DAQ-2025-000966

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DAQC-CI109360001-25
Site ID 10936 (B1)

MEMORANDUM

TO: FILE – GRAIN CRAFT, LLC – Ogden Flour Mill

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: February 3, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Weber County

INSPECTION DATE: September 26, 2024

SOURCE LOCATION: 220 West 30th Street
Ogden, UT 84401

DIRECTIONS: From I-15 north bound, take exit 341, 31st Street in Ogden. Turn
far right to 30th Street. The offices are in the small brick
building to the east of the silos. Be aware that the main contact
has changed from Steve Mosier to Stephen Gray.

SOURCE CONTACTS: Stephen Gray, Mill Superintendent
385-244-4764

Dave Dougherty, President Grain Craft, LLC
704-793-3387

OPERATING STATUS: Operating

PROCESS DESCRIPTION: Grain Craft, LLC operates a soft and hard flour wheat elevator
storage and flour processing mill. Wheat is received at the mill
by truck and rail car. The wheat is unloaded into a reclaiming pit.
It is then augured and conveyed to storage where it is cleaned by
air mixing and agitation. Waste wheat is collected from this first
baghouse and sold to be used as animal feed. Flour is milled
after the wheat has been cleaned. Various levels of refined flour
are sold in bags or shipped in bulk. This mill is permitted for 28
baghouses. All material collected by the baghouses is conveyed
back into the mill for additional processing or sold to use as
animal feed.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN109360008-23, dated
July 31, 2023

NSPS (Part 60) -DD: Standards of Performance for Grain
Elevators.
0 . ) $ . ) - "
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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Grain Craft, LLC
Ogden Flour Mill

220 West 30th Street 220 West 30th Street
Ogden, UT 84401 Ogden, UT 84401

SIC Code: 2041: (Flour & Other Grain Mill Products)

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. Grain Craft, LLC was out of compliance with the stack testing
reporting and protocol notification requirements (conditions II.B.3.b.3 and II.B.3.b.4) for
the Mill B stack test performed on March 30, 2021. This issue was resolved with the
acceptance of the protocol and stack test with the memo DAQC-1150-24. This facility was
otherwise in compliance with the limits, maintenance, and record keeping requirements of
this AO. No UACR 307-107 applicable breakdowns have occurred during the last five
months. An Emissions Inventory was submitted for the 2023 activity year and is attached to
this inspection memo.
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Section II: SPECIAL PROVISIONS

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

II.A.1 Ogden Flour Mill

II.A.2 Unit #2
One (1) "A" mill cleaning baghouse (Kice M240-8' baghouse, "A" wheat cleaning baghouse with an
airflow approximately 12,200 dscfm.

II.A.3 Unit #3
One (1) Kice M150-8' baghouse ("A" mill leg/purifier suction baghouse)

II.A.4 Unit #7
One (1) Kice M72-8' baghouse ("B" wheat cleaning baghouse #2)

II.A.5 Unit #8
One (1) Kice M20-4' baghouse (feed load-out baghouse)

II.A.6 Unit #9
One (1) Micro Pulsaire MP160-8' baghouse ("B" wheat cleaning baghouse #1)

II.A.7 Unit #10
One (1) Kice M32-8' baghouse (Hammermill suction baghouse)

II.A.8 Unit #11
One (1) Kice M120-8' baghouse ("B" rolls suction baghouse)

II.A.9 Unit #12
One (1) Kice M96-6' baghouse (bulk flour load-out baghouse)

II.A.10 Unit #13
One (1) Kice M49-8' baghouse (cake-drier baghouse)

II.A.11 Unit #14
One (1) Kice M120-10' baghouse (bulk plant general suction baghouse)

II.A.12 Unit #15
One (1) Kice M120-8' baghouse ("B" mill leg suction baghouse)

II.A.13 Unit #17
One (1) Kice M16-10' baghouse ("B" mill roll suction baghouse)

II.A.14 Unit #19
One (1) Kice M96-8' baghouse (elevator load-out suction baghouse)

II.A.15 Unit #20
One (1) Kice M72-8' baghouse (belt conveyor suction baghouse)

II.A.16 Unit #23
One (1) Kice M64-6' baghouse (bin-top suction baghouse)
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II.A.17 Unit #24
One (1) Kice M72-8' baghouse (transfer floor suction baghouse)

II.A.18 Unit #27
One (1) Kice M192-10' baghouse (flour-mill pneumatic-lift system baghouse)

II.A.19 Unit #1
One (1) Kice M240-8' baghouse ("A" mill pneumatics baghouse). This baghouse vents to the
atmosphere or to the inside of a building.

II.A.20 Unit #18
One (1) Buhler ASFA64-10 pulse-jet baghouse ("C" mill pneumatics baghouse). This baghouse
vents to the atmosphere or to the inside of a building.

II.A.21 Unit #28
One (1) "C" mill pneumatics general suction baghouse. This baghouse vents to the atmosphere or to
the inside of a building.

II.A.22 Unit #4
One (1) Kice M48-6' baghouse (large packing bin/leg baghouse). This baghouse shall only vent
directly to the inside of the building.

II.A.23 Unit #5
One (1) Kice M6-6' baghouses (packing system baghouse). This baghouse shall only vent directly to
the inside of the building.

II.A.24 Unit #6
One (1) Kice M6-6' baghouses (packing system baghouse). This baghouse shall only vent directly to
the inside of the building.

II.A.25 Unit #16
One (1) Kice M21-6' baghouse (large pack-receiver baghouse). This baghouse shall only vent
directly to the inside of the building.

II.A.26 Unit #21
One (1) Kice M72-8' baghouse (belt conveyor suction baghouse). This baghouse shall only vent
directly to the inside of the building.

II.A.27 Unit #22
One (1) Kice M72-8' baghouse (belt conveyor suction baghouse). This baghouse shall only vent
directly to the inside of the building.

II.A.28 Unit #25
One (1) Kice M72-6' baghouse (elevator leg suction baghouse). This baghouse shall only vent
directly to the inside of the building.

II.A.29 Unit #26
One (1) Kice M96-6' baghouse (elevator leg suction baghouse). This baghouse shall only vent
directly to the inside of the building.

Brand names and model numbers mentioned above are for identification only
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II.A.30 Solvent Parts Washer
Purpose: Cleaning Metal Parts with Solvents
This is a closed system with no emissions.

Status: Out of Compliance. The referenced equipment has been installed and is operating
with the following exceptions. II.A.10, Unit #13, the Kice M49-8' (cake dryer)
baghouse was removed prior to 2000. II.A.14, Unit #19 (the elevator load-out suction
baghouse), operates as a whole wheat berry baghouse, and is currently rarely used.
II.A.23, Unit #5, and II.A.24, Unit #6 refer to internally venting packing baghouses
that have been removed. This facility was non-compliant with the timely stack testing
data submission requirements of conditions II.B.3.b.3 and II.B.3.b.4. The late
submission was documented with a Warning Letter. No further compliance action is
required at this time.

II.B Requirements and Limitations

II.B.1 Site-wide Requirements

II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions to
exceed the following limits:

A. Unit #10 Hammermill suction baghouse - 10% opacity

B. Unit #7 wheat-cleaning baghouse #2 - 10% opacity

C. Unit #14 Kice M120-10' baghouse - 10% opacity

D. Unit #18 Buhler ASFA64-10 baghouse - 10% opacity

E. Unit #27 pneumatic lift-system baghouse (Kice M192-10') - 10% opacity

F. Unit #28 baghouse - 10% opacity

G. All other emission sources - 20% opacity

[R307-401-8]

II.B.1.a.1 Opacity observations of visible emissions from stationary sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9. [R307-401-8]

Status: In Compliance. The baghouse stacks can be viewed from the outside areas
surrounding the buildings. No visible emissions were observed from any stack or vent
during this inspection.

