DAQ-2025-000568

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DAQC-CI144070001-25
Site ID 14407 (B1)

MEMORANDUM

TO: FILE – PHIBRO BIODIGESTER, LLC

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: January 21, 2025

SUBJECT: ATTEMPTED COMPLIANCE EVALUATION , Minor, Beaver County

INSPECTION DATE: August 1, 2024

SOURCE LOCATION: Near the City of Beaver
Beaver County, UT
DIRECTIONS: Take exit 112 from 115 and take a left onto Main Street, at
Center Street, turn right heading west on Highway 21 to
Minersville. After Minersville exit, in about a 1/2 mile turn left
onto Thermo Road. Go about 20 miles (road will head west then
turn south). The plant is on the east side of the road.

SOURCE CONTACTS: Tom Eckert, Inspection Contact
203-767-1854 [e-mail]

OPERATING STATUS: Not operating

PROCESS DESCRIPTION: Biogas produced from the nearby Murphy Brown Farm is used
to generate electricity. The plant collects waste from Murphy
Brown Farm and captures the methane from the waste. The
equipment includes two generator engines, a boiler, a flare, and a
biogas sweetening system.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN144070004-20, dated
September 2, 2020
NSPS (Part 60) Dc : Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units,
NSPS (Part 60) IIII : Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
NSPS (Part 60) A: General Provisions,
MACT (Part 63) -A : General Provisions,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

* - ) - # )
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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Phibro Biodigester, LLC
9 West Broad Street Suite 640 Near the City of Beaver
Standford, CT 06902 Beaver County, UT

SIC Code: 4991: (Cogeneration Services & Small Power Producers)

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]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: Out of Compliance. Source failed to respond to multiple attempts at requested information from the attempted inspection. A Compliance Advisory (DAQC-1243-24) was issued for failing to respond, as well as failing to conduct a stack test within the required timeframe. Based on the response from Phibro, a No Further Action letter (DAQC-030-25) was issued. The source has not been operating since January 2023, but has plans to operate in the immediate future.

Section II: SPECIAL PROVISIONS

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

II.A.1 Phibro Biodigester, LLC Power generation
II.A.2 Emergency Generator Engine One (1) diesel-fired generator engine rated at 56.7. hp Applicable Federal Standards: NSPS Subpart IIII/MACT Subpart ZZZZ
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II.A.3 Sulfur Sweetening System One (1) sulfur removal unit to remove hydrogen sulfide in the biogas
II.A.4 Flare One (1) flare to burn excess biogas
II.A.5 Boiler One (1) hot water boiler rated at 16.0 MMBtu/hr Primary Fuel: Propane; Secondary Fuel: Biogas Applicable Federal Standard: NSPS Subpart Dc
II.A.6 Generator Engines Two (2) generator engines rated at 2,233 Bhp each. The engines are equipped with oxidation catalysts to control VOC and CO emissions; the engines have rich-burn design that reduces NOx emissions Applicable Federal Standards: NSPS Subpart JJJJ/MACT Subpart ZZZZ
Status: Not Observed. Unable to view equipment at the time of attempted inspection. Source has not operated since January 2023, but has plans in the immediate future to being operations again.

II.B Requirements and Limitations
II.B.1 The biogas sweetening system shall be subject to the following requirements. II.B.1.a The biogas sweetening system shall be installed and operated to remove H2S from the incoming biogas streams. All biogas shall be routed through the system before being combusted in any equipment. [R307-401-8] Status: Not Observed. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.1.b The following operating parameters shall be maintained within the indicated ranges: A. Inlet biogas flow rate between 180 and 900 scfm; B. Outlet H2S concentration no greater than 200 ppmv; C. Inlet water temperature between 50 and 102 degrees Fahrenheit. [R307-401-8] II.B.1.b.1 The parameters shall be monitored with instruments located such that an inspector/operator can safely read the output any time. The readings shall be accurate to within plus or minus 5%. [R307-401-8] II.B.1.b.2 All instruments shall be calibrated according to the manufacturers' instructions at least once every 12 months. [R307-401-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.1.c The operating parameters shall be recorded once a day. The records shall be kept for all periods when the plant is in operation. [R307-401-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.2 The emergency generator engine shall be subject to the following requirements II.B.2.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60 Subpart ZZZZ, R307-401-8]
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II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: 1. The date the emergency engine was used 2. The duration of operation in hours 3. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: Not Observed. Source was not operating at the time of attempted inspection. Source has not operated since January 2023. Unable to view equipment at the time of inspection. II.B.2.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency generator engine. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm sulfur. [R307-401-8] II.B.2.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [40 CFR 60 Subpart IIII, R307-401-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.2.c Visible emissions from the emergency generator engine shall not exceed 20% opacity. [R307-401-8] II.B.2.c.1 Opacity shall be determined by conducting observations in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. [40 CFR 60] Status: Not Observed. Source was not operating at the time of attempted inspection. II.B.3 The flare shall be subject to the following requirements. II.B.3.a The flare shall control excess biogas produced in the anaerobic digesters and subsequently treated with the biogas sweetening system. All excess biogas shall be routed through the flare before being vented to the atmosphere. [R307-403-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.3.b Visible emissions from the flare shall not exceed 10% opacity. [R307-401-8] II.B.3.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: Not Observed. Source was not operating at the time of attempted inspection. II.B.4 The hot water boiler shall be subject to the following requirements. II.B.4.a The owner/operator shall install a low NOx burner that is certified to meet NOx concentration of 30 ppm or less. [R307-401-8]

