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Home My WebLink AboutDAQ-2025-001247 Small Source Registration DAQE-EN162500001-25 {{$d1 }} Dave Fiala Kings Peak Lumber LLC PO Box 950 Panguitch, UT 84759 dave@kingspl.com Dear Mr. Fiala: Re: Request for Evaluation of Compliance with Rule R307-401-9, UAC: Small Source Exemption Project Fee Code: N162500001 On January 29, 2025, the Division of Air Quality (DAQ) received your request for a small source exemption for Kings Peak Lumber LLC’s Panguitch Lumber Mill. The source is located at 165 North 700 West, Panguitch, in Garfield County. DAQ has determined the small source exemption applies to the source, as long as the equipment and associated processes operate as specified in the registration request. The registration request assumes the source saws and debarks less than 25,000 tons of logs per year, dries less than 3,800,000 board feet of lumber per year, and operates the 13 MMBtu/hr boiler for less than 7,000 hours per year. The small source exemption does not exempt a source from complying with other applicable federal, state, and local regulations and the current Utah Administrative Code. Based on the emissions that you submitted to DAQ with your registration request, Kings Peak Lumber LLC’s Panguitch Lumber Mill is not required to obtain an approval order under R307-401. If you change your operation such that there is an increase in emissions, we recommend that you notify us, as an approval order may be required. As authorized by the Utah Legislature, the fee for issuing this small source exemption is a one-time filing fee in addition to the actual time spent by the review engineer and all other staff on the project. Payment should be sent to DAQ upon receipt of the invoice. 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Tim Davis Interim Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director / % Ý Û Ù Û Þ DAQE-EN162500001-25 Page 2 Thank you for registering your source with the DAQ. If you have any additional questions, please contact Dungan Adams at (385) 290-2474 or dunganadams@utah.gov. Sincerely, Bryce C. Bird Director {{$s }} Alan D. Humpherys, Manager New Source Review Section BCB:ADH:DA:jg {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}} Updated 2/6/2025 Pollutant Total Tons per Year(PTE) NOx 4.37 25000 tons/year CO 3.67 3,800,000 board feet/year VOCs 4.94 300 tons/year SOx 0.03 45 lb/ft3 PM10 4.78 6.33 bf/ft3 PM10- fugitive 0.52 0.38 PM2.5 3.20 HAPs 0.32 Pollutant PM PM10 PM2.5 VOCs Log Bucking Emission Factorsb (lb/ton log)0.035 0.018 0.009 Log Bucking Emissions (tpy)0.438 0.219 0.109 Log Debarking Emission Factorsb (lb/ton log)0.024 0.012 0.006 Log Debarking Emissions (tpy)0.300 0.150 0.075 Emission Factors from Sawingb (lb/ton log)0.350 0.175 0.088 Emissions from Sawing (tpy)4.375 2.188 1.094Pneumatically convey material from sawing through cyclone to binb (lb/bdt)0.200 0.190 0.160 Criteria Pollutant Emissions Kings Peak Lumber Emissions Operating Data Raw logs debarking and sawing b EPA Region 10 Particulate Matter Potential to Emit Emission Factors for Activities at Sawmills, Excluding Boilers, Located in Pacific Northwest Indian Country, May 2014, No emission factor found for planing, so assuming the same as debarking a Wood Species - Moisture Content and Weight https://www.engineeringtoolbox.com/weigt-wood-d_821.html accessed 6/4/24 Lumber Drying Sawdust pile handling Ponderosa Pine Densitya Log Recovery Factorb Moisture in Wooda (62%) Pneumatically convey material from sawing through cyclone to bin (tpy)0.944 0.897 0.756 Emission Factors from Dryingb,c (lb/mbf) or (lb/ton log)0.020 0.020 0.020 2.345 Annual Emissions from Drying Wood (tpy)0.038 0.038 0.038 4.5 Emission Factors from Planing b (lb/ton log)0.024 0.012 0.006 Emissions from Planing (tpy)0.113 0.057 0.028Pneumatically convey material from planing through cyclone to binb (lb/bdt)0.200 0.190 0.160Pneumatically convey material from planing through cyclone to bin (tpy)0.944 0.897 0.756 Pollutant Drying Emission Factor j (lb/mbf) Drying Emissions (tpy) Drying Emissions (lb/hr) Methanol 0.07 0.14 0.00 Acetaldehyde 0.04 0.08 0.00 Propionaldeyde 0.00 0.01 0.00 Acrolein 0.00 0.01 0.00 0.00 0.00 Formaldehyde 0.00 0.01 0.00 total: 0.24 0.00 13 Mmbtu/hr 7000 hours/year 1020.0 btu/scf 87.4 Mmscf/yr aAP-42, Appendix A, Page A-5 Pollutant Emisison Factors lb/106scf c Criteria Emissions from Boiler (lb/hr) Annual Criteria Emissions from Boiler Requeste d (tpy) NOx 100 1.25 4.37 CO 84 1.05 3.67 VOCs 11 0.14 0.48 SOx 0.6 0.01 0.03 PM 7.6 0.09 0.33 PM10 7.6 0.09 0.33 PM2.5 7.6 0.09 0.33 Pollutantc Natural Gas Emission Factor (lb/MMscf) d HAPs from Natural Gas (tpy) Pollutant Emission Factor (kg/MMBtu) g Global Warming Potentiali Annual GHG Emissions (metric tpy) Arsenic 2.0E-04 8.7E-06 CO2 53.06 1 4,731 Benzene 2.1E-03 9.2E-05 CH4 1.00E-03 25 2 Cadmium 1.1E-03 4.8E-05 N2O 1.00E-04 298 3 Chromium 1.4E-03 6.1E-05 CO2e 4,736 Cobalt 8.4E-05 3.7E-06 gAP-42 Appendix A, page A-5 Dichlorobenz 1.2E-03 5.2E-05 Formaldehyd 7.5E-02 3.3E-03 i40 CFR 98 Subpart A, Table A-1 Hexane 1.8E+00 7.9E-02 Lead 0.0005 2.2E-05 Manganese 3.8E-04 1.7E-05 Mercury 2.6E-04 1.1E-05 Naphthalene 6.1E-04 2.7E-05 Nickel 2.1E-03 9.2E-05 Toluene 3.4E-03 1.5E-04 2-Methylnaph 2.4E-05 1.0E-06 Fluoranthene 3.0E-06 1.3E-07 Fluorene 2.8E-06 1.2E-07 Phenanathre 1.7E-05 7.4E-07 b AP42 Table 1.4-1 h40 CFR 98 Subpart C, Tables C-1, C-2 Default CO2 Emission Factors and High Heat Values for Various Types of Annual Heat Rate Operating Data Heat rate for Boiler Expected Use Natural Gasa Pyrene 5.0E-06 2.2E-07 Total 8.3E-02 cOnly use emission factors greater than detection levels d AP-42, Table 1.4-3 or 1.4-4 e EPA Region 10 HAP and VOC Emission Factors for Lumber Drying, December 2012 f kiln temperature maximum is 180 degrees F Production Rates Hourly Rates 500 tons/hr Annual Production 25,000 tons/year From AP-42, Table 13.2.2-2 PM30 PM10 PM2.5 k for particulate matter 4.9 1.5 0.15 a for particulate matter 0.7 0.9 0.9 b for particulate matter 0.45 0.45 0.45 surface material silt contenta 4.8 % empty truck weighta 15 tons Estimated log load weight 42.5 tons mean vehicle weight 36.25 tons Basic Watering 70%Control Vehicle Travel Emissions AP-42, Section 13.2.2 1b provides the following equation for calculating emissions from unpaved roads: a) From AP-42, Table 13.2.2-1, mean silt content for municipal solid waste landfills. a)Based on email from Dave Fiala of Kings Peak Lumber on 6/3/2024 Emissions Factor lb = k (s/12)a(W/3)b VMT k, a and b are constants provided in AP-42 s = surface material silt content (%) W = mean vehicle weight (tons) Assume average truck weight per trip is based on a full truck one direction and an empty truck on the return. Mean Vehicle Weight = Full Truck + Empty Truck = (Empty Truck + Load) + Empty Truck 2 2 Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Road Base with Watering 75%Control Chemical Suppressant & Watering 85%Control Emission Factor PM30 =7.92 lb/VMT Emission Factor PM10=2.02 lb/VMT Emission Factor PM2.5=0.20 lb/VMT ControlledEmission Factor PM30 =2.38 lb/VMT Controlled Emission Factor PM10=0.61 lb/VMT Controlled Emission Factor PM2.5=0.06 lb/VMT Haul Road One-Way Lengtha 275 feet Hourly Vehicle Miles Traveled 1.2 miles Road Length (round-trip)0.10 miles Vehicle Miles Traveled = 61.27 VMT/year Particulate Emissions PM30 = 0.07 tons/year Particulate Emissions PM10 = 0.02 tons/year Particulate Emissions PM2.5 = 0.00 tons/year a)From email from Dave Fiala, Kings Peak Lumber 1/27/2025 Vehicle Miles Traveled miles = loads x miles . year year round trip tons = Emission Factor lb x VMT x tons . year VMT year 2000 lb Production Rates Hourly Rates 500 tons/hr Annual Production 25,000 tons/year From AP-42, Table 13.2.2-2 PM30 PM10 k for particulate matter 4.9 1.5 a for particulate matter 0.7 0.9 b for particulate matter 0.45 0.45 surface material silt contenta 4.8 % empty truck weighta 15 tons Estimated log load weight 42.5 tons mean vehicle weight 36.25 tons Basic Watering 70%Control Road Base with Watering 75%Control Chemical Suppressant & Watering 85%Control Emission Factor PM30 =7.92 lb/VMT Emission Factor PM10=2.02 lb/VMT Emission Factor PM2.5=0.20 lb/VMT ControlledEmission Factor PM30 =2.38 lb/VMT Controlled Emission Factor PM10=0.61 lb/VMT Controlled Emission Factor PM2.5=0.06 lb/VMT Haul Road One-Way Lengtha 240 feet Vehicle Travel Emissions AP-42, Section 13.2.2 1b provides the following equation for calculating emissions from a) From AP-42, Table 13.2.2-1, mean silt content for municipal solid waste landfills. a)Based on email from Dave Fiala of Kings Peak Lumber on 6/3/2024 Emissions Factor lb = k (s/12)a(W/3)b VMT k, a and b are constants provided in AP-42 s = surface material silt content (%) W = mean vehicle weight (tons) Assume average truck weight per trip is based on a full truck one direction and an emp the return. Mean Vehicle Weight = Full Truck + Empty Truck = (Empty Truck + Load) + Empty Tr 2 2 Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Hourly Vehicle Miles Traveled 1.1 miles Road Length (round-trip)a 11.00 miles Vehicle Miles Traveled = 53.48 VMT/year Particulate Emissions PM30 = 0.06 tons/year Particulate Emissions PM10 = 0.02 tons/year Particulate Emissions PM2.5 = 0.00 tons/year a)From email from Dave Fiala, Kings Peak Lumber 1/27/2025 Vehicle Miles Traveled miles = loads x miles .year year round trip tons = Emission Factor lb x VMT x tons . year VMT year 2000 lb PM2.5 0.15 0.9 0.45 m unpaved roads: pty truck on ruck Production Rates Hourly Rates 500 tons/hr Annual Production 25,000 tons/year From AP-42, Table 13.2.2-2 PM30 PM10 PM2.5 k for particulate matter 4.9 1.5 0.15 a for particulate matter 0.7 0.9 0.9 b for particulate matter 0.45 0.45 0.45 surface material silt contenta 4.8 % empty truck weighta 33.5 tons Estimated log load weight 18 tons mean vehicle weight 42.5 tons Basic Watering 70%Control Vehicle Travel Emissions AP-42, Section 13.2.2 1b provides the following equation for calculating emissions from unpaved roads: a) From AP-42, Table 13.2.2-1, mean silt content for municipal solid waste landfills. a)Based on email from Dave Fiala of Kings Peak Lumber on 6/3/2024 Emissions Factor lb = k (s/12)a(W/3)b VMT k, a and b are constants provided in AP-42 s = surface material silt content (%) W = mean vehicle weight (tons) Assume average truck weight per trip is based on a full truck one direction and an empty truck on the return. Mean Vehicle Weight = Full Truck + Empty Truck = (Empty Truck + Load) + Empty Truck 2 2 Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Road Base with Watering 75%Control Chemical Suppressant & Watering 85%Control Emission Factor PM30 =8.51 lb/VMT Emission Factor PM10=2.17 lb/VMT Emission Factor PM2.5=0.22 lb/VMT ControlledEmission Factor PM30 =2.55 lb/VMT Controlled Emission Factor PM10=0.65 lb/VMT Controlled Emission Factor PM2.5=0.07 lb/VMT Haul Road One-Way Lengtha 700 feet Hourly Vehicle Miles Traveled 7.4 miles Road Length (round-trip)0.27 miles Vehicle Miles Traveled = 368.27 VMT/year Particulate Emissions PM30 = 0.47 tons/year Particulate Emissions PM10 = 0.12 tons/year Particulate Emissions PM2.5 = 0.01 tons/year a)From email from Dave Fiala, Kings Peak Lumber 1/27/2025 Vehicle Miles Traveled miles = loads x miles . year year round trip tons = Emission Factor lb x VMT x tons . year VMT year 2000 lb Dungan Adams <dunganadams@utah.gov> Kings Peak Lumber Notice of Intent 42 messages Dungan Adams <dunganadams@utah.gov>Wed, Aug 7, 2024 at 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Bethany Moffat <bmoffat@air-resource.com>Tue, Aug 13, 2024 at 8:37 AM To: Dungan Adams <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-61971011147485…1/385 transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 [Quoted text hidden] 2024 0812 KP Lumber.xlsx 44K Bethany Moffat <bmoffat@air-resource.com>Mon, Aug 19, 2024 at 8:05 AM To: Dungan Adams <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 [Quoted text hidden] 2024 0819 KP Lumber.xlsx 46K Dungan Adams <dunganadams@utah.gov>Mon, Aug 19, 2024 at 8:40 AM To: Bethany Moffat <bmoffat@air-resource.com> 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-61971011147485…2/385 Cc: Dave Fiala <dave@kplumber.com> Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Wed, Aug 21, 2024 at 4:27 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan [Quoted text hidden] Bethany Moffat <bmoffat@air-resource.com>Thu, Aug 22, 2024 at 8:51 AM To: Dungan Adams <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Thu, Aug 22, 2024 at 10:47 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Tue, Sep 10, 2024 at 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-61971011147485…3/385 - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan [Quoted text hidden] Bethany Moffat <bmoffat@air-resource.com>Tue, Sep 10, 2024 at 12:44 PM To: Dungan Adams <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 [Quoted text hidden] NP-Prop 9419 Released Version SHORT.pdf 716K Dungan Adams <dunganadams@utah.gov>Tue, Sep 10, 2024 at 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR-- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-61971011147485…4/385 so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP- 42 rate. Let me know if you have any questions. Thanks, Dungan [Quoted text hidden] Bethany Moffat <bmoffat@air-resource.com>Mon, Sep 16, 2024 at 8:42 AM To: Dungan Adams <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Mon, Sep 16, 2024 at 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-61971011147485…5/385 Thanks, Dungan [Quoted text hidden] 3 attachments Screenshot 2024-09-16 123242.png 1832K Haul Roads.xlsx 74K Loader Routes.xlsx 74K Bethany Moffat <bmoffat@air-resource.com>Wed, Sep 25, 2024 at 8:38 AM To: Dungan Adams <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Wed, Sep 25, 2024 at 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-61971011147485…6/385 Thanks, Dungan [Quoted text hidden] Bethany Moffat <bmoffat@air-resource.com>Wed, Sep 25, 2024 at 11:54 AM To: Dungan Adams <dunganadams@utah.gov> Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Wed, Sep 25, 2024 at 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-61971011147485…7/385 I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan [Quoted text hidden] Bethany Moffat <bmoffat@air-resource.com>Thu, Sep 26, 2024 at 8:06 AM To: Dungan Adams <dunganadams@utah.gov> Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Thu, Sep 26, 2024 at 9:16 AM To: Bethany Moffat <bmoffat@air-resource.com> Sounds good, thanks for the update. -Dungan [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Wed, Oct 9, 2024 at 11:49 AM To: Bethany Moffat <bmoffat@air-resource.com> Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Tue, Oct 29, 2024 at 8:47 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-61971011147485…8/385 I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan [Quoted text hidden] Bethany Moffat <bmoffat@air-resource.com>Tue, Oct 29, 2024 at 4:44 PM To: Dungan Adams <dunganadams@utah.gov>, Dave Fiala <dave@kplumber.com> Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Mon, Nov 4, 2024 at 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan [Quoted text hidden] Bethany Moffat <bmoffat@air-resource.com>Mon, Nov 4, 2024 at 1:06 PM To: Dungan Adams <dunganadams@utah.gov> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-61971011147485…9/385 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…10/385 Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…11/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…12/385 Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…13/385 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…14/385 in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…15/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…16/385 Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…17/385 Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…18/385 Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front- end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…19/385 Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…20/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…21/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…22/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…23/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…24/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…25/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…26/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…27/385 2 attachments Haul Road and Loader Distance.docx 14761K 2024 1104 KP Lumber.xlsx 51K Dungan Adams <dunganadams@utah.gov>Mon, Nov 4, 2024 at 2:44 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Tue, Dec 10, 2024 at 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. Thanks, Dungan [Quoted text hidden] 2024 1104 KPL Lumber.xlsx 42K Bethany Moffat <bmoffat@air-resource.com>Tue, Dec 10, 2024 at 3:01 PM To: Dungan Adams <dunganadams@utah.gov> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Dungan, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…28/385 I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…29/385 On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…30/385 Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…31/385 Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…32/385 The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…33/385 Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…34/385 I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…35/385 I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…36/385 Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…37/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…38/385 Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…39/385 Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…40/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…41/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…42/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…43/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…44/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…45/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…46/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…47/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…48/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Dungan Adams <dunganadams@utah.gov>Tue, Dec 10, 2024 at 3:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: "dave@kingspl.com" <dave@kingspl.com> 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…49/385 Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, Dungan [Quoted text hidden] Dungan Adams <dunganadams@utah.gov>Wed, Dec 11, 2024 at 4:24 PM To: Bethany Moffat <bmoffat@air-resource.com> Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan [Quoted text hidden] Bethany Moffat <bmoffat@air-resource.com>Thu, Dec 12, 2024 at 9:12 AM To: Dungan Adams <dunganadams@utah.gov> Cc: "dave@kingspl.com" <dave@kingspl.com> Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…50/385 I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…51/385 Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…52/385 working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…53/385 Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…54/385 earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP- 42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…55/385 Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…56/385 Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…57/385 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307- 205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…58/385 directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…59/385 Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…60/385 all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…61/385 Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…62/385 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…63/385 - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…64/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…65/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…66/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…67/385 M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…68/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…69/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…70/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…71/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…72/385 M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Dungan Adams <dunganadams@utah.gov>Thu, Dec 12, 2024 at 12:15 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…73/385 ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. Let me know if you have any other questions or concerns. Thanks, Dungan [Quoted text hidden] image001.png 13K Dungan Adams <dunganadams@utah.gov>Wed, Jan 22, 2025 at 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan [Quoted text hidden] Bethany Moffat <bmoffat@air-resource.com>Mon, Jan 27, 2025 at 8:49 AM To: Dungan Adams <dunganadams@utah.gov> Hey Dungan, I just received documentation on the old boiler over the weekend. I will put together the numbers and have some more information for you hopefully by the end of the week. Thank you! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…74/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…75/385 Let me know if you have any other questions or concerns. Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…76/385 Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…77/385 Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…78/385 Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…79/385 Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…80/385 load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…81/385 Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…82/385 On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…83/385 I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…84/385 Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Error! Filename not specified. Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…85/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…86/385 Thanks again, Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…87/385 Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Error! Filename not specified. Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…88/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non- paved surface then you need to include emissions from this process. Thanks, Dungan -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…89/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…90/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…91/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…92/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…93/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…94/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…95/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…96/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…97/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…98/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-6197101114748…99/385 M: (385) 290-2474 airquality.utah.gov Bethany Moffat <bmoffat@air-resource.com>Tue, Jan 28, 2025 at 8:41 AM To: Dungan Adams <dunganadams@utah.gov> Cc: "dave@kingspl.com" <dave@kingspl.com> Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…100/385 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…101/385 Let me know if you have any other questions or concerns. Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…102/385 Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…103/385 Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…104/385 Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…105/385 Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…106/385 If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…107/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…108/385 them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…109/385 Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…110/385 For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…111/385 I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…112/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…113/385 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…114/385 - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non- paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…115/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…116/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…117/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…118/385 M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…119/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…120/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…121/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…122/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…123/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…124/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Dungan Adams <dunganadams@utah.gov>Tue, Jan 28, 2025 at 10:03 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Bethany, If you intend to exclusively operate the boiler at the new site (and not dry, saw, plane, etc. any wood), you could limit the operation of the boiler to less than 7000 hours per year, and remain a Small Source as you have suggested. However, my understanding is the boiler would be used for wood drying and the wood drying process will result in VOC emissions. There would also be emissions from sawing, planing, etc. to prepare the wood for drying. If you can provide emission calculations that show the new site-wide emissions are less than 5 tons per year of all criteria pollutants with operation and production limits, I can issue a Small Source Exemption (SSE) for the new site. The exemption process is much faster, but you would likely need to operate at less than a third of the scale that was originally proposed to stay below the SSE threshold. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…125/385 The other option, like you have mentioned, is to include the existing boiler in addition to the original calculations. The increase in primarily NOx and CO would not trigger any new requirements, but you would need to provide BACT analysis for the 2002 boiler. Let me know how you would like to proceed and if you have any questions. Thanks, Dungan On Tue, Jan 28, 2025 at 8:41 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…126/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. Let me know if you have any other questions or concerns. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…127/385 Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…128/385 On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…129/385 Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…130/385 Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…131/385 Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…132/385 If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…133/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…134/385 to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…135/385 Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…136/385 to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…137/385 Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…138/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…139/385 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…140/385 - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non- paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…141/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…142/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…143/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…144/385 M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…145/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…146/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…147/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…148/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…149/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…150/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…151/385 airquality.utah.gov Dungan Adams <dunganadams@utah.gov>Tue, Jan 28, 2025 at 11:45 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Bethany, Attached is the link to the Small Source Exemption Application form. Please let me know if you have any questions. Thanks, Dungan On Tue, Jan 28, 2025 at 10:03 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, If you intend to exclusively operate the boiler at the new site (and not dry, saw, plane, etc. any wood), you could limit the operation of the boiler to less than 7000 hours per year, and remain a Small Source as you have suggested. However, my understanding is the boiler would be used for wood drying and the wood drying process will result in VOC emissions. There would also be emissions from sawing, planing, etc. to prepare the wood for drying. If you can provide emission calculations that show the new site-wide emissions are less than 5 tons per year of all criteria pollutants with operation and production limits, I can issue a Small Source Exemption (SSE) for the new site. The exemption process is much faster, but you would likely need to operate at less than a third of the scale that was originally proposed to stay below the SSE threshold. The other option, like you have mentioned, is to include the existing boiler in addition to the original calculations. The increase in primarily NOx and CO would not trigger any new requirements, but you would need to provide BACT analysis for the 2002 boiler. Let me know how you would like to proceed and if you have any questions. Thanks, Dungan On Tue, Jan 28, 2025 at 8:41 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…152/385 Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…153/385 On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. Let me know if you have any other questions or concerns. Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…154/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…155/385 Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…156/385 Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…157/385 Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…158/385 Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…159/385 Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…160/385 Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…161/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…162/385 I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…163/385 Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…164/385 - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…165/385 Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…166/385 Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…167/385 Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…168/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…169/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…170/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…171/385 M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…172/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…173/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…174/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…175/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…176/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…177/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…178/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Bethany Moffat <bmoffat@air-resource.com>Fri, Jan 31, 2025 at 9:26 AM To: Dungan Adams <dunganadams@utah.gov> Cc: "dave@kingspl.com" <dave@kingspl.com> Hey Dungan, We submitted the minor source exemption information yesterday with limited production and use for the boiler. I am preparing the updated application with the dryer included now. I think we discussed this, but I just want to clarify – can we keep the minor source exemption for just the boiler itself and have it as a backup after we get the permit for full production with the dryer? I think you said that if we want to do that, we need to include it in the overall emissions and do a RACT analysis on it, but I want to just make sure before I do it. Thanks for your help with this! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, January 28, 2025 10:03 AM To: Bethany Moffat <bmoffat@air-resource.com> 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…179/385 Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, If you intend to exclusively operate the boiler at the new site (and not dry, saw, plane, etc. any wood), you could limit the operation of the boiler to less than 7000 hours per year, and remain a Small Source as you have suggested. However, my understanding is the boiler would be used for wood drying and the wood drying process will result in VOC emissions. There would also be emissions from sawing, planing, etc. to prepare the wood for drying. If you can provide emission calculations that show the new site-wide emissions are less than 5 tons per year of all criteria pollutants with operation and production limits, I can issue a Small Source Exemption (SSE) for the new site. The exemption process is much faster, but you would likely need to operate at less than a third of the scale that was originally proposed to stay below the SSE threshold. The other option, like you have mentioned, is to include the existing boiler in addition to the original calculations. The increase in primarily NOx and CO would not trigger any new requirements, but you would need to provide BACT analysis for the 2002 boiler. Let me know how you would like to proceed and if you have any questions. Thanks, Dungan On Tue, Jan 28, 2025 at 8:41 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…180/385 Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…181/385 On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. Let me know if you have any other questions or concerns. Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…182/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…183/385 Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…184/385 Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…185/385 Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…186/385 Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…187/385 Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…188/385 Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…189/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…190/385 FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…191/385 Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…192/385 Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…193/385 project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…194/385 I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…195/385 paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…196/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…197/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…198/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…199/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…200/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…201/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…202/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…203/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…204/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…205/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…206/385 M: (385) 290-2474 airquality.utah.gov Dungan Adams <dunganadams@utah.gov>Tue, Feb 4, 2025 at 11:40 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Bethany, KPL will need to include the boiler in the new NOI application if they want to use it as a backup once production increases and the new dryer is added. The Small Source Exemption (SSE) for the boiler at reduced production will be replaced by the Approval Order (AO) for the full production sawmill when it is approved. KPL can either include emission calculations and BACT analysis for the boiler or remove the boiler once the AO is approved-- it is not possible to keep the SSE for the boiler alongside the AO for the full production sawmill since both operate at the same location. I just received KPL's SSE application and will review it shortly. Thanks, Dungan On Fri, Jan 31, 2025 at 9:26 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, We submitted the minor source exemption information yesterday with limited production and use for the boiler. I am preparing the updated application with the dryer included now. I think we discussed this, but I just want to clarify – can we keep the minor source exemption for just the boiler itself and have it as a backup after we get the permit for full production with the dryer? I think you said that if we want to do that, we need to include it in the overall emissions and do a RACT analysis on it, but I want to just make sure before I do it. Thanks for your help with this! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, January 28, 2025 10:03 AM To: Bethany Moffat <bmoffat@air-resource.com> 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…207/385 Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, If you intend to exclusively operate the boiler at the new site (and not dry, saw, plane, etc. any wood), you could limit the operation of the boiler to less than 7000 hours per year, and remain a Small Source as you have suggested. However, my understanding is the boiler would be used for wood drying and the wood drying process will result in VOC emissions. There would also be emissions from sawing, planing, etc. to prepare the wood for drying. If you can provide emission calculations that show the new site-wide emissions are less than 5 tons per year of all criteria pollutants with operation and production limits, I can issue a Small Source Exemption (SSE) for the new site. The exemption process is much faster, but you would likely need to operate at less than a third of the scale that was originally proposed to stay below the SSE threshold. The other option, like you have mentioned, is to include the existing boiler in addition to the original calculations. The increase in primarily NOx and CO would not trigger any new requirements, but you would need to provide BACT analysis for the 2002 boiler. Let me know how you would like to proceed and if you have any questions. Thanks, Dungan On Tue, Jan 28, 2025 at 8:41 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…208/385 Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…209/385 On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. Let me know if you have any other questions or concerns. Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…210/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…211/385 Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…212/385 Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…213/385 Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…214/385 Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…215/385 Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…216/385 Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…217/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…218/385 I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…219/385 Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…220/385 - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…221/385 Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…222/385 Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…223/385 Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…224/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…225/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…226/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…227/385 M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…228/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…229/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…230/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…231/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…232/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…233/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…234/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Dungan Adams <dunganadams@utah.gov>Wed, Feb 5, 2025 at 2:53 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: "dave@kingspl.com" <dave@kingspl.com> Hi Bethany, I have a few quick question about the Small Source Exemption (SSE) application submitted January 29, 2025: - Is "Kings Peak Lumber- Panguitch Lumber Mill" still an appropriate name for the facility? The owner/company was listed as Dave Fiala and the name of the site was just listed as "Mill" in the application. Please advise if this facility is going to be named differently than the previous site. - What is the physical location of the new lumber mill? - As written, the emission calculations show that the boiler/kiln has the potential to operate 8,760 hours per year and the source's actual emissions have the potential to be greater than 5 tpy of NOx. Can you remove the part of the emission calculations that suggest 8,760 hours per year operation base all boiler emissions on the 7,000 hours of operation value? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…235/385 Thanks, Dungan On Tue, Feb 4, 2025 at 11:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, KPL will need to include the boiler in the new NOI application if they want to use it as a backup once production increases and the new dryer is added. The Small Source Exemption (SSE) for the boiler at reduced production will be replaced by the Approval Order (AO) for the full production sawmill when it is approved. KPL can either include emission calculations and BACT analysis for the boiler or remove the boiler once the AO is approved-- it is not possible to keep the SSE for the boiler alongside the AO for the full production sawmill since both operate at the same location. I just received KPL's SSE application and will review it shortly. Thanks, Dungan On Fri, Jan 31, 2025 at 9:26 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, We submitted the minor source exemption information yesterday with limited production and use for the boiler. I am preparing the updated application with the dryer included now. I think we discussed this, but I just want to clarify – can we keep the minor source exemption for just the boiler itself and have it as a backup after we get the permit for full production with the dryer? I think you said that if we want to do that, we need to include it in the overall emissions and do a RACT analysis on it, but I want to just make sure before I do it. Thanks for your help with this! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, January 28, 2025 10:03 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…236/385 If you intend to exclusively operate the boiler at the new site (and not dry, saw, plane, etc. any wood), you could limit the operation of the boiler to less than 7000 hours per year, and remain a Small Source as you have suggested. However, my understanding is the boiler would be used for wood drying and the wood drying process will result in VOC emissions. There would also be emissions from sawing, planing, etc. to prepare the wood for drying. If you can provide emission calculations that show the new site-wide emissions are less than 5 tons per year of all criteria pollutants with operation and production limits, I can issue a Small Source Exemption (SSE) for the new site. The exemption process is much faster, but you would likely need to operate at less than a third of the scale that was originally proposed to stay below the SSE threshold. The other option, like you have mentioned, is to include the existing boiler in addition to the original calculations. The increase in primarily NOx and CO would not trigger any new requirements, but you would need to provide BACT analysis for the 2002 boiler. Let me know how you would like to proceed and if you have any questions. Thanks, Dungan On Tue, Jan 28, 2025 at 8:41 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…237/385 Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…238/385 It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. Let me know if you have any other questions or concerns. Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…239/385 Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…240/385 Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…241/385 Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…242/385 Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…243/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP- 42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…244/385 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…245/385 Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…246/385 value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…247/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air- resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…248/385 will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…249/385 Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…250/385 I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…251/385 Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…252/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…253/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…254/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…255/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…256/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…257/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…258/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…259/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…260/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…261/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…262/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…263/385 M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Bethany Moffat <bmoffat@air-resource.com>Thu, Feb 6, 2025 at 8:38 AM To: Dungan Adams <dunganadams@utah.gov>, "dave@kingspl.com" <dave@kingspl.com> Hey Dungan, Dave – do you want to choose a name for the lumber mill? Should it still be: "Kings Peak Lumber- Panguitch Lumber Mill"? The address is 165 N Street, Panguitch, UT 84759. Is that what you need for location or do you want a map too? I will remove all references to 8760 and send the revised version to you shortly. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…264/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, February 5, 2025 2:53 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I have a few quick question about the Small Source Exemption (SSE) application submitted January 29, 2025: - Is "Kings Peak Lumber- Panguitch Lumber Mill" still an appropriate name for the facility? The owner/company was listed as Dave Fiala and the name of the site was just listed as "Mill" in the application. Please advise if this facility is going to be named differently than the previous site. - What is the physical location of the new lumber mill? - As written, the emission calculations show that the boiler/kiln has the potential to operate 8,760 hours per year and the source's actual emissions have the potential to be greater than 5 tpy of NOx. Can you remove the part of the emission calculations that suggest 8,760 hours per year operation base all boiler emissions on the 7,000 hours of operation value? Thanks, Dungan On Tue, Feb 4, 2025 at 11:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, KPL will need to include the boiler in the new NOI application if they want to use it as a backup once production increases and the new dryer is added. The Small Source Exemption (SSE) for the boiler at reduced production will be replaced by the Approval Order (AO) for the full production sawmill when it is approved. KPL can either include emission calculations and BACT analysis for the boiler or remove the boiler once the AO is approved-- it is not possible to keep the SSE for the boiler alongside the AO for the full production sawmill since both operate at the same location. I just received KPL's SSE application and will review it shortly. Thanks, Dungan On Fri, Jan 31, 2025 at 9:26 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, We submitted the minor source exemption information yesterday with limited production and use for the boiler. I am preparing the updated application with the dryer included now. I think we discussed this, but I just want to clarify – can we keep the minor source exemption for just the boiler itself and have it 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…265/385 as a backup after we get the permit for full production with the dryer? I think you said that if we want to do that, we need to include it in the overall emissions and do a RACT analysis on it, but I want to just make sure before I do it. Thanks for your help with this! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, January 28, 2025 10:03 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, If you intend to exclusively operate the boiler at the new site (and not dry, saw, plane, etc. any wood), you could limit the operation of the boiler to less than 7000 hours per year, and remain a Small Source as you have suggested. However, my understanding is the boiler would be used for wood drying and the wood drying process will result in VOC emissions. There would also be emissions from sawing, planing, etc. to prepare the wood for drying. If you can provide emission calculations that show the new site-wide emissions are less than 5 tons per year of all criteria pollutants with operation and production limits, I can issue a Small Source Exemption (SSE) for the new site. The exemption process is much faster, but you would likely need to operate at less than a third of the scale that was originally proposed to stay below the SSE threshold. The other option, like you have mentioned, is to include the existing boiler in addition to the original calculations. The increase in primarily NOx and CO would not trigger any new requirements, but you would need to provide BACT analysis for the 2002 boiler. Let me know how you would like to proceed and if you have any questions. Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…266/385 On Tue, Jan 28, 2025 at 8:41 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…267/385 Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. Let me know if you have any other questions or concerns. Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…268/385 On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…269/385 I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…270/385 On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…271/385 Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…272/385 Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP- 42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…273/385 excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…274/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…275/385 I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…276/385 required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…277/385 improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air- resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…278/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…279/385 Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…280/385 Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…281/385 Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…282/385 M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…283/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…284/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…285/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…286/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…287/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…288/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…289/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…290/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…291/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…292/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…293/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov Bethany Moffat <bmoffat@air-resource.com>Thu, Feb 6, 2025 at 8:51 AM To: Dungan Adams <dunganadams@utah.gov> Cc: "dave@kingspl.com" <dave@kingspl.com> Here are the emissions calculations with the just the 7000 hours included. Thanks! Bethany Moffat 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…294/385 Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, February 5, 2025 2:53 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I have a few quick question about the Small Source Exemption (SSE) application submitted January 29, 2025: - Is "Kings Peak Lumber- Panguitch Lumber Mill" still an appropriate name for the facility? The owner/company was listed as Dave Fiala and the name of the site was just listed as "Mill" in the application. Please advise if this facility is going to be named differently than the previous site. - What is the physical location of the new lumber mill? - As written, the emission calculations show that the boiler/kiln has the potential to operate 8,760 hours per year and the source's actual emissions have the potential to be greater than 5 tpy of NOx. Can you remove the part of the emission calculations that suggest 8,760 hours per year operation base all boiler emissions on the 7,000 hours of operation value? Thanks, Dungan On Tue, Feb 4, 2025 at 11:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, KPL will need to include the boiler in the new NOI application if they want to use it as a backup once production increases and the new dryer is added. The Small Source Exemption (SSE) for the boiler at reduced production will be replaced by the Approval Order (AO) for the full production sawmill when it is approved. KPL can either include emission calculations and BACT analysis for the boiler or remove the boiler once the AO is approved-- it is not possible to keep the SSE for the boiler alongside the AO for the full production sawmill since both operate at the same location. I just received KPL's SSE application and will review it shortly. Thanks, Dungan On Fri, Jan 31, 2025 at 9:26 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…295/385 Hey Dungan, We submitted the minor source exemption information yesterday with limited production and use for the boiler. I am preparing the updated application with the dryer included now. I think we discussed this, but I just want to clarify – can we keep the minor source exemption for just the boiler itself and have it as a backup after we get the permit for full production with the dryer? I think you said that if we want to do that, we need to include it in the overall emissions and do a RACT analysis on it, but I want to just make sure before I do it. Thanks for your help with this! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, January 28, 2025 10:03 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, If you intend to exclusively operate the boiler at the new site (and not dry, saw, plane, etc. any wood), you could limit the operation of the boiler to less than 7000 hours per year, and remain a Small Source as you have suggested. However, my understanding is the boiler would be used for wood drying and the wood drying process will result in VOC emissions. There would also be emissions from sawing, planing, etc. to prepare the wood for drying. If you can provide emission calculations that show the new site-wide emissions are less than 5 tons per year of all criteria pollutants with operation and production limits, I can issue a Small Source Exemption (SSE) for the new site. The exemption process is much faster, but you would likely need to operate at less than a third of the scale that was originally proposed to stay below the SSE threshold. The other option, like you have mentioned, is to include the existing boiler in addition to the original calculations. The increase in primarily NOx and CO would not trigger any new requirements, but you would need to provide BACT analysis for the 2002 boiler. Let me know how you would like to proceed and if you have any questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…296/385 Thanks, Dungan On Tue, Jan 28, 2025 at 8:41 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…297/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…298/385 Let me know if you have any other questions or concerns. Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…299/385 Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…300/385 Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…301/385 Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…302/385 Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…303/385 42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…304/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…305/385 Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…306/385 I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…307/385 To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air- resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! Bethany Moffat Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…308/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…309/385 Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…310/385 the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…311/385 To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…312/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…313/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…314/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…315/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…316/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…317/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…318/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…319/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…320/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…321/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…322/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…323/385 M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2 attachments ~WRD0003.jpg 1K 2025 0206 KPL Lumber Revised for Limits.xlsx 56K Bethany Moffat <bmoffat@air-resource.com>Thu, Feb 6, 2025 at 9:01 AM To: Dungan Adams <dunganadams@utah.gov> Cc: "dave@kingspl.com" <dave@kingspl.com> I just found a couple of labels that I needed to change. Please use this one. Thanks! 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…324/385 Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, February 5, 2025 2:53 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I have a few quick question about the Small Source Exemption (SSE) application submitted January 29, 2025: - Is "Kings Peak Lumber- Panguitch Lumber Mill" still an appropriate name for the facility? The owner/company was listed as Dave Fiala and the name of the site was just listed as "Mill" in the application. Please advise if this facility is going to be named differently than the previous site. - What is the physical location of the new lumber mill? - As written, the emission calculations show that the boiler/kiln has the potential to operate 8,760 hours per year and the source's actual emissions have the potential to be greater than 5 tpy of NOx. Can you remove the part of the emission calculations that suggest 8,760 hours per year operation base all boiler emissions on the 7,000 hours of operation value? Thanks, Dungan On Tue, Feb 4, 2025 at 11:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, KPL will need to include the boiler in the new NOI application if they want to use it as a backup once production increases and the new dryer is added. The Small Source Exemption (SSE) for the boiler at reduced production will be replaced by the Approval Order (AO) for the full production sawmill when it is approved. KPL can either include emission calculations and BACT analysis for the boiler or remove the boiler once the AO is approved-- it is not possible to keep the SSE for the boiler alongside the AO for the full production sawmill since both operate at the same location. I just received KPL's SSE application and will review it shortly. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…325/385 Thanks, Dungan On Fri, Jan 31, 2025 at 9:26 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, We submitted the minor source exemption information yesterday with limited production and use for the boiler. I am preparing the updated application with the dryer included now. I think we discussed this, but I just want to clarify – can we keep the minor source exemption for just the boiler itself and have it as a backup after we get the permit for full production with the dryer? I think you said that if we want to do that, we need to include it in the overall emissions and do a RACT analysis on it, but I want to just make sure before I do it. Thanks for your help with this! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, January 28, 2025 10:03 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, If you intend to exclusively operate the boiler at the new site (and not dry, saw, plane, etc. any wood), you could limit the operation of the boiler to less than 7000 hours per year, and remain a Small Source as you have suggested. However, my understanding is the boiler would be used for wood drying and the wood drying process will result in VOC emissions. There would also be emissions from sawing, planing, etc. to prepare the wood for drying. If you can provide emission calculations that show the new site-wide emissions are less than 5 tons per year of all criteria pollutants with operation and production limits, I can issue a Small Source Exemption (SSE) for the new site. The exemption process is much faster, but you would likely need to operate at less than a third of the scale that was originally proposed to stay below the SSE threshold. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…326/385 The other option, like you have mentioned, is to include the existing boiler in addition to the original calculations. The increase in primarily NOx and CO would not trigger any new requirements, but you would need to provide BACT analysis for the 2002 boiler. Let me know how you would like to proceed and if you have any questions. Thanks, Dungan On Tue, Jan 28, 2025 at 8:41 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. Thanks, Bethany Moffat Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…327/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…328/385 demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. Let me know if you have any other questions or concerns. Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…329/385 I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…330/385 With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…331/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…332/385 Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…333/385 mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is the AP- 42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…334/385 Thanks for your help. Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…335/385 Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…336/385 image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…337/385 Bethany, Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air- resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…338/385 Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…339/385 Dungan On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…340/385 Dungan On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…341/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…342/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…343/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…344/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…345/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…346/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…347/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…348/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…349/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…350/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…351/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…352/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…353/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2 attachments ~WRD0005.jpg 1K 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…354/385 2025 0206 KPL Lumber Revised for Limits.xlsx 56K Dave Fiala <dave@kingspl.com>Thu, Feb 6, 2025 at 9:07 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dungan Adams <dunganadams@utah.gov> Let's call it - Kings Peak Lumber LLC Address Physical: 165 N 700 W Panguitch, UT 84759 Address Mailing: PO Box 950 Panguitch, UT 84759 Thanks, Dave Fiala 435.288.9060 On Thu, Feb 6, 2025 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, Dave – do you want to choose a name for the lumber mill? Should it still be: "Kings Peak Lumber- Panguitch Lumber Mill"? The address is 165 N Street, Panguitch, UT 84759. Is that what you need for location or do you want a map too? I will remove all references to 8760 and send the revised version to you shortly. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…355/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, February 5, 2025 2:53 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I have a few quick question about the Small Source Exemption (SSE) application submitted January 29, 2025: - Is "Kings Peak Lumber- Panguitch Lumber Mill" still an appropriate name for the facility? The owner/company was listed as Dave Fiala and the name of the site was just listed as "Mill" in the application. Please advise if this facility is going to be named differently than the previous site. - What is the physical location of the new lumber mill? - As written, the emission calculations show that the boiler/kiln has the potential to operate 8,760 hours per year and the source's actual emissions have the potential to be greater than 5 tpy of NOx. Can you remove the part of the emission calculations that suggest 8,760 hours per year operation base all boiler emissions on the 7,000 hours of operation value? Thanks, Dungan On Tue, Feb 4, 2025 at 11:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, KPL will need to include the boiler in the new NOI application if they want to use it as a backup once production increases and the new dryer is added. The Small Source Exemption (SSE) for the boiler at reduced production will be replaced by the Approval Order (AO) for the full production sawmill when it is approved. KPL can either include emission calculations and BACT analysis for the boiler or remove the boiler once the AO is approved-- it is not possible to keep the SSE for the boiler alongside the AO for the full production sawmill since both operate at the same location. I just received KPL's SSE application and will review it shortly. Thanks, Dungan On Fri, Jan 31, 2025 at 9:26 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…356/385 We submitted the minor source exemption information yesterday with limited production and use for the boiler. I am preparing the updated application with the dryer included now. I think we discussed this, but I just want to clarify – can we keep the minor source exemption for just the boiler itself and have it as a backup after we get the permit for full production with the dryer? I think you said that if we want to do that, we need to include it in the overall emissions and do a RACT analysis on it, but I want to just make sure before I do it. Thanks for your help with this! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, January 28, 2025 10:03 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, If you intend to exclusively operate the boiler at the new site (and not dry, saw, plane, etc. any wood), you could limit the operation of the boiler to less than 7000 hours per year, and remain a Small Source as you have suggested. However, my understanding is the boiler would be used for wood drying and the wood drying process will result in VOC emissions. There would also be emissions from sawing, planing, etc. to prepare the wood for drying. If you can provide emission calculations that show the new site-wide emissions are less than 5 tons per year of all criteria pollutants with operation and production limits, I can issue a Small Source Exemption (SSE) for the new site. The exemption process is much faster, but you would likely need to operate at less than a third of the scale that was originally proposed to stay below the SSE threshold. The other option, like you have mentioned, is to include the existing boiler in addition to the original calculations. The increase in primarily NOx and CO would not trigger any new requirements, but you would need to provide BACT analysis for the 2002 boiler. Let me know how you would like to proceed and if you have any questions. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…357/385 Thanks, Dungan On Tue, Jan 28, 2025 at 8:41 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Hey Dungan, It looks like the existing boiler is just under 13 MMbtu/hr, which makes it not insignificant at 8760 hours per year. Can we limit the hours to keep the boiler insignificant? It would be under 5tpy of NOx even at 7000 hours of run time. Also, it was manufactured in 2002. Otherwise, the emissions with the old boiler, the new dryer, the new location and the wood drying are looking like this: Does it still make sense to permit the old boiler first or should we just do the one thing in one permitting action? Let me know if it’s easier to discuss over the phone or in a screenshare call. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…358/385 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, January 22, 2025 12:39 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Do you have any updates on how KPL is planning to proceed with this project? Thanks, Dungan On Thu, Dec 12, 2024 at 12:15 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, You would still need to include the existing boiler's combustion and wood drying emissions into the permit. While the VOC emissions from wood drying from the new kiln are likely going to be larger than the VOC emissions from wood drying from the existing boiler, if you intend to operate both under the same permit, both pieces of equipment and their respective emissions would need to be included in the permit. The potential emissions from the entire facility need to be calculated. One option would be to permit the existing boiler and its wood drying emissions and then modify the permit to account for equipment and emission changes once the new dry kiln is built. Another option would be to include both the existing boiler and the new dry kiln in the same permit. However, it won't be possible to permit the new dry kiln and have the existing boiler's wood drying emissions count towards those that are expected to be produced from the dry kiln. I still think the best option is to keep emissions at the current facility under 5 tpy through operation/production restrictions until the new kiln is built. Once the new kiln is up and running, remove the old boiler from the site because I am anticipating it will have difficulties meeting BACT. Does that make sense? If I misinterpreted your question please let me know. It's tough to estimate exactly how long it will take to get an Approval Order issued, but I have already done a good bit of work on this project prior to the changes we discussed yesterday. Once I have the information we spoke about, it shouldn't take me long to get this project sent for internal reviews. Normally I estimate the internal review process takes ~1 month and then the project enters a 30-day public comment period. A good time frame would be 2-3 months from the date I receive all the information I need. I don't think the "stack testing or manufacturer guarantee" condition you have requested will be possible. We don't like to include conditions with that type of flexibility in order to keep permits concise and to ease the jobs of our compliance division. I can check with my manager just to be sure. Regarding the stack testing; because the CO and VOC emissions at the facility are low, the source would only be required to conduct initial stack testing that shows emissions are below the rate used for emission calculations. After the source has demonstrated compliance with an initial stack test, we could modify the permit to remove the future stack testing conditions. That being said, my plan is still to justify BACT for the kiln without stack testing for CO and VOCs. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…359/385 Let me know if you have any other questions or concerns. Thanks, Dungan On Thu, Dec 12, 2024 at 9:12 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! I was thinking about this more after we talked last night. Since most of the VOC is coming from the wood drying process, we should be covered on that once the new permit is issued, correct? How long do you think that would take? Also, I’m wondering if the permit could say something like, “These emission factors are to be used and either verified by a stack test or manufacturer guarantee” so that we can get the permit issued and then work on getting the guarantee with the manufacturer over the next few months while the kiln is being built? Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, December 11, 2024 4:25 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I wasn't able to find an Approval Order (AO) associated with K&D Forest Products' Panguitch Sawmill. However, the name pulled up an empty file in our permitting software which suggests that an AO was issued at some point. I'll keep searching and hopefully find something. Thanks, Dungan On Tue, Dec 10, 2024 at 3:25 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I can meet tomorrow at 3pm MT if that works for you. I will send a meeting invitation momentarily. Thanks, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…360/385 Dungan On Tue, Dec 10, 2024 at 3:01 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I don’t think we need to go through the details of the changes. As far as the project itself, we would like to schedule a meeting with you to discuss some changes. I am still working on the emission rate guarantee for the kiln, but it’s moving very slowly. If you can check to see if stack testing is required if we use AP42 emission factors, that would be great. Do you have time to meet tomorrow after 2:30 pm MT or Thursday at 8am or after 12pm? We also have time Monday, Tuesday or Wednesday next week. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, December 10, 2024 1:08 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: dave@kingspl.com Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, Sorry for the delayed response. Could you give me an update on the status of this project and any potential changes I need to be aware of? I have looked through the site map and everything looks good. I did make a couple of changes to the spreadsheet (2024 1104 KP Lumber) you attached. The equations for the round trip road length, hourly VMT, and annual VMT have all been corrected slightly, however the PM10 and PM2.5 emissions are similar. I have attached the updated spreadsheet for you to review and I am happy to explain the changes I made in more detail if that would be helpful. With the haul roads and loader routes finalized, the only thing holding up the project is justification for the 24 MMBtu/hr dryer emission rates. Have you heard anything from the manufacturer? I am okay using the 30 ppm NOx rate listed in the dry kiln information sheet. If you are really struggling to get CO and VOC values I think we can probably move forward using AP-42. I will check with my manager to see if stack testing would be required for either of these. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…361/385 Let me know if you have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 2:44 PM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I did not cancel the project, I apologize if my response caused any confusion. Thanks for including Dave's updated email contact and providing the update about the vendor emission guarantee. I will review the haul road and loader route documents and let you know if I have any questions. Thanks, Dungan On Mon, Nov 4, 2024 at 1:07 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, I didn’t mean cancel the project. Please see the attached updated emissions and measurements for the roads. Also, please note that Dave has a new email address: dave@kingspl.com. I’m still working on an emissions guarantee from the burner vendor, but I’ve been told that they are working on it. Thanks for your help, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, November 4, 2024 11:57 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…362/385 Hi Bethany, Please elaborate on the changes to the project. By hold off, do you mean you want me to cancel the permitting project? Thanks, Dungan On Tue, Oct 29, 2024 at 4:44 PM Bethany Moffat <bmoffat@air-resource.com> wrote: Hi Dungan, Dave and I nailed down the haul road routes but not the loader routes. I think this project has had some changes outside of permitting though and maybe we should hold off on it for now? Dave – do you have any thoughts? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, October 29, 2024 8:48 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am following up about the haul road and loader route estimates for this project. Have you had the chance to review any updates with Dave? Thanks, Dungan On Wed, Oct 9, 2024 at 11:49 AM Dungan Adams <dunganadams@utah.gov> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…363/385 Hi Bethany, Do you have any update on this project? Have you been able to confirm the haul roads / loader routes / site map with Dave? Thanks, Dungan On Thu, Sep 26, 2024 at 9:16 AM Dungan Adams <dunganadams@utah.gov> wrote: Sounds good, thanks for the update. -Dungan On Thu, Sep 26, 2024 at 8:06 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan! Everything is matching now! I think Dave is out of town this week because I haven’t heard back from him, but I made overlays of the property on google earth and once he reviews those then I’ll get this updated and back to you. Thanks again! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 1:04 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent I think part of the issue is W, the mean vehicle weight. In your spreadsheet you had the empty truck weight as 15 tons, the estimated log load weight as 42.5 tons, and the mean vehicle weight as 28.75 tons (the average of these two). If 42.5 tons is the estimated weight of only the load, then the mean vehicle weight should be (Empty Truck + Load + Empty Truck) / 2 = (15 + 42.5 + 15) / 2 = 36.25 tons. The other issue is I realized that the DAQ haul road/loader route spreadsheets do not account for silt content. The DAQ spreadsheets use 4.8% silt content which is 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…364/385 the AP-42 value for sand and gravel processing. As 4.8% is the lower end of the silt content range for lumber sawmills listed in AP-42, I am okay using this value. If you change your spreadsheet silt value to 4.8% and fix the mean vehicle weight equation, you should be able to get both to produce the same uncontrolled emission factors. The last thing is I think I had an incorrect "Weight of Load" in the haul road excel sheet I sent to you on September 26th. I had this as 28 tons, when I believe it should be 42.5 tons. When I made these changes I got an uncontrolled PM10 emission factor of 2.02 lb/VMT for both spreadsheets. If this doesn't work, give me a call at (385) 290-2474 and we can figure out what isn't lining up. Thanks, Dungan On Wed, Sep 25, 2024 at 11:54 AM Bethany Moffat <bmoffat@air-resource.com> wrote: Thanks, Dungan. This is helpful, but I’m still struggling to get my numbers to match yours. For this: Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) These are the numbers I’m using: 1.5*(8.4/12)^0.9*(28/3)^0.45=2.96 (roughly – excel says 3.01 using all of the decimal places) lb/PM10 per VMT uncontrolled but the spreadsheet is saying it should be 1.82 lb/VMT Am I missing something? Thanks for your help. Bethany Moffat Compliance Manager 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…365/385 bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, September 25, 2024 9:24 AM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am not supposed to share the unlocked version of the spreadsheets, but I can explain the calculations as best I can. The haul road and loader routes are both calculated the same way: Annual Vehicle Miles Traveled = (Annual Production / Weight of Load) * (Haul Road One-Way Length / 5280 ft) * 2 Uncontrolled Emission Factor = k * (s/12)^a * (W/3)^b k = 1.5 for PM10, 0.15 for PM2.5 a = 0.9 for both b = 0.45 for both s = silt content % (8.4% for lumber sawmills) W = mean vehicle weight (average of empty + loaded) Controlled Emission Factor = Uncontrolled Emission Factor * (1 - Control Efficiency) Total Annual Emissions = (Controlled Emission Factor * Annual VMT) / 2000 The uncontrolled emission factor calculation is from AP-42 Section 13.2.2. Let me know if you have any further questions about calculations. Thanks, Dungan On Wed, Sep 25, 2024 at 8:38 AM Bethany Moffat <bmoffat@air-resource.com> wrote: 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…366/385 Hey Dungan, I’m working with Dave to get the haul roads and loader routes updated. Would you possibly be able to share the spreadsheets that you sent in an unlocked format so that I can add them to the site total spreadsheet? I tried to recreate them but I’m struggling to match some of the formulas. If you can’t share them unlocked, would it be possible to share screenshots of the formulas? Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Monday, September 16, 2024 12:51 PM To: Bethany Moffat <bmoffat@air-resource.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, That sounds good. I have a few questions/comments about haul roads and loader routes. BACT for almost all the sources I have permitted is at least basic watering. UAC Code R307-205-4 requires sources to maintain visible opacity from fugitive emissions at or below 20%, and water application is often required to maintain this value. Unless you have more justification that wasn't included in the NOI, BACT for the haul roads and loader routes will be the application of water to maintain an opacity of 20%. I'd also like to discuss haul road and loader route length. I've attached an image of the site map overlaid onto Google Earth with what I am anticipating the haul road might be. It looks like it will follow US Hwy 89 and then will have to route to the planing/sawing area (Or maybe the log decks?). Based on the attached image, I think the haul road length will be longer than 0.14 miles round trip. The route shown on the attached image is 0.42 miles round trip, but if trucks go to the log decks it will be a bit longer. Alternatively, I think that 2.8 miles round trip for a loader route seems like an overestimate given the size of the site. Could you explain how you arrived at the respective lengths? I could definitely be missing something and just want to understand the anticipated layout as best I can. 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…367/385 I've attached two DAQ excel spreadsheets that you might find helpful for emission calculations. The DAQ prefers to base fugitive emissions on annual production instead of # of trucks per day so that a haul truck/loader per day limit isn't required in the permit. Using 60,000 tons per year of raw lumber production for these makes sense to me, as it would be the maximum allowable lumber processed on site. I've tried to fill them in with the emission calculation information that you provided. Let me know if you have any questions. Thanks, Dungan On Mon, Sep 16, 2024 at 8:42 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. I wanted to give you an update: You’re probably correct on the FGR. I thought that the description seemed like Flue Gas Recirculation but since it’s not going directly back into the burner then that’s probably not actually FGR. On the emission guarantees – we are working with the kiln and burner manufacturers to get these. It will probably take a couple of weeks though. I will send over what we get back from them. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 1:46 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Bethany, 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…368/385 Thanks for sending this over. Is there any mention specifically of flue gas recirculation? Flue gas recirculation would take the flue gas from the burner and directly recirculate it back through the combustion chamber of the burner. To me the recirculation system in the document you attached seems more like one specific to a dry kiln and not FGR control. That being said, the KINEDIZER spec sheet you attached stated that the efficiency of the burner can be improved with FGR--so if the actual burners are equipped with FGR I can proceed with that control but I do not think the FGR system would need to be paused to vent moisture/pressure. Does that make sense? As for the manufacturer rates-- I would at least like to see CO. If the manufacturer is unable to provide VOCs, you can continue to use the AP-42 value. If you are unable to get a response from the manufacturer a second time, we could move forward but we would need to require stack testing for CO at the AP-42 rate. For now, I will finish the BACT review and draft permit with the assumption that you are eventually (hopefully) going to get manufacturer emission rates for CO and VOC. Assuming they respond to your request, when you do get the manufacturer rates please update the site-wide emissions calculations with the manufacturer ppm rates. I won't be able to finalize the draft and send it for my manager's approval without either the manufacturer rates or the decision to stack test at the AP-42 rate. Let me know if you have any questions. Thanks, Dungan On Tue, Sep 10, 2024 at 12:44 PM Bethany Moffat <bmoffat@air- resource.com> wrote: Hi Dungan, The kiln is designed to have FGR but the air will sometimes need to be vented outside to release moisture in the air. I have attached a shortened version of the specifications that are from the kiln manufacturer and highlighted the section that states that the burners will have 30ppm NOx. The following 2 pages detail the flue gas recirculation, so those might be helpful to you as well. The kiln was originally designed for a different client in 2018 and Kings Peak is purchasing the kiln used. I contacted the burner manufacturer back in July and requested guarantees for NOx, CO, and VOC and never received a response. I will reach out to them again though. Are the guarantees necessary to move forward with the project? Thanks! 