it will never run that speed. Astraflex is max 1300 fpm and has 3 dryers (gas) for ink and lacquer. (new) Soma Press is max 2000 fpm with 1 dryer (gas) and NO lacquer. So less emissions. When installed we will be monitoring our VOC and HAP limits and It will be less than our old Astraflex. Jeff From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 17, 2024 5:03 PM To: Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> Subject: Re: Printing Press Replacement-in-Kind EXTERNAL SENDER Hi Jeff, Thanks for sending this over. I have two questions: (1) What are the printing parameters of the new press? Looking at old emission calculations, I think the Astraflex had an average print speed of 650 fpm and a maximum width of 4.17 ft. Since you have rolling 12-month VOC and HAP limits in your active Approval Order, the 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:1789627054914261…7/13 printing parameters don't have to be identical, but you will have to monitor production/operation in order to stay in compliance with the condition. (2) What are the combustion sources for the new press? The Astraflex press has three dryers rated at 0.34, 0.42, and 0.85 MMBtu/hr which contribute to NOx, CO, and other air pollutants. Thanks, Dungan On Wed, Jan 17, 2024 at 7:51 AM Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> wrote: See attached. Tabs are for different years. You can see each month for the astraflex VOC’s that we are removing. We are also NOT using Laquer on the new press. Just water base ink. And our VOC’s with our new ink supplier is much lower than other suppliers. Jeff From: Vincent Jeff (US, Salt Lake City) Sent: Monday, January 15, 2024 2:52 PM To: Dungan Adams <dunganadams@utah.gov> Subject: RE: Printing Press Replacement-in-Kind Different name, but same Press, using same water base inks and same production/printing output. Nothing has changed but name. Jeff From: Dungan Adams <dunganadams@utah.gov> Sent: Friday, January 12, 2024 10:26 AM To: Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> Subject: Re: Printing Press Replacement-in-Kind EXTERNAL SENDER Jeff, Since you are replacing the Astraflex with a different press, I am going to need emission calculations or some type of justification that show site-wide emissions will remain identical or decrease. I'm not sure how emissions were calculated for the plant previously, 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:1789627054914261…8/13 but I think the easiest option would be to send me emission calculations for the current press and the replacement so I can compare the two. Let me know if you have any questions or need help with emission calculations. Thanks, Dungan On Fri, Jan 12, 2024 at 9:56 AM Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> wrote: We are removing our Astraflex press and replacing it with the following. Manufacture: Soma Press: Optima 2 1300-1270-8 WGM We are replacing this press and there will be no changes in any emissions. Thank you! Jeff From: Dungan Adams <dunganadams@utah.gov> Sent: Thursday, January 11, 2024 12:41 PM To: Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> Subject: Printing Press Replacement-in-Kind EXTERNAL SENDER Hi Jeff, The Utah Division of Air Quality has received your request for a Replacement-in-Kind for a printing press at the Mondi Bags Salt Lake City Manufacturing Plant. From what I see in our records, the active approval order for the plant is DAQE-AN116910013-20. I've attached it below so you can look it over. Can you please let me know which printing press you are replacing and confirm it is being replaced by a identical printing press and there will be no changes in any emissions. Then, I will write up a Replacement-in-Kind letter and you should be all set. 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:1789627054914261…9/13 Let me know if you have any questions. Thanks, Dungan -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov This e-mail as well as any files transmitted with it is confidential and may well contain information which is legally privileged. It is intended solely for the use of the individual or the entity to whom it is addressed. If you are not the intended recipient of this e-mail, you are hereby on notice of this status. Any disclosure, copying, distribution, dissemination or publication of the information contained therein is strictly prohibited, unless you have been permitted thereto by the sender, and might be a breach of confidence. If you are not the intended recipient, please return this e-mail immediately to the sender and then delete this message from your system. The sender is not liable for the proper transmission of this information nor for any delay in its receipt. -- 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:178962705491426…10/13 Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:178962705491426…11/13 -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer I | Minor NSR Section 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:178962705491426…12/13 M: (385) 290-2474 airquality.utah.gov Confidentiality / GDPR Disclaimer The information contained in this e-mail is confidential and is intended solely for the use of subject to whom it is addressed (intended recipient). Full Disclaimer of this email is here Our full GDPR policy may be found here / Naši plnou GDPR strategii naleznete zde 2 attachments Concere pressure.pdf 74K V2_ThermJet_TJ0040_Datasheet_205-2.5.pdf 665K Dungan Adams <dunganadams@utah.gov>Thu, Feb 1, 2024 at 11:05 AM To: "Vincent Jeff (US, Salt Lake City)" <jeff.vincent@mondigroup.com> Hi Jeff, Thank you for providing information that shows the combustion source for the new Soma press is smaller than those of the old Astraflex press. I am going to update the classification of the project from a Replacement-in-Kind to a Reduction in Air Pollutants. My reasoning for this is as follows: When looked at individually, the new press technically has a greater potential to emit than the old press because it has a greater print rate and is capable of producing more VOCs and HAPs. However, since the overall site-wide VOC and HAP emissions will be limited by the same rolling 12-month totals and the combustion emissions are lower for the new press, site-wide emissions will decrease slightly. This change in classification will not affect fees or any other aspect of the project, but I wanted to explain the reasoning for this change. If you have any questions or concerns, I can provide a greater explanation and point you to the state rules for Replacement-in-Kind Equipment and Reduction in Air Pollutants. The project will move along quickly now and I should have the updated permit to you within the next week or so. Thanks, Dungan [Quoted text hidden] Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com>Thu, Feb 1, 2024 at 11:09 AM To: Dungan Adams <dunganadams@utah.gov> Perfect! [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] 1. The burner we use is Eclipse Thermjet TJ040 ( see attachment for data sheet ) 2/1/24, 11:59 AM State of Utah Mail - FW: FW: Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1789627054914261459&simpl=msg-f:178962705491426…13/13 Medium/ high velocity max output 400 000 BTU ( 106 kW ) Min output 40 000 BTU ( 11 kW ) Natural gas requirement: Volume 20 Nm3/h Pressure 50 – 200 mBar Exhaust: Max volume: 10500 m3/h Pressure: 250 Pa Since the machine is water based there is no floor sweep nor Corona on this unit so the max volume of exhausted air is final. Please find more Installation parameter on page 13 of the technical specification 2. Please see attachment for the concrete pressure points. [Quoted text hidden] [Quoted text hidden] 2/1/24, 11:59 AM State of Utah Mail - Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-6524741774458608390&simpl=msg-a:r42536428594588…1/6 Dungan Adams <dunganadams@utah.gov> Printing Press Replacement-in-Kind 10 messages Dungan Adams <dunganadams@utah.gov>Thu, Jan 11, 2024 at 12:41 PM To: jeff.vincent@mondigroup.com Hi Jeff, The Utah Division of Air Quality has received your request for a Replacement-in-Kind for a printing press at the Mondi Bags Salt Lake City Manufacturing Plant. From what I see in our records, the active approval order for the plant is DAQE- AN116910013-20. I've attached it below so you can look it over. Can you please let me know which printing press you are replacing and confirm it is being replaced by a identical printing press and there will be no changes in any emissions. Then, I will write up a Replacement-in-Kind letter and you should be all set. Let me know if you have any questions. Thanks, Dungan -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov DAQE-AN116910013-20.pdf 492K Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com>Fri, Jan 12, 2024 at 9:56 AM To: Dungan Adams <dunganadams@utah.gov> We are removing our Astraflex press and replacing it with the following. Manufacture: Soma Press: Optima 2 1300-1270-8 WGM 2/1/24, 11:59 AM State of Utah Mail - Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-6524741774458608390&simpl=msg-a:r42536428594588…2/6 We are replacing this press and there will be no changes in any emissions. Thank you! Jeff From: Dungan Adams <dunganadams@utah.gov> Sent: Thursday, January 11, 2024 12:41 PM To: Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> Subject: Printing Press Replacement-in-Kind EXTERNAL SENDER [Quoted text hidden] This e-mail as well as any files transmitted with it is confidential and may well contain information which is legally