DAQ-2025-000687

DAQE-AN162330001-25

{{$d1 }}

Kirk Arens
Utah Flour Milling LLC
730 17th Street, Suite 600
Denver, CO 80202
[e-mail]

Dear Mr. Arens:

Re: Approval Order: New Richmond Flour Mill
Project Number: N162330001

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August
21, 2024. Utah Flour Milling LLC must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Dungan Adams, who can be contacted at [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:DA:jg

cc: Bear River Health Department

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
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

January 31, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN162330001-25
New Richmond Flour Mill

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
Utah Flour Milling LLC - Richmond Flour Mill

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

January 31, 2025
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-AN162330001-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Utah Flour Milling LLC Utah Flour Milling LLC - Richmond Flour Mill

Mailing Address Physical Address
730 17th Street, Suite 600 11595 North US 91 Highway
Denver, CO 80202 Richmond, UT 84333

Source Contact UTM Coordinates
Name: Kirk Arens 432,439 m Easting
Phone: [phone],643,738 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2041 (Flour & Other Grain Mill Products)

SOURCE INFORMATION
General Description
Utah Flour Milling LLC (Utah Flour) has requested an AO for a new flour mill located in Richmond,
Cache County. Raw wheat will be received at the facility by truck and rail and conveyed to storage bins.
The raw wheat will then be processed into flour through cleaning, tempering, and milling operations.
Whole wheat will be produced through hammer milling. Animal feed will be produced as a byproduct.
The flour, whole wheat, and animal feed will be kept in storage bins until loadout. Particulate matter
emissions at the facility will be controlled using baghouses, cyclones, dust filters, and bin vents. The
facility will be powered exclusively by line power.

NSR Classification
New Minor Source

Source Classification
Located in Attainment Area
Cache County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), DD: Standards of Performance for Grain Elevators
Title V (Part 70) Area Source
DAQE-AN162330001-25
Page 4

Project Description
The facility will operate eight (8) baghouses to control particulate emissions from grain receiving,
handling, cleaning, tempering, milling, and flour loadout. Parallel cyclones will also be used to filter
larger particles from the cleaning and milling processes. Flour, whole wheat, and feed storage bins will be
controlled with bin vent filters. Dust filters will be used to control the hammer mill and the truck and
packaging loadouts.

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 0.00
Carbon Monoxide 0.00
Nitrogen Oxides 0.00
Particulate Matter - PM10 9.85
Particulate Matter - PM2.5 5.06
Sulfur Dioxide 0.00
Volatile Organic Compounds 0.00

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0
Change (TPY) Total (TPY)
Total HAPs 0.00

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]
DAQE-AN162330001-25
Page 5

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 or modification 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
II.A THE APPROVED EQUIPMENT
II.A.1 Richmond Flour Mill II.A.2 One (1) Grain Receiving and Handling Baghouse Exhaust Flow Rate: 10,000 acfm
II.A.3 One (1) Grain Cleaning Baghouse Exhaust Flow Rate: 16,046 acfm II.A.4 One (1) Grain Tempering Baghouse Exhaust Flow Rate: 3,527 acfm
II.A.5 Three (3) Grain Milling Baghouses Exhaust Flow Rate: 12,867 acfm each Operated in parallel II.A.6 Two (2) Plansifter Baghouses Exhaust Flow Rate: Variable
II.A.7 Three (3) Grain Cleaning Cyclones Operated in parallel before the Grain Cleaning Baghouse II.A.8 Three (3) Grain Milling Cyclones Operated in parallel before the Grain Milling Baghouses
II.A.9 One (1) Hammer Mill Dust Filter
DAQE-AN162330001-25
Page 6

II.A.10 Two (2) Flour/Whole Wheat Loadout Dust Filters Controls truck and packaging loadouts II.A.11 Twelve (12) Grain Elevator Bins
II.A.12 Twelve (12) Grain Storage Bins II.A.13 Nine (9) Flour/Whole Wheat Storage Bins Each controlled with bin vent

II.A.14 One (1) Feed Storage Bin Controlled with bin vent

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All baghouse exhaust stacks - 10% opacity B. All dust filters - 7% opacity C. All bin vents - 7% opacity D. Flour loadout by rail - 5% opacity E. Feed loadout by truck - 10% opacity F. All other points - 20% opacity. [40 CFR 60 Subpart DD, R307-205-4, R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]
II.B.1.b The owner/operator shall pave all haul roads at the facility. [R307-401-8]
II.B.1.c The owner/operator shall only use line power to provide electricity to stationary equipment at the
facility. [R307-401-8]
II.B.2 Production Requirements
II.B.2.a The owner/operator shall not store more than 240,000 tons of raw wheat per rolling 12-month period. [R307-401-8]
II.B.2.b The owner/operator shall not produce more than 174,000 tons of processed flour and whole wheat combined per rolling 12-month period. [R307-401-8]
II.B.2.c The owner/operator shall not load out more than 60,000 tons per year of processed flour and
whole wheat combined per rolling 12-month period from the rail loadout, the truck loadout, or the packaging loadout. [R307-401-8]
DAQE-AN162330001-25
Page 7

II.B.2.d The owner/operator shall not produce more than 64,200 tons of feed by-product per rolling 12-month period. [R307-401-8] II.B.2.e To determine compliance with conditions II.B.2.a through II.B.2.d, the owner/operator shall:
A. Determine production for each process with equipment scales B. Record production for each process on a daily basis
C. Use the production data to calculate a new rolling 12-month total for each process by the 20th day of each month using data from the previous 12 months
D. Keep production records for each process for all periods the plant is in production.
[R307-401-8]
II.B.3 Baghouse Requirements
II.B.3.a The owner/operator shall install one (1) baghouse to control particulate emissions from each of
the following activities and equipment: grain receiving and handling, grain cleaning, grain tempering, and each plansifter. Each baghouse shall meet a particulate matter emission rate of
0.01 gr/dscf. [R307-401-8]

II.B.3.a.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emission guarantee for each baghouse. The records shall be kept for the life of each baghouse. [R307-401-8] II.B.3.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across the baghouse. [R307-401-8]

II.B.3.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8]
II.B.3.b.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8]

II.B.3.c During operation of the baghouse, the owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for normal operations. [R307-401-8]
II.B.3.c.1 The owner/operator shall record the pressure drop at least once per operating day while the
baghouse is operating. [R307-401-8]
II.B.3.c.2 The owner/operator shall maintain the following records of the pressure drop readings: A. Unit identification B. Manufacturer recommended static pressure drop for the unit C. Date of reading D. Daily static pressure drop readings. [R307-401-8]
II.B.3.d At least once every 12 months, the owner/operator shall calibrate the pressure gauges in
accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]

DAQE-AN162330001-25
Page 8

II.B.3.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] II.B.4 Grain Milling Baghouse Stack Testing Requirements
II.B.4.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.4.a.1 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8]

II.B.4.a.2 Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.4.a.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]

II.B.4.a.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.4.a.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]
II.B.4.a.6 Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
II.B.4.b Standard Conditions
A. Temperature - 68 degrees Fahrenheit (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method.
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.4.b.1 Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. [R307-401-8]
DAQE-AN162330001-25
Page 9

II.B.4.c The owner/operator shall not emit more than the following rates and concentrations from the Two (2) Grain Milling Baghouse Stacks: Pollutant grains/dscf Filterable PM10 0.01 Filterable PM2.5 0.01 [R307-401-8] II.B.4.c.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8]
II.B.4.c.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]
II.B.4.c.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Is Derived From NOI dated August 21, 2024 Incorporates Additional Information dated October 1, 2024 Incorporates Additional Information dated October 30, 2024 Incorporates Additional Information dated November 6, 2024 Incorporates Additional Information dated November 13, 2024 Incorporates Additional Information dated December 4, 2024 Incorporates Additional Information dated December 11, 2024 Incorporates Additional Information dated December 18, 2024
DAQE-AN162330001-25
Page 10

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-IN162330001-24

December 26, 2024

Kirk Arens
Utah Flour Milling LLC
730 17th Street, Suite 600
Denver, CO 80202
[e-mail]

Dear Mr. Arens:

Re: Intent to Approve: New Richmond Flour Mill
Project Number: N162330001

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, Dungan Adams, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Dungan Adams, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DA:jg

cc: Bear River Health Department

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
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-IN162330001-24
New Richmond Flour Mill

Prepared By
Dungan Adams, Engineer
[phone]
[e-mail]

Issued to
Utah Flour Milling LLC - Richmond Flour Mill

Issued On
December 26, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#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............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-IN162330001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Utah Flour Milling LLC Utah Flour Milling LLC - Richmond Flour Mill

Mailing Address Physical Address
730 17th Street, Suite 600 11595 North US 91 Highway
Denver, CO 80202 Richmond, UT 84333

Source Contact UTM Coordinates
Name: Kirk Arens 432,439 m Easting
Phone: [phone],643,738 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2041 (Flour & Other Grain Mill Products)

SOURCE INFORMATION
General Description
Utah Flour Milling LLC has requested an AO for a new flour mill located in Richmond, Cache County.
Raw wheat will be received at the facility by truck and rail and conveyed to storage bins. The raw wheat
will then be processed into flour through cleaning, tempering, and milling operations. Whole wheat will
be produced through hammer milling. Animal feed will be produced as a byproduct. The flour, whole
wheat, and animal feed will be kept in storage bins until loadout. Particulate matter emissions at the
facility will be controlled using baghouses, cyclones, dust filters, and bin vents. The facility will be
powered exclusively by line power.
NSR Classification
New Minor Source

Source Classification
Located in Attainment Area
Cache County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), DD: Standards of Performance for Grain Elevators
Title V (Part 70) Area Source
DAQE-IN162330001-24
Page 4

Project Description
The facility will operate eight (8) baghouses to control particulate emissions from grain receiving,
handling, cleaning, tempering, milling, and flour loadout. Parallel cyclones will also be used to filter
larger particles from the cleaning and milling processes. Flour, whole wheat, and feed storage bins will be
controlled with bin vent filters. Dust filters will be used to control the hammer mill and the truck and
packaging loadouts.

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 0.00
Carbon Monoxide 0.00
Nitrogen Oxides 0.00
Particulate Matter - PM10 9.85
Particulate Matter - PM2.5 5.06
Sulfur Dioxide 0.00
Volatile Organic Compounds 0.00

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0
Change (TPY) Total (TPY)
Total HAPs 0.00

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 Herald Journal on December 28, 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.

DAQE-IN162330001-24
Page 5

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]
I.8 The owner/operator shall submit documentation of the status of construction or modification 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 Richmond Flour Mill
DAQE-IN162330001-24
Page 6

II.A.2 One (1) Grain Receiving and Handling Baghouse Exhaust Flow Rate: 10,000 acfm II.A.3 One (1) Grain Cleaning Baghouse Exhaust Flow Rate: 16,046 acfm

II.A.4 One (1) Grain Tempering Baghouse Exhaust Flow Rate: 3,527 acfm
II.A.5 Three (3) Grain Milling Baghouses Exhaust Flow Rate: 12,867 acfm each Operated in parallel

II.A.6 Two (2) Plansifter Baghouses Exhaust Flow Rate: Variable
II.A.7 Three (3) Grain Cleaning Cyclones Operated in parallel before the Grain Cleaning Baghouse

II.A.8 Three (3) Grain Milling Cyclones Operated in parallel before the Grain Milling Baghouses
II.A.9 One (1) Hammer Mill Dust Filter

II.A.10 Two (2) Flour/Whole Wheat Loadout Dust Filters Controls truck and packaging loadouts
II.A.11 Twelve (12) Grain Elevator Bins
II.A.12 Twelve (12) Grain Storage Bins
II.A.13 Nine (9) Flour/Whole Wheat Storage Bins Each controlled with bin vent

II.A.14 One (1) Feed Storage Bin Controlled with bin vent

DAQE-IN162330001-24
Page 7

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 The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All baghouse exhaust stacks - 10% opacity B. All dust filters - 7% opacity C. All bin vents - 7% opacity D. Flour loadout by rail - 5% opacity E. Feed loadout by truck - 10% opacity F. All other points - 20% opacity. [40 CFR 60 Subpart DD, R307-205-4, R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3]
II.B.1.b The owner/operator shall pave all haul roads at the facility. [R307-401-8] II.B.1.c The owner/operator shall only use line power to provide electricity to stationary equipment at the facility. [R307-401-8]
II.B.2 Production Requirements II.B.2.a The owner/operator shall not store more than 240,000 tons of raw wheat per rolling 12-month period. [R307-401-8]
II.B.2.b The owner/operator shall not produce more than 174,000 tons of processed flour and whole wheat combined per rolling 12-month period. [R307-401-8] II.B.2.c The owner/operator shall not loadout more than 60,000 tons per year of processed flour and whole wheat combined per rolling 12-month period from the rail loadout, the truck loadout, or the packaging loadout. [R307-401-8]
II.B.2.d The owner/operator shall not produce more than 64,200 tons of feed by-product per rolling 12-month period. [R307-401-8]
DAQE-IN162330001-24
Page 8

II.B.2.e To determine compliance with conditions II.B.2.a through II.B.2.d, the owner/operator shall: A. Determine production for each process with equipment scales B. Record production for each process on a daily basis C. Use the production data to calculate a new rolling 12-month total for each process by the 20th day of each month using data from the previous 12 months D. Keep production records for each process for all periods the plant is in production. [R307-401-8] II.B.3 Baghouse Requirements
II.B.3.a The owner/operator shall install one (1) baghouse to control particulate emissions from each of the following activities and equipment: grain receiving and handling, grain cleaning, grain tempering, and each plansifter. Each baghouse shall meet a particulate matter emission rate of 0.01 gr/dscf. [R307-401-8] II.B.3.a.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's emission guarantee for each baghouse. The records shall be kept for the life
of each baghouse. [R307-401-8]
II.B.3.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure drop across the baghouse. [R307-401-8] II.B.3.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.3.b.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8]
II.B.3.c During operation of the baghouse, the owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for normal operations. [R307-401-8]

II.B.3.c.1 The owner/operator shall record the pressure drop at least once per operating day while the baghouse is operating. [R307-401-8]
II.B.3.c.2 The owner/operator shall maintain the following records of the pressure drop readings:
A. Unit identification

B. Manufacturer recommended static pressure drop for the unit
C. Date of reading

D. Daily static pressure drop readings.

[R307-401-8]

II.B.3.d At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the gauges. [R307-401-8]
II.B.3.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

DAQE-IN162330001-24
Page 9

II.B.4 Grain Milling Baghouse Stack Testing Requirements II.B.4.a The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]
II.B.4.a.1 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.4.a.2 Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]
II.B.4.a.3 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]
II.B.4.a.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]
II.B.4.a.5 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]
II.B.4.a.6 Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.4.b Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.4.b.1 Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10. [R307-401-8]

II.B.4.c The owner/operator shall not emit more than the following rates and concentrations from the Two (2) Grain Milling Baghouse Stacks: Pollutant grains/dscf Filterable PM10 0.01 Filterable PM2.5 0.01 [R307-401-8]
DAQE-IN162330001-24
Page 10

II.B.4.c.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8]
II.B.4.c.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]

II.B.4.c.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated August 21, 2024 Incorporates Additional Information dated October 1, 2024 Incorporates Additional Information dated October 30, 2024 Incorporates Additional Information dated November 6, 2024 Incorporates Additional Information dated November 13, 2024 Incorporates Additional Information dated December 4, 2024 Incorporates Additional Information dated December 11, 2024 Incorporates Additional Information dated December 18, 2024

DAQE-IN162330001-24
Page 11

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

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: Utah Flour Milling LLCLocation: Utah Flour Milling LLC - Richmond Flour Mill – 11595 North US 91 Highway, Richmond, UTProject Description: Utah Flour Milling LLC has requested an Approval Order (AO) for a new flour mill located in Richmond, Cache County. Raw wheat will be received at the facility by truck and rail and conveyed to storage bins. The raw wheat will then be processed into flour through cleaning, tempering, and milling operations. Whole wheat will be produced through hammer milling. Animal feed will be produced as a byproduct. The flour, whole wheat, and animal feed will be kept in storage bins until loadout. The facility will oper ate eight (8) baghouses to control particulate emissions from grain receiving, handling, cleaning, tempering, milling, and flour loadout. Flour, whole wheat, and feed storage bins will be controlled with bin vent filters. Dust filters will be used to control the hammer mill and the truck and packaging loadouts. The facility will be powered exclusively by line power.
The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of fed-eral 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 in-spection 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 27, 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 adjudi-catory 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.Published: December 28th, 2024 (HJ6167-593997)

DAQE-NN162330001-24

December 26, 2024

The Herald Journal
Legal Advertising Dept
1068 W 130 S
Logan, UT 84321

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in The Herald Journal on
December 28, 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: Cache County

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
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-NN162330001-24
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: Utah Flour Milling LLC
Location: Utah Flour Milling LLC - Richmond Flour Mill – 11595 North US 91 Highway,
Richmond, UT
Project Description: Utah Flour Milling LLC has requested an Approval Order (AO) for a new flour
mill located in Richmond, Cache County. Raw wheat will be received at the
facility by truck and rail and conveyed to storage bins. The raw wheat will then
be processed into flour through cleaning, tempering, and milling operations.
Whole wheat will be produced through hammer milling. Animal feed will be
produced as a byproduct. The flour, whole wheat, and animal feed will be kept in
storage bins until loadout. The facility will operate eight (8) baghouses to control
particulate emissions from grain receiving, handling, cleaning, tempering,
milling, and flour loadout. Flour, whole wheat, and feed storage bins will be
controlled with bin vent filters. Dust filters will be used to control the hammer
mill and the truck and packaging loadouts. The facility will be powered
exclusively by line power.

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 27, 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 28, 2024

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

DAQE-

RN162330001 December 18, 2024 Kirk Arens
Utah Flour Milling LLC 730 17th Street, Suite 600 Denver, CO 80202
[e-mail] Dear Kirk Arens,
Re: Engineer Review: New Richmond Flour Mill Project Number: N162330001 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Utah Flour Milling LLC should complete this review within 10 business days of receipt. Utah Flour Milling LLC should contact Dungan Adams at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dungan Adams at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Utah Flour Milling LLC does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Utah Flour Milling LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [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 N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N162330001 Owner Name Utah Flour Milling LLC Mailing Address 730 17th Street, Suite 600
Denver, CO, 80202 Source Name Utah Flour Milling LLC- Richmond Flour Mill
Source Location 11595 North US 91 Highway Richmond, UT 84333
UTM Projection 432,439 m Easting, 4,643,738 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2041 (Flour & Other Grain Mill Products) Source Contact Kirk Arens Phone Number [phone] Email [e-mail] Billing Contact Kirk Arens Phone Number [phone]
Email [e-mail] Project Engineer Dungan Adams, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted August 21, 2024 Date of Accepted Application November 6, 2024

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 2
SOURCE DESCRIPTION General Description
Utah Flour Milling LLC has requested an Approval Order (AO) for a new flour mill located in Richmond, Cache County. Raw wheat will be received at the facility by truck and rail and conveyed to storage bins. The raw wheat will then be processed into flour through cleaning,
tempering, and milling operations. Whole wheat will be produced through hammer milling. Animal feed will be produced as a byproduct. The flour, whole wheat, and animal feed will be kept in storage bins until loadout. Particulate matter emissions at the facility will be controlled using baghouses, cyclones, dust filters, and bin vents. The facility will be powered exclusively by line power. NSR Classification: New Minor Source Source Classification Located in Attainment Area
Cache County Airs Source Size: SM
Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), DD: Standards of Performance for Grain Elevators
Title V (Part 70) Area Source Project Proposal New Richmond Flour Mill Project Description
Utah Flour Milling LLC has requested an Approval Order (AO) for a new flour mill located in Richmond, Cache County. The facility will operate eight (8) baghouses to control particulate emissions from grain receiving, handling, cleaning, tempering, milling, and flour loadout. Parallel cyclones will also be used to filter larger particles from the cleaning and milling processes. Flour, whole wheat, and feed storage bins will be controlled with bin vent filters. Dust filters will be used to control the hammer mill and the truck and packaging loadouts. EMISSION IMPACT ANALYSIS
All criteria pollutants increases are below the modeling thresholds outlined in R307-410-4. This project will not produce any HAP emission increases. Therefore, no modeling is required for this project. [Last updated December 18, 2024]

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 3
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0.00 Carbon Monoxide 0.00
Nitrogen Oxides 0.00
Particulate Matter - PM10 9.85
Particulate Matter - PM2.5 5.06
Sulfur Dioxide 0.00
Volatile Organic Compounds 0.00 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0
Change (TPY) Total (TPY)
Total HAPs 0.00

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding New Flour Mill
Utah Flour Milling, LLC has proposed a new flour mill. The source has indicated that the following operations at the mill will produce particulate emission (PM10 and PM2.5): grain receiving, grain handling, grain storage, grain cleaning, grain tempering, roller milling, hammer
milling, flour/whole wheat storage, flour/whole wheat loadout, feed storage, and feed loadout. Control options for particulate matter emissions from the various operations at the mill include: Total Enclosures (100%) Fabric Filters (99-99.5%)
Electrostatic Precipitators (ESPs) (70-99.5%) Wet Scrubbers (20-99%) Cyclones (10-50%)
Because emitting large amounts of grain and flour product particulate matter inside an enclosed building presents a number of safety concerns, total enclosures are not considered a technically feasible control option. ESPs and Wet Scrubbers tend to have higher capital costs than fabric filters and are not considered because of their lower control efficiency. Several different types of control technology use fabric filters to control particulate, including baghouses, bin vents, and dust filters. Baghouses use many fabric filters and actively push air though the filters. Because of their active and multi-bag design, baghouses are best suited for large, continuous sources of particulate
emissions. Bin vents are passive control technology that are often installed on storage bins or silos to prevent the loss of material and limit particulate emission. Dust filters are smaller control devices that are best suited for smaller sources of particulate emissions. The source has elected to
use a variety of baghouses, cyclones, dust filters, and bin vents to control particulate emissions. [Last updated December 18, 2024]
2. BACT review regarding Grain Receiving and Handling Raw wheat (grain) will be received at the flour mill by truck and rail. The grain will then by transported to storage bins by conveyor. The source has elected to use a baghouse to control emissions from grain receiving and handling. Other flour mills permitted in Utah have been required to meet a visible opacity of 10% or less from baghouses. BACT is to control PM2.5 and PM10 emissions from grain receiving and handling using a baghouse reasonably expected to meet an emission rate of 0.01 gr/dscf. In addition, BACT is to maintain visible emissions from the baghouse at an opacity of 10% or less. [Last updated December 18, 2024] 3. BACT review regarding Storage Bins Storage bins will be used to store grain, flour/whole wheat, and feed. The source has elected to use
bin vents to control particulate emission from the flour/whole wheat storage bins and the feed storage bin. Because the raw wheat (grain) is roughly a quarter inch in width, very little particulate emissions are created from grain storage. The source conservatively estimated 0.76 tons per year
(TPY) of PM10 and 0.13 TPY of PM2.5 would be produced from grain storage. 40 CFR 60 (NSPS) Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants) requires dry control devices to meet a visible opacity limit of 7% or less. While this facility is not subject to
NSPS Subpart OOO, the visible opacity limit is used as a reference value that dry control devices (bin vents, dust filters, etc.) can reasonably meet. BACT for storage bins is to install a bin vent on each flour/whole wheat and feed storage bin and to maintain a visible opacity of 7% or less from all storage bins. [Last updated December 18, 2024]

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 5
4. BACT review regarding Grain Cleaning Before grain can be processed into flour, unwanted particles are removed during grain cleaning to
ensure the final product is high quality. The source has elected to use three (3) cyclones operated in parallel and one (1) baghouse to capture particulate emissions from the cleaning process. The cyclones will capture larger particulate matter before exhausting to the baghouse. BACT is to control PM2.5 and PM10 emissions from grain cleaning using a baghouse reasonably expected to meet an emission rate of 0.01 gr/dscf. In addition, BACT is to maintain visible emissions from the baghouse at an opacity of 10% or less. [Last updated December 18, 2024] 5. BACT review regarding Grain Tempering After the grain is cleaned, moisture is added to the grain through a process called grain tempering. The source has elected to install a baghouse to control PM emissions from the tempering process. BACT is to control PM2.5 and PM10 emissions from grain tempering using a baghouse reasonably
expected to meet an emission rate of 0.01 gr/dscf. In addition, BACT is to maintain visible emissions from the baghouse at an opacity of 10% or less. [Last updated December 18, 2024]
6. BACT review regarding Grain Milling The source operates a roller mill and a hammer mill at the facility. The roller mill grinds the prepared grain into fine flour. The hammer mill produces a smaller amount of whole wheat. Whole
wheat is whole grains of wheat which include the outer layer or husk. The roller milling process produces the majority of the PM emissions at the facility. The source has elected to install three (3) cyclones in parallel and three (3) baghouses in parallel to control particulate emissions from roller milling. The cyclones will capture larger particles before they
exhaust to the baghouses. According to emission estimates provided by the source, the grain milling process has the potential to emit 3,296 tons of PM10 and 560 tons of PM2.5 without control technology or production limitations. Emissions from the three (3) baghouses are ducted into a
plenum before venting to the atmosphere through two (2) stacks. Because the source's classification as a minor source is dependent on the functionality of the three (3) parallel baghouses, BACT is to control PM2.5 and PM10 emissions from the roller milling process using
three (3) baghouses that are certified to meet an emission rate of 0.01 gr/dscf through stack testing. Both stacks are required to meet the 0.01 gr/dscf emission rate. In addition, BACT is to maintain visible emissions from the baghouse stacks at an opacity of 10% or less.
The hammer milling process produces a much smaller amount of PM emissions. The particle size
of the whole wheat is much larger than processes flour. The source has elected to use a dust filter to capture emissions produced from hammer milling. The source has estimated that hammer milling will produce 0.73 TPY of PM10 and 0.13 TPY of PM2.5 when controlled with the dust filter.
Because of the small amount of PM emissions produced by this process, more efficient control technology is not considered economically feasible. BACT is to install a dust filter to capture PM2.5 and PM10 emissions from hammer milling and to maintain visible emissions from the dust filter at
an opacity of 7% or less. [Last updated December 18, 2024] 7. BACT review regarding Flour and Whole Grain Loadout Once the grain is milled into flour, it is sent to storage bins. The flour is sized and graded using two (2) plansifters. The source has elected to capture PM emissions from plansifting using a baghouse for each plansifter. After being sized, flour is sent to four (4) loadouts: truck loadout, rail loadout, packaging loadout, and adjacent facility loadout. The loadout to the adjacent facility does not produce any emissions that are released to the atmosphere. The combined particulate emissions
from the remaining three loadouts are estimated to be 0.45 TPY of PM10 and 0.08 TPY of PM2.5. The source has elected to capture PM emissions from the truck and packing loadouts using dust

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 6
filters. The particulate emissions estimated from rail loadout alone are 0.02 TPY of PM10 and <0.01 TPY of PM2.5. Because of the very small amount of particulate emissions estimated from rail
loadout, control technology is not considered cost effective. Once the whole wheat has been produced at the hammer mill, it is stored and loaded out using the same flour storage and loadout systems. Because the particle size of whole wheat is much larger than flour, less emissions are produced from whole wheat storage and loadout. The source has conservatively estimated that 100% of the storage and loadout is processed flour, however a small amount of the material stored and loaded out will be whole wheat.
BACT is to control PM2.5 and PM10 emissions from each plansifter using a baghouse reasonably expected to meet an emission rate of 0.01 gr/dscf. In addition, BACT is to maintain visible emissions from each baghouse at an opacity of 10% or less. BACT is to install a dust filter to capture PM2.5 and PM10 emissions from the truck and packaging loadouts and to maintain visible
emissions from each dust filter at an opacity of 7% or less. Because the source is subject to 40 CFR 60 Subpart DD - Standards of Performance for Grain Elevators, BACT is also to maintain visible emissions from flour/whole wheat loadout by rail at an opacity of 5%. [Last updated December 18, 2024] 8. BACT review regarding Feed Production, Storage, and Loadout The source will use by-product produced through the grain milling and cleaning processes to make animal feed. Because the feed is produced as a by-product from other emitting operations, there are no direct emissions from feed production. The source has elected to capture emissions from feed storage using a bin vent. Because the feed is made up of much later particles than processed flour, the storage and loadout of the feed produce very little PM2.5 and PM10 emissions. The source has
estimated that storage and loadout will produce 0.10 TPY of PM10 and 0.02 TPY of PM2.5. BACT is to install a bin vent on the feed storage bin and maintain a visible opacity of 7% or less from the bin. Because this source is subject to 40 CFR 60 Subpart DD - Standards of Performance for Grain
Elevators, BACT is also to maintain visible emissions from feed loadout by truck at an opacity of 10% or less. [Last updated December 18, 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]

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 7
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 or modification
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 NEW Richmond Flour Mill
II.A.2
NEW
One (1) Grain Receiving and Handling Baghouse
Exhaust Flow Rate: 10,000 acfm II.A.3 NEW One (1) Grain Cleaning Baghouse Exhaust Flow Rate: 16,046 acfm
II.A.4 NEW One (1) Grain Tempering Baghouse Exhaust Flow Rate: 3,527 acfm

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 8
II.A.5 NEW Three (3) Grain Milling Baghouses Exhaust Flow Rate: 12,867 acfm each Operated in parallel

II.A.6 NEW Two (2) Plansifter Baghouses Exhaust Flow Rate: Variable II.A.7 NEW Three (3) Grain Cleaning Cyclones Operated in parallel before the Grain Cleaning Baghouse

II.A.8 NEW Three (3) Grain Milling Cyclones Operated in parallel before the Grain Milling Baghouses II.A.9 NEW One (1) Hammer Mill Dust Filter
II.A.10
NEW
Two (2) Flour/Whole Wheat Loadout Dust Filters
Controls truck and packaging loadouts II.A.11 NEW Twelve (12) Grain Elevator Bins II.A.12 NEW Twelve (12) Grain Storage Bins
II.A.13
NEW
Nine (9) Flour/Whole Wheat Storage Bins
Each controlled with bin vent II.A.14 NEW One (1) Feed Storage Bin Controlled with bin vent

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 NEW Site-wide Requirements

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 9
II.B.1.a NEW The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All baghouse exhaust stacks - 10% opacity B. All dust filters - 7% opacity
C. All bin vents - 7% opacity
D. Flour loadout by rail - 5% opacity
E. Feed loadout by truck - 10% opacity F. All other points - 20% opacity. [40 CFR 60 Subpart DD, R307-205-4, R307-401-8]
II.B.1.a.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] II.B.1.b NEW The owner/operator shall pave all haul roads at the facility. [R307-401-8] II.B.1.c NEW The owner/operator shall only use line power to provide electricity to stationary equipment at the facility. [R307-401-8]

II.B.2 NEW Production Requirements
II.B.2.a NEW The owner/operator shall not store more than 240,000 tons of raw wheat per rolling 12-month period. [R307-401-8]
II.B.2.b
NEW
The owner/operator shall not produce more than 174,000 tons of processed flour and whole
wheat combined per rolling 12-month period. [R307-401-8] II.B.2.c NEW The owner/operator shall not loadout more than 60,000 tons per year of processed flour and whole wheat combined per rolling 12-month period from the rail loadout, the truck loadout, or the packaging loadout. [R307-401-8] II.B.2.d NEW The owner/operator shall not produce more than 64,200 tons of feed by-product per rolling 12-month period. [R307-401-8]
II.B.2.e
NEW
To determine compliance with conditions II.B.2.a through II.B.2.d, the owner/operator shall:
A. Determine production for each process with equipment scales B. Record production for each process on a daily basis C. Use the production data to calculate a new rolling 12-month total for each process by
the 20th day of each month using data from the previous 12 months D. Keep production records for each process for all periods the plant is in production. [R307-401-8]

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 10
II.B.3 NEW Baghouse Requirements
II.B.3.a NEW The owner/operator shall install one (1) baghouse to control particulate emissions from each of the following activities and equipment: grain receiving and handling, grain cleaning, grain tempering, and each plansifter. Each baghouse shall meet a particulate matter emission rate of 0.01 gr/dscf. [R307-401-8] II.B.3.a.1 NEW To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emission guarantee for each baghouse. The records shall be kept
for the life of each baghouse. [R307-401-8] II.B.3.b NEW The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure drop across the baghouse. [R307-401-8]
II.B.3.b.1 NEW The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.3.b.2 NEW The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8]

II.B.3.c NEW During operation of the baghouse, the owner/operator shall maintain the static pressure drop within the range recommended by the manufacturer for normal operations. [R307-401-8]
II.B.3.c.1 NEW The owner/operator shall record the pressure drop at least once per operating day while the baghouse is operating. [R307-401-8]
II.B.3.c.2 NEW The owner/operator shall maintain the following records of the pressure drop readings: A. Unit identification
B. Manufacturer recommended static pressure drop for the unit
C. Date of reading D. Daily static pressure drop readings. [R307-401-8]
II.B.3.d
NEW
At least once every 12 months, the owner/operator shall calibrate the pressure gauges in
accordance with the manufacturer's instructions or replace the gauges. [R307-401-8] II.B.3.d.1 NEW The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8]
II.B.4 NEW Grain Milling Baghouse Stack Testing Requirements
II.B.4.a NEW The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 11
II.B.4.a.1 NEW Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8]
II.B.4.a.2 NEW Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.4.a.3 NEW Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]
II.B.4.a.4
NEW
Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8]
II.B.4.a.5 NEW Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.4.a.6 NEW Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
II.B.4.b NEW Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)
C. Averaging Time - As specified in the applicable test method
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.4.b.1
NEW
Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate
emissions, all of the filterable particulate emissions shall be considered PM10. [R307-401-8]

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 12
II.B.4.c NEW The owner/operator shall not emit more than the following rates and concentrations from the Two (2) Grain Milling Baghouse Stacks: Pollutant grains/dscf Filterable PM10 0.01 Filterable PM2.5 0.01. [R307-401-8]
II.B.4.c.1 NEW Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained
in this AO. [R307-165-2, R307-401-8] II.B.4.c.2 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days
after startup of the emission unit. [R307-165-2] II.B.4.c.3 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 13
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 August 21, 2024
Incorporates Additional Information dated October 1, 2024 Incorporates Additional Information dated October 30, 2024 Incorporates Additional Information dated November 6, 2024 Incorporates Additional Information dated November 13, 2024 Incorporates Additional Information dated December 4, 2024 Incorporates Additional Information dated December 11, 2024 Incorporates Additional Information dated December 18, 2024
REVIEWER COMMENTS
1. Comment regarding Emission Calculation Methodology: The Richmond Flour Mill will only produce PM10 and PM2.5 emissions. All of the equipment on site is run using line power. The efficiencies of control equipment are determined using AP-42 Appendix B.2, Table B.2-3. The emission factors of each process are determined using AP-42 Section 9.9.1: Grain Elevators and Processing. Emissions for each process are estimated using monthly throughput,
emission factors, and control equipment efficiency.
Grain receiving (from truck and rail), grain handling, and grain storage emissions are estimated using 20,000 tons of throughput per month, which equates to 240,000 tons per year. Grain cleaning, grain tempering, and grain milling emissions are estimated using 14,500 tons of throughput per month, which equates to 174,000 tons per year. Flour and whole wheat storage, handling, and plansifting emissions are also estimated using 14,500 tons of throughput per month, which equates to 174,000 tons per year. Flour and whole wheat loadout emissions are estimated to using 5,000 tons of
throughput per month for each loadout, which equates to 60,000 tons per year for each loadout. Finally, feed storage and feed loadout emissions are estimated using 5,200 tons of throughput per month, which equates to 62,400 tons per year.
The source produces flour at a slower rate than they receive and store grain. Therefore, a separate grain storage limit of 240,000 tons per rolling 12-month period has been included in the permit. The source will not be able to receive more than 240,000 tons of grain per year from truck and rail receiving combined without exceeding the grain storage limit. A flour/whole wheat production limit of 174,000 tons per rolling 12-month period has been included in the permit. The source will not be able to clean, temper, or mill more than 174,000 tons per year of grain without exceeding the flour/whole wheat production limit. The source will also not be able to handle and store more than
174,000 tons per year of processed flour/whole wheat without exceeding the flour/whole wheat production limit. The source has several different loadouts and has based emissions on limited flour/whole wheat loadout from each. Therefore, a flour/whole wheat loadout limit of 60,000 tons
per rolling 12-month period for the rail loadout, the truck loadout, and the packaging loadout has been included in the permit. A feed production limit of 62,400 tons per rolling 12-month period has been included in the permit. The source will not be able to store and loadout more than 62,400 tons
per year of feed without exceeding the feed production limit. The source has indicated that the hammer mill is a subset of the total site-wide grain milling operations. The source has estimated that of the total 174,000 tons of grain milled per year, 17,400

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 Page 14
tons of whole wheat will be produced through the hammer mill. However, emissions were conservatively estimated assuming 100% of the grain milled is turned into flour. Since the hammer
mill produces PM emissions at a much lower rate than the roller mill, and the source has estimated emissions assuming all grain is milled into flour, an individual production limit is not necessary for whole wheat produced at the hammer mill.
The source has indicated that areas of the facility will be paved in order for trucks to unload raw
grain product and receive processed flour and animal feed. These areas can be considered haul roads. However, unlike an aggregate pit, very little particulate generating material (grain, flour, feed) will be deposited on the road. Road emissions were calculated using AP-42 Section 13.2.1 - Paved Roads. Using Google Earth and the site-map overlay, PM10 and PM2.5 emissions were both calculated to be <0.01 TPY. The source is required to pave all haul roads used for grain, flour, and feed loading/unloading. [Last updated December 18, 2024]
2. Comment regarding Fugitive Emissions: The proposed facility has three sources of fugitive emissions: grain storage, flour loadout by rail, and feed loadout by truck. Because the facility is subject to 40 CFR 60 Subpart DD, the facility is required to meet the following opacities for fugitive emissions. Flour loadout by rail meets the definition of railcar loading and the process must maintain a visible opacity of 5% or less. Feed loadout by truck meets the definition of truck loading and must maintain a visible opacity of 10% or less. Grain storage does not meet the definition of grain handling and therefore is not subject to specific opacity requirements from the subpart. [Last updated December 18, 2024] 3. Comment regarding Federal Subpart Applicability:
NSPS 40 CFR 60 Subpart DD (Standards of Performance for Grain Elevators) applies to any grain terminal elevator or any grain storage elevator which commences construction, modification, or
reconstruction after August 3, 1978. The twelve (12) grain elevator bins at the Richmond Flour Mill meet the definition of a grain storage elevator; therefore, NSPS Subpart DD applies to the source. [Last updated December 18, 2024]
4. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source.
This source is not a major source, is not a Title IV source, and is not subject to 40 CFR 61 or 40
CFR 63 requirements. However, the source is subject to 40 CFR 60 NSPS Subpart DD requirements. These regulations do not specifically exempt the source from Title V; therefore, Title V applies to the source as an area source. [Last updated December 18, 2024]

Engineer Review N162330001: Utah Flour Milling LLC- Richmond Flour Mill December 18, 2024 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 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
Reference Throughput (TPY)PM10 Control Eff (%)
Grain Receiving (Truck)3,8 240,000 99.5
Grain Receiving (Rail)3,8 240,000 99.5
Grain Handling (Conveyors, etc 3 240,000 99.5
Grain Storage (Bins)3 240,000 0
Grain Cleaning 3 174,000 99.5
Grain Tempering 6 174,000 99.5
Grain Milling 1,3,4 174,000 99.75
Flour Storage (Bins)2,5 174,000 50
Flour Handling (Plansifters)7 174,000 99.5
Flour Loadout (Truck)2,5 60,000 50
Flour Loadout (Rail)5,8 60,000 0
Flour Loadout (Packaging)2,5 60,000 50
Whole Grain Hammer Milling 2,3,4 17,400 50
Feed Storage (Bins)2,3 62,400 50
Feed Loudout (Truck)3,4,8 62,400 0
6 A factor of 50% applied to grain handling EF (Directly from AP-42 Section 9.9) to determine grai
7 Same EF as grain handling used
8 50% capture eff used, if 100% capture eff was used, PM10 emissions would increase by 0.03 T
*** Only PM total that doesn't match the Updated Emission Calculations (11/6/24). The source's E
Haul Road Length (mi)Annual VMT (mi/yr)PM10 EF (lb/VMT)
Grain Receiving Haul Road 0.071 1693 0.0022
Flour Loadout Haul Road 0.117 704 0.0022
Feed Haul Road 0.129 155 0.0022
11 Annual VMT determined using production values, haul road length, and assuming 20 ton trucks
*** Including annual PM10 and PM2.5 emissions from haul roads would not impact site-wide PTE
1 The source will control the grain milling process with three parallel cyclones and three parallel ba
PM2.5 control effcecnies are estimated to be 10% for a cyclone and 99% for a baghouse. These a
parallel. The control efficency factors are estimated using one baghouse and one cyclone togethe
2 The souce has used 50% control efficency for PM10 and PM2.5 for emission calculations from d
3 PM10 and PM2.5 EF Directly from AP-42 Section 9.9
4 PM2.5 estimated to be 17% of PM10 when no PM2.5 data is available
5 A factor of 50% applied to grain process EF (directly from AP-42 Section 9.9) to determine flour
9 PM10 and PM2.5 Emission Factors from AP-42 Section 13.2.1 - Paved Roads
10 Haul Road Length determined by overlaying site map with Google Earth location
PM2.5 Control Eff (%)Capture Eff (%)PM10 EF (lb/ton)PM2.5 EF (lb/ton)PM10 (TPY)PM2.5 (TPY)
99 50 0.0078 0.0013 0.002 0.001
99 50 0.0078 0.0013 0.002 0.001
99 100 0.034 0.0058 0.020 0.007
0 100 0.0063 0.0011 0.756 0.132
99 100 0.019 0.0032 0.008 0.003
99 100 0.017 0.0029 0.007 0.003
99.1 100 35 5.95 7.613 4.659
50 100 0.00315 0.00055 0.137 0.024
99 100 0.034 0.0058 0.015 0.005
50 100 0.0145 0.00245 0.218 0.037
0 50 0.0011 0.000185 0.017 0.003
50 100 0.0145 0.00245 0.218 0.037
50 100 0.067 0.01139 0.291 0.050
50 100 0.0063 0.0011 0.098 0.017
0 50 0.0033 0.0008 0.051 0.012
n tempering EF, listed as ND in Ap-42 Section 9.9
PY...
EFs are more conservative and the discrepency is small
PM2.5 EF (lb/VMT)PM10 (TPY)PM2.5 (TPY)
0.00054 0.0018623 0.00045711 Total PM10 (TPYTotal PM2.5 (TPY)
0.00054 0.0007744 0.00019008 0.003 0.001
0.00054 0.0001705 0.00004185
s w/ 20 ton load
estimates
aghouses. The PM10 control effcecnies are estimated to be 50% for a cyclone and 99.5% for a baghouse. The
are conservative estimates because the source intends to operate three cyclones and three baghouses in
r.
dust filters and bin vents. This is a conservative estimate and AP-42 suggests that a fabric filter is more efficent.

EF for similar process, listed as ND (non-detect) in AP-42 Section 9.9

Total PM10 (TPY)Total PM2.5 (TPY)
9.454 4.989
***
)
***
Dungan Adams <[e-mail]>
Modeling for Utah Flour Milling LLC
kirk.arens <[e-mail]>Wed, Dec 18, 2024 at 10:28 AM
To: Dungan Adams <[e-mail]>
Cc: Scott Hanson <[e-mail]>, Ryan Miller <[e-mail]>, Jack Batho <[e-mail]>
Per our conversation the Whole wheat is treated as a flour product that is stored in a flour bins and loaded out by the flour loadout system. The
difference is the Whole wheat process is it does not go through the roller mill process but rather passes through the hammermill and transfer to a
flour bin. Unlike the flour milling process the whole wheat does not generate feed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, December 18, 2024 9:02 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Ryan Miller <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,

I think you may have mentioned this over the phone, but then how is the feed produced? Before our brief conversation this morning, I was under the assumption that all
of the feed was produced through hammer milling and that the hammer mill, storage, and loadout limits should be the same. Now it seems like there are two types of
feed being produced at the facility? Please elaborate on the feed production process so I can update the permit accordingly.

Thanks,
Dungan

On Wed, Dec 18, 2024 at 8:55 AM kirk.arens <[e-mail]> wrote:
It can be left at 1450. It will only be used for Whole Wheat which will not be a major product here

From: Dungan Adams <[e-mail]>
Sent: Wednesday, December 18, 2024 8:53 AM
To: Sco Hanson <[e-mail]>
Cc: Ryan Miller <[e-mail]>; Jack Batho <[e-mail]>; kirk.arens <[e-mail]>
Subject: Re: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Should the hammer milling / milling byproduct row also be updated to 5,200 tons per month instead of 1,450 tons per month?

Thanks,
Dungan

On Wed, Dec 18, 2024 at 8:41 AM Scott Hanson <[e-mail]> wrote:
Dugan

Kirk indicated that he discussed increasing the limit for milling byproduct (animal feed) that is potenally produced at the facility from what is currently on
the dra permit. I have aached the updated emission calculaons with the feed loadout (EU-14) and corresponding feed storage (EU-13) monthly requested
limits increased to 5,200 tons per month. This change results in a relavely small increase to the facility total emissions. Let us know if you need have any
quesons or need addional informaon.

12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…1/37

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, December 17, 2024 6:37 PM
To: kirk.arens <[e-mail]>
Cc: Ryan Miller <[e-mail]>; Jack Batho <[e-mail]>; Sco Hanson <[e-mail]>
Subject: Re: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,

I accidentally attached the wrong draft... Please review this attachment and disregard my previous email.

Thanks,
Dungan

On Tue, Dec 17, 2024 at 5:34 PM Dungan Adams <[e-mail]> wrote:
Hi Kirk,

Attached is the draft permit for the Richmond Flour Mill. Please review the document and let me know if you have any questions or concerns. If everything looks
good, please sign the cover page and return it to me.

Thanks,
Dungan

On Wed, Dec 11, 2024 at 2:32 PM Dungan Adams <[e-mail]> wrote:
Kirk,

My manager has still not completed their review of the project. Once they finish their review, I will implement any changes they request, and get the draft
permit over for you to review. I understand that you are working with a tight timeline and will try to get this to public comment as quickly as I can. I will let you
know if my manager brings up any other questions.

Thanks,
Dungan

On Wed, Dec 11, 2024 at 2:25 PM kirk.arens <[e-mail]> wrote:
Dungan hate to be a pest any update on how the review is going. I have a huge following in my company right now wanting updates on
the permit.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, December 11, 2024 2:18 PM
To: Ryan Miller <[e-mail]>
Cc: Jack Batho <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: Re: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Ryan,

12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…2/37
Sorry, I missed your message this morning. The permit will require an initial stack test within 180 days of startup and then future tests every five (5) years.

Thanks,
Dungan

On Wed, Dec 11, 2024 at 8:27 AM Ryan Miller <[e-mail]> wrote:
Dungan,

Testing at the stacks would be the most accessible and safe location to sample. Is the testing required continual monitoring throughoutoperations or individual tests at a set interval?

Thanks,

Ryan Miller
Design Engineer

Phone [phone] Mobile [phone]
Web www.bratney.com
Email [e-mail]
3400 109th St, Des Moines, IA 50322

From: Jack Batho <[e-mail]>
Sent: Wednesday, December 11, 2024 8:52 AM
To: Dungan Adams <[e-mail]>; kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Ryan Miller <[e-mail]>
Subject: RE: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good morning, Dungan,

I don’t believe you are misinterpreting anything. I will let Ryan add any comment necessary that may indicate the ability to perform aperformance stack test prior to the split to the two exhaust vents (stacks).

For the performance stack testing based on the way you explained the emissions below, would the facility be able to reasonablyassume that stack testing would only be required on the milling baghouses or would stack testing be required on additionalbaghouses? I want to make sure we have the understanding on the level of effort and potential costs that are going to be required by
conditions in the permit.

Thank you for your help and please let me know if you have any additional questions.

Kind Regards,

Jack Batho IV
Staff Engineer
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…3/37
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, December 10, 2024 5:13 PM
To: kirk.arens <[e-mail]>
Cc: Jack Batho <[e-mail]>; Sco Hanson <[e-mail]>; [e-mail]
Subject: Re: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

Thanks for providing the baghouse stack explanation. I wanted to include Jack and Ryan as they may have input about this. According to the emission
calculations provided, the potential uncontrolled PM10 and PM2.5 emissions from the grain milling process are 3,296 tpy and 560 tpy respectively.
Because the uncontrolled emissions from this specific process are so large, failure of a baghouse could trigger major source status, and some type of
stack testing for filterable PM10 and PM2.5 will be required. The stack(s) will be required to meet an emission rate of 0.01 gr/dscf.

The way you have described things, the three (3) parallel baghouses are routed into a space which then vents through two (2) stacks. I don't think
testing before the plenum would be possible, but if it is, then only a single stack test would be required. Otherwise, I am thinking both of the 44 in.,22,000 cfm stacks will need to meet the 0.01 gr/dscf rate.

Please let me know if I am misinterpreting anything or if you have any questions or concerns about the stack testing requirement.

Thanks,
Dungan

On Tue, Dec 10, 2024 at 3:13 PM kirk.arens <[e-mail]> wrote:

Currently the three (3) Baghouses associated with the milling process will be ducted via a single large plenum. The large plenum will
be routed to two (2) separate stacks with a diameter of 44 inched each. The reason for two (2) separate stacks is due to the spaceconstraints for the facility. The flow rates for each stack is approximately 44,000 cfm combined (22,000 cfm each). However, theoperating parameters of the stacks will be determined on the amount of air that must be exhausted from the process. Under normaloperating circumstances one stack/damper would be emitting up to its approximate capacity (22,000 cfm) and the otherstack/damper will be opened up as needed for any additional capacity. The approximate stack locations are depicted in the attached
snippet below.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Ryan Miller <[e-mail]>
Sent: Tuesday, December 10, 2024 3:34 PM
To: Jack Batho <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Quick note. The 2 exhaust stacks described below have a combined capacity of 44,000 cfm total (22,000 cfm each).

Thanks,
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…4/37

Ryan Miller
Design Engineer

Phone [phone] Mobile [phone]
Web www.bratney.com
Email [e-mail]
3400 109th St, Des Moines, IA 50322

From: Jack Batho <[e-mail]>
Sent: Tuesday, December 10, 2024 3:29 PM
To: Ryan Miller <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good afternoon, All,

Please see my response to Dungan’s question below.

Currently the three (3) Baghouses associated with the milling process will be ducted via a single large plenum. The large plenum will
be routed to two (2) separate stacks with a diameter of 44 inched each. The reason for two (2) separate stacks is due to the space
constraints for the facility. The flow rates for each stack is approximately 44,000 cfm. However, the operating parameters of thestacks will be determined on the amount of air that must be exhausted from the process. Under normal operating circumstances onestack/damper would be emitting up to its approximate capacity (44,000 cfm) and the other stack/damper will be opened up asneeded for any additional capacity. The approximate stack locations are depicted in the attached snippet below.

Please let me know if you have any questions, comments, or concerns.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Ryan Miller <[e-mail]>
Sent: Tuesday, December 10, 2024 3:16 PM
To: Jack Batho <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

After looking at your question again I have a bit more explanation.

The various milling jet filters are ducting into a single large plenum. This plenum then has two stacks that penetrate the roof to expel
air as needed.

12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…5/37
Ryan Miller
Design Engineer

Phone [phone] Mobile [phone]
Web www.bratney.com
Email [e-mail]
3400 109th St, Des Moines, IA 50322

From: Jack Batho <[e-mail]>
Sent: Tuesday, December 10, 2024 1:48 PM
To: Ryan Miller <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Ryan,

Thank you for the additional information. I will work on drafting an email and send to the group for review before sending it along toDungan. One last question. I don’t want to get too far into splitting the flows between the two stacks, but is there a set process forwhat amount of CFM goes to each stack? Or is this a variable process?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Ryan Miller <[e-mail]>
Sent: Tuesday, December 10, 2024 1:46 PM
To: Jack Batho <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

The two stacks discussed are related to being able to decide how much warm process air (milling process) is returned into the mill.

We have three additional stacks on the roof that are not related to the milling process. Two of them are related to wheat cleaning jet
filters while the third is for displacement air in the flour silos during general milling operations. These three stacks dump air that isnot intended to be recirculated. This air is made up by three RTU’s that only pull in fresh air.

Thanks,

Ryan Miller
Design Engineer
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…6/37

Phone [phone] Mobile [phone]
Web www.bratney.com
Email [e-mail]
3400 109th St, Des Moines, IA 50322

From: Jack Batho <[e-mail]>
Sent: Tuesday, December 10, 2024 1:28 PM
To: Ryan Miller <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Ryan,

I wanted to make sure; this would be specifically for the baghouses vents associated with the milling process. Not sure if thatchanges your answer at all?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Jack Batho
Sent: Tuesday, December 10, 2024 1:24 PM
To: Ryan Miller <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good afternoon, Ryan,

Thank you for the additional information. I am assuming the next question from the regulators will be flow rates and diameters. Do
you have that information readily available, so I can provide it to Dungan?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Ryan Miller <[e-mail]>
Sent: Tuesday, December 10, 2024 1:21 PM
To: Jack Batho <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…7/37

Jack,

We will utilize two separate stacks to allow warm process air to be dumped that will not be returned via the RTU’s. The requirementfor two stacks is due to space available. We did not have enough physical space for one large stack. The airflow through thesestacks will be controlled via individual automated dampers based on how much air will be recirculated into the mill building ordumped to atmosphere.

Thanks,

Ryan Miller
Design Engineer

Phone [phone] Mobile [phone]
Web www.bratney.com
Email [e-mail]
3400 109th St, Des Moines, IA 50322

From: Jack Batho <[e-mail]>
Sent: Tuesday, December 10, 2024 12:45 PM
To: kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Cc: Ryan Miller <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good afternoon, Kirk,

Based on the drawings that we have at this time and the information provided to us in the past by Ryan, we do not specifically knowthe answer to that question. Based on our understanding, the baghouses vent into the pressurization system (ducting) and is then
vented outdoors as needed, therefore it very well could be a singular stack. However, we do not have any information to substantiate
other than what Ryan has told us.

Ryan,

Can you confirm if the three milling baghouses vent outdoors via the same stack (ducting system) or via separate stacks?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: kirk.arens <[e-mail]>
Sent: Tuesday, December 10, 2024 12:23 PM
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…8/37
To: Jack Batho <[e-mail]>; Sco Hanson <[e-mail]>
Subject: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Can you please answer this asap

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphoneGet Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Monday, December 9, 2024 3:42:02 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,

My manager is still reviewing the project. Once he has finished his review and you sign off, the project will be sent for public comment.

I do have one other question that the compliance manager brought up: For the three (3) parallel grain milling baghouses, is there one combined stack
or three individual stacks?

Thanks,
Dungan

On Fri, Dec 6, 2024 at 9:39 AM kirk.arens <[e-mail]> wrote:
When will it post for public notice

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: kirk.arens <[e-mail]>
Sent: Wednesday, December 4, 2024 6:18:16 PM
To: Dungan Adams <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

That is correct. We do not

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From: kirk.arens <[e-mail]>
Sent: Wednesday, December 4, 2024 5:17:54 PM
To: Dungan Adams <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

That is correct. We do

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
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From: Dungan Adams <[e-mail]>
Sent: Wednesday, December 4, 2024 5:01:18 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…9/37
The compliance division has completed their review of the project and brought up a couple of minor questions:

- Can you confirm that there are no natural gas/diesel fired boilers or dryers on site?
- Can you confirm that no materials containing chromium or manganese are used in the feed by-product process?