II.B.1.b The owner/operator shall not produce more than the following: A. 5,840,000 hundred weights per rolling 12-month period B. 18,000 hundred weights per day [R307-401-8]
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II.B.1.b.1 The owner/operator shall:

A. Determine production by operator logs

B. Record production on a daily basis

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

D. Keep the production records for all periods the plant is in operation.

[R307-401-8]

Status: In Compliance. The 12-month rolling total for the time period of September 2023
to August 2024 was reported as 21,840.25 tons or 390,004.46 hundred weights (US ton x
18380). See the attached monthly spreadsheet summary. The daily average calculated by
the Plant Manager, Steve Mosier, was created in the office as the daily spreadsheet totals
were reviewed. The daily average was calculated as 16,500 hundred weights. No single daily
total reviewed exceeded the limit of 18,000 hundred weights.

II.B.1.c The owner/operator shall not exceed the following hours of operation for the elevator load-out
suction baghouse (Unit #19, Kice M96-8'):

A. 4,380 hours per rolling 12-month period

B. 12 hours per day

[R307-301-8]

Status: Not Applicable. Unit #19 did not operate during the previous 12-months. See
II.B.1.c.1 for more details.

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

A. Determine hours of operation by monitoring and maintaining an operations log

B. Record hours of operation on a daily basis

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th
day of each month using data from the previous 12 months

D. Keep hours of operation records for all periods the plant is in operation.

[R307-401-8]

Status: Not Applicable. The Plant Manager stated that Unit #19, Kice M96-8", refers to
the whole wheat berry loadout baghouse which was not used during the 12-month period of
September 2023 through August 2024. Bill of Lading records are used to calculate the
operation hours for the time periods when this baghouse is used.

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II.B.1.d The owner/operator shall comply with UAC R307-309: Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust. [R307-309]

Status: In Compliance. The area surrounding the plant is paved. No fugitive dust was observed from any area. There was no track-out at the entrance to the facility.

II.B.1.e The owner/operator shall comply with UAC R307-304: Solvent Cleaning Operations.
[R307-304]

Status: In Compliance. This condition refers to the Torrent 400 Parts Washer as listed
under the permitted equipment list as II.A.30. A review of this condition determined that
the State Rule regulating this equipment should be R307-335 for degreasing rather than
R307-304 for manually applied Solvent Cleaning Operations. The Torrent 400 Parts
Washer is referenced on the current AO as a closed system with no emissions. The product
used in the parts washer is Hydro Solv. A Safety Data Sheet for this product has been
included in the attachment for informational purposes.

II.B.2 Requirements on Units #10, 18, 27, and 28 Baghouses
II.B.2.a The owner/operator shall use the following baghouses to control particulate emissions from the following areas: A. Unit #18 Buhler ASFA64-10 pulse-jet baghouse and Unit #28 "C" mill pneumatics general suction baghouse - the milling equipment consisting of six roller mills, eighteen cyclones, one purifier and two dusters. B. Unit #27 Kice M192-10' baghouse - the pneumatic lift system in the flourmill. [R307-401-8] Status: In Compliance. The referenced baghouses were installed and permitted with the 2011 DAQE-AN109360006-11 AO and operate as described. No changes have occurred since 2011. II.B.2.b The Unit #18 Buhler ASFA64-10 pulse-jet baghouse shall be sized to handle at least 7,500 ACFM. The Unit #27 Kice M192-10' baghouse shall be sized to handle at least 14,000 ACFM. [R307-401-8] Status: In Compliance. The ACFM capacities for both the Unit #18 and #27 baghouses were rated at the time of the 2011 AO and were submitted with the NOI for that permit. See the attached NOI description for the baghouses. No changes in these baghouse flow rates have occurred since that time.
II.B.2.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure differential across each baghouse. [R307-401-8]

Status: In Compliance. Pressure gauges have been installed to measure the static
differential across each baghouse.

II.B.2.c.1 Each pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] Status: In Compliance. Each pressure gauge can be safely read at any time during the baghouse operation.
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II.B.2.c.2 Each pressure gauge shall measure the static pressure differential in 0.5-inch water column
increments or less. [R307-401-8]

Status: In Compliance. The pressure gauges can measure less than 0.5 increments.

II.B.2.d During operation of the Unit #28 baghouse, the owner/operator shall maintain the static pressure
differential across the baghouse between 0.5 and 6.0 inches of water column.

During operation of the Unit #10 Hammermill suction baghouse, the owner/operator shall
maintain the static pressure differential across the baghouse between 0.5 and 6.0 inches of water
column.

During operation of the Unit #18 Buhler ASFA64-10 pulse-jet baghouse, the owner/operator
shall maintain the static pressure differential across the baghouse between 0.2 and 7.0 inches of
water column.

[R307-401-8]

Status: In Compliance. Records for the referenced baghouses are maintained at the office.
Records for a 12-month period were reviewed during the site visit. All pressure-drop
readings reviewed were within the established limits. The reviewed records for Unit #28
(The C-Mill Suction) were between 1.0 to 6.0, with the average daily reading recorded at
2.0. The Unit #10 Hammermill daily reading were between .8 to 6.0 with the average
reading recorded at 2.8. The Unit #18 (C-Mill Pneumatic) readings ranged between 4.0 to
5.9 with the average daily reading recorded at 5.1. The daily readings for the month of
August of 2024 are attached as example records.

II.B.2.d.1 The owner/operator shall record the static pressure differential at least once per operating day
while each baghouse is operating. [R307-401-8]

Status: In Compliance. Daily readings are taken for all periods when the baghouse is
operating.

II.B.2.d.2 The owner/operator shall maintain the following records of the static pressure differential:

A. Unit identification;

B. Daily static pressure differential readings;

C. Date of reading.

[R307-401-8]

Status: In Compliance. The pressure-drop records identify the specific baghouse, the
actual pressure drop, and the date of the reading.

II.B.2.e At least once every 12 months, the owner/operator shall calibrate each pressure gauge in
accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8]

Status: In Compliance. The plant manager, Steve Mosier, stated that the pressure gauges
are calibrated every time that the filters in the baghouses are replaced. In addition, the
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gauge is verified at the end of each month and signed by the Supervisor to verify the
previous month's magnehelic readings. See the attached August 2024 log with signature
examples. Mr. Mosier stated that the gauges are frequently replaced throughout the year
due to heavy use and in the event that the pressure readings appear inconsistent with actual
operating conditions.

II.B.2.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

Status: In Compliance. The gauge accuracy is verified near the beginning of each month.

II.B.3 Requirements and Testing Procedures on Units #2 and 9 Baghouse

II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from Units
#2 and #9 Baghouses:

Source Pollutant lb/hr grains/dscf
Unit #2 "A" mill wheat Filterable PM10 2.11 0.016
cleaning baghouse1

Unit #9 "B" mill wheat Filterable PM10 4.98 0.016
cleaning baghouse2

1The throughput of wheat for this baghouse during the test shall be at least 200 hundred weights
per hour (cwt/hr). A hundred weight is 100 pounds of flour.
2The throughput of wheat for this baghouse during the test shall be at least 600 bushels per hour.

[R307-401-8]

Status: In Compliance. The Unit #2 "A" mill wheat cleaning baghouse was tested for Total
PM on May 21, 2024. The DAQ reviewed results for this test was 0.1481 lb/hr and 0.0014
gr/dscf. See the stack testing memo dated July 18, 2024 (DAQC-730-24), for more
information.