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II.B.4.a.1 The owner/operator shall keep a record of the manufacturer's certification of the NOx concentration. The record shall be kept for the life of the equipment. [R307-401-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.4.b The owner/operator shall only burn propane or biogas as fuel in the hot water boiler. [R307-401-8] Status: Not Observed. Source was not operating at the time of attempted inspection. II.B.4.c The owner/operator shall not burn biogas as fuel in the hot water boiler for more than 2,000 hours per rolling 12-month period. [R307-401-8] II.B.4.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records of hours of operation shall be kept for all periods when the plant is in operation. The records shall be kept on a daily basis. Hours of operation shall be determined by supervisor monitoring and maintaining of an operations log. [R307-401-8] Status: Not Observed. Source has not operated since January 2023. Source was not operating at the time of inspection. II.B.4.d When burning biogas as fuel in the hot water boiler, the owner/operator shall only burn biogas produced in the anaerobic digesters and subsequently treated with the biogas sweetening system. [R307-401-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.4.e Visible emissions from the boiler shall not exceed 10% opacity. [R307-401-8] II.B.4.e.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: Not Observed. Source was not operating at the time of attempted inspection. II.B.5 The generator engines shall be subject to the following requirements. II.B.5.a The generator engines shall be equipped with oxidation catalysts. The oxidation catalysts shall be installed, operated, and maintained according to the manufacturer's instructions and recommendations. [R307-401-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.5.b A manometer or magnehelic pressure gauge shall be installed to measure the differential pressure across the oxidation catalysts. Static pressure differential across the oxidation catalysts shall be no more than 4.6 inches of water column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The instrument shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of the reading is required on a once-a-week basis. [R307-340-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future.

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II.B.5.c The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the measurement of the operating temperature in the oxidation catalysts. The temperature shall be maintained between 600 and 1300 degrees Fahrenheit. The gauge shall be located such that an inspector /operator can safely read the indicator at any time. The monitoring device shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of the reading is required on a once-a-week basis. [R307-401-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.5.d Visible emissions from the generator engines shall not exceed 10% opacity. [R307-401-8] II.B.5.d.1 Opacity shall be determined by conducting observations in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. [40 CFR 60] Status: Not Observed. Source was not operating at the time of inspection. II.B.5.e The owner/operator shall only use biogas produced in the anaerobic digesters and subsequently treated with the biogas sweetening system. [R307-401-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.5.f Emissions to the atmosphere at all times from the indicated emission points shall not exceed the following rates: Source: each of the generator engine stacks Pollutants lb/hr NOx 4.92 CO 2.03 VOC 2.87. [R307-401-8] Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not been operating since January 2023, but has plans to operate in the immediate future. II.B.5.g Stack testing to show compliance with the emission limitations stated in the above condition shall be performed as specified below: Testing Test Emissions Point Pollutant Status Frequency Each of the engine generator stacks NOx ** @ CO ** @ VOC ** @. [R307-401-8]

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II.B.5.g.1 Testing Status ** Initial compliance testing has been completed. If an existing source is modified, a compliance test is required on the modified emission point that has an emission rate limit. @ Test every 8760 hours or 3 years, whichever comes first. The Director may require testing at any time. [40 CFR 60 Subpart JJJJ, R307-401-8] Status: Out of Compliance. Source has not stack tested since previous stack test in 2020. A CA was issued and based on the response from Phibro to the CA, a No Further Action letter was issued. The source has not been operating since January 2023, but has plans on operating in the immediate future. II.B.5.g.2 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The source test protocol shall be approved by the Director prior to performing the tests. The source test protocol shall outline the proposed test methodologies, stacks to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-401-8] II.B.5.g.3 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the Director. An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location. [R307-401-8] II.B.5.g.4 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director. [R307-401-8] II.B.5.g.5 Nitrogen Oxides (NOx) Table 2 to Subpart JJJJ of Part 60 - Requirements for Performance Tests, or other testing methods approved by the Director. [40 CFR 60 Subpart JJJJ] II.B.5.g.6 Carbon Monoxide (CO) Table 2 to Subpart JJJJ of Part 60 - Requirements for Performance Tests, or other testing methods approved by the Director. [40 CFR 60 Subpart JJJJ] II.B.5.g.7 Volatile Organic Compounds (VOCs) Table 2 to Subpart JJJJ of Part 60 - Requirements for Performance Tests, or other testing methods approved by the Director. [40 CFR 60 Subpart JJJJ] II.B.5.g.8 Calculations To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-401-8]

