DAQ-2025-000276

DAQE-AN141070020-25
{{$d1 }}
Seth Garner
The Procter & Gamble Paper Products Company
5000 North Iowa String Road
Bear River City, UT 84301
[e-mail]
Dear Mr. Garner:
Re: Approval Order: Minor Modification to Approval Order DAQE-AN141070018-23 for the
Addition of a Storage Tank
Project Number: N141070020
The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on April 26,
2024. The Procter & Gamble Paper Products Company must comply with the requirements of this AO, all
applicable state requirements (R307), and Federal Standards.
The project engineer for this action is Tad Anderson, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as
the DAQE number shown on the upper right-hand corner of this letter. No public comments were
received on this action.
Sincerely,
{{$s }}
Bryce C. Bird
Director
BCB:TA:jg
cc: Bear River Health Department
EPA Region 8
Salt Lake City, UT
-4820
Telephone (801) 536---4414
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
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APPROVAL ORDER
DAQE-AN141070020-25
Minor Modification to Approval Order DAQE-AN141070018-23
for the Addition of a Storage Tank
Prepared By
Tad Anderson, Engineer
[phone]
[e-mail]
Issued to
The Procter & Gamble Paper Products Company
Issued On
{{$d2 }}
Issued By
{{$s }}
Bryce C. Bird
Director
Division of Air Quality
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 8
PERMIT HISTORY ................................................................................................................... 14
ACRONYMS ............................................................................................................................... 15

DAQE-AN141070020-25
Page 3
GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
The Procter & Gamble Paper Products Company The Procter & Gamble Paper Products Company

Mailing Address Physical Address
5000 North Iowa String Road 5000 North Iowa Road
Bear River City, UT 84301 Bear River City, UT 84301

Source Contact UTM Coordinates
Name: Dean Shepherd 402500 m Easting
Phone: [phone] 4605600 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12
SIC code 2621 (Paper Mills)

SOURCE INFORMATION
General Description
The Procter and Gamble Paper Products Company (P&G) operates the Box Elder Plant. The Box Elder
Plant produces paper and assembled paper products. The Box Elder Plant is located in Bear River City,
Utah.

NSR Classification
Minor Modification at Major Source

Source Classification
Located in Box Elder County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
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), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
DAQE-AN141070020-25
Page 4
Source Category: Gasoline Dispensing Facilities
Title V (Part 70) Major Source

Project Description
P&G has requested to add a sodium bisulfate tank. The additional 6,300-gallon sodium bisulfite tank is
necessary in its Assembled Paper Products B operations, and it is recognized that a minor amount of SO2
emissions result from the breathing and filling of the tank.

The original NOI that was submitted to Utah Division of Air Quality had a sodium bisulfate tank size of
4,000 gallons, but additional information was submitted on September 11, 2024, requesting the size to be
increased to 6,300 gallons.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 280301.00
Carbon Monoxide 0 184.81
Nitrogen Oxides 0 138.84
Particulate Matter - PM10 0 164.63
Particulate Matter - PM2.5 0 142.03
Sulfur Oxides 0.05 4.28
Volatile Organic Compounds 0 130.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 13
Acrylamide (CAS #79061) 0 194
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 17
Epichlorohydrin (L-Chloro-2,3-Epoxypropane) (CAS #106898) 0 16
Formaldehyde (CAS #50000) 0 325
Generic HAPs (CAS #GHAPS) 0 1011
Hexane (CAS #110543) 0 6286
Methanol (CAS #67561) 0 18132
Methyl Methacrylate (CAS #80626) 0 82
Propylene[1-Propene] (CAS #115071) 0 646
Toluene (CAS #108883) 0 45
Xylenes (Isomers And Mixture) (CAS #1330207) 0 25
Change (TPY) Total (TPY)
Total HAPs 0 13.40

DAQE-AN141070020-25
Page 5
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] I.8 The owner/operator shall submit documentation of the status of construction of the 16B paper machine and natural gas-fired emergency generator to the Director within 18 months from
November 16, 2023. The owner/operator shall submit documentation of the status of construction of the sodium bisulfite tank to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the
date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

DAQE-AN141070020-25
Page 6
SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 The Procter & Gamble-Box Elder Facility
II.A.2 Paper Machine 15B
One (1) Paper Machine
Natural Gas-Fired dryer
Size: 150 MMBTU/hr
Controls: Low NOx burner
Stack Height: 33.53 meters
Stack Diameter: 2.19 meters
Stack Flow rate: 183,335 acfm

Cyclonic Separator (wet-end of process and under machine exhaust)
Venturi Scrubber (dry-end of process) with a PM10 Control Efficiency: approximately 95%*
*Not for determining compliance but for replacement-in-kind.

II.A.3 Paper Machine 16B One (1) Paper Machine Natural Gas-Fired dryer Size: 130 MMBTU/hr (combined) Paper Machine Dryer Controls: Ultra-Low NOx burner Make up Air Units Controls: Low NOx burners Venturi Scrubber (dry end stack) Cyclonic Separator (wet-end of process and under machine exhaust)
II.A.4 Paper Product and Utility Boilers
Two (2) Natural Gas-Fired Paper Product Boilers Maximum Capacity: 60.24 MMBTU/hr (each) Controls: Low-NOx Burners
Secondary fuel: Propane (emergency or curtailment) Two (2) Natural Gas-Fired Utility Boilers
Maximum Capacity: 50 MMBTU/hr (each) Controls: Ultra-Low NOx Burners
One (1) Natural Gas Back-Up Boiler (if boilers are out of service) II.A.5 Paper Product Converting Operation One (1) Paper Product Converting Operation PM10 Controls: Three (3) existing Drum Filters -Vent to Atmosphere Two (2) New Baghouses - Vent Indoors Five (5) Converting Lines
II.A.6 Assembled Paper Product A Baghouse One (1) Assembled Paper Product Baghouses
II.A.7 Assembled Paper Product A Drum Filters Four (4) Assembled Paper Product Drum Filters
II.A.8 Assembled Paper Product A Equipment
Pneumatic Pumps
DAQE-AN141070020-25
Page 7
II.A.9 Assembled Paper Product A Portable Dry Vacuum Unit
II.A.10 Assembled Paper Product B Dryer Capacity: 10 MMBtu/hr (4-2.5 MMBtu/hr burners)
II.A.11 Assembled Paper Product B Drum Filter System Drum Filter systems II.A.12 Assembled Paper Product B Baghouse/Fabric Filter
Three (3) Baghouses: 1) Briquetter Baghouse
2) Active Ingredient Baghouse 3) Central Vacuum System Baghouse
II.A.13 Storage Tank (NEW) Sodium Bisulfite Storage Tank Capacity: 6,300 gallons
II.A.14 FAM Regenerative Thermal Oxidizer (RTO) Burner Size: 2 MMBtu/hr Control: Low-NOx Burner
Flow Rate: 7,500 scfm
II.A.15 FAM Silo
II.A.16 Assembled Paper Product B Equipment Pneumatic Pumps
II.A.17 Assembled Paper Product B Inks RTO Burner Size: 1 MMBtu/hr Flow Rate: 2,500 scfm
II.A.18 Diesel-Fired Back-Up Engines
Five (5) Emergency Equipment

Two (2) Fire Pumps
Maximum Capacity: 375 hp (each)

Two (2) Fire Pumps
Maximum Capacity: 399 hp (each)

One (1) Power Generator
Maximum Capacity: 1,214 hp

II.A.19 Natural Gas-Fired Back-Up Engines One (1) Emergency Generator Capacity: 54 hp (40 kW) One (1) Emergency Generator Capacity: 1006 hp (750 kW)
II.A.20 Cooling Towers
Multiple cooling towers with drift eliminators (0.001%) to support the facility

DAQE-AN141070020-25
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II.A.21 Tanks Multiple tanks, including diesel and gasoline fuel storage and various raw material storage tanks. 40 CFR 60 Subpart Kb is not applicable to these storage tanks based on exemptions listed under 40 CFR 60.110b(b). II.A.22 FAM Making Operations Tanks Capacity: 500 gallons
Material: Sodium Bisulfite Capacity: 6,000 gallons
Material: Sodium Bisulfite Capacity: 60 gallons
Material: 25% mixture of HCl
II.A.23 Multiple Space Heaters
II.A.24 Truck Loading

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

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

A. All natural gas operated equipment - 10% opacity B. Cooling towers - 10 % opacity C. Baghouses - 10% opacity D. RTO - 10% opacity E. All other points - 20% opacity. [R307-401]
DAQE-AN141070020-25
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II.B.1.a.1 The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in accordance with 40 CFR 60, Appendix A, Method 22. If no visible emissions are observed in six (6) consecutive monthly tests for any affected source, the permittee may decrease the frequency of testing from monthly to semiannually for the affected source. If visible emissions are observed during any semi-annual test, the permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed for six (6) consecutive monthly tests. If no visible emissions are observed during two (2) consecutive semi-annual tests for any affected source, the permittee may decrease the frequency of testing from semi-annually to annually for the affected source. If visible emissions are observed during any annual test, the permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed for six (6) consecutive monthly tests. If visible emissions are observed during any Method 22 test, a current Method 9 certified observer shall conduct a: 1) Six-minute test of opacity in accordance with 40 CFR 60, Appendix A Method 9 for point sources, or 2) One-minute test of opacity with five-second observation intervals in accordance with 71 FR 55126, Method 203C for fugitive emission sources 3) The Method 9 or 203C test shall begin within 24 hours of any observation of visible emission. [R307-401-8] II.B.1.a.2 Records of visible emission tests performed and data required by 40 CFR 60, Appendix A,
Method 22, Method 9, or 58 FR 61640, Method 203C shall be maintained. [R307-401-8]

II.B.1.b The plant-wide emissions of VOCs and HAPs from the operations shall not exceed: 130.07 tons of VOC emissions per rolling 12-month period 3.14 tons of Hexane per rolling 12-month period 9.07 tons of Methanol per rolling 12-month period. [R307-401-8]
II.B.1.b.1 Compliance with each limitation shall be determined on a rolling 12-month total. Based on the
last day of each month, a new 12-month total shall be calculated using data from the previous 12
months. Monthly calculations shall be made no later than 30 days after the end of each calendar
month. [R307-401-8]

DAQE-AN141070020-25
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II.B.1.b.2 VOC and HAP emissions shall be determined by maintaining a record of VOC- and HAP-emitting materials used each month if applicable to the product in sections 1, 2, and 3 below and/or to emission calculations in section 4. The record shall include the following data for each material used for calculating the rolling 12-month total: A. Name of the VOC- or volatile HAP-emitting process material B. Percent by weight of all VOC and volatile HAP in each process material used C. Quantity of each VOC- and volatile HAP-emitting process material used in pounds D. The amount of VOC and volatile HAP emitted monthly by each process material used, calculated by the following procedure: VOC = (% VOC by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000 lb) Or an Alternative VOC calculation consistent with US EPA emission calculation methodologies HAP = (% HAP by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000lb) Or an Alternative HAP calculation consistent with US EPA emission calculation methodologies E. The amount of VOC and volatile HAP emitted monthly from all materials used F. The amount of VOC and volatile HAP reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC and volatile HAP emissions. [R307-401-8]
II.B.1.c The backup boiler may only be used during periods when a permitted boiler is taken out of
service. The backup boiler and the permitted boiler must not be operated at the same time, except
for periods of post-repair readiness checks and initial start-up of the permitted boiler. The backup
boiler shall only burn natural gas or propane. The backup boiler capacity shall not exceed the
boiler capacity listed in equipment section of this permit. Emission testing for the backup boiler
shall not be required, and emissions rates shall be guaranteed by vendor documentation.
[R307-401-8]

II.B.1.d The owner/operator shall use natural gas as fuel in all equipment listed in this permit as a primary fuel and propane as a backup fuel in the boilers (except for listed emergency equipment, which is diesel operated). [R307-401-8]
II.B.2 Paper Making Requirements
II.B.2.a The paper-making machines 15B and 16B shall include cyclone separators (installed on the Under Dryer Stacks and Wet End Stacks) and a venturi scrubber (installed on the Dry End Stacks) to control PM/PM10/PM2.5 emissions. [R307-401-8]
II.B.2.b The owner/operator shall maintain the pressure drop across the venturi scrubbers at no less than
four (4) inches of water gauge when the unit is operating and venting to the atmosphere.
[R307-401-8]

II.B.2.b.1 Monitor the scrubber differential pressure once per operating day. [R307-401-8]
II.B.2.b.2 Results of daily pressure drop readings shall be maintained. [R307-401-8]

DAQE-AN141070020-25
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II.B.2.c One (1) drum filter for each of the existing three (3) paper-making converting lines shall control process streams from the paper-making converting operation when venting to the atmosphere. [R307-401-8] II.B.2.d The permittee shall install, calibrate, maintain, and operate a monitoring device for the
continuous measurement of the change in pressure of the gas stream through the paper-making converting room drum filters. The monitoring device must be certified by the manufacturer to be accurate within plus or minus one (1) inch of water gauge and must be calibrated on an annual
basis in accordance with the manufacturer's instructions. Continuous recording for the monitoring device is not required. When the paper-making converting room drum filters are in operation and venting to the atmosphere, the pressure drop shall be no less than one (1) inch
water gauge (w.g.) for more than five (5) minutes in any 60-minute period except during start-up and shut-down of the converting dust control fans. The permittee is not restricted to a minimum pressure drop across the control device for the first 96 consecutive hours after replacement of a
filter. This seasoning-in period shall last no more than 96 hours. [R307-401-8]
II.B.2.d.1 Monitor the drum filter pressure drop once per operating day. [R307-401-8]
II.B.2.d.2 Records of the pressure drop shall be maintained. [R307-401-8]
II.B.2.e The owner/operator shall not exceed 96,360 MMBtu per rolling 12-month total of the 16B make-up air units. [R307-401-8] II.B.2.e.1 To determine the operational limitation for the 16B make-up air units, the owner/operator shall maintain a monthly log tracking the MMBtu per rolling 12-month total. [R307-401-8]

II.B.2.f The owner/operator shall not exceed 163,800 gallons of sodium bisulfite per rolling 12-month in the storage tank. [R307-401-8]
II.B.2.f.1 To determine the throughput for the sodium bisulfite tank, the owner/operator shall maintain a
monthly log tracking the gallons per rolling 12-month total. [R307-401-8]

DAQE-AN141070020-25
Page 12
II.B.3 Stack Testing Requirements II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from the
indicated emissions unit(s): ***Paper Machine 15B Process Stack ***
Pollutant lb/hr lb/MMBTU PM2.5 6.65 0.044 NOx 13.50 0.09
CO 15.75 0.105 ***Paper Machine 16B Process Stack ***
Pollutant lb/hr lb/MMBTU PM2.5 6.65 0.05115 NOx 3.95 0.03
CO 4.82 0.037 ***Paper Making Boilers*** (each)
Pollutant lb/hr ppmdv PM2.5 0.9 NA NOx 3.3 45
CO 3.0 70 ***Utility Boilers*** (each)
Pollutant lb/hr ppmdv PM2.5 0.74 NA NOx 1.80 10
CO 4.06 156 [R307-401-8]

II.B.3.a.1 Initial Test The owner/operator shall conduct an initial stack test for the Paper Machine 16B Process Stack within 180 days after startup. [R307-165-2]
II.B.3.a.2 Test Frequency
The owner/operator shall conduct subsequent stack tests for the following emissions units
according to the following schedule. The owner/operator must complete subsequent stack tests
within the indicated time after the date of the most recent stack test for the specified emission
unit.

Test every three (3) years for:

Paper Machine 15B Process Stack
Paper Machine 16B Process Stack
Utility Boilers
Paper Machine Boilers

The Director may require the owner/operator to perform a stack test at any time.

