DAQ-2024-011203

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DAQC-CI143010001-24
Site ID 14301 (B1)

MEMORANDUM

TO: FILE – WHITE FLAME, INC. – Lindon Wood Pellet Manufacturing Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: October 17, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County

INSPECTION DATE: March 27, 2024

SOURCE LOCATION: 125 South 1800 West
Lindon, UT 84042

SOURCE CONTACTS: Karl Kunz, Owner
[e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Clean scrap wood is shipped to the source and unloaded onto an
open concrete storage area. The wood is manually sorted, loaded
onto one of two conveyors: one conveys usable wood to a
portable metal container where it is stockpiled and made into
wood stakes, the second feeds the remaining wood into a shaker
machine that separates out any sawdust and odd-sized pieces.
The scrap wood is then carried up a third conveyor to a hog,
which grinds the wood into 1" minus diameter wood chips. The
chips then pass through a cyclone that separates out any
unwanted sawdust. The chips fall into Silo #1. The unwanted
saw dust is vented through a deflector tube to a tube sock type
open baghouse and collected in 50 gallon barrels. The chips in
Silo #1 are then fed through a hammer mill, for further grinding
into coarse sawdust (3/16" minus diameter). The coarse sawdust
is then transported through a 10" diameter tube to another
cyclone. This cyclone separates any unwanted fines from the
coarse sawdust. The unwanted fines are fed to a 64-bag Dust
Hog pulse jet baghouse. The coarse sawdust settles into Silo #2.

The sawdust in Silo #2 is carried up an enclosed conveyor to a
hopper that feeds into the pellet mill, where the coarse sawdust is
compressed into 1/8" diameter pellets. The compression of the
coarse sawdust into pellets generates a lot of heat. The hot pellets
exit the pellet machine and are carried up an enclosed elevator to
a mechanical screen on the roof. Any remaining sawdust passes

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through the screen and is run back through the pellet mill a
second time. The hot pellets pass through a cooler and into a
pellet storage silo. The pellets exit the silo through a bagging
machine at the base of silo. The bagging machine doses 40 lbs.
of pellets into each bag. The bags are placed on pallets and
shipped.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN0143010001-10, dated
August 23, 2010

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

White Flame, Inc.
Lindon Wood Pellet Manufacturing Plant

125 South 1800 West 125 South 1800 West
Lindon, UT 84042 Lindon, UT 84042

SIC Code: 2499: (Wood 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 UAC R307-107. General Requirements: Breakdowns.
[R307-107]

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I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Status: Out of Compliance. Source exceeded the limit for number of hours the forklift and
loader can operate within a 12-month period. Source was issued a CA (DAQC-341-24) and
an ESA (DAQC-882-24) for exceeding the limits.

No unapproved equipment was observed at the time of inspection. No Emission Inventory
is required at this source. Records are maintained for at least 2 years.

Section II: SPECIAL PROVISIONS

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

II.A.1 Wood pellet manufacturing plant
Wood pellet manufacturing from sawdust and wood scraps

II.A.2 One cyclone
The cyclone attached to a fan rated at 5,500 ACFM

II.A.3 Baghouse for Hammer mill process
One Hammer mill with associated cyclone and bag house, rated at 2,800 ACFM

II.A.4 One drum dryer
Dryer supported by a natural gas-fired burner rated at 12 MMBtu per hour

II.A.5 One front-end loader
Caterpillar 924 loader with diesel engine

II.A.6 Two forklifts
JCB 541-70 forklift with diesel engine and Allis Chalmers F40-24PS forklift with LPG
engine

II.A.7 Three conveyors, #1, 2 and 3 for sawdust transfer
Sawdust transfer from storage bunkers to hog: #1 Shaker Conveyor, model number FSCB-
30; #2 Hog discharge conveyor, which is 60 feet long; and #3 conveyor moves the pellets
from the mills to the cooling tower, model number EF Mueller RB9A.