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II.B.5.g.9 New Source Operation For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the production rate for the engine generators listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be followed: 1) Testing shall be at no less than 90% of the production rate achieved to date. 2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable maximum production rate shall remain in effect until successfully tested at a higher rate. 3) The owner/operator shall request a higher production rate when necessary. Testing at no less than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the maximum AO production rate is achieved. [R307-401-8] II.B.5.g.10 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. [R307-401-8] Status: Out of Compliance. Source has not stack tested since previous stack test in 2020. A Compliance Advisory was issued and based on the response from Phibro to the Compliance Advisory, a No Further Action letter was issued. The source has not been operating since January 2023, but has plans on operating in the immediate future.
Section III: APPLICABLE FEDERAL REQUIREMENTS

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

NSPS (Part 60) Dc : Standards of Performance for Small Industrial-Commercial-Institutional Steam
Generating Units

Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not
been operating since January 2023, but has plans to operate in the immediate future.

NSPS (Part 60) IIII : Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not
been operating since January 2023, but has plans to operate in the immediate future.

NSPS (Part 60) A: General Provisions

Status: Not Observed. Compliance with Subpart A is determined by compliance with applicable federal
subparts. Compliance not observed with Subparts Dc and IIII.

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MACT (Part 63) -A : General Provisions

Status: Not Observed. Compliance with Subpart A is determined by compliance with applicable federal
subparts. Compliance not observed with Subpart ZZZZ.

MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: Not Observed. Unable to view equipment at the time of attempted inspection. The source has not
been operating since January 2023, but has plans to operate in the immediate future.
AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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

Status: Not Observed. Source was not operating at the time of inspection.
Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

Status: Not Observed. Source was not operating at the time of inspection.
Stationary Sources [R307-210]

Status: Not Observed. Source was not operating at the time of inspection. Source is subject to
R307-210 via NSPS Part 60 Subparts Dc and IIII.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: Not Observed. Source is subject to R307-214 via MACT 63 Subpart ZZZZ. Source was not
operating at the time of inspection.

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EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Phibro
Biodigester, LLC on the Approval Order (AO) DAQE-AN144070004-20, dated September 2, 2020.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 35951.00
Carbon Monoxide 30.19
Nitrogen Oxides 54.29
Particulate Matter - PM10 3.01
Particulate Matter - PM2.5 3.01
Sulfur Dioxide 8.15
Volatile Organic Compounds 28.24

Hazardous Air Pollutant PTE lbs/yr
1,3-Butadiene (CAS #106990) 165
Acetaldehyde (CAS #75070) 694
Acrolein (CAS #107028) 654
Benzene (Including Benzene From Gasoline) (CAS #71432) 394
Formaldehyde (CAS #50000) 5120
Generic HAPs (CAS #GHAPS) 120
Hexane (CAS #110543) 464
Methanol (CAS #67561) 762
Naphthalene (CAS #91203) 24
Toluene (CAS #108883) 140
Xylenes (Isomers And Mixture) (CAS #1330207) 49

PREVIOUS ENFORCEMENT
ACTIONS: None within the past 5 years

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN144070004-20,
dated September 2, 2020, the overall status is: Out of
Compliance. Out of Compliance with conditions I.4 and
II.B.5.g.1 of the AO. Source failed to respond to multiple
requests for information and has not conducted a stack test on
the applicable equipment within the appropriate time frame. A
Compliance Advisory (DAQ-1243-24) was issued. Source
responded stating that they had not been in operation since
January 2023, but have plans to return to operation in the
immediate future. A No Further Action letter (DAQ-030-25) was
then issued. No further action is currently recommended.

Compliance not determined as operations were not ongoing at
the time of attempted inspection.

HPV STATUS: Not Applicable.
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RECOMMENDATION FOR
NEXT INSPECTION: Inspect once they begin operations again. Source has not
conducted a stack test on the biogas sweetening system since
2021. Check to see if stack test has been conducted or if they are
in the process of conducting stack test before inspecting. Contact
Tom Eckert before inspecting to ensure they are operating.