The Unit #9 "B" mill wheat cleaning baghouse was tested for PM10 on March 30, 2021.
The DAQ reviewed results for this test was 0.0190 lb/hr and 0.000 gr/dscf. See the stack
testing memo dated November 14, 2024 (DAQC-1150-24), for more information. The
Environmental Consulting Company (Tetco) that performed this test had failed to submit
the protocol and completed stack test to the DAQ for this baghouse. Grain Craft and Tetco
were alerted to the fact that the relevant documents had never been submitted. Grain Craft
determined that a previous employee had left prior to providing the DAQ with the data.
Tetco submitted the documents on October 25, 2024. The issue of non-compliance was
documented with a Warning Letter. The stack testing results were otherwise accurate and
within the AO limits.

II.B.3.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-165-2, R307-401-8]

II.B.3.a.2 Test Frequency
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The owner/operator shall conduct a stack test on the emission unit within five (5) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

Status: In Compliance. Unit #2 "A" mill baghouse shall test again during the 2029
calendar year. Unit #9 "B" mill wheat cleaning baghouse shall test again during the 2026
calendar year.

II.B.3.a.3 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]

II.B.3.b The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.3.b.1 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.3.b.2 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.3.b.3 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

Status: Out of Compliance. This facility did not submit the stack testing data for the Unit
#9 "B" mill baghouse within the specified time period. The missing documents were
submitted after this inspection. A Warning Letter documenting the findings was issued. No
additional compliance action is recommended.

II.B.3.b.4 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

Status: Out of Compliance. This facility did not submit the protocol for the Unit #9 "B"
mill baghouse within the specified time period. The missing documents were submitted
after this inspection. A Warning Letter documenting the findings was issued. No additional
compliance action is recommended.

II.B.3.b.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.3.c Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
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methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.3.c.1 Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K)

B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

Status: In Compliance. This condition was added to the 2023 AO due to the NSPS Subpart
DD determination for grain elevators. The March 30, 2021, particulate stack test was
evaluated based on the criteria of DAQE-AN109360008-23 and was reviewed as compliant
with this AO's stack testing requirements.

II.B.3.c.2 Filterable PM10

40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10.

[R307-401-8]

II.B.3.c.3 Volumetric Flow Rate

40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director.
[R307-401-8]

Section III: APPLICABLE FEDERAL REQUIREMENTS

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

NSPS (Part 60) - DD: Standards of Performance for Grain Elevators

Status: In Compliance. The NSR engineering review for the 2023 DAQE-AN109360008-23 AO
determined that NSPS Subpart DD applies to this grain elevator facility. The particulate standards for
40 CFR 60.302 were addressed by adding temperature, pressure, and averaging time requirements
during stack testing as established by Condition II.B.3.c.1. The March 30, 2021, B-Mill baghouse stack
test was evaluated using the standards of DAQE-AN109360008-23. See DAQC-1150-24 for more
information.

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AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Stationary Sources [R307-210]

Status: In Compliance. This Area Source Rule incorporates NSPS Subpart DD for Grain Elevators.
See the above Federal Requirement reference for more information.

Solvent Cleaning [R307-304]

Status: Not Applicable. A reference to this Rule was intended to address the Torrent 400 Parts
Washer referenced by Condition II.A.30. A Minor Source Section Compliance review determined
that this process is not a solvent cleaning operation but is applicable to R307-335 for Degreasing.

Degreasing [R307-335]

Status: In Compliance. Grain Craft uses the Torrent 400 Parts Washer referenced by Condition
II.A.30. The Parts Washer is a closed system that the current AO identifies as having no emissions.
The spent solvent is transported for offsite disposal by a third-party contractor. The product used is
Hydro Solv. This solvent used has not changed during the last 5 years. A Safety Data Sheet has been
attached to this memo for informational purposes.

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

Status: In Compliance. No fugitive dust was observed from the operation areas or entrance road at
the time of this inspection. All of the applicable areas at this site are paved.

EMISSION INVENTORY:
Grain Craft, LLC submitted an Emissions Inventory for the 2023 activity year. The Summary Emission
Report is attached in the documents for this inspection. Listed below are the Actual Emissions Inventory
provided from Grain Craft, LLC – Ogden Flour Mill. A comparison of the estimated total potential
emissions (PTE) on AO: DAQE-AN109360008-23, dated July 31, 2023, is provided. PTE are supplied
for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Particulate Matter - PM10 46.79
Particulate Matter - PM2.5 23.40

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr

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PREVIOUS ENFORCEMENT
ACTIONS: A Compliance Advisory was issued on November 5, 2022, for
failure to maintain baghouse differentials within the permitted
limits (DAQC-1452-22). A No Further Action Letter was issued
on December 15, 2022 (DAQC-1588-22), after the company
addressed the issue.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN109360008-23,
dated July 31, 2023, the overall status is: Out of Compliance.
Grain Craft, LLC, failed to provide a stack testing protocol and
the testing data for the March 30, 2021, PM10 stack test for the
B-Mill Baghouse. The missing documents were noted during this
inspection, which were then submitted to the DAQ on November
8, 2024. A subsequent DAQ review determined that the B-Mill
stack test was compliant with the 2023 AO limits and were
accepted. This facility was otherwise in compliance with the AO
DAQE-AN109360008-23 dated July 31, 2023, and NSPS
Subpart DD for Grain Elevators. A Warning Letter was issued to
document the late submission of the stack testing data and
protocol. No further action is recommended.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect during the next targeting year. Check for all new stack
testing documents when applicable. Be aware that the new site
contact is Stephen Gray.

NSR RECOMMENDATIONS: The next AO modification should update Condition II.B.1.e to
change the reference from R307-304 for Solvent Cleaning to
R307-335 for Degreasing. In addition, NSR should consider
removing II.A.10, Unit #13, the cake-dryer baghouse, II.A.23,
and II.A.24, the two internally venting packing system
baghouses, as they have been removed.

ATTACHMENTS: VEO, August 2024 examples of the Magnehelic Readings log,
Monthly production totals, Hydro Solv SDS, January 2011 NOI
Baghouse acfm references, email correspondence regarding “B”
Mill Baghouse Stack Testing Requirements, and 2023 activity
year SLEIS Summary Emissions Report.
Applied filters:Date Name is on or after 9/1/2023 12:00:00 AM and is before 9/1/2024 12:00:00 AMMill Short N
Fiscal Year Fiscal Mon Total Flour Total Flour Ton
2024 1 376,959 18,847.95
2024 2 412,011 20,600.55
2024 3 527,792 26,389.60
2024 4 424,424 21,221.20
2024 5 447,310 22,365.50
2024 6 508,416 25,420.80
2024 7 416,702 20,835.10
2024 8 436,805 21,840.25
2023 9 432,362 21,618.10
2024 9 128,410 6,420.50
2023 10 409,519 20,475.95
2023 11 431,946 21,597.30
2023 12 508,973 25,448.65
Safety Data Sheet: HYDRO SOLV
Supercedes Date 12/20/2012 Issuing Date 09/19/2013
1. PRODUCT AND COMPANY IDENTIFICATION

Product Name HYDRO SOLV Product Code 0687
Recommended use Cleaning agent Chemical nature Aqueous solution of surfactants and ethanolamine
Information on Manufacturer Emergency Telephone Number
CERTIFIED LABS, DIV. OF NCH CORP.CHEMTREC® 800-424-9300
BOX 152170
IRVING, TEXAS 75015
Telephone inquiry
972-579-2477