[R307-165-2]

II.B.3.a.3 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]
DAQE-AN141070020-25
Page 13
II.B.3.a.4 Reporting Within 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]
II.B.3.a.5 PM2.5 Total PM2.5 = Filterable PM2.5 + Condensable PM2.5
Filterable PM2.5 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A, or other EPA-approved testing method as acceptable to the Director. If other approved testing methods
are used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM2.5.
Condensable PM2.5 40 CFR 51, Appendix M, Method 202, or other EPA-approved testing method as acceptable to the Director.
Total PM2.5 40 CFR 60.8(b)(2), Appendix A, including EPA-approved testing method OTM 37.
[R307-401-8]
II.B.3.a.6 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.3.b CO 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

II.B.4 Assembled Paper Products Requirements
II.B.4.a The emissions from the assembled paper products A and B converting operation shall be routed
to the assembled paper products drum filters and the assembled paper product baghouses.
[R307-401-8]

II.B.4.b The assembled paper product drum filters and the assembled paper product baghouses shall be operated and maintained in accordance with the manufacturer's specifications. The drum filters and baghouses shall be equipped with gauges or meters, which indicates the pressure drop across the control device. The pressure gauges or meters shall be located such that an inspector/operator can safely read the indicators at any time. The drum filters and baghouses while in operation and venting to the atmosphere shall be operated such that the minimum pressure drop across each control device is greater than or equal to 0.5 inches of water column except during start-up and shutdown of the fans. The permittee is not restricted to a minimum pressure drop across the control device for the first 96 hours of operation after replacement of the filter media on the drum filter or a bag(s) in the baghouse. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance warranty. [R307-401-8]
II.B.4.b.1 The permittee shall monitor the operating pressure drop across each drum filter and each
baghouse once per operating day. [R307-401-8]

II.B.4.b.2 The permittee shall maintain an operating and maintenance log for each drum filter and each baghouse along with the manufacturer's warranty. Records shall be maintained. [R307-401-8]
II.B.5 FAM Operations Requirements
II.B.5.a The emissions from the FAM raw material operational tanks, curing oven, and treatment from skid waste vents shall be routed to the RTO. [R307-401-8]
DAQE-AN141070020-25
Page 14
II.B.5.b The RTO shall be preheated and maintain the Manufacturer recommended temperature for ideal operation. [R307-401-8] II.B.5.b.1 The permittee shall monitor and record the RTO's temperatures once per operating day. The RTO's temperatures shall be maintained within the design conditions specified by the
manufacturer's performance warranty. The permittee shall maintain an operating and maintenance log for the RTOs. Continuous recording for the monitoring device is not required. [R307-401-8]

II.B.6 Emergency Generator Requirements II.B.6.a The owner/operator shall not operate each diesel-fired backup 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. [R307-401-8]
II.B.6.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 each diesel-fired backup engine shall be kept in a log and shall include the following: A. The date and time the diesel-fired backup engine was used B. The duration of operation in hours C. The reason for diesel-fired backup engine usage. [R307-401-8] II.B.6.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each diesel-fired backup engine. [R307-401-8]
II.B.6.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each diesel-fired backup engine. [R307-401-8]
II.B.6.b.1 The owner/operator shall only combust diesel fuel that meets a sulfur content of 15 ppm or less.
[R307-401-8]

II.B.6.b.2 To demonstrate compliance with the 15 ppm requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate the diesel fuel requirements. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN141070018-23 dated November 16, 2023 Is Derived From NOI dated April 26, 2024 Incorporates Additional Information dated September 11, 2024

DAQE-AN141070020-25
Page 15
ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN141070020-24

December 2, 2024

Seth Garner
The Procter & Gamble Paper Products Company
5000 North Iowa String Road
Bear River City, UT 84301
[e-mail]

Dear Mr. Garner:

Re: Intent to Approve: Minor Modification to Approval Order DAQE-AN141070018-23 for the
Addition of a Storage Tank at the Box Elder Facility
Project Number: N141070020

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Tad Anderson, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Tad Anderson, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:TA:jg

cc: Bear River Health Department
EPA Region 8

Salt Lake City, UT
-4820
Telephone (801) 536---4414
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN141070020-24
Minor Modification to Approval Order DAQE-AN141070018-23
for the Addition of a Storage Tank

Prepared By
Tad Anderson, Engineer
[phone]
[e-mail]

Issued to
The Procter & Gamble Paper Products Company - Box Elder Facility

Issued On
December 2, 2024

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 9
PERMIT HISTORY ................................................................................................................... 14
ACRONYMS ............................................................................................................................... 15

DAQE-IN141070020-24
Page 3
GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
The Procter & Gamble Paper Products Company The Procter & Gamble Paper Products Company - Box Elder Facility

Mailing Address Physical Address
5000 North Iowa String Road 5000 North Iowa String Road
Bear River City, UT 84301 Bear River City, UT 84301

Source Contact UTM Coordinates
Name: Dean Shepherd 402500 m Easting
Phone: [phone] 4605600 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12
SIC code 2621 (Paper Mills)

SOURCE INFORMATION
General Description
The Procter & Gamble Paper Products Company (P&G) operates the Box Elder Facility. The Box Elder
facility produces paper and assembled paper products. The Box Elder facility is located in Bear River
City, Utah.
NSR Classification
Minor Modification at Major Source

Source Classification
Located in Box Elder County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
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), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
DAQE-IN141070020-24
Page 4
Source Category: Gasoline Dispensing Facilities
Title V (Part 70) Major Source

Project Description
P&G has requested to add a sodium bisulfate tank. The additional 6,300-gallon sodium bisulfite tank is
necessary in its Assembled Paper Products B operations, and it is recognized that a minor amount of SO2
emissions result from the breathing and filling of the tank.

The original NOI that was submitted to UDAQ had a sodium bisulfate tank size of 4,000 gallons, but
additional information was submitted on September 11, 2024, requesting the size to be increased to 6,300
gallons.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 280301.00
Carbon Monoxide 0 184.81
Nitrogen Oxides 0 138.84
Particulate Matter - PM10 0 164.63
Particulate Matter - PM2.5 0 142.03
Sulfur Oxides 0.05 4.28
Volatile Organic Compounds 0 130.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 13
Acrylamide (CAS #79061) 0 194
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 17
Epichlorohydrin (L-Chloro-2,3-Epoxypropane) (CAS #106898) 0 16
Formaldehyde (CAS #50000) 0 325
Generic HAPs (CAS #GHAPS) 0 1011
Hexane (CAS #110543) 0 6286
Methanol (CAS #67561) 0 18132
Methyl Methacrylate (CAS #80626) 0 82
Propylene[1-Propene] (CAS #115071) 0 646
Toluene (CAS #108883) 0 45
Xylenes (Isomers And Mixture) (CAS #1330207) 0 25
Change (TPY) Total (TPY)
Total HAPs 0 13.40

DAQE-IN141070020-24
Page 5
PUBLIC NOTICE STATEMENT
The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Box Elder News & Journal on December 4, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

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]
DAQE-IN141070020-24
Page 6
I.8 The owner/operator shall submit documentation of the status of construction of the 16B paper machine and natural gas-fired emergency generator to the Director within 18 months from November 16, 2023. The owner/operator shall submit documentation of the status of construction of the sodium bisulfite tank to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT II.A.1 The Procter & Gamble - Box Elder Facility
II.A.2 Paper Machine 15B One (1) Paper Machine Natural Gas-Fired dryer Size: 150 MMBTU/hr Controls: Low NOx burner Stack Height: 33.53 meters Stack Diameter: 2.19 meters Stack Flow rate: 183,335 acfm Cyclonic Separator (wet end of process and under machine exhaust) Venturi Scrubber (dry end of process) with a PM10 Control Efficiency: approximately 95%* *Not for determining compliance but for replacement-in-kind. II.A.3 Paper Machine 16B
One (1) Paper Machine
Natural Gas-Fired dryer
Size: 130 MMBTU/hr (combined)
Paper Machine Dryer Controls: Ultra-Low NOx burner Make up Air Units Controls: Low NOx burners

Venturi Scrubber (dry end stack) Cyclonic Separator (wet end of process and under machine exhaust)

DAQE-IN141070020-24
Page 7
II.A.4 Paper Product and Utility Boilers Two (2) Natural Gas-Fired Paper Product Boilers Maximum Capacity: 60.24 MMBTU/hr (each) Controls: Low-NOx Burners Secondary fuel: Propane (emergency or curtailment) Two (2) Natural Gas-Fired Utility Boilers Maximum Capacity: 50 MMBTU/hr (each) Controls: Ultra-Low NOx Burners One (1) Natural Gas Back-Up Boiler (if boilers are out of service) II.A.5 Paper Product Converting Operation One (1) Paper Product Converting Operation
PM10 Controls: Three (3) existing Drum Filters -Vent to Atmosphere Two (2) New Baghouses - Vent Indoors Five (5) Converting Lines

II.A.6 Assembled Paper Product A Baghouse One (1) Assembled Paper Product Baghouses
II.A.7 Assembled Paper Product A Drum Filters Four (4) Assembled Paper Product Drum Filters
II.A.8 Assembled Paper Product A Equipment Pneumatic Pumps II.A.9 Assembled Paper Product A Portable Dry Vacuum Unit

II.A.10 Assembled Paper Product B Dryer Capacity: 10 MMBtu/hr (4-2.5 MMBtu/hr burners)
II.A.11 Assembled Paper Product B Drum Filter System
Drum Filter systems

II.A.12 Assembled Paper Product B Baghouse/Fabric Filter Three (3) Baghouses: 1) Briquetter Baghouse 2) Active Ingredient Baghouse 3) Central Vacuum System Baghouse
II.A.13 Storage Tank (NEW)
Sodium Bisulfite Storage Tank
Capacity: 6,300 gallons

II.A.14 FAM RTO Burner Size: 2 MMBtu/hr Control: Low-NOx Burner Flow Rate: 7,500 scfm
II.A.15 FAM Silo

II.A.16 Assembled Paper Product B Equipment Pneumatic Pumps
DAQE-IN141070020-24
Page 8
II.A.17 Assembled Paper Product B Inks RTO Burner Size: 1 MMBtu/hr Flow Rate: 2,500 scfm II.A.18 Diesel-Fired Back-Up Engines
Five (5) Emergency Equipment Two (2) Fire Pumps
Maximum Capacity: 375 hp (each) Two (2) Fire Pumps
Maximum Capacity: 399 hp (each) One (1) Power Generator
Maximum Capacity: 1,214 hp
II.A.19 Natural Gas-Fired Back-Up Engines One (1) Emergency Generator Capacity: 54 hp (40kW) One (1) Emergency Generator Capacity: 1006 hp (750kW) II.A.20 Cooling Towers
Multiple cooling towers with drift eliminators (0.001%) to support the facility.
II.A.21 Tanks Multiple tanks including diesel and gasoline fuel storage and various raw material storage tanks. 40 CFR 60 Subpart Kb is not applicable to these storage tanks based on exemptions listed under 40 CFR 60.110b(b).
II.A.22 FAM Making Operations Tanks
Capacity: 500-gallons
Material: Sodium Bisulfite

Capacity: 6,000-gallons
Material: Sodium Bisulfite

Capacity: 60-gallons
Material: 25% mixture HCl

II.A.23 Multiple Space Heaters
II.A.24 Truck Loading

DAQE-IN141070020-24
Page 9
SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site Wide Requirements
II.B.1.a Visible emissions from the following emission points shall not exceed the following values: A. All natural gas operated equipment - 10% opacity B. Cooling towers - 10 % opacity C. Baghouses - 10% opacity D. RTO - 10% opacity E. All other points - 20% opacity. [R307-401] II.B.1.a.1 The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in accordance with 40 CFR 60, Appendix A, Method 22. If no visible emissions are observed in six consecutive monthly tests for any affected source, the permittee may decrease the frequency of testing from monthly to semi-annually for the affected source. If visible emissions are observed during any semi-annual test, the permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed for six consecutive monthly tests. If no visible emissions are observed during two consecutive semi-annual tests for any affected source, the permittee may decrease the frequency of testing from semi-annually to annually for the affected source. If visible emissions are observed during any annual test, the permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed for six consecutive monthly tests. If visible emissions are observed during any Method 22 test, a current Method 9 certified observer shall conduct a: 1) six minute test of opacity in accordance with 40 CFR 60, Appendix A Method 9 for point sources, or 2) one minute test of opacity with five second observation intervals in accordance with 71 FR 55126, Method 203C for fugitive emission sources 3) the Method 9 or 203C test shall begin within 24 hours of any observation of visible emission. [R307-401-8]
II.B.1.a.2 Records of visible emission tests performed and data required by 40 CFR 60, Appendix A, Method 22, Method 9, or 58 FR 61640, Method 203C shall be maintained. [R307-401-8]
DAQE-IN141070020-24
Page 10
II.B.1.b The plant-wide emissions of VOCs and HAPs from the operations shall not exceed: 130.07 tons of VOC emissions per rolling 12-month period 3.14 tons of Hexane per rolling 12-month period 9.07 tons of Methanol per rolling 12-month period. [R307-401-8] II.B.1.b.1 Compliance with each limitation shall be determined on a rolling 12-month total. Based on the
last day of each month, a new 12-month total shall be calculated using data from the previous 12 months. Monthly calculations shall be made no later than 30 days after the end of each calendar month. [R307-401-8]

II.B.1.b.2 VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP emitting materials used each month if applicable to the product in sections 1, 2, and 3 below and/or to emission calculations in section 4. The record shall include the following data for each material used for calculating the rolling 12-month total: 1. Name of the VOC or volatile HAP-emitting process material 2. Percent by weight of all VOC and volatile HAP in each process material used 3. Quantity of each VOC and volatile HAP emitting process material used in pounds 4. The amount of VOC and volatile HAP emitted monthly by each process material used, calculated by the following procedure: VOC = (% VOC by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000 lb) Or an alternative VOC calculation consistent with US EPA emission calculation methodologies HAP = (% HAP by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000lb) Or an alternative HAP calculation consistent with US EPA emission calculation methodologies 5. The amount of VOC and volatile HAP emitted monthly from all materials used 6. The amount of VOC and volatile HAP reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC and volatile HAP emissions. [R307-401-8]
II.B.1.c The backup boiler may only be used during periods when a permitted boiler is taken out of
service. The backup boiler and the permitted boiler must not be operated at the same time, except
for periods of post-repair readiness checks and initial start-up of the permitted boiler. The backup
boiler shall only burn natural gas or propane. The backup boiler capacity shall not exceed the
boiler capacity listed in equipment section of this permit. Emission testing for the backup boiler
shall not be required, and emissions rates shall be guaranteed by vendor documentation.
[R307-401-8]

II.B.1.d The owner/operator shall use natural gas as fuel in all equipment listed in this permit as a primary fuel and propane as a backup fuel in the boilers (except for listed emergency equipment, which is diesel operated). [R307-401-8]

DAQE-IN141070020-24
Page 11
II.B.2 Paper Making Requirements II.B.2.a The paper-making machines 15B and 16B shall include cyclone separators (installed on the
Under Dryer Stacks and Wet End Stacks) and a venturi scrubber (installed on the Dry End Stacks) to control PM/PM10/PM2.5 emissions. [R307-401-8]
II.B.2.b The owner/operator shall maintain the pressure drop across the venturi scrubbers at no less than 4 inches of water gauge when the unit is operating and venting to the atmosphere. [R307-401-8] II.B.2.b.1 Monitor the scrubber differential pressure once per operating day. [R307-401-8]

II.B.2.b.2 Results of daily pressure drop readings shall be maintained. [R307-401-8] II.B.2.c One (1) drum filter for each of the existing 3 paper making converting lines shall control process
streams from the paper making converting operation when venting to the atmosphere. [R307-401-8]
II.B.2.d The permittee shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the change in pressure of the gas stream through the paper-making converting room drum filters. The monitoring device must be certified by the manufacturer to be accurate within plus or minus one inch of water gauge and must be calibrated on an annual basis in accordance with the manufacturer's instructions. Continuous recording for the monitoring device is not required. When the paper-making converting room drum filters are in operation and venting to the atmosphere, the pressure drop shall be no less than 1 inch of water gauge (w.g.) for more than five minutes in any 60-minute period except during start-up and shut-down of the converting dust control fans. The permittee is not restricted to a minimum pressure drop across the control device for the first 96 consecutive hours after replacement of a filter. This seasoning-in period shall last no more than 96 hours. [R307-401-8] II.B.2.d.1 Monitor the drum filter pressure drop once per operating day. [R307-401-8]

II.B.2.d.2 Records of the pressure drop shall be maintained. [R307-401-8]
II.B.2.e The owner/operator shall not exceed 96,360 MMBtu per rolling 12-month total of the 16B make-
up air units. [R307-401-8]

II.B.2.e.1 To determine the operational limitation for the 16B make-up air units, the owner/operator shall maintain a monthly log tracking the MMBtu per rolling 12-month total. [R307-401-8]
II.B.2.f The owner/operator shall not exceed 163,800 gallons of sodium bisulfite per rolling 12-month in
the storage tank. [R307-401-8]

II.B.2.f.1 To determine the throughput for the sodium bisulfite tank, the owner/operator shall maintain a monthly log tracking the gallons per rolling 12-month total. [R307-401-8]

DAQE-IN141070020-24
Page 12
II.B.3 Stack Testing Requirements II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from the
indicated emissions unit(s): ***Paper Machine 15B Process Stack ***
Pollutant lb/hr lb/MMBTU PM2.5 6.65 0.044 NOx 13.50 0.09
CO 15.75 0.105 ***Paper Machine 16B Process Stack ***
Pollutant lb/hr lb/MMBTU PM2.5 6.65 0.05115 NOx 3.95 0.03
CO 4.82 0.037 ***Paper Making Boilers*** (each)
Pollutant lb/hr ppmdv PM2.5 0.9 NA NOx 3.3 45
CO 3.0 70 ***Utility Boilers*** (each)
Pollutant lb/hr ppmdv PM2.5 0.74 NA NOx 1.80 10
CO 4.06 156 [R307-401-8]

II.B.3.a.1 Initial Test The owner/operator shall conduct an initial stack test for the Paper Machine 16B Process Stack within 180 days after startup. [R307-165-2]
II.B.3.a.2 Test Frequency
The owner/operator shall conduct subsequent stack tests for the following emissions units
according to the following schedule. The owner/operator must complete subsequent stack tests
within the indicated time after the date of the most recent stack test for the specified emission
unit.