NSR RECOMMENDATIONS: None at this time

ATTACHMENTS: Applicable Supporting Documentation Included
Jordan Garahana <[e-mail]>
Records Request for Inspection Phibro Beaver
2 messages
Jordan Garahana <[e-mail]>Thu, Aug 1, 2024 at 4:31 PM
To: [e-mail]
Hello Tom,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's Division of Air Quality. I am
requesting records/information for an inspection, and these are the records that I am looking for:
II.B.1.b- The following operating parameters shall be maintained within the indicated ranges: A. Inlet biogas flow rate
between 180 and 900 scfm; B. Outlet H2S concentration no greater than 200 ppmv; C. Inlet water temperature between
50 and 102 degrees Fahrenheit. I need recent records that show this is being recorded daily and that the parameters
mentioned in this condition are not exceeded.
II.B.1.b.2- All instruments shall be calibrated according to the manufacturers' instructions at least once every 12 months. I
need a record that shows the instruments used to measure these parameters are being calibrated according to
manufacturer's specifications within the previous 12 months.
II.B.2.a- The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month
period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60
Subpart ZZZZ, R307-401-8] I need a rolling 12-month total from July 2023 to June 2024 of the hours the emergency
engine operated indicating the reason the emergency engine was operating. I also need any recent maintenance
records for the emergency engines and generator engines.
II.B.2.b- The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency generator
engine. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm
sulfur. [R307-401-8] I need a recent bill of sale from your diesel fuel provider that demonstrates the diesel fuel
utilized onsite is ULSD and has a PPM of 15 or less.
II.B.4.c- The owner/operator shall not burn biogas as fuel in the hot water boiler for more than 2,000 hours per rolling 12-
month period. I need the rolling 12-month total from July 2023 to June 2024 showing that amount the hot water
boiler operated on biogas.
II.B.5.b- A manometer or magnehelic pressure gauge shall be installed to measure the differential pressure across the
oxidation catalysts. Static pressure differential across the oxidation catalysts shall be no more than 4.6 inches of water
column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time.
The instrument shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of
the reading is required on a once-a-week basis. I need a log of the magnehelic pressure gauge readings indicating
that they are being recorded once a week. I also need a record that shows the magnehelic gauge is calibrated
once every 12 months.
II.B.5.c- The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the measurement of the
operating temperature in the oxidation catalysts. The temperature shall be maintained between 600 and 1300 degrees
Fahrenheit. The gauge shall be located such that an inspector /operator can safely read the indicator at any time. The
monitoring device shall be calibrated according to the manufacturer's instructions at least once every 12 months.
Recording of the reading is required on a once-a-week basis. I need a record that shows the temperature on the
oxidation catalysts is being recorded once a week and is operating between 600 and 1300 degrees. I also need a
record that shows the monitoring device is being calibrated once every 12 months according to the
manufacturer's specifications.
II.B.5.g.10- Existing Source Operation For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. Your most recent
stack test according to our files for your operation was in December of 2020. If you have had a stack test since
then, please send me a copy of the report from that test. Otherwise, please schedule to have one conducted as
you are out of compliance with this AO condition.
1/21/25, 2:37 PM State of Utah Mail - Records Request for Inspection Phibro Beaver
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r1150784747246676171&simpl=msg-a:r-270014382597561…1/3
Please let me know if you have any questions about the records I am requesting. Please have this information to me by
Thursday, August 8.
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.
Mail Delivery Subsystem <[e-mail]>Thu, Aug 1, 2024 at 4:31 PM
To: [e-mail]
Message blocked
Your message to [e-mail] has been blocked. See
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The response from the remote server was:
550 5.4.1 Recipient address rejected: Access denied. [BL02EPF0001A0FB.namprd03.prod.outlook.com
2024-08-01T22:31:11.780Z 08DCAFA19E76D8EC]
Final-Recipient: rfc822; [e-mail]
Action: failed
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Last-Attempt-Date: Thu, 01 Aug 2024 15:31:11 -0700 (PDT)
---------- Forwarded message ----------
1/21/25, 2:37 PM State of Utah Mail - Records Request for Inspection Phibro Beaver
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r1150784747246676171&simpl=msg-a:r-270014382597561…2/3
From: Jordan Garahana <[e-mail]>
To: [e-mail]
Cc:
Bcc:
Date: Thu, 1 Aug 2024 16:31:00 -0600
Subject: Records Request for Inspection Phibro Beaver
----- Message truncated -----
1/21/25, 2:37 PM State of Utah Mail - Records Request for Inspection Phibro Beaver
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r1150784747246676171&simpl=msg-a:r-270014382597561…3/3
Jordan Garahana <[e-mail]>
Records Request Phibro Beaver Facility
5 messages
Jordan Garahana <[e-mail]>Thu, Aug 1, 2024 at 4:33 PM
To: [e-mail]
Hello Simon,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's Division of Air Quality. I am
requesting records/information for an inspection, and these are the records that I am looking for:
II.B.1.b- The following operating parameters shall be maintained within the indicated ranges: A. Inlet biogas flow rate