2. HAZARD IDENTIFICATION

Color Blue Physical State Liquid Odor Mild amine

GHS
Classification
Physical Hazards
None
Health Hazard
Skin Corrosion/Irritation Category 2
Serious Eye Damage/Eye Irritation Category 2A
Respiratory Sensitization Category 1
Skin Sensitization Category 1
Specific target organ systemic toxicity (single exposure) Category 3
Specific target organ systemic toxicity (repeated exposure) Category 2
Other hazards
None

Labeling
Signal Word
DANGER

Hazard Statements
H315 - Causes skin irritation
H317 - May cause an allergic skin reaction
H319 - Causes serious eye irritation
H334 - May cause allergy or asthma symptoms or breathing difficulties if
inhaled
H336 - May cause drowsiness or dizziness
H373 - May cause damage to organs through prolonged or repeated
exposure
Precautionary Statements
P280 - Wear protective gloves, protective clothing and eye protection.
P264 - Wash face, hands and any exposed skin thoroughly after handling.
P272 - Contaminated work clothing should not be allowed out of the workplace
P260 - Do not breathe mist
P271 - Use in a well-ventilated area.
P285 - In case of inadequate ventilation wear respiratory protection
P302+ P352 - IF ON SKIN: Wash with plenty of soap and water
P333 + P313 - If skin irritation or rash occurs, get medical attention
P362 - Take off contaminated clothing and wash before reuse
P305 + P351 + P338 - IF IN EYES: Rinse cautiously with water for several minutes.
Remove contact lenses, if present and easy to do. Continue rinsing.
P337 + P313 - If eye irritation persists, get medical attention.
P304 + P341 - IF INHALED: If breathing is difficult, remove to fresh air and keep at rest in
a position comfortable for breathing
P342 + P311 - If experiencing respiratory symptoms, call a physician
P501 - Dispose of contents and container in accordance with applicable regulations.

4 % of the mixture consists of ingredient(s) of unknown toxicity

3. COMPOSITION / INFORMATION ON INGREDIENTS

Component CAS-No Weight %
Tallow alkylamine ethoxylate surfactant 61791-26-2 10-30
Polyethylene glycol phenyl ether phosphate 39464-70-5 10-30
Sodium tripolyphosphate 7758-29-4 1-5
Ethanolamine 141-43-5 1-5
Page 1 / 5
Monoethanolamine Phosphate 68005-08-3 1-5

4. FIRST AID MEASURES

General advice Avoid contact with skin, eyes and clothing. Avoid breathing vapors or mists.
Eye Contact Rinse thoroughly with plenty of water, also under the eyelids. Get medical attention if irritation
develops and persists.
Skin Contact Wash off immediately with plenty of water for at least 15 minutes. Remove contaminated clothing
and shoes. Get medical attention if irritation develops and persists. Wash contaminated clothing
before re-use.
Inhalation Move to fresh air. In case of shortness of breath, give oxygen. If breathing has stopped, apply artificial
respiration. Get medical attention immediately.
Ingestion Drink 1 or 2 glasses of water. Do NOT induce vomiting. Get medical attention if symptoms occur.
Notes to physician May cause sensitization of susceptible persons.

5. FIRE-FIGHTING MEASURES

Flash Point > 201 °F / > 94 °C Method Not applicable
Flammability Limits in Air % Not applicable. Upper No data available Lower No data available
Suitable Extinguishing Media
Water spray. Foam. Alcohol-resistant foam. Carbon dioxide (CO2). Dry chemical. Use extinguishing measures that are appropriate to local
circumstances and the surrounding environment.
Specific hazards arising from the chemical
Material can create slippery conditions.
Protective Equipment and Precautions for Firefighters
As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full protective gear.
NFPA Health 2 Flammability 1 Instability 0
HMIS Health 2 Flammability 1 Instability 0

6. ACCIDENTAL RELEASE MEASURES

Personal Precautions Use personal protective equipment. Prevent further leakage or spillage if safe to do so. Material can
create slippery conditions.
Environmental Precautions Do not flush into surface water or sanitary sewer system.
Methods for Containment Contain spillage, soak up with non-combustible absorbent material, (e.g. sand, earth,
diatomaceous earth, vermiculite) and transfer to a container for disposal according to local / national
regulations (see section 13).
Methods for Cleaning Up Pick up and transfer to properly labeled containers.
Neutralizing Agent Not applicable.

7. HANDLING AND STORAGE

Handling Avoid contact with skin, eyes and clothing. Avoid breathing vapors or mists.
Storage Store in original container. Keep containers tightly closed in a dry, cool and well-ventilated place.
Freezing will affect the physical condition but will not damage the material. Thaw and mix before
using.
Storage Temperature Minimum 35 °F / 2 °C Maximum 120 °F / 49 °C
Storage Conditions Indoor X Outdoor Heated Refrigerated

8. EXPOSURE CONTROLS / PERSONAL PROTECTION

Exposure Guidelines
Component ACGIH TLV OSHA PEL NIOSH
Tallow alkylamine ethoxylate surfactant No data available No data available No data available
Polyethylene glycol phenyl ether phosphate No data available No data available No data available
Sodium tripolyphosphate No data available No data available No data available
Ethanolamine TWA: 3 ppm
STEL: 6 ppm
TWA: 3 ppm
TWA: 6 mg/m3
IDLH: 30 ppm
STEL 6 ppm
STEL 15 mg/m3
TWA: 3 ppm
TWA: 8 mg/m3
Monoethanolamine Phosphate No data available No data available No data available

Engineering Measures Ensure adequate ventilation, especially in confined areas.
Personal Protective Equipment
Eye/Face Protection Safety glasses with side-shields.
0687 - HYDRO SOLV0687 - HYDRO SOLV0687 - HYDRO SOLV0687 - HYDRO SOLV Issuing Date 09/19/2013Issuing Date 09/19/2013Issuing Date 09/19/2013Issuing Date 09/19/2013
Page 2 / 5
Skin Protection Wear suitable protective clothing, Impervious gloves.
Respiratory Protection In case of inadequate ventilation wear respiratory protection. When workers are facing
concentrations above the exposure limit they must use appropriate certified respirators.
General Hygiene Considerations Remove and wash contaminated clothing before re-use. Ensure that eyewash stations and safety
showers are close to the workstation location.

9. PHYSICAL AND CHEMICAL PROPERTIES

Physical State Liquid Viscosity Non viscous
Color Blue Odor Mild amine
Odor Threshold Not applicable Appearance Transparent
pH 7.5 Specific Gravity 1.075
Evaporation Rate 0.4 (Butyl acetate=1) Percent Volatile (Volume) 70.6
VOC Content (%) 2.8 VOC Photoreactive (Y/N) Yes
VOC Max Use Dilution (g/L) 8.5 VOC Content (g/L) 34
Vapor Pressure 15.9 mmHg @ 70°F Vapor Density 0.6 (Air = 1.0)
Solubility Completely soluble n-Octanol/Water Partition No data available
Melting Point/Range No data available Decomposition Temperature No data available
Boiling Point/Range 212 °F / 100 °C Flammability (solid, gas) No data available
Flash Point > 201 °F / > 94 °C Method Not applicable
Autoignition Temperature No information available.
Flammability Limits in Air % Not applicable. Upper No data available Lower No data available