Thanks,
Dungan

On Mon, Nov 18, 2024 at 1:31 PM kirk.arens <[e-mail]> wrote:
We have in process scales that continuously weight product streams as we use and make product. It gives us real time information on wheat
used and flour and by products made

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Monday, November 18, 2024 1:13:22 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

Following up about my question from last Thursday.

Thanks,
Dungan

On Thu, Nov 14, 2024 at 10:08 AM Dungan Adams <[e-mail]> wrote:
Can you explain what you mean by online scales?

Thanks,
Dungan

On Thu, Nov 14, 2024 at 10:06 AM kirk.arens <[e-mail]> wrote:
We have online scales

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Thursday, November 14, 2024 11:04:36 AM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,

Since the facility's estimated emissions are based on tons of monthly throughput, I will need to include conditions that limit throughput. To
determine compliance with the throughput limits, the facility will be required to maintain records of throughput through the various
operations at the mill.

Do you know how the facility will weigh grain/flour/feed by-product at the mill? We often see this done with belt or floor scales, but I wanted
to check with you to confirm what type of weighing systems you plan to use.

12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…10/37
Thanks,
Dungan

On Wed, Nov 13, 2024 at 11:41 AM Dungan Adams <[e-mail]> wrote:
Great, thanks for confirming.

- Dungan

On Wed, Nov 13, 2024 at 11:41 AM kirk.arens <[e-mail]> wrote:
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent tothe atmosphere through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12)
internal grain storage bins are not controlled by any equipment?

Thanks,
Dungan

On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside
floor bins, 1 feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to becompleted.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction,
modification, or establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat
storage is an air pollution source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The
number of each will be included in the permit.

Thanks,
Dungan

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:1818800067747988…11/37
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the
facility. The mill will not be capable of running product until the permit is in place but I was wondering if we can
bring wheat into our bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency
for the cyclones as this will be more consistent with the current system setup emissions. I have aached our revised
Emission Calculaons Spreadsheet with highlighng showing the cells with revised inputs. We increased the efficiency of
the baghouses and added the cyclones to the control efficiency for the grain mill (EU-05A). We also adjusted the
discharge for the vent system to be 100% outdoors and 0% recirculated indoors as a worst case scenario and would
provide an addional emission safety factor. Of note the air that is recirculated back into the building flows through
addional filters before being discharged back into the building to collect parculate maer and further reduce interior
emissions and the buildup of parculate maer within the building that needs to be cleaned up. Let us know if you have
any quesons or need any addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions
are currently calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the
atmosphere without exceeding modeling thresholds. Especially because of the seasonal temperature justification of the 60-40split, I do not think there is a good way to enforce this without requiring a lot of stack testing. If there is no enforceable limit in
the permit, then nothing is stopping the facility from exhausting greater than 40% of the baghouse emissions to the
atmosphere. Richmond could experience an unusually long summer and the facility could exhaust for a greater period thanwhat is anticipated. The permit would also need to ensure that 100% of the recirculated baghouse exhaust remains and
settles inside the building and ~18 TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to
calculate more accurate estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain
milling baghouse by half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…12/37
baghouse control efficiencies are used across the facility, if we conservatively assume that all of the baghouse emissions areexhausted to the atmosphere, the facility will remain below the modeling threshold. With this approach this is no need to try
and enforce the 60-40 split are ensure that 100% of the recirculated air remains inside the facility. The facility would be able to
use their HVAC system with full flexibility and exhaust as much or as little of the grain milling baghouse exhaust asnecessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should
justify why our calculations have been revised and give real world data and “good engineering practice” as to how we
arrived at the calculations provided in the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original
understanding of the air flow system design was that the air from some systems, including the mill exhaust after thebaghouses, would be discharged back into a room in the interior of the building. We have seen this design in other setups
where the discharge is generally directed to a room before being directed to other building areas. Air within the building
would be exhausted through various exhaust vents. These exhaust fans are identified as emission point EP-RV on the
permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being
emitted through the roof vent as a starting point. This emission split was likely higher than required, but we were not certain
of the distances and configuration from the emission point in the building to the roof vents. In addition, we estimated that
the whole facility air flow would be recirculated at a rate of 75% emitted through roof vents outdoors and 25% would be
returned internally. This number was further reduced in the most recent permit based on our understanding that
approximately 50% of this air would be circulated back into the building equipment and would not be exhausted. Therefore,
the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is
some process equipment that draws in air from inside the building, which is discharged through emission points (outdoors)
as identified in the permit and there is no changes with these units. However, the emission points identified as EP-RV haveflow directed through ducts to a valving system that determines how much of this air is discharged to the exterior of the
building and how much of this air is recirculated and directed through the RTUs and then back into the building. In the
colder winter months this system would recirculate 100% of this air back into the building to maintain heat, with additionalheating provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100% of the
airflow to the exterior to allow for more cool air to be drawn into the building. This recirculation system accounts for 45,000
CFM of the total 80,000 CFM that is drawn through all equipment with the other air flows being discharged (outdoors)through other emission points. Therefore, when this circulation system is closed during cooler periods an additional 35,000
CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a thermostat based on
interior and exterior temperatures and the following table was derived with monthly average temperatures for the facility
area to calculate split between exhausted and recirculated air. Based on this information the 40% to 60% split included in
the permit is scientifically correct. Another temperature analysis was performed with data from 2023 in the area of the
facility and approximately 36% of the days in the year had a high and low daily temperature above 65 degrees where the
HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage
of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month AverageHigh AverageLow AverageHigh AverageLow Ave Temp %Exhausted %Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…13/37
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that
have been built into these emission calculations as discussed below; therefore, the actual facility emissions would be lowerthan these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the milland no emission reduction factor for these units was included in the calculations. These units would beconsidered medium efficiency cyclones, which would have a control efficiency of 50% for PM10; therefore,
the milling equipment EU-06A PM10 emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It isunlikely that the facility will be able to maintain this flow rate as there will be down time for repairs and
maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facilitywide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is avested interest in reducing emissions and improving efficiency of the systems and assuring the emissionequipment in place is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanationfor why the original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40%
outdoor - 60% indoor split. If Kirk or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest
to capture product. However, the emission calculations that were provided in the updated NOI are close to modelingthresholds and I need to understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…14/37
On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller withBratney who is part of the team responsible for designing the air flow and hvac systems for this facility.Once we removed the mill line B from the initial application package, we revisited numerous calculations tobetter reflect what would be happening with the emissions associated with mill line A. Please keep in mindthat Scott and I are not HVAC engineers, we are familiar with this operation, but Ryan may be better suitedwith explaining how this process works specifically. Essentially, similar to other mills, most of the
recirculated air will cause the particulate matter to settle on the floor within the mill. This waste settled
material is constantly swept up and disposed of. It is not uncommon for numerous tons to be disposed of
in this fashion at similar sized mills across the country via the dumpster (garbage service) or other
alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the
emissions past the level represented in the NOI and submitted calculations. As to make everything easier
to review on the agency end, we tried to limit step-wise or series calculations and simply apply themanufacturer guaranteed emissions control rates submitted in the application as if the baghouses were setup in a parallel formation. As you can see in the submittal there are three baghouses and at least onecyclone associated with the milling process. This vastly reduces emissions below the levels within thecalculations provided. As stated in previous emails any lost product or by-product is lost revenue for the
facility and company as a whole, so there is a vested interest in reducing emissions and improving
efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS
representative for the facility and company as a whole. Ryan can also provide more knowledgeable and in-
depth information related to the HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better
answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to
produce 31.5 tpy of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where
75% of particulate emissions are directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. Theexhaust would be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain
indoors. If the 75% outdoor - 25% indoor split was used in the updated calculations, the source would be above the
modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations andwhy it changed from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used
at other mills and I would like to see an example of a mill that operates this way. I searched the other permitted flour
mills in Utah and it looks like they all use baghouses that vent directly to the atmosphere. From my perspective, it lookslike the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements and I will need to see
stronger justification for this process before I am able to accept the calculations.
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…15/37

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back
to discuss this in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and
recycle the air for air handling balancing purposes. In pracce the actual dust that accumulates in the building is
less than the these calculated values due to several factors, and the calculated values represent a worst case
scenario. This system includes several small cyclones that are primarily used for material transfer from the milling
process prior to the baghouses but the emission reducon form these units is not included in the emission
reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values
used in the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and
actual emissions would be less than these values. The flow from the baghouses is discharged to certain interior
areas of the building that will facilitate in the seling of parculates and the cleanup of parculates for the
recycling of the air. The parculate and process waste maer that is developed at this facility that cannot be used
as flour and is used as animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation,
~30 tpy of PM10 and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40%being vented to the atmosphere. This seems like a huge amount of particulate inside of the building. Can you
elaborate on what happens to the particulate that stays inside the building? If it is captured for reuse, how does the
capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would
be contained within the building, which is on the indoor line. These emissions would not be discharged to
the outside of the building. The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40%
fracon of the milling emissions discharged to the atmosphere through the vents, which is on the outdoor
line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has very minor
emissions in comparison.
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…16/37

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors
exit the building to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide
PTE. I just want to understand where the particulate goes since a substantial amount is routed indoors and thesource is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but
in your case the source has chosen to use baghouses (generally the best control option for PM) for all of the
primary emitting processes. The remaining processes that are uncontrolled or controlled with lowerefficiency filters produce such minor amounts of PM that it would be challenging to justify more expensive
control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurizationsystem that feeds air back into the mill. The reason for this design is to account for the need of
extra airflow to reduce the likelihood of creating a vacuum in the mill. If the air was not returned
you would not be able to open a single door in the mill. With that in mind, in the pressurization
room, there is a “burp” vent type system that would allow some of the internal air to exit via the
roof vent. All the baghouses (and cycle) vents associated with the milling are routed to theaforementioned process. The 60/40 split is an approximate number based on a similar operatingparameter at other mills throughout the portfolio. The HVAC designer confirmed that this is evenan overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available
Control Technology (BACT) please provide it. The facility equipment are being designed using current
technologies and industry standards to minimize emissions. The facility is construcng the mill in a way to
reduce emissions consistent with using the Best Available Control Technology (BACT). We can provide a
wrien determinaon on the processes that are not currently equipped with a baghouse, but the
reducon in emissions per the cost basis would not be economically viable or appropriate for the
reducon provided by the baghouse/cyclone. Addionally, since the emissions that are produced are
essenally flour product any emissions from the milling or cleaning processes are essenally lost product
that could have been sold; therefore, the facility has a vested capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…17/37

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the
PM emissions are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are
vented to the interior of the building and then directed to through building roof vents. I believe the building's
roof vents exhaust to the atmosphere. How are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology
(BACT) analysis was included. I did not see any BACT analysis in the document. Did you complete BACT
analysis for all emission units and emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They
do not need to pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I
have begun my review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising theair permit application to only cover Phase I due to Phase II being more than a year out(greater than 14 months, but likely greater than 18). We have only included the Phase I inthis application. With that in mind, the client paid the $3,000 fee upon initial submittal, since
we are modifying the application, should they submit via the online portal or can we submit
via email. We want to make sure that they are not paying $3,000 twice since only one
application will apply. Can you please provide insight on the correct submittal steps, or point
us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…18/37
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an
Approval Order (AO) prior to any construction, modification, testing, etc. You can reach out to Chad
Gilgen if you have questions, but I imagine he will say something similar about conducting testing prior
to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy
fugitive, 50.66 tpy non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds thattrigger the requirement to conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive
PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates would need to drop below these
values and be enforceable from a permitting perspective. If you think this is possible, we can take thisapproach, but you will need to resubmit the NOI with new emissions estimates. Before the second half
of the site is constructed, you will need to submit a second NOI for a minor modification and conduct
modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval
Order. Technically, an AO should be issued before construction even begins. You might want to try
running this by Chad Gilgen who's the manager of the minor source compliance section. He can bereached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some
of the system operaons and would operate at low levels. Would they be able to do this?
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…19/37
2. The permit emission that were submied on the applicaon are based on the worst case
scenario at the full future maximum operang capacity. Only half of the facility is being
constructed at this me so the emissions would easily be reduced in half and with some
addional flow reducons and adjustments the facility could operate below the modeling
threshold. So inially the facility would be running at limited capacity based on the future
potenal. So would it be possible to operate inially at a lower capacity with calculated
emission under the modeling threshold? We would connue with the modeling work, but this
may also allow us to beer define the model based on actual performance of the system
components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike
Freese <[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than
those listed in Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to
submit a dispersion modeling analysis as part of a complete NOI. Based on the estimated
emissions in your NOI, you will need to conduct modeling and demonstrate compliance with all
applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling
protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is
conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general,
please direct those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). Thatappears to be a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department.Does the modeling department perform the modeling in house at the UDEQ or howdoes that specifically work? We have performed modeling in other states, and weunderstand that each state handles modeling differently.

Thank you for your assistance.

12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1818800067747988924&simpl=msg-f:181880006774798…20/37
Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please
use caution when opening attachments.
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent
(NOI) application for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it
was checked off on the NOI application checklist but did not see any modeling analysis in the
NOI. The estimated potential to emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above
the thresholds which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If youhave not, I will provide some guidance and put you in contact with our modeling department to
set up a modeling protocol.

Thanks,
Dungan

--

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Adams
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M: (385) 290-
2474
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--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of the message is not the intended
recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have received this
communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

12/18/24, 4:16 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams <[e-mail]>
Modeling for Utah Flour Milling LLC
kirk.arens <[e-mail]>Wed, Dec 4, 2024 at 5:18 PM
To: Dungan Adams <[e-mail]>
That is correct. We do not
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: kirk.arens <[e-mail]>
Sent: Wednesday, December 4, 2024 5:17:54 PM
To: Dungan Adams <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

That is correct. We do
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Wednesday, December 4, 2024 5:01:18 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,
The compliance division has completed their review of the project and brought up a couple of minor questions:
- Can you confirm that there are no natural gas/diesel fired boilers or dryers on site?
- Can you confirm that no materials containing chromium or manganese are used in the feed by-product process?
Thanks,
Dungan
On Mon, Nov 18, 2024 at 1:31 PM kirk.arens <[e-mail]> wrote:
We have in process scales that continuously weight product streams as we use and make product. It gives us real time information on wheat used
and flour and by products made
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Monday, November 18, 2024 1:13:22 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,
Following up about my question from last Thursday.
Thanks,
Dungan
On Thu, Nov 14, 2024 at 10:08 AM Dungan Adams <[e-mail]> wrote:
Can you explain what you mean by online scales?
Thanks,
Dungan
On Thu, Nov 14, 2024 at 10:06 AM kirk.arens <[e-mail]> wrote:
We have online scales
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Thursday, November 14, 2024 11:04:36 AM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…1/22

Kirk,
Since the facility's estimated emissions are based on tons of monthly throughput, I will need to include conditions that limit throughput. To
determine compliance with the throughput limits, the facility will be required to maintain records of throughput through the various operations at the
mill.
Do you know how the facility will weigh grain/flour/feed by-product at the mill? We often see this done with belt or floor scales, but I wanted to
check with you to confirm what type of weighing systems you plan to use.
Thanks,
Dungan
On Wed, Nov 13, 2024 at 11:41 AM Dungan Adams <[e-mail]> wrote:
Great, thanks for confirming.
- Dungan
On Wed, Nov 13, 2024 at 11:41 AM kirk.arens <[e-mail]> wrote:
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to the
atmosphere through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12) internal grain
storage bins are not controlled by any equipment?

Thanks,
Dungan

On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floor
bins, 1 feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution
source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number
of each will be included in the permit.
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…2/22

Thanks,
Dungan

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The
mill will not be capable of running product until the permit is in place but I was wondering if we can bring wheat into our
bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the
cyclones as this will be more consistent with the current system setup emissions. I have aached our revised Emission
Calculaons Spreadsheet with highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses
and added the cyclones to the control efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system
to be 100% outdoors and 0% recirculated indoors as a worst case scenario and would provide an addional emission safety
factor. Of note the air that is recirculated back into the building flows through addional filters before being discharged back into
the building to collect parculate maer and further reduce interior emissions and the buildup of parculate maer within the
building that needs to be cleaned up. Let us know if you have any quesons or need any addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are
currently calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere
without exceeding modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think
there is a good way to enforce this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…3/22
stopping the facility from exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an
unusually long summer and the facility could exhaust for a greater period than what is anticipated. The permit would also need to
ensure that 100% of the recirculated baghouse exhaust remains and settles inside the building and ~18 TPY of particulate settling
inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more
accurate estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling
baghouse by half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control
efficiencies are used across the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the
atmosphere, the facility will remain below the modeling threshold. With this approach this is no need to try and enforce the 60-40 split
are ensure that 100% of the recirculated air remains inside the facility. The facility would be able to use their HVAC system with full
flexibility and exhaust as much or as little of the grain milling baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why
our calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the
calculations provided in the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding
of the air flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be
discharged back into a room in the interior of the building. We have seen this design in other setups where the discharge is
generally directed to a room before being directed to other building areas. Air within the building would be exhausted through
various exhaust vents. These exhaust fans are identified as emission point EP-RV on the permit documents. We estimated 25% of
the particulate would be contained in the building with the remaining 75% being emitted through the roof vent as a starting point.
This emission split was likely higher than required, but we were not certain of the distances and configuration from the emission
point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated at a rate of 75%
emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent
permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and
would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some
process equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified
in the permit and there is no changes with these units. However, the emission points identified as EP-RV have flow directed
through ducts to a valving system that determines how much of this air is discharged to the exterior of the building and how much
of this air is recirculated and directed through the RTUs and then back into the building. In the colder winter months this system
would recirculate 100% of this air back into the building to maintain heat, with additional heating provided by the RTUs. In the
summer months the system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for more cool air to
be drawn into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all
equipment with the other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation
system is closed during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC
valving system is controlled by a thermostat based on interior and exterior temperatures and the following table was derived with
monthly average temperatures for the facility area to calculate split between exhausted and recirculated air. Based on this
information the 40% to 60% split included in the permit is scientifically correct. Another temperature analysis was performed with
data from 2023 in the area of the facility and approximately 36% of the days in the year had a high and low daily temperature
above 65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both
cases the percentage of exhausted air flow would be expected to be higher than actual operating parameters.

12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…4/22
Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have
been built into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these
calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and noemission reduction factor for these units was included in the calculations. These units would be consideredmedium efficiency cyclones, which would have a control efficiency of 50% for PM10; therefore, the milling
equipment EU-06A PM10 emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely thatthe facility will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wideemissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested
interest in reducing emissions and improving efficiency of the systems and assuring the emission equipment inplace is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…5/22

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why
the original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor
split. If Kirk or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to
capture product. However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I
need to understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney
who is part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed
the mill line B from the initial application package, we revisited numerous calculations to better reflect what wouldbe happening with the emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC
engineers, we are familiar with this operation, but Ryan may be better suited with explaining how this process
works specifically. Essentially, similar to other mills, most of the recirculated air will cause the particulate matter to
settle on the floor within the mill. This waste settled material is constantly swept up and disposed of. It is notuncommon for numerous tons to be disposed of in this fashion at similar sized mills across the country via the
dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissionspast the level represented in the NOI and submitted calculations. As to make everything easier to review on the
agency end, we tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed
emissions control rates submitted in the application as if the baghouses were set up in a parallel formation. Asyou can see in the submittal there are three baghouses and at least one cyclone associated with the millingprocess. This vastly reduces emissions below the levels within the calculations provided. As stated in previous
emails any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested
interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS
representative for the facility and company as a whole. Ryan can also provide more knowledgeable and in-depth
information related to the HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

Kind Regards,

12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…6/22

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce
31.5 tpy of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate
emissions are directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The
exhaust would be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors.
If the 75% outdoor - 25% indoor split was used in the updated calculations, the source would be above the modeling threshold
for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it
changed from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills
and I would like to see an example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks
like they all use baghouses that vent directly to the atmosphere. From my perspective, it looks like the ratio of particulate
emission vented outdoors was adjusted to avoid modeling requirements and I will need to see stronger justification for this
process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to
discuss this in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle
the air for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the
these calculated values due to several factors, and the calculated values represent a worst case scenario. This system
includes several small cyclones that are primarily used for material transfer from the milling process prior to the
baghouses but the emission reducon form these units is not included in the emission reducon calculaons.
Addionally, the baghouses would be expected to have higher efficiencies than the values used in the calculaons.
Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less
than these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in
the seling of parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste
maer that is developed at this facility that cannot be used as flour and is used as animal feed. Let me know if you have
any other quesons.

12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…7/22
Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy
of PM10 and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the
atmosphere. This seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the
particulate that stays inside the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be
contained within the building, which is on the indoor line. These emissions would not be discharged to the outside
of the building. The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling
emissions discharged to the atmosphere through the vents, which is on the outdoor line for the milling. This indoor/
outdoor spilt is also the same for EU-08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…8/22

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the
building to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want tounderstand where the particulate goes since a substantial amount is routed indoors and the source is very close to
reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your
case the source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting
processes. The remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor
amounts of PM that it would be challenging to justify more expensive control. I will move forward with my BACT write up
without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization systemthat feeds air back into the mill. The reason for this design is to account for the need of extra airflow to
reduce the likelihood of creating a vacuum in the mill. If the air was not returned you would not be able
to open a single door in the mill. With that in mind, in the pressurization room, there is a “burp” vent type
system that would allow some of the internal air to exit via the roof vent. All the baghouses (and cycle)vents associated with the milling are routed to the aforementioned process. The 60/40 split is an
approximate number based on a similar operating parameter at other mills throughout the portfolio. The
HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the
system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control
Technology (BACT) please provide it. The facility equipment are being designed using current technologies and
industry standards to minimize emissions. The facility is construcng the mill in a way to reduce emissions
consistent with using the Best Available Control Technology (BACT). We can provide a wrien determinaon on
the processes that are not currently equipped with a baghouse, but the reducon in emissions per the cost basis
would not be economically viable or appropriate for the reducon provided by the baghouse/cyclone.
Addionally, since the emissions that are produced are essenally flour product any emissions from the milling or
cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested
capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…9/22
I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM
emissions are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the
interior of the building and then directed to through building roof vents. I believe the building's roof vents exhaust to
the atmosphere. How are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT)
analysis was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all
emission units and emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not
need to pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have
begun my review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the airpermit application to only cover Phase I due to Phase II being more than a year out (greater than
14 months, but likely greater than 18). We have only included the Phase I in this application. With
that in mind, the client paid the $3,000 fee upon initial submittal, since we are modifying the
application, should they submit via the online portal or can we submit via email. We want to makesure that they are not paying $3,000 twice since only one application will apply. Can you please
provide insight on the correct submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…10/22
From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval
Order (AO) prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have
questions, but I imagine he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66
tpy non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement
to conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5.
The flour mill's emission estimates would need to drop below these values and be enforceable from a permitting
perspective. If you think this is possible, we can take this approach, but you will need to resubmit the NOI with
new emissions estimates. Before the second half of the site is constructed, you will need to submit a second
NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by
Chad Gilgen who's the manager of the minor source compliance section. He can be reached at
[e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the
system operaons and would operate at low levels. Would they be able to do this?
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:1817557494267605…11/22
2. The permit emission that were submied on the applicaon are based on the worst case scenario
at the full future maximum operang capacity. Only half of the facility is being constructed at this me
so the emissions would easily be reduced in half and with some addional flow reducons and
adjustments the facility could operate below the modeling threshold. So inially the facility would be
running at limited capacity based on the future potenal. So would it be possible to operate inially at
a lower capacity with calculated emission under the modeling threshold? We would connue with the
modeling work, but this may also allow us to beer define the model based on actual performance of
the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those
listed in Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a
dispersion modeling analysis as part of a complete NOI. Based on the estimated emissions in your NOI,
you will need to conduct modeling and demonstrate compliance with all applicable national ambient air
quality standards (NAAQS). I recommend submitting a modeling protocol to Dave Prey and Jason Krebs
(cc'd in this email) to help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please
direct those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears
to be a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does themodeling department perform the modeling in house at the UDEQ or how does that
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…12/22
specifically work? We have performed modeling in other states, and we understand that
each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution
when opening attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI)
application for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was
checked off on the NOI application checklist but did not see any modeling analysis in the NOI. The
estimated potential to emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds
which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have
not, I will provide some guidance and put you in contact with our modeling department to set up a
modeling protocol.

Thanks,
Dungan

--
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…13/22

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is
privileged and/or confidential. If the reader of the message is not the intended recipient or an authorized representative of the
intended recipient, you are hereby notified that any use and/or dissemination of any of this communication is strictly prohibited.
If you have received this communication in error, notify the sender immediately by return email and delete the message and
any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged
and/or confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended
recipient, you are hereby notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have
received this communication in error, notify the sender immediately by return email and delete the message and any attachments
from your system.

--
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…14/22

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are
hereby notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have received this
communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…15/22

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby
notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have received this communication in error,
notify the sender immediately by return email and delete the message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby
notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have received this communication in error,
notify the sender immediately by return email and delete the message and any attachments from your system.

--
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…16/22

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If
the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use
and/or dissemination of any of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by
return email and delete the message and any attachments from your system.

--
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…17/22

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or
dissemination of any of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return
email and delete the message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or
dissemination of any of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email
and delete the message and any attachments from your system.

--
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…18/22

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader
of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of
any of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the
message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…19/22

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…20/22
M: [phone]
airquality.utah.gov
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…21/22
airquality.utah.gov
2 attachments
image002.jpg
1K
image003.jpg
1K
12/5/24, 3:17 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-f:1817557494267605304&simpl=msg-f:181755749426760…22/22
Dungan Adams <[e-mail]>
Modeling for Utah Flour Milling LLC
40 messages
Dungan Adams <[e-mail]>Thu, Aug 22, 2024 at 11:13 AM
To: [e-mail]
Cc: [e-mail]
Hi Jack,
The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a new flour mill.
Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on the NOI application checklist but did
not see any modeling analysis in the NOI. The estimated potential to emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds
which require the source to conduct modeling.
If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will provide some guidance and put you
in contact with our modeling department to set up a modeling protocol.
Thanks,
Dungan
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
Jack Batho <[e-mail]>Thu, Aug 22, 2024 at 11:43 AM
To: Dungan Adams <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, Scott Hanson <[e-mail]>, Mike Freese
<[e-mail]>
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modeling department perform the
modeling in house at the UDEQ or how does that specifically work? We have performed modeling in other states, and we
understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r87915711123850…1/327
Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening attachments.

[Quoted text hidden]
This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of the message is
not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of any of this communication is strictlyprohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.
Dungan Adams <[e-mail]>Thu, Aug 22, 2024 at 12:27 PM
To: Jack Batho <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, Scott Hanson <[e-mail]>, Mike Freese
<[e-mail]>, Jason Krebs <[e-mail]>, Dave Prey <[e-mail]>
Jack,
Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.
The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table 1 of the Emissions Impact
Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as part of a complete NOI. Based on the estimated emissions
in your NOI, you will need to conduct modeling and demonstrate compliance with all applicable national ambient air quality standards (NAAQS). I
recommend submitting a modeling protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is conducted correctly.
If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those to Dave or Jason and they
should be able to help.
Thanks,
Dungan
[Quoted text hidden]
2 attachments
ModelingProtocolForm.pdf
30K
EmissionsImpactAssessmentGuideline.pdf
325K
Dungan Adams <[e-mail]>Tue, Sep 3, 2024 at 9:34 AM
To: Jack Batho <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, Scott Hanson <[e-mail]>, Mike Freese
<[e-mail]>, Jason Krebs <[e-mail]>, Dave Prey <[e-mail]>
Hi Jack,
The DAQ received a second NOI submittal for Utah Flour LLC's new flour mill on Friday, August 30. From a quick look, the NOI appeared the same
or very similar to the one originally submitted on August 21. If there are changes from the original submittal could you please let me know what they
are?
Thanks,
Dungan
[Quoted text hidden]
kirk.arens <[e-mail]>Tue, Sep 3, 2024 at 9:37 AM
To: Dungan Adams <[e-mail]>, Jack Batho <[e-mail]>
Cc: Scott Hanson <[e-mail]>, Mike Freese <[e-mail]>, Jason Krebs <[e-mail]>, Dave Prey
<[e-mail]>
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r87915711123850…2/327
You don't often get email from [e-mail]. Learn why this is important
The system did not recognized the first one when I went to pay. I redid it so I could pay the fee. There should just be one but it was
the only way I could pay the fee

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 3, 2024 10:35 AM
To: Jack Batho <[e-mail]>
Cc: kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>; Mike Freese <[e-mail]>;
Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Sep 3, 2024 at 9:38 AM
To: "kirk.arens" <[e-mail]>
Cc: Jack Batho <[e-mail]>, Scott Hanson <[e-mail]>, Mike Freese <[e-mail]>, Jason Krebs
<[e-mail]>, Dave Prey <[e-mail]>
Got it. Thanks for letting me know.
Thanks,
Dungan
[Quoted text hidden]
Jason Krebs <[e-mail]>Tue, Sep 24, 2024 at 7:01 AM
To: Scott Hanson <[e-mail]>, Dungan Adams <[e-mail]>
Cc: Dave Prey <[e-mail]>, Jack Batho <[e-mail]>
Scott -
This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically, an AO should be issued
before construction even begins. You might want to try running this by Chad Gilgen who's the manager of the minor source compliance section. He
can be reached at [e-mail] and at 385-306-6500.
Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]
195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system operaons and would operate at
low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full future maximum operang
capacity. Only half of the facility is being constructed at this me so the emissions would easily be reduced in half and with some addional
flow reducons and adjustments the facility could operate below the modeling threshold. So inially the facility would be running at limited
capacity based on the future potenal. So would it be possible to operate inially at a lower capacity with calculated emission under the
modeling threshold? We would connue with the modeling work, but this may also allow us to beer define the model based on actual
performance of the system components.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r87915711123850…3/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r87915711123850…4/327
Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

[Quoted text hidden]
Dungan Adams <[e-mail]>Tue, Sep 24, 2024 at 9:33 AM
To: Scott Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>, Dave Prey <[e-mail]>, Jack Batho <[e-mail]>
Hi Scott,
As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior to any construction,
modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will say something similar about conducting
testing prior to receiving an AO.
The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-fugitive) and 18.23 tpy of
total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of
fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates would need to drop below these values and be enforceable from a
permitting perspective. If you think this is possible, we can take this approach, but you will need to resubmit the NOI with new emissions estimates.
Before the second half of the site is constructed, you will need to submit a second NOI for a minor modification and conduct modeling analysis.
Let me know if you have any questions.
Thanks,
Dungan
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[Quoted text hidden]
Jack Batho <[e-mail]>Wed, Oct 2, 2024 at 3:12 PM
To: Dungan Adams <[e-mail]>, Scott Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>, Dave Prey <[e-mail]>
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permit application to only cover
Phase I due to Phase II being more than a year out (greater than 14 months, but likely greater than 18). We have only included the
Phase I in this application. With that in mind, the client paid the $3,000 fee upon initial submittal, since we are modifying the
application, should they submit via the online portal or can we submit via email. We want to make sure that they are not paying
$3,000 twice since only one application will apply. Can you please provide insight on the correct submittal steps, or point us in the
correct direction?

Kind Regards,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r87915711123850…5/327
Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior to any construction,
modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will say something similar about conducting
testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-fugitive) and 18.23 tpy of
total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of
fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates would need to drop below these values and be enforceable from a
permitting perspective. If you think this is possible, we can take this approach, but you will need to resubmit the NOI with new emissions estimates.
Before the second half of the site is constructed, you will need to submit a second NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically, an AO should be issued
before construction even begins. You might want to try running this by Chad Gilgen who's the manager of the minor source compliance section.
He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r87915711123850…6/327

1. The facility would like to start loading grain at the facility before long to start tesng some of the system operaons and would operate
at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full future maximum
operang capacity. Only half of the facility is being constructed at this me so the emissions would easily be reduced in half and with some
addional flow reducons and adjustments the facility could operate below the modeling threshold. So inially the facility would be
running at limited capacity based on the future potenal. So would it be possible to operate inially at a lower capacity with calculated
emission under the modeling threshold? We would connue with the modeling work, but this may also allow us to beer define the model
based on actual performance of the system components.

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Dungan Adams <[e-mail]>Wed, Oct 2, 2024 at 3:19 PM
To: Jack Batho <[e-mail]>
Cc: Scott Hanson <[e-mail]>
Hi Jack,
If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay a second fee for a
revised NOI as it will be considered the same project.
The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my review and will reach out if I
have any questions about the project.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Oct 3, 2024 at 2:01 PM
To: Jack Batho <[e-mail]>
Cc: Scott Hanson <[e-mail]>
Hi Jack,
I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.
- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are produced from grain
milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building and then directed to through building roof
vents. I believe the building's roof vents exhaust to the atmosphere. How are you accounting for this in your PTE estimate?
- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis was included. I did not
see any BACT analysis in the document. Did you complete BACT analysis for all emission units and emitting processes? I can send some guidance if
that would be helpful.
Let me know if you have any questions.
Thanks,
Dungan
[Quoted text hidden]
Scott Hanson <[e-mail]>Fri, Oct 4, 2024 at 8:50 AM
To: Dungan Adams <[e-mail]>
Cc: Jack Batho <[e-mail]>
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feeds air back into the mill. The
reason for this design is to account for the need of extra airflow to reduce the likelihood of creating a vacuum in the mill. If the air was not
returned you would not be able to open a single door in the mill. With that in mind, in the pressurization room, there is a “burp” vent type system
that would allow some of the internal air to exit via the roof vent. All the baghouses (and cycle) vents associated with the milling are routed to the
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r87915711123850…7/327
aforementioned process. The 60/40 split is an approximate number based on a similar operating parameter at other mills throughout the portfolio.
The HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology (BACT) please provide
it. The facility equipment are being designed using current technologies and industry standards to minimize emissions. The facility is
construcng the mill in a way to reduce emissions consistent with using the Best Available Control Technology (BACT). We can provide a wrien
determinaon on the processes that are not currently equipped with a baghouse, but the reducon in emissions per the cost basis would not be
economically viable or appropriate for the reducon provided by the baghouse/cyclone. Addionally, since the emissions that are produced are
essenally flour product any emissions from the milling or cleaning processes are essenally lost product that could have been sold; therefore,
the facility has a vested capital interest in reducing emissions.

[Quoted text hidden]
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Dungan Adams <[e-mail]>Fri, Oct 4, 2024 at 11:34 AM
To: Scott Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Hi Scott,
Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the atmosphere
through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the particulate goes since a
substantial amount is routed indoors and the source is very close to reaching the modeling threshold.
As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the source has chosen to
use baghouses (generally the best control option for PM) for all of the primary emitting processes. The remaining processes that are uncontrolled or
controlled with lower efficiency filters produce such minor amounts of PM that it would be challenging to justify more expensive control. I will move
forward with my BACT write up without a formal written analysis.
Thanks,
Dungan
[Quoted text hidden]
Scott Hanson <[e-mail]>Fri, Oct 4, 2024 at 12:19 PM
To: Dungan Adams <[e-mail]>
Cc: Jack Batho <[e-mail]>
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within the building,
which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above this with 12.180 tpy of
PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere through the vents, which is on the
outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has very minor emissions in comparison.
[Quoted text hidden]
[Quoted text hidden]
Dungan Adams <[e-mail]>Fri, Oct 4, 2024 at 12:37 PM
To: Scott Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Understood. Thanks for the explanation.
Thanks,
Dungan
[Quoted text hidden]
Dungan Adams <[e-mail]>Wed, Oct 9, 2024 at 12:29 PM
To: Scott Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Hi Scott,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r87915711123850…8/327
I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and ~10 tpy of
PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems like a huge amount of
particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the building? If it is captured for reuse, how
does the capture process work?
Thanks,
Dungan
[Quoted text hidden]
Scott Hanson <[e-mail]>Thu, Oct 10, 2024 at 7:22 AM
To: Dungan Adams <[e-mail]>
Cc: Jack Batho <[e-mail]>
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for air handling
balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values due to several factors,
and the calculated values represent a worst case scenario. This system includes several small cyclones that are primarily used for material
transfer from the milling process prior to the baghouses but the emission reducon form these units is not included in the emission reducon
calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values used in the calculaons. Therefore, the
system will operate at higher efficiencies than the calculaons show and actual emissions would be less than these values. The flow from the
baghouses is discharged to certain interior areas of the building that will facilitate in the seling of parculates and the cleanup of parculates
for the recycling of the air. The parculate and process waste maer that is developed at this facility that cannot be used as flour and is used as
animal feed. Let me know if you have any other quesons.
[Quoted text hidden]
[Quoted text hidden]
Dungan Adams <[e-mail]>Thu, Oct 10, 2024 at 12:16 PM
To: Scott Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Scott,
The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of PM10 from
baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed outdoors and 25%
remain indoors.
The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be vented
inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25% indoor split was
used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.
Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the 75%
outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an example of a millthat operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent directly to the atmosphere.
From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements and I will need to
see stronger justification for this process before I am able to accept the calculations.
Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in more
detail.
Thanks,
Dungan
[Quoted text hidden]
Jack Batho <[e-mail]>Thu, Oct 10, 2024 at 12:30 PM
To: Dungan Adams <[e-mail]>, Scott Hanson <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, "kirk.arens" <[e-mail]>
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is part of the
team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B from the initial
application package, we revisited numerous calculations to better reflect what would be happening with the emissions associated
with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with this operation, but Ryan may be
better suited with explaining how this process works specifically. Essentially, similar to other mills, most of the recirculated air will
cause the particulate matter to settle on the floor within the mill. This waste settled material is constantly swept up and disposed of. It
is not uncommon for numerous tons to be disposed of in this fashion at similar sized mills across the country via the dumpster(garbage service) or other alternative green friendly options.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r87915711123850…9/327
As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the level
represented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we tried to limit step-
wise or series calculations and simply apply the manufacturer guaranteed emissions control rates submitted in the application as if
the baghouses were set up in a parallel formation. As you can see in the submittal there are three baghouses and at least onecyclone associated with the milling process. This vastly reduces emissions below the levels within the calculations provided. Asstated in previous emails any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested
interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for the facility
and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC and air flow
systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of PM10 from
baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed outdoors and 25%
remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be vented
inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25% indoor split was
used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the 75%
outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an example of a mill
that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent directly to the atmosphere.
From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements and I will need to
see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in more
detail.

Thanks,
Dungan
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…10/327

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for air
handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values due to
several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that are primarily used
for material transfer from the milling process prior to the baghouses but the emission reducon form these units is not included in the
emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values used in the
calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less than
these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in the seling of
parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste maer that is developed at this
facility that cannot be used as flour and is used as animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and ~10 tpy
of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems like a huge
amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the building? If it is captured for
reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within the
building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above this with
12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere through the vents,
which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has very minor
emissions in comparison.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…11/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the
atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the particulate
goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the source has
chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The remaining processes that
are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would be challenging to justify more
expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feeds air
back into the mill. The reason for this design is to account for the need of extra airflow to reduce the likelihood of creating a
vacuum in the mill. If the air was not returned you would not be able to open a single door in the mill. With that in mind, in
the pressurization room, there is a “burp” vent type system that would allow some of the internal air to exit via the roof vent.
All the baghouses (and cycle) vents associated with the milling are routed to the aforementioned process. The 60/40 splitis an approximate number based on a similar operating parameter at other mills throughout the portfolio. The HVACdesigner confirmed that this is even an overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology (BACT)
please provide it. The facility equipment are being designed using current technologies and industry standards to minimize emissions.
The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available Control Technology (BACT).
We can provide a wrien determinaon on the processes that are not currently equipped with a baghouse, but the reducon in
emissions per the cost basis would not be economically viable or appropriate for the reducon provided by the baghouse/cyclone.
Addionally, since the emissions that are produced are essenally flour product any emissions from the milling or cleaning processes
are essenally lost product that could have been sold; therefore, the facility has a vested capital interest in reducing emissions.

[Quoted text hidden]
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…12/327
You don't often get email from [e-mail]. Learn why this is important
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Dungan Adams <[e-mail]>Thu, Oct 24, 2024 at 3:03 PM
To: Jack Batho <[e-mail]>
Cc: Scott Hanson <[e-mail]>, "[e-mail]" <[e-mail]>, "kirk.arens" <[e-mail]>
Jack,
I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the original milling
calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or Ryan could provide a
better explanation that would be great.
I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why this aspect
of the milling calculations changed from the original NOI.
Thanks,
Dungan
[Quoted text hidden]
kirk.arens <[e-mail]>Tue, Oct 29, 2024 at 2:26 PM
To: Dungan Adams <[e-mail]>
Adam do you have me tomorrow to meet with me and Ryan to discuss. I really want to get this wrapped up as our target date is Late dec.

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,
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Dungan Adams <[e-mail]>Tue, Oct 29, 2024 at 3:28 PM
To: "kirk.arens" <[e-mail]>
Hi Kirk,
I can meet anytime after 1pm tomorrow. Let me know what works best for you and I will send out a meeting invitation.
Thanks,
Dungan
[Quoted text hidden]
Scott Hanson <[e-mail]>Fri, Nov 1, 2024 at 2:41 PM
To: Dungan Adams <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, "kirk.arens" <[e-mail]>, Jack Batho <[e-mail]>
Good afternoon, Dungan,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…13/327
After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our calculations
have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in the most recent
Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air flow
system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a room in the
interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being directed to other
building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified as emission point EP-RV
on the permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being emitted through the
roof vent as a starting point. This emission split was likely higher than required, but we were not certain of the distances and configuration from the
emission point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated at a rate of 75% emitted
through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent permit based on our
understanding that approximately 50% of this air would be circulated back into the building equipment and would not be exhausted. Therefore, the
75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process equipment that
draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and there is no changes with
these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system that determines how much of this
air is discharged to the exterior of the building and how much of this air is recirculated and directed through the RTUs and then back into the building.
In the colder winter months this system would recirculate 100% of this air back into the building to maintain heat, with additional heating provided by
the RTUs. In the summer months the system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for more cool air to be
drawn into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all equipment with the other
air flows being discharged (outdoors) through other emission points. Therefore, when this circulation system is closed during cooler periods an
additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a thermostat based on interior and
exterior temperatures and the following table was derived with monthly average temperatures for the facility area to calculate split between exhausted
and recirculated air. Based on this information the 40% to 60% split included in the permit is scientifically correct. Another temperature analysis was
performed with data from 2023 in the area of the facility and approximately 36% of the days in the year had a high and low daily temperature above
65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage of
exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…14/327
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built into these
emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emission reduction
factor for these units was included in the calculations. These units would be considered medium efficiency cyclones, which wouldhave a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions in the calculations could be cut
in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facility will beable to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest in reducingemissions and improving efficiency of the systems and assuring the emission equipment in place is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the original milling
calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or Ryan could provide a
better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why this aspect
of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is part of
the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B from the initial
application package, we revisited numerous calculations to better reflect what would be happening with the emissions associated
with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with this operation, but Ryan may be
better suited with explaining how this process works specifically. Essentially, similar to other mills, most of the recirculated air will
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…15/327
cause the particulate matter to settle on the floor within the mill. This waste settled material is constantly swept up and disposed
of. It is not uncommon for numerous tons to be disposed of in this fashion at similar sized mills across the country via the
dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the levelrepresented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we tried to limitstep-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates submitted in the
application as if the baghouses were set up in a parallel formation. As you can see in the submittal there are three baghouses and
at least one cyclone associated with the milling process. This vastly reduces emissions below the levels within the calculations
provided. As stated in previous emails any lost product or by-product is lost revenue for the facility and company as a whole, so
there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for the facility
and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC and air flowsystems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of PM10
from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed outdoors and
25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be vented
inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25% indoor split was
used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the 75%
outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an example of a mill
that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent directly to the
atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements and
I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in more
detail.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…16/327

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for air
handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values due to
several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that are primarily
used for material transfer from the milling process prior to the baghouses but the emission reducon form these units is not included in
the emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values used in the
calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less than
these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in the seling of
parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste maer that is developed at this
facility that cannot be used as flour and is used as animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and ~10
tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems like a
huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the building? If it is
captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within the
building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above this with
12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere through the
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…17/327
vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has very
minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the
atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the particulate
goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the source has
chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The remaining processes that
are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would be challenging to justify more
expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feeds airback into the mill. The reason for this design is to account for the need of extra airflow to reduce the likelihood of creatinga vacuum in the mill. If the air was not returned you would not be able to open a single door in the mill. With that in mind,
in the pressurization room, there is a “burp” vent type system that would allow some of the internal air to exit via the roof
vent. All the baghouses (and cycle) vents associated with the milling are routed to the aforementioned process. The
60/40 split is an approximate number based on a similar operating parameter at other mills throughout the portfolio. The
HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology (BACT)
please provide it. The facility equipment are being designed using current technologies and industry standards to minimize
emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available Control
Technology (BACT). We can provide a wrien determinaon on the processes that are not currently equipped with a baghouse, but
the reducon in emissions per the cost basis would not be economically viable or appropriate for the reducon provided by the
baghouse/cyclone. Addionally, since the emissions that are produced are essenally flour product any emissions from the milling
or cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested capital interest in
reducing emissions.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…18/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are produced
from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building and then directed to
through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you accounting for this in your PTE
estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis was
included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and emitting
processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay a
second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my review and
will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…19/327
We had a question about the permit application submittal, since the client will be revising the air permit application
to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but likely greater than
18). We have only included the Phase I in this application. With that in mind, the client paid the $3,000 fee upon
initial submittal, since we are modifying the application, should they submit via the online portal or can we submitvia email. We want to make sure that they are not paying $3,000 twice since only one application will apply. Canyou please provide insight on the correct submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior to
any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will say
something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-fugitive)
and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling analysis are:
15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates would need to
drop below these values and be enforceable from a permitting perspective. If you think this is possible, we can take this approach,
but you will need to resubmit the NOI with new emissions estimates. Before the second half of the site is constructed, you will
need to submit a second NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically, an AO
should be issued before construction even begins. You might want to try running this by Chad Gilgen who's the manager of the
minor source compliance section. He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…20/327
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system operaons
and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full future
maximum operang capacity. Only half of the facility is being constructed at this me so the emissions would easily be
reduced in half and with some addional flow reducons and adjustments the facility could operate below the modeling
threshold. So inially the facility would be running at limited capacity based on the future potenal. So would it be
possible to operate inially at a lower capacity with calculated emission under the modeling threshold? We would
connue with the modeling work, but this may also allow us to beer define the model based on actual performance of
the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table 1 of the
Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as part of a complete
NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and demonstrate compliance with all
applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling protocol to Dave Prey and
Jason Krebs (cc'd in this email) to help ensure the modeling is conducted correctly.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…21/327
If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those to
Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be a minor
typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modelingdepartment perform the modeling in house at the UDEQ or how does that specifically work? We haveperformed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a new
flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on the NOI
application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit (PTE) for PM10,
fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct modeling.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…22/327
If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will provide
some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any
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immediately by return email and delete the message and any attachments from your system.

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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kirk.arens <[e-mail]>Mon, Nov 4, 2024 at 2:20 PM
To: Dungan Adams <[e-mail]>
Was scott explanation what you were needing. Our timing is extremely tight and this permit is needing to be in place by early Dec to hit time line
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Sco Hanson <[e-mail]>
Sent: Friday, November 1, 2024 3:41:46 PM
To: Dungan Adams <[e-mail]>
Cc: [e-mail] <[e-mail]>; kirk.arens <[e-mail]>; Jack Batho
<[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our calculations
have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in the most recent
Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air flow
system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a room in the
interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being directed to other
building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified as emission point EP-RV
on the permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being emitted through the
roof vent as a starting point. This emission split was likely higher than required, but we were not certain of the distances and configuration from the
emission point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated at a rate of 75% emitted
through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent permit based on our
understanding that approximately 50% of this air would be circulated back into the building equipment and would not be exhausted. Therefore, the
75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process equipment that
draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and there is no changes with
these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system that determines how much of this
air is discharged to the exterior of the building and how much of this air is recirculated and directed through the RTUs and then back into the building.
In the colder winter months this system would recirculate 100% of this air back into the building to maintain heat, with additional heating provided by
the RTUs. In the summer months the system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for more cool air to be
drawn into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all equipment with the other
air flows being discharged (outdoors) through other emission points. Therefore, when this circulation system is closed during cooler periods an
additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a thermostat based on interior and
exterior temperatures and the following table was derived with monthly average temperatures for the facility area to calculate split between exhausted
and recirculated air. Based on this information the 40% to 60% split included in the permit is scientifically correct. Another temperature analysis was
performed with data from 2023 in the area of the facility and approximately 36% of the days in the year had a high and low daily temperature above
65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage of
exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…28/327
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built into these
emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emission reductionfactor for these units was included in the calculations. These units would be considered medium efficiency cyclones, which wouldhave a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions in the calculations could be cut
in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facility will beable to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest in reducingemissions and improving efficiency of the systems and assuring the emission equipment in place is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…29/327
From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the original milling
calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or Ryan could provide a
better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why this aspect
of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is part of
the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B from the initial
application package, we revisited numerous calculations to better reflect what would be happening with the emissions associated
with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with this operation, but Ryan may bebetter suited with explaining how this process works specifically. Essentially, similar to other mills, most of the recirculated air willcause the particulate matter to settle on the floor within the mill. This waste settled material is constantly swept up and disposedof. It is not uncommon for numerous tons to be disposed of in this fashion at similar sized mills across the country via the
dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the level
represented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we tried to limit
step-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates submitted in the
application as if the baghouses were set up in a parallel formation. As you can see in the submittal there are three baghouses and
at least one cyclone associated with the milling process. This vastly reduces emissions below the levels within the calculationsprovided. As stated in previous emails any lost product or by-product is lost revenue for the facility and company as a whole, sothere is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for the facility
and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC and air flow
systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…30/327
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of PM10
from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed outdoors and
25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be vented
inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25% indoor split was
used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the 75%
outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an example of a mill
that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent directly to the
atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements and
I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in more
detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for air
handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values due to
several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that are primarily
used for material transfer from the milling process prior to the baghouses but the emission reducon form these units is not included in
the emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values used in the
calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less than
these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in the seling of
parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste maer that is developed at this
facility that cannot be used as flour and is used as animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…31/327
From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and ~10
tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems like a
huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the building? If it is
captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within the
building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above this with
12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere through the
vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has very
minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the
atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the particulate
goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…32/327
As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the source has
chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The remaining processes that
are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would be challenging to justify more
expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feeds air
back into the mill. The reason for this design is to account for the need of extra airflow to reduce the likelihood of creating
a vacuum in the mill. If the air was not returned you would not be able to open a single door in the mill. With that in mind,in the pressurization room, there is a “burp” vent type system that would allow some of the internal air to exit via the roofvent. All the baghouses (and cycle) vents associated with the milling are routed to the aforementioned process. The60/40 split is an approximate number based on a similar operating parameter at other mills throughout the portfolio. The
HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology (BACT)
please provide it. The facility equipment are being designed using current technologies and industry standards to minimize
emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available Control
Technology (BACT). We can provide a wrien determinaon on the processes that are not currently equipped with a baghouse, but
the reducon in emissions per the cost basis would not be economically viable or appropriate for the reducon provided by the
baghouse/cyclone. Addionally, since the emissions that are produced are essenally flour product any emissions from the milling
or cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested capital interest in
reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are produced
from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building and then directed to
through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you accounting for this in your PTE
estimate?