between 180 and 900 scfm; B. Outlet H2S concentration no greater than 200 ppmv; C. Inlet water temperature between
50 and 102 degrees Fahrenheit. I need recent records that show this is being recorded daily and that the parameters
mentioned in this condition are not exceeded.
II.B.1.b.2- All instruments shall be calibrated according to the manufacturers' instructions at least once every 12 months. I
need a record that shows the instruments used to measure these parameters are being calibrated according to
manufacturer's specifications within the previous 12 months.
II.B.2.a- The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month
period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60
Subpart ZZZZ, R307-401-8] I need a rolling 12-month total from July 2023 to June 2024 of the hours the emergency
engine operated indicating the reason the emergency engine was operating. I also need any recent maintenance
records for the emergency engines and generator engines.
II.B.2.b- The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency generator
engine. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm
sulfur. [R307-401-8] I need a recent bill of sale from your diesel fuel provider that demonstrates the diesel fuel
utilized onsite is ULSD and has a PPM of 15 or less.
II.B.4.c- The owner/operator shall not burn biogas as fuel in the hot water boiler for more than 2,000 hours per rolling 12-
month period. I need the rolling 12-month total from July 2023 to June 2024 showing that amount the hot water
boiler operated on biogas.
II.B.5.b- A manometer or magnehelic pressure gauge shall be installed to measure the differential pressure across the
oxidation catalysts. Static pressure differential across the oxidation catalysts shall be no more than 4.6 inches of water
column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time.
The instrument shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of
the reading is required on a once-a-week basis. I need a log of the magnehelic pressure gauge readings indicating
that they are being recorded once a week. I also need a record that shows the magnehelic gauge is calibrated
once every 12 months.
II.B.5.c- The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the measurement of the
operating temperature in the oxidation catalysts. The temperature shall be maintained between 600 and 1300 degrees
Fahrenheit. The gauge shall be located such that an inspector /operator can safely read the indicator at any time. The
monitoring device shall be calibrated according to the manufacturer's instructions at least once every 12 months.
Recording of the reading is required on a once-a-week basis. I need a record that shows the temperature on the
oxidation catalysts is being recorded once a week and is operating between 600 and 1300 degrees. I also need a
record that shows the monitoring device is being calibrated once every 12 months according to the
manufacturer's specifications.
II.B.5.g.10- Existing Source Operation For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. Your most recent
stack test according to our files for your operation was in December of 2020. If you have had a stack test since
then, please send me a copy of the report from that test. Otherwise, please schedule to have one conducted as
you are out of compliance with this AO condition.
1/21/25, 2:37 PM State of Utah Mail - Records Request Phibro Beaver Facility
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r5054899927963740891&simpl=msg-a:r-635497834135559…1/3
Please let me know if you have any questions about the records I am requesting. Please have this information to me by
Thursday, August 8.
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.
Jordan Garahana <[e-mail]>Mon, Aug 19, 2024 at 2:42 PM
To: [e-mail]
Hey Simon,
I am following up on my records request. Please let me know as soon as possible.
Thanks,
Jordan
[Quoted text hidden]
Jordan Garahana <[e-mail]>Thu, Aug 29, 2024 at 3:25 PM
To: [e-mail]
Hey Simon,
Please respond to my request for records as part of my inspection.
Thanks,
Jordan
[Quoted text hidden]
Jordan Garahana <[e-mail]>Tue, Oct 1, 2024 at 10:36 AM
To: [e-mail]
Hello Simon,
Please respond to my email for my request for records of the Phibro facility in Beaver.
Thanks,
Jordan
[Quoted text hidden]
1/21/25, 2:37 PM State of Utah Mail - Records Request Phibro Beaver Facility
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r5054899927963740891&simpl=msg-a:r-635497834135559…2/3
Jordan Garahana <[e-mail]>Mon, Oct 28, 2024 at 10:50 AM
To: [e-mail]
Hello Simon,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's Division of Air Quality. I am
requesting records/information for an inspection, and these are the records that I am looking for:
II.B.1.b- The following operating parameters shall be maintained within the indicated ranges: A. Inlet biogas flow rate
between 180 and 900 scfm; B. Outlet H2S concentration no greater than 200 ppmv; C. Inlet water temperature between
50 and 102 degrees Fahrenheit. I need recent records that show this is being recorded daily and that the parameters
mentioned in this condition are not exceeded.
II.B.1.b.2- All instruments shall be calibrated according to the manufacturers' instructions at least once every 12 months. I
need a record that shows the instruments used to measure these parameters are being calibrated according to
manufacturer's specifications within the previous 12 months.
II.B.2.a- The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month
period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60
Subpart ZZZZ, R307-401-8] I need a rolling 12-month total from July 2023 to June 2024 of the hours the emergency
engine operated indicating the reason the emergency engine was operating. I also need any recent maintenance
records for the emergency engines and generator engines.