10. STABILITY AND REACTIVITY

Chemical Stability Stable under normal conditions. Hazardous polymerization does not
occur.
Conditions to Avoid None known
Incompatible Products Strong oxidizing agents, Strong acids, Reducing agents, Highly
halogenated compounds, Nitrites, Nitrates.
Hazardous Decomposition Products Carbon oxides, Nitrogen oxides (NOx), Oxides of phosphorus, Sodium
oxides, Ammonia.
Possibility of Hazardous Reactions None under normal processing

11. TOXICOLOGICAL INFORMATION

Product Information

The following values are calculated based on chapter 3.1 of the GHS document (Rev. 3, 2009):
Oral LD50 No information available
Dermal LD50 No information available
Inhalation LC50
Gas No information available
Mist No information available
Vapor No information available

Principle Route of Exposure Skin contact, Eye contact, Inhalation.
Primary Routes of Entry Skin Absorption, Inhalation.
Acute Effects
Eyes Severe irritation.
Skin Severe irritation. May cause allergic skin reaction.
Inhalation May cause irritation of respiratory tract. May cause allergic respiratory reaction. Inhalation may cause
central nervous system effects. May cause central nervous system depression. Symptoms and
signs include headache, dizziness, fatigue, muscular weakness, drowsiness and in extreme cases,
loss of consciousness.
Ingestion Ingestion may cause gastrointestinal irritation, nausea, vomiting and diarrhea.
Chronic Toxicity Liver and kidney injuries may occur. May cause sensitization by skin contact. May cause sensitization
by inhalation. Contains a known or suspected reproductive toxin.
Target Organ Effects Central nervous system, Respiratory system, Immune system, Reproductive System, Liver, Kidney.
Aggravated Medical Conditions Skin disorders, Respiratory disorders, Neurological disorders, Liver disorders, Kidney disorders.
Component Information
Acute Toxicity
Component LD50 Oral LD50 Dermal LC50 Inhalation Draize Test Other
Tallow alkylamine ethoxylate
surfactant
no data available no data available no data available no data available no data available
Polyethylene glycol phenyl
ether phosphate
no data available no data available no data available no data available no data available
Sodium tripolyphosphate = 3100 mg/kg ( Rat ) > 7940 mg/kg ( Rabbit ) no data available no data available no data available
Ethanolamine = 1720 mg/kg ( Rat ) = 1 mL/kg ( Rabbit ) no data available no data available no data available
Monoethanolamine Phosphate no data available no data available no data available no data available no data available
0687 - HYDRO SOLV0687 - HYDRO SOLV0687 - HYDRO SOLV0687 - HYDRO SOLV Issuing Date 09/19/2013Issuing Date 09/19/2013Issuing Date 09/19/2013Issuing Date 09/19/2013
Page 3 / 5

Chronic Toxicity
Component Mutagenicity Sensitization Developmental Toxicity Reproductive Toxicity Target Organ Effects
Tallow alkylamine ethoxylate
surfactant
no data available Skin sensitization no data available no data available Immune system
Polyethylene glycol phenyl
ether phosphate
no data available no data available no data available no data available no data available
Sodium tripolyphosphate no data available no data available no data available no data available Spleen, kidneys
Ethanolamine no data available Skin sensitization,
Respiratory sensitization
no data available X eyes, CNS, respiratory
system, skin, liver,
kidney, reproductive
system, immune system
Monoethanolamine Phosphate no data available no data available no data available no data available no data available

Carcinogenicity
Component ACGIH IARC NTP OSHA Other
Tallow alkylamine ethoxylate
surfactant
not applicable not applicable not applicable not applicable not applicable
Polyethylene glycol phenyl
ether phosphate
not applicable not applicable not applicable not applicable not applicable
Sodium tripolyphosphate not applicable not applicable not applicable not applicable not applicable
Ethanolamine not applicable not applicable not applicable not applicable not applicable
Monoethanolamine Phosphate not applicable not applicable not applicable not applicable not applicable

12. ECOLOGICAL INFORMATION
Product Information No information available.
Component Information
Component Toxicity to Algae Toxicity to Fish Microtox Water Flea log Pow
Tallow alkylamine ethoxylate
surfactant
no data available no data available no data available no data available N/A
Polyethylene glycol phenyl ether
phosphate
no data available no data available no data available no data available N/A
Sodium tripolyphosphate no data available LC50 = 1650 mg/L Leuciscus idus
48 h
no data available no data available N/A
Ethanolamine EC50 = 15 mg/L
Desmodesmus
subspicatus 72 h
LC50 = 227 mg/L Pimephales
promelas 96 h
LC50 = 3684 mg/L Brachydanio rerio
96 h
LC50 300 - 1000 mg/L Lepomis
macrochirus 96 h
LC50 114 - 196 mg/L Oncorhynchus
mykiss 96 h
LC50 > 200 mg/L Oncorhynchus
mykiss 96 h
EC50 = 110 mg/L 17 h
EC50 = 12200 mg/L 2 h
EC50 = 13.7 mg/L 30 min
EC50= 65 mg/L 48 h -1.91
Monoethanolamine Phosphate no data available no data available no data available no data available N/A

Persistence and Degradability No information available.
Bioaccumulation No information available.
Mobility No information available.

13. DISPOSAL CONSIDERATIONS

Product Disposal Dispose of in accordance with local regulations.
Container Disposal Empty containers should be taken for local recycling, recovery, or waste disposal.

14. TRANSPORT INFORMATION

DOT Not regulated

TDG Not regulated

ICAO Not regulated

IATA Not regulated

IMDG/IMO Not regulated

0687 - HYDRO SOLV0687 - HYDRO SOLV0687 - HYDRO SOLV0687 - HYDRO SOLV Issuing Date 09/19/2013Issuing Date 09/19/2013Issuing Date 09/19/2013Issuing Date 09/19/2013
Page 4 / 5

15. REGULATORY INFORMATION

Inventories
TSCA Complies
DSL Complies
U.S. Federal Regulations
SARA 313
Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA). This product does not contain any chemicals
which are subject to the reporting requirements of the Act and and Title 40 of the Code of Federal Regulations, Part 372.

SARA 311/312 Hazardous Categorization
Acute Health Hazard

Yes
Chronic Health Hazard

Yes
Fire Hazard

No
Sudden Release of
Pressure Hazard
No
Reactive Hazard

No
CERCLA
Component Hazardous Substances RQs CERCLA EHS RQs
Tallow alkylamine ethoxylate surfactant Not applicable Not applicable
Polyethylene glycol phenyl ether phosphate Not applicable Not applicable
Sodium tripolyphosphate Not applicable Not applicable
Ethanolamine Not applicable Not applicable
Monoethanolamine Phosphate Not applicable Not applicable

16. OTHER INFORMATION

Prepared By Sarah Williamson
Supercedes Date 12/20/2012
Issuing Date 09/19/2013
Reason for Revision No information available.
Glossary No information available.
List of References. No information available.
CERTIFIED LABS, DIV. OF NCH CORP.assumes no responsibility for personal injury or property damage caused by the use, storage,
or disposal of the product in a manner not recommended on the product label. Users assume all risks associated with such
unrecommended use, storage or disposal of the product. The information provided on this document is correct to the best of our
knowledge, information and belief at the date of its publication. The information given is designed only as a guide for safe handling, use,
processing, storage, transportation, disposal and release and is not to be considered as a warranty or quality specification. The
information relates only to the specific material designated and may not be valid for such material used in combination with any other
material or in any process, unless specified in the text.