privileged. It is intended solely for the use of the individual or the entity to whom it is addressed. If you are not the intended recipient of this e-mail, you are hereby on notice of this status. Any disclosure, copying, distribution, dissemination or publication of the information contained therein is strictly prohibited, unless you have been permitted thereto by the sender, and might be a breach of confidence. If you are not the intended recipient, please return this e-mail immediately to the sender and then delete this message from your system. The sender is not liable for the proper transmission of this information nor for any delay in its receipt. Dungan Adams <dunganadams@utah.gov>Fri, Jan 12, 2024 at 10:26 AM To: "Vincent Jeff (US, Salt Lake City)" <jeff.vincent@mondigroup.com> Jeff, Since you are replacing the Astraflex with a different press, I am going to need emission calculations or some type of justification that show site-wide emissions will remain identical or decrease. I'm not sure how emissions were calculated for the plant previously, but I think the easiest option would be to send me emission calculations for the current press and the replacement so I can compare the two. Let me know if you have any questions or need help with emission calculations. Thanks, Dungan [Quoted text hidden] Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com>Mon, Jan 15, 2024 at 2:51 PM To: Dungan Adams <dunganadams@utah.gov> Different name, but same Press, using same water base inks and same production/printing output. Nothing has changed but name. [Quoted text hidden] Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com>Wed, Jan 17, 2024 at 7:51 AM To: Dungan Adams <dunganadams@utah.gov> See attached. Tabs are for different years. You can see each month for the astraflex VOC’s that we are removing. We are also NOT using Laquer on the new press. Just water base ink. And our VOC’s with our new ink supplier is much lower 2/1/24, 11:59 AM State of Utah Mail - Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-6524741774458608390&simpl=msg-a:r42536428594588…3/6 than other suppliers. Jeff [Quoted text hidden] Copy of VOCs HAPs Monthly.xlsm 1220K Dungan Adams <dunganadams@utah.gov>Wed, Jan 17, 2024 at 5:03 PM To: "Vincent Jeff (US, Salt Lake City)" <jeff.vincent@mondigroup.com> Hi Jeff, Thanks for sending this over. I have two questions: (1) What are the printing parameters of the new press? Looking at old emission calculations, I think the Astraflex had an average print speed of 650 fpm and a maximum width of 4.17 ft. Since you have rolling 12-month VOC and HAP limits in your active Approval Order, the printing parameters don't have to be identical, but you will have to monitor production/operation in order to stay in compliance with the condition. (2) What are the combustion sources for the new press? The Astraflex press has three dryers rated at 0.34, 0.42, and 0.85 MMBtu/hr which contribute to NOx, CO, and other air pollutants. Thanks, Dungan [Quoted text hidden] Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com>Thu, Jan 18, 2024 at 11:12 AM To: Dungan Adams <dunganadams@utah.gov> When we received all our printing presses in the facility we used the machine max run rate for our air quality permit, even though it will never run that speed. Astraflex is max 1300 fpm and has 3 dryers (gas) for ink and lacquer. (new) Soma Press is max 2000 fpm with 1 dryer (gas) and NO lacquer. So less emissions. When installed we will be monitoring our VOC and HAP limits and It will be less than our old Astraflex. [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Tue, Jan 23, 2024 at 11:20 AM To: "Vincent Jeff (US, Salt Lake City)" <jeff.vincent@mondigroup.com> Jeff, What is the size of the dryer (in MMBtu/hr) for the Soma Press? As for the larger printing rate for the new press, this should be okay. The 12-month rolling limits for VOCs and HAPs in the active Approval Order will remain the same, so you will have to run the new press at the same rate as the previous press or adjust production rates to keep VOCs and HAPs below their respective limits. 2/1/24, 11:59 AM State of Utah Mail - Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-6524741774458608390&simpl=msg-a:r42536428594588…4/6 Thanks, Dungan [Quoted text hidden] Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com>Tue, Jan 23, 2024 at 2:24 PM To: Dungan Adams <dunganadams@utah.gov> Hope this answers your question. 