II.B.2.b- The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency generator
engine. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm
sulfur. [R307-401-8] I need a recent bill of sale from your diesel fuel provider that demonstrates the diesel fuel
utilized onsite is ULSD and has a PPM of 15 or less.
II.B.4.c- The owner/operator shall not burn biogas as fuel in the hot water boiler for more than 2,000 hours per rolling 12-
month period. I need the rolling 12-month total from July 2023 to June 2024 showing that amount the hot water
boiler operated on biogas.
II.B.5.b- A manometer or magnehelic pressure gauge shall be installed to measure the differential pressure across the
oxidation catalysts. Static pressure differential across the oxidation catalysts shall be no more than 4.6 inches of water
column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time.
The instrument shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of
the reading is required on a once-a-week basis. I need a log of the magnehelic pressure gauge readings indicating
that they are being recorded once a week. I also need a record that shows the magnehelic gauge is calibrated
once every 12 months.
II.B.5.c- The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the measurement of the
operating temperature in the oxidation catalysts. The temperature shall be maintained between 600 and 1300 degrees
Fahrenheit. The gauge shall be located such that an inspector /operator can safely read the indicator at any time. The
monitoring device shall be calibrated according to the manufacturer's instructions at least once every 12 months.
Recording of the reading is required on a once-a-week basis. I need a record that shows the temperature on the
oxidation catalysts is being recorded once a week and is operating between 600 and 1300 degrees. I also need a
record that shows the monitoring device is being calibrated once every 12 months according to the
manufacturer's specifications.
II.B.5.g.10- Existing Source Operation For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. Your most recent
stack test according to our files for your operation was in December of 2020. If you have had a stack test since
then, please send me a copy of the report from that test. Otherwise, please schedule to have one conducted as
you are out of compliance with this AO condition.
Please let me know if you have any questions about the records I am requesting. Please have this information to me ASAP.
Thanks,
Jordan Garahana
[Quoted text hidden]
1/21/25, 2:37 PM State of Utah Mail - Records Request Phibro Beaver Facility
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r5054899927963740891&simpl=msg-a:r-635497834135559…3/3
Jordan Garahana <[e-mail]>
Records Request for Inspection
2 messages
Jordan Garahana <[e-mail]>Wed, Nov 13, 2024 at 1:41 PM
To: [e-mail]
Hello Thomas,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's Division of Air Quality. I am
requesting records/information as part of an attempted inspection I conducted of the facility in August, and these are the
records that I am looking for:
I.6- The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. I need any information
about any breakdowns that occurred, if there were any, from the previous inspection in 2021. If any of the
generators brokedown or there were any major leaks in the equipment.
II.A Equipment List- I need a confirmation that the equipment list in your AO is current and accurate. If any of that
equipment is no longer onsite please let me know. If you have any unapproved equipment, such as an extra
generator or boiler, please let me know as well. Please provide me with photos of the generators onsite that
include the power rating and the date of manufacture. I have attached the AO for your reference.
II.B.1.b- The following operating parameters shall be maintained within the indicated ranges: A. Inlet biogas flow rate
between 180 and 900 scfm; B. Outlet H2S concentration no greater than 200 ppmv; C. Inlet water temperature between
50 and 102 degrees Fahrenheit. I need recent records that show this is being recorded daily and that the parameters
mentioned in this condition are not exceeded.
II.B.1.b.2- All instruments shall be calibrated according to the manufacturers' instructions at least once every 12 months. I
need a record that shows the instruments used to measure these parameters are being calibrated according to
manufacturer's specifications within the previous 12 months.
II.B.2.a- The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month
period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60
Subpart ZZZZ, R307-401-8] I need a rolling 12-month total from July 2023 to June 2024 of the hours the emergency
engine operated indicating the reason the emergency engine was operating. I also need any recent maintenance
records for the emergency engines and generator engines.
II.B.2.b- The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency generator
engine. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm
sulfur. [R307-401-8] I need a recent bill of sale from your diesel fuel provider that demonstrates the diesel fuel
utilized onsite is ULSD and has a PPM of 15 or less.
II.B.4.c- The owner/operator shall not burn biogas as fuel in the hot water boiler for more than 2,000 hours per rolling 12-
month period. I need the rolling 12-month total from July 2023 to June 2024 showing that amount the hot water
boiler operated on biogas.
II.B.5.b- A manometer or magnehelic pressure gauge shall be installed to measure the differential pressure across the
oxidation catalysts. Static pressure differential across the oxidation catalysts shall be no more than 4.6 inches of water
column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time.
The instrument shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of