0687 - HYDRO SOLV0687 - HYDRO SOLV0687 - HYDRO SOLV0687 - HYDRO SOLV Issuing Date 09/19/2013Issuing Date 09/19/2013Issuing Date 09/19/2013Issuing Date 09/19/2013
Page 5 / 5
Susan Weisenberg <[e-mail]>
Re: requirement to stack test "B" Mill baghouse
1 message
Chad Gilgen <[e-mail]>Wed, Nov 6, 2024 at 11:00 AM
To: Steve Mosier <[e-mail]>
Cc: Susan Weisenberg <[e-mail]>, Dean Kitchen <[e-mail]>
Hello Steve,
The DAQ has reviewed your response. Due to the factors surrounding the changeover in employment, we will be able to
close this one out with a Warning Letter.
Please submit this stack test through the DAQ's online portal at https://deq.utah.gov/air-quality/stationary-source-
compliance and choosing "Submit Minor Stack Test Protocol/Report" in the middle of the page. The DAQ reserves the
right to pursue additional compliance action if our internal stack test audit shows this test to be out of compliance with the
conditions in the AO.
Thanks and let me know if you have any questions.
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.
On Fri, Oct 25, 2024 at 12:20 PM Steve Mosier <[e-mail]> wrote:
I think part of the issue stemmed from Tim Becker leaving Grain Cra, and some emails were sent to his
old email aer he le?
Steve Mosier
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844
From: Susan Weisenberg <[e-mail]>
Sent: Friday, October 25, 2024 12:12 PM
To: Dean Kitchen <[e-mail]>
1/23/25, 8:07 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1814997062486485067…1/5
Cc: Steve Mosier <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse

[EXTERNAL]
Thanks, I appreciate the additional information - I may be missing this, I see calibration dates, but do you have anything
that indicates the date it was submitted?
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
On Fri, Oct 25, 2024 at 12:00 PM Dean Kitchen <[e-mail]> wrote:
Steve,

Here is the protocol.

That was during COVID. DAQ started using a online portal around that time to submit smaller facility
protocols and reports, and the protocol should have been sent that way. The system works pretty good,
but I have not been receiving a lot of protocol response letters since that time, and it’s too far back to try
and remember.

Let me know,
Dean

From: Steve Mosier <[e-mail]>
Sent: Friday, 25 October, 2024 11:53 AM
To: Dean Kitchen <[e-mail]>; 'Susan Weisenberg' <[e-mail]>
Cc: 'Chad Gilgen' <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse

My understanding when talking to Susan was that they had no record of the protocol. If we can get that to them, I
think we should be ok.

Steve Mosier
Plant Manager
Grain Cra
1/23/25, 8:07 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1814997062486485067…2/5
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844

From: Dean Kitchen <[e-mail]>
Sent: Friday, October 25, 2024 11:51 AM
To: Steve Mosier <[e-mail]>; 'Susan Weisenberg' <[e-mail]>
Cc: 'Chad Gilgen' <[e-mail]>
Subject: RE: requirement to stack test "B" Mill baghouse

[EXTERNAL]

Steve,

I can send you the protocol, but I think Susan is saying that DAQ never received notice of the test and
wants a retest scheduled, etc. Can you find out for sure? None of us want to retest if possible. It would
be due again in 2026.
Dean

From: Steve Mosier <[e-mail]>
Sent: Friday, 25 October, 2024 11:13 AM
To: Susan Weisenberg <[e-mail]>
Cc: [e-mail]; Chad Gilgen <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse

Thanks Susan.

Dean-do you have the info they're looking for? I think they just need the protocol info?

Steve Mosier
1/23/25, 8:07 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1814997062486485067…3/5
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844

From: Susan Weisenberg <[e-mail]>
Sent: Friday, October 25, 2024 11:05 AM
To: Steve Mosier <[e-mail]>
Cc: [e-mail] <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: requirement to stack test "B" Mill baghouse

[EXTERNAL]

Hello, as stated during our telephone conversation this morning:

In response to my inspection of your facility located at 220 West 36th Street, in Ogden, on September 26, 2024 - your
company submitted a copy of the March 30, 2021 stack test of the Unit 9 "B" Mill Wheat Cleaning Baghouse. As of
the time of that email, the DAQ did not have a copy of that test, or the associated required Stack Testing Protocol for
that specific stack which would notify our agency of the methodology used for that test for the necessary review.

In addition to your company's current Approval Order (AO) Condition II.B.3.b.3 requirement to report the stack test to
the DAQ no later than 60 days after completing a stack test, Condition II.B.3.b.4 of this AO and the State
Administrative Rule regarding stack testing R307-165-3, mandates that the necessary protocol shall be submitted to
the DAQ at least 30 days prior to conducting the test. See the attached documents for reference.

R307-165-6 states that "The director may reject stack testing results if determined to be incomplete, inadequate, not
representative of operating conditions specified for the test, or if the director was not provided an opportunity to have
an observer present at the test."

In order to be in compliance with the above requirements, please schedule a stack test for the "B" Mill baghouse and
submit the required notifications to the DAQ as soon as possible.

If you believe that you have received this notification in error, and that the test and protocol were sent as required -
submit a copy of the missing documents to demonstrate compliance with the referenced regulations. You may
contact me if you have any questions. Thanks
1/23/25, 8:07 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1814997062486485067…4/5
Susan Weisenberg <[e-mail]>
Re: requirement to stack test "B" Mill baghouse
1 message
Chad Gilgen <[e-mail]>Tue, Dec 3, 2024 at 10:38 AM
To: Susan Weisenberg <[e-mail]>
Hey Susan,
I never heard back from Kyle on this one but it looks like he reviewed the report and accepted the results based on what
is in Laserfiche. See attached for that memo. Based on this, and per my November 6, 2024, email, please put together a
Warning Letter to document this one.
Thanks and let me know if you have any questions or would like to discuss this one further.
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.
On Wed, Nov 6, 2024 at 12:17 PM Chad Gilgen <[e-mail]> wrote:
Thanks, Kyle.
They were issued a new AO last year. See attached.
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.
On Wed, Nov 6, 2024 at 12:06 PM Kyle Greenberg <[e-mail]> wrote:
Hi Chad,
I'll grab this one. I should have time to get it reviewed by next week. Is the AO that's attached the most current?
Kyle
On Wed, Nov 6, 2024 at 11:02 AM Chad Gilgen <[e-mail]> wrote:
Hey Guys,
1/23/25, 8:09 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1817441761295065503…1/7
Here's an FYI on an old stack test that Grain Craft should be submitting soon. It was determined during a recent
inspection that this one (pretest and results) was never submitted to the DAQ. Thanks and please let me know
which of you reviews this test and if the results are acceptable.
Thanks,
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.
---------- Forwarded message ---------
From: Chad Gilgen <[e-mail]>
Date: Wed, Nov 6, 2024 at 11:00 AM
Subject: Re: requirement to stack test "B" Mill baghouse
To: Steve Mosier <[e-mail]>
Cc: Susan Weisenberg <[e-mail]>, Dean Kitchen <[e-mail]>
Hello Steve,
The DAQ has reviewed your response. Due to the factors surrounding the changeover in employment, we will be
able to close this one out with a Warning Letter.
Please submit this stack test through the DAQ's online portal at https://deq.utah.gov/air-quality/stationary-source-
compliance and choosing "Submit Minor Stack Test Protocol/Report" in the middle of the page. The DAQ reserves
the right to pursue additional compliance action if our internal stack test audit shows this test to be out of
compliance with the conditions in the AO.
Thanks and let me know if you have any questions.
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.
On Fri, Oct 25, 2024 at 12:20 PM Steve Mosier <[e-mail]> wrote:
I think part of the issue stemmed from Tim Becker leaving Grain Cra, and some emails were sent
to his old email aer he le?
Steve Mosier
1/23/25, 8:09 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1817441761295065503…2/7
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844
From: Susan Weisenberg <[e-mail]>
Sent: Friday, October 25, 2024 12:12 PM
To: Dean Kitchen <[e-mail]>
Cc: Steve Mosier <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse

[EXTERNAL]
Thanks, I appreciate the additional information - I may be missing this, I see calibration dates, but do you have
anything that indicates the date it was submitted?
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
On Fri, Oct 25, 2024 at 12:00 PM Dean Kitchen <[e-mail]> wrote:
Steve,

Here is the protocol.