Test every three (3) years for:
Paper Machine 15B Process Stack
Paper Machine 16B Process Stack
Utility Boilers
Paper Machine Boilers

The Director may require the owner/operator to perform a stack test at any time. [R307-165-2]

II.B.3.a.3 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]
DAQE-IN141070020-24
Page 13
II.B.3.a.4 Reporting Within 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]
II.B.3.a.5 PM2.5 Total PM2.5 = Filterable PM2.5 + Condensable PM2.5
Filterable PM2.5 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are
used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM2.5.
Condensable PM2.5 40 CFR 51, Appendix M, Method 202, or other EPA-approved testing method as acceptable to the Director.
Total PM2.5 40 CFR 60.8(b)(2), Appendix A, including EPA-approved testing method OTM 37.
[R307-401-8]
II.B.3.a.6 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.3.b CO 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

II.B.4 Assembled Paper Products Requirements
II.B.4.a The emissions from the assembled paper products A and B converting operation shall be routed
to the assembled paper products drum filters and the assembled paper product baghouses.
[R307-401-8]

II.B.4.b The assembled paper product drum filters and the assembled paper product baghouses shall be operated and maintained in accordance with the manufacturer's specifications. The drum filters and baghouses shall be equipped with gauges or meters, which indicate the pressure drop across the control device. The pressure gauges or meters shall be located such that an inspector/operator can safely read the indicators at any time. The drum filters and baghouses, while in operation and venting to the atmosphere, shall be operated such that the minimum pressure drop across each control device is greater than or equal to 0.5 inches of water column, except during start-up and shutdown of the fans. The permittee is not restricted to a minimum pressure drop across the control device for the first 96 hours of operation after replacement of the filter media on the drum filter or a bag(s) in the baghouse. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance warranty. [R307-401-8]
II.B.4.b.1 The permittee shall monitor the operating pressure drop across each drum filter and each
baghouse once per operating day. [R307-401-8]

II.B.4.b.2 The permittee shall maintain an operating and maintenance log for each drum filter and each baghouse along with the manufacturer's warranty. Records shall be maintained. [R307-401-8]
II.B.5 FAM Operations Requirements
II.B.5.a The emissions from the FAM raw material operational tanks, curing oven, and treatment from skid waste vents shall be routed to the RTO. [R307-401-8]
DAQE-IN141070020-24
Page 14
II.B.5.b The RTO shall be preheated and maintain the Manufacturer recommended temperature for ideal operation. [R307-401-8] II.B.5.b.1 The permittee shall monitor and record the RTO's temperatures once per operating day. The RTO's temperatures shall be maintained within the design conditions specified by the
manufacturer's performance warranty. The permittee shall maintain an operating and maintenance log for the RTO's. Continuous recording for the monitoring device is not required. [R307-401-8]

II.B.6 Emergency Generator Requirements II.B.6.a The owner/operator shall not operate each diesel-fired backup 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. [R307-401-8]
II.B.6.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 each diesel-fired backup engine shall be kept in a log and shall include the following: A. The date and time the diesel-fired backup engine was used B. The duration of operation in hours C. The reason for diesel-fired backup engine usage. [R307-401-8] II.B.6.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each diesel-fired backup engine. [R307-401-8]
II.B.6.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each diesel-fired backup engine. [R307-401-8]
II.B.6.b.1 The owner/operator shall only combust diesel fuel that meets a sulfur content of 15 ppm or less.
[R307-401-8]

II.B.6.b.2 To demonstrate compliance with the 15 ppm requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate the diesel fuel requirements. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN141070018-23 dated November 16, 2023 Is Derived From NOI dated April 26, 2024 Incorporates Additional Information dated September 11, 2024

DAQE-IN141070020-24
Page 15
ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-NN141070020-24
December 2, 2024
Box Elder News & Journal
Legal Advertising Dept
PO BOX 370
Brigham City, UT 84302-0370
RE: Legal Notice of Intent to Approve
This letter will confirm the authorization to publish the attached NOTICE in the Box Elder News &
Journal on December 4, 2024.
Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].
Sincerely,
{{$s }}
Jeree Greenwood
Office Technician
Enclosure
cc:Bear River Association of Governments
cc: Box Elder County
-4820
Telephone [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
DAQE-NN141070020-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: The Procter & Gamble Paper Products Company
Location: The Procter & Gamble Paper Products Company 5000 North Iowa Road, Bear
River City, UT
Project Description: The Procter & Gamble Paper Products Company (P&G) operates the Box Elder
Facility. The Box Elder Facility produces assembled paper products, soap
manufacturing products, and consumer article cleaning products. P&G has
requested to add a sodium bisulfate tank.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before January 3, 2025, will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: December 4, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-
RN141070020
July 30, 2024
Seth Garner
The Procter & Gamble Paper Products Company
5000 North Iowa String Road
Bear River City, UT 84301
[e-mail]
Dear Seth Garner,
Re: Engineer Review:
Minor Modification to Approval Order DAQE-AN141070018-24, for the Addition of a Storage
Tank
Project Number: N141070020
Please review and sign this letter and attached Engineer Review (ER) within 10 business days. For this
document to be considered as the application for a Title V administrative amendment, a Title V
Responsible Official must sign the next page.
Please contact Tad Anderson at [phone] if you have any questions or concerns about the ER. If
you accept the contents of this ER, please email this signed cover letter to Tad Anderson at
[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the DAQ
will consider any comments received and will issue the Approval Order.
If you do not respond to this letter within 10 business days,the project will move forward without your
approval. If you have concerns that we cannot resolve, the DAQ Director may issue an Order prohibiting
construction.
Approval Signature _____________________________________________________________
(Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 1
OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible Official, as
defined in R307-415-3, must sign the statement below. THIS IS STRICTLY OPTIONAL.
If you do not want the Engineer Review to be considered as an application to administratively amend
your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will require
submittal of a separate Operating Permit Application to revise the Title V permit in accordance with
R307-415-5a through 5e and R307-415-7a through 7i. A guidance document: Title V Operating Permit
Application Due Dates clarifies the required due dates for Title V operating permit applications and can
be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality
“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate and
complete and request that this Approval Order be considered as an application to
administratively amend the Operating Permit.”
Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 2
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW
SOURCE INFORMATION
Project Number N141070020
Owner Name The Procter & Gamble Paper Products Company
Mailing Address 5000 North Iowa String Road
Bear River City, UT, 84301

Source Name The Procter & Gamble Paper Products Company
Source Location 5000 North Iowa Road
Bear River City, UT 84301

UTM Projection 402500 m Easting, 4605600 m Northing
UTM Datum NAD27
UTM Zone UTM Zone 12
SIC Code 2621 (Paper Mills)

Source Contact Dean Shepherd
Phone Number [phone]
Email [e-mail]

Billing Contact Seth Garner
Phone Number 435-279-1377
Email [e-mail]

Project Engineer Tad Anderson, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted May 3, 2024
Date of Accepted Application No date entered

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 3
SOURCE DESCRIPTION
General Description
The Procter and Gamble Paper Products Company (P&G) operates the Box Elder Plant. The Box
Elder Plant produces paper and assembled paper products. The Box Elder Plant is located in Bear
River City, Utah.

NSR Classification:
Minor Modification at Major Source
Source Classification
Located in Box Elder County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
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), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities
Title V (Part 70) Major Source
Project Proposal
Minor Modification to Approval Order DAQE-AN141070018-24, for the Addition of a Storage
Tank
Project Description
P&G has requested to add a sodium bisulfate tank. The additional 4,000-gallon Sodium Bisulfite
tank is necessary in its Assembled Paper Products B operations, and it has recognized that a
minor amount of SO2 emissions result from the breathing and filling of the tank.

EMISSION IMPACT ANALYSIS
The emission rate for SO2 (0.041 tons per year) does not trigger modeling under R307-410-4. There are no
HAP emissions from these operations, so no modeling is required under R307-410-5. [Last updated July 30,
2024]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 4
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 280301.00
Carbon Monoxide 0 184.81
Nitrogen Oxides 0 138.84
Particulate Matter - PM10 0 164.63
Particulate Matter - PM2.5 0 142.03
Sulfur Oxides 0.04 4.27
Volatile Organic Compounds 0 130.07
Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 13
Acrylamide (CAS #79061) 0 194
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 17
Epichlorohydrin (L-Chloro-2,3-Epoxypropane) (CAS #106898) 0 16
Formaldehyde (CAS #50000) 0 325
Generic HAPs (CAS #GHAPS) 0 1011
Hexane (CAS #110543) 0 6286
Methanol (CAS #67561) 0 18132
Methyl Methacrylate (CAS #80626) 0 82
Propylene[1-Propene] (CAS #115071) 0 646
Toluene (CAS #108883) 0 45
Xylenes (Isomers And Mixture) (CAS #1330207) 0 25
Change (TPY) Total (TPY)
Total HAPs 0 13.40
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 5
Review of BACT for New/Modified Emission Units
1.BACT review regarding BACT/LAER
This project is not subject to UAC R307-403-3(3)a, since the source is major for PM2.5 in an PM2.5
nonattainment area but the project increase is for SO2 so LAER is not required.

Emissions from the sodium bisulfite tanks are 0.041 tons per year of SO2. The emissions from the
tank come from both breathing and working loss from the tank operations. A BACT analysis was
submitted for the addition of the tank which included flue gas desulfurization by scrubbing and
good operating practices.

Flue gas desulfurization by scrubbing is typically used on large combustion units with constant
concentrations and is not designed for the low and intermittent flow from small tanks. Based on
available BACT resources, this technology has not been established as technically feasible for this
application and is therefore not considered further.

BACT to control the 0.041 tons per year of SO2 is good operating practice.
[Last updated July 30, 2024]
SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 6
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]

I.8 The owner/operator shall submit documentation of the status of construction of the 16B paper
machine and natural gas-fired emergency generator to the Director within 18 months from
November 16, 2023. The owner/operator shall submit documentation of the status of
construction of the sodium bisulfite tank to the Director within 18 months from the date of this
AO. This AO may become invalid if construction is not commenced within 18 months from
the date of this AO or if construction is discontinued for 18 months or more. To ensure proper
credit when notifying the Director, send the documentation to the Director, attn.: NSR Section.
[R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 The Procter & Gamble-Box Elder Facility
II.A.2 Paper Machine 15B
One (1) Paper Machine
Natural Gas-Fired dryer
Size: 150 MMBTU/hr
Controls: Low NOx burner
Stack Height: 33.53 meters
Stack Diameter: 2.19 meters
Stack Flow rate: 183,335 acfm

Cyclonic Separator (wet-end of process and under machine exhaust)
Venturi Scrubber (dry-end of process) with a PM10 Control Efficiency: approximately 95%*
*Not for determining compliance but for replacement-in-kind.

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 7
II.A.3 Paper Machine 16B
One (1) Paper Machine

Natural Gas-Fired dryer
Size: 130 MMBTU/hr (combined)
Paper Machine Dryer Controls: Ultra-Low NOx burner
Make up Air Units Controls: Low NOx burners

Venturi Scrubber (dry end stack)
Cyclonic Separator (wet-end of process and under machine exhaust)

II.A.4 Paper Product and Utility Boilers
Two (2) Natural Gas-Fired Paper Product Boilers
Maximum Capacity: 60.24 MMBTU/hr (each)
Controls: Low-NOx Burners
Secondary fuel: Propane (emergency or curtailment)

Two (2) Natural Gas-Fired Utility Boilers
Maximum Capacity: 50 MMBTU/hr (each)
Controls: UltraLow-NOx Burners

One (1) Natural Gas Back-Up Boiler (if boilers are out of service)

II.A.5 Paper Product Converting Operation
One (1) Paper Product Converting Operation
PM10 Controls: Three existing (3) Drum Filters -Vent to Atmosphere
Two (2) New Baghouses - Vent Indoors
Five (5) Converting Lines

II.A.6 Assembled Paper Product A Baghouse
One (1) Assembled Paper Product Baghouses

II.A.7 Assembled Paper Product A Drum Filters
Four (4) Assembled Paper Product Drum Filters

II.A.8 Assembled Paper Product A Equipment
Pneumatic Pumps

II.A.9 Assembled Paper Product A Portable Dry Vacuum Unit

II.A.10 Assembled Paper Product B Dryer
Capacity: 10 MMBtu/hr (4-2.5 MMBtu/hr burners)

II.A.11 Assembled Paper Product B Drum Filter System
Drum Filter systems

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 8
II.A.12 Assembled Paper Product B Baghouse/Fabric Filter
Three (3) Baghouses:
1) Briquetter Baghouse
2) Active Ingredient Baghouse
3) Central Vacuum System Baghouse

II.A.13
NEW
Storage Tank (NEW)
Sodium Bisulfite Storage Tank
Capacity: 4,000 gallons

II.A.14 FAM RTO
Burner Size: 2 MMBtu/hr
Control: Low-NOx Burner
Flow Rate: 7,500 scfm
II.A.15 FAM Silo

II.A.16 Assembled Paper Product B Equipment
Pneumatic Pumps

II.A.17 Assembled Paper Product B Inks RTO
Burner Size: 1 MMBtu/hr
Flow Rate: 2,500 scfm

II.A.18 Diesel-Fired Back-Up Engines
Five (5) Emergency Equipment

Two (2) Fire Pumps
Maximum Capacity:375 hp (each)

Two (2) Fire Pumps
Maximum Capacity:399 hp (each)

One (1) Power Generator
Maximum Capacity:1,214 hp

II.A.19 Natural Gas-Fired Back-Up Engines
One (1) Emergency Generator
Capacity: 54 hp (40kW)

One (1) Emergency Generator (NEW)
Capacity: 1006 hp (750kW)

II.A.20 Cooling Towers
Multiple cooling towers with drift eliminators (0.001%) to support the facility.

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 9
II.A.21 Tanks
Multiple tanks including diesel and gasoline fuel storage and various raw material storage
tanks.

40 CFR 60 Subpart Kb is not applicable to these storage tanks based on exemptions listed
under 40 CFR 60.110b(b).

II.A.22 FAM Making Operations Tanks
Capacity: 500-gallons
Material: Sodium Bisulfite

Capacity: 6,000-gallons
Material: Sodium Bisulfite

Capacity: 60-gallons
Material: 25% mixture HCl

II.A.23 Multiple Space Heaters

II.A.24 Truck Loading

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Requirements
II.B.1.a Visible emissions from the following emission points shall not exceed the following values:
A. All natural gas operated equipment - 10% opacity
B. Cooling towers - 10 % opacity
C. Baghouses - 10% opacity
D. RTO - 10% opacity
E. All other points - 20% opacity. [R307-401]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 10
II.B.1.a.1 The permittee shall conduct a monthly 1-minute visible emissions test of each affected source
in accordance with 40 CFR 60, Appendix A, Method 22.

If no visible emissions are observed in six consecutive monthly tests for any affected source,
the permittee may decrease the frequency of testing from monthly to semi-annually for the
affected source. If visible emissions are observed during any semi-annual test, the permittee
shall resume testing of that affected source on a monthly basis and maintain that schedule until
no visible emissions are observed for six consecutive monthly tests.