the reading is required on a once-a-week basis. I need a log of the magnehelic pressure gauge readings indicating
that they are being recorded once a week. I also need a record that shows the magnehelic gauge is calibrated
once every 12 months.
II.B.5.c- The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the measurement of the
operating temperature in the oxidation catalysts. The temperature shall be maintained between 600 and 1300 degrees
Fahrenheit. The gauge shall be located such that an inspector /operator can safely read the indicator at any time. The
monitoring device shall be calibrated according to the manufacturer's instructions at least once every 12 months.
Recording of the reading is required on a once-a-week basis. I need a record that shows the temperature on the
oxidation catalysts is being recorded once a week and is operating between 600 and 1300 degrees. I also need a
1/21/25, 2:38 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-4408888969579897139&simpl=msg-a:r-43196548415192…1/3
record that shows the monitoring device is being calibrated once every 12 months according to the
manufacturer's specifications.
II.B.5.g.10- Existing Source Operation For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. Your most recent
stack test according to our files for your operation was in December of 2020. If you have had a stack test since
then, please send me a copy of the report from that test. Otherwise, please schedule to have one conducted as
you are out of compliance with this AO condition.
Please let me know if you have any questions about the records I am requesting. Please have this information to me as
soon as possible.
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.
Phibro 2020 AO.pdf
555K
Mail Delivery Subsystem <[e-mail]>Wed, Nov 13, 2024 at 1:42 PM
To: [e-mail]
Message blocked
Your message to [e-mail] has been blocked. See
technical details below for more information.
1/21/25, 2:38 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-4408888969579897139&simpl=msg-a:r-43196548415192…2/3
The response from the remote server was:
550 5.4.1 Recipient address rejected: Access denied. [MN1PEPF0000ECD7.namprd02.prod.outlook.com
2024-11-13T20:42:05.972Z 08DD012F59DD07C1]
Final-Recipient: rfc822; [e-mail]
Action: failed
Status: 5.4.1
Remote-MTA: dns; phibro-com.mail.protection.outlook.com. (52.101.9.2, the
server for the domain phibro.com.)
Diagnostic-Code: smtp; 550 5.4.1 Recipient address rejected: Access denied. [MN1PEPF0000ECD7.namprd02.
prod.outlook.com 2024-11-13T20:42:05.972Z 08DD012F59DD07C1]
Last-Attempt-Date: Wed, 13 Nov 2024 12:42:06 -0800 (PST)
---------- Forwarded message ----------
From: Jordan Garahana <[e-mail]>
To: [e-mail]
Cc:
Bcc:
Date: Wed, 13 Nov 2024 13:41:52 -0700
Subject: Records Request for Inspection
----- Message truncated -----
1/21/25, 2:38 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-4408888969579897139&simpl=msg-a:r-43196548415192…3/3
Jordan Garahana <[e-mail]>
Records Request for Inspection
2 messages
Jordan Garahana <[e-mail]>Wed, Nov 6, 2024 at 4:36 PM
To: [e-mail]
Hello Thomas,
My name is Jordan Garahana and I am an Environmental Scientist with the state of Utah's Division of Air Quality. I am
requesting records/information as part of an attempted inspection I conducted of the facility in August, and these are the
records that I am looking for:
I.6- The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. I need any information
about any breakdowns that occurred, if there were any, from the previous inspection in 2021. If any of the
generators brokedown or there were any major leaks in the equipment.
II.A Equipment List- I need a confirmation that the equipment list in your AO is current and accurate. If any of that
equipment is no longer onsite please let me know. If you have any unapproved equipment, such as an extra
generator or boiler, please let me know as well. Please provide me with photos of the generators onsite that
include the power rating and the date of manufacture. I have attached the AO for your reference.
II.B.1.b- The following operating parameters shall be maintained within the indicated ranges: A. Inlet biogas flow rate
between 180 and 900 scfm; B. Outlet H2S concentration no greater than 200 ppmv; C. Inlet water temperature between
50 and 102 degrees Fahrenheit. I need recent records that show this is being recorded daily and that the parameters
mentioned in this condition are not exceeded.
II.B.1.b.2- All instruments shall be calibrated according to the manufacturers' instructions at least once every 12 months. I
need a record that shows the instruments used to measure these parameters are being calibrated according to
manufacturer's specifications within the previous 12 months.
II.B.2.a- The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month
period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60
Subpart ZZZZ, R307-401-8] I need a rolling 12-month total from July 2023 to June 2024 of the hours the emergency
engine operated indicating the reason the emergency engine was operating. I also need any recent maintenance
records for the emergency engines and generator engines.
II.B.2.b- The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency generator
engine. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm
sulfur. [R307-401-8] I need a recent bill of sale from your diesel fuel provider that demonstrates the diesel fuel
utilized onsite is ULSD and has a PPM of 15 or less.
II.B.4.c- The owner/operator shall not burn biogas as fuel in the hot water boiler for more than 2,000 hours per rolling 12-
month period. I need the rolling 12-month total from July 2023 to June 2024 showing that amount the hot water
boiler operated on biogas.
II.B.5.b- A manometer or magnehelic pressure gauge shall be installed to measure the differential pressure across the