That was during COVID. DAQ started using a online portal around that time to submit smaller
facility protocols and reports, and the protocol should have been sent that way. The system works
pretty good, but I have not been receiving a lot of protocol response letters since that time, and it’s
too far back to try and remember.

Let me know,
Dean

From: Steve Mosier <[e-mail]>
Sent: Friday, 25 October, 2024 11:53 AM
To: Dean Kitchen <[e-mail]>; 'Susan Weisenberg' <[e-mail]>
Cc: 'Chad Gilgen' <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse

1/23/25, 8:09 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1817441761295065503…3/7
My understanding when talking to Susan was that they had no record of the protocol. If we can get that to
them, I think we should be ok.

Steve Mosier
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844

From: Dean Kitchen <[e-mail]>
Sent: Friday, October 25, 2024 11:51 AM
To: Steve Mosier <[e-mail]>; 'Susan Weisenberg' <[e-mail]>
Cc: 'Chad Gilgen' <[e-mail]>
Subject: RE: requirement to stack test "B" Mill baghouse

[EXTERNAL]

Steve,

I can send you the protocol, but I think Susan is saying that DAQ never received notice of the test
and wants a retest scheduled, etc. Can you find out for sure? None of us want to retest if
possible. It would be due again in 2026.
Dean

From: Steve Mosier <[e-mail]>
Sent: Friday, 25 October, 2024 11:13 AM
To: Susan Weisenberg <[e-mail]>
Cc: [e-mail]; Chad Gilgen <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse
1/23/25, 8:09 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1817441761295065503…4/7

Thanks Susan.

Dean-do you have the info they're looking for? I think they just need the protocol info?

Steve Mosier
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844

From: Susan Weisenberg <[e-mail]>
Sent: Friday, October 25, 2024 11:05 AM
To: Steve Mosier <[e-mail]>
Cc: [e-mail] <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: requirement to stack test "B" Mill baghouse

[EXTERNAL]

Hello, as stated during our telephone conversation this morning:

In response to my inspection of your facility located at 220 West 36th Street, in Ogden, on September 26,
2024 - your company submitted a copy of the March 30, 2021 stack test of the Unit 9 "B" Mill Wheat Cleaning
Baghouse. As of the time of that email, the DAQ did not have a copy of that test, or the associated required
Stack Testing Protocol for that specific stack which would notify our agency of the methodology used for that
test for the necessary review.

In addition to your company's current Approval Order (AO) Condition II.B.3.b.3 requirement to report the stack
test to the DAQ no later than 60 days after completing a stack test, Condition II.B.3.b.4 of this AO and the
State Administrative Rule regarding stack testing R307-165-3, mandates that the necessary protocol shall be
submitted to the DAQ at least 30 days prior to conducting the test. See the attached documents for reference.
1/23/25, 8:09 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1817441761295065503…5/7

R307-165-6 states that "The director may reject stack testing results if determined to be incomplete,
inadequate, not representative of operating conditions specified for the test, or if the director was not provided
an opportunity to have an observer present at the test."

In order to be in compliance with the above requirements, please schedule a stack test for the "B" Mill
baghouse and submit the required notifications to the DAQ as soon as possible.

If you believe that you have received this notification in error, and that the test and protocol were sent as
required - submit a copy of the missing documents to demonstrate compliance with the referenced
regulations. You may contact me if you have any questions. Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

--
Kyle Greenberg
Environmental Scientist | Minor Source Compliance
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
1/23/25, 8:09 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1817441761295065503…6/7
Susan Weisenberg <[e-mail]>
B-Mill Stack Test
1 message
Steve Mosier <[e-mail]>Thu, Sep 26, 2024 at 3:21 PM
To: "[e-mail]" <[e-mail]>
Susan,
Please find aached B-Mill Stack Test from 2021. Sorry it took me so long to find it!
Regards,
Steve
Steve Mosier
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844
Stack Test B Wheat PM 10 Compliance 2021.pdf
2391K
1/23/25, 7:53 PM State of Utah Mail - B-Mill Stack Test
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1811295163643639366%7Cmsg-f:1811295163643639366&s…1/1
Susan Weisenberg <[e-mail]>
RE: requirement to stack test "B" Mill baghouse
1 message
Dean Kitchen <[e-mail]>Fri, Oct 25, 2024 at 11:51 AM
To: Steve Mosier <[e-mail]>, Susan Weisenberg <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
Steve,

I can send you the protocol, but I think Susan is saying that DAQ never received notice of the test and
wants a retest scheduled, etc. Can you find out for sure? None of us want to retest if possible. It would be
due again in 2026.
Dean

From: Steve Mosier <[e-mail]>
Sent: Friday, 25 October, 2024 11:13 AM
To: Susan Weisenberg <[e-mail]>
Cc: [e-mail]; Chad Gilgen <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse

Thanks Susan.

Dean-do you have the info they're looking for? I think they just need the protocol info?

Steve Mosier
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844

1/23/25, 7:59 PM State of Utah Mail - RE: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1813909265616764656…1/3
From: Susan Weisenberg <[e-mail]>
Sent: Friday, October 25, 2024 11:05 AM
To: Steve Mosier <[e-mail]>
Cc: [e-mail] <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: requirement to stack test "B" Mill baghouse

[EXTERNAL]

Hello, as stated during our telephone conversation this morning:

In response to my inspection of your facility located at 220 West 36th Street, in Ogden, on September 26, 2024 - your
company submitted a copy of the March 30, 2021 stack test of the Unit 9 "B" Mill Wheat Cleaning Baghouse. As of the
time of that email, the DAQ did not have a copy of that test, or the associated required Stack Testing Protocol for that
specific stack which would notify our agency of the methodology used for that test for the necessary review.

In addition to your company's current Approval Order (AO) Condition II.B.3.b.3 requirement to report the stack test to the
DAQ no later than 60 days after completing a stack test, Condition II.B.3.b.4 of this AO and the State Administrative Rule
regarding stack testing R307-165-3, mandates that the necessary protocol shall be submitted to the DAQ at least 30 days
prior to conducting the test. See the attached documents for reference.

R307-165-6 states that "The director may reject stack testing results if determined to be incomplete, inadequate, not
representative of operating conditions specified for the test, or if the director was not provided an opportunity to have an
observer present at the test."

In order to be in compliance with the above requirements, please schedule a stack test for the "B" Mill baghouse and
submit the required notifications to the DAQ as soon as possible.