If no visible emissions are observed during two consecutive semi-annual tests for any affected
source, the permittee may decrease the frequency of testing from semi-annually to annually
for the affected source. If visible emissions are observed during any annual test, the permittee
shall resume testing of that affected source on a monthly basis and maintain that schedule until
no visible emissions are observed for six consecutive monthly tests.

If visible emissions are observed during any Method 22 test, a current Method 9 certified
observer shall conduct a:

1) six minute test of opacity in accordance with 40 CFR 60, Appendix A Method 9 for point
sources, or
2) one minute test of opacity with five second observation intervals in accordance with 71 FR
55126, Method 203C for fugitive emission sources
3) the Method 9 or 203C test shall begin within 24 hours of any observation of visible
emission. [R307-401-8]

II.B.1.a.2 Records of visible emission tests performed and data required by 40 CFR 60, Appendix A,
Method 22, Method 9, or 58 FR 61640, Method 203C shall be maintained. [R307-401-8]

II.B.1.b The plant-wide emissions of VOCs and HAPs from the operations shall not exceed:

130.07 tons of VOC emissions per rolling 12-month period
3.14 tons of Hexane per rolling 12-month period
9.07 tons of Methanol per rolling 12-month period. [R307-401-8]

II.B.1.b.1 Compliance with each limitation shall be determined on a rolling 12-month total. Based on the
last day of each month, a new 12-month total shall be calculated using data from the previous
12 months. Monthly calculations shall be made no later than 30 days after the end of each
calendar month. [R307-401-8]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 11
II.B.1.b.2 VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP
emitting materials used each month if applicable to the product in sections 1, 2, and 3 below
and/or to emission calculations in section 4. The record shall include the following data for
each material used for calculating the rolling 12-month total:

1. Name of the VOC or volatile HAP emitting process material.

2. Percent by weight of all VOC and volatile HAP in each process material used.

3. Quantity of each VOC and volatile HAP emitting process material used in pounds.

4. The amount of VOC and volatile HAP emitted monthly by each process material used,
calculated by the following procedure:

VOC = (% VOC by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000 lb)
Or an Alternative VOC calculation consistent with US EPA emission calculation
methodologies.

HAP = (% HAP by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000lb)
Or an Alternative HAP calculation consistent with US EPA emission calculation
methodologies.

5. The amount of VOC and volatile HAP emitted monthly from all materials used.

6. The amount of VOC and volatile HAP reclaimed for the month shall be similarly quantified
and subtracted from the quantities calculated above, to provide the monthly total VOC and
volatile HAP emissions. [R307-401-8]

II.B.1.c The back-up boiler may only be used during periods when a permitted boiler is taken out of
service. The back-up boiler and the permitted boiler must not be operated at the same time,
except for periods of post-repair readiness checks and initial start-up of the permitted boiler.
The back-up boiler shall only burn natural gas or propane. The back-up boiler capacity shall
not exceed the boiler capacity listed in equipment section of this permit. Emission testing for
the back-up boiler shall not be required and emissions rates shall be guaranteed by vendor
documentation. [R307-401-8]

II.B.1.d The owner/operator shall use natural gas as fuel in all equipment listed in this permit as a
primary fuel and propane as a backup fuel in the boilers (except for listed emergency
equipment which is diesel operated). [R307-401-8]

II.B.2 Paper Making Requirements
II.B.2.a The paper making machines 15B and 16B shall include cyclone separators (installed on the
Under Dryer Stacks and Wet End Stacks) and a venturi scrubber (installed on the Dry End
Stacks) to control PM/PM10/PM2.5 emissions. [R307-401-8]

II.B.2.b The owner/operator shall maintain the pressure drop across the venturi scrubbers at no less
than 4 inches of water gauge when the unit is operating and venting to the atmosphere. [R307-
401-8]

II.B.2.b.1 Monitor the scrubber differential pressure once per operating day. [R307-401-8]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 12
II.B.2.b.2 Results of daily pressure drop readings shall be maintained. [R307-401-8]
II.B.2.c One drum filter for each of the existing 3 paper making converting lines shall control process
streams from the paper making converting operation when venting to the atmosphere. [R307-
401-8]
II.B.2.d The permittee shall install, calibrate, maintain, and operate a monitoring device for the
continuous measurement of the change in pressure of the gas stream through the paper making
converting room drum filters. The monitoring device must be certified by the
Manufacturer to be accurate within plus or minus one inch of water gauge and must be
calibrated on an annual basis in accordance with the
Manufacturer's instructions. Continuous recording for the monitoring device is not required.
When the paper making converting room drum filters are in operation and venting to the
atmosphere the pressure drop shall be no less than 1 inches water gauge (w.g.) for more than
five minutes in any 60-minute period except during start-up and shut-down of the converting
dust control fans. After a media change the pressure drop will be less than 1.0 inches of water
gauge. The permittee is not restricted to a minimum pressure drop across the control device
for the first 96 consecutive hours after replacement of a filter. This seasoning-in period shall
last no more than 96 hours. [R307-401-8]

II.B.2.d.1 Monitor the drum filter pressure drop once per operating day. [R307-401-8]

II.B.2.d.2 Records of the pressure drop shall be maintained. [R307-401-8]

II.B.2.e The owner/operator shall not exceed 96,360 MMBtu per rolling 12-month total of the 16B
make-up air units. [R307-401-8]

II.B.2.e.1 To determine the operational limitation for the 16B make-up air units, the owner/operator
shall maintain a monthly log tracking the MMBtu per rolling 12-month total. [R307-401-8]

II.B.2.f
NEW
The owner/operator shall not exceed 10,400 gallons of sodium bisulfite per rolling 12-month
in the storage tank. [R307-401-8]

II.B.2.f.1
NEW
To determine the throughput for the sodium bisulfite tank, the owner/operator shall maintain a
monthly log tracking the gallons per rolling 12-month total. [R307-401-8]

II.B.3 Stack Testing Requirements
Engineer Review N141070020: The Procter & Gamble Paper Products Company
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Page 13
II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from the
indicated emissions unit(s):

***Paper Machine 15B Process Stack ***
Pollutant lb/hr lb/MMBTU
PM2.5 6.65 0.044
NOx 13.50 0.09
CO 15.75 0.105

***Paper Machine 16B Process Stack ***
Pollutant lb/hr lb/MMBTU
PM2.5 6.65 0.05115
NOx 3.95 0.03
CO 4.82 0.037

***Paper Making Boilers*** (each)
Pollutant lb/hr ppmdv
PM2.5 0.9 NA
NOx 3.3 45
CO 3.0 70

***Utility Boilers*** (each)
Pollutant lb/hr ppmdv
PM2.5 0.74 NA
NOx 1.80 10
CO 4.06 156. [R307-401-8]

II.B.3.a.1 Initial Test
The owner/operator shall conduct an initial stack test for the Paper Machine 16B Process
Stack within 180 days after startup. [R307-165-2]

II.B.3.a.2 Test Frequency
The owner/operator shall conduct subsequent stack tests for the following emissions units
according to the following schedule. The owner/operator must complete subsequent stack tests
within the indicated time after the date of the most recent stack test for the specified emission
unit.

Test every three years for:
Paper Machine 15B Process Stack
Paper Machine 16B Process Stack
Utility Boilers
Paper Machine Boilers

The Director may require the owner/operator to perform a stack test at any time. [R307-165-2]

II.B.3.a.3 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]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
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II.B.3.a.4 Reporting
Within 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]
II.B.3.a.5 PM2.5
Total PM2.5 = Filterable PM2.5 + Condensable PM2.5

Filterable PM2.5
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-
approved testing method as acceptable to the Director. If other approved testing methods are
used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the
filterable particulate emissions shall be considered PM2.5.

Condensable PM2.5
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to
the Director.

Total PM2.5
40 CFR 60.8(b)(2), Appendix A, including EPA-approved testing method OTM 37. [R307-
401-8]

II.B.3.a.6 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]

II.B.3.b CO
40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to
the Director. [R307-401-8]

II.B.4 Assembled Paper Products Requirements
II.B.4.a The emissions from the assembled paper products A and B converting operation shall be
routed to the assembled paper products drum filters and the assembled paper product
baghouses. [R307-401-8]

II.B.4.b The assembled paper product drum filters and the assembled paper product baghouses shall be
operated and maintained in accordance with the Manufacturer's specifications. The drum
filters and baghouses shall be equipped with gauges or meters, which indicates the pressure
drop across the control device. The pressure gauges or meters shall be located such that an
inspector/operator can safely read the indicators at any time. The drum filters and baghouses
while in operation and venting to the atmosphere shall be operated such that the minimum
pressure drop across each control device is greater than or equal to 0.5 inches of water column
except during start-up and shutdown of the fans. The permittee is not restricted to a minimum
pressure drop across the control device for the first 96 hours of operation after replacement of
the filter media on the drum filter or a bag(s) in the baghouse. The operating pressure drop
shall be maintained within the design conditions specified by the Manufacturer's performance
warranty. [R307-401-8]

II.B.4.b.1 The permittee shall monitor the operating pressure drop across each drum filter and each
baghouse once per operating day. [R307-401-8]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 15
II.B.4.b.2 The permittee shall maintain an operating and maintenance log for each drum filter and each
baghouse along with the Manufacturer's warranty. Records shall be maintained. [R307-401-8]

II.B.5 FAM Operations Requirements
II.B.5.a The emissions from the FAM raw material operational tanks, curing oven, treatment from skid
waste vents shall be routed to the RTO. [R307-401-8]

II.B.5.b The RTO shall be preheated and maintain the Manufacturer recommended temperature for
ideal operation. [R307-401-8]

II.B.5.b.1 The permittee shall monitor and record the RTO's temperatures once per operating day. The
RTO's temperatures shall be maintained within the design conditions specified by the
Manufacturer's performance warranty. The permittee shall maintain an operating and
maintenance log for the RTO's. Continuous recording for the monitoring device is not
required. [R307-401-8]

II.B.6 Emergency Generator Requirements
II.B.6.a The owner/operator shall not operate each diesel-fired backup 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. [R307-401-8]

II.B.6.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 each diesel-fired backup engine shall be kept in a log
and shall include the following:

A. The date and time the diesel-fired backup engine was used
B. The duration of operation in hours
C. The reason for diesel-fired backup engine usage. [R307-401-8]

II.B.6.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each diesel-fired backup engine. [R307-401-8]

II.B.6.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each diesel-fired backup engine. [R307-401-8]

II.B.6.b.1 The owner/operator shall only combust diesel fuel that meets a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.6.b.2 To demonstrate compliance with the 15 ppm requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate the diesel fuel requirements.
[R307-401-8]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 16
PERMIT HISTORY
When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Is Derived From NOI dated April 26, 2024
Supersedes DAQE-AN141070018-23 dated November 16, 2023
REVIEWER COMMENTS
1.Comment regarding Emission Estimates:
Emissions from the sodium bisulfite tank are estimated using equations from the Environmental
Protection Agency's, Air Emissions Inventory Improvement Program, Technical Report Series,
Volume II3. Section 2.2.4 of Chapter 16 states that the two significant types of losses from storage
tanks are breathing loss and working loss. Breathing loss is "the expulsion of vapor from a tank
through vapor expansion and contraction that result from changes in ambient temperature and
barometric pressure." Working loss is defined as "the combined loss from filling and emptying
tanks.". The tank is estimated to be filled 26 times per year with a throughput of 10, 400 gallons per
year. [Last updated July 30, 2024]
2.Comment regarding Netting Analysis:
The P&G, Box Elder Facility is an existing major source for nonattainment (PM2.5) new source
review. To determine project is classified as a major modification, the project must result in a
significant emissions increase, and a significant net emissions increase (40 CFR 51.165(a)(1)(v)(A)).
The addition of the storage tank has a 0.041 tons per year increase of SO2 which does not does not
result in a significant net emissions increase because the net emissions increase from both projects is
less than significant emissions rates (40 tons per year). [Last updated July 30, 2024]
3.Comment regarding Project Classification:
Box Elder County is in attainment for CO, NO2, PM10, SO2, Ozone, and Lead. The major source
threshold for PSD is 250 tons per year per pollutant. The Box Elder Facility site-wide emissions per
pollutants in attainment are less than 250 tons per year. The Box Elder Plant and the proposed
modification is not subject to the PSD program.

The P&G, Box Elder facility is an existing major source for nonattainment (PM2.5) new source
review. If a major source undergoes a modification which requires a physical change or change in
operation, the facility must determine whether the project will be considered a major modification.
To determine project is classified as a major modification, the project must result in a significant
emissions increase, and a significant net emissions increase. This project has a SO2 emissions
increase of 0.041 tons per year which is below the 40 tons per year of SO2 threshold limit for
significant. This project is classified as a minor modification at a major source.
[Last updated July 30, 2024]
5.Comment regarding Offsets:
This project is not classified as a major modification in a nonattainment area for PM2.5 and is not
subject to UAC R307-403-3(3) c and d. No offsets are required for this permit modification. [Last
updated July 30, 2024]
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 17
7.Comment regarding PM2.5 SIP Source:
The Box Elder Facility is a listed major source with conditions in Part H.12.n of the PM2.5 Serious
Nonattainment SIP. The PM2.5 Serious Nonattainment SIP has been approved by the Air Quality
Board, but has not been approved by Region 8 EPA. The PM2.5 Serious Nonattainment SIP
conditions have been incorporated into the current AO. Once the AO has been signed by the director
appropriate actions will be conducted to fulfil state obligations for this modification. [Last updated
April 29, 2024]
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 18
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds
Working Document
Project Number: N14107-0020
Regarding: Modification to Approval Order DAQE-AN141070018-24, for the Addition of a Storage
Tank

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXAbstract/Project
Abstract
The Procter and Gamble Paper Products Company (P&G) operates the Box Elder Plant. The Box Elder
Plant produces assembled paper products, soap manufacture products and consumer article cleaning
products. The Box Elder Plant is located in Bear River City, Utah.

Project Description
P&G has requested to add a sodium bisulfate tank. The additional 4,000-gallon Sodium Bisulfite tank is
necessary in its Assembled Paper Products B operations, and it has recognized that a minor amount of
SO2 emissions result from the breathing and filling of the tank.

