DAQ-2024-011874

DAQE-AN141070022-24

{{$d1 }}

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

Dear Mr. Garner:

Re: Approval Order: Experimental Approval Order for Chlorine Emissions at the Box Elder Plant
Project Number: N141070022

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August
26, 2024. The Procter & Gamble Paper Products Company must comply with the requirements of this
AO, all applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Tad Anderson, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as
the DAQE number shown on the upper right-hand corner of this letter.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:TA:jg

cc: Bear River Health Department
EPA Region 8

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

November 25, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN141070022-24
Experimental Approval Order for Chlorine Emissions

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

Issued to
The Procter & Gamble Paper Products Company – Box Elder Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

November 25, 2024
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.................................................................................................................. 3
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 4
SECTION II: SPECIAL PROVISIONS ..................................................................................... 5
PERMIT HISTORY ..................................................................................................................... 5
ACRONYMS ................................................................................................................................. 6

DAQE-AN141070022-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

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

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

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

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

NSR Classification
Experimental AO

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

Applicable Federal Standards
None

Project Description
P&G submitted a request for an Experimental Approval Order (EAO) for the unexpected chlorine
emissions resulting from a side reaction caused by the cleaning of microfiltration skids associated with a
manufacturing process. The EAO is needed to provide the necessary time to study how the chlorine
emissions form, evaluate options to eliminate or reduce them, and monitor and quantify the emissions as
necessary.
DAQE-AN141070022-24
Page 4

This EAO is granted in accordance with Section 19-2-107(2)(b)(iii) of the Utah Air Conservation Act.
The objective of this project is to determine the quantity of chlorine emissions from the process and
evaluate options to eliminate or reduce them. This operation will in no way alter the existing operations or
processes at P&G. P&G may operate the chlorine testing for a maximum of 12 months starting from the
date of this document.

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this EAO conform to those used in the Utah Administrative Code (UAC) Rule 307 (R307) and Title 40 of the Code of Federal Regulations (40 CFR). Unless noted otherwise, references cited in these EAO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this EAO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this EAO that could affect the emissions covered by this EAO must be reviewed and approved in accordance with UAC R307-401. [R307-401-1]
I.4 All records referenced in this EAO 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 EAO 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 EAO, 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 EAO 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]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 P&G Box Elder Plant
DAQE-AN141070022-24
Page 5

II.A.2 Storage Tanks Bleach Tank Hydrochloric Acid Solution Tank II.A.3 Chlorine Sensor

II.A.4 Continuous Chlorine Monitoring Meter

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Experimental Approval Order Requirements
II.B.1.a A chlorine monitor shall be placed in the exhaust duct work from the acid storage tanks and bleach storage tank in the FAM manufacturing process. [R307-401]
II.B.1.a.1 Records of actual chlorine emissions readings shall be kept on a daily basis from the chlorine
monitor in the FAM manufacturing process. All actual chlorine emissions shall be included in
the final report. [R307-401]
II.B.1.b Upon completion of the chlorine measuring and monitoring operations, owner/operator shall submit a final report of results of the chlorine emissions analysis with the quantity test and control options to eliminate or reduce. Additional operation of the equipment listed in this EAO shall be addressed through a NOI for new equipment, submitted pursuant to UAC R307-401. The final report shall be submitted to the Director, attention NSR Section, within 90 days of completion of the chlorine emissions analysis. [R307-401]
II.B.1.c This EAO does not give approval to violate any conditions or limitations of P&G AO's and Title
V Operating Permit. [R307-401]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Is Derived From NOI dated August 26, 2024
DAQE-AN141070022-24
Page 6

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-

RN141070022 October 22, 2024 Seth Garner
The Procter & Gamble Paper Products Company 5000 North Iowa String Road Bear River City, UT 84301
[e-mail] Dear Seth Garner,
Re: Engineer Review: Experimental Approval Order for Chlorine Emissions at Procter and Gamble Paper Products Company, Box Elder Plant Project Number: N141070022 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.
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 N141070022: The Procter & Gamble Paper Products Company October 22, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N141070022 Owner Name The Procter & Gamble Paper Products Company Mailing Address 5000 North Iowa String Road
Bear River City, UT, 84301 Source Name The Procter & Gamble Paper Products Company
Source Location 5000 North Iowa Road Bear River City, UT 84301
UTM Projection 402500 m Easting, 4605600 m Northing UTM Datum NAD27 UTM Zone UTM Zone 12 SIC Code 2621 (Paper Mills) Source Contact Dean Shepherd Phone Number [phone] Email [e-mail] Billing Contact Seth Garner Phone Number 435-279-1377
Email [e-mail] Project Engineer Tad Anderson, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted August 26, 2024