2/1/24, 11:59 AM State of Utah Mail - Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-6524741774458608390&simpl=msg-a:r42536428594588…5/6 [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Tue, Jan 23, 2024 at 3:14 PM To: "Vincent Jeff (US, Salt Lake City)" <jeff.vincent@mondigroup.com> Hi Jeff, I tried multiplying the gas heating power by the volume of exhausted area from the drying loop and then converting to MMBtu/hr, but this did not lead to a reasonable value. I cannot confirm this press qualifies for a replacement-in-kind without knowing the size of its combustion source. If it is not listed in any specification sheet, I would suggest reaching out to the manufacturer. Thanks, Dungan 2/1/24, 11:59 AM State of Utah Mail - Printing Press Replacement-in-Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r-6524741774458608390&simpl=msg-a:r42536428594588…6/6 [Quoted text hidden] 2/1/24, 11:58 AM State of Utah Mail - Fwd: Replacement in Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1787809581029559983&simpl=msg-f:17878095810295599…1/3 Dungan Adams <dunganadams@utah.gov> Fwd: Replacement in Kind 6 messages Alan Humpherys <ahumpherys@utah.gov>Thu, Jan 11, 2024 at 8:47 AM To: Dungan Adams <dunganadams@utah.gov> Dungan, Can you please contact this source and help them start the permit application process? Thanks, Alan ---------- Forwarded message --------- From: Vincent Jeff (US, Salt Lake City) <jeff.vincent@mondigroup.com> Date: Mon, Jan 8, 2024 at 8:12 AM Subject: Replacement in Kind To: ahumpherys@utah.gov <ahumpherys@utah.gov> Good morning Allan, We would like a replacement in kind printing press with a new one due to lack of getting replacement parts. The press should arrive in a couple months. Modification to DAQE-AN0116910008-10. All criteria pollutants are below the modeling thresholds and emissions are below their respective emission threshold. Apples for Apples replacement. 😊 can you lead me in the right direction to get this completed? Jeff Jeff Vincent SHE Manager Mondi Bags USA Paper Bags #STRONGERTOGETHER Mondi 2357 South 900 West Salt lake City, UT 84119 2/1/24, 11:58 AM State of Utah Mail - Fwd: Replacement in Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1787809581029559983&simpl=msg-f:17878095810295599…2/3 Mobile: 385-502-6736, Fax 801-384-1501 Email: jeff.vincent@mondigroup.com www.mondigroup.com This e-mail as well as any files transmitted with it is confidential and may well contain information which is legally privileged. It is intended solely for the use of the individual or the entity to whom it is addressed. If you are not the intended recipient of this e-mail, you are hereby on notice of this status. Any disclosure, copying, distribution, dissemination or publication of the information contained therein is strictly prohibited, unless you have been permitted thereto by the sender, and might be a breach of confidence. If you are not the intended recipient, please return this e-mail immediately to the sender and then delete this message from your system. The sender is not liable for the proper transmission of this information nor for any delay in its receipt. -- Alan Humpherys Manager | Minor NSR Section P: (385) 306-6520 F: (801) 536-4099 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Dungan Adams <dunganadams@utah.gov>Thu, Jan 11, 2024 at 11:56 AM To: Alan Humpherys <ahumpherys@utah.gov> Hi Alan, What is the procedure for replacement in kind? I looked over the R307-401-11 and I'm not exactly sure what is needed as a written notification. The "apples to apples" replacement would meet the applicability for the rule and nothing would change in the active AO. Thanks, Dungan [Quoted text hidden] 2/1/24, 11:58 AM State of Utah Mail - Fwd: Replacement in Kind https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1787809581029559983&simpl=msg-f:17878095810295599…3/3 -- Dungan Adams Environmental Engineer I | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Alan Humpherys <ahumpherys@utah.gov>Thu, Jan 11, 2024 at 12:06 PM To: Dungan Adams <dunganadams@utah.gov> Dungan, If nothing would change in the current AO, then we would issue a letter stating that we've review the request and that nothing needs to be updated in the AO and so the source can continue to operate under the existing AO. If the rating is lower, or if the existing AO has a manufacturer or model number, we would need to update the AO with the new information. If you have questions about this, please let me know. Thanks, Alan [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Thu, Jan 11, 2024 at 12:09 PM To: Alan Humpherys <ahumpherys@utah.gov> Okay, sounds good. Is there any peer or manager review for letters like this? Thanks, Dungan [Quoted text hidden] Alan Humpherys <ahumpherys@utah.gov>Thu, Jan 11, 2024 at 12:48 PM To: Dungan Adams <dunganadams@utah.gov> Yes, you treat it like a normal project in TEMPO, but the project type is "other" I think. [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Thu, Jan 11, 2024 at 12:56 PM To: Alan Humpherys <ahumpherys@utah.gov> Okay, thanks. [Quoted text hidden]