Newspaper Notice
4/26/202

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXHistory
Project History
NOI Date 4/26/2024
Superseded AO DAQE-AN141070018-223 5/26/2022
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXEquipment
EEEEEEEEEEEEEEEEEE 1
CCCCCCCCCCCCCCCC General Requirements
The Procter & Gamble-Box Elder Facility
EEEEEEEEEEEEEEEEEE
CCCCCCCCCCCCCCCC Site wide
II.A.2
Paper Machine 15B
One (1) Paper Machine
Natural Gas-Fired dryer
Size: 150 MMBTU/hr
Controls: Low NOx burner
Stack Height: 33.53 meters
Stack Diameter: 2.19 meters
Stack Flow rate: 183,335 acfm

Cyclonic Separator (wet-end of process and under machine exhaust)
Venturi Scrubber (dry-end of process) with a PM10 Control Efficiency: approximately 95%*
*Not for determining compliance but for replacement-in-kind.
EEEEEEEEEEEEEEEEEE
CCCCCCCCCCCCCCCCCCPaper Making Requirements
Paper Machine 16B (NEW)
One (1) Paper Machine
Natural Gas-Fired dryer
Size: 130 MMBTU/hr (combined)
Paper Machine Dryer Controls: Ultra-Low NOx burner
Make up Air Units Controls: Ultra-Low NOx burners

Venturi Scrubber (dry end stack)
Cyclonic Separator (wet-end of process and under machine exhaust)

EEEEEEEEEEEEEEEEE
CCCCCCCCCCCCCCCCCStack Testing Requirements
II.A.3
Paper Product and Utility Boilers
EEEEEEEEEEEEEEEEEEEEEEEE
CCCCCCCCCCCCCCAssembled Paper Products A Requirements
II.A.4
Paper Product Converting Operation
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.5
Assembled Paper Product A Baghouses
Two (2) Assembled Paper Product Baghouses
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.6
Assembled Paper Product A Drum Filters
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.7
Assembled Paper Product A Equipment
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.8
Assembled Paper Product A Portable Dry Vacuum Unit
EEEEEEEEEEEEEEEEEEEEEEEE
CCCCCCCCCCCCCAssembled Paper Products B Requirements
II.A.9
Assembled Paper Product B Dryer
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.10
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.11
Assembled Paper Product B Baghouse/Fabric Filter
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.12
Storage Tank
Sodium Bisulfite Storage Tank
Capacity: 4,000 gallons
EEEEEEEEEEEEEEEEEEEEEEEE
CCCCCCCCCCCCCCFAM Operations Requirements
II.A.12
FAM RTO (84)
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.13
FAM Silo
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.14
Assembled Paper Product B Equipment
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.15
Assembled Paper Product B Inks RTO
EEEEEEEEEEEEEEEEEEEEEEEE
CCCCCCCCCCCCCCCCEmergency Generator Requirements
II.A.16
Diesel-Fired Back-Up Engines

EEEEEEEEEEEEEEEEEEEEEEEE
UPDATED

NEW II.A.17
Natural Gas-Fired Back-Up Engines
One (1) Emergency Generator
Capacity: 54 hp (40kW)
One (1) Emergency Generator (NEW)
Capacity: 1006 hp (750kW)

EEEEEEEEEEEEEEEEEEEEEEEE
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.18
Cooling Towers
Multiple cooling towers with drift eliminators to support the facility.
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.19
Tanks
Multiple tanks including diesel and gasoline fuel storage and various raw material storage tanks.
40 CFR 60 Subpart Kb is not applicable to these storage tanks based on exemptions listed under 40 CFR
60.110b(b).
EEEEEEEEEEEEEEEEEEEEEEEE
II.A.20
FAM Making Operations Tanks
Capacity: 500-gallons
Material: Sodium Bisulfite

Capacity: 6,000-gallons
Material: Sodium Bisulfite

Capacity: 60-gallons
Material: 25% mixture HCl

EEEEEEEEEEEEEEEEEEEEEEEE
II.A.21
Multiple Space Heaters

EEEEEEEEEEEEEEEEEEEEEEEE
II.A.22
Truck Loading
EEEEEEEEEEEEEEEEEEEEEEEE
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXEmissions Summary
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXAir Program Codes
Bring Forward
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXRequirement Profiles
Bring Forward
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXConditions
Bring Forward
Standard requirements
CCCCCCCCCCCCCCCCCCCCCCCCCCC
I.8 installation
The owner/operator shall notify the Director in writing when the installation of the RTO is completed as
required by AO DAQE-AN141070016-22.

The owner/operator shall submit documentation of the status of construction of the two additional
paper converting lines, three cooling towers and three pneumatic pumps to the Director within 18
months from the date of this AO. This AO may become invalid if construction is not commenced within
18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section
CCCCCCCCCCCCCCCCCCCCCCCCCCC
Site Wide Requirements
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary AI
Visible emissions from the following emission points shall not exceed the following values:

A. All natural gas operated equipment - 10% opacity
B. Cooling towers - 10 % opacity
C. Baghouses – 10% opacity
D. RTO – 10% opacity
E. All other points - 20% opacity

CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Records of visible emission tests performed and data required by 40 CFR 60, Appendix A, Method 22,
Method 9, or 58 FR 61640, Method 203C shall be maintained.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
The plant-wide emissions of VOCs and HAPs from the operations shall not exceed:

152.12 tons of VOC emissions per rolling 12-month
3.14 tons of Hexane per rolling 12-month period
9.07 tons of Methanol per rolling 12-month period

CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Compliance with each limitation shall be determined on a rolling 12-month total. Based on the last day
of each month, a new 12-month total shall be calculated using data from the previous 12 months.
Monthly calculations shall be made no later than 30 days after the end of each calendar month.

CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP emitting materials
used each month if applicable to the product in sections 1, 2, and 3 below and/or to emission
calculations in section 4. The record shall include the following data for each material used for
calculating the rolling 12-month total:
1. Name of the VOC or volatile HAP emitting process material.

2. Percent by weight of all VOC and volatile HAP in each process material used.

3. Quantity of each VOC and volatile HAP emitting process material used in pounds.

4. The amount of VOC and volatile HAP emitted monthly by each process material used, calculated by
the following procedure:

VOC = (% VOC by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000 lb)
Or an Alternative VOC calculation consistent with US EPA emission calculation methodologies.
HAP = (% HAP by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000lb)
Or an Alternative HAP calculation consistent with US EPA emission calculation methodologies.
5. The amount of VOC and volatile HAP emitted monthly from all materials used.
6. The amount of VOC and volatile HAP reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above, to provide the monthly total VOC and volatile HAP
emissions.

CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
The back-up boiler may only be used during periods when a permitted boiler is taken out of service. The
back-up boiler and the permitted boiler must not be operated at the same time, except for periods of
post-repair readiness checks and initial start-up of the permitted boiler. The back-up boiler shall only
burn natural gas or propane. The back-up boiler capacity shall not exceed the boiler capacity listed in
equipment section of this permit. Emission testing for the back-up boiler shall not be required and
emissions rates shall be guaranteed by vendor documentation.

CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
The owner/operator shall use natural gas as fuel in all equipment listed in this permit as a primary fuel
and propane as a backup fuel in the boilers (except for listed emergency equipment which is diesel
operated).
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
II.B.2
Paper Making Requirements
The paper making machines 15B and 16B shall include cyclone separators (installed on the Under Dryer
Stacks and Wet End Stacks) and a venturi scrubber (installed on the Dry End Stacks) to control
PM/PM10/PM2.5 emissions.

CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
The owner/operator shall maintain the pressure drop across the venturi scrubbers at no less than 4
inches of water gauge when the unit is operating and venting to the atmosphere.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Monitor the scrubber differential pressure once per operating day.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Results of daily pressure drop readings shall be maintained.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
One drum filter for each of the existing 3 paper making converting lines shall control process streams
from the paper making converting operation when venting to the atmosphere.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
The permittee shall install, calibrate, maintain, and operate a monitoring device for the continuous
measurement of the change in pressure of the gas stream through the paper making converting room
drum filters. The monitoring device must be certified by the manufacturer to be accurate within plus or
minus one inch of water gauge and must be calibrated on an annual basis in accordance with the
manufacturer's instructions. Continuous recording for the monitoring device is not required. When the
paper making converting room drum filters are in operation and venting to the atmosphere the pressure
drop shall be no less than 1 inches water gauge (w.g.) for more than five minutes in any 60-minute
period except during start-up and shut-down of the converting dust control fans. After a media change
the pressure drop will be less than 1.0 inches of water gauge. The permittee is not restricted to a
minimum pressure drop across the control device for the first 96 consecutive hours after replacement of
a filter. This seasoning-in period shall last no more than 96 hours.

CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Monitor the drum filter pressure drop once per operating day.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Records of the pressure drop shall be maintained.

CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
The owner/operator shall not exceed 10,400 gallons of sodium bisulfite per rolling 12-month in the
storage tank.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
To determine the throughput for the sodium bisulfite tank, the owner/operator shall maintain a
monthly log tracking the gallons per rolling 12-month total.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
Stack Testing Requirements Paper Product and Utility Boilers
II.B.3.a Update Testing limits
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Standard Conditions & Emission Limit Parameters

CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Initial Test
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Test Frequency
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
Notification
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
PM2.5
Total PM2.5 = Filterable PM2.5 + Condensable PM2.5
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
NOx
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CO
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
Assembled Paper Products A Requirements Paper Product Converting Operation
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
The assembled paper product drum filters and the assembled paper product baghouses shall be
operated and maintained in accordance with the manufacturer's specifications. specified by the
manufacturer's performance warranty.

CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
FAM Operations Requirements FAM RTO
The emissions from the FAM raw material operational tanks, curing oven, treatment from skid waste
vents shall be routed to the RTO.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
The RTO shall be preheated and maintain the Manufacturer recommended temperature for ideal
operation.

CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
Emergency Generator Requirements
The owner/operator shall not operate each diesel-fired backup engine on site for more than 100 hours

CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in
each diesel-fired backup engine.
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Tertiary
CCCCCCCCCCCCCCCCCCCCCCCCCCC Secondary
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXBACT
This project is not subject to UAC R307-403-3(3)a, since the source is major for PM2.5 in an PM2.5
nonattainment area but the project increase is for SO2 so LAER is not required.

Emissions from the sodium bisulfite tanks are 0.041 tons per year of SO2. The emissions from the tank
come from both breathing and working loss from the tank operations. A BACT analysis was submitted
for the addition of the tank which included flue gas desulfurization by scrubbing and good operating
practices.

Flue gas desulfurization by scrubbing is typically used on large combustion units with constant
concentrations and is not designed for the low and intermittent flow from small tanks. Based on
available BACT resources, this technology has not been established as technically feasible for this
application and is therefore not considered further.

BACT to control the 0.041 tons per year of SO2 is good operating practice.

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXModeling
The emission rate for SO2 (0.041 tons per year) does not trigger modeling under R307-410-4. There are
no HAP emissions from these operations, so no modeling is required under R307-410-5.

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXComments
MMMMMMMMMMMMMMMMMMM
Emission Estimates
Emissions from the sodium bisulfite tank are estimated using equations from the Environmental
Protection Agency’s, Air Emissions Inventory Improvement Program, Technical Report Series, Volume
II3. Section 2.2.4 of Chapter 16 states that the two significant types of losses from storage tanks are
breathing loss and working loss. Breathing loss is “the expulsion of vapor from a tank through vapor
expansion and contraction that result from changes in ambient temperature and barometric pressure.”
Working loss is defined as “the combined loss from filling and emptying tanks.”. The tank is estimated
to be filled 26 times per year with a throughput of 10, 400 gallons per year.

MMMMMMMMMMMMMMMMMMM
Permit Updates
With the addition of the sodium bisulfite tank, a throughput limit of sodium bisulfite has been included
to the permit to control the SO2 emissions.

MMMMMMMMMMMMMMMMMMM
Netting Analysis
The P&G, Box Elder Facility is an existing major source for nonattainment (PM2.5) new source review.
To determine project is classified as a major modification, the project must result in a significant
emissions increase, and a significant net emissions increase (40 CFR 51.165(a)(1)(v)(A)). The addition of
the storage tank has a 0.041 tons per year increase of SO2 which does not does not result in a
significant net emissions increase because the net emissions increase from both projects is less than
significant emissions rates (40 tons per year).

MMMMMMMMMMMMMMMMMMM
Project Classification
Box Elder County is in attainment for CO, NO2, PM10, SO2, Ozone, and Lead. The major source threshold
for PSD is 250 tons per year per pollutant. The Box Elder Facility site-wide emissions per pollutants in
attainment are less than 250 tons per year. The Box Elder Plant and the proposed modification is not
subject to the PSD program.

The P&G, Box Elder facility is an existing major source for nonattainment (PM2.5) new source review. If
a major source undergoes a modification which requires a physical change or change in operation, the
facility must determine whether the project will be considered a major modification. To determine
project is classified as a major modification, the project must result in a significant emissions increase,
and a significant net emissions increase. This project has a SO2 emissions increase of 0.041 tons per
year which is below the 40 tons per year of SO2 threshold limit for significant. This project is classified
as a minor modification at a major source.

MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
Offsets
This project is not classified as a major modification in a nonattainment area for PM2.5 and is not
subject to UAC R307-403-3(3) c and d. No offsets are required for this permit modification.

MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
PM2.5 SIP Source
The Box Elder Facility is a listed major source with conditions in Part H.12.n of the PM2.5 Serious
Nonattainment SIP. The PM2.5 Serious Nonattainment SIP has been approved by the Air Quality Board,
but has not been approved by Region 8 EPA. The PM2.5 Serious Nonattainment SIP conditions have
been incorporated into the current AO. Once the AO has been signed by the director the appropriate
actions will be conducted to fulfil state obligations for this modification.

MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
MMMMMMMMMMMMMMMMMMM
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Project Emissions
New Equipment Process
PM10 PM2.5 VOC NOX CO SOx GHG
Paper Machine (16B) 55.22 45.03 34.13 18.8 30 0.37 72317
Emergency Generator 0.00426 0.00426 0.26 0.2 0.2 0.000251 49.99
Total Emissions 55.22 45.03 34.39 19.00 30.20 0.37 72366.99
Contemporaneous PTE Emissions Increase
Permits PM2.5 emissions AO date Increases PTE
DAQE-AN141070017-22 150.88 10/6/2022
DAQE-AN141070016-22 150.38 5/26/2022 0.5
DAQE-AN141070014-21 150.35 2/22/2021 0.19
DAQE-AN141070012-19 150.16 6/18/2016 0
DAQE-AN141070009-16 150.16 10/26/2016 12.76
DAQE-AN141070008-14 137.4 1/21/2014 0
DAQE-AN141070006-13* 137.4 8/2/2013 0
DAQE-AN141070003-11 137.4 9/25/2012 0
DAQE-AN141070002-11 137.4 11/3/2011 0
*seperation of PM10 and PM2.5
2020 2017
Pollutant Description Emissions Pollutant
PM10 Primary (Filt + Cond) 43.47582 PM10 Primary (Filt + C
PM2.5 Primary (Filt + Cond) 43.47582 PM2.5 Primary (Filt +
Sulfur Dioxide 0.24819 Sulfur Dioxide
Nitrogen Oxides 43.73682 Nitrogen Oxides
Volatile Organic Compounds 49.76895 Volatile Organic Comp
Carbon Monoxide 35.72156 Carbon Monoxide
Acrylamide 3.5887 Acrylamide
Benzene 0.63563
Cadmium 0.00046 Cadmium
Chromium 0.00058 Chromium
Formaldehyde 0.32247 Formaldehyde
Hexane 1.3166 Hexane
Mercury 0.00011
Methanol 2.2742 Methanol
Toluene 0.75679
Xylenes (Mixed Isomers) 0.3056
Nickel 0.00088 Nickel
Polycyclic Organic Ma
Netting Analysis
2014 2015 2016 2017 2018 2019 2020
PM2.5 PTE 137.4 137.4 150.16 150.16 150.16 150.16 150.16
PM2.5 Actuals 40.54 43.48
Submitted Emissions Inventories
Significant TPY Significant Emission increase
CO 100 PM2.5=45.03 TPY > 10 TPY significant
NOx 40
SO2 40 Significan Net Emissions Increase
PM 25 10 years of actual emissions to future allowable
PM10 15 Contemporaeneous Period July 2021 to July 2026
PM2.5 10 BAE year selected March 2020 to February 2022
Ozone/VOC 40
Lead 0.6
Fluorides 3
Questions
BAE
Need support information (actual emissions) for all year
Netting Analysis Timeline
End Analysis
Emissions
Cond)40.75048
+ Cond)40.53512
0.28669
26.69857
pounds 16.80916
27.10999
1.6575
0.00083
0.0005
0.15843
1.07397
3.08267
0.00046
atter 7.00E-05
2021 2022 2023 2024
150.35 150.88 150.88
rs not just 2020 to 2022

Procter and Gamble Paper Products Company
Trinity Consultants A-1

APPENDIX A. EMISSIONS CALCULATIONS

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Procter and Gamble Paper Products Company
Trinity Consultants B-1

APPENDIX B. ENGINEERING REVIEW
DAQE-
RN141070020
July 30, 2024
Seth Garner
The Procter & Gamble Paper Products Company
5000 North Iowa String Road
Bear River City, UT 84301
[e-mail]
Dear Seth Garner,
Re: Engineer Review:
Minor Modification to Approval Order DAQE-AN141070018-24, for the Addition of a Storage
Tank
Project Number: N141070020
Please review and sign this letter and attached Engineer Review (ER) within 10 business days. For this
document to be considered as the application for a Title V administrative amendment, a Title V
Responsible Official must sign the next page.
Please contact Tad Anderson at [phone] if you have any questions or concerns about the ER. If
you accept the contents of this ER, please email this signed cover letter to Tad Anderson at
[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the DAQ
will consider any comments received and will issue the Approval Order.
If you do not respond to this letter within 10 business days, the project will move forward without your
approval. If you have concerns that we cannot resolve, the DAQ Director may issue an Order prohibiting
construction.
Approval Signature _____________________________________________________________
(Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 1
OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible Official, as
defined in R307-415-3, must sign the statement below. THIS IS STRICTLY OPTIONAL.
If you do not want the Engineer Review to be considered as an application to administratively amend
your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will require
submittal of a separate Operating Permit Application to revise the Title V permit in accordance with
R307-415-5a through 5e and R307-415-7a through 7i. A guidance document: Title V Operating Permit
Application Due Dates clarifies the required due dates for Title V operating permit applications and can
be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality
“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate and
complete and request that this Approval Order be considered as an application to
administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 2
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW
SOURCE INFORMATION
Project Number N141070020
Owner Name The Procter & Gamble Paper Products Company
Mailing Address 5000 North Iowa String Road
Bear River City, UT, 84301

Source Name The Procter & Gamble Paper Products Company
Source Location 5000 North Iowa Road
Bear River City, UT 84301

UTM Projection 402500 m Easting, 4605600 m Northing
UTM Datum NAD27
UTM Zone UTM Zone 12
SIC Code 2621 (Paper Mills)

Source Contact Dean Shepherd
Phone Number [phone]
Email [e-mail]

Billing Contact Seth Garner
Phone Number 435-279-1377
Email [e-mail]

Project Engineer Tad Anderson, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted May 3, 2024
Date of Accepted Application No date entered

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 3
SOURCE DESCRIPTION
General Description
The Procter and Gamble Paper Products Company (P&G) operates the Box Elder Plant. The Box
Elder Plant produces paper and assembled paper products. The Box Elder Plant is located in Bear
River City, Utah.