Engineer Review N141070022: The Procter & Gamble Paper Products Company October 22, 2024 Page 2
SOURCE DESCRIPTION General Description
The Procter and Gamble Paper Products Company (P&G) operates the Box Elder Plant. The Box Elder Plant produces paper and assembled paper products. The Box Elder Plant is located in Bear River City, Utah.
NSR Classification: Experimental AO Source Classification Located in Box Elder County Airs Source Size: A Applicable Federal Standards Project Proposal
Experimental Approval Order for Chlorine Emissions at Procter and Gamble Paper Products Company, Box Elder Plant
Project Description Procter and Gamble Paper Products Company (P&G), Box Elder Plant submitted a request for an Experimental Approval Order (EAO) for the unexpected chlorine emissions resulting from a side
reaction caused by the cleaning of microfiltration skids associated with a manufacturing process. The EAO is needed to provide the necessary time to study how the chlorine emissions form, evaluate options to eliminate or reduce them, and monitor and quantify the emissions as necessary. This EAO is granted in accordance with Section 19-2-107(2)(b)(iii) of the Utah Air Conservation
Act. The objective of this project is to determine the quantity of chlorine emissions from the process and evaluate options to eliminate or reduce them. This operation will in no way alter the existing operations or processes at P&G. P&G may operate the chlorine testing for a maximum of 12 months starting from the date of this document. EMISSION IMPACT ANALYSIS
No modeling is required for EAO's. [Last updated October 17, 2024]

Engineer Review N141070022: The Procter & Gamble Paper Products Company October 22, 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.

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Chlorine (CAS #7782505) ? ?

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

Engineer Review N141070022: The Procter & Gamble Paper Products Company October 22, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding BACT
No BACT is required for EAO's. The EAO is needed to determine the unknown quantity of chlorine emissions being created. [Last updated October 17, 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 EAO conform to those used in the Utah Administrative Code (UAC) Rule 307 (R307) and Title 40 of the Code of Federal Regulations (40 CFR). Unless noted otherwise, references cited in these EAO conditions refer
to those rules. [R307-101] I.2 The limits set forth in this EAO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this EAO that could affect the emissions covered by this EAO must be reviewed and approved in accordance with UAC R307-401. [R307-401-1] I.4 All records referenced in this EAO 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 EAO 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 EAO, 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 EAO 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]

Engineer Review N141070022: The Procter & Gamble Paper Products Company October 22, 2024 Page 5
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 P&G Box Elder Plant II.A.2 NEW Storage Tanks Bleach Tank Hydrochloric Acid Solution Tank II.A.3 NEW Chlorine Sensor
II.A.4 NEW Continuous Chlorine Monitoring Meter

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 Experimental Approval Order Requirements
II.B.1.a NEW A chlorine monitor shall be placed in the exhaust duct work from the acid storage tanks and bleach storage tank in the FAM manufacturing process. [R307-401]
II.B.1.a.1 NEW Records of actual chlorine emissions reading shall be kept on a daily basis from the chlorine monitor in the FAM manufacturing process. All actual chlorine emissions shall be included in the final report. [R307-401]
II.B.1.b
NEW
Upon completion of the chlorine measuring and monitoring operations, P&G shall submit a
final report of results of the chlorine emissions analysis with the quantity test and control options to eliminate or reduce. Additional operation of the equipment listed in this EAO shall be addressed through a NOI for new equipment, submitted pursuant to UAC R307-401. The
final report shall be submitted to the Director, attention NSR Section, Within 90 days of completion of the chlorine emissions analysis. [R307-401]
II.B.1.c NEW This EAO does not give approval to violate any conditions or limitations of P&G, AO's and Title V Operating Permit. [R307-401]

Engineer Review N141070022: The Procter & Gamble Paper Products Company October 22, 2024 Page 6
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 26, 2024
REVIEWER COMMENTS
1. Comment regarding Chlorine Emissions:
No chlorine emission has been included in this EAO. The chlorine emissions associated with this EAO are unknown since the concentration of emissions varies with each cleaning process. Upon completion of the proposed study, P&G will either submit a NOI to include control equipment for chlorine emissions or provide a solution to eliminate chlorine emissions in the EAO final report. [Last updated October 17, 2024]

Engineer Review N141070022: The Procter & Gamble Paper Products Company October 22, 2024 Page 7
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

August 26, 2024

Mr. Tad Anderson
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84116

RE: Procter and Gamble Paper Products Company (P&G)
Box Elder Plant – Experimental Approval Order Request

Dear Tad:

The Procter and Gamble Paper Products Company (P&G) operates a paper products manufacturing
plant in Box Elder, Utah facility (i.e., Box Elder Plant). Currently, the facility is permitted in
accordance with Approval Order No. AN141070018-23 and Title V operating permit 300053003.