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…369/385 Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Tuesday, September 10, 2024 12:22 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, I am writing up the BACT review for this project and I have some questions about the burners that KP Lumber will use for the dry kiln: - The NOI mentions that the burners are equipped with FGR, but the control will not operate all of the time. Can you explain why it is not possible to use the FGR control for all periods the burners are in use? - Page 12 of the NOI lists the NOx ppm for the dryer at 30 ppm. Is this value from a manufacturer guarantee? I did not see any burner manufacturer emission rates in the NOI, but I could have missed them. I would like to use manufacturer emission rates for NOx, CO, and VOC if you have these values or quotes from the manufacturer-- the AP-42 values are generic and not necessarily a good estimate. Thanks, Dungan On Thu, Aug 22, 2024 at 10:47 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, Once I finish writing the draft permit, the internal review process can take about a month and then the project will go out for a 30-day public comment period. At this time, it's hard to give a precise estimate of when Kings Peak Lumber will receive their Approval Order (AO) but I will keep you updated as the project moves forward. Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…370/385 On Thu, Aug 22, 2024 at 8:51 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Great! Thank you for the update. Do you have a ballpark estimate on how long the permit will take? Thanks again, Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 21, 2024 4:28 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Re: Kings Peak Lumber Noce of Intent Hi Bethany, The process explanation and updated emission calculations look good and still keep you below all modeling thresholds. I will move forward with the project and let you know if I have any other questions. Thanks, Dungan On Mon, Aug 19, 2024 at 8:40 AM Dungan Adams <dunganadams@utah.gov> wrote: Hi Bethany, I was out of town this past week, I apologize for the delay in getting back to you. I will review your response and updated calculations shortly and will let you know if I have any follow up questions. Thanks, Dungan 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…371/385 On Mon, Aug 19, 2024 at 8:05 AM Bethany Moffat <bmoffat@air- resource.com> wrote: Good Morning, Dungan. Dave let me know that there would be additional trucks at the facility after I sent you the last update. Please see the attached calculations, updated for 6 log trucks per day. Thanks! Bethany Moffat Compliance Manager bmoffat@air-resource.com 303-981-0607 From: Bethany Moffat Sent: Tuesday, August 13, 2024 8:38 AM To: 'Dungan Adams' <dunganadams@utah.gov> Cc: Dave Fiala <dave@kplumber.com> Subject: RE: Kings Peak Lumber Noce of Intent Good Morning Dungan, I have added log bucking and debarking to the fugitive emissions. I originally thought they were enclosed but Dave and I discussed the details more yesterday and it sounds like they are not. The planning process is in its own building and will have a separate cyclone. No emission factor exists for this piece of the process, so I have assumed the same emissions as sawing, which is an overestimate. The logs will be transported between buildings by a front-end loader, and I have added emissions for this process in the attached spreadsheet. Please take a look and let me know what other questions you have. Thanks, Bethany Moffat Compliance Manager bmoffat@air-resource.com 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…372/385 303-981-0607 From: Dungan Adams <dunganadams@utah.gov> Sent: Wednesday, August 7, 2024 4:58 PM To: Bethany Moffat <bmoffat@air-resource.com> Cc: Dave Fiala <dave@kplumber.com> Subject: Kings Peak Lumber Noce of Intent Hi Bethany, The Utah Division of Air Quality (DAQ) has received Kings Peak Lumber's NOI for a new sawmill. I have started reviewing the NOI and I have a couple of initial questions. - Are the PM emissions from log bucking and debarking fugitive? From the description in the NOI it seems like these processes take place outside of the enclosed buildings and would not pass through a stack. - Can you please provide a more detailed explanation of how the sawing and planning process will work? In the site diagram, I see a sawmill building and a planning building, but in the emission calculations I see only emissions from sawing and emissions from pneumatically conveyed material through the cyclone to the bin. Does the cyclone control emissions from both buildings? Are there two cyclones, one for each building? - How will logs be transported between buildings, storage areas, etc.? If this transfer is done using some type of mobile equipment on a non-paved surface then you need to include emissions from this process. Thanks, Dungan -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…373/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…374/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…375/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…376/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…377/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…378/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…379/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…380/385 -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…381/385 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…382/385 Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…383/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…384/385 Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov -- Dungan Adams Environmental Engineer | Minor NSR Section M: (385) 290-2474 airquality.utah.gov 2/6/25, 9:49 AM State of Utah Mail - Kings Peak Lumber Notice of Intent https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r588015884026763623&simpl=msg-a:r-619710111474…385/385 Dungan Adams <dunganadams@utah.gov> Fwd: Small Source Exemption 1 message Alan Humpherys <ahumpherys@utah.gov>Wed, Feb 5, 2025 at 7:05 AM To: Dungan Adams <dunganadams@utah.gov> Dungan, Can you please process this SSE? Site ID: 16250 Peer: Tim Thanks, Alan ---------- Forwarded message --------- From: <noreply@qemailserver.com> Date: Wed, Jan 29, 2025 at 3:57 PM Subject: Small Source Exemption To: <ahumpherys@utah.gov> The following small source exemeption was submitted, please go into qualtrics and print off the PDF and forward to Alan. Recipient Data: Time Finished: 2025-01-29 15:57:35 MST IP: 208.92.185.194 ResponseID: R_1OjIIZFisLM00aa Link to View Results: Click Here URL to View Results: https://utahgov.iad1.qualtrics.com/apps/single-response-reports/reports/ D35w4m1uXz33y5UykBM-ZACrDJl7mocFwYk5YG%2EP47on-lmEia1-Uzso3FcXwxhApxyYlIOcDh0uIYQZ3R O31krxS1UmwBH8LwGcDJD5qYy3S-0qYNKmqUZP%2EF6obq7lOeC0MG0TGchfPG2Abdy3n EZEM9NBiYc9vsnpdA6LruMd%2E9ccPO5-L4B6rVCmRjjYJ%2Ewdp0Xsov4MPoOX5zwqtzkJnoGgSc dEU9TM09iDcFb90u-asV-w1eyXzNOKlfgHvH9YOKjshRO7fEMObxDa5HI%2EMW1- XqeinV3OVXkB6soBN1P7zQ1ScmGUTcmHKJsll6-xW-Wq9VRwpYx4obuVww Response Summary: Please fill out the following contact information: Name Site Contact Dave Fiala Site Mill Owner Dave Fiala Mailing Address Site Contact PO Box 950 Site PO Box 950 Owner PO Box 950 Mailing Address 2 Site Contact NA Site NA Owner NA City Site Contact Panguitch Site Panguitch Owner Panguitch 2/5/25, 2:22 PM State of Utah Mail - Fwd: Small Source Exemption https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1823226564524811599&simpl=msg-f:1823226564524811599 1/3 State Site Contact Utah Site Utah Owner Utah Zip Code Site Contact 84759 Site 84759 Owner 84759 Phone Site Contact 435-288-9060 Site 435-710-5000 Owner 435-288-9060 Fax Site Contact NA Site NA Owner NA Email Site Contact dave@kingspl.com Site dave@kingspl.com Owner dave@kingspl.com County the Site is located in: Garfield County Briefly describe the process including the end products, raw materials, and process equipment used. Raw wood will be brought in on trucks and then bucked, debarked, sawed and dried. A boiler will be used to dry the wood. Log bucking and debarking will be done outside of the sawmill building. Sawing, conveying and chipping will be done inside an enclosed building. Sawdust and wood ships will be conveyed to an enclosed chipper and captured in a bin. The bin material is then loaded into a truck for use by a third party offset. List emission units 13MMBtu/hr boiler, log bucking and debarking machines, conveyors and saw are all process equipment. A front end loader will also be used. List any pollution control equipment Sawing, conveying and chipping will be done inside an enclosed building. Please include Annual Emission Rates calculation spreadsheet. https://utahgov.co1.qualtrics.com/WRQualtricsControlPanel/File.php?F=F_9NdoiWgrOjJF0e5 Contact Information: (person filling out form - signature will be required) Name Dave Fiala Title CEO Phone 435-288-9060 Date 01/29/2025 By signing below, I hereby certify that the information and data submitted in this notice fully d... https://utahgov.co1.qualtrics.com/WRQualtricsControlPanel/File.php?F=F_2wG24qnQRZQ1mHC -- Alan Humpherys Manager | Minor NSR Section P: (385) 306-6520 F: (801) 536-4099 airquality.utah.gov 2/5/25, 2:22 PM State of Utah Mail - Fwd: Small Source Exemption https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1823226564524811599&simpl=msg-f:1823226564524811599 2/3 Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. 2025_200128_20KPL_20Lumber_20Revised_20for_20Limits.xlsx 55K 2/5/25, 2:22 PM State of Utah Mail - Fwd: Small Source Exemption https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1823226564524811599&simpl=msg-f:1823226564524811599 3/3 Response Summary: To be eligible businesses shall not do any of the follow: 1) Emit more than 5 tons per year of each of the following pollutants: Sulfur Dioxide (SO2), Carbon Monoxide (CO), Nitrogen Oxides (NOx), Particulate Matter (PM10), Ozone (O3), or Volatile Organic Compounds (VOCs). 2) Emit more than 500 lbs/yr of any single Hazardous Air Pollutant (HAP), and emit more than 2000 lbs/yr of any combination of HAPs 3) Emit more than 500 lbs/yr of any combination of air contaminants not listed in 1 or 2 A copy of this registration notice and worksheets are required on site to verify permit exemption status. Please be aware a the Small Source Exemption ONLY exempts the site from the air permitting requirements of R307- 401-5 thru R307-401-8 of the Utah Administrative Code, all other air quality regulations still apply. Q4. Please fill out the following contact information: Site Contact Site Owner Name Dave Fiala Mill Dave Fiala Mailing Address PO Box 950 PO Box 950 PO Box 950 Mailing Address 2 NA NA NA City Panguitch Panguitch Panguitch State Utah Utah Utah Zip Code 84759 84759 84759 Phone 435-288-9060 435-710-5000 435-288-9060 Fax NA NA NA Email dave@kingspl.com dave@kingspl.com dave@kingspl.com Q5. County the Site is located in: Garfield County Q6. Briefly describe the process including the end products, raw materials, and process equipment used. Raw wood will be brought in on trucks and then bucked, debarked, sawed and dried. A boiler will be used to dry the wood. Log bucking and debarking will be done outside of the sawmill building. Sawing, conveying and chipping will be done inside an enclosed building. Sawdust and wood ships will be conveyed to an enclosed chipper and captured in a bin. The bin material is then loaded into a truck for use by a third party offset. Q7. List emission units 13MMBtu/hr boiler, log bucking and debarking machines, conveyors and saw are all process equipment. A front end loader will also be used. Q8. List any pollution control equipment Sawing, conveying and chipping will be done inside an enclosed building. Q9. Please include Annual Emission Rates calculation spreadsheet. [Click here] Q11. Contact Information: (person filling out form - signature will be required) Name Dave Fiala Title CEO Phone 435-288-9060 Date 01/29/2025 Q10. By signing below, I hereby certify that the information and data submitted in this notice fully describes this site and ONLY this site. The information provide is true, accurate, and complete to the best of my knowledge. I understand that I am responsible for determining whether the site remain eligible for this exemption before making operational or process changes in the future, and agree to notify the Division of Air Quality when this site is not longer eligible for this exemption. (Signature of Owner/Manager) [Click here] Embedded Data: N/A