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…33/327
- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis was
included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and emitting
processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay a
second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my review and
will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permit applicationto only cover Phase I due to Phase II being more than a year out (greater than 14 months, but likely greater than
18). We have only included the Phase I in this application. With that in mind, the client paid the $3,000 fee upon
initial submittal, since we are modifying the application, should they submit via the online portal or can we submit
via email. We want to make sure that they are not paying $3,000 twice since only one application will apply. Can
you please provide insight on the correct submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…34/327

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior to
any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will say
something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-fugitive)
and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling analysis are:
15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates would need to
drop below these values and be enforceable from a permitting perspective. If you think this is possible, we can take this approach,
but you will need to resubmit the NOI with new emissions estimates. Before the second half of the site is constructed, you will
need to submit a second NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically, an AO
should be issued before construction even begins. You might want to try running this by Chad Gilgen who's the manager of the
minor source compliance section. He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system operaons
and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full future
maximum operang capacity. Only half of the facility is being constructed at this me so the emissions would easily be
reduced in half and with some addional flow reducons and adjustments the facility could operate below the modeling
threshold. So inially the facility would be running at limited capacity based on the future potenal. So would it be
possible to operate inially at a lower capacity with calculated emission under the modeling threshold? We would
connue with the modeling work, but this may also allow us to beer define the model based on actual performance of
the system components.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…35/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table 1 of the
Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as part of a complete
NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and demonstrate compliance with all
applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling protocol to Dave Prey and
Jason Krebs (cc'd in this email) to help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those to
Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be a minortypo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modeling
department perform the modeling in house at the UDEQ or how does that specifically work? We have
performed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…36/327

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a new
flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on the NOI
application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit (PTE) for PM10,
fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will provide
some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…37/327
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential.
If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any
use and/or dissemination of any of this communication is strictly prohibited. If you have received this communication in error, notify the sender
immediately by return email and delete the message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…38/327
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Environmental Engineer | Minor NSR Section
M: [phone]
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…39/327
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Environmental Engineer | Minor NSR Section
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…40/327
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M: [phone]
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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airquality.utah.gov

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Dungan Adams <[e-mail]>Mon, Nov 4, 2024 at 2:41 PM
To: "kirk.arens" <[e-mail]>
Hi Kirk,
I will be reviewing this project with my manager tomorrow when they are back in the office. My main concern is how to enforce the 60-40 indoor-
outdoor split in through permit conditions. I will let you know if I have any other questions or concerns after this discussion.
Receiving an Approval Order (AO) for this project by early December is unrealistic. The permit still needs to be reviewed by modeling, compliance,
and management. Once it has been reviewed by these parties and by you (the source) it will enter a 30-day public comment period. Were the permit
draft finalized and sent for review today, I would estimate ~2 months before you receive an AO. The justification for the grain milling emission
calculations is critical in determining whether modeling analysis is required for this project or not. I cannot finalize my draft until the DAQ has
accepted the justification provided.
Let me know if you have any questions.
Thanks,
Dungan
On Mon, Nov 4, 2024 at 2:20 PM kirk.arens <[e-mail]> wrote:
Was scott explanation what you were needing. Our timing is extremely tight and this permit is needing to be in place by early Dec to hit time line
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Sco Hanson <[e-mail]>
Sent: Friday, November 1, 2024 3:41:46 PM
To: Dungan Adams <[e-mail]>
Cc: [e-mail] <[e-mail]>; kirk.arens <[e-mail]>; Jack Batho
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…42/327
<[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our calculations
have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in the most recent
Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air flow
system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a room in the
interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being directed to other
building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified as emission point EP-
RV on the permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being emitted
through the roof vent as a starting point. This emission split was likely higher than required, but we were not certain of the distances and
configuration from the emission point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated
at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent
permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and would not be
exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process equipment
that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and there is no changes
with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system that determines how much
of this air is discharged to the exterior of the building and how much of this air is recirculated and directed through the RTUs and then back into the
building. In the colder winter months this system would recirculate 100% of this air back into the building to maintain heat, with additional heating
provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for
more cool air to be drawn into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all
equipment with the other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation system is closed
during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a
thermostat based on interior and exterior temperatures and the following table was derived with monthly average temperatures for the facility area
to calculate split between exhausted and recirculated air. Based on this information the 40% to 60% split included in the permit is scientifically
correct. Another temperature analysis was performed with data from 2023 in the area of the facility and approximately 36% of the days in the year
had a high and low daily temperature above 65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in
for cooling. In both cases the percentage of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…43/327
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built into
these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emission reduction
factor for these units was included in the calculations. These units would be considered medium efficiency cyclones, which wouldhave a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions in the calculations could be
cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facility will
be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest in reducingemissions and improving efficiency of the systems and assuring the emission equipment in place is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the original
milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or Ryan could
provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why this
aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…44/327

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is part of
the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B from the initial
application package, we revisited numerous calculations to better reflect what would be happening with the emissionsassociated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with this operation, butRyan may be better suited with explaining how this process works specifically. Essentially, similar to other mills, most of therecirculated air will cause the particulate matter to settle on the floor within the mill. This waste settled material is constantly
swept up and disposed of. It is not uncommon for numerous tons to be disposed of in this fashion at similar sized mills across
the country via the dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the level
represented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we tried to limit
step-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates submitted in the
application as if the baghouses were set up in a parallel formation. As you can see in the submittal there are three baghousesand at least one cyclone associated with the milling process. This vastly reduces emissions below the levels within thecalculations provided. As stated in previous emails any lost product or by-product is lost revenue for the facility and company asa whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for the
facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC and
air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of PM10
from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed outdoors
and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be
vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25% indoor
split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the
75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an example
of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent directly to the
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…45/327
atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements
and I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in more
detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for air
handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values due to
several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that are primarily
used for material transfer from the milling process prior to the baghouses but the emission reducon form these units is not included in
the emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values used in
the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less
than these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in the seling of
parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste maer that is developed at this
facility that cannot be used as flour and is used as animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and
~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems like
a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the building? If it is
captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…46/327

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within the
building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above this
with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere through
the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has
very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the
atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the
particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the source
has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The remaining
processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would be challenging
to justify more expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feeds airback into the mill. The reason for this design is to account for the need of extra airflow to reduce the likelihood ofcreating a vacuum in the mill. If the air was not returned you would not be able to open a single door in the mill. With
that in mind, in the pressurization room, there is a “burp” vent type system that would allow some of the internal air to
exit via the roof vent. All the baghouses (and cycle) vents associated with the milling are routed to the aforementioned
process. The 60/40 split is an approximate number based on a similar operating parameter at other mills throughout
the portfolio. The HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the
system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology (BACT)
please provide it. The facility equipment are being designed using current technologies and industry standards to minimize
emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available Control
Technology (BACT). We can provide a wrien determinaon on the processes that are not currently equipped with a baghouse,
but the reducon in emissions per the cost basis would not be economically viable or appropriate for the reducon provided by
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…47/327
the baghouse/cyclone. Addionally, since the emissions that are produced are essenally flour product any emissions from the
milling or cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested capital
interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are
produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building and
then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you accounting for
this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis was
included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and emitting
processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay a
second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my review
and will reach out if I have any questions about the project.

Thanks,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…48/327
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permit application
to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but likely greater than18). We have only included the Phase I in this application. With that in mind, the client paid the $3,000 fee uponinitial submittal, since we are modifying the application, should they submit via the online portal or can we submitvia email. We want to make sure that they are not paying $3,000 twice since only one application will apply. Can
you please provide insight on the correct submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior to
any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will say
something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-
fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling
analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates
would need to drop below these values and be enforceable from a permitting perspective. If you think this is possible, we can
take this approach, but you will need to resubmit the NOI with new emissions estimates. Before the second half of the site is
constructed, you will need to submit a second NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…49/327
This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically, an
AO should be issued before construction even begins. You might want to try running this by Chad Gilgen who's the manager
of the minor source compliance section. He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full
future maximum operang capacity. Only half of the facility is being constructed at this me so the emissions would
easily be reduced in half and with some addional flow reducons and adjustments the facility could operate below
the modeling threshold. So inially the facility would be running at limited capacity based on the future potenal. So
would it be possible to operate inially at a lower capacity with calculated emission under the modeling threshold? We
would connue with the modeling work, but this may also allow us to beer define the model based on actual
performance of the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…50/327

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table 1 of
the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as part of a
complete NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and demonstrate
compliance with all applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling
protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those to
Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be a minor
typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modeling
department perform the modeling in house at the UDEQ or how does that specifically work? We haveperformed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…51/327
The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a new
flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on the
NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit (PTE) for
PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will provide
some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby
notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have received this communication in error, notify
the sender immediately by return email and delete the message and any attachments from your system.

--

Dungan Adams
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…52/327
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential.
If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any
use and/or dissemination of any of this communication is strictly prohibited. If you have received this communication in error, notify the sender
immediately by return email and delete the message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…53/327
Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader
of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of
any of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the
message and any attachments from your system.

--

Dungan Adams
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…54/327
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of
the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of any of
this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and
any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…55/327
airquality.utah.gov

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attachments from your system.

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of the
message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of any of this
communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and any
attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…56/327
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of the message is
not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of any of this communication is strictlyprohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
kirk.arens <[e-mail]>Mon, Nov 4, 2024 at 2:50 PM
To: Dungan Adams <[e-mail]>
Is there something that we can for just testing or systems and equipment
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Monday, November 4, 2024 3:41:56 PM
To: kirk.arens <[e-mail]>
Subject: Re: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,
I will be reviewing this project with my manager tomorrow when they are back in the office. My main concern is how to enforce the 60-40 indoor-
outdoor split in through permit conditions. I will let you know if I have any other questions or concerns after this discussion.
Receiving an Approval Order (AO) for this project by early December is unrealistic. The permit still needs to be reviewed by modeling, compliance,
and management. Once it has been reviewed by these parties and by you (the source) it will enter a 30-day public comment period. Were the permit
draft finalized and sent for review today, I would estimate ~2 months before you receive an AO. The justification for the grain milling emission
calculations is critical in determining whether modeling analysis is required for this project or not. I cannot finalize my draft until the DAQ has
accepted the justification provided.
Let me know if you have any questions.
Thanks,
Dungan
On Mon, Nov 4, 2024 at 2:20 PM kirk.arens <[e-mail]> wrote:
Was scott explanation what you were needing. Our timing is extremely tight and this permit is needing to be in place by early Dec to hit time line
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Sco Hanson <[e-mail]>
Sent: Friday, November 1, 2024 3:41:46 PM
To: Dungan Adams <[e-mail]>
Cc: [e-mail] <[e-mail]>; kirk.arens <[e-mail]>; Jack Batho
<[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good afternoon, Dungan,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…57/327

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our calculations
have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in the most recent
Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air flow
system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a room in the
interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being directed to other
building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified as emission point EP-
RV on the permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being emitted
through the roof vent as a starting point. This emission split was likely higher than required, but we were not certain of the distances and
configuration from the emission point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated
at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent
permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and would not be
exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process equipment
that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and there is no changes
with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system that determines how much
of this air is discharged to the exterior of the building and how much of this air is recirculated and directed through the RTUs and then back into the
building. In the colder winter months this system would recirculate 100% of this air back into the building to maintain heat, with additional heating
provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for
more cool air to be drawn into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all
equipment with the other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation system is closed
during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a
thermostat based on interior and exterior temperatures and the following table was derived with monthly average temperatures for the facility area
to calculate split between exhausted and recirculated air. Based on this information the 40% to 60% split included in the permit is scientifically
correct. Another temperature analysis was performed with data from 2023 in the area of the facility and approximately 36% of the days in the year
had a high and low daily temperature above 65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in
for cooling. In both cases the percentage of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…58/327
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built into
these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emission reduction
factor for these units was included in the calculations. These units would be considered medium efficiency cyclones, which wouldhave a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions in the calculations could be
cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facility willbe able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest in reducingemissions and improving efficiency of the systems and assuring the emission equipment in place is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the original
milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or Ryan could
provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why this
aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is part of
the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B from the initial
application package, we revisited numerous calculations to better reflect what would be happening with the emissions
associated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with this operation, but
Ryan may be better suited with explaining how this process works specifically. Essentially, similar to other mills, most of the
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…59/327
recirculated air will cause the particulate matter to settle on the floor within the mill. This waste settled material is constantly
swept up and disposed of. It is not uncommon for numerous tons to be disposed of in this fashion at similar sized mills across
the country via the dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the levelrepresented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we tried to limitstep-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates submitted in the
application as if the baghouses were set up in a parallel formation. As you can see in the submittal there are three baghouses
and at least one cyclone associated with the milling process. This vastly reduces emissions below the levels within the
calculations provided. As stated in previous emails any lost product or by-product is lost revenue for the facility and company as
a whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for the
facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC andair flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of PM10
from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed outdoors
and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be
vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25% indoor
split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the
75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an example
of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent directly to the
atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements
and I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in more
detail.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…60/327

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for air
handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values due to
several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that are primarily
used for material transfer from the milling process prior to the baghouses but the emission reducon form these units is not included in
the emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values used in
the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less
than these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in the seling of
parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste maer that is developed at this
facility that cannot be used as flour and is used as animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and
~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems like
a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the building? If it is
captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within the
building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above this
with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere through
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…61/327
the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has
very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the
atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the
particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the source
has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The remaining
processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would be challenging
to justify more expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feeds airback into the mill. The reason for this design is to account for the need of extra airflow to reduce the likelihood ofcreating a vacuum in the mill. If the air was not returned you would not be able to open a single door in the mill. With
that in mind, in the pressurization room, there is a “burp” vent type system that would allow some of the internal air to
exit via the roof vent. All the baghouses (and cycle) vents associated with the milling are routed to the aforementioned
process. The 60/40 split is an approximate number based on a similar operating parameter at other mills throughout
the portfolio. The HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the
system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology (BACT)
please provide it. The facility equipment are being designed using current technologies and industry standards to minimize
emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available Control
Technology (BACT). We can provide a wrien determinaon on the processes that are not currently equipped with a baghouse,
but the reducon in emissions per the cost basis would not be economically viable or appropriate for the reducon provided by
the baghouse/cyclone. Addionally, since the emissions that are produced are essenally flour product any emissions from the
milling or cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested capital
interest in reducing emissions.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…62/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are
produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building and
then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you accounting for
this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis was
included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and emitting
processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay a
second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my review
and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…63/327
We had a question about the permit application submittal, since the client will be revising the air permit application
to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but likely greater than
18). We have only included the Phase I in this application. With that in mind, the client paid the $3,000 fee upon
initial submittal, since we are modifying the application, should they submit via the online portal or can we submitvia email. We want to make sure that they are not paying $3,000 twice since only one application will apply. Canyou please provide insight on the correct submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior to
any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will say
something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-
fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling
analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates
would need to drop below these values and be enforceable from a permitting perspective. If you think this is possible, we can
take this approach, but you will need to resubmit the NOI with new emissions estimates. Before the second half of the site is
constructed, you will need to submit a second NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically, an
AO should be issued before construction even begins. You might want to try running this by Chad Gilgen who's the manager
of the minor source compliance section. He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full
future maximum operang capacity. Only half of the facility is being constructed at this me so the emissions would
easily be reduced in half and with some addional flow reducons and adjustments the facility could operate below
the modeling threshold. So inially the facility would be running at limited capacity based on the future potenal. So
would it be possible to operate inially at a lower capacity with calculated emission under the modeling threshold? We
would connue with the modeling work, but this may also allow us to beer define the model based on actual
performance of the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table 1 of
the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as part of a
complete NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and demonstrate
compliance with all applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling
protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is conducted correctly.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…65/327
If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those to
Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be a minor
typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modelingdepartment perform the modeling in house at the UDEQ or how does that specifically work? We haveperformed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a new
flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on the
NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit (PTE) for
PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct modeling.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will provide
some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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M: [phone]
airquality.utah.gov
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of the message isnot the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of any of this communication is strictly
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
Dungan Adams <[e-mail]>Tue, Nov 5, 2024 at 2:46 PM
To: Scott Hanson <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, "kirk.arens" <[e-mail]>, Jack Batho <[e-mail]>
Hi Scott,
I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently calculated,
the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without exceeding modeling thresholds.
Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a good way to enforce this without requiring a lot
of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the facility from exhausting greater than 40% of the baghouse
emissions to the atmosphere. Richmond could experience an unusually long summer and the facility could exhaust for a greater period than what is
anticipated. The permit would also need to ensure that 100% of the recirculated baghouse exhaust remains and settles inside the building and ~18
TPY of particulate settling inside facility still seems problematic to me.
I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more accurate
estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:
0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling baghouse by half.
Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control efficiencies are used across the
facility, if we conservatively assume that all of the baghouse emissions are exhausted to the atmosphere, the facility will remain below the modeling
threshold. With this approach this is no need to try and enforce the 60-40 split are ensure that 100% of the recirculated air remains inside the facility.
The facility would be able to use their HVAC system with full flexibility and exhaust as much or as little of the grain milling baghouse exhaust as
necessary.
What are your thoughts on this approach?
Thanks,
Dungan
On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our calculations
have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in the most recent
Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air flow
system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a room in the
interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being directed to other
building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified as emission point EP-
RV on the permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being emitted
through the roof vent as a starting point. This emission split was likely higher than required, but we were not certain of the distances and
configuration from the emission point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated
at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent
permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and would not be
exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process equipment
that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and there is no changes
with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system that determines how much
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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of this air is discharged to the exterior of the building and how much of this air is recirculated and directed through the RTUs and then back into the
building. In the colder winter months this system would recirculate 100% of this air back into the building to maintain heat, with additional heating
provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for
more cool air to be drawn into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all
equipment with the other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation system is closed
during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a
thermostat based on interior and exterior temperatures and the following table was derived with monthly average temperatures for the facility area
to calculate split between exhausted and recirculated air. Based on this information the 40% to 60% split included in the permit is scientifically
correct. Another temperature analysis was performed with data from 2023 in the area of the facility and approximately 36% of the days in the year
had a high and low daily temperature above 65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in
for cooling. In both cases the percentage of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built into
these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emission reductionfactor for these units was included in the calculations. These units would be considered medium efficiency cyclones, which wouldhave a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions in the calculations could be
cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facility will
be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest in reducingemissions and improving efficiency of the systems and assuring the emission equipment in place is operating a peak efficiency.
Let us know if you have any further questions.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…73/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the original
milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or Ryan could
provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why this
aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is part ofthe team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B from the initial
application package, we revisited numerous calculations to better reflect what would be happening with the emissions
associated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with this operation, but
Ryan may be better suited with explaining how this process works specifically. Essentially, similar to other mills, most of the
recirculated air will cause the particulate matter to settle on the floor within the mill. This waste settled material is constantly
swept up and disposed of. It is not uncommon for numerous tons to be disposed of in this fashion at similar sized mills across
the country via the dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the levelrepresented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we tried to limitstep-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates submitted in the
application as if the baghouses were set up in a parallel formation. As you can see in the submittal there are three baghouses
and at least one cyclone associated with the milling process. This vastly reduces emissions below the levels within the
calculations provided. As stated in previous emails any lost product or by-product is lost revenue for the facility and company as
a whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for the
facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC andair flow systems used at the facility.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of PM10
from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed outdoors
and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be
vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25% indoor
split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the
75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an example
of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent directly to the
atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements
and I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in more
detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for air
handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values due to
several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that are primarily
used for material transfer from the milling process prior to the baghouses but the emission reducon form these units is not included in
the emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values used in
the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less
than these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in the seling of
parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste maer that is developed at this
facility that cannot be used as flour and is used as animal feed. Let me know if you have any other quesons.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and
~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems like
a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the building? If it is
captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within the
building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above this
with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere through
the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has
very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the
atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the
particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the source
has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The remaining
processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would be challenging
to justify more expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feeds airback into the mill. The reason for this design is to account for the need of extra airflow to reduce the likelihood of
creating a vacuum in the mill. If the air was not returned you would not be able to open a single door in the mill. With
that in mind, in the pressurization room, there is a “burp” vent type system that would allow some of the internal air to
exit via the roof vent. All the baghouses (and cycle) vents associated with the milling are routed to the aforementioned
process. The 60/40 split is an approximate number based on a similar operating parameter at other mills throughout
the portfolio. The HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the
system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology (BACT)
please provide it. The facility equipment are being designed using current technologies and industry standards to minimize
emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available Control
Technology (BACT). We can provide a wrien determinaon on the processes that are not currently equipped with a baghouse,
but the reducon in emissions per the cost basis would not be economically viable or appropriate for the reducon provided by
the baghouse/cyclone. Addionally, since the emissions that are produced are essenally flour product any emissions from the
milling or cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested capital
interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…77/327

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are
produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building and
then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you accounting for
this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis was
included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and emitting
processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay a
second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my review
and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permit applicationto only cover Phase I due to Phase II being more than a year out (greater than 14 months, but likely greater than
18). We have only included the Phase I in this application. With that in mind, the client paid the $3,000 fee upon
initial submittal, since we are modifying the application, should they submit via the online portal or can we submit
via email. We want to make sure that they are not paying $3,000 twice since only one application will apply. Can
you please provide insight on the correct submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…78/327
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior to
any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will say
something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-
fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling
analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates
would need to drop below these values and be enforceable from a permitting perspective. If you think this is possible, we can
take this approach, but you will need to resubmit the NOI with new emissions estimates. Before the second half of the site is
constructed, you will need to submit a second NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically, an
AO should be issued before construction even begins. You might want to try running this by Chad Gilgen who's the manager
of the minor source compliance section. He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…79/327
1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full
future maximum operang capacity. Only half of the facility is being constructed at this me so the emissions would
easily be reduced in half and with some addional flow reducons and adjustments the facility could operate below
the modeling threshold. So inially the facility would be running at limited capacity based on the future potenal. So
would it be possible to operate inially at a lower capacity with calculated emission under the modeling threshold? We
would connue with the modeling work, but this may also allow us to beer define the model based on actual
performance of the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table 1 of
the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as part of a
complete NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and demonstrate
compliance with all applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling
protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those to
Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be a minor
typo, our apologies.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…80/327
Can you please give us some guidance and direction to the modeling department. Does the modeling
department perform the modeling in house at the UDEQ or how does that specifically work? We have
performed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a new
flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on the
NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit (PTE) for
PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will provide
some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Scott Hanson <[e-mail]>Wed, Nov 6, 2024 at 10:10 AM
To: Dungan Adams <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, "kirk.arens" <[e-mail]>, Jack Batho <[e-mail]>
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the cyclones as this
will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons Spreadsheet with
highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the cyclones to the control efficiency
for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100% outdoors and 0% recirculated indoors as a worst case
scenario and would provide an addional emission safety factor. Of note the air that is recirculated back into the building flows through
addional filters before being discharged back into the building to collect parculate maer and further reduce interior emissions and the
buildup of parculate maer within the building that needs to be cleaned up. Let us know if you have any quesons or need any addional
informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently calculated,
the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without exceeding modeling thresholds.
Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a good way to enforce this without requiring a lot
of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the facility from exhausting greater than 40% of the baghouse
emissions to the atmosphere. Richmond could experience an unusually long summer and the facility could exhaust for a greater period than what is
anticipated. The permit would also need to ensure that 100% of the recirculated baghouse exhaust remains and settles inside the building and ~18
TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more accurate
estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling baghouse by half.
Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control efficiencies are used across the
facility, if we conservatively assume that all of the baghouse emissions are exhausted to the atmosphere, the facility will remain below the modeling
threshold. With this approach this is no need to try and enforce the 60-40 split are ensure that 100% of the recirculated air remains inside the facility.
The facility would be able to use their HVAC system with full flexibility and exhaust as much or as little of the grain milling baghouse exhaust as
necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our calculations
have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in the most recent
Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air flow
system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a room in the
interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being directed to other
building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified as emission point EP-
RV on the permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being emitted
through the roof vent as a starting point. This emission split was likely higher than required, but we were not certain of the distances and
configuration from the emission point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated
at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent
permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and would not be
exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process equipment
that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and there is no
changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system that determines
how much of this air is discharged to the exterior of the building and how much of this air is recirculated and directed through the RTUs and then
back into the building. In the colder winter months this system would recirculate 100% of this air back into the building to maintain heat, with
additional heating provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100% of the airflow to the
exterior to allow for more cool air to be drawn into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is
drawn through all equipment with the other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation
system is closed during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC valving system is
controlled by a thermostat based on interior and exterior temperatures and the following table was derived with monthly average temperatures for
the facility area to calculate split between exhausted and recirculated air. Based on this information the 40% to 60% split included in the permit is
scientifically correct. Another temperature analysis was performed with data from 2023 in the area of the facility and approximately 36% of the
days in the year had a high and low daily temperature above 65 degrees where the HVAC system would discharge more air to allow for additional
air to be drawn in for cooling. In both cases the percentage of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built into
these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emissionreduction factor for these units was included in the calculations. These units would be considered medium efficiency cyclones,which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions in the
calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facility willbe able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest inreducing emissions and improving efficiency of the systems and assuring the emission equipment in place is operating a peakefficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…89/327
I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the original
milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or Ryan could
provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why this
aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is part of
the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B from the initial
application package, we revisited numerous calculations to better reflect what would be happening with the emissions
associated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with this operation, but
Ryan may be better suited with explaining how this process works specifically. Essentially, similar to other mills, most of the
recirculated air will cause the particulate matter to settle on the floor within the mill. This waste settled material is constantly
swept up and disposed of. It is not uncommon for numerous tons to be disposed of in this fashion at similar sized mills across
the country via the dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the levelrepresented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we tried to limit
step-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates submitted in the
application as if the baghouses were set up in a parallel formation. As you can see in the submittal there are three baghouses
and at least one cyclone associated with the milling process. This vastly reduces emissions below the levels within the
calculations provided. As stated in previous emails any lost product or by-product is lost revenue for the facility and company as
a whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for thefacility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC andair flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…90/327

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of PM10
from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed outdoors
and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be
vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25% indoor
split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the
75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an example
of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent directly to the
atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements
and I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in more
detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for air
handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values due to
several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that are primarily
used for material transfer from the milling process prior to the baghouses but the emission reducon form these units is not included in
the emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values used in
the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less
than these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in the seling of
parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste maer that is developed at this
facility that cannot be used as flour and is used as animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…91/327
I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and
~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems like
a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the building? If it is
captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within the
building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above this
with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere through
the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has
very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the
atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the
particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the source
has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The remaining
processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would be challenging
to justify more expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…92/327

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feeds airback into the mill. The reason for this design is to account for the need of extra airflow to reduce the likelihood ofcreating a vacuum in the mill. If the air was not returned you would not be able to open a single door in the mill. With
that in mind, in the pressurization room, there is a “burp” vent type system that would allow some of the internal air to
exit via the roof vent. All the baghouses (and cycle) vents associated with the milling are routed to the aforementioned
process. The 60/40 split is an approximate number based on a similar operating parameter at other mills throughout
the portfolio. The HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the
system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology (BACT)
please provide it. The facility equipment are being designed using current technologies and industry standards to minimize
emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available Control
Technology (BACT). We can provide a wrien determinaon on the processes that are not currently equipped with a baghouse,
but the reducon in emissions per the cost basis would not be economically viable or appropriate for the reducon provided by
the baghouse/cyclone. Addionally, since the emissions that are produced are essenally flour product any emissions from the
milling or cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested capital
interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are
produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building and
then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you accounting for
this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis was
included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and emitting
processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…93/327
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay a
second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my review
and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permit
application to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but likely
greater than 18). We have only included the Phase I in this application. With that in mind, the client paid the
$3,000 fee upon initial submittal, since we are modifying the application, should they submit via the online portal
or can we submit via email. We want to make sure that they are not paying $3,000 twice since only one
application will apply. Can you please provide insight on the correct submittal steps, or point us in the correct
direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior to
any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will say
something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-
fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…94/327
analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates
would need to drop below these values and be enforceable from a permitting perspective. If you think this is possible, we can
take this approach, but you will need to resubmit the NOI with new emissions estimates. Before the second half of the site is
constructed, you will need to submit a second NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically, an
AO should be issued before construction even begins. You might want to try running this by Chad Gilgen who's the manager
of the minor source compliance section. He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full
future maximum operang capacity. Only half of the facility is being constructed at this me so the emissions would
easily be reduced in half and with some addional flow reducons and adjustments the facility could operate below
the modeling threshold. So inially the facility would be running at limited capacity based on the future potenal. So
would it be possible to operate inially at a lower capacity with calculated emission under the modeling threshold?
We would connue with the modeling work, but this may also allow us to beer define the model based on actual
performance of the system components.

Scott Hanson, PE
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…95/327
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table 1 of
the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as part of a
complete NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and demonstrate
compliance with all applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling
protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those to
Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be a minor
typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modelingdepartment perform the modeling in house at the UDEQ or how does that specifically work? We haveperformed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r8791571112385…96/327
From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a new
flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on the
NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit (PTE) for
PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will provide
some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
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airquality.utah.gov

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airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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3 attachments
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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image002.jpg
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image003.jpg
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Att 8 PHM Brands Richmond Calculations 11.06.24.pdf
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Dungan Adams <[e-mail]>Wed, Nov 6, 2024 at 10:21 AM
To: Scott Hanson <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, "kirk.arens" <[e-mail]>, Jack Batho <[e-mail]>
Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.
Thanks,
Dungan
On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the cyclones as this
will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons Spreadsheet with
highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the cyclones to the control
efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100% outdoors and 0% recirculated indoors as
a worst case scenario and would provide an addional emission safety factor. Of note the air that is recirculated back into the building flows
through addional filters before being discharged back into the building to collect parculate maer and further reduce interior emissions and
the buildup of parculate maer within the building that needs to be cleaned up. Let us know if you have any quesons or need any
addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently calculated,
the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without exceeding modeling
thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a good way to enforce this without
requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the facility from exhausting greater than 40% of
the baghouse emissions to the atmosphere. Richmond could experience an unusually long summer and the facility could exhaust for a greater
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…103/327
period than what is anticipated. The permit would also need to ensure that 100% of the recirculated baghouse exhaust remains and settles inside
the building and ~18 TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more accurate
estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling baghouse by half.
Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control efficiencies are used across the
facility, if we conservatively assume that all of the baghouse emissions are exhausted to the atmosphere, the facility will remain below the modeling
threshold. With this approach this is no need to try and enforce the 60-40 split are ensure that 100% of the recirculated air remains inside the
facility. The facility would be able to use their HVAC system with full flexibility and exhaust as much or as little of the grain milling baghouse exhaust
as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our
calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in the
most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air flow
system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a room in the
interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being directed to
other building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified as emission
point EP-RV on the permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being
emitted through the roof vent as a starting point. This emission split was likely higher than required, but we were not certain of the distances and
configuration from the emission point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be
recirculated at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the
most recent permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and
would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process
equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and there
is no changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system that
determines how much of this air is discharged to the exterior of the building and how much of this air is recirculated and directed through the
RTUs and then back into the building. In the colder winter months this system would recirculate 100% of this air back into the building to
maintain heat, with additional heating provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100% of
the airflow to the exterior to allow for more cool air to be drawn into the building. This recirculation system accounts for 45,000 CFM of the total
80,000 CFM that is drawn through all equipment with the other air flows being discharged (outdoors) through other emission points. Therefore,
when this circulation system is closed during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The
HVAC valving system is controlled by a thermostat based on interior and exterior temperatures and the following table was derived with monthly
average temperatures for the facility area to calculate split between exhausted and recirculated air. Based on this information the 40% to 60%
split included in the permit is scientifically correct. Another temperature analysis was performed with data from 2023 in the area of the facility and
approximately 36% of the days in the year had a high and low daily temperature above 65 degrees where the HVAC system would discharge
more air to allow for additional air to be drawn in for cooling. In both cases the percentage of exhausted air flow would be expected to be higher
than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…104/327
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built into
these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emissionreduction factor for these units was included in the calculations. These units would be considered medium efficiency cyclones,which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions in the
calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facility
will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest inreducing emissions and improving efficiency of the systems and assuring the emission equipment in place is operating a peakefficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…105/327
From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the original
milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or Ryan could
provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why this
aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is part
of the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B from the
initial application package, we revisited numerous calculations to better reflect what would be happening with the emissions
associated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with this operation,but Ryan may be better suited with explaining how this process works specifically. Essentially, similar to other mills, most ofthe recirculated air will cause the particulate matter to settle on the floor within the mill. This waste settled material isconstantly swept up and disposed of. It is not uncommon for numerous tons to be disposed of in this fashion at similar sized
mills across the country via the dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the level
represented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we tried to limit
step-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates submitted in the
application as if the baghouses were set up in a parallel formation. As you can see in the submittal there are three baghouses
and at least one cyclone associated with the milling process. This vastly reduces emissions below the levels within thecalculations provided. As stated in previous emails any lost product or by-product is lost revenue for the facility and companyas a whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for the
facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC
and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…106/327
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of
PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed
outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be
vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25%
indoor split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the
75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an
example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent
directly to the atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid modeling
requirements and I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in
more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for
air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values
due to several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that are
primarily used for material transfer from the milling process prior to the baghouses but the emission reducon form these units is not
included in the emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the
values used in the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and actual
emissions would be less than these values. The flow from the baghouses is discharged to certain interior areas of the building that will
facilitate in the seling of parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste
maer that is developed at this facility that cannot be used as flour and is used as animal feed. Let me know if you have any other
quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…107/327
From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and
~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems
like a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the
building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within
the building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above
this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere
through the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit
have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the
atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the
particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…108/327
As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the
source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The
remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would
be challenging to justify more expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feeds
air back into the mill. The reason for this design is to account for the need of extra airflow to reduce the likelihood of
creating a vacuum in the mill. If the air was not returned you would not be able to open a single door in the mill. Withthat in mind, in the pressurization room, there is a “burp” vent type system that would allow some of the internal airto exit via the roof vent. All the baghouses (and cycle) vents associated with the milling are routed to theaforementioned process. The 60/40 split is an approximate number based on a similar operating parameter at other
mills throughout the portfolio. The HVAC designer confirmed that this is even an overestimate to what will be emitted
outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology
(BACT) please provide it. The facility equipment are being designed using current technologies and industry standards to
minimize emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available
Control Technology (BACT). We can provide a wrien determinaon on the processes that are not currently equipped with a
baghouse, but the reducon in emissions per the cost basis would not be economically viable or appropriate for the reducon
provided by the baghouse/cyclone. Addionally, since the emissions that are produced are essenally flour product any
emissions from the milling or cleaning processes are essenally lost product that could have been sold; therefore, the facility
has a vested capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are
produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building and
then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you accounting
for this in your PTE estimate?

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…109/327
- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis was
included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and emitting
processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay a
second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my review
and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permitapplication to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but likely
greater than 18). We have only included the Phase I in this application. With that in mind, the client paid the
$3,000 fee upon initial submittal, since we are modifying the application, should they submit via the online
portal or can we submit via email. We want to make sure that they are not paying $3,000 twice since only one
application will apply. Can you please provide insight on the correct submittal steps, or point us in the correct
direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…110/327
Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior
to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will
say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-
fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling
analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission
estimates would need to drop below these values and be enforceable from a permitting perspective. If you think this is
possible, we can take this approach, but you will need to resubmit the NOI with new emissions estimates. Before the second
half of the site is constructed, you will need to submit a second NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically,
an AO should be issued before construction even begins. You might want to try running this by Chad Gilgen who's the
manager of the minor source compliance section. He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full
future maximum operang capacity. Only half of the facility is being constructed at this me so the emissions would
easily be reduced in half and with some addional flow reducons and adjustments the facility could operate below
the modeling threshold. So inially the facility would be running at limited capacity based on the future potenal.
So would it be possible to operate inially at a lower capacity with calculated emission under the modeling
threshold? We would connue with the modeling work, but this may also allow us to beer define the model based
on actual performance of the system components.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…111/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table 1
of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as part of
a complete NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and demonstrate
compliance with all applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling
protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those to
Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be aminor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modeling
department perform the modeling in house at the UDEQ or how does that specifically work? We have
performed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…112/327

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a
new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on the
NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit (PTE) for
PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will
provide some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby
notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have received this communication in error,
notify the sender immediately by return email and delete the message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
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Environmental Engineer | Minor NSR Section
M: [phone]
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
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dissemination of any of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader
of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of
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M: [phone]
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of the
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…117/327
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of the
message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of any of this
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…118/327
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
kirk.arens <[e-mail]>Wed, Nov 13, 2024 at 7:00 AM
To: Dungan Adams <[e-mail]>
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The mill will not
be capable of running product until the permit is in place but I was wondering if we can bring wheat into our bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the cyclones as
this will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons Spreadsheet with
highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the cyclones to the control
efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100% outdoors and 0% recirculated indoors as
a worst case scenario and would provide an addional emission safety factor. Of note the air that is recirculated back into the building flows
through addional filters before being discharged back into the building to collect parculate maer and further reduce interior emissions
and the buildup of parculate maer within the building that needs to be cleaned up. Let us know if you have any quesons or need any
addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…119/327

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently
calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without exceeding
modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a good way to enforce
this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the facility from exhausting greater
than 40% of the baghouse emissions to the atmosphere. Richmond could experience an unusually long summer and the facility could exhaust for
a greater period than what is anticipated. The permit would also need to ensure that 100% of the recirculated baghouse exhaust remains and
settles inside the building and ~18 TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more accurate
estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling baghouse by half.
Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control efficiencies are used across the
facility, if we conservatively assume that all of the baghouse emissions are exhausted to the atmosphere, the facility will remain below the
modeling threshold. With this approach this is no need to try and enforce the 60-40 split are ensure that 100% of the recirculated air remains inside
the facility. The facility would be able to use their HVAC system with full flexibility and exhaust as much or as little of the grain milling baghouse
exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our
calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in the
most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air flow
system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a room in the
interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being directed to
other building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified as emission
point EP-RV on the permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being
emitted through the roof vent as a starting point. This emission split was likely higher than required, but we were not certain of the distances and
configuration from the emission point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be
recirculated at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the
most recent permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and
would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process
equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and there
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…120/327
is no changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system that
determines how much of this air is discharged to the exterior of the building and how much of this air is recirculated and directed through the
RTUs and then back into the building. In the colder winter months this system would recirculate 100% of this air back into the building to
maintain heat, with additional heating provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100% of
the airflow to the exterior to allow for more cool air to be drawn into the building. This recirculation system accounts for 45,000 CFM of the total
80,000 CFM that is drawn through all equipment with the other air flows being discharged (outdoors) through other emission points. Therefore,
when this circulation system is closed during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The
HVAC valving system is controlled by a thermostat based on interior and exterior temperatures and the following table was derived with monthly
average temperatures for the facility area to calculate split between exhausted and recirculated air. Based on this information the 40% to 60%
split included in the permit is scientifically correct. Another temperature analysis was performed with data from 2023 in the area of the facility
and approximately 36% of the days in the year had a high and low daily temperature above 65 degrees where the HVAC system would
discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage of exhausted air flow would be expected to
be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built into
these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emissionreduction factor for these units was included in the calculations. These units would be considered medium efficiency cyclones,
which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions in the
calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facilitywill be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest in
reducing emissions and improving efficiency of the systems and assuring the emission equipment in place is operating a peakefficiency.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…121/327
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the original
milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or Ryan could
provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why this
aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is part
of the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B from the
initial application package, we revisited numerous calculations to better reflect what would be happening with the emissions
associated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with this operation,
but Ryan may be better suited with explaining how this process works specifically. Essentially, similar to other mills, most ofthe recirculated air will cause the particulate matter to settle on the floor within the mill. This waste settled material isconstantly swept up and disposed of. It is not uncommon for numerous tons to be disposed of in this fashion at similar sizedmills across the country via the dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the level
represented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we tried to
limit step-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates submitted in the
application as if the baghouses were set up in a parallel formation. As you can see in the submittal there are three baghouses
and at least one cyclone associated with the milling process. This vastly reduces emissions below the levels within the
calculations provided. As stated in previous emails any lost product or by-product is lost revenue for the facility and companyas a whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for thefacility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC
and air flow systems used at the facility.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…122/327
Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of
PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed
outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be
vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25%
indoor split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from the
75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an
example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent
directly to the atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid
modeling requirements and I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in
more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for
air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values
due to several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that are
primarily used for material transfer from the milling process prior to the baghouses but the emission reducon form these units is not
included in the emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the
values used in the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and actual
emissions would be less than these values. The flow from the baghouses is discharged to certain interior areas of the building that will
facilitate in the seling of parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste
maer that is developed at this facility that cannot be used as flour and is used as animal feed. Let me know if you have any other
quesons.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…123/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10 and
~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This seems
like a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside the
building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within
the building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line above
this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the atmosphere
through the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this
unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…124/327
From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to the
atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the
particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the
source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The
remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would
be challenging to justify more expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that feedsair back into the mill. The reason for this design is to account for the need of extra airflow to reduce the likelihood ofcreating a vacuum in the mill. If the air was not returned you would not be able to open a single door in the mill.With that in mind, in the pressurization room, there is a “burp” vent type system that would allow some of the
internal air to exit via the roof vent. All the baghouses (and cycle) vents associated with the milling are routed to the
aforementioned process. The 60/40 split is an approximate number based on a similar operating parameter at other
mills throughout the portfolio. The HVAC designer confirmed that this is even an overestimate to what will be
emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology
(BACT) please provide it. The facility equipment are being designed using current technologies and industry standards to
minimize emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available
Control Technology (BACT). We can provide a wrien determinaon on the processes that are not currently equipped with a
baghouse, but the reducon in emissions per the cost basis would not be economically viable or appropriate for the reducon
provided by the baghouse/cyclone. Addionally, since the emissions that are produced are essenally flour product any
emissions from the milling or cleaning processes are essenally lost product that could have been sold; therefore, the facility
has a vested capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…125/327
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are
produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building and
then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you accounting
for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis was
included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and emitting
processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay a
second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my
review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permit
application to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but likelygreater than 18). We have only included the Phase I in this application. With that in mind, the client paid the$3,000 fee upon initial submittal, since we are modifying the application, should they submit via the onlineportal or can we submit via email. We want to make sure that they are not paying $3,000 twice since only one
application will apply. Can you please provide insight on the correct submittal steps, or point us in the correct
direction?

Kind Regards,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…126/327

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO) prior
to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine he will
say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-
fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct modeling
analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's emission
estimates would need to drop below these values and be enforceable from a permitting perspective. If you think this is
possible, we can take this approach, but you will need to resubmit the NOI with new emissions estimates. Before the second
half of the site is constructed, you will need to submit a second NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically,
an AO should be issued before construction even begins. You might want to try running this by Chad Gilgen who's the
manager of the minor source compliance section. He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…127/327
We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full
future maximum operang capacity. Only half of the facility is being constructed at this me so the emissions would
easily be reduced in half and with some addional flow reducons and adjustments the facility could operate below
the modeling threshold. So inially the facility would be running at limited capacity based on the future potenal.
So would it be possible to operate inially at a lower capacity with calculated emission under the modeling
threshold? We would connue with the modeling work, but this may also allow us to beer define the model based
on actual performance of the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table 1
of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as part of
a complete NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and demonstrate
compliance with all applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling
protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those to
Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…128/327
At this time, we have not completed the emissions impact analysis (modeling). That appears to be a
minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modelingdepartment perform the modeling in house at the UDEQ or how does that specifically work? We haveperformed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a
new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on the
NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit (PTE) for
PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will
provide some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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2 attachments
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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image002.jpg
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Dungan Adams <[e-mail]>Wed, Nov 13, 2024 at 9:47 AM
To: "kirk.arens" <[e-mail]>
Cc: Scott Hanson <[e-mail]>, Jack Batho <[e-mail]>
Hi Kirk,
I am hoping to send this project off for internal reviews by the end of the week.
UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution source.
I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number of each
will be included in the permit.
Thanks,
Dungan
On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The mill will
not be capable of running product until the permit is in place but I was wondering if we can bring wheat into our bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the cyclones as
this will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons Spreadsheet with
highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the cyclones to the control
efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100% outdoors and 0% recirculated indoors
as a worst case scenario and would provide an addional emission safety factor. Of note the air that is recirculated back into the building
flows through addional filters before being discharged back into the building to collect parculate maer and further reduce interior
emissions and the buildup of parculate maer within the building that needs to be cleaned up. Let us know if you have any quesons or
need any addional informaon.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…136/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently
calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without exceeding
modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a good way to enforce
this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the facility from
exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an unusually long summer and the
facility could exhaust for a greater period than what is anticipated. The permit would also need to ensure that 100% of the recirculated baghouse
exhaust remains and settles inside the building and ~18 TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more accurate
estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling baghouse by
half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control efficiencies are used across
the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the atmosphere, the facility will remain below the
modeling threshold. With this approach this is no need to try and enforce the 60-40 split are ensure that 100% of the recirculated air remains
inside the facility. The facility would be able to use their HVAC system with full flexibility and exhaust as much or as little of the grain milling
baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our
calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in
the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air
flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a room
in the interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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directed to other building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified
as emission point EP-RV on the permit documents. We estimated 25% of the particulate would be contained in the building with the remaining
75% being emitted through the roof vent as a starting point. This emission split was likely higher than required, but we were not certain of the
distances and configuration from the emission point in the building to the roof vents. In addition, we estimated that the whole facility air flow
would be recirculated at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally. This number was further
reduced in the most recent permit based on our understanding that approximately 50% of this air would be circulated back into the building
equipment and would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process
equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and
there is no changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system
that determines how much of this air is discharged to the exterior of the building and how much of this air is recirculated and directed through
the RTUs and then back into the building. In the colder winter months this system would recirculate 100% of this air back into the building to
maintain heat, with additional heating provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100%
of the airflow to the exterior to allow for more cool air to be drawn into the building. This recirculation system accounts for 45,000 CFM of the
total 80,000 CFM that is drawn through all equipment with the other air flows being discharged (outdoors) through other emission points.
Therefore, when this circulation system is closed during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the
building. The HVAC valving system is controlled by a thermostat based on interior and exterior temperatures and the following table was
derived with monthly average temperatures for the facility area to calculate split between exhausted and recirculated air. Based on this
information the 40% to 60% split included in the permit is scientifically correct. Another temperature analysis was performed with data from
2023 in the area of the facility and approximately 36% of the days in the year had a high and low daily temperature above 65 degrees where
the HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage of exhausted air
flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built into
these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emissionreduction factor for these units was included in the calculations. These units would be considered medium efficiencycyclones, which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions in
the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facility
will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest inreducing emissions and improving efficiency of the systems and assuring the emission equipment in place is operating a
peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the
original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or
Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why
this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who ispart of the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B
from the initial application package, we revisited numerous calculations to better reflect what would be happening with the
emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar with
this operation, but Ryan may be better suited with explaining how this process works specifically. Essentially, similar to
other mills, most of the recirculated air will cause the particulate matter to settle on the floor within the mill. This waste
settled material is constantly swept up and disposed of. It is not uncommon for numerous tons to be disposed of in this
fashion at similar sized mills across the country via the dumpster (garbage service) or other alternative green friendlyoptions.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…139/327
As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the
level represented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we
tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates
submitted in the application as if the baghouses were set up in a parallel formation. As you can see in the submittal thereare three baghouses and at least one cyclone associated with the milling process. This vastly reduces emissions below thelevels within the calculations provided. As stated in previous emails any lost product or by-product is lost revenue for the
facility and company as a whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for the
facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC
and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of
PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are directed
outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be
vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25%
indoor split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from
the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an
example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent
directly to the atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid
modeling requirements and I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in
more detail.

Thanks,
Dungan
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…140/327

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air for
air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated values
due to several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones that
are primarily used for material transfer from the milling process prior to the baghouses but the emission reducon form these units
is not included in the emission reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies
than the values used in the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and
actual emissions would be less than these values. The flow from the baghouses is discharged to certain interior areas of the building
that will facilitate in the seling of parculates and the cleanup of parculates for the recycling of the air. The parculate and
process waste maer that is developed at this facility that cannot be used as flour and is used as animal feed. Let me know if you
have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10
and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This
seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside
the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within
the building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line
above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the
atmosphere through the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-
08A but this unit have has very minor emissions in comparison.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…141/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to
the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the
particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the
source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The
remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it would
be challenging to justify more expensive control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that
feeds air back into the mill. The reason for this design is to account for the need of extra airflow to reduce the
likelihood of creating a vacuum in the mill. If the air was not returned you would not be able to open a single door
in the mill. With that in mind, in the pressurization room, there is a “burp” vent type system that would allow some
of the internal air to exit via the roof vent. All the baghouses (and cycle) vents associated with the milling arerouted to the aforementioned process. The 60/40 split is an approximate number based on a similar operatingparameter at other mills throughout the portfolio. The HVAC designer confirmed that this is even an overestimateto what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology
(BACT) please provide it. The facility equipment are being designed using current technologies and industry standards to
minimize emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best Available
Control Technology (BACT). We can provide a wrien determinaon on the processes that are not currently equipped with a
baghouse, but the reducon in emissions per the cost basis would not be economically viable or appropriate for the
reducon provided by the baghouse/cyclone. Addionally, since the emissions that are produced are essenally flour
product any emissions from the milling or cleaning processes are essenally lost product that could have been sold;
therefore, the facility has a vested capital interest in reducing emissions.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…142/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are
produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building
and then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you
accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis
was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and
emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay
a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my
review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…143/327
We had a question about the permit application submittal, since the client will be revising the air permit
application to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but
likely greater than 18). We have only included the Phase I in this application. With that in mind, the client paid
the $3,000 fee upon initial submittal, since we are modifying the application, should they submit via the onlineportal or can we submit via email. We want to make sure that they are not paying $3,000 twice since onlyone application will apply. Can you please provide insight on the correct submittal steps, or point us in thecorrect direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO)
prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine
he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-
fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct
modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's
emission estimates would need to drop below these values and be enforceable from a permitting perspective. If you think
this is possible, we can take this approach, but you will need to resubmit the NOI with new emissions estimates. Before the
second half of the site is constructed, you will need to submit a second NOI for a minor modification and conduct modeling
analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order. Technically,
an AO should be issued before construction even begins. You might want to try running this by Chad Gilgen who's the
manager of the minor source compliance section. He can be reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…144/327
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full
future maximum operang capacity. Only half of the facility is being constructed at this me so the emissions
would easily be reduced in half and with some addional flow reducons and adjustments the facility could
operate below the modeling threshold. So inially the facility would be running at limited capacity based on the
future potenal. So would it be possible to operate inially at a lower capacity with calculated emission under the
modeling threshold? We would connue with the modeling work, but this may also allow us to beer define the
model based on actual performance of the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table
1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as
part of a complete NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and
demonstrate compliance with all applicable national ambient air quality standards (NAAQS). I recommend submitting
a modeling protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is conducted
correctly.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…145/327

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those
to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be a
minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modeling
department perform the modeling in house at the UDEQ or how does that specifically work? We have
performed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for a
new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on
the NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit
(PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct
modeling.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…146/327

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will
provide some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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image003.jpg
1K
kirk.arens <[e-mail]>Wed, Nov 13, 2024 at 10:35 AM
To: Dungan Adams <[e-mail]>
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floor bins, 1
feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number of each
will be included in the permit.

Thanks,
Dungan

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…153/327
On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The mill will
not be capable of running product until the permit is in place but I was wondering if we can bring wheat into our bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the cyclones as
this will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons Spreadsheet with
highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the cyclones to the control
efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100% outdoors and 0% recirculated indoors
as a worst case scenario and would provide an addional emission safety factor. Of note the air that is recirculated back into the building
flows through addional filters before being discharged back into the building to collect parculate maer and further reduce interior
emissions and the buildup of parculate maer within the building that needs to be cleaned up. Let us know if you have any quesons or
need any addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently
calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without exceeding
modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a good way to enforce
this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the facility from
exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an unusually long summer and the
facility could exhaust for a greater period than what is anticipated. The permit would also need to ensure that 100% of the recirculated baghouse
exhaust remains and settles inside the building and ~18 TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more accurate
estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…154/327

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling baghouse by
half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control efficiencies are used across
the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the atmosphere, the facility will remain below the
modeling threshold. With this approach this is no need to try and enforce the 60-40 split are ensure that 100% of the recirculated air remains
inside the facility. The facility would be able to use their HVAC system with full flexibility and exhaust as much or as little of the grain milling
baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our
calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided in
the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air
flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a
room in the interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before being
directed to other building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are identified
as emission point EP-RV on the permit documents. We estimated 25% of the particulate would be contained in the building with the
remaining 75% being emitted through the roof vent as a starting point. This emission split was likely higher than required, but we were not
certain of the distances and configuration from the emission point in the building to the roof vents. In addition, we estimated that the whole
facility air flow would be recirculated at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally. This number
was further reduced in the most recent permit based on our understanding that approximately 50% of this air would be circulated back into
the building equipment and would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process
equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and
there is no changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving system
that determines how much of this air is discharged to the exterior of the building and how much of this air is recirculated and directed through
the RTUs and then back into the building. In the colder winter months this system would recirculate 100% of this air back into the building to
maintain heat, with additional heating provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100%
of the airflow to the exterior to allow for more cool air to be drawn into the building. This recirculation system accounts for 45,000 CFM of the
total 80,000 CFM that is drawn through all equipment with the other air flows being discharged (outdoors) through other emission points.
Therefore, when this circulation system is closed during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the
building. The HVAC valving system is controlled by a thermostat based on interior and exterior temperatures and the following table was
derived with monthly average temperatures for the facility area to calculate split between exhausted and recirculated air. Based on this
information the 40% to 60% split included in the permit is scientifically correct. Another temperature analysis was performed with data from
2023 in the area of the facility and approximately 36% of the days in the year had a high and low daily temperature above 65 degrees where
the HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage of exhausted
air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…155/327
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built
into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emissionreduction factor for these units was included in the calculations. These units would be considered medium efficiencycyclones, which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10 emissions
in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that the facilitywill be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest inreducing emissions and improving efficiency of the systems and assuring the emission equipment in place is operating apeak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…156/327
Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the
original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk or
Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture product.
However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to understand why
this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is
part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B
from the initial application package, we revisited numerous calculations to better reflect what would be happening with the
emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar withthis operation, but Ryan may be better suited with explaining how this process works specifically. Essentially, similar toother mills, most of the recirculated air will cause the particulate matter to settle on the floor within the mill. This wastesettled material is constantly swept up and disposed of. It is not uncommon for numerous tons to be disposed of in this
fashion at similar sized mills across the country via the dumpster (garbage service) or other alternative green friendly
options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the
level represented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we
tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates
submitted in the application as if the baghouses were set up in a parallel formation. As you can see in the submittal thereare three baghouses and at least one cyclone associated with the milling process. This vastly reduces emissions below thelevels within the calculations provided. As stated in previous emails any lost product or by-product is lost revenue for thefacility and company as a whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for the
facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC
and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…157/327
From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy of
PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are
directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would be
vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor - 25%
indoor split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed from
the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to see an
example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses that vent
directly to the atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to avoid
modeling requirements and I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this in
more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air
for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated
values due to several factors, and the calculated values represent a worst case scenario. This system includes several small cyclones
that are primarily used for material transfer from the milling process prior to the baghouses but the emission reducon form these
units is not included in the emission reducon calculaons. Addionally, the baghouses would be expected to have higher
efficiencies than the values used in the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons
show and actual emissions would be less than these values. The flow from the baghouses is discharged to certain interior areas of
the building that will facilitate in the seling of parculates and the cleanup of parculates for the recycling of the air. The
parculate and process waste maer that is developed at this facility that cannot be used as flour and is used as animal feed. Let
me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…158/327
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10
and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere. This
seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays inside
the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained within
the building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The line
above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the
atmosphere through the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for EU-
08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building to
the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where the
particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the
source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The
remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…159/327
would be challenging to justify more expensive control. I will move forward with my BACT write up without a formal written
analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that
feeds air back into the mill. The reason for this design is to account for the need of extra airflow to reduce the
likelihood of creating a vacuum in the mill. If the air was not returned you would not be able to open a single door
in the mill. With that in mind, in the pressurization room, there is a “burp” vent type system that would allow some
of the internal air to exit via the roof vent. All the baghouses (and cycle) vents associated with the milling are
routed to the aforementioned process. The 60/40 split is an approximate number based on a similar operating
parameter at other mills throughout the portfolio. The HVAC designer confirmed that this is even an overestimateto what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology
(BACT) please provide it. The facility equipment are being designed using current technologies and industry standards to
minimize emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best
Available Control Technology (BACT). We can provide a wrien determinaon on the processes that are not currently
equipped with a baghouse, but the reducon in emissions per the cost basis would not be economically viable or
appropriate for the reducon provided by the baghouse/cyclone. Addionally, since the emissions that are produced are
essenally flour product any emissions from the milling or cleaning processes are essenally lost product that could have
been sold; therefore, the facility has a vested capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions are
produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the building
and then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How are you
accounting for this in your PTE estimate?