Status: In Compliance. No unapproved equipment was observed at the time of
inspection. The drum dryer is still not in use as per the previous inspection in
2021.

II.B Requirements and Limitations

II.B.1 Requirements and Limitations.

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

A. All conveyor transfer points - 10% opacity
B. All diesel engines - 20% opacity
C. All conveyor drop points - 10% opacity
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Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

Status: In Compliance. No visible emissions were observed at the time of inspection. See
the attached VEO form for additional information.

II.B.1.b The following limits shall not be exceeded:

A. Total pellets produced - 72,000 tons per rolling 12-month period
B. Total natural gas usage - 35.29 MMBtu per rolling 12-month period
C. Total sawdust in-take - 36,000 tons per rolling 12-month period
D. Total propane usage - 1,500 gallons per rolling 12-month period
E. Total operating hours for diesel-fueled forklift and loader - 600 each per rolling
12-month period.
[R307-401-8]

II.B.1.b.1 Compliance with the limitations shall be determined on a rolling 12-month total. The
owner/operator shall calculate a new 12-month total based on the twentieth day of each month
using data from the previous 12 months. Records of production and usages shall be kept for all
periods when the plant is in operation. Production shall be determined by scale house records or
shipping records. Sawdust in-take shall be determined by vendors' billings. Natural gas and
propane usages shall be determined by billings or purchase records. Hours of operation shall be
determined by supervisor monitoring and maintaining of an operation log. The records shall be
kept on a daily basis. [R307-401-8]

Status: Out of Compliance. The rolling 12-month totals from April 2023 to March 2024
include:

4,684 tons of pellets produced
0 MMBtu of natural gas consumed
0 tons of sawdust intake
40 gallons of propane consumed
665 hours the forklift operated
616 hours the loader operated

Both the forklift and loader exceeded permitted operating hours. A CA and ESA were
issued for exceeding the limits.

The source stores the information listed here electronically and writes in monthly totals.
The logbook was viewed at the time of inspection that demonstrated the monthly
breakdown. A total for the rolling 12-months was provided via email. See the attachment
section for additional information.

II.B.1.c Scrap wood received for processing into wood pellets shall be free of coatings such as varnish,
paint, oil, or contaminants. [R307-401-8]

Status: In Compliance. The wood pellets are free of coatings and varnish. Pellets are
inspected as they are brought on site. Any pellets with coatings or contaminants are
discarded in a pile that is sent to the landfill for disposal.

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II.B.1.d The owner/operator shall apply water treatment or chemical dust suppression treatment on all
areas on site disturbed by mobile equipment to control fugitive dust emissions. Application shall
be applied to ensure the opacity limits in this AO are not exceeded. [R307-205]

Status: In Compliance. Wood piles are watered over the summer months to help limit dust.
A water truck is also utilized in the yard over the summer to help mitigate fugitive dust
onsite.

II.B.1.e The owner/operator shall notify the Executive Secretary or Executive Secretary's representative
when the new site is fully operational and the operation at old site ceased. The existing AO
DAQE-017-96, dated January 8, 1996, shall be revoked at that time. [R307-401-18]

Status: Out of Compliance. Notification has not been sent since this current AO has been
issued in 2010. Multiple inspections have occurred at this source and the equipment onsite
has been installed since 2008 and has not changed since then. No further action is currently
recommended.

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.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]

Status: In Compliance. According to the fuel invoice from Rhinehart Oil, the diesel fuel utilized
onsite is ULSD. See the attachments section for a copy of the fuel invoice.

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

Status: In Compliance. This rule is satisfied by compliance with conditions II.B.1.a and II.B.1.d of
this AO.

Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. This rule is satisfied by compliance with conditions II.B.1.a and II.B.1.d of
this AO.