oxidation catalysts. Static pressure differential across the oxidation catalysts shall be no more than 4.6 inches of water
column. The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time.
The instrument shall be calibrated according to the manufacturer's instructions at least once every 12 months. Recording of
the reading is required on a once-a-week basis. I need a log of the magnehelic pressure gauge readings indicating
that they are being recorded once a week. I also need a record that shows the magnehelic gauge is calibrated
once every 12 months.
II.B.5.c- The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the measurement of the
operating temperature in the oxidation catalysts. The temperature shall be maintained between 600 and 1300 degrees
Fahrenheit. The gauge shall be located such that an inspector /operator can safely read the indicator at any time. The
monitoring device shall be calibrated according to the manufacturer's instructions at least once every 12 months.
Recording of the reading is required on a once-a-week basis. I need a record that shows the temperature on the
oxidation catalysts is being recorded once a week and is operating between 600 and 1300 degrees. I also need a
1/21/25, 2:38 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-1354522575544002463&simpl=msg-a:r548243408255137…1/3
record that shows the monitoring device is being calibrated once every 12 months according to the
manufacturer's specifications.
II.B.5.g.10- Existing Source Operation For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. Your most recent
stack test according to our files for your operation was in December of 2020. If you have had a stack test since
then, please send me a copy of the report from that test. Otherwise, please schedule to have one conducted as
you are out of compliance with this AO condition.
Please let me know if you have any questions about the records I am requesting. Please have this information to me as
soon as possible.
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.
Phibro 2020 AO.pdf
555K
Mail Delivery Subsystem <[e-mail]>Wed, Nov 6, 2024 at 4:37 PM
To: [e-mail]
Message blocked
Your message to [e-mail] has been blocked. See
technical details below for more information.
1/21/25, 2:38 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-1354522575544002463&simpl=msg-a:r548243408255137…2/3
The response from the remote server was:
550 5.4.1 Recipient address rejected: Access denied. [CH3PEPF0000000F.namprd04.prod.outlook.com
2024-11-06T23:37:01.168Z 08DCFBA404C39C62]
Final-Recipient: rfc822; [e-mail]
Action: failed
Status: 5.4.1
Remote-MTA: dns; phibro-com.mail.protection.outlook.com. (52.101.194.4, the
server for the domain phibro.com.)
Diagnostic-Code: smtp; 550 5.4.1 Recipient address rejected: Access denied. [CH3PEPF0000000F.namprd04.
prod.outlook.com 2024-11-06T23:37:01.168Z 08DCFBA404C39C62]
Last-Attempt-Date: Wed, 06 Nov 2024 15:37:01 -0800 (PST)
---------- Forwarded message ----------
From: Jordan Garahana <[e-mail]>
To: [e-mail]
Cc:
Bcc:
Date: Wed, 6 Nov 2024 16:36:47 -0700
Subject: Records Request for Inspection
----- Message truncated -----
1/21/25, 2:38 PM State of Utah Mail - Records Request for Inspection
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-a:r-1354522575544002463&simpl=msg-a:r548243408255137…3/3
Jordan Garahana <[e-mail]>
Phibro Biodigester Compliance Advisory
3 messages
Chad Gilgen <[e-mail]>Tue, Jan 7, 2025 at 12:38 PM
To: [e-mail]
Cc: Jordan Garahana <[e-mail]>
Hello Tom,
Thanks for your call this afternoon. It was good to speak with you.
Per our discussion, you are in receipt of the Compliance Advisory (see attached DAQC-1243-24) for the Phibro
Biodigester near Beaver, Utah which is permitted under Utah Division of Air Quality (DAQ) Approval Order DAQE-
AN144070004-20 (also attached).
During our conversation you confirmed this facility has not operated since January 2023 and there are plans for it to
become operational within the immediate future.
Based on this information, the DAQ will issue a No Further Action Letter to close out the Compliance Advisory. What
would be the best address to send this letter to?
Please respond back to this email to let me know it was received and also please let me know if I missed anything from
our conversation or if you have any questions.
Thanks again,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
2 attachments
C-1243-24 - signed.pdf
395K
DAQE-AN144070004-20.pdf
555K
Tom Eckert <[e-mail]>Tue, Jan 7, 2025 at 12:47 PM
To: Chad Gilgen <[e-mail]>
Cc: Jordan Garahana <[e-mail]>
Thank you, Chad! I confirm receipt of your email. Please send the No Further Action Letter to:
Tom Eckert
600 Summer Street
Suite 205
1/7/25, 1:46 PM State of Utah Mail - Phibro Biodigester Compliance Advisory
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1820620223014172605&simpl=msg-f:182062022301417260…1/2
Stamford, CT 06901

Thanks for your assistance with this matter.

Best regards,
Tom
[Quoted text hidden]
Disclaimer
The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and
others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or
taking action in relation of the contents of this information is strictly prohibited and may be unlawful.
This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast Ltd, an innovator
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Chad Gilgen <[e-mail]>Tue, Jan 7, 2025 at 1:31 PM
To: Tom Eckert <[e-mail]>
Cc: Jordan Garahana <[e-mail]>
Hello Tom,
Thanks for confirming receipt of the email and letting us know the preferred address for the No Further Action Letter.
Sincerely,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
1/7/25, 1:46 PM State of Utah Mail - Phibro Biodigester Compliance Advisory
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1820620223014172605&simpl=msg-f:182062022301417260…2/2