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…160/327
- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis
was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and
emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to pay
a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my
review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permitapplication to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but
likely greater than 18). We have only included the Phase I in this application. With that in mind, the client
paid the $3,000 fee upon initial submittal, since we are modifying the application, should they submit via the
online portal or can we submit via email. We want to make sure that they are not paying $3,000 twice since
only one application will apply. Can you please provide insight on the correct submittal steps, or point us in
the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…161/327
Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO)
prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I imagine
he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy non-
fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct
modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's
emission estimates would need to drop below these values and be enforceable from a permitting perspective. If you think
this is possible, we can take this approach, but you will need to resubmit the NOI with new emissions estimates. Before
the second half of the site is constructed, you will need to submit a second NOI for a minor modification and conduct
modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by Chad
Gilgen who's the manager of the minor source compliance section. He can be reached at [e-mail] and at 385-
306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the full
future maximum operang capacity. Only half of the facility is being constructed at this me so the emissions
would easily be reduced in half and with some addional flow reducons and adjustments the facility could
operate below the modeling threshold. So inially the facility would be running at limited capacity based on the
future potenal. So would it be possible to operate inially at a lower capacity with calculated emission under
the modeling threshold? We would connue with the modeling work, but this may also allow us to beer define
the model based on actual performance of the system components.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…162/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in Table
1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling analysis as
part of a complete NOI. Based on the estimated emissions in your NOI, you will need to conduct modeling and
demonstrate compliance with all applicable national ambient air quality standards (NAAQS). I recommend submitting
a modeling protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is conducted
correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct those
to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be a
minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the modeling
department perform the modeling in house at the UDEQ or how does that specifically work? We have
performed modeling in other states, and we understand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…163/327

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when opening
attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application for
a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on
the NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit
(PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct
modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will
provide some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
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Dungan Adams <[e-mail]>Wed, Nov 13, 2024 at 11:31 AM
To: "kirk.arens" <[e-mail]>
Understood, I will move this project forward as quickly as I can.
The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to the atmosphere
through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12) internal grain storage bins are not
controlled by any equipment?
Thanks,
Dungan
On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floor bins, 1
feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution
source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number of each
will be included in the permit.

Thanks,
Dungan

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…171/327
On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The mill
will not be capable of running product until the permit is in place but I was wondering if we can bring wheat into our bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the cyclones
as this will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons Spreadsheet
with highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the cyclones to the
control efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100% outdoors and 0%
recirculated indoors as a worst case scenario and would provide an addional emission safety factor. Of note the air that is recirculated
back into the building flows through addional filters before being discharged back into the building to collect parculate maer and
further reduce interior emissions and the buildup of parculate maer within the building that needs to be cleaned up. Let us know if
you have any quesons or need any addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently
calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without exceeding
modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a good way to
enforce this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the facility from
exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an unusually long summer and the
facility could exhaust for a greater period than what is anticipated. The permit would also need to ensure that 100% of the recirculated
baghouse exhaust remains and settles inside the building and ~18 TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more accurate
estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…172/327

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling baghouse by
half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control efficiencies are used
across the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the atmosphere, the facility will remain
below the modeling threshold. With this approach this is no need to try and enforce the 60-40 split are ensure that 100% of the recirculated air
remains inside the facility. The facility would be able to use their HVAC system with full flexibility and exhaust as much or as little of the grain
milling baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our
calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided
in the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the air
flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into a
room in the interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before
being directed to other building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are
identified as emission point EP-RV on the permit documents. We estimated 25% of the particulate would be contained in the building with
the remaining 75% being emitted through the roof vent as a starting point. This emission split was likely higher than required, but we were
not certain of the distances and configuration from the emission point in the building to the roof vents. In addition, we estimated that the
whole facility air flow would be recirculated at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally. This
number was further reduced in the most recent permit based on our understanding that approximately 50% of this air would be circulated
back into the building equipment and would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to
40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process
equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and
there is no changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving
system that determines how much of this air is discharged to the exterior of the building and how much of this air is recirculated and
directed through the RTUs and then back into the building. In the colder winter months this system would recirculate 100% of this air back
into the building to maintain heat, with additional heating provided by the RTUs. In the summer months the system may be opened up to
discharge nearly 100% of the airflow to the exterior to allow for more cool air to be drawn into the building. This recirculation system
accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all equipment with the other air flows being discharged (outdoors)
through other emission points. Therefore, when this circulation system is closed during cooler periods an additional 35,000 CFM of fresh air
is still being drawn into the building. The HVAC valving system is controlled by a thermostat based on interior and exterior temperatures
and the following table was derived with monthly average temperatures for the facility area to calculate split between exhausted and
recirculated air. Based on this information the 40% to 60% split included in the permit is scientifically correct. Another temperature analysis
was performed with data from 2023 in the area of the facility and approximately 36% of the days in the year had a high and low daily
temperature above 65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In
both cases the percentage of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…173/327
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built
into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emissionreduction factor for these units was included in the calculations. These units would be considered medium efficiencycyclones, which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that thefacility will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest inreducing emissions and improving efficiency of the systems and assuring the emission equipment in place is operating apeak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…174/327

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the
original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk
or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture
product. However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to
understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is
part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B
from the initial application package, we revisited numerous calculations to better reflect what would be happening with
the emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiar
with this operation, but Ryan may be better suited with explaining how this process works specifically. Essentially, similar
to other mills, most of the recirculated air will cause the particulate matter to settle on the floor within the mill. This waste
settled material is constantly swept up and disposed of. It is not uncommon for numerous tons to be disposed of in thisfashion at similar sized mills across the country via the dumpster (garbage service) or other alternative green friendlyoptions.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the
level represented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we
tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed emissions control rates
submitted in the application as if the baghouses were set up in a parallel formation. As you can see in the submittal there
are three baghouses and at least one cyclone associated with the milling process. This vastly reduces emissions below
the levels within the calculations provided. As stated in previous emails any lost product or by-product is lost revenue for
the facility and company as a whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative forthe facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to theHVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…175/327
From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy
of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are
directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would
be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor -
25% indoor split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed
from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to
see an example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use baghouses
that vent directly to the atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was adjusted to
avoid modeling requirements and I will need to see stronger justification for this process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this
in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air
for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated
values due to several factors, and the calculated values represent a worst case scenario. This system includes several small
cyclones that are primarily used for material transfer from the milling process prior to the baghouses but the emission reducon
form these units is not included in the emission reducon calculaons. Addionally, the baghouses would be expected to have
higher efficiencies than the values used in the calculaons. Therefore, the system will operate at higher efficiencies than the
calculaons show and actual emissions would be less than these values. The flow from the baghouses is discharged to certain
interior areas of the building that will facilitate in the seling of parculates and the cleanup of parculates for the recycling of
the air. The parculate and process waste maer that is developed at this facility that cannot be used as flour and is used as
animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…176/327
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10
and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere.
This seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays
inside the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained
within the building, which is on the indoor line. These emissions would not be discharged to the outside of the building. The
line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged to the
atmosphere through the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the same for
EU-08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building
to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand where
the particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling
threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the
source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…177/327
remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it
would be challenging to justify more expensive control. I will move forward with my BACT write up without a formal written
analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system thatfeeds air back into the mill. The reason for this design is to account for the need of extra airflow to reduce thelikelihood of creating a vacuum in the mill. If the air was not returned you would not be able to open a singledoor in the mill. With that in mind, in the pressurization room, there is a “burp” vent type system that would
allow some of the internal air to exit via the roof vent. All the baghouses (and cycle) vents associated with the
milling are routed to the aforementioned process. The 60/40 split is an approximate number based on a similar
operating parameter at other mills throughout the portfolio. The HVAC designer confirmed that this is even an
overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control Technology
(BACT) please provide it. The facility equipment are being designed using current technologies and industry standards to
minimize emissions. The facility is construcng the mill in a way to reduce emissions consistent with using the Best
Available Control Technology (BACT). We can provide a wrien determinaon on the processes that are not currently
equipped with a baghouse, but the reducon in emissions per the cost basis would not be economically viable or
appropriate for the reducon provided by the baghouse/cyclone. Addionally, since the emissions that are produced are
essenally flour product any emissions from the milling or cleaning processes are essenally lost product that could have
been sold; therefore, the facility has a vested capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions
are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the
building and then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How
are you accounting for this in your PTE estimate?

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…178/327
- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis
was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and
emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to
pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my
review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permitapplication to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but
likely greater than 18). We have only included the Phase I in this application. With that in mind, the client
paid the $3,000 fee upon initial submittal, since we are modifying the application, should they submit via
the online portal or can we submit via email. We want to make sure that they are not paying $3,000 twice
since only one application will apply. Can you please provide insight on the correct submittal steps, or point
us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…179/327
Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO)
prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I
imagine he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy
non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct
modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's
emission estimates would need to drop below these values and be enforceable from a permitting perspective. If you
think this is possible, we can take this approach, but you will need to resubmit the NOI with new emissions estimates.
Before the second half of the site is constructed, you will need to submit a second NOI for a minor modification and
conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by Chad
Gilgen who's the manager of the minor source compliance section. He can be reached at [e-mail] and at
385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the
full future maximum operang capacity. Only half of the facility is being constructed at this me so the
emissions would easily be reduced in half and with some addional flow reducons and adjustments the
facility could operate below the modeling threshold. So inially the facility would be running at limited capacity
based on the future potenal. So would it be possible to operate inially at a lower capacity with calculated
emission under the modeling threshold? We would connue with the modeling work, but this may also allow
us to beer define the model based on actual performance of the system components.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…180/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in
Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling
analysis as part of a complete NOI. Based on the estimated emissions in your NOI, you will need to conduct
modeling and demonstrate compliance with all applicable national ambient air quality standards (NAAQS). I
recommend submitting a modeling protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the
modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct
those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be
a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the
modeling department perform the modeling in house at the UDEQ or how does that specifically
work? We have performed modeling in other states, and we understand that each state handlesmodeling differently.

Thank you for your assistance.

Kind Regards,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…181/327

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when
opening attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application
for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off on
the NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to emit
(PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to conduct
modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will
provide some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…182/327
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Environmental Engineer | Minor NSR Section
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
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2 attachments
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kirk.arens <[e-mail]>Wed, Nov 13, 2024 at 11:41 AM
To: Dungan Adams <[e-mail]>
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to the atmosphere
through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12) internal grain storage bins are not
controlled by any equipment?

Thanks,
Dungan

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…189/327
On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floor bins, 1
feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution
source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number of each
will be included in the permit.

Thanks,
Dungan

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The millwill not be capable of running product until the permit is in place but I was wondering if we can bring wheat into our bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the cyclones
as this will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons Spreadsheet
with highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the cyclones to the
control efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100% outdoors and 0%
recirculated indoors as a worst case scenario and would provide an addional emission safety factor. Of note the air that is recirculated
back into the building flows through addional filters before being discharged back into the building to collect parculate maer and
further reduce interior emissions and the buildup of parculate maer within the building that needs to be cleaned up. Let us know if
you have any quesons or need any addional informaon.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…190/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently
calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without exceeding
modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a good way to
enforce this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the facility from
exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an unusually long summer and the
facility could exhaust for a greater period than what is anticipated. The permit would also need to ensure that 100% of the recirculated
baghouse exhaust remains and settles inside the building and ~18 TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more accurate
estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling baghouse by
half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control efficiencies are used
across the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the atmosphere, the facility will remain
below the modeling threshold. With this approach this is no need to try and enforce the 60-40 split are ensure that 100% of the recirculated
air remains inside the facility. The facility would be able to use their HVAC system with full flexibility and exhaust as much or as little of the
grain milling baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our
calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations provided
in the most recent Notice of Intent (NOI).

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…191/327
The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the
air flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back into
a room in the interior of the building. We have seen this design in other setups where the discharge is generally directed to a room before
being directed to other building areas. Air within the building would be exhausted through various exhaust vents. These exhaust fans are
identified as emission point EP-RV on the permit documents. We estimated 25% of the particulate would be contained in the building with
the remaining 75% being emitted through the roof vent as a starting point. This emission split was likely higher than required, but we were
not certain of the distances and configuration from the emission point in the building to the roof vents. In addition, we estimated that the
whole facility air flow would be recirculated at a rate of 75% emitted through roof vents outdoors and 25% would be returned internally.
This number was further reduced in the most recent permit based on our understanding that approximately 50% of this air would be
circulated back into the building equipment and would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was
rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process
equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit and
there is no changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a valving
system that determines how much of this air is discharged to the exterior of the building and how much of this air is recirculated and
directed through the RTUs and then back into the building. In the colder winter months this system would recirculate 100% of this air back
into the building to maintain heat, with additional heating provided by the RTUs. In the summer months the system may be opened up to
discharge nearly 100% of the airflow to the exterior to allow for more cool air to be drawn into the building. This recirculation system
accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all equipment with the other air flows being discharged (outdoors)
through other emission points. Therefore, when this circulation system is closed during cooler periods an additional 35,000 CFM of fresh
air is still being drawn into the building. The HVAC valving system is controlled by a thermostat based on interior and exterior temperatures
and the following table was derived with monthly average temperatures for the facility area to calculate split between exhausted and
recirculated air. Based on this information the 40% to 60% split included in the permit is scientifically correct. Another temperature analysis
was performed with data from 2023 in the area of the facility and approximately 36% of the days in the year had a high and low daily
temperature above 65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In
both cases the percentage of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…192/327
While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been built
into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no emissionreduction factor for these units was included in the calculations. These units would be considered medium efficiency
cyclones, which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A PM10
emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that thefacility will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest in
reducing emissions and improving efficiency of the systems and assuring the emission equipment in place is operating apeak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the
original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If Kirk
or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture
product. However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to
understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who is
part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill line B
from the initial application package, we revisited numerous calculations to better reflect what would be happening withthe emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC engineers, we are familiarwith this operation, but Ryan may be better suited with explaining how this process works specifically. Essentially, similarto other mills, most of the recirculated air will cause the particulate matter to settle on the floor within the mill. This waste
settled material is constantly swept up and disposed of. It is not uncommon for numerous tons to be disposed of in this
fashion at similar sized mills across the country via the dumpster (garbage service) or other alternative green friendly
options.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…193/327

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past the
level represented in the NOI and submitted calculations. As to make everything easier to review on the agency end, we
tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed emissions control ratessubmitted in the application as if the baghouses were set up in a parallel formation. As you can see in the submittal thereare three baghouses and at least one cyclone associated with the milling process. This vastly reduces emissions belowthe levels within the calculations provided. As stated in previous emails any lost product or by-product is lost revenue for
the facility and company as a whole, so there is a vested interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for
the facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the
HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5 tpy
of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions are
directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust would
be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75% outdoor -
25% indoor split was used in the updated calculations, the source would be above the modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed
from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would like to
see an example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use
baghouses that vent directly to the atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors was
adjusted to avoid modeling requirements and I will need to see stronger justification for this process before I am able to accept the
calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss this
in more detail.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…194/327
Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the air
for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these calculated
values due to several factors, and the calculated values represent a worst case scenario. This system includes several small
cyclones that are primarily used for material transfer from the milling process prior to the baghouses but the emission reducon
form these units is not included in the emission reducon calculaons. Addionally, the baghouses would be expected to have
higher efficiencies than the values used in the calculaons. Therefore, the system will operate at higher efficiencies than the
calculaons show and actual emissions would be less than these values. The flow from the baghouses is discharged to certain
interior areas of the building that will facilitate in the seling of parculates and the cleanup of parculates for the recycling of
the air. The parculate and process waste maer that is developed at this facility that cannot be used as flour and is used as
animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of PM10
and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the atmosphere.
This seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the particulate that stays
inside the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained
within the building, which is on the indoor line. These emissions would not be discharged to the outside of the building.
The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…195/327
to the atmosphere through the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the
same for EU-08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the building
to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to understand
where the particulate goes since a substantial amount is routed indoors and the source is very close to reaching the modeling
threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case the
source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes. The
remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM that it
would be challenging to justify more expensive control. I will move forward with my BACT write up without a formal written
analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that
feeds air back into the mill. The reason for this design is to account for the need of extra airflow to reduce the
likelihood of creating a vacuum in the mill. If the air was not returned you would not be able to open a single
door in the mill. With that in mind, in the pressurization room, there is a “burp” vent type system that would
allow some of the internal air to exit via the roof vent. All the baghouses (and cycle) vents associated with the
milling are routed to the aforementioned process. The 60/40 split is an approximate number based on a similaroperating parameter at other mills throughout the portfolio. The HVAC designer confirmed that this is even anoverestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control
Technology (BACT) please provide it. The facility equipment are being designed using current technologies and industry
standards to minimize emissions. The facility is construcng the mill in a way to reduce emissions consistent with using
the Best Available Control Technology (BACT). We can provide a wrien determinaon on the processes that are not
currently equipped with a baghouse, but the reducon in emissions per the cost basis would not be economically viable
or appropriate for the reducon provided by the baghouse/cyclone. Addionally, since the emissions that are produced
are essenally flour product any emissions from the milling or cleaning processes are essenally lost product that could
have been sold; therefore, the facility has a vested capital interest in reducing emissions.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…196/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions
are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the
building and then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How
are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT) analysis
was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission units and
emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to
pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun my
review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…197/327

We had a question about the permit application submittal, since the client will be revising the air permit
application to only cover Phase I due to Phase II being more than a year out (greater than 14 months, but
likely greater than 18). We have only included the Phase I in this application. With that in mind, the clientpaid the $3,000 fee upon initial submittal, since we are modifying the application, should they submit viathe online portal or can we submit via email. We want to make sure that they are not paying $3,000 twicesince only one application will apply. Can you please provide insight on the correct submittal steps, or
point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order (AO)
prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I
imagine he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy
non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to conduct
modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The flour mill's
emission estimates would need to drop below these values and be enforceable from a permitting perspective. If you
think this is possible, we can take this approach, but you will need to resubmit the NOI with new emissions estimates.
Before the second half of the site is constructed, you will need to submit a second NOI for a minor modification and
conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by Chad
Gilgen who's the manager of the minor source compliance section. He can be reached at [e-mail] and at
385-306-6500.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…198/327
Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at the
full future maximum operang capacity. Only half of the facility is being constructed at this me so the
emissions would easily be reduced in half and with some addional flow reducons and adjustments the
facility could operate below the modeling threshold. So inially the facility would be running at limited
capacity based on the future potenal. So would it be possible to operate inially at a lower capacity with
calculated emission under the modeling threshold? We would connue with the modeling work, but this may
also allow us to beer define the model based on actual performance of the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in
Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling
analysis as part of a complete NOI. Based on the estimated emissions in your NOI, you will need to conduct
modeling and demonstrate compliance with all applicable national ambient air quality standards (NAAQS). I
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…199/327
recommend submitting a modeling protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the
modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct
those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to be
a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does themodeling department perform the modeling in house at the UDEQ or how does that specificallywork? We have performed modeling in other states, and we understand that each state handles
modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when
opening attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI) application
for a new flour mill.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…200/327
Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off
on the NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to
emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to
conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I will
provide some guidance and put you in contact with our modeling department to set up a modeling protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
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Environmental Engineer | Minor NSR Section
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Environmental Engineer | Minor NSR Section
M: [phone]
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of the
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2 attachments
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…207/327
image002.jpg
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Dungan Adams <[e-mail]>Wed, Nov 13, 2024 at 11:41 AM
To: "kirk.arens" <[e-mail]>
Great, thanks for confirming.
- Dungan
On Wed, Nov 13, 2024 at 11:41 AM kirk.arens <[e-mail]> wrote:
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to the
atmosphere through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12) internal grain storage
bins are not controlled by any equipment?

Thanks,
Dungan

On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floor bins, 1
feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…208/327
UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution
source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number of
each will be included in the permit.

Thanks,
Dungan

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The mill
will not be capable of running product until the permit is in place but I was wondering if we can bring wheat into our bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the
cyclones as this will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons
Spreadsheet with highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the
cyclones to the control efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100% outdoors
and 0% recirculated indoors as a worst case scenario and would provide an addional emission safety factor. Of note the air that is
recirculated back into the building flows through addional filters before being discharged back into the building to collect parculate
maer and further reduce interior emissions and the buildup of parculate maer within the building that needs to be cleaned up. Let
us know if you have any quesons or need any addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…209/327
Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently
calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without exceeding
modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a good way to
enforce this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the facility from
exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an unusually long summer and
the facility could exhaust for a greater period than what is anticipated. The permit would also need to ensure that 100% of the recirculated
baghouse exhaust remains and settles inside the building and ~18 TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more
accurate estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling baghouse
by half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control efficiencies are
used across the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the atmosphere, the facility will
remain below the modeling threshold. With this approach this is no need to try and enforce the 60-40 split are ensure that 100% of the
recirculated air remains inside the facility. The facility would be able to use their HVAC system with full flexibility and exhaust as much or as
little of the grain milling baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our
calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations
provided in the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of the
air flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged back
into a room in the interior of the building. We have seen this design in other setups where the discharge is generally directed to a room
before being directed to other building areas. Air within the building would be exhausted through various exhaust vents. These exhaust
fans are identified as emission point EP-RV on the permit documents. We estimated 25% of the particulate would be contained in the
building with the remaining 75% being emitted through the roof vent as a starting point. This emission split was likely higher than
required, but we were not certain of the distances and configuration from the emission point in the building to the roof vents. In addition,
we estimated that the whole facility air flow would be recirculated at a rate of 75% emitted through roof vents outdoors and 25% would
be returned internally. This number was further reduced in the most recent permit based on our understanding that approximately 50%
of this air would be circulated back into the building equipment and would not be exhausted. Therefore, the 75% was divided in half or
37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process
equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit
and there is no changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a
valving system that determines how much of this air is discharged to the exterior of the building and how much of this air is recirculated
and directed through the RTUs and then back into the building. In the colder winter months this system would recirculate 100% of this air
back into the building to maintain heat, with additional heating provided by the RTUs. In the summer months the system may be opened
up to discharge nearly 100% of the airflow to the exterior to allow for more cool air to be drawn into the building. This recirculation
system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all equipment with the other air flows being discharged
(outdoors) through other emission points. Therefore, when this circulation system is closed during cooler periods an additional 35,000
CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a thermostat based on interior and
exterior temperatures and the following table was derived with monthly average temperatures for the facility area to calculate split
between exhausted and recirculated air. Based on this information the 40% to 60% split included in the permit is scientifically correct.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…210/327
Another temperature analysis was performed with data from 2023 in the area of the facility and approximately 36% of the days in the
year had a high and low daily temperature above 65 degrees where the HVAC system would discharge more air to allow for additional
air to be drawn in for cooling. In both cases the percentage of exhausted air flow would be expected to be higher than actual operating
parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been
built into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated
values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and noemission reduction factor for these units was included in the calculations. These units would be considered medium
efficiency cyclones, which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A
PM10 emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely that thefacility will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest
in reducing emissions and improving efficiency of the systems and assuring the emission equipment in place isoperating a peak efficiency.
Let us know if you have any further questions.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…211/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why the
original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor split. If
Kirk or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture
product. However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to
understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney who
is part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed the mill
line B from the initial application package, we revisited numerous calculations to better reflect what would be
happening with the emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC
engineers, we are familiar with this operation, but Ryan may be better suited with explaining how this process works
specifically. Essentially, similar to other mills, most of the recirculated air will cause the particulate matter to settle on
the floor within the mill. This waste settled material is constantly swept up and disposed of. It is not uncommon fornumerous tons to be disposed of in this fashion at similar sized mills across the country via the dumpster (garbageservice) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past
the level represented in the NOI and submitted calculations. As to make everything easier to review on the agency
end, we tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed emissions control
rates submitted in the application as if the baghouses were set up in a parallel formation. As you can see in the
submittal there are three baghouses and at least one cyclone associated with the milling process. This vastly reduces
emissions below the levels within the calculations provided. As stated in previous emails any lost product or by-product
is lost revenue for the facility and company as a whole, so there is a vested interest in reducing emissions andimproving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative for
the facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to
the HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…212/327
Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5
tpy of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate emissions
are directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust
would be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75%
outdoor - 25% indoor split was used in the updated calculations, the source would be above the modeling threshold for PM10
emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it changed
from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and I would
like to see an example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like they all use
baghouses that vent directly to the atmosphere. From my perspective, it looks like the ratio of particulate emission vented outdoors
was adjusted to avoid modeling requirements and I will need to see stronger justification for this process before I am able to accept
the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss
this in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle the
air for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these
calculated values due to several factors, and the calculated values represent a worst case scenario. This system includes several
small cyclones that are primarily used for material transfer from the milling process prior to the baghouses but the emission
reducon form these units is not included in the emission reducon calculaons. Addionally, the baghouses would be
expected to have higher efficiencies than the values used in the calculaons. Therefore, the system will operate at higher
efficiencies than the calculaons show and actual emissions would be less than these values. The flow from the baghouses is
discharged to certain interior areas of the building that will facilitate in the seling of parculates and the cleanup of
parculates for the recycling of the air. The parculate and process waste maer that is developed at this facility that cannot
be used as flour and is used as animal feed. Let me know if you have any other quesons.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…213/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of
PM10 and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the
atmosphere. This seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the
particulate that stays inside the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained
within the building, which is on the indoor line. These emissions would not be discharged to the outside of the building.
The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions discharged
to the atmosphere through the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt is also the
same for EU-08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…214/327
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the
building to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to
understand where the particulate goes since a substantial amount is routed indoors and the source is very close to reaching
the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case
the source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes.
The remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM
that it would be challenging to justify more expensive control. I will move forward with my BACT write up without a formal
written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system that
feeds air back into the mill. The reason for this design is to account for the need of extra airflow to reduce the
likelihood of creating a vacuum in the mill. If the air was not returned you would not be able to open a single
door in the mill. With that in mind, in the pressurization room, there is a “burp” vent type system that wouldallow some of the internal air to exit via the roof vent. All the baghouses (and cycle) vents associated with themilling are routed to the aforementioned process. The 60/40 split is an approximate number based on asimilar operating parameter at other mills throughout the portfolio. The HVAC designer confirmed that this is
even an overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control
Technology (BACT) please provide it. The facility equipment are being designed using current technologies and industry
standards to minimize emissions. The facility is construcng the mill in a way to reduce emissions consistent with using
the Best Available Control Technology (BACT). We can provide a wrien determinaon on the processes that are not
currently equipped with a baghouse, but the reducon in emissions per the cost basis would not be economically
viable or appropriate for the reducon provided by the baghouse/cyclone. Addionally, since the emissions that are
produced are essenally flour product any emissions from the milling or cleaning processes are essenally lost product
that could have been sold; therefore, the facility has a vested capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…215/327
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM emissions
are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the interior of the
building and then directed to through building roof vents. I believe the building's roof vents exhaust to the atmosphere. How
are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT)
analysis was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all emission
units and emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need to
pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun
my review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permit
application to only cover Phase I due to Phase II being more than a year out (greater than 14 months,but likely greater than 18). We have only included the Phase I in this application. With that in mind, theclient paid the $3,000 fee upon initial submittal, since we are modifying the application, should theysubmit via the online portal or can we submit via email. We want to make sure that they are not paying
$3,000 twice since only one application will apply. Can you please provide insight on the correct
submittal steps, or point us in the correct direction?

Kind Regards,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…216/327

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order
(AO) prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions, but I
imagine he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy
non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to
conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The
flour mill's emission estimates would need to drop below these values and be enforceable from a permitting
perspective. If you think this is possible, we can take this approach, but you will need to resubmit the NOI with new
emissions estimates. Before the second half of the site is constructed, you will need to submit a second NOI for a
minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by Chad
Gilgen who's the manager of the minor source compliance section. He can be reached at [e-mail] and at
385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…217/327

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the system
operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at
the full future maximum operang capacity. Only half of the facility is being constructed at this me so the
emissions would easily be reduced in half and with some addional flow reducons and adjustments the
facility could operate below the modeling threshold. So inially the facility would be running at limited
capacity based on the future potenal. So would it be possible to operate inially at a lower capacity with
calculated emission under the modeling threshold? We would connue with the modeling work, but this
may also allow us to beer define the model based on actual performance of the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed in
Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion modeling
analysis as part of a complete NOI. Based on the estimated emissions in your NOI, you will need to conduct
modeling and demonstrate compliance with all applicable national ambient air quality standards (NAAQS). I
recommend submitting a modeling protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the
modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please direct
those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…218/327

At this time, we have not completed the emissions impact analysis (modeling). That appears to
be a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does themodeling department perform the modeling in house at the UDEQ or how does that specificallywork? We have performed modeling in other states, and we understand that each state handles
modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when
opening attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI)
application for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked off
on the NOI application checklist but did not see any modeling analysis in the NOI. The estimated potential to
emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the source to
conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I
will provide some guidance and put you in contact with our modeling department to set up a modeling
protocol.

Thanks,
Dungan

--
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of the
message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of any of this
communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message and any
attachments from your system.

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
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Dungan Adams <[e-mail]>Thu, Nov 14, 2024 at 10:04 AM
To: "kirk.arens" <[e-mail]>
Kirk,
Since the facility's estimated emissions are based on tons of monthly throughput, I will need to include conditions that limit throughput. To determine
compliance with the throughput limits, the facility will be required to maintain records of throughput through the various operations at the mill.
Do you know how the facility will weigh grain/flour/feed by-product at the mill? We often see this done with belt or floor scales, but I wanted to check
with you to confirm what type of weighing systems you plan to use.
Thanks,
Dungan
On Wed, Nov 13, 2024 at 11:41 AM Dungan Adams <[e-mail]> wrote:
Great, thanks for confirming.
- Dungan
On Wed, Nov 13, 2024 at 11:41 AM kirk.arens <[e-mail]> wrote:
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to the
atmosphere through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12) internal grain
storage bins are not controlled by any equipment?

Thanks,
Dungan

On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…227/327
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floor bins,
1 feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution
source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number of
each will be included in the permit.

Thanks,
Dungan

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The
mill will not be capable of running product until the permit is in place but I was wondering if we can bring wheat into our
bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the
cyclones as this will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons
Spreadsheet with highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the
cyclones to the control efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100%
outdoors and 0% recirculated indoors as a worst case scenario and would provide an addional emission safety factor. Of note the
air that is recirculated back into the building flows through addional filters before being discharged back into the building to collect
parculate maer and further reduce interior emissions and the buildup of parculate maer within the building that needs to be
cleaned up. Let us know if you have any quesons or need any addional informaon.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…228/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently
calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without
exceeding modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a
good way to enforce this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the
facility from exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an unusually long
summer and the facility could exhaust for a greater period than what is anticipated. The permit would also need to ensure that 100% of
the recirculated baghouse exhaust remains and settles inside the building and ~18 TPY of particulate settling inside facility still seems
problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more
accurate estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling
baghouse by half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control
efficiencies are used across the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the
atmosphere, the facility will remain below the modeling threshold. With this approach this is no need to try and enforce the 60-40 split are
ensure that 100% of the recirculated air remains inside the facility. The facility would be able to use their HVAC system with full flexibility
and exhaust as much or as little of the grain milling baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our
calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations
provided in the most recent Notice of Intent (NOI).

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…229/327
The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of
the air flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged
back into a room in the interior of the building. We have seen this design in other setups where the discharge is generally directed to a
room before being directed to other building areas. Air within the building would be exhausted through various exhaust vents. These
exhaust fans are identified as emission point EP-RV on the permit documents. We estimated 25% of the particulate would be
contained in the building with the remaining 75% being emitted through the roof vent as a starting point. This emission split was likely
higher than required, but we were not certain of the distances and configuration from the emission point in the building to the roof
vents. In addition, we estimated that the whole facility air flow would be recirculated at a rate of 75% emitted through roof vents
outdoors and 25% would be returned internally. This number was further reduced in the most recent permit based on our
understanding that approximately 50% of this air would be circulated back into the building equipment and would not be exhausted.
Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process
equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit
and there is no changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a
valving system that determines how much of this air is discharged to the exterior of the building and how much of this air is
recirculated and directed through the RTUs and then back into the building. In the colder winter months this system would recirculate
100% of this air back into the building to maintain heat, with additional heating provided by the RTUs. In the summer months the
system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for more cool air to be drawn into the
building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all equipment with the
other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation system is closed during
cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a
thermostat based on interior and exterior temperatures and the following table was derived with monthly average temperatures for the
facility area to calculate split between exhausted and recirculated air. Based on this information the 40% to 60% split included in the
permit is scientifically correct. Another temperature analysis was performed with data from 2023 in the area of the facility and
approximately 36% of the days in the year had a high and low daily temperature above 65 degrees where the HVAC system would
discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage of exhausted air flow would be
expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…230/327

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been
built into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated
values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and noemission reduction factor for these units was included in the calculations. These units would be considered mediumefficiency cyclones, which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A
PM10 emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely thatthe facility will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wideemissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vestedinterest in reducing emissions and improving efficiency of the systems and assuring the emission equipment in place
is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why
the original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor
split. If Kirk or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture
product. However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to
understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratneywho is part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed the
mill line B from the initial application package, we revisited numerous calculations to better reflect what would be
happening with the emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC
engineers, we are familiar with this operation, but Ryan may be better suited with explaining how this process works
specifically. Essentially, similar to other mills, most of the recirculated air will cause the particulate matter to settle on
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…231/327
the floor within the mill. This waste settled material is constantly swept up and disposed of. It is not uncommon for
numerous tons to be disposed of in this fashion at similar sized mills across the country via the dumpster (garbage
service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions pastthe level represented in the NOI and submitted calculations. As to make everything easier to review on the agencyend, we tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed emissions
control rates submitted in the application as if the baghouses were set up in a parallel formation. As you can see in
the submittal there are three baghouses and at least one cyclone associated with the milling process. This vastly
reduces emissions below the levels within the calculations provided. As stated in previous emails any lost product or
by-product is lost revenue for the facility and company as a whole, so there is a vested interest in reducing
emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representativefor the facility and company as a whole. Ryan can also provide more knowledgeable and in-depth informationrelated to the HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5
tpy of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate
emissions are directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust
would be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75%
outdoor - 25% indoor split was used in the updated calculations, the source would be above the modeling threshold for PM10
emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it
changed from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and
I would like to see an example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like
they all use baghouses that vent directly to the atmosphere. From my perspective, it looks like the ratio of particulate emission
vented outdoors was adjusted to avoid modeling requirements and I will need to see stronger justification for this process before I
am able to accept the calculations.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…232/327
Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss
this in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle
the air for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these
calculated values due to several factors, and the calculated values represent a worst case scenario. This system includes
several small cyclones that are primarily used for material transfer from the milling process prior to the baghouses but the
emission reducon form these units is not included in the emission reducon calculaons. Addionally, the baghouses
would be expected to have higher efficiencies than the values used in the calculaons. Therefore, the system will operate at
higher efficiencies than the calculaons show and actual emissions would be less than these values. The flow from the
baghouses is discharged to certain interior areas of the building that will facilitate in the seling of parculates and the
cleanup of parculates for the recycling of the air. The parculate and process waste maer that is developed at this facility
that cannot be used as flour and is used as animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of
PM10 and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the
atmosphere. This seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the
particulate that stays inside the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…233/327
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained
within the building, which is on the indoor line. These emissions would not be discharged to the outside of the
building. The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions
discharged to the atmosphere through the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt
is also the same for EU-08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the
building to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to
understand where the particulate goes since a substantial amount is routed indoors and the source is very close to
reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case
the source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes.
The remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM
that it would be challenging to justify more expensive control. I will move forward with my BACT write up without a formal
written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization systemthat feeds air back into the mill. The reason for this design is to account for the need of extra airflow toreduce the likelihood of creating a vacuum in the mill. If the air was not returned you would not be able to
open a single door in the mill. With that in mind, in the pressurization room, there is a “burp” vent type
system that would allow some of the internal air to exit via the roof vent. All the baghouses (and cycle)
vents associated with the milling are routed to the aforementioned process. The 60/40 split is an
approximate number based on a similar operating parameter at other mills throughout the portfolio. The
HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control
Technology (BACT) please provide it. The facility equipment are being designed using current technologies and
industry standards to minimize emissions. The facility is construcng the mill in a way to reduce emissions consistent
with using the Best Available Control Technology (BACT). We can provide a wrien determinaon on the processes
that are not currently equipped with a baghouse, but the reducon in emissions per the cost basis would not be
economically viable or appropriate for the reducon provided by the baghouse/cyclone. Addionally, since the
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…234/327
emissions that are produced are essenally flour product any emissions from the milling or cleaning processes are
essenally lost product that could have been sold; therefore, the facility has a vested capital interest in reducing
emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM
emissions are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the
interior of the building and then directed to through building roof vents. I believe the building's roof vents exhaust to the
atmosphere. How are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT)
analysis was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all
emission units and emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need
to pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun
my review and will reach out if I have any questions about the project.

Thanks,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…235/327
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permit
application to only cover Phase I due to Phase II being more than a year out (greater than 14 months,but likely greater than 18). We have only included the Phase I in this application. With that in mind, theclient paid the $3,000 fee upon initial submittal, since we are modifying the application, should theysubmit via the online portal or can we submit via email. We want to make sure that they are not paying
$3,000 twice since only one application will apply. Can you please provide insight on the correct
submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order
(AO) prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions,
but I imagine he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy
non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to
conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The
flour mill's emission estimates would need to drop below these values and be enforceable from a permitting
perspective. If you think this is possible, we can take this approach, but you will need to resubmit the NOI with new
emissions estimates. Before the second half of the site is constructed, you will need to submit a second NOI for a
minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…236/327

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by
Chad Gilgen who's the manager of the minor source compliance section. He can be reached at
[e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the
system operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at
the full future maximum operang capacity. Only half of the facility is being constructed at this me so the
emissions would easily be reduced in half and with some addional flow reducons and adjustments the
facility could operate below the modeling threshold. So inially the facility would be running at limited
capacity based on the future potenal. So would it be possible to operate inially at a lower capacity with
calculated emission under the modeling threshold? We would connue with the modeling work, but this
may also allow us to beer define the model based on actual performance of the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…237/327
Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed
in Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion
modeling analysis as part of a complete NOI. Based on the estimated emissions in your NOI, you will need to
conduct modeling and demonstrate compliance with all applicable national ambient air quality standards
(NAAQS). I recommend submitting a modeling protocol to Dave Prey and Jason Krebs (cc'd in this email) to
help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please
direct those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears tobe a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the
modeling department perform the modeling in house at the UDEQ or how does that specifically
work? We have performed modeling in other states, and we understand that each state
handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when
opening attachments.

Hi Jack,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…238/327

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI)
application for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked
off on the NOI application checklist but did not see any modeling analysis in the NOI. The estimated
potential to emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the
source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I
will provide some guidance and put you in contact with our modeling department to set up a modeling
protocol.

Thanks,
Dungan

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged
and/or confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended
recipient, you are hereby notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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and/or confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient,
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communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby
notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have received this communication in error, notify
the sender immediately by return email and delete the message and any attachments from your system.

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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If
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by return email and delete the message and any attachments from your system.

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of
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of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message
and any attachments from your system.

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of
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any attachments from your system.

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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airquality.utah.gov

--

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M: [phone]
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2 attachments
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kirk.arens <[e-mail]>Thu, Nov 14, 2024 at 10:06 AM
To: Dungan Adams <[e-mail]>
We have online scales
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…246/327
From: Dungan Adams <[e-mail]>
Sent: Thursday, November 14, 2024 11:04:36 AM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,
Since the facility's estimated emissions are based on tons of monthly throughput, I will need to include conditions that limit throughput. To determine
compliance with the throughput limits, the facility will be required to maintain records of throughput through the various operations at the mill.
Do you know how the facility will weigh grain/flour/feed by-product at the mill? We often see this done with belt or floor scales, but I wanted to check
with you to confirm what type of weighing systems you plan to use.
Thanks,
Dungan
On Wed, Nov 13, 2024 at 11:41 AM Dungan Adams <[e-mail]> wrote:
Great, thanks for confirming.
- Dungan
On Wed, Nov 13, 2024 at 11:41 AM kirk.arens <[e-mail]> wrote:
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to the
atmosphere through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12) internal grain
storage bins are not controlled by any equipment?

Thanks,
Dungan

On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floor bins,
1 feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution
source.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…247/327

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number of
each will be included in the permit.

Thanks,
Dungan

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The
mill will not be capable of running product until the permit is in place but I was wondering if we can bring wheat into our
bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the
cyclones as this will be more consistent with the current system setup emissions. I have aached our revised Emission Calculaons
Spreadsheet with highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses and added the
cyclones to the control efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to be 100%
outdoors and 0% recirculated indoors as a worst case scenario and would provide an addional emission safety factor. Of note the
air that is recirculated back into the building flows through addional filters before being discharged back into the building to collect
parculate maer and further reduce interior emissions and the buildup of parculate maer within the building that needs to be
cleaned up. Let us know if you have any quesons or need any addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…248/327

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are currently
calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere without
exceeding modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think there is a
good way to enforce this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is stopping the
facility from exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an unusually long
summer and the facility could exhaust for a greater period than what is anticipated. The permit would also need to ensure that 100% of
the recirculated baghouse exhaust remains and settles inside the building and ~18 TPY of particulate settling inside facility still seems
problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more
accurate estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling
baghouse by half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control
efficiencies are used across the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the
atmosphere, the facility will remain below the modeling threshold. With this approach this is no need to try and enforce the 60-40 split are
ensure that 100% of the recirculated air remains inside the facility. The facility would be able to use their HVAC system with full flexibility
and exhaust as much or as little of the grain milling baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why our
calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the calculations
provided in the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding of
the air flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be discharged
back into a room in the interior of the building. We have seen this design in other setups where the discharge is generally directed to a
room before being directed to other building areas. Air within the building would be exhausted through various exhaust vents. These
exhaust fans are identified as emission point EP-RV on the permit documents. We estimated 25% of the particulate would be
contained in the building with the remaining 75% being emitted through the roof vent as a starting point. This emission split was likely
higher than required, but we were not certain of the distances and configuration from the emission point in the building to the roof
vents. In addition, we estimated that the whole facility air flow would be recirculated at a rate of 75% emitted through roof vents
outdoors and 25% would be returned internally. This number was further reduced in the most recent permit based on our
understanding that approximately 50% of this air would be circulated back into the building equipment and would not be exhausted.
Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some process
equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in the permit
and there is no changes with these units. However, the emission points identified as EP-RV have flow directed through ducts to a
valving system that determines how much of this air is discharged to the exterior of the building and how much of this air is
recirculated and directed through the RTUs and then back into the building. In the colder winter months this system would recirculate
100% of this air back into the building to maintain heat, with additional heating provided by the RTUs. In the summer months the
system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for more cool air to be drawn into the
building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all equipment with the
other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation system is closed during
cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a
thermostat based on interior and exterior temperatures and the following table was derived with monthly average temperatures for the
facility area to calculate split between exhausted and recirculated air. Based on this information the 40% to 60% split included in the
permit is scientifically correct. Another temperature analysis was performed with data from 2023 in the area of the facility and
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…249/327
approximately 36% of the days in the year had a high and low daily temperature above 65 degrees where the HVAC system would
discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage of exhausted air flow would be
expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have been
built into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these calculated
values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and noemission reduction factor for these units was included in the calculations. These units would be considered mediumefficiency cyclones, which would have a control efficiency of 50% for PM10; therefore, the milling equipment EU-06A
PM10 emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely thatthe facility will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wide
emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vestedinterest in reducing emissions and improving efficiency of the systems and assuring the emission equipment in placeis operating a peak efficiency.
Let us know if you have any further questions.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…250/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why
the original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor
split. If Kirk or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to capture
product. However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I need to
understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney
who is part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed the
mill line B from the initial application package, we revisited numerous calculations to better reflect what would be
happening with the emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC
engineers, we are familiar with this operation, but Ryan may be better suited with explaining how this process works
specifically. Essentially, similar to other mills, most of the recirculated air will cause the particulate matter to settle on
the floor within the mill. This waste settled material is constantly swept up and disposed of. It is not uncommon fornumerous tons to be disposed of in this fashion at similar sized mills across the country via the dumpster (garbageservice) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions past
the level represented in the NOI and submitted calculations. As to make everything easier to review on the agency
end, we tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed emissions
control rates submitted in the application as if the baghouses were set up in a parallel formation. As you can see in
the submittal there are three baghouses and at least one cyclone associated with the milling process. This vastly
reduces emissions below the levels within the calculations provided. As stated in previous emails any lost product or
by-product is lost revenue for the facility and company as a whole, so there is a vested interest in reducingemissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS representative
for the facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information
related to the HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…251/327
Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce 31.5
tpy of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate
emissions are directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust
would be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the 75%
outdoor - 25% indoor split was used in the updated calculations, the source would be above the modeling threshold for PM10
emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it
changed from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills and
I would like to see an example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks like
they all use baghouses that vent directly to the atmosphere. From my perspective, it looks like the ratio of particulate emission
vented outdoors was adjusted to avoid modeling requirements and I will need to see stronger justification for this process before I
am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to discuss
this in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle
the air for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the these
calculated values due to several factors, and the calculated values represent a worst case scenario. This system includes
several small cyclones that are primarily used for material transfer from the milling process prior to the baghouses but the
emission reducon form these units is not included in the emission reducon calculaons. Addionally, the baghouses
would be expected to have higher efficiencies than the values used in the calculaons. Therefore, the system will operate at
higher efficiencies than the calculaons show and actual emissions would be less than these values. The flow from the
baghouses is discharged to certain interior areas of the building that will facilitate in the seling of parculates and the
cleanup of parculates for the recycling of the air. The parculate and process waste maer that is developed at this facility
that cannot be used as flour and is used as animal feed. Let me know if you have any other quesons.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…252/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy of
PM10 and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the
atmosphere. This seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the
particulate that stays inside the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be contained
within the building, which is on the indoor line. These emissions would not be discharged to the outside of the
building. The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling emissions
discharged to the atmosphere through the vents, which is on the outdoor line for the milling. This indoor/ outdoor spilt
is also the same for EU-08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…253/327
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the
building to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to
understand where the particulate goes since a substantial amount is routed indoors and the source is very close to
reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your case
the source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting processes.
The remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor amounts of PM
that it would be challenging to justify more expensive control. I will move forward with my BACT write up without a formal
written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system
that feeds air back into the mill. The reason for this design is to account for the need of extra airflow to
reduce the likelihood of creating a vacuum in the mill. If the air was not returned you would not be able to
open a single door in the mill. With that in mind, in the pressurization room, there is a “burp” vent typesystem that would allow some of the internal air to exit via the roof vent. All the baghouses (and cycle)vents associated with the milling are routed to the aforementioned process. The 60/40 split is anapproximate number based on a similar operating parameter at other mills throughout the portfolio. The
HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control
Technology (BACT) please provide it. The facility equipment are being designed using current technologies and
industry standards to minimize emissions. The facility is construcng the mill in a way to reduce emissions consistent
with using the Best Available Control Technology (BACT). We can provide a wrien determinaon on the processes
that are not currently equipped with a baghouse, but the reducon in emissions per the cost basis would not be
economically viable or appropriate for the reducon provided by the baghouse/cyclone. Addionally, since the
emissions that are produced are essenally flour product any emissions from the milling or cleaning processes are
essenally lost product that could have been sold; therefore, the facility has a vested capital interest in reducing
emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…254/327
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM
emissions are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the
interior of the building and then directed to through building roof vents. I believe the building's roof vents exhaust to the
atmosphere. How are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT)
analysis was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all
emission units and emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not need
to pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have begun
my review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air permit
application to only cover Phase I due to Phase II being more than a year out (greater than 14 months,but likely greater than 18). We have only included the Phase I in this application. With that in mind, theclient paid the $3,000 fee upon initial submittal, since we are modifying the application, should theysubmit via the online portal or can we submit via email. We want to make sure that they are not paying
$3,000 twice since only one application will apply. Can you please provide insight on the correct
submittal steps, or point us in the correct direction?

Kind Regards,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…255/327

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval Order
(AO) prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have questions,
but I imagine he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66 tpy
non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to
conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5. The
flour mill's emission estimates would need to drop below these values and be enforceable from a permitting
perspective. If you think this is possible, we can take this approach, but you will need to resubmit the NOI with new
emissions estimates. Before the second half of the site is constructed, you will need to submit a second NOI for a
minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by
Chad Gilgen who's the manager of the minor source compliance section. He can be reached at
[e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…256/327
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the
system operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario at
the full future maximum operang capacity. Only half of the facility is being constructed at this me so the
emissions would easily be reduced in half and with some addional flow reducons and adjustments the
facility could operate below the modeling threshold. So inially the facility would be running at limited
capacity based on the future potenal. So would it be possible to operate inially at a lower capacity with
calculated emission under the modeling threshold? We would connue with the modeling work, but this
may also allow us to beer define the model based on actual performance of the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those listed
in Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion
modeling analysis as part of a complete NOI. Based on the estimated emissions in your NOI, you will need to
conduct modeling and demonstrate compliance with all applicable national ambient air quality standards
(NAAQS). I recommend submitting a modeling protocol to Dave Prey and Jason Krebs (cc'd in this email) to
help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please
direct those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…257/327
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears to
be a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does themodeling department perform the modeling in house at the UDEQ or how does that specificallywork? We have performed modeling in other states, and we understand that each state
handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution when
opening attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI)
application for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was checked
off on the NOI application checklist but did not see any modeling analysis in the NOI. The estimated
potential to emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds which require the
source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have not, I
will provide some guidance and put you in contact with our modeling department to set up a modeling
protocol.

Thanks,
Dungan

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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airquality.utah.gov

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2 attachments
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Dungan Adams <[e-mail]>Thu, Nov 14, 2024 at 10:08 AM
To: "kirk.arens" <[e-mail]>
Can you explain what you mean by online scales?
Thanks,
Dungan
On Thu, Nov 14, 2024 at 10:06 AM kirk.arens <[e-mail]> wrote:
We have online scales
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Thursday, November 14, 2024 11:04:36 AM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,
Since the facility's estimated emissions are based on tons of monthly throughput, I will need to include conditions that limit throughput. To
determine compliance with the throughput limits, the facility will be required to maintain records of throughput through the various operations at the
mill.
Do you know how the facility will weigh grain/flour/feed by-product at the mill? We often see this done with belt or floor scales, but I wanted to
check with you to confirm what type of weighing systems you plan to use.
Thanks,
Dungan
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…266/327
On Wed, Nov 13, 2024 at 11:41 AM Dungan Adams <[e-mail]> wrote:
Great, thanks for confirming.
- Dungan
On Wed, Nov 13, 2024 at 11:41 AM kirk.arens <[e-mail]> wrote:
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to the
atmosphere through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12) internal grain
storage bins are not controlled by any equipment?

Thanks,
Dungan

On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floorbins, 1 feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution
source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number
of each will be included in the permit.

Thanks,
Dungan

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. The
mill will not be capable of running product until the permit is in place but I was wondering if we can bring wheat into our
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…267/327
bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the
cyclones as this will be more consistent with the current system setup emissions. I have aached our revised Emission
Calculaons Spreadsheet with highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses
and added the cyclones to the control efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system to
be 100% outdoors and 0% recirculated indoors as a worst case scenario and would provide an addional emission safety factor. Of
note the air that is recirculated back into the building flows through addional filters before being discharged back into the
building to collect parculate maer and further reduce interior emissions and the buildup of parculate maer within the
building that needs to be cleaned up. Let us know if you have any quesons or need any addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are
currently calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere
without exceeding modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think
there is a good way to enforce this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is
stopping the facility from exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an
unusually long summer and the facility could exhaust for a greater period than what is anticipated. The permit would also need to
ensure that 100% of the recirculated baghouse exhaust remains and settles inside the building and ~18 TPY of particulate settling
inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more
accurate estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…268/327
0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling
baghouse by half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control
efficiencies are used across the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the
atmosphere, the facility will remain below the modeling threshold. With this approach this is no need to try and enforce the 60-40 split
are ensure that 100% of the recirculated air remains inside the facility. The facility would be able to use their HVAC system with full
flexibility and exhaust as much or as little of the grain milling baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why
our calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the
calculations provided in the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding
of the air flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be
discharged back into a room in the interior of the building. We have seen this design in other setups where the discharge is
generally directed to a room before being directed to other building areas. Air within the building would be exhausted through
various exhaust vents. These exhaust fans are identified as emission point EP-RV on the permit documents. We estimated 25% of
the particulate would be contained in the building with the remaining 75% being emitted through the roof vent as a starting point.
This emission split was likely higher than required, but we were not certain of the distances and configuration from the emission
point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated at a rate of 75%
emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent
permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and
would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some
process equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified in
the permit and there is no changes with these units. However, the emission points identified as EP-RV have flow directed through
ducts to a valving system that determines how much of this air is discharged to the exterior of the building and how much of this air
is recirculated and directed through the RTUs and then back into the building. In the colder winter months this system would
recirculate 100% of this air back into the building to maintain heat, with additional heating provided by the RTUs. In the summer
months the system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for more cool air to be drawn
into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all equipment
with the other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation system is closed
during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC valving system is
controlled by a thermostat based on interior and exterior temperatures and the following table was derived with monthly average
temperatures for the facility area to calculate split between exhausted and recirculated air. Based on this information the 40% to
60% split included in the permit is scientifically correct. Another temperature analysis was performed with data from 2023 in the area
of the facility and approximately 36% of the days in the year had a high and low daily temperature above 65 degrees where the
HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage of
exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…269/327
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have
been built into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these
calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no
emission reduction factor for these units was included in the calculations. These units would be consideredmedium efficiency cyclones, which would have a control efficiency of 50% for PM10; therefore, the milling
equipment EU-06A PM10 emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely thatthe facility will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wideemissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vestedinterest in reducing emissions and improving efficiency of the systems and assuring the emission equipment inplace is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…270/327

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why
the original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor
split. If Kirk or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to
capture product. However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I
need to understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney
who is part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed
the mill line B from the initial application package, we revisited numerous calculations to better reflect what would
be happening with the emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC
engineers, we are familiar with this operation, but Ryan may be better suited with explaining how this process
works specifically. Essentially, similar to other mills, most of the recirculated air will cause the particulate matter to
settle on the floor within the mill. This waste settled material is constantly swept up and disposed of. It is notuncommon for numerous tons to be disposed of in this fashion at similar sized mills across the country via thedumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions
past the level represented in the NOI and submitted calculations. As to make everything easier to review on the
agency end, we tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed
emissions control rates submitted in the application as if the baghouses were set up in a parallel formation. As you
can see in the submittal there are three baghouses and at least one cyclone associated with the milling process.
This vastly reduces emissions below the levels within the calculations provided. As stated in previous emails any
lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested interest inreducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHSrepresentative for the facility and company as a whole. Ryan can also provide more knowledgeable and in-depth
information related to the HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…271/327
From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce
31.5 tpy of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate
emissions are directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The exhaust
would be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors. If the
75% outdoor - 25% indoor split was used in the updated calculations, the source would be above the modeling threshold for
PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it
changed from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills
and I would like to see an example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks
like they all use baghouses that vent directly to the atmosphere. From my perspective, it looks like the ratio of particulate
emission vented outdoors was adjusted to avoid modeling requirements and I will need to see stronger justification for this
process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to
discuss this in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle
the air for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the
these calculated values due to several factors, and the calculated values represent a worst case scenario. This system
includes several small cyclones that are primarily used for material transfer from the milling process prior to the
baghouses but the emission reducon form these units is not included in the emission reducon calculaons. Addionally,
the baghouses would be expected to have higher efficiencies than the values used in the calculaons. Therefore, the
system will operate at higher efficiencies than the calculaons show and actual emissions would be less than these values.
The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in the seling of
parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste maer that is
developed at this facility that cannot be used as flour and is used as animal feed. Let me know if you have any other
quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…272/327
From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy
of PM10 and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the
atmosphere. This seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the
particulate that stays inside the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be
contained within the building, which is on the indoor line. These emissions would not be discharged to the outside of
the building. The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling
emissions discharged to the atmosphere through the vents, which is on the outdoor line for the milling. This indoor/
outdoor spilt is also the same for EU-08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the
building to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to
understand where the particulate goes since a substantial amount is routed indoors and the source is very close to
reaching the modeling threshold.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…273/327

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your
case the source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting
processes. The remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor
amounts of PM that it would be challenging to justify more expensive control. I will move forward with my BACT write up
without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization systemthat feeds air back into the mill. The reason for this design is to account for the need of extra airflow to
reduce the likelihood of creating a vacuum in the mill. If the air was not returned you would not be able to
open a single door in the mill. With that in mind, in the pressurization room, there is a “burp” vent type
system that would allow some of the internal air to exit via the roof vent. All the baghouses (and cycle)
vents associated with the milling are routed to the aforementioned process. The 60/40 split is an
approximate number based on a similar operating parameter at other mills throughout the portfolio. The
HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the
system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control
Technology (BACT) please provide it. The facility equipment are being designed using current technologies and
industry standards to minimize emissions. The facility is construcng the mill in a way to reduce emissions
consistent with using the Best Available Control Technology (BACT). We can provide a wrien determinaon on
the processes that are not currently equipped with a baghouse, but the reducon in emissions per the cost basis
would not be economically viable or appropriate for the reducon provided by the baghouse/cyclone.
Addionally, since the emissions that are produced are essenally flour product any emissions from the milling or
cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested
capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…274/327
- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM
emissions are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the
interior of the building and then directed to through building roof vents. I believe the building's roof vents exhaust to the
atmosphere. How are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT)
analysis was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all
emission units and emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not
need to pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have
begun my review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air
permit application to only cover Phase I due to Phase II being more than a year out (greater than 14
months, but likely greater than 18). We have only included the Phase I in this application. With that
in mind, the client paid the $3,000 fee upon initial submittal, since we are modifying the application,should they submit via the online portal or can we submit via email. We want to make sure that theyare not paying $3,000 twice since only one application will apply. Can you please provide insight onthe correct submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…275/327
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval
Order (AO) prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have
questions, but I imagine he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66
tpy non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement to
conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5.
The flour mill's emission estimates would need to drop below these values and be enforceable from a permitting
perspective. If you think this is possible, we can take this approach, but you will need to resubmit the NOI with
new emissions estimates. Before the second half of the site is constructed, you will need to submit a second NOI
for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by
Chad Gilgen who's the manager of the minor source compliance section. He can be reached at
[e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the
system operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario
at the full future maximum operang capacity. Only half of the facility is being constructed at this me
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…276/327
so the emissions would easily be reduced in half and with some addional flow reducons and
adjustments the facility could operate below the modeling threshold. So inially the facility would be
running at limited capacity based on the future potenal. So would it be possible to operate inially at a
lower capacity with calculated emission under the modeling threshold? We would connue with the
modeling work, but this may also allow us to beer define the model based on actual performance of
the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those
listed in Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a dispersion
modeling analysis as part of a complete NOI. Based on the estimated emissions in your NOI, you will need
to conduct modeling and demonstrate compliance with all applicable national ambient air quality standards
(NAAQS). I recommend submitting a modeling protocol to Dave Prey and Jason Krebs (cc'd in this email) to
help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please
direct those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears
to be a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does themodeling department perform the modeling in house at the UDEQ or how does thatspecifically work? We have performed modeling in other states, and we understand that eachstate handles modeling differently.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…277/327

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution
when opening attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI)
application for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was
checked off on the NOI application checklist but did not see any modeling analysis in the NOI. The
estimated potential to emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds which
require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have
not, I will provide some guidance and put you in contact with our modeling department to set up a
modeling protocol.