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EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from White Flame, Inc.
– Lindon Wood Pellet Manufacturing Plant on the Approval Order (AO) DAQE-AN0143010001-10,
dated August 23, 2010. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
Carbon Monoxide 2.16
Nitrogen Oxides 4.29
Particulate Matter - PM10 0.50
Sulfur Dioxide 0.17
Volatile Organic Compounds 0.10

Hazardous Air Pollutant PTE lbs/yr
Formaldehyde (CAS #50000) 4

PREVIOUS ENFORCEMENT
ACTIONS: None within the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN0143010001-10,
dated August 23, 2010, the overall status is: Out of Compliance.
Out of Compliance for exceeding the approved limits for hours
operating the diesel-powered forklift and loader. A CA was
issued (DAQC-341-24) and an ESA was also issued for
exceeding limits without prior approval (DAQC-882-24). No
further action is currently recommended. In compliance with
other conditions listed within the AO.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect again next year to see if the source has better operating
procedures to limit and track forklift and loader hours.

NSR RECOMMENDATIONS: This AO should be subject to a 10-year Administrative Review.

ATTACHMENTS: Applicable Supporting Documentation Included
Jordan Garahana <[e-mail]>
Records Request from Inspection 32/7
4 messages
Jordan Garahana <[e-mail]>Wed, Mar 27, 2024 at 3:42 PM
To: [e-mail]
Hello Karl,
My name is Jordan Garahana and I am an Environmental Scientist with the State of Utah's Division of Air Quality. I
conducted an inspection today of your facility in Lindon and I need some records to help complete my inspection. I am
looking for records for the following:
Rolling 12-month totals from April 2023-March 2024 for the following:
Total pellets produced, total natural gas usage, total sawdust intake, total propane usage, and total operating
hours for the diesel-fueled forklift and loader
A bill of sale from where you purchase your diesel fuel that confirms the diesel fuel is classified as ultra-low
sulfur diesel fuel.
Please have these records to me via email by Wednesday, April 3. Please let me know if you have any questions about
the records I am requesting or my inspection.
Thanks,
Jordan Garahana
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
white flame <[e-mail]>Wed, Apr 10, 2024 at 11:49 AM
To: Jordan Garahana <[e-mail]>
Here is the information you requested:
Total pellets produced: 4684 tons
Natural Gas usage: 0
Sawdust intake: 0
Propane: 40 gal
Operating hours for forklift: 665
Operating hours for loader: 612
Please find the attached from Rhinehart oil as per your request.
10/17/24, 2:59 PM State of Utah Mail - Records Request from Inspection 32/7
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-3504233677538882426&simpl=msg-a:r-84781071225553…1/2
Let me know if you have any questions
Karl
[Quoted text hidden]
Rhinehart oil diesel.pdf
175K
Jordan Garahana <[e-mail]>Wed, Apr 10, 2024 at 12:34 PM
To: Chad Gilgen <[e-mail]>
FYI for Compliance action to White Flame. They are only approved to operate both the forklift and loader for 600 hours
each within a rolling 12-month period.
[Quoted text hidden]
Rhinehart oil diesel.pdf
175K
Jordan Garahana <[e-mail]>Wed, Apr 10, 2024 at 3:29 PM
To: white flame <[e-mail]>
Hey Karl,
Thank you for sending me the information I requested for my inspection. Based on what you sent me and the limits set
within your permit, you have exceeded the amount of hours the forklift and loader can operate within a 12 month period.
Both are permitted to operate 600 hours each and they both have exceeded that limit. That limit can be found on page 4,
under heading II.B.1.b of the permit I have attached below. Since that limit has been exceeded, I will be issuing a
Compliance Advisory to you within the next couple of days, which is a letter that addresses what was found out of
compliance from my inspection and what actions you plan to take to get back into compliance. Please let me know if you
have any questions about the compliance advisory or the inspection.
Thanks,
Jordan Garahana
[Quoted text hidden]
White Flame AO 2010.pdf
59K
10/17/24, 2:59 PM State of Utah Mail - Records Request from Inspection 32/7
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-3504233677538882426&simpl=msg-a:r-84781071225553…2/2