NSR Classification:
Minor Modification at Major Source
Source Classification
Located in Box Elder County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
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), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities
Title V (Part 70) Major Source
Project Proposal
Minor Modification to Approval Order DAQE-AN141070018-24, for the Addition of a Storage
Tank

Project Description
P&G has requested to add a sodium bisulfate tank. The additional 4,000-gallon Sodium Bisulfite
tank is necessary in its Assembled Paper Products B operations, and P&G has recognized that a
minor amount of SO2 emissions result from the breathing and filling of the tank.

EMISSION IMPACT ANALYSIS
The emission rate for SO2 (0.041 tons per year) does not trigger modeling under R307-410-4. There are no
HAP emissions from these operations, so no modeling is required under R307-410-5. [Last updated July 30,
2024]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 4
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 280301.00
Carbon Monoxide 0 184.81
Nitrogen Oxides 0 138.84
Particulate Matter - PM10 0 164.63
Particulate Matter - PM2.5 0 142.03
Sulfur Oxides 0.05 4.28
Volatile Organic Compounds 0 130.07
Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 13
Acrylamide (CAS #79061) 0 194
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 17
Epichlorohydrin (L-Chloro-2,3-Epoxypropane) (CAS #106898) 0 16
Formaldehyde (CAS #50000) 0 325
Generic HAPs (CAS #GHAPS) 0 1011
Hexane (CAS #110543) 0 6286
Methanol (CAS #67561) 0 18132
Methyl Methacrylate (CAS #80626) 0 82
Propylene[1-Propene] (CAS #115071) 0 646
Toluene (CAS #108883) 0 45
Xylenes (Isomers And Mixture) (CAS #1330207) 0 25
Change (TPY) Total (TPY)
Total HAPs 0 13.29
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 5
Review of BACT for New/Modified Emission Units
1.BACT review regarding BACT/LAER
This project is not subject to UAC R307-403-3(3)a, since the source is major for PM2.5 in an PM2.5
nonattainment area but the project increase is for SO2 so LAER is not required.

Emissions from the sodium bisulfite tanks are 0.041 tons per year of SO2. The emissions from the
tank come from both breathing and working loss from the tank operations. A BACT analysis was
submitted for the addition of the tank which included flue gas desulfurization by scrubbing and
good operating practices.

Flue gas desulfurization by scrubbing is typically used on large combustion units with constant
concentrations and is not designed for the low and intermittent flow from small tanks. Based on
available BACT resources, this technology has not been established as technically feasible for this
application and is therefore not considered further.

BACT to control the 0.041 tons per year of SO2 is good operating practice.
[Last updated July 30, 2024]
SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 6
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]
I.8 The owner/operator shall submit documentation of the status of construction of the 16B paper
machine and natural gas-fired emergency generator to the Director within 18 months from
November 16, 2023. The owner/operator shall submit documentation of the status of
construction of the sodium bisulfite tank to the Director within 18 months from the date of this
AO. This AO may become invalid if construction is not commenced within 18 months from
the date of this AO or if construction is discontinued for 18 months or more. To ensure proper
credit when notifying the Director, send the documentation to the Director, attn.: NSR Section.
[R307-401-18]
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT
II.A.1 The Procter & Gamble-Box Elder Facility
II.A.2 Paper Machine 15B
One (1) Paper Machine
Natural Gas-Fired dryer
Size: 150 MMBTU/hr
Controls: Low NOx burner
Stack Height: 33.53 meters
Stack Diameter: 2.19 meters
Stack Flow rate: 183,335 acfm

Cyclonic Separator (wet-end of process and under machine exhaust)
Venturi Scrubber (dry-end of process) with a PM10 Control Efficiency: approximately 95%*
*Not for determining compliance but for replacement-in-kind.
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 7
II.A.3 Paper Machine 16B
One (1) Paper Machine

Natural Gas-Fired dryer
Size: 130 MMBTU/hr (combined)
Paper Machine Dryer Controls: Ultra-Low NOx burner
Make up Air Units Controls: Low NOx burners

Venturi Scrubber (dry end stack)
Cyclonic Separator (wet-end of process and under machine exhaust)
II.A.4 Paper Product and Utility Boilers
Two (2) Natural Gas-Fired Paper Product Boilers
Maximum Capacity: 60.24 MMBTU/hr (each)
Controls: Low-NOx Burners
Secondary fuel: Propane (emergency or curtailment)

Two (2) Natural Gas-Fired Utility Boilers
Maximum Capacity: 50 MMBTU/hr (each)
Controls: UltraLow-NOx Burners

One (1) Natural Gas Back-Up Boiler (if boilers are out of service)
II.A.5 Paper Product Converting Operation
One (1) Paper Product Converting Operation
PM10 Controls: Three existing (3) Drum Filters -Vent to Atmosphere
Two (2) New Baghouses - Vent Indoors
Five (5) Converting Lines
II.A.6 Assembled Paper Product A Baghouse
One (1) Assembled Paper Product Baghouses
II.A.7 Assembled Paper Product A Drum Filters
Four (4) Assembled Paper Product Drum Filters
II.A.8 Assembled Paper Product A Equipment
Pneumatic Pumps
II.A.9 Assembled Paper Product A Portable Dry Vacuum Unit
II.A.10 Assembled Paper Product B Dryer
Capacity: 10 MMBtu/hr (4-2.5 MMBtu/hr burners)
II.A.11 Assembled Paper Product B Drum Filter System
Drum Filter systems
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 8
II.A.12 Assembled Paper Product B Baghouse/Fabric Filter
Three (3) Baghouses:
1) Briquetter Baghouse
2) Active Ingredient Baghouse
3) Central Vacuum System Baghouse
II.A.13
NEW
Storage Tank (NEW)
Sodium Bisulfite Storage Tank
Capacity: 6,300 gallons
II.A.14 FAM RTO
Burner Size: 2 MMBtu/hr
Control: Low-NOx Burner
Flow Rate: 7,500 scfm
II.A.15 FAM Silo
II.A.16 Assembled Paper Product B Equipment
Pneumatic Pumps
II.A.17 Assembled Paper Product B Inks RTO
Burner Size: 1 MMBtu/hr
Flow Rate: 2,500 scfm
II.A.18 Diesel-Fired Back-Up Engines
Five (5) Emergency Equipment

Two (2) Fire Pumps
Maximum Capacity:375 hp (each)

Two (2) Fire Pumps
Maximum Capacity:399 hp (each)

One (1) Power Generator
Maximum Capacity:1,214 hp
II.A.19 Natural Gas-Fired Back-Up Engines
One (1) Emergency Generator
Capacity: 54 hp (40kW)

One (1) Emergency Generator (NEW)
Capacity: 1006 hp (750kW)
II.A.20 Cooling Towers
Multiple cooling towers with drift eliminators (0.001%) to support the facility.
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 9
II.A.21 Tanks
Multiple tanks including diesel and gasoline fuel storage and various raw material storage
tanks.

40 CFR 60 Subpart Kb is not applicable to these storage tanks based on exemptions listed
under 40 CFR 60.110b(b).
II.A.22 FAM Making Operations Tanks
Capacity: 500-gallons
Material: Sodium Bisulfite

Capacity: 6,000-gallons
Material: Sodium Bisulfite

Capacity: 60-gallons
Material: 25% mixture HCl
II.A.23 Multiple Space Heaters
II.A.24 Truck Loading

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site Wide Requirements
II.B.1.a Visible emissions from the following emission points shall not exceed the following values:
A. All natural gas operated equipment - 10% opacity
B. Cooling towers - 10 % opacity
C. Baghouses - 10% opacity
D. RTO - 10% opacity
E. All other points - 20% opacity. [R307-401]
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 10
II.B.1.a.1 The permittee shall conduct a monthly 1-minute visible emissions test of each affected source
in accordance with 40 CFR 60, Appendix A, Method 22.

If no visible emissions are observed in six consecutive monthly tests for any affected source,
the permittee may decrease the frequency of testing from monthly to semi-annually for the
affected source. If visible emissions are observed during any semi-annual test, the permittee
shall resume testing of that affected source on a monthly basis and maintain that schedule until
no visible emissions are observed for six consecutive monthly tests.

If no visible emissions are observed during two consecutive semi-annual tests for any affected
source, the permittee may decrease the frequency of testing from semi-annually to annually
for the affected source. If visible emissions are observed during any annual test, the permittee
shall resume testing of that affected source on a monthly basis and maintain that schedule until
no visible emissions are observed for six consecutive monthly tests.

If visible emissions are observed during any Method 22 test, a current Method 9 certified
observer shall conduct a:

1) six minute test of opacity in accordance with 40 CFR 60, Appendix A Method 9 for point
sources, or
2) one minute test of opacity with five second observation intervals in accordance with 71 FR
55126, Method 203C for fugitive emission sources
3) the Method 9 or 203C test shall begin within 24 hours of any observation of visible
emission. [R307-401-8]
II.B.1.a.2 Records of visible emission tests performed and data required by 40 CFR 60, Appendix A,
Method 22, Method 9, or 58 FR 61640, Method 203C shall be maintained. [R307-401-8]
II.B.1.b The plant-wide emissions of VOCs and HAPs from the operations shall not exceed:
130.07 tons of VOC emissions per rolling 12-month period
3.14 tons of Hexane per rolling 12-month period
9.07 tons of Methanol per rolling 12-month period. [R307-401-8]
II.B.1.b.1 Compliance with each limitation shall be determined on a rolling 12-month total. Based on the
last day of each month, a new 12-month total shall be calculated using data from the previous
12 months. Monthly calculations shall be made no later than 30 days after the end of each
calendar month. [R307-401-8]
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 11
II.B.1.b.2 VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP
emitting materials used each month if applicable to the product in sections 1, 2, and 3 below
and/or to emission calculations in section 4. The record shall include the following data for
each material used for calculating the rolling 12-month total:

1. Name of the VOC or volatile HAP emitting process material.

2. Percent by weight of all VOC and volatile HAP in each process material used.

3. Quantity of each VOC and volatile HAP emitting process material used in pounds.

4. The amount of VOC and volatile HAP emitted monthly by each process material used,
calculated by the following procedure:

VOC = (% VOC by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000 lb)
Or an Alternative VOC calculation consistent with US EPA emission calculation
methodologies.

HAP = (% HAP by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000lb)
Or an Alternative HAP calculation consistent with US EPA emission calculation
methodologies.

5. The amount of VOC and volatile HAP emitted monthly from all materials used.

6. The amount of VOC and volatile HAP reclaimed for the month shall be similarly quantified
and subtracted from the quantities calculated above, to provide the monthly total VOC and
volatile HAP emissions. [R307-401-8]
II.B.1.c The back-up boiler may only be used during periods when a permitted boiler is taken out of
service. The back-up boiler and the permitted boiler must not be operated at the same time,
except for periods of post-repair readiness checks and initial start-up of the permitted boiler.
The back-up boiler shall only burn natural gas or propane. The back-up boiler capacity shall
not exceed the boiler capacity listed in equipment section of this permit. Emission testing for
the back-up boiler shall not be required and emissions rates shall be guaranteed by vendor
documentation. [R307-401-8]
II.B.1.d The owner/operator shall use natural gas as fuel in all equipment listed in this permit as a
primary fuel and propane as a backup fuel in the boilers (except for listed emergency
equipment which is diesel operated). [R307-401-8]
II.B.2 Paper Making Requirements
II.B.2.a The paper making machines 15B and 16B shall include cyclone separators (installed on the
Under Dryer Stacks and Wet End Stacks) and a venturi scrubber (installed on the Dry End
Stacks) to control PM/PM10/PM2.5 emissions. [R307-401-8]
II.B.2.b The owner/operator shall maintain the pressure drop across the venturi scrubbers at no less
than 4 inches of water gauge when the unit is operating and venting to the atmosphere. [R307-
401-8]
II.B.2.b.1 Monitor the scrubber differential pressure once per operating day. [R307-401-8]
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 12
II.B.2.b.2 Results of daily pressure drop readings shall be maintained. [R307-401-8]
II.B.2.c One drum filter for each of the existing 3 paper making converting lines shall control process
streams from the paper making converting operation when venting to the atmosphere. [R307-
401-8]
II.B.2.d The permittee shall install, calibrate, maintain, and operate a monitoring device for the
continuous measurement of the change in pressure of the gas stream through the paper making
converting room drum filters. The monitoring device must be certified by the
Manufacturer to be accurate within plus or minus one inch of water gauge and must be
calibrated on an annual basis in accordance with the
Manufacturer's instructions. Continuous recording for the monitoring device is not required.
When the paper making converting room drum filters are in operation and venting to the
atmosphere the pressure drop shall be no less than 1 inches water gauge (w.g.) for more than
five minutes in any 60-minute period except during start-up and shut-down of the converting
dust control fans. After a media change the pressure drop will be less than 1.0 inches of water
gauge. The permittee is not restricted to a minimum pressure drop across the control device
for the first 96 consecutive hours after replacement of a filter. This seasoning-in period shall
last no more than 96 hours. [R307-401-8]
II.B.2.d.1 Monitor the drum filter pressure drop once per operating day. [R307-401-8]
II.B.2.d.2 Records of the pressure drop shall be maintained. [R307-401-8]
II.B.2.e The owner/operator shall not exceed 96,360 MMBtu per rolling 12-month total of the 16B
make-up air units. [R307-401-8]
II.B.2.e.1 To determine the operational limitation for the 16B make-up air units, the owner/operator
shall maintain a monthly log tracking the MMBtu per rolling 12-month total. [R307-401-8]
II.B.2.f
NEW
The owner/operator shall not exceed 163,800 gallons of sodium bisulfite per rolling 12-month
in the storage tank. [R307-401-8]
II.B.2.f.1
NEW
To determine the throughput for the sodium bisulfite tank, the owner/operator shall maintain a
monthly log tracking the gallons per rolling 12-month total. [R307-401-8]
II.B.3 Stack Testing Requirements
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 13
II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from the
indicated emissions unit(s):

***Paper Machine 15B Process Stack ***
Pollutant lb/hr lb/MMBTU
PM2.5 6.65 0.044
NOx 13.50 0.09
CO 15.75 0.105

***Paper Machine 16B Process Stack ***
Pollutant lb/hr lb/MMBTU
PM2.5 6.65 0.05115
NOx 3.95 0.03
CO 4.82 0.037

***Paper Making Boilers*** (each)
Pollutant lb/hr ppmdv
PM2.5 0.9 NA
NOx 3.3 45
CO 3.0 70

***Utility Boilers*** (each)
Pollutant lb/hr ppmdv
PM2.5 0.74 NA
NOx 1.80 10
CO 4.06 156. [R307-401-8]
II.B.3.a.1 Initial Test
The owner/operator shall conduct an initial stack test for the Paper Machine 16B Process
Stack within 180 days after startup. [R307-165-2]
II.B.3.a.2 Test Frequency
The owner/operator shall conduct subsequent stack tests for the following emissions units
according to the following schedule. The owner/operator must complete subsequent stack tests
within the indicated time after the date of the most recent stack test for the specified emission
unit.
Test every three years for:
Paper Machine 15B Process Stack
Paper Machine 16B Process Stack
Utility Boilers
Paper Machine Boilers

The Director may require the owner/operator to perform a stack test at any time. [R307-165-2]
II.B.3.a.3 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]
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 14
II.B.3.a.4 Reporting
Within 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]
II.B.3.a.5 PM2.5
Total PM2.5 = Filterable PM2.5 + Condensable PM2.5

Filterable PM2.5
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-
approved testing method as acceptable to the Director. If other approved testing methods are
used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the
filterable particulate emissions shall be considered PM2.5.

Condensable PM2.5
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to
the Director.

Total PM2.5
40 CFR 60.8(b)(2), Appendix A, including EPA-approved testing method OTM 37. [R307-
401-8]
II.B.3.a.6 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]
II.B.3.b CO
40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to
the Director. [R307-401-8]
II.B.4 Assembled Paper Products Requirements
II.B.4.a The emissions from the assembled paper products A and B converting operation shall be
routed to the assembled paper products drum filters and the assembled paper product
baghouses. [R307-401-8]
II.B.4.b The assembled paper product drum filters and the assembled paper product baghouses shall be
operated and maintained in accordance with the Manufacturer's specifications. The drum
filters and baghouses shall be equipped with gauges or meters, which indicates the pressure
drop across the control device. The pressure gauges or meters shall be located such that an
inspector/operator can safely read the indicators at any time. The drum filters and baghouses
while in operation and venting to the atmosphere shall be operated such that the minimum
pressure drop across each control device is greater than or equal to 0.5 inches of water column
except during start-up and shutdown of the fans. The permittee is not restricted to a minimum
pressure drop across the control device for the first 96 hours of operation after replacement of
the filter media on the drum filter or a bag(s) in the baghouse. The operating pressure drop
shall be maintained within the design conditions specified by the Manufacturer's performance
warranty. [R307-401-8]
II.B.4.b.1 The permittee shall monitor the operating pressure drop across each drum filter and each
baghouse once per operating day. [R307-401-8]
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 15
II.B.4.b.2 The permittee shall maintain an operating and maintenance log for each drum filter and each
baghouse along with the Manufacturer's warranty. Records shall be maintained. [R307-401-8]
II.B.5 FAM Operations Requirements
II.B.5.a The emissions from the FAM raw material operational tanks, curing oven, treatment from skid
waste vents shall be routed to the RTO. [R307-401-8]
II.B.5.b The RTO shall be preheated and maintain the Manufacturer recommended temperature for
ideal operation. [R307-401-8]
II.B.5.b.1 The permittee shall monitor and record the RTO's temperatures once per operating day. The
RTO's temperatures shall be maintained within the design conditions specified by the
Manufacturer's performance warranty. The permittee shall maintain an operating and
maintenance log for the RTO's. Continuous recording for the monitoring device is not
required. [R307-401-8]
II.B.6 Emergency Generator Requirements
II.B.6.a The owner/operator shall not operate each diesel-fired backup 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. [R307-401-8]
II.B.6.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 each diesel-fired backup engine shall be kept in a log
and shall include the following:

A. The date and time the diesel-fired backup engine was used
B. The duration of operation in hours
C. The reason for diesel-fired backup engine usage. [R307-401-8]
II.B.6.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each diesel-fired backup engine. [R307-401-8]
II.B.6.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each diesel-fired backup engine. [R307-401-8]
II.B.6.b.1 The owner/operator shall only combust diesel fuel that meets a sulfur content of 15 ppm or
less. [R307-401-8]
II.B.6.b.2 To demonstrate compliance with the 15 ppm requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate the diesel fuel requirements.
[R307-401-8]

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July 30, 2024
Page 16
PERMIT HISTORY
When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Is Derived From NOI dated April 26, 2024
Supersedes DAQE-AN141070018-23 dated November 16, 2023
REVIEWER COMMENTS
1.Comment regarding Emission Estimates:
Emissions from the sodium bisulfite tank are estimated using equations from the Environmental
Protection Agency's, Air Emissions Inventory Improvement Program, Technical Report Series,
Volume II3. Section 2.2.4 of Chapter 16 states that the two significant types of losses from storage
tanks are breathing loss and working loss. Breathing loss is "the expulsion of vapor from a tank
through vapor expansion and contraction that result from changes in ambient temperature and
barometric pressure." Working loss is defined as "the combined loss from filling and emptying
tanks." The tank is estimated to be filled 26 times per year with a throughput of 163,800 gallons per
year. [Last updated July 30, 2024]

2.Comment regarding Netting Analysis:
The P&G, Box Elder Facility is an existing major source for nonattainment (PM2.5) new source
review. To determine if the project is classified as a major modification, the project must result in a
significant emissions increase, and a significant net emissions increase (40 CFR 51.165(a)(1)(v)(A)).
The addition of the storage tank has a 0.041 tons per year increase of SO2 which does not does not
result in a significant net emissions increase because the net emissions increase from both projects is
less than significant emissions rates (40 tons per year). [Last updated July 30, 2024]

3.Comment regarding Project Classification:
Box Elder County is in attainment for CO, NO2, PM10, SO2, Ozone, and Lead. The major source
threshold for PSD is 250 tons per year per pollutant. The Box Elder Facility site-wide emissions per
pollutants in attainment are less than 250 tons per year. The Box Elder Plant and the proposed
modification is not subject to the PSD program.

The P&G, Box Elder facility is an existing major source for nonattainment (PM2.5) new source
review. If a major source undergoes a modification which requires a physical change or change in
operation, the facility must determine whether the project will be considered a major modification.
To determine project is classified as a major modification, the project must result in a significant
emissions increase, and a significant net emissions increase. This project has a SO2 emissions
increase of 0.041 tons per year which is below the 40 tons per year of SO2 threshold limit for
significant. This project is classified as a minor modification at a major source.
[Last updated July 30, 2024]

5.Comment regarding Offsets:
This project is not classified as a major modification in a nonattainment area for PM2.5 and is not
subject to UAC R307-403-3(3) c and d. No offsets are required for this permit modification. [Last
updated July 30, 2024]

Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 17
7.Comment regarding PM2.5 SIP Source:
The Box Elder Facility is a listed major source with conditions in Part H.12.n of the PM2.5 Serious
Nonattainment SIP. The PM2.5 Serious Nonattainment SIP has been approved by the Air Quality
Board, but has not been approved by Region 8 EPA. The PM2.5 Serious Nonattainment SIP
conditions have been incorporated into the current AO. Once the AO has been signed by the director
appropriate actions will be conducted to fulfil state obligations for this modification. [Last updated
April 29, 2024]
Engineer Review N141070020: The Procter & Gamble Paper Products Company
July 30, 2024
Page 18
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds
UTAH DIVISION OF AIR QUALITY – NOTICE OF INTENT
The Procter and Gamble Paper Products Company, Box Elder, Utah
Modification of Approval Order DAQE-AN141070018-23
Prepared By:
TRINITY CONSULTANTS
4525 Wasatch Boulevard
Suite 200
Salt Lake City, Utah 84104
[phone]
Submitted on Behalf of:
5000 Iowa String Road
Bear River City, UT 84301
March 2024
Procter and Gamble Paper Products Company / Abbreviated NOI Air Permit Application
Trinity Consultants i

TABLE OF CONTENTS
1. INTRODUCTION 1-1
2. GENERAL INFORMATION 2-1
2.1 Source Identification Summary ............................................................................... 2-1
2.2 Source Information and General Location ................................................................ 2-1
2.3 Source Size Determination ....................................................................................... 2-1
2.4 Notice of Intent Forms ............................................................................................. 2-1
2.5 Notice of Intent Fees ............................................................................................... 2-2
3. DESCRIPTION OF PROCESS AND PROJECT CHANGE 3-1
3.1 Description of Project .............................................................................................. 3-1
3.2 Description of Process ............................................................................................. 3-1
3.3 Consideration of Contemporaneous Period .............................................................. 3-1
4. EMISSIONS RELATED INFORMATION 4-3

5. BEST AVAILABLE CONTROL TECHNOLOGIES (BACT) 5-1
5.1 SO2 Emissions from Sodium Bisulfite Tank .................................................................. 5-1

6. EMISSION IMPACT ANALYSIS 6-1
6.1 Comparison of Site-Wide Emissions ......................................................................... 6-1
6.2 Offset Requirements ................................................................................................ 6-1
7. APPLICABLE REQUIREMENTS 7-1
7.1 Utah Regulations ..................................................................................................... 7-1

7.2 Federal Rules: New Source Performance Standards ................................................. 7-5
APPENDIX A. FORMS A-1
APPENDIX B. EMISSION CALCULATIONS B-1

1. INTRODUCTION
The Procter and Gamble Paper Products Company (P&G) operates a paper products manufacturing plant in
Box Elder, Utah (i.e., Box Elder Plant). Box Elder County is currently classified as an attainment area for all
criteria pollutants with the exception of particulate matter less than 2.5 microns in diameter (PM2.5). As a
result, the Utah Division of Air Quality (UDAQ) closely monitors permitting of new emissions of PM2.5 as well
as its precursors: sulfur dioxide (SO2), nitrogen oxides (NOx), ammonia, and VOCs. Particularly from sources
classified as major sources of air quality emissions, such as the Box Elder Plant. Currently, the facility is
permitted in accordance with Approval Order No. DAQE-AN141070018-23 and Title V operating permit
300053003.
The Box Elder Plant has determined that an additional 4,000-gallon Sodium Bisulfite tank is necessary in its
Assembled Paper Products B operations, and it has recognized that a minor amount of SO2 emissions result
from the breathing and filling of the tank. P&G is requesting that this source be permitted to ensure the
permit contains a complete list of equipment and is easy for an inspector to review. This NOI defines the
tank operations and the character of those emissions requiring an increase to the Box Elder Facility’s PTE.
This NOI air quality application is being submitted in accordance with the Utah Division of Air Quality
(UDAQ) rules, Utah Administrative Code (UAC) R307-401, and includes the following supporting
documentation required to modify DAQE-AN141070018-23 and obtain authorization for the changes
specified above:

UDAQ NOI Application Forms;
Source Size Determination;
Process Description;
Project Change Description;
Emission Impact Analysis;
Utah BACT Analysis; and,
Regulatory Applicability Analysis.

Procter and Gamble Paper Products Company / Abbreviated NOI Air Permit Application
Trinity Consultants 2-1

2. GENERAL INFORMATION
2.1 Source Identification Summary
Company Name: The Procter and Gamble Paper Products Company
Address: 5000 North Iowa String Road, Bear River City, UT
County: Box Elder County
UTM Coordinates: Easting: 402,500 m, Northing: 4,605,600 m, Zone 12
Primary SIC Code: 2676 (Sanitary Paper Products)
Area Designation: Serious Nonattainment for PM2.5
Source Size Determination: Major Source: Title V operating permit 300053003
Current AO: DAQE-AN141070018-23

All correspondence regarding this submission should be addressed to:
Dean Shepherd
Site Environmental Leader
P&G Paper Products - Box Elder Site
Office: 435-279-1377
Cell: 801-710-7716
[e-mail]

2.2 Source Information and General Location
P&G operates a paper product manufacturing plant in Box Elder County which is a nonattainment area for
PM2.5. The plant is comprised of three primary business units manufacturing consumer products for Paper
Making, Assembled Paper Products A and Assembled Paper Products B. Support equipment includes storage
tanks, emergency generators, boilers and cooling towers.
2.3 Source Size Determination
The proposed site-wide potential emissions are summarized in Table 6-1; this table contains the information
required in UDAQ Form 1a. As presented in the previous section, site-wide emissions are greater than the
major source threshold (MST) for PM2.5, NOx, and VOCs. As such, P&G is classified as a Major Source. The
proposed addition of the Sodium Bisulfite tank with submittal of this Abbreviated NOI air permit will be a
minor modification to an existing major source under New Source Review (NSR).
2.4 Notice of Intent Forms
The following UDAQ forms have been included with the NOI application:

Form 1 – Notice of Intent Application Checklist;
Form 2 – Company Information/Notice of Intent (NOI);
Form 4 – Project Information; and
Form 5 – Emission Information.
Procter and Gamble Paper Products Company / Abbreviated NOI Air Permit Application
Trinity Consultants 2-2

2.5 Notice of Intent Fees
P&G will use the UDAQ’s Payment Portal to prepay the following UDAQ NOI fees associated with this
submittal:

“Application Filing Fee” for the “New Minor Source or Minor Modification at Minor or Major Source” category
= $500
“Application Review Fee” for the “New Minor Source or Minor Modification at Minor or Major Source”
category in maintenance or non-attainment areas = $2,300

Total UDAQ fees = $2,800

P&G understands that the total permit review fee is based on the total actual time spent by UDAQ staff
processing this NOI. Upon issuance of the AO, if the total review time is more than 20 standard hours,
UDAQ will invoice P&G at $115 per hour for the additional time above 20 standard hours.

Procter and Gamble Paper Products Company / Abbreviated NOI Air Permit Application
Trinity Consultants 3-1

3. DESCRIPTION OF PROCESS AND PROJECT CHANGE
3.1 Description of Project
The Box Elder Plant is seeking to add an additional 4,000-gallon Sodium Bisulfite tank to its Assembled
Paper Products B operations.
3.2 Description of Process
Water removed through mechanical dewatering on the FAM product is pretreated prior to disposal with the
local Publicly Owned Treatment Works (POTW). Specifically, sodium bisulfite is added to the wastewater to
dechlorinate the water through the following chemical reaction:

+++

A small amount of SO2 emissions will be generated from the storage and use of sodium bisulfite in this
process. To be consistent with the submitted NOI, P&G has assumed that all breathing and working losses
from the proposed 4,000-gallon bisulfite tanks are pure SO2.
3.3 Consideration of Contemporaneous Period
The Box Elder Plant had a major modification approved by UDAQ for the permitting of paper machine 16B
on November 16, 2023. The addition of a sodium bisulfite tank is anticipated to be installed during the
contemporaneous period for the major modification (i.e., within 5 years of regular operation). , as a result,
the SO2 emissions associated with the one (1) 4,000-gallon sodium bisulfite tank will need to be considered
in the net emissions increase of the Actual to Projected Actuals (ATPAs) calculated from the baseline
established for the major modification.1 The net emissions increase has been demonstrated in Table 3-2
and P&G has determined that the inclusion of the sodium bisulfite tank project does not result in a
significant net emissions increase because the net emissions increase from both projects is less than
significant emissions rates (SERs).2 As a result, this application represents a minor modification to the Box
Elder Plant applicable to UDAQ’s minor New Source Review (NSR) program.

1 40 CFR 52.21(b)(41)
2 40 CFR 52.21(b)(3)(i)(b)

Procter and Gamble Paper Products Company / Abbreviated NOI Air Permit Application
Trinity Consultants 3-2

Table 3-2. Actual to Projected Actual

Pollutant
tons per year
(tpy)
SO2
New Source - Sodium Bisulfite Tank (4,000 gal)
A. Baseline Actual Emissions 0
B. Potential Emissions 0.041
C. Emissions Increase (C = B - A) 0.041

Application for 16B SO2 Sources
A. Baseline Actual Emissions 0.66
B. Potential Emissions 0.74
C. Emissions Increase (C = B - A) 0.08
Project Emissions Increase 0.12
PSD/NNSR SER1 40
Greater than PSD/NNSR SER? No
% of Threshold 0%

Procter and Gamble Paper Products Company / Abbreviated NOI Air Permit Application
Trinity Consultants 4-3

4. EMISSIONS RELATED INFORMATION
P&G is proposing to install one (1) 4,000 gallon sodium bisulfite tank. It is assumed that this tank
exclusively emits SO2.

4.1 Sodium Bisulfite Tanks
Emissions from the sodium bisulfite tanks are estimated using equations from the Environmental Protection
Agency’s (EPA) Air Emissions Inventory Improvement Program (EIIP) Technical Report Series, Volume II3.
Section 2.2.4 of Chapter 16 states that the two significant types of losses from storage tanks are breathing
loss and working loss. Breathing loss is “the expulsion of vapor from a tank through vapor expansion and
contraction that result from changes in ambient temperature and barometric pressure.” Working loss is
defined as “the combined loss from filling and emptying tanks.” Thus, the emissions from the tanks can be
defined as the following:
=+

Where:
ET = Total emissions (tpy)
Eb = Breathing emissions (tpy)
EW = working emissions (tpy)
4.1.1 Breathing Emissions
Breathing emissions from evaporation are calculated using the vaporization rate of a volatile liquid from an
open vessel provided by EIIP Vol. II Chapter 16 equation 3-24. The equation has been modified to adjust
units to tpy.
=× 8,760 × 1
2000
Where:
E = evaporation losses (tpy)
M = molecular weight of the volatile substance
K = mass transfer coefficient
A = area of the evaporation surface area (ft )
P = saturated solvent vapor pressure (psia)
R = ideal gas constant .