Thanks,
Dungan

--

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…278/327

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is
privileged and/or confidential. If the reader of the message is not the intended recipient or an authorized representative of the
intended recipient, you are hereby notified that any use and/or dissemination of any of this communication is strictly prohibited.
If you have received this communication in error, notify the sender immediately by return email and delete the message and any
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--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged
and/or confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended
recipient, you are hereby notified that any use and/or dissemination of any of this communication is strictly prohibited. If you have
received this communication in error, notify the sender immediately by return email and delete the message and any attachments
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
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communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby
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notify the sender immediately by return email and delete the message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
confidential. If the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby
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--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
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email and delete the message and any attachments from your system.

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or
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and delete the message and any attachments from your system.

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader of
the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of any
of this communication is strictly prohibited. If you have received this communication in error, notify the sender immediately by return email and delete the message
and any attachments from your system.

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--

Dungan Adams
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
Dungan Adams <[e-mail]>Mon, Nov 18, 2024 at 1:13 PM
To: "kirk.arens" <[e-mail]>
Hi Kirk,
Following up about my question from last Thursday.
Thanks,
Dungan
On Thu, Nov 14, 2024 at 10:08 AM Dungan Adams <[e-mail]> wrote:
Can you explain what you mean by online scales?
Thanks,
Dungan
On Thu, Nov 14, 2024 at 10:06 AM kirk.arens <[e-mail]> wrote:
We have online scales
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Thursday, November 14, 2024 11:04:36 AM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,
Since the facility's estimated emissions are based on tons of monthly throughput, I will need to include conditions that limit throughput. To
determine compliance with the throughput limits, the facility will be required to maintain records of throughput through the various operations at the
mill.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…286/327
Do you know how the facility will weigh grain/flour/feed by-product at the mill? We often see this done with belt or floor scales, but I wanted to
check with you to confirm what type of weighing systems you plan to use.
Thanks,
Dungan
On Wed, Nov 13, 2024 at 11:41 AM Dungan Adams <[e-mail]> wrote:
Great, thanks for confirming.
- Dungan
On Wed, Nov 13, 2024 at 11:41 AM kirk.arens <[e-mail]> wrote:
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to theatmosphere through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12) internal grain
storage bins are not controlled by any equipment?

Thanks,
Dungan

On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floorbins, 1 feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution
source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number
of each will be included in the permit.

Thanks,
Dungan
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…287/327

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. Themill will not be capable of running product until the permit is in place but I was wondering if we can bring wheat into ourbins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the
cyclones as this will be more consistent with the current system setup emissions. I have aached our revised Emission
Calculaons Spreadsheet with highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses
and added the cyclones to the control efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system
to be 100% outdoors and 0% recirculated indoors as a worst case scenario and would provide an addional emission safety
factor. Of note the air that is recirculated back into the building flows through addional filters before being discharged back into
the building to collect parculate maer and further reduce interior emissions and the buildup of parculate maer within the
building that needs to be cleaned up. Let us know if you have any quesons or need any addional informaon.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are
currently calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere
without exceeding modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think
there is a good way to enforce this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is
stopping the facility from exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an
unusually long summer and the facility could exhaust for a greater period than what is anticipated. The permit would also need to
ensure that 100% of the recirculated baghouse exhaust remains and settles inside the building and ~18 TPY of particulate settling
inside facility still seems problematic to me.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…288/327

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more
accurate estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling
baghouse by half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control
efficiencies are used across the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the
atmosphere, the facility will remain below the modeling threshold. With this approach this is no need to try and enforce the 60-40 split
are ensure that 100% of the recirculated air remains inside the facility. The facility would be able to use their HVAC system with full
flexibility and exhaust as much or as little of the grain milling baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why
our calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the
calculations provided in the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding
of the air flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be
discharged back into a room in the interior of the building. We have seen this design in other setups where the discharge is
generally directed to a room before being directed to other building areas. Air within the building would be exhausted through
various exhaust vents. These exhaust fans are identified as emission point EP-RV on the permit documents. We estimated 25% of
the particulate would be contained in the building with the remaining 75% being emitted through the roof vent as a starting point.
This emission split was likely higher than required, but we were not certain of the distances and configuration from the emission
point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated at a rate of 75%
emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent
permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and
would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some
process equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified
in the permit and there is no changes with these units. However, the emission points identified as EP-RV have flow directed
through ducts to a valving system that determines how much of this air is discharged to the exterior of the building and how much
of this air is recirculated and directed through the RTUs and then back into the building. In the colder winter months this system
would recirculate 100% of this air back into the building to maintain heat, with additional heating provided by the RTUs. In the
summer months the system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for more cool air to
be drawn into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all
equipment with the other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation
system is closed during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC
valving system is controlled by a thermostat based on interior and exterior temperatures and the following table was derived with
monthly average temperatures for the facility area to calculate split between exhausted and recirculated air. Based on this
information the 40% to 60% split included in the permit is scientifically correct. Another temperature analysis was performed with
data from 2023 in the area of the facility and approximately 36% of the days in the year had a high and low daily temperature
above 65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both
cases the percentage of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…289/327
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have
been built into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these
calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and no
emission reduction factor for these units was included in the calculations. These units would be consideredmedium efficiency cyclones, which would have a control efficiency of 50% for PM10; therefore, the milling
equipment EU-06A PM10 emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely thatthe facility will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wideemissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vestedinterest in reducing emissions and improving efficiency of the systems and assuring the emission equipment inplace is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…290/327

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why
the original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor
split. If Kirk or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to
capture product. However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I
need to understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney
who is part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed
the mill line B from the initial application package, we revisited numerous calculations to better reflect what would
be happening with the emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC
engineers, we are familiar with this operation, but Ryan may be better suited with explaining how this process
works specifically. Essentially, similar to other mills, most of the recirculated air will cause the particulate matter tosettle on the floor within the mill. This waste settled material is constantly swept up and disposed of. It is notuncommon for numerous tons to be disposed of in this fashion at similar sized mills across the country via thedumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissions
past the level represented in the NOI and submitted calculations. As to make everything easier to review on the
agency end, we tried to limit step-wise or series calculations and simply apply the manufacturer guaranteed
emissions control rates submitted in the application as if the baghouses were set up in a parallel formation. As
you can see in the submittal there are three baghouses and at least one cyclone associated with the milling
process. This vastly reduces emissions below the levels within the calculations provided. As stated in previousemails any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vestedinterest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS
representative for the facility and company as a whole. Ryan can also provide more knowledgeable and in-depth
information related to the HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer your
questions.

Kind Regards,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…291/327

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce
31.5 tpy of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate
emissions are directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The
exhaust would be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors.
If the 75% outdoor - 25% indoor split was used in the updated calculations, the source would be above the modeling threshold
for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it
changed from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills
and I would like to see an example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks
like they all use baghouses that vent directly to the atmosphere. From my perspective, it looks like the ratio of particulate
emission vented outdoors was adjusted to avoid modeling requirements and I will need to see stronger justification for this
process before I am able to accept the calculations.

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to
discuss this in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle
the air for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the
these calculated values due to several factors, and the calculated values represent a worst case scenario. This system
includes several small cyclones that are primarily used for material transfer from the milling process prior to the
baghouses but the emission reducon form these units is not included in the emission reducon calculaons.
Addionally, the baghouses would be expected to have higher efficiencies than the values used in the calculaons.
Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less
than these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in
the seling of parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste
maer that is developed at this facility that cannot be used as flour and is used as animal feed. Let me know if you have
any other quesons.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…292/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy
of PM10 and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the
atmosphere. This seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the
particulate that stays inside the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be
contained within the building, which is on the indoor line. These emissions would not be discharged to the outside
of the building. The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling
emissions discharged to the atmosphere through the vents, which is on the outdoor line for the milling. This indoor/
outdoor spilt is also the same for EU-08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…293/327
Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the
building to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to
understand where the particulate goes since a substantial amount is routed indoors and the source is very close to
reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in yourcase the source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting
processes. The remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor
amounts of PM that it would be challenging to justify more expensive control. I will move forward with my BACT write up
without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system
that feeds air back into the mill. The reason for this design is to account for the need of extra airflow to
reduce the likelihood of creating a vacuum in the mill. If the air was not returned you would not be able
to open a single door in the mill. With that in mind, in the pressurization room, there is a “burp” vent type
system that would allow some of the internal air to exit via the roof vent. All the baghouses (and cycle)
vents associated with the milling are routed to the aforementioned process. The 60/40 split is an
approximate number based on a similar operating parameter at other mills throughout the portfolio. TheHVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via thesystem.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control
Technology (BACT) please provide it. The facility equipment are being designed using current technologies and
industry standards to minimize emissions. The facility is construcng the mill in a way to reduce emissions
consistent with using the Best Available Control Technology (BACT). We can provide a wrien determinaon on
the processes that are not currently equipped with a baghouse, but the reducon in emissions per the cost basis
would not be economically viable or appropriate for the reducon provided by the baghouse/cyclone.
Addionally, since the emissions that are produced are essenally flour product any emissions from the milling or
cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested
capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…294/327
Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM
emissions are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the
interior of the building and then directed to through building roof vents. I believe the building's roof vents exhaust to
the atmosphere. How are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT)
analysis was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all
emission units and emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not
need to pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have
begun my review and will reach out if I have any questions about the project.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air
permit application to only cover Phase I due to Phase II being more than a year out (greater than
14 months, but likely greater than 18). We have only included the Phase I in this application. With
that in mind, the client paid the $3,000 fee upon initial submittal, since we are modifying the
application, should they submit via the online portal or can we submit via email. We want to make
sure that they are not paying $3,000 twice since only one application will apply. Can you pleaseprovide insight on the correct submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…295/327
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval
Order (AO) prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have
questions, but I imagine he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66
tpy non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement
to conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5.
The flour mill's emission estimates would need to drop below these values and be enforceable from a permitting
perspective. If you think this is possible, we can take this approach, but you will need to resubmit the NOI with
new emissions estimates. Before the second half of the site is constructed, you will need to submit a second
NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by
Chad Gilgen who's the manager of the minor source compliance section. He can be reached at
[e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…296/327

1. The facility would like to start loading grain at the facility before long to start tesng some of the
system operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario
at the full future maximum operang capacity. Only half of the facility is being constructed at this me
so the emissions would easily be reduced in half and with some addional flow reducons and
adjustments the facility could operate below the modeling threshold. So inially the facility would be
running at limited capacity based on the future potenal. So would it be possible to operate inially at
a lower capacity with calculated emission under the modeling threshold? We would connue with the
modeling work, but this may also allow us to beer define the model based on actual performance of
the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those
listed in Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a
dispersion modeling analysis as part of a complete NOI. Based on the estimated emissions in your NOI,
you will need to conduct modeling and demonstrate compliance with all applicable national ambient air
quality standards (NAAQS). I recommend submitting a modeling protocol to Dave Prey and Jason Krebs
(cc'd in this email) to help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please
direct those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…297/327
At this time, we have not completed the emissions impact analysis (modeling). That appears
to be a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does themodeling department perform the modeling in house at the UDEQ or how does thatspecifically work? We have performed modeling in other states, and we understand thateach state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution
when opening attachments.

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI)
application for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was
checked off on the NOI application checklist but did not see any modeling analysis in the NOI. The
estimated potential to emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds
which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have
not, I will provide some guidance and put you in contact with our modeling department to set up a
modeling protocol.

Thanks,
Dungan

--
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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privileged and/or confidential. If the reader of the message is not the intended recipient or an authorized representative of the
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If you have received this communication in error, notify the sender immediately by return email and delete the message and
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
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communication in error, notify the sender immediately by return email and delete the message and any attachments from your system.

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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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--

Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If
the reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the
reader of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or
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and delete the message and any attachments from your system.

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

This message and any attachments are intended only for the use of the addressee and may contain information that is privileged and/or confidential. If the reader
of the message is not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any use and/or dissemination of
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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Environmental Engineer | Minor NSR Section
M: [phone]
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
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Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov
kirk.arens <[e-mail]>Mon, Nov 18, 2024 at 1:31 PM
To: Dungan Adams <[e-mail]>
We have in process scales that continuously weight product streams as we use and make product. It gives us real time information on wheat used
and flour and by products made
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Monday, November 18, 2024 1:13:22 PM
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…306/327
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,
Following up about my question from last Thursday.
Thanks,
Dungan
On Thu, Nov 14, 2024 at 10:08 AM Dungan Adams <[e-mail]> wrote:
Can you explain what you mean by online scales?
Thanks,
Dungan
On Thu, Nov 14, 2024 at 10:06 AM kirk.arens <[e-mail]> wrote:
We have online scales
Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Thursday, November 14, 2024 11:04:36 AM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,
Since the facility's estimated emissions are based on tons of monthly throughput, I will need to include conditions that limit throughput. To
determine compliance with the throughput limits, the facility will be required to maintain records of throughput through the various operations at the
mill.
Do you know how the facility will weigh grain/flour/feed by-product at the mill? We often see this done with belt or floor scales, but I wanted to
check with you to confirm what type of weighing systems you plan to use.
Thanks,
Dungan
On Wed, Nov 13, 2024 at 11:41 AM Dungan Adams <[e-mail]> wrote:
Great, thanks for confirming.
- Dungan
On Wed, Nov 13, 2024 at 11:41 AM kirk.arens <[e-mail]> wrote:
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to the
atmosphere through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12) internal grain
storage bins are not controlled by any equipment?

Thanks,
Dungan

On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 inside floor
bins, 1 feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be completed.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…307/327

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction, modification, or
establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat storage is an air pollution
source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The number
of each will be included in the permit.

Thanks,
Dungan

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into the facility. Themill will not be capable of running product until the permit is in place but I was wondering if we can bring wheat into ourbins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency for the
cyclones as this will be more consistent with the current system setup emissions. I have aached our revised Emission
Calculaons Spreadsheet with highlighng showing the cells with revised inputs. We increased the efficiency of the baghouses
and added the cyclones to the control efficiency for the grain mill (EU-05A). We also adjusted the discharge for the vent system
to be 100% outdoors and 0% recirculated indoors as a worst case scenario and would provide an addional emission safety
factor. Of note the air that is recirculated back into the building flows through addional filters before being discharged back into
the building to collect parculate maer and further reduce interior emissions and the buildup of parculate maer within the
building that needs to be cleaned up. Let us know if you have any quesons or need any addional informaon.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…308/327

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions are
currently calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the atmosphere
without exceeding modeling thresholds. Especially because of the seasonal temperature justification of the 60-40 split, I do not think
there is a good way to enforce this without requiring a lot of stack testing. If there is no enforceable limit in the permit, then nothing is
stopping the facility from exhausting greater than 40% of the baghouse emissions to the atmosphere. Richmond could experience an
unusually long summer and the facility could exhaust for a greater period than what is anticipated. The permit would also need to
ensure that 100% of the recirculated baghouse exhaust remains and settles inside the building and ~18 TPY of particulate settling
inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to calculate more
accurate estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain milling
baghouse by half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42 baghouse control
efficiencies are used across the facility, if we conservatively assume that all of the baghouse emissions are exhausted to the
atmosphere, the facility will remain below the modeling threshold. With this approach this is no need to try and enforce the 60-40 split
are ensure that 100% of the recirculated air remains inside the facility. The facility would be able to use their HVAC system with full
flexibility and exhaust as much or as little of the grain milling baghouse exhaust as necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should justify why
our calculations have been revised and give real world data and “good engineering practice” as to how we arrived at the
calculations provided in the most recent Notice of Intent (NOI).

The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original understanding
of the air flow system design was that the air from some systems, including the mill exhaust after the baghouses, would be
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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discharged back into a room in the interior of the building. We have seen this design in other setups where the discharge is
generally directed to a room before being directed to other building areas. Air within the building would be exhausted through
various exhaust vents. These exhaust fans are identified as emission point EP-RV on the permit documents. We estimated 25% of
the particulate would be contained in the building with the remaining 75% being emitted through the roof vent as a starting point.
This emission split was likely higher than required, but we were not certain of the distances and configuration from the emission
point in the building to the roof vents. In addition, we estimated that the whole facility air flow would be recirculated at a rate of 75%
emitted through roof vents outdoors and 25% would be returned internally. This number was further reduced in the most recent
permit based on our understanding that approximately 50% of this air would be circulated back into the building equipment and
would not be exhausted. Therefore, the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is some
process equipment that draws in air from inside the building, which is discharged through emission points (outdoors) as identified
in the permit and there is no changes with these units. However, the emission points identified as EP-RV have flow directed
through ducts to a valving system that determines how much of this air is discharged to the exterior of the building and how much
of this air is recirculated and directed through the RTUs and then back into the building. In the colder winter months this system
would recirculate 100% of this air back into the building to maintain heat, with additional heating provided by the RTUs. In the
summer months the system may be opened up to discharge nearly 100% of the airflow to the exterior to allow for more cool air to
be drawn into the building. This recirculation system accounts for 45,000 CFM of the total 80,000 CFM that is drawn through all
equipment with the other air flows being discharged (outdoors) through other emission points. Therefore, when this circulation
system is closed during cooler periods an additional 35,000 CFM of fresh air is still being drawn into the building. The HVAC
valving system is controlled by a thermostat based on interior and exterior temperatures and the following table was derived with
monthly average temperatures for the facility area to calculate split between exhausted and recirculated air. Based on this
information the 40% to 60% split included in the permit is scientifically correct. Another temperature analysis was performed with
data from 2023 in the area of the facility and approximately 36% of the days in the year had a high and low daily temperature
above 65 degrees where the HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both
cases the percentage of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month Average High Average Low Average High Average Low Ave Temp % Exhausted % Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that have
been built into these emission calculations as discussed below; therefore, the actual facility emissions would be lower than these
calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the mill and noemission reduction factor for these units was included in the calculations. These units would be consideredmedium efficiency cyclones, which would have a control efficiency of 50% for PM10; therefore, the milling
equipment EU-06A PM10 emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It is unlikely thatthe facility will be able to maintain this flow rate as there will be down time for repairs and maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facility wideemissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vestedinterest in reducing emissions and improving efficiency of the systems and assuring the emission equipment in
place is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanation for why
the original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40% outdoor - 60% indoor
split. If Kirk or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest to
capture product. However, the emission calculations that were provided in the updated NOI are close to modeling thresholds and I
need to understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with Bratney
who is part of the team responsible for designing the air flow and hvac systems for this facility. Once we removed
the mill line B from the initial application package, we revisited numerous calculations to better reflect what would
be happening with the emissions associated with mill line A. Please keep in mind that Scott and I are not HVAC
engineers, we are familiar with this operation, but Ryan may be better suited with explaining how this process
works specifically. Essentially, similar to other mills, most of the recirculated air will cause the particulate matter to
settle on the floor within the mill. This waste settled material is constantly swept up and disposed of. It is not
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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uncommon for numerous tons to be disposed of in this fashion at similar sized mills across the country via the
dumpster (garbage service) or other alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce the emissionspast the level represented in the NOI and submitted calculations. As to make everything easier to review on theagency end, we tried to limit step-wise or series calculations and simply apply the manufacturer guaranteedemissions control rates submitted in the application as if the baghouses were set up in a parallel formation. As
you can see in the submittal there are three baghouses and at least one cyclone associated with the milling
process. This vastly reduces emissions below the levels within the calculations provided. As stated in previous
emails any lost product or by-product is lost revenue for the facility and company as a whole, so there is a vested
interest in reducing emissions and improving efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS
representative for the facility and company as a whole. Ryan can also provide more knowledgeable and in-depthinformation related to the HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better answer yourquestions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated to produce
31.5 tpy of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where 75% of particulate
emissions are directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The
exhaust would be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain indoors.
If the 75% outdoor - 25% indoor split was used in the updated calculations, the source would be above the modeling threshold
for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and why it
changed from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used at other mills
and I would like to see an example of a mill that operates this way. I searched the other permitted flour mills in Utah and it looks
like they all use baghouses that vent directly to the atmosphere. From my perspective, it looks like the ratio of particulate
emission vented outdoors was adjusted to avoid modeling requirements and I will need to see stronger justification for this
process before I am able to accept the calculations.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…312/327
Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back to
discuss this in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and recycle
the air for air handling balancing purposes. In pracce the actual dust that accumulates in the building is less than the
these calculated values due to several factors, and the calculated values represent a worst case scenario. This system
includes several small cyclones that are primarily used for material transfer from the milling process prior to the
baghouses but the emission reducon form these units is not included in the emission reducon calculaons.
Addionally, the baghouses would be expected to have higher efficiencies than the values used in the calculaons.
Therefore, the system will operate at higher efficiencies than the calculaons show and actual emissions would be less
than these values. The flow from the baghouses is discharged to certain interior areas of the building that will facilitate in
the seling of parculates and the cleanup of parculates for the recycling of the air. The parculate and process waste
maer that is developed at this facility that cannot be used as flour and is used as animal feed. Let me know if you have
any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation, ~30 tpy
of PM10 and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40% being vented to the
atmosphere. This seems like a huge amount of particulate inside of the building. Can you elaborate on what happens to the
particulate that stays inside the building? If it is captured for reuse, how does the capture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would be
contained within the building, which is on the indoor line. These emissions would not be discharged to the outside
of the building. The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40% fracon of the milling
emissions discharged to the atmosphere through the vents, which is on the outdoor line for the milling. This indoor/
outdoor spilt is also the same for EU-08A but this unit have has very minor emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors exit the
building to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide PTE. I just want to
understand where the particulate goes since a substantial amount is routed indoors and the source is very close to
reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but in your
case the source has chosen to use baghouses (generally the best control option for PM) for all of the primary emitting
processes. The remaining processes that are uncontrolled or controlled with lower efficiency filters produce such minor
amounts of PM that it would be challenging to justify more expensive control. I will move forward with my BACT write up
without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurization system
that feeds air back into the mill. The reason for this design is to account for the need of extra airflow to
reduce the likelihood of creating a vacuum in the mill. If the air was not returned you would not be ableto open a single door in the mill. With that in mind, in the pressurization room, there is a “burp” vent typesystem that would allow some of the internal air to exit via the roof vent. All the baghouses (and cycle)vents associated with the milling are routed to the aforementioned process. The 60/40 split is an
approximate number based on a similar operating parameter at other mills throughout the portfolio. The
HVAC designer confirmed that this is even an overestimate to what will be emitted outdoors via the
system.

If you have some guidance for what documentaon you would like to see regarding the Best Available Control
Technology (BACT) please provide it. The facility equipment are being designed using current technologies and
industry standards to minimize emissions. The facility is construcng the mill in a way to reduce emissions
consistent with using the Best Available Control Technology (BACT). We can provide a wrien determinaon on
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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the processes that are not currently equipped with a baghouse, but the reducon in emissions per the cost basis
would not be economically viable or appropriate for the reducon provided by the baghouse/cyclone.
Addionally, since the emissions that are produced are essenally flour product any emissions from the milling or
cleaning processes are essenally lost product that could have been sold; therefore, the facility has a vested
capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the PM
emissions are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are vented to the
interior of the building and then directed to through building roof vents. I believe the building's roof vents exhaust to
the atmosphere. How are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology (BACT)
analysis was included. I did not see any BACT analysis in the document. Did you complete BACT analysis for all
emission units and emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They do not
need to pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I have
begun my review and will reach out if I have any questions about the project.

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…315/327
Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising the air
permit application to only cover Phase I due to Phase II being more than a year out (greater than
14 months, but likely greater than 18). We have only included the Phase I in this application. With
that in mind, the client paid the $3,000 fee upon initial submittal, since we are modifying the
application, should they submit via the online portal or can we submit via email. We want to makesure that they are not paying $3,000 twice since only one application will apply. Can you pleaseprovide insight on the correct submittal steps, or point us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an Approval
Order (AO) prior to any construction, modification, testing, etc. You can reach out to Chad Gilgen if you have
questions, but I imagine he will say something similar about conducting testing prior to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy fugitive, 50.66
tpy non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that trigger the requirement
to conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive PM10, and 10 tpy of total PM2.5.
The flour mill's emission estimates would need to drop below these values and be enforceable from a permitting
perspective. If you think this is possible, we can take this approach, but you will need to resubmit the NOI with
new emissions estimates. Before the second half of the site is constructed, you will need to submit a second
NOI for a minor modification and conduct modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…316/327
Scott -

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval Order.
Technically, an AO should be issued before construction even begins. You might want to try running this by
Chad Gilgen who's the manager of the minor source compliance section. He can be reached at
[e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some of the
system operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case scenario
at the full future maximum operang capacity. Only half of the facility is being constructed at this me
so the emissions would easily be reduced in half and with some addional flow reducons and
adjustments the facility could operate below the modeling threshold. So inially the facility would be
running at limited capacity based on the future potenal. So would it be possible to operate inially at
a lower capacity with calculated emission under the modeling threshold? We would connue with the
modeling work, but this may also allow us to beer define the model based on actual performance of
the system components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike Freese
<[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…317/327
Jack,

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than those
listed in Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to submit a
dispersion modeling analysis as part of a complete NOI. Based on the estimated emissions in your NOI,
you will need to conduct modeling and demonstrate compliance with all applicable national ambient air
quality standards (NAAQS). I recommend submitting a modeling protocol to Dave Prey and Jason Krebs
(cc'd in this email) to help ensure the modeling is conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general, please
direct those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). That appears
to be a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department. Does the
modeling department perform the modeling in house at the UDEQ or how does that
specifically work? We have performed modeling in other states, and we understand thateach state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please use caution
when opening attachments.
11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r5921968390698790284&simpl=msg-a:r879157111238…318/327

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent (NOI)
application for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it was
checked off on the NOI application checklist but did not see any modeling analysis in the NOI. The
estimated potential to emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above the thresholds
which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you have
not, I will provide some guidance and put you in contact with our modeling department to set up a
modeling protocol.

Thanks,
Dungan

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Dungan Adams
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

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If you have received this communication in error, notify the sender immediately by return email and delete the message and
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Environmental Engineer | Minor NSR Section
M: [phone]
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2 attachments
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11/18/24, 5:21 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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Dungan Adams <[e-mail]>
Modeling for Utah Flour Milling LLC
Dungan Adams <[e-mail]>Wed, Dec 11, 2024 at 8:36 AM
To: Jack Batho <[e-mail]>
Cc: "kirk.arens" <[e-mail]>, Scott Hanson <[e-mail]>, "[e-mail]" <[e-mail]>
Hi Jack,
Yes, stack testing will only be required for the grain milling baghouses.
Thanks,
Dungan
On Wed, Dec 11, 2024 at 7:52 AM Jack Batho <[e-mail]> wrote:
Good morning, Dungan,

I don’t believe you are misinterpreting anything. I will let Ryan add any comment necessary that may indicate the ability to perform aperformance stack test prior to the split to the two exhaust vents (stacks).

For the performance stack testing based on the way you explained the emissions below, would the facility be able to reasonably
assume that stack testing would only be required on the milling baghouses or would stack testing be required on additional
baghouses? I want to make sure we have the understanding on the level of effort and potential costs that are going to be required byconditions in the permit.

Thank you for your help and please let me know if you have any additional questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, December 10, 2024 5:13 PM
To: kirk.arens <[e-mail]>
Cc: Jack Batho <[e-mail]>; Sco Hanson <[e-mail]>; [e-mail]
Subject: Re: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

Thanks for providing the baghouse stack explanation. I wanted to include Jack and Ryan as they may have input about this. According to the emission
calculations provided, the potential uncontrolled PM10 and PM2.5 emissions from the grain milling process are 3,296 tpy and 560 tpy respectively.
Because the uncontrolled emissions from this specific process are so large, failure of a baghouse could trigger major source status, and some type of
stack testing for filterable PM10 and PM2.5 will be required. The stack(s) will be required to meet an emission rate of 0.01 gr/dscf.

The way you have described things, the three (3) parallel baghouses are routed into a space which then vents through two (2) stacks. I don't think
testing before the plenum would be possible, but if it is, then only a single stack test would be required. Otherwise, I am thinking both of the 44 in.,22,000 cfm stacks will need to meet the 0.01 gr/dscf rate.
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-4548766519599…1/36

Please let me know if I am misinterpreting anything or if you have any questions or concerns about the stack testing requirement.

Thanks,
Dungan

On Tue, Dec 10, 2024 at 3:13 PM kirk.arens <[e-mail]> wrote:

Currently the three (3) Baghouses associated with the milling process will be ducted via a single large plenum. The large plenum will
be routed to two (2) separate stacks with a diameter of 44 inched each. The reason for two (2) separate stacks is due to the spaceconstraints for the facility. The flow rates for each stack is approximately 44,000 cfm combined (22,000 cfm each). However, the
operating parameters of the stacks will be determined on the amount of air that must be exhausted from the process. Under normal
operating circumstances one stack/damper would be emitting up to its approximate capacity (22,000 cfm) and the otherstack/damper will be opened up as needed for any additional capacity. The approximate stack locations are depicted in the attached
snippet below.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Ryan Miller <[e-mail]>
Sent: Tuesday, December 10, 2024 3:34 PM
To: Jack Batho <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-4548766519599…2/36

Quick note. The 2 exhaust stacks described below have a combined capacity of 44,000 cfm total (22,000 cfm each).

Thanks,

Ryan Miller
Design Engineer

Phone [phone] Mobile [phone]
Web www.bratney.com
Email [e-mail]
3400 109th St, Des Moines, IA 50322

From: Jack Batho <[e-mail]>
Sent: Tuesday, December 10, 2024 3:29 PM
To: Ryan Miller <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good afternoon, All,

Please see my response to Dungan’s question below.

Currently the three (3) Baghouses associated with the milling process will be ducted via a single large plenum. The large plenum will
be routed to two (2) separate stacks with a diameter of 44 inched each. The reason for two (2) separate stacks is due to the space
constraints for the facility. The flow rates for each stack is approximately 44,000 cfm. However, the operating parameters of thestacks will be determined on the amount of air that must be exhausted from the process. Under normal operating circumstances one
stack/damper would be emitting up to its approximate capacity (44,000 cfm) and the other stack/damper will be opened up asneeded for any additional capacity. The approximate stack locations are depicted in the attached snippet below.

12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-4548766519599…3/36

Please let me know if you have any questions, comments, or concerns.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Ryan Miller <[e-mail]>
Sent: Tuesday, December 10, 2024 3:16 PM
To: Jack Batho <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

After looking at your question again I have a bit more explanation.

The various milling jet filters are ducting into a single large plenum. This plenum then has two stacks that penetrate the roof to expel
air as needed.

Ryan Miller
Design Engineer

Phone [phone] Mobile [phone]
Web www.bratney.com
Email [e-mail]
3400 109th St, Des Moines, IA 50322

12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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From: Jack Batho <[e-mail]>
Sent: Tuesday, December 10, 2024 1:48 PM
To: Ryan Miller <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Ryan,

Thank you for the additional information. I will work on drafting an email and send to the group for review before sending it along to
Dungan. One last question. I don’t want to get too far into splitting the flows between the two stacks, but is there a set process for
what amount of CFM goes to each stack? Or is this a variable process?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Ryan Miller <[e-mail]>
Sent: Tuesday, December 10, 2024 1:46 PM
To: Jack Batho <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

The two stacks discussed are related to being able to decide how much warm process air (milling process) is returned into the mill.

We have three additional stacks on the roof that are not related to the milling process. Two of them are related to wheat cleaning jet
filters while the third is for displacement air in the flour silos during general milling operations. These three stacks dump air that is
not intended to be recirculated. This air is made up by three RTU’s that only pull in fresh air.

Thanks,

Ryan Miller
Design Engineer

Phone [phone] Mobile [phone]
Web www.bratney.com
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-4548766519599…5/36
Email [e-mail]
3400 109th St, Des Moines, IA 50322

From: Jack Batho <[e-mail]>
Sent: Tuesday, December 10, 2024 1:28 PM
To: Ryan Miller <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Ryan,

I wanted to make sure; this would be specifically for the baghouses vents associated with the milling process. Not sure if that
changes your answer at all?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Jack Batho
Sent: Tuesday, December 10, 2024 1:24 PM
To: Ryan Miller <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good afternoon, Ryan,

Thank you for the additional information. I am assuming the next question from the regulators will be flow rates and diameters. Do
you have that information readily available, so I can provide it to Dungan?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-4548766519599…6/36

From: Ryan Miller <[e-mail]>
Sent: Tuesday, December 10, 2024 1:21 PM
To: Jack Batho <[e-mail]>; kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

We will utilize two separate stacks to allow warm process air to be dumped that will not be returned via the RTU’s. The requirement
for two stacks is due to space available. We did not have enough physical space for one large stack. The airflow through these
stacks will be controlled via individual automated dampers based on how much air will be recirculated into the mill building ordumped to atmosphere.

Thanks,

Ryan Miller
Design Engineer

Phone [phone] Mobile [phone]
Web www.bratney.com
Email [e-mail]
3400 109th St, Des Moines, IA 50322

From: Jack Batho <[e-mail]>
Sent: Tuesday, December 10, 2024 12:45 PM
To: kirk.arens <[e-mail]>; Sco Hanson <[e-mail]>
Cc: Ryan Miller <[e-mail]>
Subject: RE: [EXTERNAL] Modeling for Utah Flour Milling LLC

Good afternoon, Kirk,

Based on the drawings that we have at this time and the information provided to us in the past by Ryan, we do not specifically know
the answer to that question. Based on our understanding, the baghouses vent into the pressurization system (ducting) and is thenvented outdoors as needed, therefore it very well could be a singular stack. However, we do not have any information to substantiate
other than what Ryan has told us.

Ryan,

Can you confirm if the three milling baghouses vent outdoors via the same stack (ducting system) or via separate stacks?

Kind Regards,
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-4548766519599…7/36

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: kirk.arens <[e-mail]>
Sent: Tuesday, December 10, 2024 12:23 PM
To: Jack Batho <[e-mail]>; Sco Hanson <[e-mail]>
Subject: Fw: [EXTERNAL] Modeling for Utah Flour Milling LLC

Can you please answer this asap

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Monday, December 9, 2024 3:42:02 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,

My manager is still reviewing the project. Once he has finished his review and you sign off, the project will be sent for public comment.

I do have one other question that the compliance manager brought up: For the three (3) parallel grain milling baghouses, is there one combined stack
or three individual stacks?

Thanks,
Dungan

On Fri, Dec 6, 2024 at 9:39 AM kirk.arens <[e-mail]> wrote:
When will it post for public notice

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
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From: kirk.arens <[e-mail]>
Sent: Wednesday, December 4, 2024 6:18:16 PM
To: Dungan Adams <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

That is correct. We do not

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12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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From: kirk.arens <[e-mail]>
Sent: Wednesday, December 4, 2024 5:17:54 PM
To: Dungan Adams <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

That is correct. We do

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Wednesday, December 4, 2024 5:01:18 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

The compliance division has completed their review of the project and brought up a couple of minor questions:

- Can you confirm that there are no natural gas/diesel fired boilers or dryers on site?
- Can you confirm that no materials containing chromium or manganese are used in the feed by-product process?

Thanks,
Dungan

On Mon, Nov 18, 2024 at 1:31 PM kirk.arens <[e-mail]> wrote:
We have in process scales that continuously weight product streams as we use and make product. It gives us real time information on wheat
used and flour and by products made

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Monday, November 18, 2024 1:13:22 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

Following up about my question from last Thursday.

Thanks,
Dungan

On Thu, Nov 14, 2024 at 10:08 AM Dungan Adams <[e-mail]> wrote:
Can you explain what you mean by online scales?

Thanks,
Dungan
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-4548766519599…9/36

On Thu, Nov 14, 2024 at 10:06 AM kirk.arens <[e-mail]> wrote:
We have online scales

Sent via the Samsung Galaxy S24 Ultra, an AT&T 5G smartphone
Get Outlook for Android
From: Dungan Adams <[e-mail]>
Sent: Thursday, November 14, 2024 11:04:36 AM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Kirk,

Since the facility's estimated emissions are based on tons of monthly throughput, I will need to include conditions that limit throughput. To
determine compliance with the throughput limits, the facility will be required to maintain records of throughput through the various
operations at the mill.

Do you know how the facility will weigh grain/flour/feed by-product at the mill? We often see this done with belt or floor scales, but I wanted
to check with you to confirm what type of weighing systems you plan to use.

Thanks,
Dungan

On Wed, Nov 13, 2024 at 11:41 AM Dungan Adams <[e-mail]> wrote:
Great, thanks for confirming.

- Dungan

On Wed, Nov 13, 2024 at 11:41 AM kirk.arens <[e-mail]> wrote:
That is correct.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 12:31 PM
To: kirk.arens <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Understood, I will move this project forward as quickly as I can.

The NOI lists that the nine (9) flour bins and one (1) feed bin are equipped with bin vents. The NOI lists that grain storage bins vent to
the atmosphere through various roof vents (no control). Can you confirm that the twelve (12) grain elevator bins and twelve (12)
internal grain storage bins are not controlled by any equipment?

Thanks,
Dungan

On Wed, Nov 13, 2024 at 10:35 AM kirk.arens <[e-mail]> wrote:
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…10/36
12 outside elevator bins. 12 internal wheat bins (7 pre clean wheat storage bin, 5 clean temper wheat bins), 9 insidefloor bins, 1 feed bin. If you can please keep me up to date as both Campbells and ourself are waiting for this to be
completed.

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 13, 2024 10:47 AM
To: kirk.arens <[e-mail]>
Cc: Sco Hanson <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Kirk,

I am hoping to send this project off for internal reviews by the end of the week.

UAC Code R307-401-5 states that a source shall receive an Approval Order (approved permit) prior to the construction,
modification, or establishment of an air pollution source. I cannot authorize you to start bringing product into your facility as wheat
storage is an air pollution source.

I have one quick question about storage bins. What are the number of grain storage bins and flour storage bins at the facility? The
number of each will be included in the permit.

Thanks,
Dungan

On Wed, Nov 13, 2024 at 7:01 AM kirk.arens <[e-mail]> wrote:
Just wondering if there is any updates on the permit. I also have a question around bringing wheat into thefacility. The mill will not be capable of running product until the permit is in place but I was wondering if we can
bring wheat into our bins?

From: Dungan Adams <[e-mail]>
Sent: Wednesday, November 6, 2024 11:21 AM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Great, thanks for sending this over. I will let you know if I have any more questions or need any additional info.

Thanks,
Dungan

On Wed, Nov 6, 2024 at 10:10 AM Scott Hanson <[e-mail]> wrote:
We are fine with this approach to use a higher control efficiency for the baghouses and to include the control efficiency
for the cyclones as this will be more consistent with the current system setup emissions. I have aached our revised
Emission Calculaons Spreadsheet with highlighng showing the cells with revised inputs. We increased the efficiency of
the baghouses and added the cyclones to the control efficiency for the grain mill (EU-05A). We also adjusted the
discharge for the vent system to be 100% outdoors and 0% recirculated indoors as a worst case scenario and would
provide an addional emission safety factor. Of note the air that is recirculated back into the building flows through
addional filters before being discharged back into the building to collect parculate maer and further reduce interior
emissions and the buildup of parculate maer within the building that needs to be cleaned up. Let us know if you have
any quesons or need any addional informaon.

12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…11/36

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Tuesday, November 05, 2024 3:47 PM
To: Sco Hanson <[e-mail]>
Cc: [e-mail]; kirk.arens <[e-mail]>; Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I still have a few issues with this justification, the biggest being the enforceability of the 60-40 split. With the way emissions
are currently calculated, the facility cannot emit much more than 40% of the annual grain milling baghouse exhaust to the
atmosphere without exceeding modeling thresholds. Especially because of the seasonal temperature justification of the 60-40
split, I do not think there is a good way to enforce this without requiring a lot of stack testing. If there is no enforceable limit in
the permit, then nothing is stopping the facility from exhausting greater than 40% of the baghouse emissions to the
atmosphere. Richmond could experience an unusually long summer and the facility could exhaust for a greater period than
what is anticipated. The permit would also need to ensure that 100% of the recirculated baghouse exhaust remains andsettles inside the building and ~18 TPY of particulate settling inside facility still seems problematic to me.

I understand that there are safety factors built in to the emission calculations and I think the best way to proceed is to
calculate more accurate estimates. AP-42 Appendix Table B.2-3 lists the following control efficiencies:

0-2.5 μm 2.5-6 μm 6-10 μm
Fabric Filter/Baghouse 99% 99.5% 99.5%
Single Cyclone 10% 35% 50%
Using the AP-42 baghouse control efficiencies for calculations will reduce the PM10 and PM2.5 estimates from the grain
milling baghouse by half. Adding on the cyclone control efficiency will further reduce the emissions. I think if the AP-42
baghouse control efficiencies are used across the facility, if we conservatively assume that all of the baghouse emissions are
exhausted to the atmosphere, the facility will remain below the modeling threshold. With this approach this is no need to try
and enforce the 60-40 split are ensure that 100% of the recirculated air remains inside the facility. The facility would be able to
use their HVAC system with full flexibility and exhaust as much or as little of the grain milling baghouse exhaust as
necessary.

What are your thoughts on this approach?

Thanks,
Dungan

On Fri, Nov 1, 2024 at 2:41 PM Scott Hanson <[e-mail]> wrote:
Good afternoon, Dungan,

After thorough talks with Ryan Miller and Kirk Arens internally, we have put together the following document that should
justify why our calculations have been revised and give real world data and “good engineering practice” as to how we
arrived at the calculations provided in the most recent Notice of Intent (NOI).

12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…12/36
The facility has been in the construction design phase during the perpetration of this air permit. Our (Atlas’) original
understanding of the air flow system design was that the air from some systems, including the mill exhaust after the
baghouses, would be discharged back into a room in the interior of the building. We have seen this design in other setups
where the discharge is generally directed to a room before being directed to other building areas. Air within the building
would be exhausted through various exhaust vents. These exhaust fans are identified as emission point EP-RV on the
permit documents. We estimated 25% of the particulate would be contained in the building with the remaining 75% being
emitted through the roof vent as a starting point. This emission split was likely higher than required, but we were not certain
of the distances and configuration from the emission point in the building to the roof vents. In addition, we estimated thatthe whole facility air flow would be recirculated at a rate of 75% emitted through roof vents outdoors and 25% would be
returned internally. This number was further reduced in the most recent permit based on our understanding that
approximately 50% of this air would be circulated back into the building equipment and would not be exhausted. Therefore,
the 75% was divided in half or 37.5%, which was rounded to 40%.

It appears that our understanding of the system is not fully consistent with the current design setup for air flow. There is
some process equipment that draws in air from inside the building, which is discharged through emission points (outdoors)as identified in the permit and there is no changes with these units. However, the emission points identified as EP-RV have
flow directed through ducts to a valving system that determines how much of this air is discharged to the exterior of the
building and how much of this air is recirculated and directed through the RTUs and then back into the building. In the
colder winter months this system would recirculate 100% of this air back into the building to maintain heat, with additional
heating provided by the RTUs. In the summer months the system may be opened up to discharge nearly 100% of the
airflow to the exterior to allow for more cool air to be drawn into the building. This recirculation system accounts for 45,000
CFM of the total 80,000 CFM that is drawn through all equipment with the other air flows being discharged (outdoors)
through other emission points. Therefore, when this circulation system is closed during cooler periods an additional 35,000
CFM of fresh air is still being drawn into the building. The HVAC valving system is controlled by a thermostat based on
interior and exterior temperatures and the following table was derived with monthly average temperatures for the facility
area to calculate split between exhausted and recirculated air. Based on this information the 40% to 60% split included in
the permit is scientifically correct. Another temperature analysis was performed with data from 2023 in the area of the
facility and approximately 36% of the days in the year had a high and low daily temperature above 65 degrees where the
HVAC system would discharge more air to allow for additional air to be drawn in for cooling. In both cases the percentage
of exhausted air flow would be expected to be higher than actual operating parameters.

Richmond Utah Average Monthly Temperatures and HVAC Recirculation
usclimatedata.com NOAA Combined 45,000 CFM Duct Flow
Month
Average
High
Average
Low
Average
High
Average
Low Ave Temp
%
Exhausted
%
Recirculated
January 31 15 32 15 23.25 0 100
February 36 18 38 19 27.75 0 100
March 49 27 49 27 38 0 100
April 59 34 60 34 46.75 0 100
May 69 40 69 40 54.5 50 50
June 79 47 81 48 63.75 80 20
July 90 55 91 55 72.75 90 10
August 88 54 89 54 71.25 90 10
September 77 45 79 46 61.75 80 20
October 62 35 63 36 49 50 50
November 44 26 46 26 35.5 0 100
December 26 17 34 17 23.5 0 100
Average 36.67 63.33
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…13/36

While the calculated facility PM10 emissions are close to the modeling threshold values there are some safety factors that
have been built into these emission calculations as discussed below; therefore, the actual facility emissions would be lower
than these calculated values.
· The milling process includes multiple cyclones as part of the flour transfer process through the milland no emission reduction factor for these units was included in the calculations. These units would beconsidered medium efficiency cyclones, which would have a control efficiency of 50% for PM10; therefore,
the milling equipment EU-06A PM10 emissions in the calculations could be cut in half.
· The facility emissions are based on production rates near the maximum production capacity. It isunlikely that the facility will be able to maintain this flow rate as there will be down time for repairs and
maintenance.
· The baghouses may operate at higher efficiencies than identified, which will further reduce facilitywide emissions.
· Any lost product or by-product is lost revenue for the facility and company as a whole, so there is a
vested interest in reducing emissions and improving efficiency of the systems and assuring the emissionequipment in place is operating a peak efficiency.
Let us know if you have any further questions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 24, 2024 4:04 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>; [e-mail]; kirk.arens
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,

I've been out of the office the past week, but I wanted to continue this conversation. I need to see some type of explanationfor why the original milling calculations used a 75% outdoor - 25% indoor split and updated calculations used a 40%
outdoor - 60% indoor split. If Kirk or Ryan could provide a better explanation that would be great.

I understand what you are saying about the baghouses operating in series and about how it is in the facilities best interest
to capture product. However, the emission calculations that were provided in the updated NOI are close to modeling
thresholds and I need to understand why this aspect of the milling calculations changed from the original NOI.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 12:30 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

This was not an attempt to avoid the modeling thresholds and was done after consulting Ryan Miller with
Bratney who is part of the team responsible for designing the air flow and hvac systems for this facility.
Once we removed the mill line B from the initial application package, we revisited numerous calculations tobetter reflect what would be happening with the emissions associated with mill line A. Please keep in mind
that Scott and I are not HVAC engineers, we are familiar with this operation, but Ryan may be better suited
with explaining how this process works specifically. Essentially, similar to other mills, most of the
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…14/36
recirculated air will cause the particulate matter to settle on the floor within the mill. This waste settledmaterial is constantly swept up and disposed of. It is not uncommon for numerous tons to be disposed of
in this fashion at similar sized mills across the country via the dumpster (garbage service) or other
alternative green friendly options.

As Scott mentioned before, some of the baghouses operate in series which would further reduce theemissions past the level represented in the NOI and submitted calculations. As to make everything easier
to review on the agency end, we tried to limit step-wise or series calculations and simply apply the
manufacturer guaranteed emissions control rates submitted in the application as if the baghouses were setup in a parallel formation. As you can see in the submittal there are three baghouses and at least one
cyclone associated with the milling process. This vastly reduces emissions below the levels within the
calculations provided. As stated in previous emails any lost product or by-product is lost revenue for thefacility and company as a whole, so there is a vested interest in reducing emissions and improving
efficiency.

Kirk can provide additional information as he has worked in this industry for decades and is the EHS
representative for the facility and company as a whole. Ryan can also provide more knowledgeable and in-depth information related to the HVAC and air flow systems used at the facility.

Thank you for your continued efforts in the permitting process. Please let us know how we can better
answer your questions.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 10, 2024 1:17 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Scott,

The emission calculations from the initial NOI submitted in August show that each grain milling side was estimated toproduce 31.5 tpy of PM10 from baghouse exhaust. The baghouse exhaust would be vented inside the building where
75% of particulate emissions are directed outdoors and 25% remain indoors.

The current NOI suggests the single grain milling operation will produce 30.45 tpy of PM10 from baghouse exhaust. The
exhaust would be vented inside the building where 40% of particulate emissions are directed outdoors and 60% remain
indoors. If the 75% outdoor - 25% indoor split was used in the updated calculations, the source would be above the
modeling threshold for PM10 emissions.

Please provide justification for how you arrived at the 40% outdoor - 60% indoor split in the updated calculations and
why it changed from the 75% outdoor - 25% indoor split originally used. You stated this 40/60 parameter has been used
at other mills and I would like to see an example of a mill that operates this way. I searched the other permitted flour
mills in Utah and it looks like they all use baghouses that vent directly to the atmosphere. From my perspective, it looks
like the ratio of particulate emission vented outdoors was adjusted to avoid modeling requirements and I will need to see
stronger justification for this process before I am able to accept the calculations.
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…15/36

Let me know if you have any questions. I am out of the office next week, but we could set up a meeting when I am back
to discuss this in more detail.

Thanks,
Dungan

On Thu, Oct 10, 2024 at 7:22 AM Scott Hanson <[e-mail]> wrote:
They have used this design in other similar facilies so they have experience with the setup used to recapture and
recycle the air for air handling balancing purposes. In pracce the actual dust that accumulates in the building is
less than the these calculated values due to several factors, and the calculated values represent a worst case
scenario. This system includes several small cyclones that are primarily used for material transfer from the milling
process prior to the baghouses but the emission reducon form these units is not included in the emission
reducon calculaons. Addionally, the baghouses would be expected to have higher efficiencies than the values
used in the calculaons. Therefore, the system will operate at higher efficiencies than the calculaons show and
actual emissions would be less than these values. The flow from the baghouses is discharged to certain interior
areas of the building that will facilitate in the seling of parculates and the cleanup of parculates for the
recycling of the air. The parculate and process waste maer that is developed at this facility that cannot be used
as flour and is used as animal feed. Let me know if you have any other quesons.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Wednesday, October 09, 2024 1:29 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

I am still a little concerned with routing the milling baghouse exhaust inside the flour mill. Based on your explanation,
~30 tpy of PM10 and ~10 tpy of PM2.5 are routed inside the building, with 60% remaining in the building and 40%
being vented to the atmosphere. This seems like a huge amount of particulate inside of the building. Can you
elaborate on what happens to the particulate that stays inside the building? If it is captured for reuse, how does thecapture process work?

Thanks,
Dungan

On Fri, Oct 4, 2024 at 12:37 PM Dungan Adams <[e-mail]> wrote:
Understood. Thanks for the explanation.

Thanks,
Dungan

12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…16/36
On Fri, Oct 4, 2024 at 12:20 PM Scott Hanson <[e-mail]> wrote:
The 18.27 tpy of PM10 and 6.12 tpy of the PM2.5 are the 60% fracon of the milling emissions that would
be contained within the building, which is on the indoor line. These emissions would not be discharged to
the outside of the building. The line above this with 12.180 tpy of PM10 and 4.141 of PM2.5 are the 40%
fracon of the milling emissions discharged to the atmosphere through the vents, which is on the outdoor
line for the milling. This indoor/ outdoor spilt is also the same for EU-08A but this unit have has very minor
emissions in comparison.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Friday, October 04, 2024 12:35 PM
To: Sco Hanson <[e-mail]>
Cc: Jack Batho <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

Thanks for getting back to me. Does any of the 18.27 tpy of PM10 and 6.12 tpy of PM2.5 that is routed indoors
exit the building to the atmosphere through roof vents? If so, this needs to be accounted for in the site-wide
PTE. I just want to understand where the particulate goes since a substantial amount is routed indoors and the
source is very close to reaching the modeling threshold.