If you believe that you have received this notification in error, and that the test and protocol were sent as required - submit
a copy of the missing documents to demonstrate compliance with the referenced regulations. You may contact me if you
have any questions. Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

1/23/25, 7:59 PM State of Utah Mail - RE: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1813909265616764656…2/3
Susan Weisenberg <[e-mail]>
Re: requirement to stack test "B" Mill baghouse
1 message
Steve Mosier <[e-mail]>Fri, Oct 25, 2024 at 12:20 PM
To: Susan Weisenberg <[e-mail]>, Dean Kitchen <[e-mail]>
Cc: Chad Gilgen <[e-mail]>
I think part of the issue stemmed from Tim Becker leaving Grain Cra, and some emails were sent to his old
email aer he le?
Steve Mosier
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844
From: Susan Weisenberg <[e-mail]>
Sent: Friday, October 25, 2024 12:12 PM
To: Dean Kitchen <[e-mail]>
Cc: Steve Mosier <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse

[EXTERNAL]
Thanks, I appreciate the additional information - I may be missing this, I see calibration dates, but do you have anything
that indicates the date it was submitted?
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
On Fri, Oct 25, 2024 at 12:00 PM Dean Kitchen <[e-mail]> wrote:
Steve,

Here is the protocol.

1/23/25, 8:05 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1813911105404570273&…1/5
That was during COVID. DAQ started using a online portal around that time to submit smaller facility
protocols and reports, and the protocol should have been sent that way. The system works pretty good,
but I have not been receiving a lot of protocol response letters since that time, and it’s too far back to try
and remember.

Let me know,
Dean

From: Steve Mosier <[e-mail]>
Sent: Friday, 25 October, 2024 11:53 AM
To: Dean Kitchen <[e-mail]>; 'Susan Weisenberg' <[e-mail]>
Cc: 'Chad Gilgen' <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse

My understanding when talking to Susan was that they had no record of the protocol. If we can get that to them, I think
we should be ok.

Steve Mosier
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844

From: Dean Kitchen <[e-mail]>
Sent: Friday, October 25, 2024 11:51 AM
To: Steve Mosier <[e-mail]>; 'Susan Weisenberg' <[e-mail]>
Cc: 'Chad Gilgen' <[e-mail]>
Subject: RE: requirement to stack test "B" Mill baghouse

[EXTERNAL]
1/23/25, 8:05 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1813911105404570273&…2/5

Steve,

I can send you the protocol, but I think Susan is saying that DAQ never received notice of the test and
wants a retest scheduled, etc. Can you find out for sure? None of us want to retest if possible. It would
be due again in 2026.
Dean

From: Steve Mosier <[e-mail]>
Sent: Friday, 25 October, 2024 11:13 AM
To: Susan Weisenberg <[e-mail]>
Cc: [e-mail]; Chad Gilgen <[e-mail]>
Subject: Re: requirement to stack test "B" Mill baghouse

Thanks Susan.

Dean-do you have the info they're looking for? I think they just need the protocol info?

Steve Mosier
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844

From: Susan Weisenberg <[e-mail]>
Sent: Friday, October 25, 2024 11:05 AM
To: Steve Mosier <[e-mail]>
Cc: [e-mail] <[e-mail]>; Chad Gilgen <[e-mail]>
Subject: requirement to stack test "B" Mill baghouse

1/23/25, 8:05 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1813911105404570273&…3/5
[EXTERNAL]

Hello, as stated during our telephone conversation this morning:

In response to my inspection of your facility located at 220 West 36th Street, in Ogden, on September 26, 2024 - your
company submitted a copy of the March 30, 2021 stack test of the Unit 9 "B" Mill Wheat Cleaning Baghouse. As of the
time of that email, the DAQ did not have a copy of that test, or the associated required Stack Testing Protocol for that
specific stack which would notify our agency of the methodology used for that test for the necessary review.

In addition to your company's current Approval Order (AO) Condition II.B.3.b.3 requirement to report the stack test to
the DAQ no later than 60 days after completing a stack test, Condition II.B.3.b.4 of this AO and the State Administrative
Rule regarding stack testing R307-165-3, mandates that the necessary protocol shall be submitted to the DAQ at least
30 days prior to conducting the test. See the attached documents for reference.

R307-165-6 states that "The director may reject stack testing results if determined to be incomplete, inadequate, not
representative of operating conditions specified for the test, or if the director was not provided an opportunity to have an
observer present at the test."

In order to be in compliance with the above requirements, please schedule a stack test for the "B" Mill baghouse and
submit the required notifications to the DAQ as soon as possible.

If you believe that you have received this notification in error, and that the test and protocol were sent as required -
submit a copy of the missing documents to demonstrate compliance with the referenced regulations. You may contact
me if you have any questions. Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512

1/23/25, 8:05 PM State of Utah Mail - Re: requirement to stack test "B" Mill baghouse
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-a:r4550337001237660967%7Cmsg-f:1813911105404570273&…4/5
Susan Weisenberg <[e-mail]>
Re: B-Mill Stack Test
1 message
Chad Gilgen <[e-mail]>Thu, Oct 3, 2024 at 2:05 PM
To: Susan Weisenberg <[e-mail]>
Hi Susan,
The DAQ will always generate an acceptance letter and pretest memo prior to testing to show that we received, reviewed,
and accepted the terms for the test. We will also always review every stack test report and generate a memo for each set
of stack test results we receive.
From what I am seeing in the source file, and our stack test tracking spreadsheet (which goes back to September 2020),
Grain Craft did not submit anything for this 2021 test of the B Mill. Since Grain Craft did not submit a pretest protocol, or
stack test results in 2021, we are not going to accept this test in accordance with the provisions of R307-165 (copy
attached) and Grain Craft will need to schedule a new test as soon as possible and follow the procedures like they
recently did for the A Mill test.
Thanks,
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.
On Fri, Sep 27, 2024 at 12:10 PM Susan Weisenberg <[e-mail]> wrote:
Hello, with regards to Cereal Foods aka Grain Craft, LLC (10936) - I was unable to find their most recent stack test for
specifically the "B" Mill during my file search. The "A" Mill is present both for 2019 and 2024. The company just
submitted this test after I requested a copy. Here's the 2021 TETCO report. Does the DAQ still always produce a stack
testing memo following the review of each test, or was this specific test not submitted as required? Thanks
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
---------- Forwarded message ---------
From: Steve Mosier <[e-mail]>
Date: Thu, Sep 26, 2024 at 3:21 PM
Subject: B-Mill Stack Test
To: [e-mail] <[e-mail]>
Susan,
Please find aached B-Mill Stack Test from 2021. Sorry it took me so long to find it!
1/23/25, 7:57 PM State of Utah Mail - Re: B-Mill Stack Test
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1811295163643639366%7Cmsg-f:1811924617382855696&s…1/2
Regards,
Steve
Steve Mosier
Plant Manager
Grain Cra
220 W. 30th St.
Ogden, UT 84401
W 801-394-4523
DL 385-244-4787
F 801-627-1844
R307-165.pdf
68K
1/23/25, 7:57 PM State of Utah Mail - Re: B-Mill Stack Test
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1811295163643639366%7Cmsg-f:1811924617382855696&s…2/2
2023 Emissions Inventory Report
Grain Craft, LLC. - Ogden Flour Mill (10936)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons,
excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)39.52736 <.00001 39.52736
PM10-FIL PM10 Filterable 39.50684 <.00001 39.50684
PM25-PRI PM2.5 Primary (Filt + Cond)19.78736 <.00001 19.78736
PM25-FIL PM2.5 Filterable 19.76684 <.00001 19.76684
PM-CON PM Condensible 0.02052 <.00001 0.02052
SO2 Sulfur Dioxide 0.00216 <.00001 0.00216
NOX Nitrogen Oxides 0.36 <.00001 0.36
VOC Volatile Organic Compounds 0.0198 <.00001 0.0198
CO Carbon Monoxide 0.3024 <.00001 0.3024
7439921 Lead <.00001 <.00001 <.00001
NH3 Ammonia 0.01152 <.00001 0.01152
HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM?Total Emissions
(tons)*
*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
1/2