T = absolute temperature of the liquid (°R)

The mass transfer coefficient is calculated using EIIP Vol. II Chapter 16 equation 3-27.

K = K × M
M
Where:

3 EIIP Vol II: Chapter 16, Methods for Estimating Air Emissions from Chemical Manufacturing Facilities.

Procter and Gamble Paper Products Company / Abbreviated NOI Air Permit Application
Trinity Consultants 4-4

K = mass transfer coefficient
K = mass transfer coefficient of water
M = molecular weight of water
M = molecular weight of solvent
4.1.2 Working Loss
Working losses in the tank are caused by the displacement of gases inside the tank during filling. The
following equation is used to calculate emissions with the modification of converting to tpy.

E =Being Purged per Fill × 26 × 1
2,000

Procter and Gamble Paper Products Company | Notice of Intent
Trinity Consultants 5-1

5. BEST AVAILABLE CONTROL TECHNOLOGIES (BACT)
In the State of Utah, under R307-401-5(2)(d), Notice of Intent, every facility, operation, or process that
proposes any activity that would emit an air contaminant into the air, must consider BACT for a proposed
new source or modification.4 The below BACT analysis only addresses units which will be modified, installed,
or otherwise addressed in this NOI.

The UDAQ NOI Guide details the requirement to achieve BACT as required in the State of Utah permitting
process. The proposed BACT must be based on the most effective engineering techniques and control
equipment to minimize emission of air contaminants into the outside environment from its process.
5.1 SO2 Emissions from Sodium Bisulfite Tank
Emissions from the sodium bisulfite tanks are minimal, less than 0.05 tpy. The emissions from the tank
come from both breathing and working loss and are vented to the atmosphere.
5.1.1 SO2 Emissions Step 1 & 2 – Identify All Control Technologies and Eliminate
Technically Infeasible Options
SO2 control technologies were identified based on research and extensive historic knowledge of common
control technologies used in similar manufacturing industries. The RBLC database was searched to identify
comparable sources, however, due to such small emissions there were no comparable sources.

In addition to a review of the RBLC, P&G also reviewed BACT statements issued via the following air quality
agencies:

TCEQ; and
BAAQMD.

P&G also researched the EPA Air Pollution Technology Fact Sheets.
After accounting for the physical and operational characteristics of the sodium bisulfite tank, the control
technologies considered in this BACT analysis for controlling SO2 emissions include the following:

Flue Gas Desulfurization by Scrubbing
Good Operating Practices
Flue Gas Desulfurization by Scrubbing
The Flue Gas Desulfurization (FGD) scrubbing process typically uses a calcium or sodium based alkaline
reagent. The reagent is injected into an emissions stream in a spray tower or directly into the duct. The SO2
is absorbed, neutralized, and/or oxidized by the alkaline reagent into a solid compound which is then
removed
from the waste gas stream using downstream equipment. The typical collection efficiency range is from
50% to greater than 98%.5

4 UAC R307-401-4
5 EPA, Air Pollution Control Technology Fact Sheet – Flue Gas Desulfurization (FGD) – Wet, Spray Dry, and Dry Scrubbers.
EPA-452/F-03-034

Procter and Gamble Paper Products Company | Notice of Intent
Trinity Consultants 5-2

FGD is typically used on large combustion units and is not designed for the low and intermittent flow from
small tanks. Based on available BACT resources, this technology has not been established as technically
feasible for this application and is therefore not considered further.
Good Operating Practices
Good Operating Practices includes proper equipment design and proper loading of the tanks during filling.
These will minimize emissions from spills.
5.1.2 SO2 Emissions Step 3-5 – Rank Remaining Control Technologies by Control
Effectiveness, Economic, Environmental, and Energy Impacts of Control
Technologies, and Select BACT
Good Operating Practices is the only remaining control and as such is considered BACT for SO2 emissions
from the sodium bisulfite tank. Good Operating Practices will be followed at P&G.

Procter and Gamble Paper Products Company | Notice of Intent
Trinity Consultants 6-1

6. EMISSION IMPACT ANALYSIS
As shown in Table 6-1, and in the emission calculations in Appendix B, the proposed site-wide emission
change with the addition of the sodium bisulfite at the Box Elder plant results in a 0.041 tpy increase of SO2.
There are no other changes to site wide emissions proposed with this NOI. Because this is not a significant
increase, the UDAQ modeling thresholds contained in UAC R307-410-4 do not apply, and no criteria
pollutant modeling analysis is required.
6-1. Emissions Summary
Business Unit/Process Potential to Emit (tpy)
PM10 PM2.5 VOC HAPs NOX CO SO2 GHGs (CO2e)
Current PTE with 16B1 164.63 142.03 130.07 13.29 138.84 184.81 4.23 280,301
4,000 gal Sodium Bisulfite Tank -- -- -- -- -- -- 0.04 --
Proposed PTE 164.63 142.03 130.07 13.29 138.84 184.81 4.27 280,301
1. Current PTE per Approval Order DAQE-AN141070018-23.

6.1 Comparison of Site-Wide Emissions
The proposed site-wide total emissions represent a minimal increase in SO2; therefore, P&G will not be
required to obtain offsets and will remain a major source.
6.2 Offset Requirements
The UDAQ offset requirements recorded in R307-403, R307-420-3 and R307-421-3 are not applicable to the
proposed modifications with this NOI because proposed emission increases are less than the significant
emission rates documented in R307-420-3 and R307-421-3.

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7. APPLICABLE REQUIREMENTS
7.1 Utah Regulations
P&G has evaluated the applicability of each rule under the Utah Administrative Code (UAC) Title R307. Rules
generally applicable to P&G but not affected by this project have not been addressed.
Table 8-1. Evaluation of UDAQ Air Quality Rules
Reference Regulation Name Applicability
Yes No
R307-101
1 General Requirements X
R307-102 1 General Requirements: Broadly Applicable
Requirements X
R307-103 Administrative Procedures X
R307-104 Conflict of Interest X
R307-105 1 General Requirements: Emergency controls X
R307-107 1 General Requirements: Breakdowns X
R307-110 1 General Requirements: State Implementation
Plan X
R307-115 General Conformity X
R307-120 General Requirements: Tax Exemption for Air
Pollution Control Equipment X
R307-121 General Requirements: Clean Air and Efficient
Vehicle Tax Credit X
R307-122 General Requirements: Heavy Duty Vehicle Tax
Credit X
R307-123 General Requirements: Clean Fuels and Vehicle
Technology Grant and Loan Program X
R307-124 General Requirements: Conversion to Alternative
Fuel Grant Program X
R307-125 Clean Air Retrofit, Replacement, and Off-Road
Technology Program X
R307-130 General Penalty Policy X
R307-135 Enforcement Policy for Asbestos Hazard
Emergency Response Act X
R307-150
1 Emission Inventories X
R307-165 1 Emission Testing X
R307-170 Continuous Emission Monitoring Program X
R307-201 Emission Standards: General Emission Standards X
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Reference Regulation Name Applicability
Yes No
R307-202 Emission Standards: General Burning X
R307-203 1 Emission Standards: Sulfur Content of Fuels X
R307-204 Emission Standards: Smoke Management X
R307-205 Emission Standards: Fugitive Emissions and
Fugitive Dust X
R307-206 Emission Standards: Abrasive Blasting X
R307-207 Residential Fireplaces and Solid Fuel Burning
Devices X
R307-208 Outdoor Wood Boilers X
R307-210 1 Standards of Performance for New Stationary
Sources X
R307-214 1 National Emission Standards for Hazardous Air
Pollutants X
R307-220 Emission Standards: Plan for Designated
Facilities X
R307-221 Emission Standards: Emission Controls for
Existing Municipal Solid Waste Landfills X
R307-222 Emission Standards: Existing incinerator for
Hospital, Medical, Infectious Waste X
R307-223 Emission Standards: Existing Small Municipal
Waste Combustion Units X
R307-224 Mercury Emission Standards: Coal Fired Electric
Generating Units X
R307-230 NOX Emission Limits for Natural Gas-Fired Water
Heaters X
R307-250 Western Backstop Sulfur Dioxide Trading
Program X
R307-301 Utah and Weber Counties: Oxygenated Gasoline
Program as a Contingency Measure X
R307-302 Solid Fuel Burning Devices X
R307-303 Commercial Cooking X
R307-304 1 Solvent Cleaning X
R307-305 Nonattainment and Maintenance Areas for PM10:
Emission Standards X
R307-306 PM10 Nonattainment and Maintenance Areas:
Abrasive Blasting X
R307-307 1 Road Salting and Sanding X
R307-309 1 Nonattainment and Maintenance Areas for PM10
and PM2.5: Fugitive Emissions and Fugitive Dust X
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Reference Regulation Name Applicability
Yes No
R307-310 Salt Lake County: Trading of Emission Budgets
for Transportation Conformity X
R307-311 Utah County: Trading of Emission Budgets for
Transportation Conformity X
R307-312 Aggregate Processing Operations for PM2.5
Nonattainment Areas X
R307-320 Ozone Maintenance Areas and Ogden City:
Employer Based Trip Reduction X
R307-325 Ozone Nonattainment and Maintenance Areas:
General Requirements X
R307-326
Ozone Nonattainment and Maintenance Areas:
Control of Hydrocarbon Emissions in Petroleum
Refineries
X
R307-327 Ozone Nonattainment and Maintenance Areas:
Petroleum Liquid Storage X
R307-328 Gasoline Transfer and Storage X
R307-335 Degreasing X
R307-341 Ozone Nonattainment and Maintenance Areas:
Cutback Asphalt X
R307-342 1 Adhesives and Sealants X
R307-343 Wood Furniture Manufacturing Operations X
R307-344 Paper, Film, and Foil Coatings X
R307-345 Fabric and Vinyl Coatings X
R307-346 Metal Furniture Surface Coatings X
R307-347 Large Applicable Surface Coatings X
R307-348 Magnet Wire Coatings X
R307-349 Flat Wood Panel Coating X
R307-350 Misc. Metal Parts and Product Coating X
R307-351 Graphic Arts X
R307-352 Metal Container, Closure, and Coil Coatings X
R307-353 Plastic Parts Coatings X
R307-354 Automotive Refinishing Coatings X
R307-355 Aerospace Manufacture and Rework Facilities X
R307-356 Appliance Pilot Light X
R307-357 Consumer Products X
R307-361 1 Architectural Coatings X
R307-401 Permit: New and Modified Sources X
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Reference Regulation Name Applicability
Yes No
R307-403 Permits: New and Modified Sources in
Nonattainment and Maintenance Areas X
R307-405 Permits: Major Sources in Attainment or
Unclassified Areas (PSD) X
R307-406 Visibility X
R307-410 Permits: Emission Impact Analysis X
R307-414 Permits: Fees for Approval Orders X
R307-415 Permits: Operating Permit Requirements X
R307-417 Permits: Acid Rain Sources X
R307-420 Permits: Ozone Offset Requirements in Salt Lake
County and Utah County X
R307-421 Permits: PM10 Offset Requirements in Salt Lake
County and Utah County X
R307-424 Permits: Mercury Requirements for Electric
Generating Units X
R307-501 to
505 Oil and Gas Industry X
R307-801 Utah Asbestos Rule X
R307-840 1 Lead-Based Paint Program Purpose, Applicability,
and Definitions X
R307-841 Residential Property and Child-Occupied Facility
Renovation X
R307-842 Lead-Based Paint Activities X
1. The subject rule is applicable to the P&G’s operations; however, is not associated with changes described inthis Abbreviated NOI application and is not addressed in the subsequent sections.
7.1.1 UAC R307-101. General Requirements Foreword
P&G complies with Condition I.1 of the currently issued AO and with the definitions, terms, abbreviations,
and references issued therein which conform to those used in the UAC R307-101 and 40 CFR.
7.1.2 UAC R307-410. Emission Impact Analysis
Emission impacts associated with the Box Elder Plant are addressed in Section 6 of this submittal.
7.1.3 UAC R307-414 Permits: Fees for Approval Orders:
Fees associated with the submission of this Abbreviated NOI air permit application are addressed in Section
2 of this submittal.
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7.2 Federal Rules: New Source Performance Standards
New Source Performance Standards (NSPS) require new, modified, or reconstructed sources to control
emissions to the level achievable by the best demonstrated technology as specified in the applicable
provisions. Any source subject to an NSPS is also subject to the general provisions of NSPS Subpart A,
except as specified by rule. There are no NSPS that apply to the proposed changes.
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APPENDIX A. FORMS
Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number
2. Company contact (Name, mailing address, and telephone number)
3. Name and contact of person submitting NOI application (if different than 2)
4. Source Universal Transverse Mercator (UTM) coordinates
5. Source Standard Industrial Classification (SIC) code
6. Area designation (attainment, maintenance, or nonattainment)
7. Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8. Source size determination (Major, Minor, PSD)
9. Current Approval Order(s) and/or Title V Permit numbers
NOI Application Information:[R307-401]
N/A
N/A
A. Air quality analysis (air model, met data, background data, source impact analysis) N/A
Detailed description of the project and source process
Discussion of fuels, raw materials, and products consumed/produced
Description of equipment used in the process and operating schedule
Description of changes to the process, production rates, etc.
Site plan of source with building dimensions, stack parameters, etc.
Best Available Control Technology (BACT) Analysis [R307-401-8]
BACT analysis for all new and modified equipment
Emissions Related Information: [R307-401-2(b)]
Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)
References/assumptions, SDS, for each calculation and pollutant
All speciated HAP emissions (list in lbs/hr)
Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
Alternative site analysis, Major source ownership compliance certification
Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
Visibility impact analysis, Class I area impact N/A
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data -For Modification/Amendment ONLY
1. Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2. Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3. Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4. Does new emission unit affect existing
permitted process limits?
Yes No
5. Condition(s) Changing:
6. Description of Permit/Process Change**
7. New or modified materials and quantities used in process. **
Material Quantity Annually
8. New or modified process emitting units **
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
Page 1 of 1
Company___________________________
_____________________________
Form
Emissions Information
Criteria/GHGs/
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants**(**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
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APPENDIX B. EMISSION CALCULATIONS
Facility Wide Emissions Calculations
Table 1. Sulfur Emissions from Storage and Filling of Sodium Bisulfite Tank 3
Parameter Value Unit
4,000 gal
15141.6471 L
Temperature 77 °F
Molecular Weight of Sodium Bisulfite 104.06 Ib/Ib-mol
10 mmHg
0.193 psia
Vent Exposed Area 0.04 ft²
0.46 cm/sec
54.62 ft/hr
Constant Evaportation Emission Estimate4 0.01 lb/hr
Headspace of NaBiS Storage Tank1 15873.0 ppm
Air being Purged1 16731.5 g
SO2 Being Purged per Fill 0.586 lb/fill
Total SO2 Emission Estimate6 0.041 tpy
1. General Parameters for Salt Lake City Utah (https://www.timeanddate.com/weather/usa/salt-lake-city/climate)
Density of Air: 1.105 (g/L)
Average Atmospheric Pressure: 630 (mmHg)
2. Vapor pressure found using Southern Ionics Table for Sodium Bisulfite Solution Vapor Pressure vs Temperature, assuming 40% NaHSO3 solution, pH=4.
3. Calculated using equation 3-27 from EIIP Vol.II: Chapter 16 and H2O mass transfer coefficient.
Where,
KH2O=0.83 Mass transfer coefficient of H2O (cm/sec)
MH2O=18 MW of H2O (Ib/Ib-mol)
4. Calculated using equation 3-24 from EIIP Vol.II: Chapter 16
Where,
R= 10.731 Gas constant (psi-ft3)/(Ib-mol-°R)
TL=536.67 Temperature of the liquid (°R)
5. Assumes tank is filled once every two weeks
26 (fills/year)
7. Conversion factors:
3600 (sec/hr)
6. Total emission estimates assume that the tanks are filled once every two weeks and
never twice in the same hour.
Totals
Saturated Solvent Vapor Pressure (psi)2
Vent opening (constant evaporation)
Mass Transfer Coefficient2,3, &7
Filling Operation
General Parameters
Size of Tank
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