As for BACT analysis, what you are saying makes sense. Normally we would like to see a written analysis, but
in your case the source has chosen to use baghouses (generally the best control option for PM) for all of the
primary emitting processes. The remaining processes that are uncontrolled or controlled with lower
efficiency filters produce such minor amounts of PM that it would be challenging to justify more expensive
control. I will move forward with my BACT write up without a formal written analysis.

Thanks,
Dungan

On Fri, Oct 4, 2024 at 8:50 AM Scott Hanson <[e-mail]> wrote:
The facility baghouses associated with the milling process are routed to an indoor pressurizationsystem that feeds air back into the mill. The reason for this design is to account for the need of
extra airflow to reduce the likelihood of creating a vacuum in the mill. If the air was not returned
you would not be able to open a single door in the mill. With that in mind, in the pressurizationroom, there is a “burp” vent type system that would allow some of the internal air to exit via the
roof vent. All the baghouses (and cycle) vents associated with the milling are routed to the
aforementioned process. The 60/40 split is an approximate number based on a similar operatingparameter at other mills throughout the portfolio. The HVAC designer confirmed that this is even
an overestimate to what will be emitted outdoors via the system.

If you have some guidance for what documentaon you would like to see regarding the Best Available
Control Technology (BACT) please provide it. The facility equipment are being designed using current
technologies and industry standards to minimize emissions. The facility is construcng the mill in a way to
reduce emissions consistent with using the Best Available Control Technology (BACT). We can provide a
wrien determinaon on the processes that are not currently equipped with a baghouse, but the
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…17/36
reducon in emissions per the cost basis would not be economically viable or appropriate for the
reducon provided by the baghouse/cyclone. Addionally, since the emissions that are produced are
essenally flour product any emissions from the milling or cleaning processes are essenally lost product
that could have been sold; therefore, the facility has a vested capital interest in reducing emissions.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, October 03, 2024 3:01 PM
To: Jack Batho <[e-mail]>
Cc: Sco Hanson <[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Jack,

I have a couple of initial questions about the NOI that was submitted for Utah Flour Milling, LLC.

- I reviewed the emission calculations attached at the end of the NOI. It seems as though the majority of the
PM emissions are produced from grain milling. As I understand it, ~18 tpy of PM10 and ~6 tpy of PM2.5 are
vented to the interior of the building and then directed to through building roof vents. I believe the building's
roof vents exhaust to the atmosphere. How are you accounting for this in your PTE estimate?

- The NOI Application Checklist form (on page 5 of the NOI) indicated that Best Available Control Technology(BACT) analysis was included. I did not see any BACT analysis in the document. Did you complete BACT
analysis for all emission units and emitting processes? I can send some guidance if that would be helpful.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Oct 2, 2024 at 3:19 PM Dungan Adams <[e-mail]> wrote:
Hi Jack,

If the client has already paid the filing and review fees with the initial submittal, then they are all set. They
do not need to pay a second fee for a revised NOI as it will be considered the same project.

The submission was received via the online portal, and the updated NOI was sent my way this morning. I
have begun my review and will reach out if I have any questions about the project.

Thanks,
Dungan
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…18/36

On Wed, Oct 2, 2024 at 3:12 PM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

We had a question about the permit application submittal, since the client will be revising theair permit application to only cover Phase I due to Phase II being more than a year out
(greater than 14 months, but likely greater than 18). We have only included the Phase I in
this application. With that in mind, the client paid the $3,000 fee upon initial submittal, sincewe are modifying the application, should they submit via the online portal or can we submit
via email. We want to make sure that they are not paying $3,000 twice since only oneapplication will apply. Can you please provide insight on the correct submittal steps, or point
us in the correct direction?

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Tuesday, September 24, 2024 10:33 AM
To: Sco Hanson <[e-mail]>
Cc: Jason Krebs <[e-mail]>; Dave Prey <[e-mail]>; Jack Batho
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Hi Scott,

As stated in UAC Code R307-401-5, a new or modified source shall submit an NOI and receive an
Approval Order (AO) prior to any construction, modification, testing, etc. You can reach out to Chad
Gilgen if you have questions, but I imagine he will say something similar about conducting testing prior
to receiving an AO.

The NOI submitted listed estimates of 59.07 tons per year (tpy) of total PM10 emissions (8.41 tpy
fugitive, 50.66 tpy non-fugitive) and 18.23 tpy of total PM2.5 emissions. The emissions thresholds that
trigger the requirement to conduct modeling analysis are: 15 tpy of non-fugitive PM10, 5 tpy of fugitive
PM10, and 10 tpy of total PM2.5. The flour mill's emission estimates would need to drop below these
values and be enforceable from a permitting perspective. If you think this is possible, we can take this
approach, but you will need to resubmit the NOI with new emissions estimates. Before the second half
of the site is constructed, you will need to submit a second NOI for a minor modification and conduct
modeling analysis.

Let me know if you have any questions.

Thanks,
Dungan

On Tue, Sep 24, 2024 at 7:02 AM Jason Krebs <[e-mail]> wrote:
Scott -
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…19/36

This is more of a compliance issue than a modeling issue if the mill doesn't have an existing Approval
Order. Technically, an AO should be issued before construction even begins. You might want to try
running this by Chad Gilgen who's the manager of the minor source compliance section. He can be
reached at [e-mail] and at 385-306-6500.

Dungan - How do you guys advise sources in this situation?
Jason Krebs | Environmental Scientist | Utah Division of Air Quality
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

On Mon, Sep 23, 2024 at 4:10 PM Scott Hanson <[e-mail]> wrote:
Jason and Dave

We are sll working on the modeling for this facility, but we have a couple quesons.

1. The facility would like to start loading grain at the facility before long to start tesng some
of the system operaons and would operate at low levels. Would they be able to do this?
2. The permit emission that were submied on the applicaon are based on the worst case
scenario at the full future maximum operang capacity. Only half of the facility is being
constructed at this me so the emissions would easily be reduced in half and with some
addional flow reducons and adjustments the facility could operate below the modeling
threshold. So inially the facility would be running at limited capacity based on the future
potenal. So would it be possible to operate inially at a lower capacity with calculated
emission under the modeling threshold? We would connue with the modeling work, but this
may also allow us to beer define the model based on actual performance of the system
components.

Scott Hanson, PE
Project Manager II
O: 319.233.0441 C: 319.290.9783

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 1:27 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]; Sco Hanson <[e-mail]>; Mike
Freese <[e-mail]>; Jason Krebs <[e-mail]>; Dave Prey
<[e-mail]>
Subject: Re: [EXTERNAL] Modeling for Utah Flour Milling LLC

Jack,
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…20/36

Attached are the DAQ's Emissions Impact Analysis Guideline and Modeling Protocol Form.

The DAQ requires new sources whose total controlled emission increase levels are greater than
those listed in Table 1 of the Emissions Impact Analysis Guideline or state rule R307-410-4 to
submit a dispersion modeling analysis as part of a complete NOI. Based on the estimated
emissions in your NOI, you will need to conduct modeling and demonstrate compliance with all
applicable national ambient air quality standards (NAAQS). I recommend submitting a modeling
protocol to Dave Prey and Jason Krebs (cc'd in this email) to help ensure the modeling is
conducted correctly.

If you have further questions about the modeling protocol or emissions impact analysis in general,
please direct those to Dave or Jason and they should be able to help.

Thanks,
Dungan

On Thu, Aug 22, 2024 at 11:43 AM Jack Batho <[e-mail]> wrote:
Good afternoon, Dungan,

At this time, we have not completed the emissions impact analysis (modeling). Thatappears to be a minor typo, our apologies.

Can you please give us some guidance and direction to the modeling department.
Does the modeling department perform the modeling in house at the UDEQ or how
does that specifically work? We have performed modeling in other states, and weunderstand that each state handles modeling differently.

Thank you for your assistance.

Kind Regards,

Jack Batho IV
Staff Engineer
O: 402.697.9747 C: 402.536.0694

From: Dungan Adams <[e-mail]>
Sent: Thursday, August 22, 2024 12:14 PM
To: Jack Batho <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL] Modeling for Utah Flour Milling LLC

[External Email] This email originated from outside of the Atlas mail system. Please
use caution when opening attachments.
12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…21/36

Hi Jack,

The Utah Division of Air Quality (DAQ) has received Utah Flour Milling LLC's Notice of Intent
(NOI) application for a new flour mill.

Has Emissions Impact Analysis (modeling) been conducted for this new source? I saw that it
was checked off on the NOI application checklist but did not see any modeling analysis in the
NOI. The estimated potential to emit (PTE) for PM10, fugitive PM10, and PM2.5 are all above
the thresholds which require the source to conduct modeling.

If you have conducted modeling, please pass the analysis and modeling files along to me. If you
have not, I will provide some guidance and put you in contact with our modeling department to
set up a modeling protocol.

12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permmsgid=msg-a:r-4548766519599539845&simpl=msg-a:r-454876651959…22/36
Thanks,
Dungan

--

Dungan
Adams
EnvironmentalEngineer |
Minor NSR
Section
M: (385) 290-
2474
airquality.utah.gov
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12/11/24, 12:03 PM State of Utah Mail - Modeling for Utah Flour Milling LLC
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EMISSION CALCULATIONS
Utah Flour Milling LLC - Conventional / Organic Milling Operations
11595 N. US 91 HWY, Richmond, UT 84333
EU ID #EP ID#CE ID#Emission Unit (EU)SCC #
Raw
Material
Max.
Design
Rate
(tons/hr.)
Requested
Permit (tpm)Exhaust
Capt.
Eff.
Cont.
Eff. PM
Cont.
Eff.
PM10
Cont.
Eff.
PM2.5
Conv.
Factor
(lbs./ton)
Conv.
Factor
(hrs./yr.) PM EF PM10 EF PM2.5 EF PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5
EU-01A EP-01 CE-01 Grain Receiving (Truck)30200552 Wheat 200 20,000 Outdoors 0.5 0.001 0.005 0.01 2,000 8,760 0.0350 0.0078 0.0013 15.33 3.42 0.57 0.015 0.017 0.006 2.100 0.468 0.078 0.002 0.002 0.001
EU-01B EP-01 CE-01 Grain Receiving (Rail)30200552 Wheat 300 20,000 Outdoors 0.5 0.001 0.005 0.01 2,000 8,760 0.0320 0.0078 0.0013 21.02 5.12 0.85 0.021 0.026 0.009 1.920 0.468 0.078 0.002 0.002 0.001
EU-02 EP-01 CE-01 Grain Handling (legs, conveyors,
belts, etc.)30200553 Wheat 300 20,000 Outdoors 1 0.001 0.005 0.01 2,000 8,760 0.0610 0.0340 0.0058 80.15 44.68 7.62 0.080 0.223 0.076 7.320 4.080 0.696 0.007 0.020 0.007
EU-03 FS-03 N/A Grain Storage (Bins)30200540 Wheat 300 20,000 Outdoors 1 1 1 1 2,000 8,760 0.0250 0.0063 0.0011 32.85 8.28 1.45 32.850 8.278 1.445 - 0.756 0.132 3.000 0.756 0.132
EU-04A EP-04A
CE-04AA
CE-04AB
CE-04AC
CE-04AD
Grain Cleaning (Side A)30200733 Wheat 21.5 14,500 Outdoors 1 0.001 0.005 0.01 2,000 8,760 0.0480 0.0120 0.0020 4.52 1.13 0.19 0.005 0.006 0.002 4.176 1.044 0.174 0.004 0.005 0.002
EU-05A EP-05A CE-05A Grain Tempering (Side A) (7)Listed as ND in
AP-42 Wheat 21.5 14,500 Outdoors 1 0.001 0.005 0.01 2,000 8,760 0.0305 0.0170 0.0029 2.87 1.60 0.27 0.003 0.008 0.003 2.654 1.479 0.252 0.003 0.007 0.003
Outdoors (5)1 0.00025 0.0025 0.009 2,000 8,760 70.0000 35.0000 5.9500 6,591.90 3,295.95 560.31 1.648 8.240 5.043 6,090.000 3,045.000 517.650 1.523 7.613 4.659
Indoors (5)0 0.00025 0.0025 0.009 2,000 8,760 70.0000 35.0000 5.9500 - - - - - - - - - - - -
EU-07A EP-07A CE-07A Flour Storage Bins (Side A)30200560 (1)Flour 20 14,500 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0125 0.0032 0.0006 1.10 0.28 0.05 0.274 0.140 0.026 1.088 0.278 0.052 0.272 0.139 0.026
Outdoors (5)1 0.001 0.005 0.01 2,000 8,760 0.0610 0.0340 0.0057 18.70 10.42 1.75 0.019 0.052 0.017 5.307 2.958 0.496 0.005 0.015 0.005
Indoors (5)0 0.001 0.005 0.01 2,000 8,760 0.0610 0.0340 0.0057 - - - - - - - - - - - -
EU-09 EP-09 CE-09 Flour Bulk Loadout (Truck)30200560 (2)Flour 30 5,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0430 0.0145 0.0025 5.65 1.91 0.33 1.413 0.953 0.164 1.290 0.435 0.075 0.323 0.218 0.038
EU-10 FS-10 NA Flour Bulk Loadout (Rail)30200563 (3)Flour 30 5,000 Outdoors 0.5 1 1 1 2,000 8,760 0.0135 0.0011 0.0002 0.89 0.07 0.01 0.887 0.072 0.012 0.203 0.017 0.003 0.203 0.017 0.003
EU-11 EP-11 CE-11 Flour Packaging (Bags and Totes)30200560 (4)Flour 30 5,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0430 0.0145 0.0025 5.65 1.91 0.33 1.413 0.953 0.164 1.290 0.435 0.075 0.323 0.218 0.038
EU-12 EP-12 CE-12 Milling Byproduct, Hammer
Milling 30200817 Feed 1.5 1,450 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.3350 0.1680 0.0290 2.20 1.10 0.19 0.550 0.552 0.095 2.915 1.462 0.252 0.729 0.731 0.126
EU-13 EP-13 CE-13 Feed Storage (Bins)Listed as ND in
AP-42 (8)Feed 1.5 1,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0250 0.0060 0.0011 0.16 0.04 0.01 0.041 0.020 0.004 0.150 0.036 0.007 0.038 0.018 0.003
EU-14 FS-14 N/A Feed Loadout (Truck)30200803 Feed 40 1,000 Outdoors 0.5 1 1 1 2,000 8,760 0.0033 0.0008 0.0001 0.29 0.07 0.01 0.289 0.070 0.009 0.010 0.002 0.000 0.010 0.002 0.000
34.03 8.42 1.47 34.03 8.42 1.47 0.21 0.77 0.14 3.21 0.77 0.14
9,586.47 4,785.29 813.48 8.59 25.50 10.45 6,120.21 3,058.14 519.89 3.23 8.99 4.91
9,620.49 4,793.71 814.95 42.62 33.92 11.92 6,120.42 3,058.92 520.02 6.44 9.76 5.04
13,828.77 6,907.08 1,174.17 12.83 46.72 17.67 6,120.21 3,058.14 519.89 3.23 8.99 4.91
13,862.80 6,915.50 1,175.64 46.86 55.14 19.13 6,120.42 3,058.92 520.02 6.44 9.76 5.04
(1) 50% SCC for grain storage used since no SCC for flour storage and flour storage is cleaner
(4) 50% SCC for grain shipping by truck used since no SCC for flour packaging and flour packaging is cleaner and SCC for Flour Bulk Loading is Non-Detect
(5) The emission are vented thorugh a duct valving system that can be opened to discharge to outside the building or closed to direct flow through RTUs with filters and then back into the building. The valving split is based on interior temperature.
(6) SCC for grain handling used since no SCC for flour handling and flour handling is cleaner.
(8) SCC for grain storage used since Feed storage Listed as ND, but is assumed to be similar to grain storage.
tpm = tons per month
PTE Controlled (tpy) = [Max. Design Rate (tons/hr.) x Emission Factor (lb./ton) x 8760 hrs./yr. x Capture Efficiency x Control Efficiency / 2000 lbs./ton]
PTE Limited (tpy) = [Permit Limit (tons/mo.) x 12 mo./yr. x Emission Factor (lb./ton) x Capture Efficiency / 2000 lbs./ton]
PTE Controlled & Limited (tpy) = [Permit Limit (tons/mo.) x 12 mo./yr. x Emission Factor (lb./ton) x Capture Efficiency x Control Efficiency / 2000 lbs./ton]
Control Efficiencies are based on industry standard PM control percentages. Actual emissions would likely be lower.
Control Efficiencies for Baghouse: 99.9% PM, 99.5% PM10, 99.0% PM2.5 or 0.001 PM, 0.005 PM10, 0.01 PM2.5
Control Efficiencies for Cyclone: 75% PM, 50% PM10, 10% PM2.5 or 0.25 PM, 0.5 PM10, 0.90 PM2.5
Control Efficiencies for Filters: 75% PM, 50% PM10, 50% PM2.5 or 0.25 PM, 0.50 PM10, 0.50 PM2.5
EU-08A EP-RV CE-08AA
CE-08AB
Flour Handling / Final Plansifters
(Side A)
21.5 14,500 EU-06A EP-RV CE-06AA
CE-06AB Grain Milling (Side A)30200734 Wheat
30200533 (6)Flour 70 14,500
PTE (tpy) Limited Controlled & Limited (tpy)
Fugitive Source Totals
Outdoor Point Source Totals
Emission Factors (lb./ton) from
AP-42 9.9.1-1 & 9.9.1-2 PTE (tpy) PTE (tpy) Controlled
(3) 50% SCC for grain shipping by rail used since no SCC for flour shipping and flour shipping is cleaner and SCC for Flour Bulk Loading is Non-Detect
(2) 50% SCC for grain shipping by truck used since no SCC for flour shipping and flour shipping is cleaner and SCC for Flour Bulk Loading is Non-Detect
PTE (tpy) = Max. Design Rate (tons/hr.) x Emission Factor (lb./ton) x 8760 hrs./yr. x Capture Efficiency / 2000 lbs./ton
(7) Grain Tempering is listed as ND in AP-42, the PM emissions for grain tempering are estimated to be 50% of grain handling
All Point Source (Indoor and
Outdoor Totals
Total Outdoor Emissions
Footnotes:
Modeling Thresholds
PM10 Fugitive Emissions 5 tpy
PM10 Non Fugitive Emissions 15 tpy
PM2.5 Total Combined Emissions 10 tpy
All Totals
EMISSION CALCULATIONS
Utah Flour Milling LLC - Conventional / Organic Milling Operations
11595 N. US 91 HWY, Richmond, UT 84333
EU ID #EP ID#CE ID#Emission Unit (EU)SCC #
Raw
Material
Max.
Design
Rate
(tons/hr.)
Requested
Permit (tpm)Exhaust
Capt.
Eff.
Cont.
Eff. PM
Cont.
Eff.
PM10
Cont.
Eff.
PM2.5
Conv.
Factor
(lbs./ton)
Conv.
Factor
(hrs./yr.) PM EF PM10 EF PM2.5 EF PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5
EU-01A EP-01 CE-01 Grain Receiving (Truck)30200552 Wheat 200 20,000 Outdoors 0.5 0.001 0.005 0.01 2,000 8,760 0.0350 0.0078 0.0013 15.33 3.42 0.57 0.015 0.017 0.006 2.100 0.468 0.078 0.002 0.002 0.001
EU-01B EP-01 CE-01 Grain Receiving (Rail)30200552 Wheat 300 20,000 Outdoors 0.5 0.001 0.005 0.01 2,000 8,760 0.0320 0.0078 0.0013 21.02 5.12 0.85 0.021 0.026 0.009 1.920 0.468 0.078 0.002 0.002 0.001
EU-02 EP-01 CE-01 Grain Handling (legs, conveyors,
belts, etc.)30200553 Wheat 300 20,000 Outdoors 1 0.001 0.005 0.01 2,000 8,760 0.0610 0.0340 0.0058 80.15 44.68 7.62 0.080 0.223 0.076 7.320 4.080 0.696 0.007 0.020 0.007
EU-03 FS-03 N/A Grain Storage (Bins)30200540 Wheat 300 20,000 Outdoors 1 1 1 1 2,000 8,760 0.0250 0.0063 0.0011 32.85 8.28 1.45 32.850 8.278 1.445 - 0.756 0.132 3.000 0.756 0.132
EU-04A EP-04A
CE-04AA
CE-04AB
CE-04AC
CE-04AD
Grain Cleaning (Side A)30200733 Wheat 21.5 14,500 Outdoors 1 0.001 0.005 0.01 2,000 8,760 0.0480 0.0120 0.0020 4.52 1.13 0.19 0.005 0.006 0.002 4.176 1.044 0.174 0.004 0.005 0.002
EU-05A EP-05A CE-05A Grain Tempering (Side A) (7)Listed as ND in
AP-42 Wheat 21.5 14,500 Outdoors 1 0.001 0.005 0.01 2,000 8,760 0.0305 0.0170 0.0029 2.87 1.60 0.27 0.003 0.008 0.003 2.654 1.479 0.252 0.003 0.007 0.003
Outdoors (5)1 0.00025 0.0025 0.009 2,000 8,760 70.0000 35.0000 5.9500 6,591.90 3,295.95 560.31 1.648 8.240 5.043 6,090.000 3,045.000 517.650 1.523 7.613 4.659
Indoors (5)0 0.00025 0.0025 0.009 2,000 8,760 70.0000 35.0000 5.9500 - - - - - - - - - - - -
EU-07A EP-07A CE-07A Flour Storage Bins (Side A)30200560 (1)Flour 20 14,500 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0125 0.0032 0.0006 1.10 0.28 0.05 0.274 0.140 0.026 1.088 0.278 0.052 0.272 0.139 0.026
Outdoors (5)1 0.001 0.005 0.01 2,000 8,760 0.0610 0.0340 0.0057 18.70 10.42 1.75 0.019 0.052 0.017 5.307 2.958 0.496 0.005 0.015 0.005
Indoors (5)0 0.001 0.005 0.01 2,000 8,760 0.0610 0.0340 0.0057 - - - - - - - - - - - -
EU-09 EP-09 CE-09 Flour Bulk Loadout (Truck)30200560 (2)Flour 30 5,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0430 0.0145 0.0025 5.65 1.91 0.33 1.413 0.953 0.164 1.290 0.435 0.075 0.323 0.218 0.038
EU-10 FS-10 NA Flour Bulk Loadout (Rail)30200563 (3)Flour 30 5,000 Outdoors 0.5 1 1 1 2,000 8,760 0.0135 0.0011 0.0002 0.89 0.07 0.01 0.887 0.072 0.012 0.203 0.017 0.003 0.203 0.017 0.003
EU-11 EP-11 CE-11 Flour Packaging (Bags and Totes)30200560 (4)Flour 30 5,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0430 0.0145 0.0025 5.65 1.91 0.33 1.413 0.953 0.164 1.290 0.435 0.075 0.323 0.218 0.038
EU-12 EP-12 CE-12 Milling Byproduct, Hammer
Milling 30200817 Feed 1.5 1,450 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.3350 0.1680 0.0290 2.20 1.10 0.19 0.550 0.552 0.095 2.915 1.462 0.252 0.729 0.731 0.126
EU-13 EP-13 CE-13 Feed Storage (Bins)Listed as ND in
AP-42 (8)Feed 1.5 5,200 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0250 0.0060 0.0011 0.16 0.04 0.01 0.041 0.020 0.004 0.780 0.187 0.034 0.195 0.094 0.017
EU-14 FS-14 N/A Feed Loadout (Truck)30200803 Feed 40 5,200 Outdoors 0.5 1 1 1 2,000 8,760 0.0033 0.0008 0.0001 0.29 0.07 0.01 0.289 0.070 0.009 0.051 0.012 0.002 0.051 0.012 0.002
34.03 8.42 1.47 34.03 8.42 1.47 0.25 0.78 0.14 3.25 0.78 0.14
9,586.47 4,785.29 813.48 8.59 25.50 10.45 6,120.84 3,058.29 519.91 3.39 9.06 4.92
9,620.49 4,793.71 814.95 42.62 33.92 11.92 6,121.09 3,059.08 520.05 6.64 9.85 5.06
13,828.77 6,907.08 1,174.17 12.83 46.72 17.67 6,120.84 3,058.29 519.91 3.39 9.06 4.92
13,862.80 6,915.50 1,175.64 46.86 55.14 19.13 6,121.09 3,059.08 520.05 6.64 9.85 5.06
(1) 50% SCC for grain storage used since no SCC for flour storage and flour storage is cleaner
(4) 50% SCC for grain shipping by truck used since no SCC for flour packaging and flour packaging is cleaner and SCC for Flour Bulk Loading is Non-Detect
(5) The emission are vented thorugh a duct valving system that can be opened to discharge to outside the building or closed to direct flow through RTUs with filters and then back into the building. The valving split is based on interior temperature.
(6) SCC for grain handling used since no SCC for flour handling and flour handling is cleaner.
(8) SCC for grain storage used since Feed storage Listed as ND, but is assumed to be similar to grain storage.
tpm = tons per month
PTE Controlled (tpy) = [Max. Design Rate (tons/hr.) x Emission Factor (lb./ton) x 8760 hrs./yr. x Capture Efficiency x Control Efficiency / 2000 lbs./ton]
PTE Limited (tpy) = [Permit Limit (tons/mo.) x 12 mo./yr. x Emission Factor (lb./ton) x Capture Efficiency / 2000 lbs./ton]
PTE Controlled & Limited (tpy) = [Permit Limit (tons/mo.) x 12 mo./yr. x Emission Factor (lb./ton) x Capture Efficiency x Control Efficiency / 2000 lbs./ton]
Control Efficiencies are based on industry standard PM control percentages. Actual emissions would likely be lower.
Control Efficiencies for Baghouse: 99.9% PM, 99.5% PM10, 99.0% PM2.5 or 0.001 PM, 0.005 PM10, 0.01 PM2.5
Control Efficiencies for Cyclone: 75% PM, 50% PM10, 10% PM2.5 or 0.25 PM, 0.5 PM10, 0.90 PM2.5
Control Efficiencies for Filters: 75% PM, 50% PM10, 50% PM2.5 or 0.25 PM, 0.50 PM10, 0.50 PM2.5
EU-08A EP-RV CE-08AA
CE-08AB
Flour Handling / Final Plansifters
(Side A)
21.5 14,500 EU-06A EP-RV CE-06AA
CE-06AB Grain Milling (Side A)30200734 Wheat
30200533 (6)Flour 70 14,500
PTE (tpy) Limited Controlled & Limited (tpy)
Fugitive Source Totals
Outdoor Point Source Totals
Emission Factors (lb./ton) from
AP-42 9.9.1-1 & 9.9.1-2 PTE (tpy) PTE (tpy) Controlled
(3) 50% SCC for grain shipping by rail used since no SCC for flour shipping and flour shipping is cleaner and SCC for Flour Bulk Loading is Non-Detect
(2) 50% SCC for grain shipping by truck used since no SCC for flour shipping and flour shipping is cleaner and SCC for Flour Bulk Loading is Non-Detect
PTE (tpy) = Max. Design Rate (tons/hr.) x Emission Factor (lb./ton) x 8760 hrs./yr. x Capture Efficiency / 2000 lbs./ton
(7) Grain Tempering is listed as ND in AP-42, the PM emissions for grain tempering are estimated to be 50% of grain handling
All Point Source (Indoor and
Outdoor Totals
Total Outdoor Emissions
Footnotes:
Modeling Thresholds
PM10 Fugitive Emissions 5 tpy
PM10 Non Fugitive Emissions 15 tpy
PM2.5 Total Combined Emissions 10 tpy
All Totals
11117 Mockingbird Drive
Omaha, NE 68137
402.697.9747 | oneatlas.com
New Air Permit (NOI) / Utah Flour Milling LLC / 11595 N. US 91 HWY / Richmond, UT 84333
September 26, 2024 1

September 26, 2024

Jon Black or Alan Humphreys
Utah Dept. of Environmental Quality – Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84116

Submitted Via Email: [e-mail] & [e-mail]

SUBJECT: New Air Permit (NOI)
Utah Flour Milling LLC Facility
11595 N. US 91 HWY
Richmond, UT 84333

Dear Jon Black or Alan Humphreys:
Atlas Technical Consultants (Atlas) was retained by Utah Flour Milling LLC to complete the Air Permit review
and prepare the Notice of Intent (NOI) permit forms for a new wheat milling facility at 11595 North US 91
Highway Richmond, Utah. The document summarizes the facility activities and provides the applicable permit
forms as an attachment. The facility is subject to permitting requirements under Utah Administrative Code
R307-401.
FACILITY INFORMATION
The Utah Flour Milling LLC Facility is an entirely new facility that is in the process of building and construction
and final design stage for the equipment. The facility will intake raw wheat product from trucks or railcars and
process the wheat into flour. The facility will also generate wheat byproduct that will be utilized for animal feed.
Key features to the facility operations in relation to the air permit are summarized below. A Process Flow
Diagram is also included in the permit documents.
 The facility is initially being constructed with half of the planned milling equipment, and the design will
allow for the installation of additional equipment at a later date to increase the facility production. This
application is being submitted for the current planned operations and a second application will be
submitted in the future that will include modifications for the additional equipment. Based on the
estimated emission calculations, the equipment included in this application does not require dispersion
modeling. If future modifications exceed modeling thresholds, it will be included with the application.
 The facility will receive wheat by truck or rail at combined maximum design unloading rate of up to
300 tons per hour, or 10,000 bushels per hour based on wheat having a weight of 60 pounds per
bushel. This receiving will only need to be performed on an intermittent basis to maintain sufficient
grain capacity for the facility as the milling process will have a maximum processing rate of 21.5
tons/hour. The requested monthly receiving limits of 20,000 tons by truck and 20,000 tons by rail are
conservative values and would allow for higher intakes than the approximately 14,500 tons per month
that is required for the maximum 21.5 tons per hour milling process rate.

New Air Permit (NOI) / Utah Flour Milling LLC Facility / 11595 N. US 91 HWY / Richmond, UT 84333
September 25, 2024 2

 The facility will have grain bins that will store approximately 1,000,000 bushels of wheat, which would
equate to approximately 30,000 tons, based on an estimated 60 pounds per bushel. This total capacity
would be sufficient for the facility to operate for approximately 58 days at the maximum milling
production capacity of 21.5 tons per hour. This storage capacity allows for volatilities in grain pricing
and availability. The future expansion plans will add approximately 600,000 bushels of storage.
 The facility milling equipment is the restricting production factor with a maximum grain processing
capacity of approximately 20 tons per hour (40,000 pounds per hour); however, the actual average
throughput rate is anticipated to be lower than this maximum. A requested permit limit of 14,500 tons
per month for these operations allows for an average production rate of 19.9 tons per hour.
 The production process includes grain cleaning, milling, storage and product transfer activities. These
processes were broken down into distinctive processes, which were identified as specific Emission
Units (EUs) with associated Emission Control Equipment (CEs) and Emission Points (EPs) for
permitting purposes. For simplicity purposes, some of these EUs, CEs and EPs may include multiple
steps or multiple parallel pieces of similar equipment that perform a similar function. The included
permit calculation are based on the combined throughputs for similar equipment; therefore, details
regarding every piece of equipment that is included in the EU may not be included. The combined
details for the equipment and system layout are depicted on the process flow diagram and listed on
the Emission Calculation spreadsheet.
 The flour product will be temporarily stored at the facility for shipment by truck, rail, packaging (bags
and totes), or by a direct supply line to a neighboring facility (Cambell’s). The flour loadout can occur
directly from bins at 10 tons per hour, or through plansifters with flow rates of 30 tons per hour each.
 The wheat by-product that is collected from various milling process stages at the facility is either milled
into flour or stored at the facility where it is then shipped out by truck for use as animal feed.
NON ATTAINMENT AREA
The facility was identified by the US EPA to be located within the Logan, UT-Franklin, ID PM2.5 Nonattainment
Area, which would be subject to the permitting regulations under the Utah Administrative Code R307-403.
However, according to Alan Humpherys with the UDEQ, the Logan nonattainment area was redesignated to
Attainment in 2021. Based on this redesignation, there are no offsetting requirements in the area of the facility
and air permitting in this area would only need to follow the general air permitting requirements of the Utah
Administrative Code R307-401.
The calculations within this permit application result in emissions below the significant emission increase
thresholds of 15 and 10 tons per year for PM10 and PM2.5 that would require dispersion modeling. However,
future expansions at the facility may exceed this threshold.
EMISSION FACTORS
The emission factors for the emission units were generally obtained from AP-42 9.9.1-1 and 9.9.1-2 using the
most applicable Source Classification Codes (SCC). Some of the emission units such as flour storage and
handling did not have applicable SCCs. In these cases, conservative emission factors were used that result

New Air Permit (NOI) / Utah Flour Milling LLC Facility / 11595 N. US 91 HWY / Richmond, UT 84333
September 25, 2024 3

in higher calculated emissions. The SCC numbers and the justification for using adjusted emission factors are
detailed on the Emission Calculations Spreadsheet.
Some of the EUs are configured in a way where other facility designs or layout would limit the potential
emissions that are emitted through the associated EP. In these cases, the resulting particulates would pass
through the process or would be cleaned up by general cleaning. For example, some emissions from
equipment are directed through baghouses and then discharged back to the interior of the building. The air
would be circulated through the building, which may be then directed to roof exhaust vents. Therefore, the
potential emissions for some equipment was reduced based this system.
CONTROL EQUIPMENT
The facility will use baghouses as Control Equipment (CE) in specific areas to reduce emissions from some of
the EUs. The air flow rates through the baghouses may vary; however, the facility will use similar baghouses
with the baghouse designed to handle the maximum flow rate. The baghouse control efficiencies of 99.9% for
PM, 99% for PM10 and, 98% for PM2.5 were used in the emission calculations; however, the control equipment
is anticipated to have higher control efficiencies. Manufacturer and design information for these baghouses is
included with the included permit documents.
The facility system will also use cyclones in specific areas that are primarily designed to assist in the movement
of the flour products in piping at the facility through aspiration. These types of cyclones have control efficiencies
of 88% for PM, 78% for PM10 and, 63% for PM2.5. These cyclones may provide some reduction in particulate
emissions. However, based on their variable usage, they have been generally excluded from inclusion as
emission control equipment in the included emission calculations.
The flour and feed storage bins have bin vent filters and some of the unloading areas have dust filter vents
that will limit emissions. Since there may be some variability in the efficiencies of this equipment, conservative
control efficiencies of 75% for PM, 50% for PM10 and, 50% for PM2.5 were used in the emission calculations.
Manufacturer information for these filters is included with the permit documents. Additionally, it is anticipated
that some of this equipment will not run continuous during facility operations; therefore, the actual emissions
are expected to be lower than identified in the potential emission calculations.
The grain cleaning, milling, and flour handling operations have some air discharges that vent to the interior of
the building. Some of this air may be directed to the exterior by roof mounted exhaust fans; however, some
particulates will be retained within the building and will be removed by general cleaning or through other
means. Therefore, this system will further reduce facility emissions and these emissions have been divided
into outdoors and indoors on the emission calculations spreadsheet.
AIR EMISSION EVALUATION
Based on the calculated potential to emit from the facility equipment and operations and proposed limits, the
facility is required to have an operating permit. The facility emissions are associated with particulates that are
produced during the wheat handling and milling processes. The following potential emissions were calculated
and are included as an attachment.

New Air Permit (NOI) / Utah Flour Milling LLC Facility / 11595 N. US 91 HWY / Richmond, UT 84333
September 25, 2024 4

 Potential To Emit (PTE) Emissions were calculated from established emission factors and equipment
design rates and based on continuous operation. These emission calculations do not consider reductions
in emissions due to control equipment or requested permit limits.
 The PTE Controlled emission calculations result in a reduction of emissions since they include efficiencies
from control equipment.
 Some of the facility equipment does not operate continuously or at the maximum design rate. For example,
the grain receiving is not continuous to maintain facility operations. The PTE Limited emission calculations
provide a more realistic anticipated operational periods and result in a reduction of emissions due to
requested permit limits.
 The Controlled & Limited emission calculations take into account potential emission from both control
equipment and requested permit limits. These calculations are more consistent with the potential
emissions that would be expected from the facility.
 The Controlled & Limited emissions are generally higher than actual emissions for various reasons. The
control equipment has higher efficiencies than were used in the emission calculations and the facility
generally operates below the hours or flow rates used in the emission calculations. Atlas has prepared a
spreadsheet for this facility that they can use to input the actual product throughput, which will provide
more accurate information regarding actual emissions from the facility for a specific period.
FACILTY PERMIT PREPARATION
Based on the provided facility operations and equipment as previously summarized, Atlas has prepared the
attached applicable forms that have been signed by Utah Flour Milling LLC. In addition, the applicable payment
fees have been provided (https://deq.utah.gov/air-quality/fees-air-quality-permitting).
We appreciate the opportunity to provide this proposal for your project. If you have any questions or require
further information, please email [e-mail].
Sincerely,
ATLAS TECHNICAL CONSULTANTS

Scott Hanson, PE (IA, NE, KS, MO) Jack Batho IV
Project Engineer Staff Engineer

Facility Air Permit Application Attachments:
1 - Notice of Intent (NOI) Application (State Forms 1, 2, 3 & 5)
2 - Facility Vicinity Plan
3 - Facility Site Plan
4 - Facility Process Flow Diagram
5 - Facility Process Information (State Form 2)
6 - Facility Control Equipment, Fabric Filters, Baghouses (State Form 10)
7 - Facility Emission Unit Specifications
8 - Facility Emission Calculations

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 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
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.
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
Page 1 of 1
Form 3 Company____________________
Process Information Site________________________
Utah Division of Air Quality
New Source Review Section
Process Information - For New Permit ONLY
1.Name of process:2.End product of this process:
3.Process Description*:
Operating Data
4.Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year
5.Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall _______
6.Maximum Hourly production (indicate units.):
_____________
7.Maximum annual production (indicate units):
________________
8.Type of operation:
Continuous Batch Intermittent
9.If batch, indicate minutes per cycle ________
Minutes between cycles ________
10. Materials and quantities used in process.*
Material Maximum Annual Quantity (indicate units)
11.Process-Emitting Units with pollution control equipment*
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If additional space is required, please create a spreadsheet or Word processing document and attach to form.
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
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
Parcel Boundary
Existing Railroad Line
Proposed Railroad
Line Spurs
Truck and Rail Unloading
WarehouseMill Building
Flour Line to Plant
E 11600 N (Two Lane, Pavement)
Hig
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Single Family Residential
11611 N Highway 91
Single Family Residnetial
11646 N Highway 91
Ag/Storage Buildings
Non Residential
1027 E 1160 N
Single Family Residential
1080 N 200 W
Non Residential
930 N Highway 91
Non Residential
93901 N 200 W

N
0 250125
Parcel Boundary
Flour Line to Adjoining Campbell's Factory
E 11600 N (Two Lane, Pavement)
Grain Receiving, Rail (EU-01B)
Flour Bulk Loadout, Rail (EU-10)
Grain Receiving, Truck (EU-01A)
Grain Handling, Legs, conveyors, belt, etc. (EU-02)
Grain Storage, Bins (EU-03)
Grain Storage, Bin Vents (FS-03)
Grain Receiving and Handling (EP-01)
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Future Warehouse
Grain Tempering Bins (EU-05A)
Flour Storage Bins (EU-07A)
Flour Handling / Plansifters (EU-08A)
Feed Storage, Bins (EU-13)
Feed Storage, Bins (EP-13)
Main Plant Building
Flour Loadout, Rail (EP-10)
Flour Packaging,
Bags and Totes
(EU-11)
Flour Packaging
(EP-11)
Grain Tempering (EP-05A)
Milling Byproduct, Hammer Milling (EP-12)
Existing Railroad Line
Proposed Railroad
Spur Lines
Pavement Drive
Flour Storage Bin Vents (EP-07A)
Grain Cleaning (EU-04A)
Grain Cleaning (EP-04A)
Grain Milling (EU-06A)
Various Roof Vents
Grain Milling (EP-RV)
Flour Handling / Plansifters (EP-RV)
Flour Loadout, Truck (EU-09)
Flour Loadout, Truck (EP-09)
Milling Byproduct, Hammer Milling (EU-12)
Feed Loadout (EU-14)
Feed Loadout (FS-14)
Warehouse Office

N
0 7035
PROCESS FLOW DIAGRAM
Utah Flour Milling LLC Facility – Conventional/Organic Milling Operations
Grain Receiving, Storage, Cleaning, and Milling
11595 N. US 91 HWY, Richmond, UT 84333
9/25/2024

Grain Receiving, Truck
EU-01A
(200) ton/hr

Grain Receiving, Rail
EU-01B
(300) ton/hr
Grain Storage, Bins
EU-03
(300) ton/hr

Grain Handling, Conveyors
EU-02
(300) ton/hr
Baghouse
CE-01
FL-8070

Stack Near receiving ~(12’)
EP-01
FN-8074

A: Grain Cleaning
EU-04A
(21.5) ton/hr

Various Roof Vents (90’)
FS-03 (Fugitive)
FN-8074

Baghouse
CE-04AD
FL-3415

Cyclones (parallel)
CE-04AA, CE-04AB, CE-04AC
CY-3140, CY- 3150, CY-3170

Stack Above roof (90’)
EP-04A
FN-3420

A: Grain Tempering
EU-05A
(21.5) ton/hr

A: Grain Milling Process
EU-06A
(21.5) ton/hr

Baghouse
CE-05A
FL-3395

Stack Above roof (90’)
EP-05A
FN-3400

Cyclones, Various (parallel)
CE-06AA
CY-4290-4315, 4758

Baghouses, (parallel)
CE-06AB
FL-4091, 4110, 4595

A: Flour Storage Bins
EU-07A
(20) ton/hr
Bin Filter (each bin)
CE-07A
FL-5285 (typical)

Stack Above Roof (90’)
EP-07A
FN-5350

Building Interior
To Roof Vents
EP-RV

Feed Storage Bin
EU-13
1.5 ton/hr
Bin Filter
CE-13
FL-8025

Feed Loadout
EU-14
40 ton/hr.
Stack Above Roof (90’)
EP-13
FL-TBD

By-Product Hammer Mill
EU-12
1.5 ton/hr
Truck Loadout (~12’)
FS-14 (Fugitive)
EQ-8050

Product Flow
Air Flow
Milling Byproduct
Emission Unit (EU)
Control Equipment (CE)
Emission Point (EP)
Notes (See Below)

Notes:
(1) (Maximum Processing Flow Rates) ton/hr.
(2) FL-##, CY-##, FN-## are references to the facility identified numbers for specific equipment.
(3) The facility milling operations to final flour storage bins are designated as Side A. The facility is being designed to allow for the addition of a Side B that will include similar
parallel functions as Side A. This Side B will increase the throughput capacity of the facility and a permit modification will be submitted in the future for this expansion.
(4) The flour loadout system include multiple product lines that allow for transfers from various flour storage bins to the four loadout locations to occur simultaneously
through Plansifter A, Plansifter B, or directly from the bins with smaller plansifters (at a reduced flow).
(5) Milling byproduct may milled for use as feed or be directed to the feed storage bin for usage as animal feed.
Total Grain Storage Capacity
1,000,000 bushels
Wheat – 60 pounds/bushel
(#)
(1)
(2) (2)
(3)
Future
Side B
Operations
To Loadout A
A: Plansifter A (EQ-5430)
EU-08AA
(30) ton/hr
Baghouse
CE-08AA
FL-5410

Building Interior
To Roof Vents
EP-RV

Flour Loadout, Truck
EU-09
(30) ton/hr

Flour Loadout, Rail
EU-10
(30) ton/hr

Flour Loadout, Packaging
EU-11
(30) ton/hr

To Adjoining Cambell’s
Facility, No Emissions
(30) ton/hr
A: Plansifter B (EQ-6060)
EU-08AB
(30) ton/hr

Baghouse
CE-08AB
FL-6035

Building Interior
To Roof Vents
EP-RV

Dust Filter
CE-09
FL-6225

Stack ~20’ Above Ground
EP-09
FN-6230

Top of Truck ~12’
FS-10

Dust Filter
CE-11
FL-TBD

Stack ~20’ Above Ground
EP-11
FN-TBD

Loadout A (a) Loadout A (c) (Direct From Bins)
(a) (c) (b)
Loadout A (b)
Loadout A (c) (Direct From Bins)
Loadout A (c) (Direct From Bins)
Loadout A (c) (Direct From Bins)
(5)
Exterior Wall (43’)
EP-12
FN-TBD

Filter
CE-12
FL-4935

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
CAMCORP, INC.
15729 College Blvd  Lenexa, Kansas 66219  Phone [phone] Fax [phone]  www.camcorpinc.com

CAMCORP EMISSION STATEMENT
Bratney - 410838
CAMCORP Model: 10SWF112
Application: Nuisance Collection
Flowrate: 10,000 ACFM @ 70° F.
Air-To-Media Ratio: 7.4 to 1
CAMCORP Inc. warrants the performance of its Baghouse with 16 oz. Polyester Filter Bags, when operated per the design parameters
referenced in the original proposal and in accordance with the manufacturer’s operations manuals, to emit dry particulate matter
greater than 2 microns in size at no more than .01 gr/dscf of air.
The warranty is subject to the following conditions:
• The equipment will be installed, operated and maintained according to generally accepted and approved engineering and
construction standards and in accordance with CAMCORP Installation, Operation and Maintenance instructions. Buyer must
maintain adequate records to allow verification of such operation and maintenance.
• Owner will perform black light testing before systems operation to ensure no dust leakage through the baghouse. If leakage
occurs, CAMCORP will determine the cause of such failure. The results will determine the recommended course of corrective
actions. If bag material or workmanship is found to be the cause of the non-compliance, CAMCORP will replace bags in question
at no charge, or make compensation to the end-user in the amount of CAMCORP cost of the bags to be replaced on a one-for-
one basis. If the non-compliance is determined to be damage to the media as a result of improper handling or installation of
the bags by the installer, replacement costs are to be responsibility of the Owner.
• Tests to determine compliance with CAMCORP’s particulate emissions warranty shall be performed in accordance with EPA
(Environmental Protection Agency) Test Method No. 5. A qualified independent test company shall perform testing. The test
shall be conducted within 45 days of start-up, and once normal operating conditions are achieved.
• Buyer shall select an independent testing company to perform the required test but such selection shall be subject to
CAMCORP’s approval. Buyer shall be responsible for all testing company fees, charges and expenses.
• CAMCORP will be notified at least (2) weeks prior to any testing, may inspect the baghouse prior to testing, has the right to be
present during testing, and will be provided with a full copy of all tests including raw data and calculations.
• At all times prior to and during testing, all specified operating conditions must be strictly adhered to.
• If the warranted .01 gr/dscf is not attained on the first test, CAMCORP Inc. will be given a maximum of 60 days with which to
bring the equipment into conformity.
• Owner will provide, on request, applicable maintenance and operation records of actual operating conditions.
• Upon satisfaction of the emissions warranty, CAMCORP shall have no further liability to Buyer under this warranty.

David Barber
Application Engineering Manager
CAMCORP Inc.
11/14/2023
PRODUCT DATA SHEET Issue 1
ANTISTATIC POLYESTER NEEDLEFELT
AREA WEIGHT EN 12127 g/m²10,4 oz/yd²DENSITY 0,35 g/cm³
THICKNESS EN ISO 9073/2 mm 0,039 in PORE VOLUME 75 %
FIBER POLYESTER
COMPOSITION
SCRIM POLYESTER/INOX
FINISH
LONGITUDINAL CROSS
TENSILE STRENGTH (5 cm)EN 29073-3 ≥900 N 198 lbs/2" ≥700 N 154 lbs/2"
ELONGATION EN 29073-3 ≤30 %≤50 %
ELONGATION at 50 N EN 29073-3 ≤N.A.%≤N.A.%
THERMAL STABILITY (SHRINKAGE)UNI 8279/12 ≤2 %≤1 %
air at 150°C - 2 h
BURST STRENGTH ISO 13938 ≥N.A.kPa ≥N.A.psi
AIR PERMEABILITY EN ISO 9237
at 200 Pa l/dm² • min
cfm @ 1/2" H 2O
EFFICIENCY FACTOR
SURFACE RESISTIVITY 10 4 ohm (DIN 54345/1-5)
FIBER PROPERTIES:ANTISTATIC POLYESTER
OPERATING TEMPERATURE (Dry) CONTINUOUS 150°C Max 302 °F Max
PEAKS 160°C Max 320 °F Max
CHEMICAL RESISTANCE
STRONG ACIDS STRONG ALKALIS SOLVENTS 
WEAK ACIDS WEAK ALKALIS OXIDIZING 
HYDROLYSIS 
LEGEND: Excellent Good Fair Poor
Testori S.p.A. Largo A. Testori n. 5 - 20026 Novate Milanese (MI - Italy)Printed date
Tel. [phone] - Fax [phone] - www.testori.it - mail: [e-mail]
20/04/22
TW 350 SA
41,00
STYLE
350
20/04/22
PRELIMINARY
All data and characteristics are not binding and may vary depending on the constant improvements that Testori Spa reserves itself to introduce.
Please contact Testori Spa before using these data for technical specification definition.
HEAT SET - SURFACE GLAZING
1,0
200
“DuPont™, the DuPont Oval Logo, and all trademarks and service marks denoted with ™, SM or ® are owned by affiliates of DuPont de Nemours, Inc. unless otherwise
noted. © 2019 DuPont.”
#RIF!
1
10
100
1000
10000
1 10 100 1000 10000
Air permeabilityPa
l
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
1
2
3
7