P&G recently discovered the potential for unexpected emissions resulting from a side reaction
caused by the cleaning of microfiltration skids associated with a manufacturing processes at the
Box Elder Plant. As an immediate safety measure, P&G has made efforts to route these emissions
to the atmosphere.

The purpose of the accompanying Notice of Intent (NOI) air permit application is to seek coverage
under an experimental approval order to provide the necessary time to study how these emissions
form, evaluate options to eliminate or reduce them, and monitor and quantify the emissions as
necessary. This NOI air permit application has been developed to meet the Utah Division of Air
Quality’s (UDAQ’s) application requirements under Utah Administrative Code (UAC) R307-401-5.

P&G has submitted remittance in the form of a check for the amount of $3,075 for both the NOI
filing fee and Application Review Fees.

Should you have any questions regarding this submittal, please do not hesitate to call or email
Dean Shepherd at [phone] or [e-mail] or Chantelle Russell at (805) 444-
8980 or [e-mail].

Sincerely,

Seth Garner
Box Elder Plant Manager
Procter and Gamble Paper Products Company (P&G)

CC: Dean Shepherd, P&G
Chantelle Russell, Trinity Consultants
Brian Mensinger, Trinity Consultant
Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants
UTAH DIVISION OF AIR QUALITY – NOTICE
OF INTENT
The Procter and Gamble Paper Products Company,
Box Elder, Utah
Experimental Approval Order Request
Prepared By:
TRINITY CONSULTANTS
4525 Wasatch Boulevard
Suite 200
Salt Lake City, Utah 84104
[phone]
Submitted on Behalf of:
The Procter and Gamble Paper Products Company
5000 Iowa String Road
Bear River City, UT 84301
August 2024
Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants i
TABLE OF CONTENTS
TABLE OF CONTENTS I 
 EXECUTIVE SUMMARY 1-1 
 GENERAL INFORMATION 2-1 
2.1 Source Identification Summary .................................................................................. 2-1 
2.2 Source Information and General Location .................................................................. 2-1 
2.3 Source Size Determination ......................................................................................... 2-1 
2.4 Notice of Intent Forms ................................................................................................ 2-1 
2.5 Notice of Intent Fees .................................................................................................. 2-2 
 DESCRIPTION OF PROJECT AND PROCESS 3-1 
3.1 Description of Project ................................................................................................. 3-1 
 EMISSIONS RELATED INFORMATION 4-1 
 BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS 5-1 
 APPLICABLE REGULATIONS 6-1 
 FORMS A 

Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants 1-1
EXECUTIVE SUMMARY
The Procter and Gamble Paper Products Company (P&G) operates a paper products manufacturing plant in
Box Elder, Utah (i.e., Box Elder Plant). Box Elder County is currently classified as an attainment area for all
criteria pollutants with the exception of particulate matter less than 2.5 microns in diameter (PM2.5).
Currently, the facility is permitted in accordance with Approval Order No. DAQE-AN141070018-23 and Title
V operating permit 300053003.

P&G recently discovered the potential for chlorine emissions resulting from the cleaning of the microfiltration
skids associated with the manufacturing of Functional Absorbent Material (FAM), a component of Assembled
Paper Product B (APPB). These chlorine emissions are the result of an unintentional side reaction and have
the potential to impact employees of the Box Elder Plant. As an immediate safety measure, P&G is in the
process of routing these potential emissions to the atmosphere.

In its approval order Approval Order No. DAQE-AN141070014-22 modification, P&G estimated hydrochloric
acid (HCl) emissions from the process as a hazardous air pollutant (HAP), but did not include chlorine
emissions. As a result, the character of air pollutants discharged from the existing microfiltration skid
installation is intermittingly occurring during cleaning operations.

The purpose of this experimental approval order application is to allow the necessary time to study how
these emissions form, evaluate options to eliminate or reduce them, and monitor and quantify the emissions
as necessary.
This Notice of Intent (NOI) air permit application has been developed pursuant to Utah Administrative Code
(UAC) R307-401-5 and Utah’s application guidance including but not limited to:

► NOI Forms and Fees;
► Process Description;
► Potential-to-Emit (PTE) Calculations;
► Best Available Control Technology (BACT) Analysis; and
► Applicable Requirements.

Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants 2-1
GENERAL INFORMATION
The following section contains the information requested under the “Source Identification Information”
section of UDAQ Form 1 Notice of Intent (NOI) Application Checklist.
2.1 Source Identification Summary
► Company Name: The Procter and Gamble Paper Products Company
► Address: 5000 North Iowa String Road, Bear River City, UT
► County: Box Elder County
► UTM Coordinates: Easting: 402,500 m, Northing: 4,605,600 m, Zone 12
► Primary SIC Code: 2676 (Sanitary Paper Products)
► Area Designation: Serious Nonattainment for PM2.5
► Source Size Determination: Major Source: Title V operating permit 300053003
► Current AO: DAQE-AN141070018-23

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

2.2 Source Information and General Location
P&G operates a paper product manufacturing plant in Box Elder County which is a nonattainment area for
PM2.5. The plant is comprised of three primary business units manufacturing consumer products for Paper
Making, Assembled Paper Products A and Assembled Paper Products B. Support equipment includes storage
tanks, emergency generators, boilers and cooling towers.
2.3 Source Size Determination
The proposed site-wide potential emissions are summarized in previous permitting documentation and no
change is proposed with this application. As previously established, site-wide emissions are greater than the
major source threshold (MST) for PM2.5, NOx, and VOCs. As such, P&G is classified as a Major Source.
2.4 Notice of Intent Forms
The following UDAQ forms have been included with the NOI application:

► Form 1 – Notice of Intent Application Checklist;
► Form 2 – Company Information/Notice of Intent (NOI);
► Form 4 – Project Information; and
► Form 5 – Emission Information.

Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants 2-2
2.5 Notice of Intent Fees
P&G will use the UDAQ’s Payment Portal to prepay the following UDAQ NOI fees associated with this
submittal:

“Application Filing Fee” for the “New Minor Source or Minor Modification at Minor or Major Source” category
= $575

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

Total UDAQ fees = $3,075

P&G understands that the total permit review fee is based on the total actual time spent by UDAQ staff
processing this NOI. Upon issuance of the AO, if the total review time is more than 20 standard hours,
UDAQ will invoice P&G at $125 per hour for the additional time above 20 standard hours.

Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants 3-1
DESCRIPTION OF PROJECT AND PROCESS
3.1 Description of Project
P&G utilizes two (2) identical microfiltration skids to clean the piping and connectors associated with the
FAM manufacturing process. Each microfiltration skid utilizes several water rinses, as well as bleach and
hydrochloric acid. Despite careful protocols, P&G suspects that residual bleach and hydrochloric acid remain
within the skid’s piping connections, causing an unintentional secondary reaction resulting in the production
of chlorine gas, as seen in the equation below:

𝑁𝑎𝐶𝑙𝑂 ൅ 2𝐻𝐶𝑙 → 𝐶𝑙ଶ ൅𝐻ଶ𝑂൅𝑁𝑎𝐶𝑙

Small amounts of chlorine gas were detected by sensors and employees in the area. As an imperative safety
measure, the vent for the microfiltration skid is now routed via stack to the roof where it can be dispersed.

P&G is evaluating its procedures and piping layout to understand the cause for this secondary reaction. P&G
is also evaluating approaches to eliminate chlorine byproducts and ensure employee safety. P&G is
proposing to conduct the following steps to monitor, identify and eliminate chlorine emissions:

► Install sperate tanks for bleach and hydrochloric acid solutions;
► Rinsing water path will be the same as the chemical path till the pH is neutral or the free chlorine is the
same as the city water;
► A chlorine sensor will be placed between the bleach and hydrochloric acid tanks; and
► A continuous chlorine monitoring meter will be installed within the exhaust duct work.

A process flow diagram for this process is displayed in Figure 1 below; microfiltration is abbreviated as “MF”
and sensor as “S”.
Figure 1. Process Flow Diagram for Microfiltration Skids

Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants 3-2
During the evaluation period P&G anticipates cleaning of each skid may occur for 12 hours each day, this
practice limits the potential for formation of chlorine gas. During normal operation, cleaning occurs once per
week per skid for approximately 12 hours. P&G requests 12 months to monitor this intermittent process to
identify and eliminate the chlorine emissions or to quantify the amount of emissions generated.

Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants 4-1
EMISSIONS RELATED INFORMATION
A full set of emissions-related information was outlined in previous permitting exercises. No emission
calculations have been performed for the chlorine emissions associated with this experimental approval
order application, because emission factors are unknown since the concentration of emissions varies with
each cleaning process. Upon completion of the proposed study, P&G hopes to have eliminated chlorine
emissions. If this is not possible, emissions will be quantified, and P&G will submit an NOI air permit
application for inclusion within the currently maintained approval order and Title V permit.

P&G proposes to monitor and record emissions through the chlorine sensors to be installed following each
cleaning event.

Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants 5-1
BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS
Should P&G be unable to eliminate chlorine emissions, P&G proposes to conduct a BACT analysis under a
separate approval order modification as the information collected through the proposed study will be
essential to determining technical feasibility and whether emissions can be eliminated and if not, if controls
can be applied.

Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants 6-1
APPLICABLE REGULATIONS
There are no applicable regulations for chlorine emissions of this type and anticipated intermittent nature of
the generation and process.

Procter and Gamble – Box Elder Plant / NOI Experimental Approval Order Application
Trinity Consultants A
FORMS

Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number †
2. Company contact (Name, mailing address, and telephone number)†
3. Name and contact of person submitting NOI application (if different than 2)†
4. Source Universal Transverse Mercator (UTM) coordinates †
5. Source Standard Industrial Classification (SIC) code †
6. Area designation (attainment, maintenance, or nonattainment)†
7. Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)†
8. Source size determination (Major, Minor, PSD)†
9. Current Approval Order(s) and/or Title V Permit numbers †
NOI Application Information:[R307-401]
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†N/A †
†N/A †
A. Air quality analysis (air model, met data, background data, source impact analysis) †N/A †
Detailed description of the project and source process
Discussion of fuels, raw materials, and products consumed/produced
Description of equipment used in the process and operating schedule
Description of changes to the process, production rates, etc.
Site plan of source with building dimensions, stack parameters, etc.
Best Available Control Technology (BACT) Analysis [R307-401-8]
$BACT analysis for all new and modified equipment
Emissions Related Information: [R307-401-2(b)]
$Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5,NOx, SO2, CO, VOCs, HAPs, and GHGs)
%References/assumptions, SDS, for each calculation and pollutant
&All speciated HAP emissions (list in lbs/hr)
Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
$Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
$NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
%Alternative site analysis, Major source ownership compliance certification
Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
%Visibility impact analysis, Class I area impact
 6LJQDWXUHRQ$SSOLFDWLRQ
†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.
August 2024
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Procter and Gamble
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Form 2 Date _____BB_____
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: Ƒ Initial Approval Order Ƒ 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):______________________
B_____________________
______________________
Phone no.:
Fax no.:
4. Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:BBBBBBBBBBBBBBBBBBBBBBBBB
X: _____B_________BBBBBBBBBBBB
Y: _________BBBBBBBBBBBBBBBBBB
5. The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7. If request for modification, AO# to be modified: DAQE #__________________BBBBBBBBBBDATED: ____/____/____
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 Ƒ %RWK
Authorization/Singnature
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:
August 2024
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Procter and Gamble Dean Shepherd
5000 N Iowa String Road [phone]
[e-mail] River City, UT 84301
Zone 12
Easting: 402,500m
Northing: 4,605,600m
Box Elder County
2 6 76
The Box Elder Plant is seeking an experimental approval order to allow the necessary time to study
how chlorine emissions form in the manufacturing process of Functional Absorbent Material (FAM),
evaluate options to eliminate or reduce them, and monitor and quantify the emissions as necessary.
✔
Plant Manager
Seth Garner [e-mail]
770-712-1564
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data -For Modification/Amendment ONLY
1. Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2. Name of process to be modified/added:
______________________________
End product of this process:
_______________________________
3. Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4. Does new emission unit affect existing
permitted process limits?
Yes No
5. Condition(s) Changing:
6. Description of Permit/Process Change**
7. New or modified materials and quantities used in process. **
Material Quantity Annually
8. New or modified process emitting units **
Emitting Unit(s)Capacity(s)Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
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Procter and Gamble
Box Elder County, UT
DAQE-AN141070018-23
The cleaning of the Microfiltration Skid
Functional Absorbent Material
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The Box Elder Plant is seeking an experimental approval order to allow the necessary
time to study how chlorine emissions form in the manufacturing process of Functional
Absorbent Material (FAM), evaluate options to eliminate or reduce them, and monitor and
quantify the emissions as necessary.
Page 1 of 1
Company___________________________
6LWH_____________________________
Form 
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
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Procter and Gamble
Box Elder