1
3
6
6

1
6
2
6

2
6
0

6
7
,
5
0

AA
1353
1
2
0
9

1088
1038
10
1063
SEZIONE A-A
N. HOLES 30

270
8
332 FN-B.4.J.16.S_1.+.F.1.1_PP.+_1.+.6.+.+_R.+.++_B
FILTRO TONDO TIPO FN - -ROUND FILTER TYPE FN - -
Wamgroup®
1 2
1 2 3
A
B
C
D
E
F
C
D
F
87654
Sigla modulare:Key code:
Data/Drw Date:Disegnatore/Drawn by:
Questo documento e le informazioni in esso contenute sono di proprietà di Wamgroup S.p.a., hanno natura riservata e non possono essere trasmesse a terzi senza autorizzazione scritta di Wamgroup S.p.a.
This document and contained informations belongs to Wamgroup S.p.a. and are confidential it must not be comunicated to other people without written authorization from Wamgroup S.p.a.
Scala:Scale:
A3Formato:Size:
DENOMINAZIONE/DENOMINATION:
Disegno/Drawing N°:Peso/Weight:Kg
WAMGROUP S.p.a. Via Cavour 33841032 Ponte MottaCavezzo (MO) ITALYTel. ++39/0535/618111Fax ++39/0535/618226
1:30
8
B
A
76453
E
D
Disegno di Controllo InterfacciaInterface Control Drawing
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
SOUTH ELEVATION
EAST ELEVATION
DISCHARGE FLANGE
3/8" PLATE
EXHAUST FLANGE
1/4" PLATE
INLET FLANGE
PURCHASED
DATE:
JOB NUMBER:
CUSTOMER:
DRAWN:
TITLE:
DRAWING NUMBER:
P.O. NUMBER:REVISION:
REV DRAWING STATUS BY DATE
9732 PFLUMM ROAD, LENEXA, KS 66215 PHONE: [phone] FAX: [phone]
THIS DRAWING AND THE SOLUTIONS/DESIGNS ARE THE PROPERTY OF CAMCORP, INC. AND ARE FURNISHED ONLY FOR
INFORMATIONAL PURPOSES ON A CONFIDENTIAL BASIS. REPRODUCTION, PUBLISHING, OR OTHER DISCLOSURES ARE ON A
"NEED TO KNOW" BASIS ONLY. ANY OTHER REPRODUCTION REQUIRES WRITTEN AUTHORIZATION BY A CORPORATE OFFICER.
BRATNEY
RICHMOND, UT
5BH10x35 DUST COLLECTOR
04/23/24 K011073 1
411034 411034-1
ZRE
A MEMBER OF THE SCHEUCH GROUP
CAMCORP
PG NUMBER:
1
1 FAN SUPPORT, MOVED EXP. VENT, ADDED HEIGHT ZRE 06/6/24
(1) UNIT REQUIRED
TAG #: FL-6225.00
S
W
N
E
(FACTORY COMPASS)
q
HOPPER ACCESS
DOOR/INLET/
q
EXHAUST
18" EXHAUST
(SEE DETAIL)
INTERIOR CAP PAINT:
EXTERIOR CAP PAINT:
INTERIOR DAP PAINT:
EXTERIOR DAP PAINT:
LADDER/PLATFORM PAINT:
SUPPORT STRUCTURE PAINT:
INTERIOR CAP WELDS:
EXTERIOR CAP WELDS:
INTERIOR DAP WELDS:
EXTERIOR DAP WELDS:
SPECIAL NOTES:
MATERIAL FINISHES
CAP WALLS:
ROOF:
DAP WALLS:
TUBE SHEET:
STIFFENERS:
GAS CONTACT:WALKING SURFACE:
HOPPER:
MATERIAL OF CONSTRUCTION
SUPPORT:CROSS BRACING:
PLATORM:LADDER:
APPLICATION SPECIFICATIONS
PRODUCT:
OPERATING TEMP:
AIR VOLUME:
AIR TO MEDIA RATIO:
APPLICATION:
CAN VELOCITY:
SQ. FT. CLOTH AREA:
DESIGN RATING:
CONTROL POWER:
INTERSTITIAL VELOCITY:
MOTOR POWER:
LOADING:
ALTITUDE:
COMPRESSED AIR:SCFM:
WEIGHT:MFG: COMPONENT: TOTAL:
47 7/8"
123"
24"
2
4
3
(35) TUBE SHEET HOLES
SAFETY GATE
1" NPT COMPRESSED AIR
CONNECTION EACH END,
FACTORY PLUG (1) END
6, 7
1/8" NPT
DP PORTS
(4) LIFTING LUGS
BOLTED LADDER & CAGE
ASSEMBLY - SHIPPED LOOSE
80"
1/4" DRAIN PLUG
20" X 60"
HINGED & CLAMPED
ACCESS DOOR,
HINGED ON LEFT
12" O.D. RADIAL INLET
W/ INTERNAL BAFFLE
(SEE DETAIL)
10" X 10" DISCHARGE
ITEM QTY.DESCRIPTION
1B
2
3
4
5
6
1A
7
35
35
5
5
1
1
1
50'
6" DIA. X 120" LG., #11 GA, GALV., (12) WIRE
1" DIA. TURBO DIAPHRAGM VALVES - NYLON TUBING
1/8" DIA. TURBO SOLENOID VALVES, NEMA 4 ENCLOSURE, HEATED T-STAT
5" x 5" x 1/4" SQ. TUBE COMPRESSED AIR HEADER - CARBON STEEL
NCC, 10-POSITION TIMER, NEMA 4 ENCLOSURE, SHIPPED LOOSE
DP KIT W/ DWYER MAGNEHELIC GUAGE, MOUNT BRACKET, SHIPPED LOOSE
1/4" NYLON TUBING & NECESSARY FITTINGS
6" DIA. X 120" LG., 16 OZ. POLYESTER FILTER BAGS
DUST COLLECTOR
FLOUR
3125 ACFM
5.58 TO 1
70 °F
155 FPM
90-100 PSIG
110 V
NUISANCE
-20" W.C.
560 SQ. FT
4610'
236 FPM
16-20 CFM
7.5HP
3538 LBS
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
CARBON STEEL
4" X 4" X 1/4" ANGLE CARBON STEEL
CARBON STEEL
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
3" X 2" X 1/4" ANGLE CARBON STEEL - 24" SPACING
#4 EXP. METAL
2" X 2" X 1/4" ANGLE CARBON STEEL
CARBON STEEL
NONE
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
NONE
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
TWO PART EPOXY PRIMED & PAINTED YELLOW ACROLON 218 HS, SSPC-SP6
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
STITCH WELDED
SPECIAL NOTES
CONTINUOUS - NOT GROUND
STITCH WELDED
CONTINUOUS - NOT GROUND
8"
1A, 1B
1384 LBS
15 1/4" SQ.
10"
4922 LBS
12 3/4"
n15 3/16"
n12 3/16"
n7/16(8) " HOLES
ON A 14" B.C.
STRADDLING CL's
n22 1/4"
n18 1/4"
n7/16(8) " HOLES
ON A 19 5/8" B.C.
STRADDLING CL's
7/8"
4 1/2"
2 1/4"
n7/16(12) "
HOLES
52" - REF
46" - UNIT
146 1/4"
REF
78"
SHIPPING
63"
UNIT
311 3/16"
9 1/4"
28 1/4"
36 1/2"
66"
8 1 SWSI SIZE 16 PLR FAN ARR. 4V, 7.5 HP
10 1 ACS MODEL CI 10x10 AIRLOCK
10
9 1 36x36 DOMED EXP. VENT
118 5/8
(3979 FPM)
INLET q
"
EXPLOSION VENT SIZING IS BASED ON AN UN-DUCTED INSTALLATION;
Kst = bar-m/s, Pmax = barg, Pstat = psig, Pred = psig.
P(RED) DOES NOT EXCEED TWO-THIRDS OF THE ULTIMATE STRENGTH FOR THE VENTED ENCLOSURE.
87 8.3 1.5 2.0
68 3/4"
9
q
EXP. VENT
8 1/4"
FOR CONSTRUCTION
SIGNATURE:
CAMCORP, INC.
CERTIFIED
06/18/24DATE:
PURPOSES
John Adkins
NORTH ELEVATION WEST ELEVATION
DETAIL A
UNIT FOOTPAD
SCALE 1/2" = 1'-0"
DETAIL B
LADDER FOOTPAD
SCALE 1/2" = 1'-0"
A
B
DATE:
JOB NUMBER:
CUSTOMER:
DRAWN:
TITLE:
DRAWING NUMBER:
P.O. NUMBER:REVISION:
REV DRAWING STATUS BY DATE
9732 PFLUMM ROAD, LENEXA, KS 66215 PHONE: [phone] FAX: [phone]
THIS DRAWING AND THE SOLUTIONS/DESIGNS ARE THE PROPERTY OF CAMCORP, INC. AND ARE FURNISHED ONLY FOR
INFORMATIONAL PURPOSES ON A CONFIDENTIAL BASIS. REPRODUCTION, PUBLISHING, OR OTHER DISCLOSURES ARE ON A
"NEED TO KNOW" BASIS ONLY. ANY OTHER REPRODUCTION REQUIRES WRITTEN AUTHORIZATION BY A CORPORATE OFFICER.
BRATNEY
RICHMOND, UT
5BH10x35 DUST COLLECTOR
04/23/24 K011073 1
411034 411034-1
ZRE
A MEMBER OF THE SCHEUCH GROUP
CAMCORP
PG NUMBER:
2
S
W
N
E
(FACTORY COMPASS)
59 1/2"65 1/2"
42 1/2"
48 1/2"
6"
6"
n7/8"
CAP INSPECTION DOOR
78 1/2"
113 1/4"
25 1/2"
3"
89 13/16"
72"
75"
4"4"
2"
n7/8"
144 7/16
q
EXP. VENT
"
1 FAN SUPPORT, MOVED EXP. VENT, ADDED HEIGHT ZRE 06/6/24
FOR CONSTRUCTION
SIGNATURE:
CAMCORP, INC.
CERTIFIED
06/18/24DATE:
PURPOSES
John Adkins
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
SOUTH ELEVATION
EAST ELEVATION
DISCHARGE FLANGE
3/8" PLATE
EXHAUST FLANGE
1/4" PLATE
INLET FLANGE
PURCHASED
DATE:
JOB NUMBER:
CUSTOMER:
DRAWN:
TITLE:
DRAWING NUMBER:
P.O. NUMBER:REVISION:
REV DRAWING STATUS BY DATE
9732 PFLUMM ROAD, LENEXA, KS 66215 PHONE: [phone] FAX: [phone]
THIS DRAWING AND THE SOLUTIONS/DESIGNS ARE THE PROPERTY OF CAMCORP, INC. AND ARE FURNISHED ONLY FOR
INFORMATIONAL PURPOSES ON A CONFIDENTIAL BASIS. REPRODUCTION, PUBLISHING, OR OTHER DISCLOSURES ARE ON A
"NEED TO KNOW" BASIS ONLY. ANY OTHER REPRODUCTION REQUIRES WRITTEN AUTHORIZATION BY A CORPORATE OFFICER.
BRATNEY
RICHMOND, UT
5BH10x35 DUST COLLECTOR
04/23/24 K011073 1
411034 411034-1
ZRE
A MEMBER OF THE SCHEUCH GROUP
CAMCORP
PG NUMBER:
1
1 FAN SUPPORT, MOVED EXP. VENT, ADDED HEIGHT ZRE 06/6/24
(1) UNIT REQUIRED
TAG #: FL-6225.00
S
W
N
E
(FACTORY COMPASS)
q
HOPPER ACCESS
DOOR/INLET/
q
EXHAUST
18" EXHAUST
(SEE DETAIL)
INTERIOR CAP PAINT:
EXTERIOR CAP PAINT:
INTERIOR DAP PAINT:
EXTERIOR DAP PAINT:
LADDER/PLATFORM PAINT:
SUPPORT STRUCTURE PAINT:
INTERIOR CAP WELDS:
EXTERIOR CAP WELDS:
INTERIOR DAP WELDS:
EXTERIOR DAP WELDS:
SPECIAL NOTES:
MATERIAL FINISHES
CAP WALLS:
ROOF:
DAP WALLS:
TUBE SHEET:
STIFFENERS:
GAS CONTACT:WALKING SURFACE:
HOPPER:
MATERIAL OF CONSTRUCTION
SUPPORT:CROSS BRACING:
PLATORM:LADDER:
APPLICATION SPECIFICATIONS
PRODUCT:
OPERATING TEMP:
AIR VOLUME:
AIR TO MEDIA RATIO:
APPLICATION:
CAN VELOCITY:
SQ. FT. CLOTH AREA:
DESIGN RATING:
CONTROL POWER:
INTERSTITIAL VELOCITY:
MOTOR POWER:
LOADING:
ALTITUDE:
COMPRESSED AIR:SCFM:
WEIGHT:MFG: COMPONENT: TOTAL:
47 7/8"
123"
24"
2
4
3
(35) TUBE SHEET HOLES
SAFETY GATE
1" NPT COMPRESSED AIR
CONNECTION EACH END,
FACTORY PLUG (1) END
6, 7
1/8" NPT
DP PORTS
(4) LIFTING LUGS
BOLTED LADDER & CAGE
ASSEMBLY - SHIPPED LOOSE
80"
1/4" DRAIN PLUG
20" X 60"
HINGED & CLAMPED
ACCESS DOOR,
HINGED ON LEFT
12" O.D. RADIAL INLET
W/ INTERNAL BAFFLE
(SEE DETAIL)
10" X 10" DISCHARGE
ITEM QTY.DESCRIPTION
1B
2
3
4
5
6
1A
7
35
35
5
5
1
1
1
50'
6" DIA. X 120" LG., #11 GA, GALV., (12) WIRE
1" DIA. TURBO DIAPHRAGM VALVES - NYLON TUBING
1/8" DIA. TURBO SOLENOID VALVES, NEMA 4 ENCLOSURE, HEATED T-STAT
5" x 5" x 1/4" SQ. TUBE COMPRESSED AIR HEADER - CARBON STEEL
NCC, 10-POSITION TIMER, NEMA 4 ENCLOSURE, SHIPPED LOOSE
DP KIT W/ DWYER MAGNEHELIC GUAGE, MOUNT BRACKET, SHIPPED LOOSE
1/4" NYLON TUBING & NECESSARY FITTINGS
6" DIA. X 120" LG., 16 OZ. POLYESTER FILTER BAGS
DUST COLLECTOR
FLOUR
3125 ACFM
5.58 TO 1
70 °F
155 FPM
90-100 PSIG
110 V
NUISANCE
-20" W.C.
560 SQ. FT
4610'
236 FPM
16-20 CFM
7.5HP
3538 LBS
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
CARBON STEEL
4" X 4" X 1/4" ANGLE CARBON STEEL
CARBON STEEL
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
3" X 2" X 1/4" ANGLE CARBON STEEL - 24" SPACING
#4 EXP. METAL
2" X 2" X 1/4" ANGLE CARBON STEEL
CARBON STEEL
NONE
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
NONE
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
TWO PART EPOXY PRIMED & PAINTED YELLOW ACROLON 218 HS, SSPC-SP6
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
STITCH WELDED
SPECIAL NOTES
CONTINUOUS - NOT GROUND
STITCH WELDED
CONTINUOUS - NOT GROUND
8"
1A, 1B
1384 LBS
15 1/4" SQ.
10"
4922 LBS
12 3/4"
n15 3/16"
n12 3/16"
n7/16(8) " HOLES
ON A 14" B.C.
STRADDLING CL's
n22 1/4"
n18 1/4"
n7/16(8) " HOLES
ON A 19 5/8" B.C.
STRADDLING CL's
7/8"
4 1/2"
2 1/4"
n7/16(12) "
HOLES
52" - REF
46" - UNIT
146 1/4"
REF
78"
SHIPPING
63"
UNIT
311 3/16"
9 1/4"
28 1/4"
36 1/2"
66"
8 1 SWSI SIZE 16 PLR FAN ARR. 4V, 7.5 HP
10 1 ACS MODEL CI 10x10 AIRLOCK
10
9 1 36x36 DOMED EXP. VENT
118 5/8
(3979 FPM)
INLET q
"
EXPLOSION VENT SIZING IS BASED ON AN UN-DUCTED INSTALLATION;
Kst = bar-m/s, Pmax = barg, Pstat = psig, Pred = psig.
P(RED) DOES NOT EXCEED TWO-THIRDS OF THE ULTIMATE STRENGTH FOR THE VENTED ENCLOSURE.
87 8.3 1.5 2.0
68 3/4"
9
q
EXP. VENT
8 1/4"
FOR CONSTRUCTION
SIGNATURE:
CAMCORP, INC.
CERTIFIED
06/18/24DATE:
PURPOSES
John Adkins
NORTH ELEVATION WEST ELEVATION
DETAIL A
UNIT FOOTPAD
SCALE 1/2" = 1'-0"
DETAIL B
LADDER FOOTPAD
SCALE 1/2" = 1'-0"
A
B
DATE:
JOB NUMBER:
CUSTOMER:
DRAWN:
TITLE:
DRAWING NUMBER:
P.O. NUMBER:REVISION:
REV DRAWING STATUS BY DATE
9732 PFLUMM ROAD, LENEXA, KS 66215 PHONE: [phone] FAX: [phone]
THIS DRAWING AND THE SOLUTIONS/DESIGNS ARE THE PROPERTY OF CAMCORP, INC. AND ARE FURNISHED ONLY FOR
INFORMATIONAL PURPOSES ON A CONFIDENTIAL BASIS. REPRODUCTION, PUBLISHING, OR OTHER DISCLOSURES ARE ON A
"NEED TO KNOW" BASIS ONLY. ANY OTHER REPRODUCTION REQUIRES WRITTEN AUTHORIZATION BY A CORPORATE OFFICER.
BRATNEY
RICHMOND, UT
5BH10x35 DUST COLLECTOR
04/23/24 K011073 1
411034 411034-1
ZRE
A MEMBER OF THE SCHEUCH GROUP
CAMCORP
PG NUMBER:
2
S
W
N
E
(FACTORY COMPASS)
59 1/2"65 1/2"
42 1/2"
48 1/2"
6"
6"
n7/8"
CAP INSPECTION DOOR
78 1/2"
113 1/4"
25 1/2"
3"
89 13/16"
72"
75"
4"4"
2"
n7/8"
144 7/16
q
EXP. VENT
"
1 FAN SUPPORT, MOVED EXP. VENT, ADDED HEIGHT ZRE 06/6/24
FOR CONSTRUCTION
SIGNATURE:
CAMCORP, INC.
CERTIFIED
06/18/24DATE:
PURPOSES
John Adkins
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
45° TYP.
0279.4 [011] OD
0139.7 [05.5] ID
TOP B-B
( 1 : 12)
)EAL.ANT D B
SEAlANT
_g 111
A A
FRONT RIGHT
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NOTES:
I. CONFIRM BLOW PIPES IN PLENUM
HAVE BLOW HOlES IN THEM, STRAIGHT DOWN
f;LTER
BIN VENT FILTER ASSY
BVC-16-84 W/QA
□--,--­□--,--­□------_/fl\' ___ _
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POINT CONtlECTION VOLTAGE CIJ.:i.REITT POWER Cl M150.SLEGLAN0 4-SMMOIA. HVOC 72W~tt
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NOTES:
1---D DIA. -------C B.C. -----,
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STANDARD FLANGES PROVIDED WITHOUT HOLES.
OPTIONS:
■ HOLES PROVIDED, ON VERTICAL CENTERLINE
(CFV STANDARD LOCATION)
□ HOLES PROVIDED, STRADDLING CENTERLINE
~ ~! Q,21!JonM90~,1 o!/~Q
TOLERANCES:
ANGLES: ± 1'
FRACTIONS ±
ALL DIMENSIONS IN INCHES
UNLESS OTHERWISE SPEClnED
SUPERSEDES:
Al 27062
(G) 7 /16 DIA. HOLES
(SEE NOTES) f P--N. f uw,f;i·C bEm\L
'A B C D E H G
I.D. O.D. B.C. DIA. DIA. QTY.
1 9 1+ 311 9 15 4 4f6 16 4f6 16
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1 13 _j_ 11 -3... 7-1.. s...5... 1 8 815 2 4 2 8
1 16 14-1 gli 9 1 8 1015 4 1 6 1015
TOLERANCES:
CAST DIMENSIONS (A, 8, D, E, H) ±3/32
MACHINED DIMENSIONS (C, FLANGE HOLE DIA.) ±1 /16
t I TITLE I A I DRAWING NO.
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REV.
6
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180 (7,087]
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01 ° ''~.:."~ 0 ro
CABLE GLANDS ARE
NICKEL PLATED CONSTRUCTION
A
( 1 : 1 )
NOTE 3: OFF-TIME
ADJUSTMENT
THIS DRAWING HAS AN ATEX DECLARATION
ASSOCIATED WITH IT
IT CANNOT BE ALTERED OR ITERATED
@
Gi' "' t:.
~
@
232 (9,134)
B
ENCLOSURE IS
ROSE 2523201100
@
@
0 1
,-----------7
,----------1 L __
ovoc (GRAY) L __ _
SOlENOID VALVE 1 {BLUE)
SOLENOID VALVE 2 {PURPLE)
SOLENOID VALVE 3 (RED)
SOLENOID VALVE 4 (PINK)
SOLENOID VALVE 5 (BROWN)
SOLENOID VALVE 6 (YELLOW)
SOLENOID VALVE 7 {BROWN/GRAY) 0
SOLENOID VALVE 8 {BLACK)
SOLENOID VALVE 9 {RED/BLUE)
SOLENOID VALVE 10 {BROWN/YELLOW)
+24V6c o~ob {GREEN) @ ~~~o,,s~~~G
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i
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CUSTOMER SUPPLIED
I
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NOTE 2: ON-TIME
ADJUSTMENT
NOTE 1: JUMPER
THIS DRAWING IS PART OF A ATEX TYPE
EXAMINATION. ANY CHANGE EXQUSIVELY
BY COPERION K-TRON SWITZERLAND.
WIRING DIAGRAM*
•DIAGRAM BASED ON A 10-WIRE CABLE USED ON
STANDARD ALTER RECEIVERS AND BIN VENTS.
WHEN USED FOR CONTROWNG MODUt.AR BIN VENTS,
All WIRING IS FIELD WIRED BY OJSTOMER
ENCLOSURE:
IP66, ATEX II 3D
DIE CAST ALUMINUM CONSTRUCTION
@ CHANG€ Of THIS CONSTRUCTION RECORD
ACCORDING K-TRON INSTRUCTION NO. 17.02-0001
AENDERUNGEN DES KONSTRUKTIONSDOKUMENT
GEMAESS K•TRON RICHTUNIE NR. 17.02·0001
NOTES:
1. JUMPER TO BE PLACED IN POSITION TO CORRESPOND
TO NUMBER OF SOLENOID VALVES CONTROLLING.
2. PRE-SET ON-TIME TO 200MSEC.
3. PRE-SET OFF· TIME TO 50 SEC.
4. DRILL BACK PLATE TO MATCH BOARD, INSTALL WITH STEEL RIVETS AND WASHERS.
PANEL
PANEL, FILTER TIMER CE ATEX 3D
"O F.,.~,,--;---,.--,b.,.;,~~.-, el
' I f<lill-lAT IU ~ R OIMEfl'SION SHOWN m MILLIMETERS [INCH <lJ
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~ cIncInnat1 ~Fan
Bratney
Silo Project
Phone: [phone]
ACFM SP
500 4.0 in. wg
Cold Start:
Qty Description
Proposal
Prepared On: 11/8/2023
Quotation #: 498929
Your Cincinnati Fan Representative:
Mark Monsen
North Monsen Company
252 Orchard Place
Salt Lake City, Utah 94101
Phone: [phone]
Fax: [phone]
Direct: 801-322-1343
Mobile: [phone]
[e-mail]
Quote valid through: 12/8/2023
Temp. Altitude Density Fan RPM BHP
100°F 4,800 ft. 0.0592 lb/ft3 3450 0.63
ASL
70°F Cold Start: 0.66
Unit Price Extended
Price
-
1 Cincinnati Fan PB-10A, Arrangement 4HM, 6" Inlet, CW Rotation, $1,073 $1,073
11 x 3 BC
MTR,3/4 HP ,2850/3450 RPM,3PH,50/60Hz, 190/380/50 & Included
230/460/60,TEFC, Std Eff,FM,56,IPSS, 1.15 SF,F lnsul.,40C
Amb.,Tropicalized for Storage. Shielded Bearings,F1 Box.Steel
frame,CSA,UL,VFD Capable 1000:1 VT, 3/4 HP & 1.00 SF@ 50
HZ., REPLACES .7536ES3EB56
Flanged Inlet-Drill on Centerlines Included
DischarQe Weather Hood with Bird Screen Included
Allow 10 working days to ship after receipt of order, or release to manufacturing. (Actual lead time
depends upon motor availability.) This order can be expedited for shipment within 5 days for an
additional CQS charge of 15%.
Approximate shipping weight (for complete fan as described above) is 71 pounds (each).
Net 30 Days. FOB Factory. Freight not included. Please issue PO to North-Monsen Co .. When
ordering, refer to the Quotation# at the top of this proposal.
Thank you,
Mark Monsen
Page 1
"' ~
t:.
0 ~ 0 C) ~
180 (7,087]
•••---rl ----~I
01 ° ''~.:."~ 0 ro
CABLE GLANDS ARE
NICKEL PLATED CONSTRUCTION
A
( 1 : 1 )
NOTE 3: OFF-TIME
ADJUSTMENT
THIS DRAWING HAS AN ATEX DECLARATION
ASSOCIATED WITH IT
IT CANNOT BE ALTERED OR ITERATED
@
Gi' "' t:.
~
@
232 (9,134)
B
ENCLOSURE IS
ROSE 2523201100
@
@
0 1
,-----------7
,----------1 L __
ovoc (GRAY) L __ _
SOlENOID VALVE 1 {BLUE)
SOLENOID VALVE 2 {PURPLE)
SOLENOID VALVE 3 (RED)
SOLENOID VALVE 4 (PINK)
SOLENOID VALVE 5 (BROWN)
SOLENOID VALVE 6 (YELLOW)
SOLENOID VALVE 7 {BROWN/GRAY) 0
SOLENOID VALVE 8 {BLACK)
SOLENOID VALVE 9 {RED/BLUE)
SOLENOID VALVE 10 {BROWN/YELLOW)
+24V6c o~ob {GREEN) @ ~~~o,,s~~~G
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i
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j I i ii I
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10
DIE CAST ALUMINUM CONSTRUCTION 3 AMP POWER
FIELD WIRED
CUSTOMER SUPPLIED
I
®
NOTE 2: ON-TIME
ADJUSTMENT
NOTE 1: JUMPER
THIS DRAWING IS PART OF A ATEX TYPE
EXAMINATION. ANY CHANGE EXQUSIVELY
BY COPERION K-TRON SWITZERLAND.
WIRING DIAGRAM*
•DIAGRAM BASED ON A 10-WIRE CABLE USED ON
STANDARD ALTER RECEIVERS AND BIN VENTS.
WHEN USED FOR CONTROWNG MODUt.AR BIN VENTS,
All WIRING IS FIELD WIRED BY OJSTOMER
ENCLOSURE:
IP66, ATEX II 3D
DIE CAST ALUMINUM CONSTRUCTION
@ CHANG€ Of THIS CONSTRUCTION RECORD
ACCORDING K-TRON INSTRUCTION NO. 17.02-0001
AENDERUNGEN DES KONSTRUKTIONSDOKUMENT
GEMAESS K•TRON RICHTUNIE NR. 17.02·0001
NOTES:
1. JUMPER TO BE PLACED IN POSITION TO CORRESPOND
TO NUMBER OF SOLENOID VALVES CONTROLLING.
2. PRE-SET ON-TIME TO 200MSEC.
3. PRE-SET OFF· TIME TO 50 SEC.
4. DRILL BACK PLATE TO MATCH BOARD, INSTALL WITH STEEL RIVETS AND WASHERS.
PANEL
PANEL, FILTER TIMER CE ATEX 3D
"O F.,.~,,--;---,.--,b.,.;,~~.-, el
' I f<lill-lAT IU ~ R OIMEfl'SION SHOWN m MILLIMETERS [INCH <lJ
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EMISSION UNIT SPECIFICATIONS
Utah Flour Milling LLC - Conventional / Organic Milling Operations
11595 N. US 91 HWY, Richmond, UT 84333
EU#EP#Emission Unit (EU)/ Description
in Permit SCC #Raw
Material
Actual Max.
Design Rate
(tons/hr)
Proposed
Limit (tpm)Exhaust Control Equipment Facility Control
Equipment ID Numbers Manufacturer Model Serial #Capture
Eff. %
Control
Eff. PM
%
Control
Eff. PM10
%
Control
Eff.
PM2.5 %
EU-01A EP-01 Grain Receiving (Truck)30200552 Wheat 200 20,000 Outdoors Baghouse (CE-01)FL-8070 Camcorp 10SWF112 TBD 0.5 0.001 0.01 0.02
EU-01B EP-01 Grain Receiving (Rail)30200552 Wheat 300 20,000 Outdoors Baghouse (CE-01)FL-8070 Camcorp 10SWF112 TBD 0.5 0.001 0.01 0.02
EU-02 EP-01 Grain Handling (legs, conveyors,
belts, etc)30200553 Wheat 300 20,000 Outdoors Baghouse (CE-01)FL-8070 Camcorp 10SWF112 TBD 1 0.001 0.01 0.02
EU-03 FS-03 Grain Storage (Bins)30200540 Wheat 300 20,000 Outdoors N/A N/A N/A N/A N/A 1 1 1 1
EU-04A EP-04A Grain Cleaning (Side A)30200733 Wheat 21.5 14,500 Outdoors
Cyclone (CE-04AA)
Cyclone (CE-04AB)
Cyclone (CE-04AC)
Baghouse (CE-04AD)
CY-3140
CY-3150
CY-3170
FL-3415
Omas FBP-112-3000 TBD 1 0.001 0.01 0.02
EU-05A EP-05A Grain Tempering (Side A)Listed as ND
in AP-42 Wheat 21.5 14,500 Outdoors Baghouse (CE-05A)FL-3395 Omas FBP33-3000 TBD 1 0.001 0.01 0.02
EU-06A EP-RV Grain Milling (Side A)30200734 Wheat 21.5 14,500 Indoors/
Outdoors
Cyclone (CE-06AA)
Parallel Baghouses
(CE-06AB)
CY-4290 (typical)
Parallel Baghouses
(FL-4091, 4110, 4595)
Omas FBP74-3000 TBD 1 0.001 0.01 0.02
EU-07A EP-07A Flour Storage Bins (Side A)30200560 Flour 20 14,500 Outdoors Bin Filer, Each Bin to one
EP (CE-07A)FL-5285 Wamgroup Round Filter Type
FN - A3 TBD 1 0.25 0.5 0.5
EU-08A EP-RV Flour Handling / Final Plansifters
(Side A)30200533 Flour 70 20,000 Indoors/
Outdoors
Baghouse (CE-08AA)
Baghouse (CE08AB)
FL-5410
FL-6035 Omas FBP-26-3000 TBD 1 0.001 0.01 0.02
EU-09 EP-09 Flour Bulk Loadout (Truck)30200560 Flour 30 5,000 Outdoors Dust Filter (CE-09)FL-6225 Camcorp 5BH10x35 TBD 1 0.25 0.5 0.5
EU-10 FS-10 Flour Bulk Loadout (Rail)30200563 Flour 30 5,000 Outdoors N/A - Dust Sock N/A N/A (Sock)N/A (Sock)TBD 1 0.25 0.5 0.5
EU-11 EP-11 Flour Packaging (Bags & Totes)30200560 Flour 30 5,000 Outdoors Dust Filter (CE-11)FL-TBD (Same as FL-6225)Camcorp 5BH10x35 TBD 1 0.25 0.5 0.5
EU-12 EP-12 Milling Byproduct, Hammer
Milling 30200817 Byproduct 1.5 1,450 Outdoors Filter (CE-12)FL-4935 schenck process 54ST64 Filter TBD 1 0.25 0.5 0.5
EU-13 EP-13 Feed Storage (Bins) Listed as ND
in AP-42 Feed 1.5 1,000 Outdoors Bin Filter (CE-13)FL-8025 Coperion K-
Tron BVC-16-84 W/QA TBD 1 0.25 0.5 0.5
EU-14 FS-14 Feed Loadout (Truck)30200803 Feed 40 1,000 Outdoors N/A N/A N/A N/A TBD 0.5 1 1 1
Notes:
1. The facility has some cyclones that could potentially be considered as emission reduction control equipment, which are included in this list; however, these cyclones are partially used for product transfers and determining the emission control
efficiency is difficult. Therefore, the cyclones identified at this facility are not considered to provide emission control for the purposes of the current emission calculations.
2. The facility is currently undergoing final design and some of this control equipment has not been constructed. Therefore, the serial numbers for the specific equipment will need to be identified. The Facility equipment numbers identified in this
table are the equipment numbers used in the plans for the facility. Once the equipment is constructed these numbers can be used to verify the model numbers and provide the associated serial numbers.
3. The facility is being contructed to allow for expansion in the future. Side A equipment will be installed initially with similiar Side B equipment being installed in the future to increase production. The Side B equipment would be included in the
future under a permit modification.
EMISSION CALCULATIONS
Utah Flour Milling LLC - Conventional / Organic Milling Operations
11595 N. US 91 HWY, Richmond, UT 84333
EU ID #EP ID#CE ID#Emission Unit (EU)SCC #
Raw
Material
Max.
Design
Rate
(tons/hr.)
Requested
Permit (tpm)Exhaust
Capt.
Eff.
Cont.
Eff. PM
Cont.
Eff.
PM10
Cont.
Eff.
PM2.5
Conv.
Factor
(lbs./ton)
Conv.
Factor
(hrs./yr.) PM EF PM10 EF PM2.5 EF PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5
EU-01A EP-01 CE-01 Grain Receiving (Truck)30200552 Wheat 200 20,000 Outdoors 0.5 0.001 0.01 0.02 2,000 8,760 0.0350 0.0078 0.0013 15.33 3.42 0.57 0.015 0.034 0.011 2.100 0.468 0.078 0.002 0.005 0.002
EU-01B EP-01 CE-01 Grain Receiving (Rail)30200552 Wheat 300 20,000 Outdoors 0.5 0.001 0.01 0.02 2,000 8,760 0.0320 0.0078 0.0013 21.02 5.12 0.85 0.021 0.051 0.017 1.920 0.468 0.078 0.002 0.005 0.002
EU-02 EP-01 CE-01 Grain Handling (legs, conveyors,
belts, etc.)30200553 Wheat 300 20,000 Outdoors 1 0.001 0.01 0.02 2,000 8,760 0.0610 0.0340 0.0058 80.15 44.68 7.62 0.080 0.447 0.152 7.320 4.080 0.696 0.007 0.041 0.014
EU-03 FS-03 N/A Grain Storage (Bins)30200540 Wheat 300 20,000 Outdoors 1 1 1 1 2,000 8,760 0.0250 0.0063 0.0011 32.85 8.28 1.45 32.850 8.278 1.445 - 0.756 0.132 3.000 0.756 0.132
EU-04A EP-04A
CE-04AA
CE-04AB
CE-04AC
CE-04AD
Grain Cleaning (Side A)30200733 Wheat 21.5 14,500 Outdoors 1 0.001 0.01 0.02 2,000 8,760 0.0480 0.0120 0.0020 4.52 1.13 0.19 0.005 0.011 0.004 4.176 1.044 0.174 0.004 0.010 0.003
EU-05A EP-05A CE-05A Grain Tempering (Side A) (7)Listed as ND in
AP-42 Wheat 21.5 14,500 Outdoors 1 0.001 0.01 0.02 2,000 8,760 0.0305 0.0170 0.0029 2.87 1.60 0.27 0.003 0.016 0.005 2.654 1.479 0.252 0.003 0.015 0.005
Outdoors (5)0.4 0.001 0.01 0.02 2,000 8,760 70.0000 35.0000 5.9500 2,636.76 1,318.38 224.12 2.637 13.184 4.482 2,436.000 1,218.000 207.060 2.436 12.180 4.141
Indoors (5)0.6 0.001 0.01 0.02 2,000 8,760 70.0000 35.0000 5.9500 3,955.14 1,977.57 336.19 3.955 19.776 6.724 3,654.000 1,827.000 310.590 3.654 18.270 6.212
EU-07A EP-07A CE-07A Flour Storage Bins (Side A)30200560 (1)Flour 20 14,500 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0125 0.0032 0.0006 1.10 0.28 0.05 0.274 0.140 0.026 1.088 0.278 0.052 0.272 0.139 0.026
Outdoors (5)0.4 0.001 0.01 0.02 2,000 8,760 0.0610 0.0340 0.0057 7.48 4.17 0.70 0.007 0.042 0.014 2.123 1.183 0.198 0.002 0.012 0.004
Indoors (5)0.6 0.001 0.01 0.02 2,000 8,760 0.0610 0.0340 0.0057 11.22 6.25 1.05 0.011 0.063 0.021 3.184 1.775 0.298 0.003 0.018 0.006
EU-09 EP-09 CE-09 Flour Bulk Loadout (Truck)30200560 (2)Flour 30 5,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0430 0.0145 0.0025 5.65 1.91 0.33 1.413 0.953 0.164 1.290 0.435 0.075 0.323 0.218 0.038
EU-10 FS-10 NA Flour Bulk Loadout (Rail)30200563 (3)Flour 30 5,000 Outdoors 0.5 1 1 1 2,000 8,760 0.0135 0.0011 0.0002 0.89 0.07 0.01 0.887 0.072 0.012 0.203 0.017 0.003 0.203 0.017 0.003
EU-11 EP-11 CE-11 Flour Packaging (Bags and Totes)30200560 (4)Flour 30 5,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0430 0.0145 0.0025 5.65 1.91 0.33 1.413 0.953 0.164 1.290 0.435 0.075 0.323 0.218 0.038
EU-12 EP-12 CE-12 Milling Byproduct, Hammer
Milling 30200817 Feed 1.5 1,450 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.3350 0.1680 0.0290 2.20 1.10 0.19 0.550 0.552 0.095 2.915 1.462 0.252 0.729 0.731 0.126
EU-13 EP-13 CE-13 Feed Storage (Bins)Listed as ND in
AP-42 (8)Feed 1.5 1,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0250 0.0060 0.0011 0.16 0.04 0.01 0.041 0.020 0.004 0.150 0.036 0.007 0.038 0.018 0.003
EU-14 FS-14 N/A Feed Loadout (Truck)30200803 Feed 40 1,000 Outdoors 0.5 1 1 1 2,000 8,760 0.0033 0.0008 0.0001 0.29 0.07 0.01 0.289 0.070 0.009 0.010 0.002 0.000 0.010 0.002 0.000
34.03 8.42 1.47 34.03 8.42 1.47 0.21 0.77 0.14 3.21 0.77 0.14
5,620.11 2,801.46 476.24 9.57 30.72 9.99 2,463.02 1,229.37 209.00 4.14 13.59 4.40
5,654.13 2,809.88 477.71 43.59 39.14 11.45 2,463.24 1,230.14 209.13 7.35 14.37 4.54
13,828.77 6,907.08 1,174.17 17.78 71.77 23.94 6,120.21 3,058.14 519.89 7.80 31.88 10.62
13,862.80 6,915.50 1,175.64 51.80 80.19 25.41 6,120.42 3,058.92 520.02 11.01 32.65 10.75
(1) 50% SCC for grain storage used since no SCC for flour storage and flour storage is cleaner
(4) 50% SCC for grain shipping by truck used since no SCC for flour packaging and flour packaging is cleaner and SCC for Flour Bulk Loading is Non-Detect
(5) The emission are vented to the interior of the building, which are circulated throughout the building with potential emissions directed through the building roof exhaust ventilation roof vents.
(6) SCC for grain handling used since no SCC for flour handling and flour handling is cleaner.
(8) SCC for grain storage used since Feed storage Listed as ND, but is assumed to be similar to grain storage.
tpm = tons per month
PTE Controlled (tpy) = [Max. Design Rate (tons/hr.) x Emission Factor (lb./ton) x 8760 hrs./yr. x Capture Efficiency x Control Efficiency / 2000 lbs./ton]
PTE Limited (tpy) = [Permit Limit (tons/mo.) x 12 mo./yr. x Emission Factor (lb./ton) x Capture Efficiency / 2000 lbs./ton]
PTE Controlled & Limited (tpy) = [Permit Limit (tons/mo.) x 12 mo./yr. x Emission Factor (lb./ton) x Capture Efficiency x Control Efficiency / 2000 lbs./ton]
Control Efficiencies are based on industry standard PM control percentages. Actual emissions would likely be lower.
Control Efficiencies for Baghouse: 99.9% PM, 99.0% PM10, 98% PM2.5 or 0.001 PM, 0.01 PM10, 0.02 PM2.5
Control Efficiencies for Filters: 75% PM, 50% PM10, 50% PM2.5 or 0.25 PM, 0.50 PM10, 0.50 PM2.5
Modeling Thresholds
PM10 Fugitive Emissions 5 tpy
PM10 Non Fugitive Emissions 15 tpy
PM2.5 Total Combined Emissions 10 tpy
All Totals
All Point Source (Indoor and
Outdoor Totals
Total Outdoor Emissions
Footnotes:
(3) 50% SCC for grain shipping by rail used since no SCC for flour shipping and flour shipping is cleaner and SCC for Flour Bulk Loading is Non-Detect
(2) 50% SCC for grain shipping by truck used since no SCC for flour shipping and flour shipping is cleaner and SCC for Flour Bulk Loading is Non-Detect
PTE (tpy) = Max. Design Rate (tons/hr.) x Emission Factor (lb./ton) x 8760 hrs./yr. x Capture Efficiency / 2000 lbs./ton
(7) Grain Tempering is listed as ND in AP-42, the PM emissions for grain tempering are estimated to be 50% of grain handling
PTE (tpy) Limited Controlled & Limited (tpy)
Fugitive Source Totals
Outdoor Point Source Totals
Emission Factors (lb./ton) from
AP-42 9.9.1-1 & 9.9.1-2 PTE (tpy) PTE (tpy) Controlled
21.5 14,500 EU-06A EP-RV CE-06AA
CE-06AB Grain Milling (Side A)30200734 Wheat
30200533 (6)Flour 70 14,500 EU-08A EP-RV CE-08AA
CE-08AB
Flour Handling / Final Plansifters
(Side A)
11117 Mockingbird Drive
Omaha, NE 68137
402.697.9747 | oneatlas.com
New Air Permit (NOI) / Utah Flour Milling LLC / 11595 N. US 91 HWY / Richmond, UT 84333
August 15, 2024 1

August 15, 2024

Jon Black or Alan Humphreys
Utah Dept. of Environmental Quality – Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84116

Submitted Via Email: [e-mail] & [e-mail]

SUBJECT: New Air Permit (NOI)
Utah Flour Milling LLC Facility
11595 N. US 91 HWY
Richmond, UT 84333

Dear Jon Black or Alan Humphreys:
Atlas Technical Consultants (Atlas) was retained by Utah Flour Milling LLC to complete the Air Permit review
and prepare the Notice of Intent (NOI) permit forms for a new wheat milling facility at 11595 North US 91
Highway Richmond, Utah. The document summarizes the facility activities and provides the applicable permit
forms as an attachment. The facility is subject to permitting requirements under Utah Administrative Code
R307-401.
FACILITY INFORMATION
The Utah Flour Milling LLC Facility is an entirely new facility that is in the process of building and construction
and final design stage of the equipment. The facility will intake raw wheat product from trucks or railcars and
process the wheat into flour. The facility will also generate wheat byproduct that will be utilized for animal feed.
Key features to the facility operations in relation to the air permit are summarized below. A Process Flow
Diagram is also included in the permit documents.
 The facility is initially being constructed with half of the milling equipment; therefore, initially the facility
will operate at approximately half the design capacity until the additional equipment is installed and
made operational. However, this permit includes flow rates that are based on the planned maximum
design flow rates.
 The facility will receive wheat by truck or rail at combined maximum design unloading rate of up to
300 tons per hour, or 10,000 bushels per hour based on wheat having a weight of 60 pounds per
bushel. This receiving will only need to be performed on an intermittent basis to maintain sufficient
grain capacity for the facility as the milling process will have a maximum combined processing rate of
46 tons/hour. The requested monthly receiving limits of 146,000 tons by truck and 219,000 tons by
rail are conservative values and would allow for higher intakes than the approximately 33,120 tons per
month that is required for the maximum 46 tons per hour milling process rate.
 The facility has grain bins that will store approximately 1,600,000 bushels of wheat, which would
equate to approximately 48,000 tons, based on an estimated 60 pounds per bushel. This total capacity
would be sufficient for the facility to operate for approximately 43 days at the maximum milling

New Air Permit (NOI) / Utah Flour Milling LLC Facility / 11595 N. US 91 HWY / Richmond, UT 84333
August 15, 2024 2

production capacity of 46 tons per hour. This storage capacity allows for volatilities in grain pricing and
availability.
 The facility milling equipment is the restricting production factor with a maximum grain processing
capacity of 46 tons per hour (92,000 pounds per hour); however, the actual throughput rate is
anticipated to be lower than this maximum rate or approximately 21 tons per hour. Therefore, the
facility has a requested limit for flour milling of 30,000 tons per month.
 The production process includes grain cleaning, milling, storage and product transfer activities. These
processes were broken down into distinctive processes, which were identified as specific Emission
Units (EUs) with associated Emission Control Equipment (CEs) and Emission Points (EPs) for
permitting purposes. For simplicity purposes, some of these EUs, CEs and EPs may include multiple
steps or multiple parallel pieces of similar equipment that perform a similar function. The included
permit calculation are based on the combined throughputs for similar equipment; therefore, details
regarding every piece of equipment that is included in the EU may not be included. The combined
details for the equipment and system layout are depicted on the process flow diagram and listed on
the Emission Calculation spreadsheet.
 The finished flour product will be temporarily stored at the facility for shipment by truck, rail, packaging
(bags and totes), or by a direct supply line to a neighboring facility (Cambell’s). The flour loadout can
occur directly from bins at 10 tons per hour, or through plansifters with flow rates of 30 tons per hour
each.
 The wheat by-product that is collected from various milling process stages at the facility is potentially
milled and then temporarily stored at the facility, which is then shipped out by truck for use as animal
feed.
NON ATTAINMENT AREA
The facility was identified by the US EPA to be located within the Logan, UT-Franklin, ID PM2.5 Nonattainment
Area, which would be subject to the permitting regulations under the Utah Administrative Code R307-403.
Based on these regulations, the facility is not classified as a new major stationary source as it emits less than
100 tons per year of criteria pollutants; however, it may be considered a significant emission increase since it
is close to the 15 and 10 tons per year threshold for PM10 and PM2.5 and is considered a major modification.
Per Section R307-403-5, the facility construction may require an emission offset. Atlas contacted the Utah
Department of Environmental Quality (UDEQ) for confirmation and potential applicable requirements. Per Alan
Humpherys with the UDEQ, the Logan nonattainment area was redesignated to Attainment in 2021. Based on
this redesignation, there are no offsetting requirements in the area of the facility and air permitting in this area
would only need to follow the general air permitting requirements of the Utah Administrative Code R307-401.
EMISSION FACTORS
The emission factors for the emission units were generally obtained from AP-42 9.9.1-1 and 9.9.1-2 using the
most applicable Source Classification Codes (SCC). Some of the emission units such as flour storage and
handling did not have applicable SCCs. In these cases, conservative emission factors were used that result
in higher calculated emissions. The SCC numbers and the justification for using adjusted emission factors are
detailed on the Emission Calculations Spreadsheet.

New Air Permit (NOI) / Utah Flour Milling LLC Facility / 11595 N. US 91 HWY / Richmond, UT 84333
August 15, 2024 3

Some of the EUs are configured in a way where other facility designs or layout would limit the potential
emissions that are emitted through the associated EP. In these cases, the resulting particulates would pass
through the process or would be cleaned up by general cleaning. For example, some emissions from
equipment are directed through baghouses and then discharged back to the interior of the building. The air
would be circulated through the building, which may be then directed to roof exhaust vents. Therefore, the
potential emissions for some equipment was reduced based this system.
CONTROL EQUIPMENT
The facility will use baghouses as Control Equipment (CE) in specific areas to reduce emissions from some of
the EUs. The air flow rates through the baghouses may vary; however, the facility will use similar baghouses
with the baghouse designed to handle the maximum flow rate. The baghouse control efficiencies of 99.9% for
PM, 99% for PM10 and, 98% for PM2.5 were used in the emission calculations; however, the control equipment
is anticipated to have higher control efficiencies. Manufacturer and design information for these baghouses is
included with the included permit documents.
The facility system will also use cyclones in specific areas that are primarily designed to assist in the movement
of the flour products in piping at the facility through aspiration. These types of cyclones have control efficiencies
of 88% for PM, 78% for PM10 and, 63% for PM2.5. These cyclones may provide some reduction in particulate
emissions. However, based on their variable usage, they have been generally excluded from inclusion as
emission control equipment in the emission calculations.
The flour and feed storage bins have bin vent filters and some of the unloading areas have dust filter vents
that will limit emissions. Since there may be some variability in the efficiencies of this equipment, conservative
control efficiencies of 75% for PM, 50% for PM10 and, 50% for PM2.5 were used in the emission calculations.
Manufacturer information for these filters is included with the permit documents. Additionally, it is anticipated
that some of this equipment will not run continuous during facility operations; therefore, the actual emissions
are expected to be lower than identified in the potential emission calculations.
The grain cleaning, milling, and flour handling operations have some air discharges that vent to the interior of
the building. Some of this air may be directed to the exterior by roof mounted exhaust fans; however, some
particulates will be retained within the building and will be removed by general cleaning or through other
means. Therefore, this system will further reduce facility emissions and these emissions have been divided
into outdoors and indoors on the emission calculations spreadsheet.
AIR EMISSION EVALUATION
Based on the calculated potential to emit from the facility equipment and operations and proposed limits, the
facility is required to have an operating permit. The facility emissions are associated with particulates that are
produced during the wheat handling and milling processes. The following potential emissions were calculated
and are included as an attachment.
 Potential To Emit (PTE) Emissions were calculated from established emission factors and equipment
design rates and based on continuous operation. These emission calculations do not consider reductions
in emissions due to control equipment or requested permit limits.

New Air Permit (NOI) / Utah Flour Milling LLC Facility / 11595 N. US 91 HWY / Richmond, UT 84333
August 15, 2024 4

 The PTE Controlled emission calculations result in a reduction of emissions since they include efficiencies
from control equipment.
 Some of the facility equipment does not operate continuously or at the maximum design rate. For example,
the grain receiving is not continuous to maintain facility operations. The PTE Limited emission calculations
provide a more realistic anticipated operational periods and result in a reduction of emissions due to
requested permit limits.
 The Controlled & Limited emission calculations take into account potential emission from both control
equipment and requested permit limits. These calculations are more consistent with the potential
emissions that would be expected from the facility.
 The Controlled & Limited emissions are generally higher than actual emissions for various reasons. The
control equipment has higher efficiencies than were used in the emission calculations and the facility
generally operates below the hours or flow rates used in the emission calculations. Atlas has prepared a
spreadsheet for this facility that they can use to input the actual product throughput, which will provide
more accurate information regarding actual emissions from the facility for a specific period.
FACILTY PERMIT PREPARATION
Based on the provided facility operations and equipment as previously summarized, Atlas has prepared the
attached applicable forms that have been signed by Utah Flour Milling LLC. In addition, the applicable payment
fees have been provided (https://deq.utah.gov/air-quality/fees-air-quality-permitting).
We appreciate the opportunity to provide this proposal for your project. If you have any questions or require
further information, please email [e-mail].
Sincerely,
ATLAS TECHNICAL CONSULTANTS

Scott Hanson, PE (IA, NE, KS, MO) Jack Batho IV
Project Engineer Staff Engineer

Facility Air Permit Application Attachments:

1 - Notice of Intent (NOI) Application (State Forms 1, 2, 3 & 5)
2 - Facility Vicinity Plan
3 - Facility Site Plan
4 - Facility Process Flow Diagram
5 - Facility Process Information (State Form 2)
6 - Facility Control Equipment, Fabric Filters, Baghouses (State Form 10)
7 - Facility Emission Unit Specifications
8 - Facility Emission Calculations

Notice of Intent (NOI) Application
Attachment 1
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 o
2. Company contact (Name, mailing address, and telephone number)o
3.Name and contact of person submitting NOI application (if different than 2)o
4.Source Universal Transverse Mercator (UTM) coordinates o
5. Source Standard Industrial Classification (SIC) code o
6.Area designation (attainment, maintenance, or nonattainment)o
7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)o
8.Source size determination (Major, Minor, PSD)o
9. Current Approval Order(s) and/or Title V Permit numbers o
NOI Application Information: [R307-401]
o
o
o
o
o
o
o
o
o
o
o N/A o
o N/A o
A.Air quality analysis (air model, met data, background data, source impact analysis) o N/A o
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced
3.Description of equipment used in the process and operating schedule4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)
B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.SignatureonApplication
o N/A o
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.
None
Minor
NO SDSs
None
40 CFR 60 Subpart DD
Grain Elevators
08/15/2024
Utah Flour Milling LLC
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2. Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact
information can be provided in a cover letter
3. Source name and physical address (if different from
above):
____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4. Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5. The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7. If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8. Brief (50 words or less) description of process.
Electronic NOI
9. A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
New Facility TBD
08/15/2024
PHM Brands
730 17th Street, Suite 600
Denver, Colorado
[phone]
Kirk Arens
[phone]
[e-mail]
Utah Flour Milling LLC
11595 N. US 91 HWY
Richmond, UT 84333
Cache
12
432435.12
4643740.09
2041
NA
The facility is a new wheat milling facility, which will take in and store raw wheat for processing into
flour. The facility will process the wheat at a maximum flow rate of 46 tons per hour. Produced flour will
be shipped off site by truck, rail, packaging, or to an adjacent facility. Wheat byproduct generated
during the milling will be shipped off the site as animal feed.
Director of EHS
Kirk Arens [phone]
[e-mail]
Page 1 of 1
Form 3 Company____________________
Process Information Site________________________
Utah Division of Air Quality
New Source Review Section
Process Information-ForNewPermitONLY
1.Name of process:2.End product of this process:
3.Process Description*:
Operating Data
4.Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year
5.Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall _______
6.Maximum Hourly production (indicate units.):
_____________
7.Maximum annual production (indicate units):
________________
8.Type of operation:
Continuous Batch Intermittent
9.If batch, indicate minutes per cycle ________
Minutes between cycles ________
10. Materials and quantities used in process.*
Material Maximum Annual Quantity (indicate units)
11.Process-Emitting Units with pollution control equipment*
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If additional space is required, please create a spreadsheet or Word processing document and attach to form.
tons per hour tons per year
tons per year
Note: The milling process is continuous; however, the intake and outputs may be intermittent.
Utah Flour Milling LLC
11595 N. US 91 HWY - Richmond
Wheat Mill Wheat Flour with feed
byproduct
The facility is a new wheat milling facility, which will take in and store raw wheat
for processing into flour. The facility will mill the wheat at a maximum flow rate
of 46 tons per hour; however, actual processing rate is anticipated to be lower.
Flour will be transported off site by truck, rail, packaging, or to a neighboring
facility. Wheat byproduct generated during the milling process will be shipped
off the site as animal feed.
8
7
52
25%
25%
25%
25%
46 402,960
Raw Wheat 402,960.00
See attached documents
Page 1 of 1
Company___________________________
Site_____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
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
NA new facility
Total
Additional details and calculations are included on attached documents.
The Controlled & Limited values on the calculation spreadsheet meet
* The Controlled & Limited values on the attached spreadsheet are consistent with the potential to emit definition R307-401-2.
Utah Flour Milling LLC
11595 N. US 91 HWY - Richmond
59.07 59.07
8.41 8.41
18.23 18.23
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
None
Facility Vicinity Plan
Attachment 2
Parcel Boundary
Existing Railroad Line
Proposed Railroad
Line Spurs
Truck and Rail Unloading
WarehouseMill Building
Flour Line to Plant
E 11600 N (Two Lane, Pavement)
Hig
h
w
a
y

9
1

(
F
o
u
r

L
a
n
e
,

P
a
v
e
m
e
n
t
)
Single Family Residential
11611 N Highway 91
Single Family Residnetial
11646 N Highway 91
Ag/Storage Buildings
Non Residential
1027 E 1160 N
Single Family Residential
1080 N 200 W
Non Residential
930 N Highway 91
Non Residential
93901 N 200 W

N
0 250125
Facility Site Plan
Attachment 3
Parcel Boundary
Flour Line to Adjoining Campbell's Factory
E 11600 N (Two Lane, Pavement)
Grain Receiving, Rail (EU-01B)
Flour Bulk Loadout, Rail (EU-10)
Grain Receiving, Truck (EU-01A)
Grain Handling, Legs, conveyors, belt, etc. (EU-02)
Grain Storage, Bins (EU-03)
Grain Storage, Bin Vents (FS-03)
Grain Receiving and Handling (EP-01)
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Grain Bin
Future Warehouse
Grain Tempering Bins (EU-05A, EU-05B)
Flour Storage Bins (EU-07A, EU-07B)
Flour Handling / Plansifters (EU-08A, EU-08B)
Feed Storage, Bins (EU-13)
Feed Storage, Bins (EP-13)
Main Plant Building
Flour Loadout, Rail (EP-10)
Flour Packaging,
Bags and Totes
(EU-11)
Flour Packaging
(EP-11)
Grain Tempering (EP-05A, EP-05B)
Milling Byproduct, Hammer Milling (EP-12)
Existing Railroad Line
Proposed Railroad
Spur Lines
Pavement Drive
Flour Storage Bin Vents (EP-07A, EP-07B)
Grain Cleaning (EU-04A, EU-04B)
Grain Cleaning (EP-04A, EP-04B)
Grain Milling (EU-06A, EU-06B)
Various Roof Vents
Grain Milling (EP--RV)
Flour Handling / Plansifters (EP-RV)
Flour Loadout, Truck (EU-09)
Flour Loadout, Truck (EP-09)
Milling Byproduct, Hammer Milling (EU-12)
Feed Loadout (EU-14)
Feed Loadout (FS-14)
Warehouse Office

N
0 7035
Facility Process Flow Diagram
Attachment 4
PROCESS FLOW DIAGRAM
Utah Flour Milling LLC Facility – Conventional/Organic Milling Operations
Grain Receiving, Storage, Cleaning, and Milling
11595 N. US 91 HWY, Richmond, UT 84333
8/15/2024

Grain Receiving, Truck
EU-01A
(200) ton/hr

Grain Receiving, Rail
EU-01B
(300) ton/hr
Grain Storage, Bins
EU-03
(300) ton/hr

Grain Handling, Conveyors
EU-02
(300) ton/hr
Baghouse
CE-01
FL-8070

Stack Near receiving ~(12’)
EP-01
FN-8074

A: Grain Cleaning
EU-04A
(23) ton/hr

Various Roof Vents (90’)
FS-03 (Fugitive)
FN-8074

Baghouse
CE-04AD
FL-3415

Cyclones (parallel)
CE-04AA, CE-04AB, CE-04AC
CY-3140, CY- 3150, CY-3170

Stack Above roof (90’)
EP-04A
FN-3420

A: Grain Tempering
EU-05A
(23) ton/hr

A: Grain Milling Process
EU-06A
(23) ton/hr

Baghouse
CE-05A
FL-3395

Stack Above roof (90’)
EP-05A
FN-3400

Cyclones, Various (parallel)
CE-06AA
CY-4290-4315, 4758

Baghouses, (parallel)
CE-06AB
FL-4091, 4110, 4595

A: Flour Storage Bins
EU-07A
(20) ton/hr
Bin Filter (each bin)
CE-07A
FL-5285 (typical)

Stack Above Roof (90’)
EP-07A
FN-5350

Building Interior
To Roof Vents
EP-RV

Feed Storage Bin
EU-13
1.5 ton/hr
Bin Filter
CE-13
FL-8025

Feed Loadout
EU-14
40 ton/hr.
Stack Above Roof (90’)
EP-13
FL-TBD

By-Product Hammer Mill
EU-12
1.5 ton/hr
Truck Loadout (~12’)
FS-14 (Fugitive)
EQ-8050

Product Flow
Air Flow
Milling Byproduct
Emission Unit (EU)
Control Equipment (CE)
Emission Point (EP)
Notes (See Below)

(3)
Notes:
(1) (Maximum Processing Flow Rates) ton/hr.
(2) FL-##, CY-##, FN-## are references to the facility identified numbers for specific equipment.
(3) The facility milling operations to final flour storage bins are divided into two separate parallel systems that can operate independently and are designated as A
and B. The side B emission details are not shown for simplicity, but will be a mirror image of side A with different equipment identification numbers.
(4) The flour loadout system include multiple product lines that allow for transfers from various flour storage bins to the four loadout locations to occur
simultaneously through Plansifter A, Plansifter B, or directly from the bins with smaller plansifers (at a reduced flow). The loadout system for side B is not shown
for simplicity; however, side B will be identical to Side A with the only significant difference being different equipment identification numbers.
(5) Milling byproduct may milled for use as feed or be directed to the feed storage bin for usage as animal feed.
Total Grain Storage Capacity
1,600,000 bushels
Wheat – 60 pounds/bushel
B: Grain Cleaning
EU-04B
(23) ton/hr

B: Grain Tempering
EU-05B
(23) ton/hr

B: Grain Milling Process
EU-06B
(23) ton/hr

B: Flour Storage Bins
EU-07B
(20) ton/hr
(#)
(1)
(2) (2)
(3)
(3)
(3)
To Loadout B To Loadout A
A: Plansifter A (EQ-5430)
EU-08AA
(30) ton/hr
Baghouse
CE-08AA
FL-5410

Building Interior
To Roof Vents
EP-RV

Flour Loadout, Truck
EU-09
(30) ton/hr

Flour Loadout, Rail
EU-10
(30) ton/hr

Flour Loadout, Packaging
EU-11
(30) ton/hr

To Adjoining Cambell’s
Facility, No Emissions
(30) ton/hr
A: Plansifter B (EQ-6060)
EU-08AB
(30) ton/hr

Baghouse
CE-08AB
FL-6035

Building Interior
To Roof Vents
EP-RV

Dust Filter
CE-09
FL-6225

Stack ~20’ Above Ground
EP-09
FN-6230

Top of Truck ~12’
FS-10

Dust Filter
CE-11
FL-TBD

Stack ~20’ Above Ground
EP-11
FN-TBD

Loadout A (a) Loadout A (c) (Direct From Bins)
(4)
(a) (c) (b)
Loadout A (b)
Loadout A (c) (Direct From Bins)
Loadout A (c) (Direct From Bins)
Loadout A (c) (Direct From Bins)
(5)
Exterior Wall (43’)
EP-12
FN-TBD

Filter
CE-12
FL-4935

Facility Process Information (State Form 2)
Attachment 5

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.

Utah Division of Air Quality Company____________________________
New Source Review Section Site/Source__________________________
Date____________________
Form 2
Process Information

Process Data
1. Name of process:

2. End product of this process:

3. Primary process equipment: _______________ Manufacturer:__________________________________
Make or model: _________________________ Identification #: ________________________________
Capacity of equipment (lbs/hr): Year installed:__________________________________
Rated _____________ Max.____________
(Add additional sheets as needed)

4. Method of exhaust ventilation:
□ Stack □ Window fan □ Roof vent □ Other, describe _______________________

Are there multiple exhausts: □ Yes □ No
Operating Data

5. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year

6. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall ________

7. Hourly production rates (lbs.):

Average ________ Maximum ________

8. Maximum annual production (indicate units):
__________________
Projected percent annual increase in production:
__________________

9. Type of operation: □ Continuous
□ Batch
□ Intermittent

10. If batch, indicate minutes per cycle ________
Minutes between cycles ________

11. Materials used in process
Raw Materials Principal Use Amounts
(Specify Units)

Page 1 of 3
Page 2 of 3

Process
Form 2 (Continued)

12. Control equipment (attach additional pages if necessary)
Item

Primary Collector

Secondary Collector
a. Type

b. Manufacturer

c. Model

d. Year installed

e. Serial or ID#

f. Pollutant controlled

g. Controlled pollutant emission
rate (if known)

h. Pressure drop across control
device

i. Design efficiency

j. Operating efficiency

Stack Data
(attach additional pages if necessary)
13. Stack identification: 14. Height: Above roof ________ft
Above ground ________ft

15. Are other sources vented to this stack:
□ Yes □ No

If yes, identify sources:

16. □ Round, top inside diameter dimension
_________
□ Rectangular, top inside dimensions
length ________ x width ________

17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min

18. Continuous monitoring equipment: □ yes □ no
If yes, indicate: Type ____________________ Manufacturer _________________________________

Make or Model ____________ Pollutant(s) monitored __________________________
Emissions Calculations (PTE)

19. Calculated emissions for this device
PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr
NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr
CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr
CO2 ___________ Tons/yr CH4 _____________ Tons/yr
N2O ____________Tons/yr
HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
Baghouses (State Form 10)
Facility Control Equipment, Fabric, Filters,
Attachment 6
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
CAMCORP, INC.
15729 College Blvd  Lenexa, Kansas 66219  Phone [phone] Fax [phone]  www.camcorpinc.com

CAMCORP EMISSION STATEMENT
Bratney - 410838
CAMCORP Model: 10SWF112
Application: Nuisance Collection
Flowrate: 10,000 ACFM @ 70° F.
Air-To-Media Ratio: 7.4 to 1
CAMCORP Inc. warrants the performance of its Baghouse with 16 oz. Polyester Filter Bags, when operated per the design parameters
referenced in the original proposal and in accordance with the manufacturer’s operations manuals, to emit dry particulate matter
greater than 2 microns in size at no more than .01 gr/dscf of air.
The warranty is subject to the following conditions:
• The equipment will be installed, operated and maintained according to generally accepted and approved engineering and
construction standards and in accordance with CAMCORP Installation, Operation and Maintenance instructions. Buyer must
maintain adequate records to allow verification of such operation and maintenance.
• Owner will perform black light testing before systems operation to ensure no dust leakage through the baghouse. If leakage
occurs, CAMCORP will determine the cause of such failure. The results will determine the recommended course of corrective
actions. If bag material or workmanship is found to be the cause of the non-compliance, CAMCORP will replace bags in question
at no charge, or make compensation to the end-user in the amount of CAMCORP cost of the bags to be replaced on a one-for-
one basis. If the non-compliance is determined to be damage to the media as a result of improper handling or installation of
the bags by the installer, replacement costs are to be responsibility of the Owner.
• Tests to determine compliance with CAMCORP’s particulate emissions warranty shall be performed in accordance with EPA
(Environmental Protection Agency) Test Method No. 5. A qualified independent test company shall perform testing. The test
shall be conducted within 45 days of start-up, and once normal operating conditions are achieved.
• Buyer shall select an independent testing company to perform the required test but such selection shall be subject to
CAMCORP’s approval. Buyer shall be responsible for all testing company fees, charges and expenses.
• CAMCORP will be notified at least (2) weeks prior to any testing, may inspect the baghouse prior to testing, has the right to be
present during testing, and will be provided with a full copy of all tests including raw data and calculations.
• At all times prior to and during testing, all specified operating conditions must be strictly adhered to.
• If the warranted .01 gr/dscf is not attained on the first test, CAMCORP Inc. will be given a maximum of 60 days with which to
bring the equipment into conformity.
• Owner will provide, on request, applicable maintenance and operation records of actual operating conditions.
• Upon satisfaction of the emissions warranty, CAMCORP shall have no further liability to Buyer under this warranty.

David Barber
Application Engineering Manager
CAMCORP Inc.
11/14/2023
PRODUCT DATA SHEET Issue 1
ANTISTATIC POLYESTER NEEDLEFELT
AREA WEIGHT EN 12127 g/m²10,4 oz/yd²DENSITY 0,35 g/cm³
THICKNESS EN ISO 9073/2 mm 0,039 in PORE VOLUME 75 %
FIBER POLYESTER
COMPOSITION
SCRIM POLYESTER/INOX
FINISH
LONGITUDINAL CROSS
TENSILE STRENGTH (5 cm)EN 29073-3 ≥900 N 198 lbs/2" ≥700 N 154 lbs/2"
ELONGATION EN 29073-3 ≤30 %≤50 %
ELONGATION at 50 N EN 29073-3 ≤N.A.%≤N.A.%
THERMAL STABILITY (SHRINKAGE)UNI 8279/12 ≤2 %≤1 %
air at 150°C - 2 h
BURST STRENGTH ISO 13938 ≥N.A.kPa ≥N.A.psi
AIR PERMEABILITY EN ISO 9237
at 200 Pa l/dm² • min
cfm @ 1/2" H 2O
EFFICIENCY FACTOR
SURFACE RESISTIVITY 10 4 ohm (DIN 54345/1-5)
FIBER PROPERTIES:ANTISTATIC POLYESTER
OPERATING TEMPERATURE (Dry) CONTINUOUS 150°C Max 302 °F Max
PEAKS 160°C Max 320 °F Max
CHEMICAL RESISTANCE
STRONG ACIDS STRONG ALKALIS SOLVENTS 
WEAK ACIDS WEAK ALKALIS OXIDIZING 
HYDROLYSIS 
LEGEND: Excellent Good Fair Poor
Testori S.p.A. Largo A. Testori n. 5 - 20026 Novate Milanese (MI - Italy)Printed date
Tel. [phone] - Fax [phone] - www.testori.it - mail: [e-mail]
20/04/22
TW 350 SA
41,00
STYLE
350
20/04/22
PRELIMINARY
All data and characteristics are not binding and may vary depending on the constant improvements that Testori Spa reserves itself to introduce.
Please contact Testori Spa before using these data for technical specification definition.
HEAT SET - SURFACE GLAZING
1,0
200
“DuPont™, the DuPont Oval Logo, and all trademarks and service marks denoted with ™, SM or ® are owned by affiliates of DuPont de Nemours, Inc. unless otherwise
noted. © 2019 DuPont.”
#RIF!
1
10
100
1000
10000
1 10 100 1000 10000
Air permeabilityPa
l
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
1
2
3
7

1
3
6
6

1
6
2
6

2
6
0

6
7
,
5
0

AA
1353
1
2
0
9

1088
1038
10
1063
SEZIONE A-A
N. HOLES 30

270
8
332 FN-B.4.J.16.S_1.+.F.1.1_PP.+_1.+.6.+.+_R.+.++_B
FILTRO TONDO TIPO FN - -ROUND FILTER TYPE FN - -
Wamgroup®
1 2
1 2 3
A
B
C
D
E
F
C
D
F
87654
Sigla modulare:Key code:
Data/Drw Date:Disegnatore/Drawn by:
Questo documento e le informazioni in esso contenute sono di proprietà di Wamgroup S.p.a., hanno natura riservata e non possono essere trasmesse a terzi senza autorizzazione scritta di Wamgroup S.p.a.
This document and contained informations belongs to Wamgroup S.p.a. and are confidential it must not be comunicated to other people without written authorization from Wamgroup S.p.a.
Scala:Scale:
A3Formato:Size:
DENOMINAZIONE/DENOMINATION:
Disegno/Drawing N°:Peso/Weight:Kg
WAMGROUP S.p.a. Via Cavour 33841032 Ponte MottaCavezzo (MO) ITALYTel. ++39/0535/618111Fax ++39/0535/618226
1:30
8
B
A
76453
E
D
Disegno di Controllo InterfacciaInterface Control Drawing
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
SOUTH ELEVATION
EAST ELEVATION
DISCHARGE FLANGE
3/8" PLATE
EXHAUST FLANGE
1/4" PLATE
INLET FLANGE
PURCHASED
DATE:
JOB NUMBER:
CUSTOMER:
DRAWN:
TITLE:
DRAWING NUMBER:
P.O. NUMBER:REVISION:
REV DRAWING STATUS BY DATE
9732 PFLUMM ROAD, LENEXA, KS 66215 PHONE: [phone] FAX: [phone]
THIS DRAWING AND THE SOLUTIONS/DESIGNS ARE THE PROPERTY OF CAMCORP, INC. AND ARE FURNISHED ONLY FOR
INFORMATIONAL PURPOSES ON A CONFIDENTIAL BASIS. REPRODUCTION, PUBLISHING, OR OTHER DISCLOSURES ARE ON A
"NEED TO KNOW" BASIS ONLY. ANY OTHER REPRODUCTION REQUIRES WRITTEN AUTHORIZATION BY A CORPORATE OFFICER.
BRATNEY
RICHMOND, UT
5BH10x35 DUST COLLECTOR
04/23/24 K011073 1
411034 411034-1
ZRE
A MEMBER OF THE SCHEUCH GROUP
CAMCORP
PG NUMBER:
1
1 FAN SUPPORT, MOVED EXP. VENT, ADDED HEIGHT ZRE 06/6/24
(1) UNIT REQUIRED
TAG #: FL-6225.00
S
W
N
E
(FACTORY COMPASS)
q
HOPPER ACCESS
DOOR/INLET/
q
EXHAUST
18" EXHAUST
(SEE DETAIL)
INTERIOR CAP PAINT:
EXTERIOR CAP PAINT:
INTERIOR DAP PAINT:
EXTERIOR DAP PAINT:
LADDER/PLATFORM PAINT:
SUPPORT STRUCTURE PAINT:
INTERIOR CAP WELDS:
EXTERIOR CAP WELDS:
INTERIOR DAP WELDS:
EXTERIOR DAP WELDS:
SPECIAL NOTES:
MATERIAL FINISHES
CAP WALLS:
ROOF:
DAP WALLS:
TUBE SHEET:
STIFFENERS:
GAS CONTACT:WALKING SURFACE:
HOPPER:
MATERIAL OF CONSTRUCTION
SUPPORT:CROSS BRACING:
PLATORM:LADDER:
APPLICATION SPECIFICATIONS
PRODUCT:
OPERATING TEMP:
AIR VOLUME:
AIR TO MEDIA RATIO:
APPLICATION:
CAN VELOCITY:
SQ. FT. CLOTH AREA:
DESIGN RATING:
CONTROL POWER:
INTERSTITIAL VELOCITY:
MOTOR POWER:
LOADING:
ALTITUDE:
COMPRESSED AIR:SCFM:
WEIGHT:MFG: COMPONENT: TOTAL:
47 7/8"
123"
24"
2
4
3
(35) TUBE SHEET HOLES
SAFETY GATE
1" NPT COMPRESSED AIR
CONNECTION EACH END,
FACTORY PLUG (1) END
6, 7
1/8" NPT
DP PORTS
(4) LIFTING LUGS
BOLTED LADDER & CAGE
ASSEMBLY - SHIPPED LOOSE
80"
1/4" DRAIN PLUG
20" X 60"
HINGED & CLAMPED
ACCESS DOOR,
HINGED ON LEFT
12" O.D. RADIAL INLET
W/ INTERNAL BAFFLE
(SEE DETAIL)
10" X 10" DISCHARGE
ITEM QTY.DESCRIPTION
1B
2
3
4
5
6
1A
7
35
35
5
5
1
1
1
50'
6" DIA. X 120" LG., #11 GA, GALV., (12) WIRE
1" DIA. TURBO DIAPHRAGM VALVES - NYLON TUBING
1/8" DIA. TURBO SOLENOID VALVES, NEMA 4 ENCLOSURE, HEATED T-STAT
5" x 5" x 1/4" SQ. TUBE COMPRESSED AIR HEADER - CARBON STEEL
NCC, 10-POSITION TIMER, NEMA 4 ENCLOSURE, SHIPPED LOOSE
DP KIT W/ DWYER MAGNEHELIC GUAGE, MOUNT BRACKET, SHIPPED LOOSE
1/4" NYLON TUBING & NECESSARY FITTINGS
6" DIA. X 120" LG., 16 OZ. POLYESTER FILTER BAGS
DUST COLLECTOR
FLOUR
3125 ACFM
5.58 TO 1
70 °F
155 FPM
90-100 PSIG
110 V
NUISANCE
-20" W.C.
560 SQ. FT
4610'
236 FPM
16-20 CFM
7.5HP
3538 LBS
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
CARBON STEEL
4" X 4" X 1/4" ANGLE CARBON STEEL
CARBON STEEL
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
3" X 2" X 1/4" ANGLE CARBON STEEL - 24" SPACING
#4 EXP. METAL
2" X 2" X 1/4" ANGLE CARBON STEEL
CARBON STEEL
NONE
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
NONE
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
TWO PART EPOXY PRIMED & PAINTED YELLOW ACROLON 218 HS, SSPC-SP6
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
STITCH WELDED
SPECIAL NOTES
CONTINUOUS - NOT GROUND
STITCH WELDED
CONTINUOUS - NOT GROUND
8"
1A, 1B
1384 LBS
15 1/4" SQ.
10"
4922 LBS
12 3/4"
n15 3/16"
n12 3/16"
n7/16(8) " HOLES
ON A 14" B.C.
STRADDLING CL's
n22 1/4"
n18 1/4"
n7/16(8) " HOLES
ON A 19 5/8" B.C.
STRADDLING CL's
7/8"
4 1/2"
2 1/4"
n7/16(12) "
HOLES
52" - REF
46" - UNIT
146 1/4"
REF
78"
SHIPPING
63"
UNIT
311 3/16"
9 1/4"
28 1/4"
36 1/2"
66"
8 1 SWSI SIZE 16 PLR FAN ARR. 4V, 7.5 HP
10 1 ACS MODEL CI 10x10 AIRLOCK
10
9 1 36x36 DOMED EXP. VENT
118 5/8
(3979 FPM)
INLET q
"
EXPLOSION VENT SIZING IS BASED ON AN UN-DUCTED INSTALLATION;
Kst = bar-m/s, Pmax = barg, Pstat = psig, Pred = psig.
P(RED) DOES NOT EXCEED TWO-THIRDS OF THE ULTIMATE STRENGTH FOR THE VENTED ENCLOSURE.
87 8.3 1.5 2.0
68 3/4"
9
q
EXP. VENT
8 1/4"
FOR CONSTRUCTION
SIGNATURE:
CAMCORP, INC.
CERTIFIED
06/18/24DATE:
PURPOSES
John Adkins
NORTH ELEVATION WEST ELEVATION
DETAIL A
UNIT FOOTPAD
SCALE 1/2" = 1'-0"
DETAIL B
LADDER FOOTPAD
SCALE 1/2" = 1'-0"
A
B
DATE:
JOB NUMBER:
CUSTOMER:
DRAWN:
TITLE:
DRAWING NUMBER:
P.O. NUMBER:REVISION:
REV DRAWING STATUS BY DATE
9732 PFLUMM ROAD, LENEXA, KS 66215 PHONE: [phone] FAX: [phone]
THIS DRAWING AND THE SOLUTIONS/DESIGNS ARE THE PROPERTY OF CAMCORP, INC. AND ARE FURNISHED ONLY FOR
INFORMATIONAL PURPOSES ON A CONFIDENTIAL BASIS. REPRODUCTION, PUBLISHING, OR OTHER DISCLOSURES ARE ON A
"NEED TO KNOW" BASIS ONLY. ANY OTHER REPRODUCTION REQUIRES WRITTEN AUTHORIZATION BY A CORPORATE OFFICER.
BRATNEY
RICHMOND, UT
5BH10x35 DUST COLLECTOR
04/23/24 K011073 1
411034 411034-1
ZRE
A MEMBER OF THE SCHEUCH GROUP
CAMCORP
PG NUMBER:
2
S
W
N
E
(FACTORY COMPASS)
59 1/2"65 1/2"
42 1/2"
48 1/2"
6"
6"
n7/8"
CAP INSPECTION DOOR
78 1/2"
113 1/4"
25 1/2"
3"
89 13/16"
72"
75"
4"4"
2"
n7/8"
144 7/16
q
EXP. VENT
"
1 FAN SUPPORT, MOVED EXP. VENT, ADDED HEIGHT ZRE 06/6/24
FOR CONSTRUCTION
SIGNATURE:
CAMCORP, INC.
CERTIFIED
06/18/24DATE:
PURPOSES
John Adkins
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
SOUTH ELEVATION
EAST ELEVATION
DISCHARGE FLANGE
3/8" PLATE
EXHAUST FLANGE
1/4" PLATE
INLET FLANGE
PURCHASED
DATE:
JOB NUMBER:
CUSTOMER:
DRAWN:
TITLE:
DRAWING NUMBER:
P.O. NUMBER:REVISION:
REV DRAWING STATUS BY DATE
9732 PFLUMM ROAD, LENEXA, KS 66215 PHONE: [phone] FAX: [phone]
THIS DRAWING AND THE SOLUTIONS/DESIGNS ARE THE PROPERTY OF CAMCORP, INC. AND ARE FURNISHED ONLY FOR
INFORMATIONAL PURPOSES ON A CONFIDENTIAL BASIS. REPRODUCTION, PUBLISHING, OR OTHER DISCLOSURES ARE ON A
"NEED TO KNOW" BASIS ONLY. ANY OTHER REPRODUCTION REQUIRES WRITTEN AUTHORIZATION BY A CORPORATE OFFICER.
BRATNEY
RICHMOND, UT
5BH10x35 DUST COLLECTOR
04/23/24 K011073 1
411034 411034-1
ZRE
A MEMBER OF THE SCHEUCH GROUP
CAMCORP
PG NUMBER:
1
1 FAN SUPPORT, MOVED EXP. VENT, ADDED HEIGHT ZRE 06/6/24
(1) UNIT REQUIRED
TAG #: FL-6225.00
S
W
N
E
(FACTORY COMPASS)
q
HOPPER ACCESS
DOOR/INLET/
q
EXHAUST
18" EXHAUST
(SEE DETAIL)
INTERIOR CAP PAINT:
EXTERIOR CAP PAINT:
INTERIOR DAP PAINT:
EXTERIOR DAP PAINT:
LADDER/PLATFORM PAINT:
SUPPORT STRUCTURE PAINT:
INTERIOR CAP WELDS:
EXTERIOR CAP WELDS:
INTERIOR DAP WELDS:
EXTERIOR DAP WELDS:
SPECIAL NOTES:
MATERIAL FINISHES
CAP WALLS:
ROOF:
DAP WALLS:
TUBE SHEET:
STIFFENERS:
GAS CONTACT:WALKING SURFACE:
HOPPER:
MATERIAL OF CONSTRUCTION
SUPPORT:CROSS BRACING:
PLATORM:LADDER:
APPLICATION SPECIFICATIONS
PRODUCT:
OPERATING TEMP:
AIR VOLUME:
AIR TO MEDIA RATIO:
APPLICATION:
CAN VELOCITY:
SQ. FT. CLOTH AREA:
DESIGN RATING:
CONTROL POWER:
INTERSTITIAL VELOCITY:
MOTOR POWER:
LOADING:
ALTITUDE:
COMPRESSED AIR:SCFM:
WEIGHT:MFG: COMPONENT: TOTAL:
47 7/8"
123"
24"
2
4
3
(35) TUBE SHEET HOLES
SAFETY GATE
1" NPT COMPRESSED AIR
CONNECTION EACH END,
FACTORY PLUG (1) END
6, 7
1/8" NPT
DP PORTS
(4) LIFTING LUGS
BOLTED LADDER & CAGE
ASSEMBLY - SHIPPED LOOSE
80"
1/4" DRAIN PLUG
20" X 60"
HINGED & CLAMPED
ACCESS DOOR,
HINGED ON LEFT
12" O.D. RADIAL INLET
W/ INTERNAL BAFFLE
(SEE DETAIL)
10" X 10" DISCHARGE
ITEM QTY.DESCRIPTION
1B
2
3
4
5
6
1A
7
35
35
5
5
1
1
1
50'
6" DIA. X 120" LG., #11 GA, GALV., (12) WIRE
1" DIA. TURBO DIAPHRAGM VALVES - NYLON TUBING
1/8" DIA. TURBO SOLENOID VALVES, NEMA 4 ENCLOSURE, HEATED T-STAT
5" x 5" x 1/4" SQ. TUBE COMPRESSED AIR HEADER - CARBON STEEL
NCC, 10-POSITION TIMER, NEMA 4 ENCLOSURE, SHIPPED LOOSE
DP KIT W/ DWYER MAGNEHELIC GUAGE, MOUNT BRACKET, SHIPPED LOOSE
1/4" NYLON TUBING & NECESSARY FITTINGS
6" DIA. X 120" LG., 16 OZ. POLYESTER FILTER BAGS
DUST COLLECTOR
FLOUR
3125 ACFM
5.58 TO 1
70 °F
155 FPM
90-100 PSIG
110 V
NUISANCE
-20" W.C.
560 SQ. FT
4610'
236 FPM
16-20 CFM
7.5HP
3538 LBS
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
CARBON STEEL
4" X 4" X 1/4" ANGLE CARBON STEEL
CARBON STEEL
#12 Ga. CARBON STEEL
#12 Ga. CARBON STEEL
3" X 2" X 1/4" ANGLE CARBON STEEL - 24" SPACING
#4 EXP. METAL
2" X 2" X 1/4" ANGLE CARBON STEEL
CARBON STEEL
NONE
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
NONE
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
TWO PART EPOXY PRIMED & PAINTED YELLOW ACROLON 218 HS, SSPC-SP6
TWO PART EPOXY PRIMED & PAINTED WHITE ACROLON 218 HS, SSPC-SP6
STITCH WELDED
SPECIAL NOTES
CONTINUOUS - NOT GROUND
STITCH WELDED
CONTINUOUS - NOT GROUND
8"
1A, 1B
1384 LBS
15 1/4" SQ.
10"
4922 LBS
12 3/4"
n15 3/16"
n12 3/16"
n7/16(8) " HOLES
ON A 14" B.C.
STRADDLING CL's
n22 1/4"
n18 1/4"
n7/16(8) " HOLES
ON A 19 5/8" B.C.
STRADDLING CL's
7/8"
4 1/2"
2 1/4"
n7/16(12) "
HOLES
52" - REF
46" - UNIT
146 1/4"
REF
78"
SHIPPING
63"
UNIT
311 3/16"
9 1/4"
28 1/4"
36 1/2"
66"
8 1 SWSI SIZE 16 PLR FAN ARR. 4V, 7.5 HP
10 1 ACS MODEL CI 10x10 AIRLOCK
10
9 1 36x36 DOMED EXP. VENT
118 5/8
(3979 FPM)
INLET q
"
EXPLOSION VENT SIZING IS BASED ON AN UN-DUCTED INSTALLATION;
Kst = bar-m/s, Pmax = barg, Pstat = psig, Pred = psig.
P(RED) DOES NOT EXCEED TWO-THIRDS OF THE ULTIMATE STRENGTH FOR THE VENTED ENCLOSURE.
87 8.3 1.5 2.0
68 3/4"
9
q
EXP. VENT
8 1/4"
FOR CONSTRUCTION
SIGNATURE:
CAMCORP, INC.
CERTIFIED
06/18/24DATE:
PURPOSES
John Adkins
NORTH ELEVATION WEST ELEVATION
DETAIL A
UNIT FOOTPAD
SCALE 1/2" = 1'-0"
DETAIL B
LADDER FOOTPAD
SCALE 1/2" = 1'-0"
A
B
DATE:
JOB NUMBER:
CUSTOMER:
DRAWN:
TITLE:
DRAWING NUMBER:
P.O. NUMBER:REVISION:
REV DRAWING STATUS BY DATE
9732 PFLUMM ROAD, LENEXA, KS 66215 PHONE: [phone] FAX: [phone]
THIS DRAWING AND THE SOLUTIONS/DESIGNS ARE THE PROPERTY OF CAMCORP, INC. AND ARE FURNISHED ONLY FOR
INFORMATIONAL PURPOSES ON A CONFIDENTIAL BASIS. REPRODUCTION, PUBLISHING, OR OTHER DISCLOSURES ARE ON A
"NEED TO KNOW" BASIS ONLY. ANY OTHER REPRODUCTION REQUIRES WRITTEN AUTHORIZATION BY A CORPORATE OFFICER.
BRATNEY
RICHMOND, UT
5BH10x35 DUST COLLECTOR
04/23/24 K011073 1
411034 411034-1
ZRE
A MEMBER OF THE SCHEUCH GROUP
CAMCORP
PG NUMBER:
2
S
W
N
E
(FACTORY COMPASS)
59 1/2"65 1/2"
42 1/2"
48 1/2"
6"
6"
n7/8"
CAP INSPECTION DOOR
78 1/2"
113 1/4"
25 1/2"
3"
89 13/16"
72"
75"
4"4"
2"
n7/8"
144 7/16
q
EXP. VENT
"
1 FAN SUPPORT, MOVED EXP. VENT, ADDED HEIGHT ZRE 06/6/24
FOR CONSTRUCTION
SIGNATURE:
CAMCORP, INC.
CERTIFIED
06/18/24DATE:
PURPOSES
John Adkins
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
45° TYP.
0279.4 [011] OD
0139.7 [05.5] ID
TOP B-B
( 1 : 12)
)EAL.ANT D B
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_g 111
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NOTES:
I. CONFIRM BLOW PIPES IN PLENUM
HAVE BLOW HOlES IN THEM, STRAIGHT DOWN
f;LTER
BIN VENT FILTER ASSY
BVC-16-84 W/QA
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STANDARD FLANGES PROVIDED WITHOUT HOLES.
OPTIONS:
■ HOLES PROVIDED, ON VERTICAL CENTERLINE
(CFV STANDARD LOCATION)
□ HOLES PROVIDED, STRADDLING CENTERLINE
~ ~! Q,21!JonM90~,1 o!/~Q
TOLERANCES:
ANGLES: ± 1'
FRACTIONS ±
ALL DIMENSIONS IN INCHES
UNLESS OTHERWISE SPEClnED
SUPERSEDES:
Al 27062
(G) 7 /16 DIA. HOLES
(SEE NOTES) f P--N. f uw,f;i·C bEm\L
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1 13 _j_ 11 -3... 7-1.. s...5... 1 8 815 2 4 2 8
1 16 14-1 gli 9 1 8 1015 4 1 6 1015
TOLERANCES:
CAST DIMENSIONS (A, 8, D, E, H) ±3/32
MACHINED DIMENSIONS (C, FLANGE HOLE DIA.) ±1 /16
t I TITLE I A I DRAWING NO.
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REV.
6
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CABLE GLANDS ARE
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A
( 1 : 1 )
NOTE 3: OFF-TIME
ADJUSTMENT
THIS DRAWING HAS AN ATEX DECLARATION
ASSOCIATED WITH IT
IT CANNOT BE ALTERED OR ITERATED
@
Gi' "' t:.
~
@
232 (9,134)
B
ENCLOSURE IS
ROSE 2523201100
@
@
0 1
,-----------7
,----------1 L __
ovoc (GRAY) L __ _
SOlENOID VALVE 1 {BLUE)
SOLENOID VALVE 2 {PURPLE)
SOLENOID VALVE 3 (RED)
SOLENOID VALVE 4 (PINK)
SOLENOID VALVE 5 (BROWN)
SOLENOID VALVE 6 (YELLOW)
SOLENOID VALVE 7 {BROWN/GRAY) 0
SOLENOID VALVE 8 {BLACK)
SOLENOID VALVE 9 {RED/BLUE)
SOLENOID VALVE 10 {BROWN/YELLOW)
+24V6c o~ob {GREEN) @ ~~~o,,s~~~G
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CUSTOMER SUPPLIED
I
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NOTE 2: ON-TIME
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NOTE 1: JUMPER
THIS DRAWING IS PART OF A ATEX TYPE
EXAMINATION. ANY CHANGE EXQUSIVELY
BY COPERION K-TRON SWITZERLAND.
WIRING DIAGRAM*
•DIAGRAM BASED ON A 10-WIRE CABLE USED ON
STANDARD ALTER RECEIVERS AND BIN VENTS.
WHEN USED FOR CONTROWNG MODUt.AR BIN VENTS,
All WIRING IS FIELD WIRED BY OJSTOMER
ENCLOSURE:
IP66, ATEX II 3D
DIE CAST ALUMINUM CONSTRUCTION
@ CHANG€ Of THIS CONSTRUCTION RECORD
ACCORDING K-TRON INSTRUCTION NO. 17.02-0001
AENDERUNGEN DES KONSTRUKTIONSDOKUMENT
GEMAESS K•TRON RICHTUNIE NR. 17.02·0001
NOTES:
1. JUMPER TO BE PLACED IN POSITION TO CORRESPOND
TO NUMBER OF SOLENOID VALVES CONTROLLING.
2. PRE-SET ON-TIME TO 200MSEC.
3. PRE-SET OFF· TIME TO 50 SEC.
4. DRILL BACK PLATE TO MATCH BOARD, INSTALL WITH STEEL RIVETS AND WASHERS.
PANEL
PANEL, FILTER TIMER CE ATEX 3D
"O F.,.~,,--;---,.--,b.,.;,~~.-, el
' I f<lill-lAT IU ~ R OIMEfl'SION SHOWN m MILLIMETERS [INCH <lJ
@[J2)@lfu@[n) ,uR1GHTSRESE,veoo 2019 c a:;
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~ cIncInnat1 ~Fan
Bratney
Silo Project
Phone: [phone]
ACFM SP
500 4.0 in. wg
Cold Start:
Qty Description
Proposal
Prepared On: 11/8/2023
Quotation #: 498929
Your Cincinnati Fan Representative:
Mark Monsen
North Monsen Company
252 Orchard Place
Salt Lake City, Utah 94101
Phone: [phone]
Fax: [phone]
Direct: 801-322-1343
Mobile: [phone]
[e-mail]
Quote valid through: 12/8/2023
Temp. Altitude Density Fan RPM BHP
100°F 4,800 ft. 0.0592 lb/ft3 3450 0.63
ASL
70°F Cold Start: 0.66
Unit Price Extended
Price
-
1 Cincinnati Fan PB-10A, Arrangement 4HM, 6" Inlet, CW Rotation, $1,073 $1,073
11 x 3 BC
MTR,3/4 HP ,2850/3450 RPM,3PH,50/60Hz, 190/380/50 & Included
230/460/60,TEFC, Std Eff,FM,56,IPSS, 1.15 SF,F lnsul.,40C
Amb.,Tropicalized for Storage. Shielded Bearings,F1 Box.Steel
frame,CSA,UL,VFD Capable 1000:1 VT, 3/4 HP & 1.00 SF@ 50
HZ., REPLACES .7536ES3EB56
Flanged Inlet-Drill on Centerlines Included
DischarQe Weather Hood with Bird Screen Included
Allow 10 working days to ship after receipt of order, or release to manufacturing. (Actual lead time
depends upon motor availability.) This order can be expedited for shipment within 5 days for an
additional CQS charge of 15%.
Approximate shipping weight (for complete fan as described above) is 71 pounds (each).
Net 30 Days. FOB Factory. Freight not included. Please issue PO to North-Monsen Co .. When
ordering, refer to the Quotation# at the top of this proposal.
Thank you,
Mark Monsen
Page 1
"' ~
t:.
0 ~ 0 C) ~
180 (7,087]
•••---rl ----~I
01 ° ''~.:."~ 0 ro
CABLE GLANDS ARE
NICKEL PLATED CONSTRUCTION
A
( 1 : 1 )
NOTE 3: OFF-TIME
ADJUSTMENT
THIS DRAWING HAS AN ATEX DECLARATION
ASSOCIATED WITH IT
IT CANNOT BE ALTERED OR ITERATED
@
Gi' "' t:.
~
@
232 (9,134)
B
ENCLOSURE IS
ROSE 2523201100
@
@
0 1
,-----------7
,----------1 L __
ovoc (GRAY) L __ _
SOlENOID VALVE 1 {BLUE)
SOLENOID VALVE 2 {PURPLE)
SOLENOID VALVE 3 (RED)
SOLENOID VALVE 4 (PINK)
SOLENOID VALVE 5 (BROWN)
SOLENOID VALVE 6 (YELLOW)
SOLENOID VALVE 7 {BROWN/GRAY) 0
SOLENOID VALVE 8 {BLACK)
SOLENOID VALVE 9 {RED/BLUE)
SOLENOID VALVE 10 {BROWN/YELLOW)
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DIE CAST ALUMINUM CONSTRUCTION 3 AMP POWER
FIELD WIRED
CUSTOMER SUPPLIED
I
®
NOTE 2: ON-TIME
ADJUSTMENT
NOTE 1: JUMPER
THIS DRAWING IS PART OF A ATEX TYPE
EXAMINATION. ANY CHANGE EXQUSIVELY
BY COPERION K-TRON SWITZERLAND.
WIRING DIAGRAM*
•DIAGRAM BASED ON A 10-WIRE CABLE USED ON
STANDARD ALTER RECEIVERS AND BIN VENTS.
WHEN USED FOR CONTROWNG MODUt.AR BIN VENTS,
All WIRING IS FIELD WIRED BY OJSTOMER
ENCLOSURE:
IP66, ATEX II 3D
DIE CAST ALUMINUM CONSTRUCTION
@ CHANG€ Of THIS CONSTRUCTION RECORD
ACCORDING K-TRON INSTRUCTION NO. 17.02-0001
AENDERUNGEN DES KONSTRUKTIONSDOKUMENT
GEMAESS K•TRON RICHTUNIE NR. 17.02·0001
NOTES:
1. JUMPER TO BE PLACED IN POSITION TO CORRESPOND
TO NUMBER OF SOLENOID VALVES CONTROLLING.
2. PRE-SET ON-TIME TO 200MSEC.
3. PRE-SET OFF· TIME TO 50 SEC.
4. DRILL BACK PLATE TO MATCH BOARD, INSTALL WITH STEEL RIVETS AND WASHERS.
PANEL
PANEL, FILTER TIMER CE ATEX 3D
"O F.,.~,,--;---,.--,b.,.;,~~.-, el
' I f<lill-lAT IU ~ R OIMEfl'SION SHOWN m MILLIMETERS [INCH <lJ
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Facility Emission Unit Specifications
Attachment 7
EMISSION UNIT SPECIFICATIONS
Utah Flour Milling LLC - Conventional / Organic Milling Operations
11595 N. US 91 HWY, Richmond, UT 84333
EU#EP#Emission Unit (EU)/ Description
in Permit SCC #Raw
Material
Actual Max.
Design Rate
(tons/hr)
Proposed
Limit (tpm)Exhaust Control Equipment Facility Control
Equipment ID Numbers Manufacturer Model Serial #Capture
Eff. %
Control
Eff. PM
%
Control
Eff. PM10
%
Control
Eff.
PM2.5 %
EU-01A EP-01 Grain Receiving (Truck)30200552 Wheat 200 150,000 Outdoors Baghouse (CE-01)FL-8070 Camcorp 10SWF112 TBD 0.5 0.001 0.01 0.02
EU-01B EP-01 Grain Receiving (Rail)30200552 Wheat 300 328,500 Outdoors Baghouse (CE-01)FL-8070 Camcorp 10SWF112 TBD 0.5 0.001 0.01 0.02
EU-02 EP-01 Grain Handling (legs, conveyors,
belts, etc)30200553 Wheat 300 328,500 Outdoors Baghouse (CE-01)FL-8070 Camcorp 10SWF112 TBD 1 0.001 0.01 0.02
EU-03 FS-03 Grain Storage (Bins)30200540 Wheat 300 328,500 Outdoors N/A N/A N/A N/A N/A 1 1 1 1
EU-04A EP-04A Grain Cleaning (Side A)30200733 Wheat 23 15,000 Outdoors
Cyclone (CE-04AA)
Cyclone (CE-04AB)
Cyclone (CE-04AC)
Baghouse (CE-04AD)
CY-3140
CY-3150
CY-3170
FL-3415
Omas FBP-112-3000 TBD 1 0.001 0.01 0.02
EU-04B EP-04B Grain Cleaning (Side B)30200733 Wheat 23 15,000 Outdoors
Cyclone (CE-04BA)
Cyclone (CE-04BB)
Cyclone (CE-04BC)
Baghouse (CE-04BD)
TBD - Similar to Side A TBD - Similar to
Side A
TBD - Similar to
Side A TBD 1 0.001 0.01 0.02
EU-05A EP-05A Grain Tempering (Side A)Listed as ND
in AP-42 Wheat 23 15,000 Outdoors Baghouse (CE-05A)FL-3395 Omas FBP33-3000 TBD 1 0.001 0.01 0.02
EU-05B EP-05B Grain Tempering (Side B)Listed as ND
in AP-42 Wheat 23 15,000 Outdoors Baghouse (CE-05B)TBD - Similar to Side A TBD - Similar to
Side A
TBD - Similar to
Side A TBD 1 0.001 0.01 0.02
EU-06A EP-RV Grain Milling (Side A)30200734 Wheat 23 15,000 Indoors/
Outdoors
Cyclone (CE-06AA)
Parallel Baghouses
(CE-06AB)
CY-4290 (typical)
Parallel Baghouses
(FL-4091, 4110, 4595)
Omas FBP74-3000 TBD 0.25 0.001 0.01 0.02
EU-06B EP-RV Grain Milling (Side B)30200734 Wheat 23 15,000 Indoors/
Outdoors
Cyclone (CE-06BA)
Parallel Baghouses
(CE-06BB)
TBD - Similar to Side A TBD - Similar to
Side A
TBD - Similar to
Side A TBD 0.25 0.001 0.01 0.02
EU-07A EP-07A Flour Storage Bins (Side A)30200560 Flour 20 14,500 Outdoors Bin Filer, Each Bin to one
EP (CE-07A)FL-5285 Wamgroup Round Filter Type
FN - A3 TBD 1 0.25 0.5 0.5
EU-07B EP-07B Flour Storage Bins (Side B)30200560 Flour 20 14,500 Outdoors Bin Filer, Each Bin to one
EP (CE-07B)TBD - Similar to Side A TBD - Similar to
Side A
TBD - Similar to
Side A TBD 1 0.25 0.5 0.5
EU-08A EP-RV Flour Handling / Final Plansifters
(Side A)30200533 Flour 70 20,000 Indoors/
Outdoors
Baghouse (CE-08AA)
Baghouse (CE08AB)
FL-5410
FL-6035 Omas FBP-26-3000 TBD 0.25 0.001 0.01 0.02
EU-08B EP-RV Flour Handling / Final Plansifters
(Side B)30200533 Flour 70 20,000 Indoors/
Outdoors
Baghouse (CE-08BA)
Baghouse (CE08BB)TBD - Similar to Side A TBD - Similar to
Side A
TBD - Similar to
Side A TBD 0.25 0.001 0.01 0.02
EU-09 EP-09 Flour Bulk Loadout (Truck)30200560 Flour 30 20,000 Outdoors Dust Filter (CE-09)FL-6225 Camcorp 5BH10x35 TBD 1 0.25 0.5 0.5
EU-10 FS-10 Flour Bulk Loadout (Rail)30200563 Flour 30 20,000 Outdoors N/A - Dust Sock N/A N/A (Sock)N/A (Sock)TBD 1 0.25 0.5 0.5
EU-11 EP-11 Flour Packaging (Bags & Totes)30200560 Flour 30 20,000 Outdoors Dust Filter (CE-11)FL-TBD (Same as FL-6225)Camcorp 5BH10x35 TBD 1 0.25 0.5 0.5
EU-12 EP-12 Milling Byproduct, Hammer
Milling 30200817 Byproduct 1.5 1,450 Outdoors Filter (CE-12)FL-4935 schenck process 54ST64 Filter TBD 1 0.25 0.5 0.5
EU-13 EP-13 Feed Storage (Bins) Listed as ND
in AP-42 Feed 1.5 1,450 Outdoors Bin Filter (CE-13)FL-8025 Coperion K-
Tron BVC-16-84 W/QA TBD 1 0.25 0.5 0.5
EU-14 FS-14 Feed Loadout (Truck)30200803 Feed 40 29,000 Outdoors N/A N/A N/A N/A TBD 1 1 1 1
Notes:
1. The facility has some cyclones that could potentially be considered as emission reduction control equipment, which are included in this list; however, these cyclones are partially used for product transfers and may provide limited emission control.
Therefore, the cyclones identified at this facility are not considered to provide emission control for calculation purposes.
2. The facility is currently undergoing final design and some of this control equipment has not been constructed. Therefore, the serial numbers for the specific equipment will need to be identified. The Facility equipment numbers identified in this
table are the equipment numbers used in the plans for the facility. Once the equipment is constructed these numbers can be used to verify the model numbers and provide the associated serial numbers.
3. The facility building will consist of two separate areas. The plans are being developed for Side A, and once constructed Side B will be constructed as a mirror image of Side B. Therefore, the Equipment ID numbers have not been determined
for Side B; however, this equipment will be nearly identical to Side A with different equipment identification numbers and serial numbers that will be determined at a later date.
Facility Emissions Calculations
Attachment 8
EMISSION CALCULATIONS
Utah Flour Milling LLC - Conventional / Organic Milling Operations
11595 N. US 91 HWY, Richmond, UT 84333
EU ID #EP ID#CE ID#Emission Unit (EU)SCC #
Raw
Material
Max.
Design
Rate
(tons/hr.)
Requested
Permit (tpm)Exhaust
Capt.
Eff.
Cont.
Eff. PM
Cont.
Eff.
PM10
Cont.
Eff.
PM2.5
Conv.
Factor
(lbs./ton)
Conv.
Factor
(hrs./yr.) PM EF PM10 EF PM2.5 EF PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5
EU-01A EP-01 CE-01 Grain Receiving (Truck)30200552 Wheat 200 146,000 Outdoors 0.5 0.001 0.01 0.02 2,000 8,760 0.0350 0.0078 0.0013 15.33 3.42 0.57 0.015 0.034 0.011 15.330 3.416 0.569 0.015 0.034 0.011
EU-01B EP-01 CE-01 Grain Receiving (Rail)30200552 Wheat 300 219,000 Outdoors 0.5 0.001 0.01 0.02 2,000 8,760 0.0320 0.0078 0.0013 21.02 5.12 0.85 0.021 0.051 0.017 21.024 5.125 0.854 0.021 0.051 0.017
EU-02 EP-01 CE-01 Grain Handling (legs, conveyors,
belts, etc.)30200553 Wheat 300 219,000 Outdoors 1 0.001 0.01 0.02 2,000 8,760 0.0610 0.0340 0.0058 80.15 44.68 7.62 0.080 0.447 0.152 80.154 44.676 7.621 0.080 0.447 0.152
EU-03 FS-03 N/A Grain Storage (Bins)30200540 Wheat 300 219,000 Outdoors 1 1 1 1 2,000 8,760 0.0250 0.0063 0.0011 32.85 8.28 1.45 32.850 8.278 1.445 - 8.278 1.445 32.850 8.278 1.445
EU-04A EP-04A
CE-04AA
CE-04AB
CE-04AC
CE-04AD
Grain Cleaning (Side A)30200733 Wheat 23 15,000 Outdoors 1 0.001 0.01 0.02 2,000 8,760 0.0480 0.0120 0.0020 4.84 1.21 0.20 0.005 0.012 0.004 4.320 1.080 0.180 0.004 0.011 0.004
EU-04B EP-04B
CE-04BA
CE-04BB
CE-04BC
CE-04BD
Grain Cleaning (Side B)30200733 Wheat 23 15,000 Outdoors 1 0.001 0.01 0.02 2,000 8,760 0.0480 0.0120 0.0020 4.84 1.21 0.20 0.005 0.012 0.004 4.320 1.080 0.180 0.004 0.011 0.004
EU-05A EP-05A CE-05A Grain Tempering (Side A) (7)Listed as ND in
AP-42 Wheat 23 15,000 Outdoors 1 0.001 0.01 0.02 2,000 8,760 0.0305 0.0170 0.0029 3.07 1.71 0.29 0.003 0.017 0.006 2.745 1.530 0.261 0.003 0.015 0.005
EU-05B EP-05B CE-05B Grain Tempering (Side B) (7)Listed as ND in
AP-42 Wheat 23 15,000 Outdoors 1 0.001 0.01 0.02 2,000 8,760 0.0305 0.0170 0.0029 3.07 1.71 0.29 0.003 0.017 0.006 2.745 1.530 0.261 0.003 0.015 0.005
Outdoors (5)0.75 0.001 0.01 0.02 2,000 8,760 70.0000 35.0000 5.9500 5,288.85 2,644.43 449.55 5.289 26.444 8.991 4,725.000 2,362.500 401.625 4.725 23.625 8.033
Indoors (5)0.25 0.001 0.01 0.02 2,000 8,760 70.0000 35.0000 5.9500 1,762.95 881.48 149.85 1.763 8.815 2.997 1,575.000 787.500 133.875 1.575 7.875 2.678
Outdoors (5)0.75 0.001 0.01 0.02 2,000 8,760 70.0000 35.0000 5.9500 5,288.85 2,644.43 449.55 5.289 26.444 8.991 4,725.000 2,362.500 401.625 4.725 23.625 8.033
Indoors (5)0.25 0.001 0.01 0.02 2,000 8,760 70.0000 35.0000 5.9500 1,762.95 881.48 149.85 1.763 8.815 2.997 1,575.000 787.500 133.875 1.575 7.875 2.678
EU-07A EP-07A CE-07A Flour Storage Bins (Side A)30200560 (1)Flour 20 14,500 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0125 0.0032 0.0006 1.10 0.28 0.05 0.274 0.140 0.026 1.088 0.278 0.052 0.272 0.139 0.026
EU-07B EP-07B CE-07B Flour Storage Bins (Side B)30200560 (1)Flour 20 14,500 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0125 0.0032 0.0006 1.10 0.28 0.05 0.274 0.140 0.026 1.088 0.278 0.052 0.272 0.139 0.026
Outdoors (5)0.75 0.001 0.01 0.02 2,000 8,760 0.0610 0.0340 0.0057 14.03 7.82 1.31 0.014 0.078 0.026 3.980 2.219 0.372 0.004 0.022 0.007
Indoors (5)0.25 0.001 0.01 0.02 2,000 8,760 0.0610 0.0340 0.0057 4.68 2.61 0.44 0.005 0.026 0.009 1.327 0.740 0.124 0.001 0.007 0.002
Outdoors (5)0.75 0.001 0.01 0.02 2,000 8,760 0.0610 0.0340 0.0057 14.03 7.82 1.31 0.014 0.078 0.026 3.980 2.219 0.372 0.004 0.022 0.007
Indoors (5)0.25 0.001 0.01 0.02 2,000 8,760 0.0610 0.0340 0.0057 4.68 2.61 0.44 0.005 0.026 0.009 1.327 0.740 0.124 0.001 0.007 0.002
EU-09 EP-09 CE-09 Flour Bulk Loadout (Truck)30200560 (2)Flour 30 20,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0430 0.0145 0.0025 5.65 1.91 0.33 1.413 0.953 0.164 5.160 1.740 0.300 1.290 0.870 0.150
EU-10 FS-10 NA Flour Bulk Loadout (Rail)30200563 (3)Flour 30 20,000 Outdoors 0.5 1 1 1 2,000 8,760 0.0135 0.0011 0.0002 0.89 0.07 0.01 0.887 0.072 0.012 0.810 0.066 0.011 0.810 0.066 0.011
EU-11 EP-11 CE-11 Flour Packaging (Bags and Totes)30200560 (4)Flour 30 20,000 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0430 0.0145 0.0025 5.65 1.91 0.33 1.413 0.953 0.164 5.160 1.740 0.300 1.290 0.870 0.150
EU-12 EP-12 CE-12 Milling Byproduct, Hammer
Milling 30200817 Feed 1.5 1,450 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.3350 0.1680 0.0290 2.20 1.10 0.19 0.550 0.552 0.095 2.915 1.462 0.252 0.729 0.731 0.126
EU-13 EP-13 CE-13 Feed Storage (Bins)Listed as ND in
AP-42 (8)Feed 1.5 1,450 Outdoors 1 0.25 0.5 0.5 2,000 8,760 0.0250 0.0060 0.0011 0.16 0.04 0.01 0.041 0.020 0.004 0.218 0.052 0.010 0.054 0.026 0.005
EU-14 FS-14 N/A Feed Loadout (Truck)30200803 Feed 40 29,000 Outdoors 0.5 1 1 1 2,000 8,760 0.0033 0.0008 0.0001 0.29 0.07 0.01 0.289 0.070 0.009 0.287 0.070 0.009 0.287 0.070 0.009
34.03 8.42 1.47 34.03 8.42 1.47 1.10 8.41 1.47 33.95 8.41 1.47
10,753.93 5,369.06 912.72 14.70 56.39 18.72 9,604.23 4,793.42 814.89 13.50 50.65 16.76
10,787.96 5,377.48 914.18 48.73 64.81 20.18 9,605.32 4,801.84 816.35 47.44 59.07 18.23
14,289.18 7,137.22 1,213.29 18.24 74.07 24.73 12,756.88 6,369.90 1,082.88 16.65 66.42 22.12
14,323.21 7,145.64 1,214.76 52.26 82.49 26.19 12,757.98 6,378.32 1,084.35 50.60 74.83 23.59
(1) 50% SCC for grain storage used since no SCC for flour storage and flour storage is cleaner
(4) 50% SCC for grain shipping by truck used since no SCC for flour packaging and flour packaging is cleaner and SCC for Flour Bulk Loading is Non-Detect
(5) The emission are vented to the interior of the building, which are circulated throughout the building with potential emissions directed through the building roof exhaust ventilation roof vents.
(6) SCC for grain handling used since no SCC for flour handling and flour handling is cleaner.
(8) SCC for grain storage used since Feed storage Listed as ND, but is assumed to be similar to grain storage.
tpm = tons per month
PTE Controlled (tpy) = [Max. Design Rate (tons/hr.) x Emission Factor (lb./ton) x 8760 hrs./yr. x Capture Efficiency x Control Efficiency / 2000 lbs./ton]
PTE Limited (tpy) = [Permit Limit (tons/mo.) x 12 mo./yr. x Emission Factor (lb./ton) x Capture Efficiency / 2000 lbs./ton]
PTE Controlled & Limited (tpy) = [Permit Limit (tons/mo.) x 12 mo./yr. x Emission Factor (lb./ton) x Capture Efficiency x Control Efficiency / 2000 lbs./ton]
Control Efficiencies are based on industry standard PM control percentages. Actual emissions would likely be lower.
Control Efficiencies for Baghouse: 99.9% PM, 99.0% PM10, 98% PM2.5 or 0.001 PM, 0.01 PM10, 0.02 PM2.5
Control Efficiencies for Filters: 75% PM, 50% PM10, 50% PM2.5 or 0.25 PM, 0.50 PM10, 0.50 PM2.5
Grain Milling (Side B)30200734 Wheat
EU-08A
EU-08B
EU-06B EP-RV CE-06BA
CE-06BB
EP-RV CE-08BA
CE-08BB
Flour Handling / Final Plansifters
(Side B)30200533 (6)Flour
EP-RV CE-08AA
CE-08AB
Flour Handling / Final Plansifters
(Side A)
70 14,500
23 15,000 EU-06A EP-RV CE-06AA
CE-06AB Grain Milling (Side A)30200734 Wheat
30200533 (6)Flour
23 15,000
70 14,500
PTE (tpy) Limited Controlled & Limited (tpy)
Fugitive Source Totals
Outdoor Point Source Totals
Emission Factors (lb./ton) from
AP-42 9.9.1-1 & 9.9.1-2 PTE (tpy) PTE (tpy) Controlled
(3) 50% SCC for grain shipping by rail used since no SCC for flour shipping and flour shipping is cleaner and SCC for Flour Bulk Loading is Non-Detect
(2) 50% SCC for grain shipping by truck used since no SCC for flour shipping and flour shipping is cleaner and SCC for Flour Bulk Loading is Non-Detect
PTE (tpy) = Max. Design Rate (tons/hr.) x Emission Factor (lb./ton) x 8760 hrs./yr. x Capture Efficiency / 2000 lbs./ton
(7) Grain Tempering is listed as ND in AP-42, the PM emissions for grain tempering are estimated to be 50% of grain handling
All Totals
All Point Source (Indoor and
Outdoor Totals
Total Outdoor Emissions
Footnotes: