DAQ-2024-009134

DAQE-AN160760002-24

{{$d1 }}

Lonnie Allen
MegaDiamond
275 West 2230 North
Provo, UT 84604
[e-mail]

Dear Mr. Allen:

Re: Approval Order: Minor Modification to Approval Order DAQE-AN160760001-22 to Add
Equipment and Update Potential to Emit
Project Number: N160760002

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August
22, 2023. MegaDiamond must comply with the requirements of this AO, all applicable state requirements
(R307), and Federal Standards.

The project engineer for this action is Dungan Adams, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well
as the DAQE number shown on the upper right-hand corner of this letter. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DA:jg

cc: Utah County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

July 9, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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

APPROVAL ORDER
DAQE-AN160760002-24
Minor Modification to Approval Order DAQE-AN160760001-22 to
Add Equipment and Update Potential to Emit

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

Issued to
MegaDiamond - Drill Bit Manufacturing Plant, South Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

July 9, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-AN160760002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
MegaDiamond MegaDiamond - Drill Bit Manufacturing Plant,
South Facility

Mailing Address Physical Address
275 West 2230 North 2185 Tracy Hall Parkway
Provo, UT 84604 Provo, UT 84606

Source Contact UTM Coordinates
Name: Lonnie Allen 446,504 m Easting
Phone: [phone],450,470 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 3544 (Special Dies & Tools, Die Sets, Jigs & Fixtures, & Industrial Molds)

SOURCE INFORMATION
General Description
MegaDiamond is the owner/operator of a drill bit manufacturing plant in Provo, Utah County.
MegaDiamond designs, manufactures, and markets ultra-hard materials that are used in cutting tools,
construction, oil and gas drilling, and mining applications. Electrically powered, multidirectional
hydraulic presses are used to produce polycrystalline diamond and cubic boron nitrate-cutting heads
under high-pressure conditions. Abrasive blasting cabinets are used for surface preparation and finishing
operations. Each cabinet vents to a baghouse filter. MegaDiamond operates a granite cutter and multiple
grinders for product shaping and finishing.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA
Utah County
Airs Source Size: B

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-AN160760002-24
Page 4

Project Description
MegaDiamond is requesting the following modifications to its Approval Order (AO):

1. Add two (2) abrasive blasting units to the blaster grinder room.
2. Update the abrasive blasting process.
3. Increase abrasive blast media usage to 13,016 tons per year.
4. Update the solvent cleaning process.
5. Remove three (3) Centor furnaces (listed as Equipment ID 11.A.10 in AO DAQE-AN160760001-22).
6. Update site-wide emission calculations and potential to emit.

SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 3249.58 3361.00
Carbon Monoxide 2.26 2.37
Nitrogen Oxides 2.67 2.80
Particulate Matter - PM10 9.93 12.88
Particulate Matter - PM2.5 3.58 5.97
Sulfur Dioxide 0.02 0.02
Volatile Organic Compounds -1.05 1.73

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 102 106
Change (TPY) Total (TPY)
Total HAPs -1.15 0.05

SECTION I: GENERAL PROVISIONS

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

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

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

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

DAQE-AN160760002-24
Page 5

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All maintenance
performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 MegaDiamond - South Facility

II.A.2 Three (3) Abrasive Blasting Cabinets (Two (2) New)
Blaster Grinder Room
Control: Blaster Grinder Baghouse, 4,000 acfm
Manufacturer: Kelco

II.A.3 One (1) Abrasive Blasting Cabinet
Glass Bead Blaster
Control: Glass Bead Baghouse, 250 acfm
Vents Internally

II.A.4 Three (3) Abrasive Blasting Cabinets
Asphalt Finishing
Control: Asphalt Finishing Baghouse
Manufacturer: Guyson
Vents Internally

II.A.5 Granite Cutter
Control: Baghouse, 4,500 acfm

II.A.6 Grinding Operations
Various Grinders
Control: Two (2) Baghouses, 4,000 acfm each
One (1) Vents Internally

DAQE-AN160760002-24
Page 6

II.A.7 Solvent Cleaning Process (New)
Isopropanol is used for cleaning and surface preparation.
Vents Internally

II.A.8 One (1) Solvent-Based Parts Washer

II.A.9 Emergency Generator
Rating: 10 kW (13.4 hp)
Fuel: Natural Gas
Manufacturer Date: 1999

II.A.10 Various Comfort Heaters
Fuel: Natural Gas
Rating: All less than 5 MMBtu/hr

II.A.11 Cubic Presses
Electric Hydraulic Presses
***Listed for informational purposes only.

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions to exceed the following limits:

A. All baghouse and fabric filter systems - 10%.

B. Natural gas emergency generator - 10%.

C. All other points - 20% opacity.

[R307-305-3, R307-401-8]

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

II.B.2 VOC Requirements
II.B.2.a The owner/operator shall not emit any HAPs from evaporative sources (painting, printing,
coating, and/or cleaning) on site. [R307-401-8]

II.B.2.b The owner/operator shall not emit more than the following from evaporative sources on site:

1.20 tons per rolling 12-month period of isopropanol.

1.57 tons per rolling 12-month period of all VOCs combined.

[R307-401-8]

DAQE-AN160760002-24
Page 7

II.B.2.b.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed].

[R307-401-8]

II.B.2.b.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs reclaimed.
The owner/operator shall subtract the amount of VOCs reclaimed from the quantities calculated
above to provide the monthly total emissions of VOCs. [R307-401-8]

II.B.2.b.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC-emitting material.

B. The maximum percent by weight of VOCs in each material used.

C. The density of each material used.

D. The volume of each VOC-emitting material used.

E. The amount of VOCs emitted from each material.

F. The amount of VOCs reclaimed and/or controlled from each material.

G. The total amount of VOCs emitted from all materials (in tons).

[R307-401-8]

II.B.2.c The owner/operator shall comply with all applicable rules in R307-304. Solvent Cleaning and
R307-335. Degreasing. [R307-304, R307-335]

II.B.3 Abrasive Blasting, Grinding, and Granite Cutting Requirements
II.B.3.a The owner/operator shall not conduct the following operations for more than the following:

A. Granite cutting operations for more than 1,700 hours per rolling 12-month period.

B. Grinding operations for more than 6,600 hours per rolling 12-month period.

C. The press debris process for more than 2,400 hours per rolling 12-month period.

D. All blasting operations for more than 3,440 hours per rolling 12-month period.

[R307-401-8]

DAQE-AN160760002-24
Page 8

II.B.3.a.1 The owner/operator shall:

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

B. Record hours of operation each day for reach process.

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

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

[R307-401-8]

II.B.3.b The owner/operator shall not use more than 13,016 tons of abrasives per rolling 12-month period
in the six (6) abrasive blasting cabinets in the blaster grinder room and asphalt finishing room.
[R307-401-8]

II.B.3.b.1 The owner/operation shall:

A. Determine consumption by receipts, records, or other method acceptable to the
Director.

B. Record consumption on a monthly basis.

C. Use the consumption data to calculate a new rolling 12-month total by the 20th day of
each month.

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

[R307-401-8]

II.B.3.c The owner/operator shall comply with all applicable rules in R307-306. PM10 Nonattainment and
Maintenance Areas: Abrasive Blasting. [R307-306]

II.B.3.d The owner/operator shall use a baghouse to control particulate emissions from the blasting
cabinets. The baghouse shall meet a PM10 removal efficiency of no less than 90%. [R307-401-8]

II.B.3.d.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's emissions guarantee for the installed abrasive blasting baghouse.
[R307-401-8]

II.B.3.e The owner/operator shall use a baghouse to control particulate emissions from the grinding and
granite cutting operations. [R307-401-8]

II.B.3.f The owner/operator shall keep a record of the manufacturer’s specifications and maintenance
recommendations for the baghouses that vent to the atmosphere. [R307-401-8]

II.B.3.g The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure differential across each baghouse. [R307-401-8]

II.B.3.g.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.3.g.2 The pressure gauge shall measure the static pressure differential in 1-inch water column
increments or less. [R307-401-8]

DAQE-AN160760002-24
Page 9

II.B.3.h During the operation of each baghouse, the owner/operator shall maintain the static pressure
differential within the range recommended by the manufacturer for normal operations.
[R307-401-8]

II.B.3.h.1 The owner/operator shall record the static pressure differential at least once per operating day
while the baghouse is operating. [R307-401-8]

II.B.3.h.2 The owner/operator shall maintain the following records of the static pressure differential:

A. Unit identification;

B. Manufacturer recommended static pressure differential;

C. Date of reading;

D. Daily static pressure differential readings.

[R307-401-8]

II.B.3.i At least once every 12 months, the owner/operator shall calibrate the pressure gauge in
accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8]

II.B.3.i.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

II.B.4 Emergency Engine Requirements
II.B.4.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following:

A. The date the emergency engine was used.

B. The duration of the operation in hours.

C. The reason for the emergency engine usage.

[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency engine. [R307-401-8]

II.B.4.b The owner/operator shall only use natural gas as fuel in the emergency engine. [R307-401-8]

DAQE-AN160760002-24
Page 10

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN160760001-22 dated February 18, 2022
Is Derived From NOI dated August 22, 2023
Incorporates Additional Information dated January 8, 2024
Incorporates Additional Information dated February 7, 2024
Incorporates Additional Information dated April 18, 2024

DAQE-AN160760002-24
Page 11

ACRONYMS

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

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

DAQE-IN160760002-24

June 4, 2024

Lonnie Allen
MegaDiamond
275 West 2230 North
Provo, UT 84604
[e-mail]

Dear Mr. Allen:

Re: Intent to Approve: Minor Modification to Approval Order DAQE-AN160760001-22 to Add
Equipment and Update Potential to Emit (PTE)
Project Number: N160760002

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

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

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DA:jg

cc: Utah County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN160760002-24
Minor Modification to Approval Order DAQE-AN160760001-22 to
Add Equipment and Update Potential to Emit

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

Issued to
MegaDiamond - Drill Bit Manufacturing Plant, South Facility

Issued On
June 4, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-IN160760002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
MegaDiamond MegaDiamond - Drill Bit Manufacturing Plant,
South Facility

Mailing Address Physical Address
275 West 2230 North 2185 Tracy Hall Parkway
Provo, UT 84604 Provo, UT 84606

Source Contact UTM Coordinates
Name: Lonnie Allen 446,504 m Easting
Phone: [phone],450,470 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 3544 (Special Dies & Tools, Die Sets, Jigs & Fixtures, & Industrial Molds)

SOURCE INFORMATION
General Description
MegaDiamond is the owner/operator of a drill bit manufacturing plant in Provo, Utah County.
MegaDiamond designs, manufactures, and markets ultra-hard materials that are used in cutting tools,
construction, oil and gas drilling, and mining applications. Electrically powered, multidirectional
hydraulic presses are used to produce polycrystalline diamond and cubic boron nitrate-cutting heads
under high-pressure conditions. Abrasive blasting cabinets are used for surface preparation and finishing
operations. Each cabinet vents to a baghouse filter. MegaDiamond operates a granite cutter and multiple
grinders for product shaping and finishing.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA
Utah County
Airs Source Size: B

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

DAQE-IN160760002-24
Page 4

Project Description
MegaDiamond is requesting the following modifications to its AO:

1. Add two (2) abrasive blasting units to the blaster grinder room.
2. Update the abrasive blasting process.
3. Increase abrasive blast media usage to 13,016 tons per year.
4. Update the solvent cleaning process.
5. Remove three (3) Centor furnaces (listed as Equipment ID 11.A.10 in AO DAQE-AN160760001-22).
6. Update site-wide emission calculations and PTE.

SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 3249.58 3361.00
Carbon Monoxide 2.26 2.37
Nitrogen Oxides 2.67 2.80
Particulate Matter - PM10 9.93 12.88
Particulate Matter - PM2.5 3.58 5.97
Sulfur Dioxide 0.02 0.02
Volatile Organic Compounds -1.05 1.73

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 102 106
Change (TPY) Total (TPY)
Total HAPs -1.15 0.05

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in The Daily Herald on June 6, 2024. During the public comment
period the proposal and the evaluation of its impact on air quality will be available for the public to
review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will
be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the
location of the source. Any comments received during the public comment period and the hearing will be
evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

DAQE-IN160760002-24
Page 5

SECTION I: GENERAL PROVISIONS

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

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

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

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

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

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All maintenance
performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

DAQE-IN160760002-24
Page 6

SECTION II: PERMITTED EQUIPMENT

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

II.A THE APPROVED EQUIPMENT

II.A.1 MegaDiamond - South Facility

II.A.2 Three (3) Abrasive Blasting Cabinets (Two (2) New)
Blaster Grinder Room
Control: Blaster Grinder Baghouse, 4,000 acfm
Manufacturer: Kelco

II.A.3 One (1) Abrasive Blasting Cabinet
Glass Bead Blaster
Control: Glass Bead Baghouse, 250 acfm
Vents Internally

II.A.4 Three (3) Abrasive Blasting Cabinets
Asphalt Finishing
Control: Asphalt Finishing Baghouse
Manufacturer: Guyson
Vents Internally

II.A.5 Granite Cutter
Control: Baghouse, 4,500 acfm

II.A.6 Grinding Operations
Various Grinders
Control: Two (2) Baghouses, 4,000 acfm each
One (1) Vents Internally

II.A.7 Solvent Cleaning Process (New)
Isopropanol used for cleaning and surface preparation
Vents Internally

II.A.8 One (1) Solvent-Based Parts Washer

II.A.9 Emergency Generator
Rating: 10 kW (13.4 hp)
Fuel: Natural Gas
Manufacturer Date: 1999

II.A.10 Various Comfort Heaters
Fuel: Natural Gas
Rating: All less than 5 MMBtu/hr

II.A.11 Cubic Presses
Electric Hydraulic Presses
***Listed for informational purposes only

DAQE-IN160760002-24
Page 7

SECTION II: SPECIAL PROVISIONS

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

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions to exceed the following limits:

A. All baghouse and fabric filter systems - 10%.

B. Natural gas emergency generator - 10%.

C. All other points - 20% opacity.

[R307-305-3, R307-401-8]

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

II.B.2 VOC Requirements
II.B.2.a The owner/operator shall not emit any HAPs from evaporative sources (painting, printing,
coating, and/or cleaning) on site. [R307-401-8]

II.B.2.b The owner/operator shall not emit more than the following from evaporative sources on site:

1.20 tons per rolling 12-month period of isopropanol .
1.57 tons per rolling 12-month period of all VOCs combined.

[R307-401-8]

II.B.2.b.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed].

[R307-401-8]

II.B.2.b.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs reclaimed.
The owner/operator shall subtract the amount of VOCs reclaimed from the quantities calculated
above to provide the monthly total emissions of VOCs. [R307-401-8]

DAQE-IN160760002-24
Page 8

II.B.2.b.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC-emitting material.

B. The maximum percent by weight of VOCs in each material used.

C. The density of each material used.

D. The volume of each VOC-emitting material used.

E. The amount of VOCs emitted from each material.

F. The amount of VOCs reclaimed and/or controlled from each material.

G. The total amount of VOCs emitted from all materials (in tons).

[R307-401-8]

II.B.2.c The owner/operator shall comply with all applicable rules in R307-304. Solvent Cleaning and
R307-335. Degreasing. [R307-304, R307-335]

II.B.3 Abrasive Blasting, Grinding, and Granite Cutting Requirements
II.B.3.a The owner/operator shall not conduct the following operations for more than the following:

A. Granite cutting operations for more than 1,700 hours per rolling 12-month
period.

B. Grinding operations for more than 6,600 hours per rolling 12-month period.

C. The press debris process for more than 2,400 hours per rolling 12-month period.

D. All blasting operations for more than 3,440 hours per rolling 12-month period.

[R307-401-8]

II.B.3.a.1 The owner/operator shall:

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

B. Record hours of operation each day for reach process.

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

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

[R307-401-8]

II.B.3.b The owner/operator shall not use more than 13,016 tons of abrasives per rolling 12-month period
in the six (6) abrasive blasting cabinets in the blaster grinder room and asphalt finishing room.
[R307-401-8]

DAQE-IN160760002-24
Page 9

II.B.3.b.1 The owner/operation shall:

A. Determine consumption by receipts, records, or other method acceptable to the
Director.

B. Record consumption on a monthly basis.

C. Use the consumption data to calculate a new rolling 12-month total by the 20th
day of each month.

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

[R307-401-8]

II.B.3.c The owner/operator shall comply with all applicable rules in R307-306. PM10 Nonattainment and
Maintenance Areas: Abrasive Blasting. [R307-306]

II.B.3.d The owner/operator shall use a baghouse to control particulate emissions from the blasting
cabinets. The baghouse shall meet a PM10 removal efficiency of no less than 90%. [R307-401-8]

II.B.3.d.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's emissions guarantee for the installed abrasive blasting baghouse.
[R307-401-8]

II.B.3.e The owner/operator shall use a baghouse to control particulate emissions from the grinding and
granite cutting operations. [R307-401-8]

II.B.3.f The owner/operator shall keep a record of the manufacturer’s specifications and maintenance
recommendations for the baghouses that vent to the atmosphere. [R307-401-8]

II.B.3.g The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure differential across each baghouse. [R307-401-8]

II.B.3.g.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

II.B.3.g.2 The pressure gauge shall measure the static pressure differential in 1-inch water column
increments or less. [R307-401-8]

II.B.3.h During operation of each baghouse, the owner/operator shall maintain the static pressure
differential within the range recommended by the manufacturer for normal operations.
[R307-401-8]

II.B.3.h.1 The owner/operator shall record the static pressure differential at least once per operating day
while the baghouse is operating. [R307-401-8]

II.B.3.h.2 The owner/operator shall maintain the following records of the static pressure differential:

A. Unit identification;

B. Manufacturer recommended static pressure differential;

C. Date of reading;

D. Daily static pressure differential readings.

[R307-401-8]

DAQE-IN160760002-24
Page 10

II.B.3.i At least once every 12 months, the owner/operator shall calibrate the pressure gauge in
accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8]

II.B.3.i.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements.
[R307-401-8]

II.B.4 Emergency Engine Requirements
II.B.4.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [40 CFR 63, Subpart ZZZZ, R307-401-8]

II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following:

A. The date the emergency engine was used.

B. The duration of operation in hours.

C. The reason for the emergency engine usage.

[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency engine. [R307-401-8]

II.B.4.b The owner/operator shall only use natural gas as fuel in the emergency engine. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN160760001-22 dated February 18, 2022
Is Derived From NOI dated August 22, 2023
Incorporates Additional Information dated January 8, 2024
Incorporates Additional Information dated February 7, 2024
Incorporates Additional Information dated April 18, 2024

DAQE-IN160760002-24
Page 11

ACRONYMS

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

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

Daily Herald
Publication Name:
Daily Herald
Publication URL:
Publication City and State:
Provo, UT
Publication County:
Utah
Notice Popular Keyword Category:
Notice Keywords:
megadiamond
Notice Authentication Number:
202406061023032813320
1761527914
Notice URL:
Back
Notice Publish Date:
Thursday, June 06, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: MegaDiamond Location: MegaDiamond- Drill Bit Manufacturing Plant, South
Facility - 2185 Tracy Hall Parkway, Provo, UT Project Description: MegaDiamond is the owner/operator of a drill bit manufacturing plant in
Provo, Utah County. MegaDiamond designs, manufactures, and markets ultra-hard materials that are used in cutting tools, construction, oil
and gas drilling, and mining applications. Electrically powered, multidirectional hydraulic presses are used to produce polycrystalline diamond
and cubic boron nitrate-cutting heads under high-pressure conditions. Abrasive blasting cabinets are used for surface preparation and
finishing operations. Each cabinet vents to a baghouse filter. MegaDiamond operates a granite cutter and multiple grinders for product
shaping and finishing. MegaDiamond has requested the following modifications to its Approval Order: 1. Add two (2) abrasive blasting units
to the blaster grinder room. 2. Update the abrasive blasting process. 3. Increase abrasive blast media usage to 13,016 tons per year. 4.
Update the solvent cleaning process. 5. Remove three (3) Centor furnaces. 6. Update site-wide emission calculations and potential to emit.
The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air
quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period.
The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same
address on or before July 6, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email
comments will also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of
this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a
Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and
was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the
issue. Date of Notice: June 6, 2024 Legal Notice 12938 Published in the Daily Herald on June 6, 2024
Back

DAQE-NN160760002-24

June 4, 2024

The Daily Herald
Legal Advertising Department
1555 North 200 West
Provo, Utah 84601

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in The Daily Herald (Account
Number: 00032838) on June 6, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Mountainland Association of Governments
cc: Utah County

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN160760002-24
Page 2
NOTICE

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

Company Name: MegaDiamond
Location: MegaDiamond- Drill Bit Manufacturing Plant, South Facility – 2185 Tracy Hall
Parkway, Provo, UT
Project Description: MegaDiamond is the owner/operator of a drill bit manufacturing plant in Provo,
Utah County. MegaDiamond designs, manufactures, and markets ultra-hard
materials that are used in cutting tools, construction, oil and gas drilling, and
mining applications. Electrically powered, multidirectional hydraulic presses are
used to produce polycrystalline diamond and cubic boron nitrate-cutting heads
under high-pressure conditions. Abrasive blasting cabinets are used for surface
preparation and finishing operations. Each cabinet vents to a baghouse filter.
MegaDiamond operates a granite cutter and multiple grinders for product shaping
and finishing.

MegaDiamond has requested the following modifications to its Approval Order:
1. Add two (2) abrasive blasting units to the blaster grinder room. 2. Update the
abrasive blasting process. 3. Increase abrasive blast media usage to 13,016 tons
per year. 4. Update the solvent cleaning process. 5. Remove three (3) Centor
furnaces. 6. Update site-wide emission calculations and potential to emit.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before July 6, 2024 will be considered in making the
final decision on the approval/disapproval of the proposed project. Email comments will also be accepted
at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication
of this notice, a hearing will be held in accordance with
R307-401-7, UAC.

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

Date of Notice: June 6, 2024

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

DAQE-

RN160760002
May 28, 2024

Lonnie Allen
MegaDiamond
275 West 2230 North
Provo, UT 84604
[e-mail]

Dear Lonnie Allen,

Re: Engineer Review:
Minor Modification to AO DAQE-AN160760001-22 to Add Equipment and Update Potential to
Emit (PTE)
Project Number: N160760002

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. MegaDiamond
should complete this review within 10 business days of receipt.

MegaDiamond should contact Dungan Adams at [phone] if there are questions or concerns with
the review of the draft permit conditions. Upon resolution of your concerns, please email Dungan Adams
at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ
will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the
DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ
Director.

If MegaDiamond does not respond to this letter within 10 business days, the project will move forward
without source concurrence. If MegaDiamond has concerns that cannot be resolved and the project
becomes stagnant, the DAQ Director may issue an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of
Environmental Quality

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N160760002
Owner Name MegaDiamond
Mailing Address 275 West 2230 North
Provo, UT, 84604

Source Name MegaDiamond- Drill Bit Manufacturing Plant, South Facility
Source Location 2185 Tracy Hall Parkway
Provo, UT 84606

UTM Projection 446,504 m Easting, 4,450,470 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3544 (Special Dies & Tools, Die Sets, Jigs & Fixtures, &
Industrial Molds)

Source Contact Lonnie Allen
Phone Number [phone]
Email [e-mail]

Billing Contact Lonnie Allen
Phone Number [phone]
Email [e-mail]

Project Engineer Dungan Adams, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted August 22, 2023
Date of Accepted Application March 11, 2024

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 2
SOURCE DESCRIPTION

General Description
MegaDiamond is the owner/operator of a drill bit manufacturing plant in Provo, Utah County.
MegaDiamond designs, manufactures, and markets ultra-hard materials that are used in cutting
tools, construction, oil and gas drilling, and mining applications. Electrically powered,
multidirectional hydraulic presses are used to produce polycrystalline diamond and cubic boron
nitrate-cutting heads under high-pressure conditions. Abrasive blasting cabinets are used for
surface preparation and finishing operations. Each cabinet vents to a baghouse filter.
MegaDiamond operates a granite cutter and multiple grinders for product shaping and finishing.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in Southern Wasatch Front O3 NAA and Provo UT PM2.5 NAA
Utah County
Airs Source Size: B

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Proposal
Minor Modification to AO DAQE-AN160760001-22 to Add Equipment and Update Potential to
Emit (PTE)

Project Description
MegaDiamond is requesting the following modifications to its Approval Order (AO):
1. Add two (2) abrasive blasting units to the blaster grinder room
2. Update the abrasive blasting process
3. Increase abrasive blast media usage to 13,016 tons per year
4. Update the solvent cleaning process
5. Remove three (3) Centor furnaces (listed as Equipment ID 11.A.10 in AO
DAQE-AN160760001-22)
6. Update site-wide emission calculations and potential to emit (PTE).

EMISSION IMPACT ANALYSIS
All criteria pollutant increases are below the modeling thresholds contained in R307-410-4. All HAP emission
increases are below their respective emission threshold values in R307-410-5. Therefore, modeling is not
required for this source. [Last updated March 19, 2024]

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 3
SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 3249.58 3361.00
Carbon Monoxide 2.26 2.37
Nitrogen Oxides 2.67 2.80
Particulate Matter - PM10 9.93 12.88
Particulate Matter - PM2.5 3.58 5.97
Sulfur Dioxide 0.02 0.02
Volatile Organic Compounds -1.05 1.73

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 102 106
Change (TPY) Total (TPY)
Total HAPs -1.15 0.05

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

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Abrasive Blasters
PM10 and PM2.5
MegaDiamond has requested to add two (2) new abrasive blasting units to the blaster grinder room
of the facility, bringing the total to three (3) abrasive blasting units in the blaster grinder room.
Emissions from the blaster grinder room are currently controlled by the blaster grinder baghouse
before exhausting to the atmosphere.

As abrasive media meets materials being cleaned, dust is created as coatings are removed. The
abrasive media also shatters upon contact, creating PM10 and PM2.5 emissions. MegaDiamond uses
blasting cabinets for the abrasive blasting. The source evaluated the following control
technologies: electrostatic precipitators, fabric filters/bag houses, wet scrubber, and cyclones. The
source considered all of these control technologies feasible and ranked them based on efficiency.

1. Fabric Filter- 90-99% efficient
2. Electrostatic Precipitator - 98% efficient
3. Wet Scrubbers - 70-99% efficient
4. Cyclone - 25-90% efficient

The source selected to use fabric filter baghouses as BACT for abrasive blasting operations in the
blaster grinder room. BACT for PM10 and PM2.5 from abrasive blasting in the blaster grinder room
is routing all emissions from the blasting cabinets through a fabric filter baghouse before venting
to the atmosphere. The baghouse fabric filter will have a removal efficiency of no less than 90%,
0.016 grains/scf, and the visible emissions will not exceed 10% opacity. The source will operate
and maintain the fabric filter baghouse in accordance with manufacturer specifications. [Last
updated March 19, 2024]

2. BACT review regarding Solvent Cleaning and Lubrication
VOCs
MegaDiamond has requested to update its solvent cleaning process. The source will no longer use
methanol (a HAP) for its solvent cleaning processes and will use only isopropanol. The source will
continue to use dry lubricant degreasers on various parts. The solvent cleaning is completed in labs
and the cleaning room. The DAQ is unaware of a feasible way to control small amounts of solvent
emissions due to the many locations in which cleaning occurs.

BACT is considered good operating procedures which includes using the minimal amount of
solvent needed, cleaning up spills immediately, keeping lids and covers closed on all solvent
containers when not in use, and disposing of used solvent properly. BACT is also complying with
UAC Rules R307-304. Solvent Cleaning and R307-335. Degreasing.
[Last updated April 18, 2024]

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 5
SECTION I: GENERAL PROVISIONS

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

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

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

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

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

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-
401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
150]

I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 6
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 MegaDiamond - South Facility

II.A.2 Three (3) Abrasive Blasting Cabinets (Two (2) New)
Blaster Grinder Room
Control: Blaster Grinder Baghouse, 4,000 acfm
Manufacturer: Kelco

II.A.3 One (1) Abrasive Blasting Cabinet
Glass Bead Blaster
Control: Glass Bead Baghouse, 250 acfm
Vents Internally

II.A.4 Three (3) Abrasive Blasting Cabinets
Asphalt Finishing
Control: Asphalt Finishing Baghouse
Manufacturer: Guyson
Vents Internally

II.A.5 Granite Cutter
Control: Baghouse, 4,500 acfm

II.A.6 Grinding Operations
Various Grinders
Control: Two (2) Baghouses, 4,000 acfm each
One (1) Vents Internally

II.A.7 Solvent Cleaning Process (New)
Isopropanol used for cleaning and surface preparation
Vents Internally

II.A.8
NEW
One (1) Solvent-Based Parts Washer

II.A.9 Emergency Generator
Rating: 10 kW (13.4 hp)
Fuel: Natural Gas
Manufacturer Date: 1999

II.A.10 Various Comfort Heaters
Fuel: Natural Gas
Rating: All less than 5 MMBtu/hr

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 7
II.A.11 Cubic Presses
Electric Hydraulic Presses
***Listed for informational purposes only

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

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Requirements
II.B.1.a
NEW
The owner/operator shall not allow visible emission to exceed the following limits:

A. All baghouse and fabric filter systems - 10%

B. Natural gas emergency generator - 10%

C. All other points - 20% opacity. [R307-305-3, R307-401-8]

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

II.B.2
NEW
VOC Requirements
II.B.2.a
NEW
The owner/operator shall not emit any HAPs from evaporative sources (painting, printing,
coating, and/or cleaning) on site. [R307-401-8]

II.B.2.b
NEW
The owner/operator shall not emit more than the following from evaporative sources on site:

1.20 tons per rolling 12-month period of isopropanol
1.57 tons per rolling 12-month period of all VOCs combined. [R307-401-8]

II.B.2.b.1
NEW
The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]

II.B.2.b.2
NEW
The owner/operator shall use a mass-balance method to quantify any amount of VOCs
reclaimed. The owner/operator shall subtract the amount of VOCs reclaimed from the
quantities calculated above to provide the monthly total emissions of VOCs. [R307-401-8]

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 8
II.B.2.b.3
NEW
The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC-emitting material

B. The maximum percent by weight of VOCs in each material used

C. The density of each material used

D. The volume of each VOC-emitting material used

E. The amount of VOCs emitted from each material

F. The amount of VOCs reclaimed and/or controlled from each material

G. The total amount of VOCs emitted from all materials (in tons). [R307-401-8]

II.B.2.c
NEW
The owner/operator shall comply with all applicable rules in R307-304. Solvent Cleaning and
R307-335. Degreasing. [R307-304, R307-335]

II.B.3 Abrasive Blasting, Grinding and Granite Cutting Requirements
II.B.3.a
NEW
The owner/operator shall not conduct the following operations for more than the following:

A. Granite cutting operations for more than 1,700 hours per rolling 12-month period

B. Grinding operations for more than 6,600 hours per rolling 12-month period

C. The press debris process for more than 2,400 hours per rolling 12-month period

D. All blasting operations for more than 3,440 hours per rolling 12-month period. [R307-
401-8]

II.B.3.a.1
NEW
The owner/operator shall:

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

B. Record hours of operation each day for reach process

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

D. Keep hours of operation records for all periods the plant is in operation for each
process. [R307-401-8]

II.B.3.b
NEW
The owner/operator shall not use more than 13,016 tons of abrasives per rolling 12-month
period in the six (6) abrasive blasting cabinets in the blaster grinder room and asphalt finishing
room. [R307-401-8]

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 9
II.B.3.b.1
NEW
The owner/operation shall:

A. Determine consumption by receipts, records, or other method acceptable to the
Director.

B. Record consumption on a monthly basis.

C. Use the consumption data to calculate a new rolling 12-month total by the 20th day of
each month.

D. Keep records of consumption for all periods the plant is in operation. [R307-401-8]

II.B.3.c
NEW
The owner/operator shall comply with all applicable rules in R307-306. PM10 Nonattainment
and Maintenance Areas: Abrasive Blasting. [R307-306]

II.B.3.d
NEW
The owner/operator shall use a baghouse to control particulate emissions from the blasting
cabinets. The baghouse shall meet a PM10 removal efficiency of no less than 90%. [R307-401-
8]

II.B.3.d.1
NEW
To demonstrate compliance with the above condition, the owner/operator shall maintain
records of the manufacturer's emissions guarantee for the installed abrasive blasting baghouse.
[R307-401-8]

II.B.3.e
NEW
The owner/operator shall use a baghouse to control particulate emissions from the grinding
and granite cutting operations. [R307-401-8]

II.B.3.f The owner/operator shall keep a record of the manufacturer specifications and maintenance
recommendations for the baghouses that vent to the atmosphere. [R307-401-8]

II.B.3.g
NEW
The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
static pressure differential across each baghouse. [R307-401-8]

II.B.3.g.1 The pressure gauge shall be located such that an inspector/operator can safely read the
indicator at any time. [R307-401-8]

II.B.3.g.2 The pressure gauge shall measure the static pressure differential in 1-inch water column
increments or less. [R307-401-8]

II.B.3.h During operation of each baghouse, the owner/operator shall maintain the static pressure
differential within the range recommended by the manufacturer for normal operations. [R307-
401-8]

II.B.3.h.1
NEW
The owner/operator shall record the static pressure differential at least once per operating day
while the baghouse is operating. [R307-401-8]

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 10
II.B.3.h.2
NEW
The owner/operator shall maintain the following records of the static pressure differential:

A. Unit identification;

B. Manufacturer recommended static pressure differential;

C. Date of reading;

D. Daily static pressure differential readings. [R307-401-8]

II.B.3.i
NEW
At least once every 12 months, the owner/operator shall calibrate the pressure gauge in
accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8]

II.B.3.i.1
NEW
The owner/operator shall maintain records of the pressure gauge calibrations and
replacements. [R307-401-8]

II.B.4 Emergency Engine Requirements
II.B.4.a
NEW
The owner/operator shall not operate the emergency engine on site for more than 100 hours
per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.4.a.1
NEW
To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 20th day of each month using data from the previous 12 months.
Records documenting the operation of each emergency engine shall be kept in a log and shall
include the following:

A. The date the emergency engine was used

B. The duration of operation in hours

C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency engine. [R307-401-8]

II.B.4.b The owner/operator shall only use natural gas as fuel in the emergency engine. [R307-401-8]

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 11
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN160760001-22 dated February 18, 2022
Is Derived From NOI dated August 22, 2023
Incorporates Additional Information dated January 8, 2024
Incorporates Additional Information dated February 7, 2024
Incorporates Additional Information dated April 18, 2024

REVIEWER COMMENTS

1. Comment regarding Emission Estimates:
Abrasive Blasting
There are two changes being made to the abrasive blasting process. The first is two (2) Kelco
abrasive blasting units are being added to the blaster grinder room. Secondly the operation of the
three (3) Guyson asphalt finishing blasters is being updated to increase abrasive usage.

The estimated emissions for each Kelco abrasive blasting unit are based on a maximum hourly
throughout for abrasive material at 273.03 lbs/hr/unit. The source estimates each Kelco abrasive
blaster is used 30 minutes an hour, 22 hours a day, 6 days a week. This equates to 3,440 hours of
annual operation and 469.81 tons of abrasive/year/Kelco unit.

The estimated emissions for each Guyson abrasive blasting unit are based on a maximum hourly
throughout for abrasive material at 2,248.48 lbs/hr/unit. The source estimates each Guyson abrasive
blaster is used 30 minutes an hour, 22 hours a day, 6 days a week. This equates to 3,440 hours of
annual operation and 3,869.00 tons of abrasive/year/Guyson unit.

The following emission factors from AP-42 Chapter 13 Table 13.2.6-1 were used.
PM10 Uncontrolled: 13 lbs emissions/1000 lbs abrasive
PM2.5 Uncontrolled: 1.3 lbs emissions/1000 lbs abrasive

The baghouse will control 95% of PM10 emissions and 90% of PM2.5 emissions.
PM10 Controlled:0.65 lbs emissions/1000 lbs abrasive
PM2.5 Controlled:0.13 lbs emissions/1000 lbs abrasive

Emissions from the glass bead abrasive blaster were not included in the previous AO and have been
added as part of this modification. The estimated emissions for the glass bead blaster are based on
grain loading and flow rate of the glass bead blaster baghouse.

Solvent Cleaning
The source uses 3,000 gallons of isopropanol annually. The source reclaims approximately 20%
(600 gallons) of the isopropanol per year and ships it off site. The remaining isopropanol is released
as VOCs.

Lubricant and Degreasers
The source used 250 pounds of Zyglo ZP-9F and Zyglo ZL60D each annually. Zyglo ZP-9F is 65.60
% VOC and Zyglo ZL60D is 30.40 % VOC. The source uses 500 pounds of Presolve Orange
Degreaser annually and the VOC content is 100%. None of the lubricants and degreasers are

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 12
reclaimed.

Emergency Engines
The source has updated the emission calculations for the emergency generator engine. The emissions
were incorrectly calculated assuming the generator was a four-stroke lean-burn engine. The
generator is actually a four-stroke rich-burn engine, and the emission factors were updated using AP-
42 Chapter 3 Table 3.2-3.

Comfort Heaters
Emissions estimates for the various comfort heaters under 5 MMBtu/hr were not included in the
previous AO and have been added as part of this modification. The estimated emission from all
comfort heating and water heating assumed 8760 hours of annual operation. [Last updated March 11,
2024]

2. Comment regarding NSPS and MACT Applicability:
40 CFR 63 (MACT) Subpart JJ: National Emission Standards for Hazardous Air Pollutants for
Source Categories. MACT Subpart JJ applies to major sources of HAP. This source is not a major
source of criteria or HAP pollutants; therefore, MACT Subpart JJ is not applicable to this facility.

40 CFR 63 (MACT) Subpart XXXXXX: National Emission Standards for Hazardous Air Pollutants
Area Source Standards for Nine Metal Fabrication and Finishing Source Categories. The source does
not complete any metal fabrication at this facility, so this subpart does not apply.

40 CFR 63 (MACT) Subpart ZZZZ: National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines. The natural gas engine at this facility was
manufactured/constructed before 2006 and is for emergency use only. The facility is an area source
for HAP emissions. Therefore, Subpart ZZZZ does apply to this facility. [Last updated March 11,
2024]

3. Comment regarding Title V Applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following:

1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources;
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants.
4. Any Title IV affected source.

This source is not a major source and is not a Title IV source. The facility is not subject to any NSPS
or NESHAP. This facility is subject to MACT Subpart ZZZZ. However, MACT Subpart ZZZZ
exempts the source from the obligation to obtain a Title V permit provided that the source is not
required to obtain the permit for any other reason. No such reasons exist for this source. Therefore,
Title V does not apply to this facility
[Last updated March 19, 2024]

Engineer Review N160760002: MegaDiamond- Drill Bit Manufacturing Plant, South Facility
May 28, 2024
Page 13
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

NEW SOURCE REVIEW AIR PERMIT APPLICATION

MegaDiamond, Inc., a Schlumberger Company - South Facility
2185 Tracy Hall Parkway
Provo, Utah 84606
Utah County

January 8, 2024
Terracon Project No. MP237319

Prepared for:
MegaDiamond Inc., A Schlumberger Company
Provo, Utah

Prepared by:
Terracon Consultants, Inc.
Minneapolis, Minnesota

January 8, 2023

Mr. Alan Humpherys
Utah Department of Environmental Quality
Division of Air Quality
195 N 1950 W.
Salt Lake City, UT 84114

RE: Notice of Intent
MegaDiamond, Inc. – South Facility
2185 Tracy Hall Parkway
Provo, Utah

Dear Mr. Humpherys:

Terracon is submitting the attached Notice of Intent (NOI) along with all the supporting
information on behalf of MegaDiamond, Inc in Provo, Utah. The following changes have been
made to the facility:
 Two abrasive blasting units will be added to the blaster grinder room to expand their
capacity for surface preparation and finishing,
 The previously permitted Centor furnaces have been removed from the facility,
 Methanol is no longer in use as a solvent.

The attached NOI includes the required regulation review. The NOI also includes all the
requested information on the NOI checklist. The facility previously was allowed to operate
under the Small Source Determination exemption.

If you have any questions on the information contained in the NOI, please contact Chris Larson
at 763-489-3153.

Sincerely,

Terracon Consultants, Inc.

Chris Larson, PE Travis W. Knisley, PE
Staff Engineer – Chemical Senior Engineer - Chemical

Enc. Notice of Intent

cc: Mr. Lonnie Allen

:UDYLV =. 1QLVOH\
New Source Review Air Permit Application
MegaDiamond – South Facility ■ Provo, Utah
January 8, 2024 ■ Terracon Project No. MP237319

3
CONTENTS
INTRODUCTION ......................................................................................................................... 4
Description of Facility Operations ..................................................................................... 4
PROCESS MODIFICATIONS ................................................................................................... 4
2.1 Abrasive Blasters (EP001) ....................................................................................... 4
2.2 Solvent Cleaning (EP-005) ...................................................................................... 5
2.3 Centor Furnace Combustion (EP-006) ................................................................ 5
BACT ............................................................................................................................................... 5
3.1 Abrasive Blasting (EP001) ....................................................................................... 5
3.2 Solvent Cleaning and Misc. Chemical Usage (EP-005) ................................. 7
EMISSIONS IMPACT ANALYSIS – APPROVED MODELING PROTOCOL ................ 8
NONATTAINMENT/MAINTENANCE AREAS – MAJOR NSR/MINOR ........................ 9
MAJOR SOURCES IN ATTAINMENT OR UNCLASSIFIED AREAS ............................ 10

Appendix List

A – Emission Calculations
B – Plot Plan
C – Process Flow Diagram
D – Permit Forms
E – Minor Source Offset Flowchart
F – Equipment Specification Pages

New Source Review Air Permit Application
MegaDiamond – South Facility ■ Provo, Utah
January 8, 2024 ■ Terracon Project No. MP237319

4
INTRODUCTION

Description of Facility Operations

MegaDiamond Inc., a Schlumberger Company (MegaDiamond) operates a facility
located at 2185 Tracy Hall Parkway in Provo, Utah. MegaDiamond designs,
manufactures and markets ultra-hard materials that are used in cutting tools,
construction, oil and gas drilling, and mining applications. MegaDiamond uses high-
pressure and high-temperature technology to create these ultra-hard materials. A
description of each major unit is described in section 2.0.

PROCESS MODIFICATIONS

2.1 Abrasive Blasters (EP001)

MegaDiamond operates blasting cabinets that are used for surface preparation and
finishing operations. Each cabinet vents to a baghouse filter to collect and recover
the abrasives and the fine particulate matter produced. Two (2) new abrasive blasting
units are being added to the blaster grinder room of the facility, bringing the total
number of blasting units at the site to seven (7) total units; three (3) in the blaster
grinder room which is controlled by the blaster grinder baghouse before exhausting
to the atmosphere (SV-001), one (1) glass bead blaster which is controlled by the
glass bead baghouse which vents internally, and three (3) asphalt finishing blasters
which are controlled by an asphalt finishing baghouse which vents internally.

The blasting units utilize silica carbide and glass beads for their blasting media. The
flowrates of material in the blaster grinder room are based on a ¼” nozzle with a
backpressure of 80 psi, while the flowrates of material in the asphalt finishing room
are based on twin ½” nozzles with an 80 psi backpressure. The units operate 30
minutes per hour, 22 hours per day, and 6 days a week, which equal out to 3,440
hours per year.

Hourly and annual emission rates were calculated utilizing the hourly and annual grit
usage along with AP-42 factors.

Please refer to Table 4 in Appendix A for the calculations of both the potential-to-
emit and the expected controlled emissions from this emission point.

New Source Review Air Permit Application
MegaDiamond – South Facility ■ Provo, Utah
January 8, 2024 ■ Terracon Project No. MP237319

5
2.2 Solvent Cleaning (EP-005)

Isopropanol is used for cleaning parts, preparing the piston press surfaces, used in
desiccation cabinets, and other cleaning and preparation processes. The emissions
from these processes vent fugitively into the room air. Some isopropanol is
recaptured and shipped off as reclaimed solvent. The site also utilizes multiple
cleaners and degreasers around the facility. In the past, methanol was also used as
a solvent at this facility, however the facility no longer uses methanol in any capacity.
These chemicals contain VOC’s per their safety data sheet but do not contain any
hazardous air pollutants (HAPs). The emissions are emitted fugitively inside the
building.

MegaDiamond expects to use 3,000 pounds of isopropanol a year while reclaiming
approximately 20% of the solvent. MegaDiamond disposes of the used solvent with
a local waste hauler.

Please refer to Table 5 in Appendix A for the calculations of emissions from this
emission point.

2.3 Centor Furnace Combustion (EP-006)

The Centor furnaces have been removed from the facility and will not be included in
future permits.

BACT
3.1 Abrasive Blasting (EP001)

Process: Abrasive Blasting (7 units)
Emission Unit ID: EP-001
Control Device ID: 2 baghouses. Abrasive Blasting Baghouse, Asphalt Blasting
Baghouse
Controls: Baghouse
Rating: MERV 15 | 95% Efficient for PM10, 90% Efficient for PM2.5

Actual Emission Summary per Kelco Unit (PM)
Pollutant PM PM10 PM2.5
Emissions
(lb/hr)
0.09 0.09 0.02
Emissions
(tons/yr)
0.324 0.305 0.061
New Source Review Air Permit Application
MegaDiamond – South Facility ■ Provo, Utah
January 8, 2024 ■ Terracon Project No. MP237319

6

Actual Emission Summary per Guyson Unit (PM)
Pollutant PM PM10 PM2.5
Emissions
(lb/hr)
0.78 0.73 0.15
Emissions
(tons/yr)
2.670 2.515 0.503

Please refer to Section 2.2 for process description and emission calculation
demonstrations along with Appendix A, Table 3 for the emissions from this process
unit. Emission Factors from AP-42 Chapter 13, Section 2 were used. A fabric filter
with MERV 15 rating was used to calculate projected actual controlled emissions of
0.324 tons PM/year from each Kelco blasting unit and 2.670 tons PM/year from each
Guyson blasting unit, totaling 8.98 tons/year of particulate matter being emitted from
the processes.

A top-down Best Available Control Technology (BACT) analysis consists of the 5 steps
detailed below.

 Step 1 – Identify all control technologies
 Step 2 – Eliminate technically infeasible options
 Step 3 – Rank remaining control technologies by control effectiveness
 Step 4 – Evaluate most effective controls and document results
 Step 5 – Select BACT

1. Identify Control Technologies
The most common types of particulate control devices include the following.
 electrostatic precipitators (wet and dry types),
 fabric filters (also called baghouses),
 wet scrubbers, and
 cyclones (or multiclones)

2. Eliminate technically infeasible options
All of the control technologies identified in Step 1 are classified as technically feasible
to control the particulate emissions from the abrasive blasting operations.

3. Rank remaining control technologies by control effectiveness
The controls identified in Step 1 above have been ranked from the most efficient to
the least efficient.
1. Fabric Filters (90-99%)
New Source Review Air Permit Application
MegaDiamond – South Facility ■ Provo, Utah
January 8, 2024 ■ Terracon Project No. MP237319

7
2. Electrostatic Precipitator (98%)
3. Wet Scrubbers (70-99%)
4. Cyclone (25-90%)

4. Evaluate most effective controls and document results
A fabric filter has been identified as being the most effective control technology. The
other available control technologies have not been evaluated but would likely not be
cost effective based on the low level of emissions coming from the process.

5. Select BACT
Based on this analysis, MegaDiamond is proposing to continue to use its fabric filter
baghouse and is asking that it be classified as BACT for controlling the emissions from
the abrasive blasting operations. MegaDiamond will continue to use its fabric filter
baghouse to control the emissions, operate the baghouse within manufacturer’s
recommended parameters, and perform maintenance as recommended by the
manufacturer.

3.2 Solvent Cleaning and Misc. Chemical Usage (EP-005)

Process: Solvent Cleaning
Emission Unit ID: EP-005
Control Device ID: None
Controls: None
Rating: N/A

Actual Emission Summary per Unit (Criteria pollutants and HAPs)
Pollutant VOC HAPs
Emissions
(lb/hr)
3.56 0.00
Emissions
(tons/yr)
1.570 0.000

Please refer to Section 2.6 for a process description and emission calculation
demonstrations along with Appendix A, Table 5 for the emissions from this process
unit. MegaDiamond currently uses isopropanol in their solvent cleaning processes.
Methanol is no longer used at this facility. The solvents are used in lab and cleaning
rooms. Currently, when the solvents become dirty and are not useable anymore, the
solvents are put into a solvent reclaim container which is disposed of as a hazardous
waste. There are no cost-effective control technology options to control small
amounts of solvent emissions from multiple cleaning stations.
New Source Review Air Permit Application
MegaDiamond – South Facility ■ Provo, Utah
January 8, 2024 ■ Terracon Project No. MP237319

8

Since there are no feasible control technology options, MegaDiamond is proposing to
utilize good operating procedures to minimize emissions from this process. The
operating procedures proposed as BACT include:

 Minimize the amount of solvent used for cleaning purposes.
 Minimize the amount of lubricant used.
 Wipe up excess solvent with a rag and dispose of the rags.
 Wipe up excess lubricant with a rag and properly dispose of the rags.
 For dip-tank operations, keep all lids and covers closed on solvent containers
when possible.
 Place used solvent into reclaimed solvent barrels to reduce the amount that
evaporates.

EMISSIONS IMPACT ANALYSIS – APPROVED
MODELING PROTOCOL

MegaDiamond reviewed the Emissions Impact Assessment Guideline from UDAQ to
determine the need for an emissions impact analysis. Upon review of this document,
it was determined that MegaDiamond does not need to provide any emissions impact
analysis modeling based on the emissions from the site and its location in Utah
County. The area is in an area classified as non-attainment for PM10 and PM2.5,
maintenance for carbon monoxide, and attainment for all other pollutants.

Table 1 of the Utah Division of Air Quality Emissions Impact Assessment Guidelines
details the modeling thresholds for controlled emissions of pollutants in attainment,
and the following table documents MegaDiamond’s controlled emissions compared to
the thresholds.

Pollutant Emissions Level to
Require Modeling (TPY)
Controlled Emissions
from Facility (TPY)
SO2 40 0.017
NO2 40 2.804
PM10 – Fugitive 5 0.466
PM10 – Non-Fugitive 15 12.723
CO 100 2.373
Lead 0.6 0.0001

UDAQ does not require sources to perform dispersion modeling if the source is located
in an area that is classified as non-attainment for that pollutant. UDAQ instead
New Source Review Air Permit Application
MegaDiamond – South Facility ■ Provo, Utah
January 8, 2024 ■ Terracon Project No. MP237319

9
requires that MegaDiamond review the applicable offset requirements. A review of
the Minor Source Offset flow diagram indicated that the facility is not required to
obtain offsets. This completed table can be seen in Appendix E.

Particulate Matter
MegaDiamond reviewed the Emissions Impact Assessment Guideline from UDAQ to
determine the need for an emissions impact analysis. Upon review of this document,
it was determined that MegaDiamond does not need to provide an emissions impact
analysis based on the emissions from the site and its location in Utah County. The
area is already classified as non-attainment for PM10 and PM2.5 and maintenance
for carbon monoxide.

Hazardous Air Pollutants (HAP)
The HVAC system and water heaters have the potential to emit a total of 0.05 tons
of HAPs per year. The emissions are fugitive, and the nearest property boundary is
less than 20 meters away from the source. Nearly all the total mass of HAPs coming
from the HVAC system is in the form of hexane, which is emitted at a maximum rate
of 0.01 lbs/hr, while all other HAPs are emitted at a rate multiple orders of magnitude
less than hexane. According to the 2014 ACGIH-TLVs and UDAQ-TSLs and ETVs, the
chronic emission threshold value is 8.988 lbs/hr. Hexane emissions are below the
chronic emission threshold value. Therefore, MegaDiamond does not need to perform
dispersion modeling for hexane emissions.

Carbon Monoxide (CO)
MegaDiamond’s facility is located in Utah County which is classified as maintenance
area for Carbon Monoxide (CO). Modeling is required if CO emissions exceed the 100
tpy threshold. Facility emission calculations indicate that the facility will only emit
2.373 tons of CO per year.

NONATTAINMENT/MAINTENANCE AREAS – MAJOR
NSR/MINOR

Per R307-403-2(1) this section is only applicable for new major stationary sources or
major modifications that are major for the pollutant or precursor pollutant for which
the area is designated nonattainment. Utah County is classified as non-attainment
for PM10 and PM2.5. A project is a major modification for a regulated NSR pollutant
if it causes two types of emissions increases, a significant emissions increase (as
defined in 40 CFR 51.165(a)(1)(xxvii)), and a significant net emissions increase (as
defined in 40 CFR 51.165(a)(1)(vi) and (x)). The project is not a major modification
if it does not cause a significant emissions increase.
New Source Review Air Permit Application
MegaDiamond – South Facility ■ Provo, Utah
January 8, 2024 ■ Terracon Project No. MP237319

10

MegaDiamond is not emitting nor do they have the potential to emit 100 tons per
year or more of any regulated NSR pollutant. Therefore, this facility does not meet
the criteria of a major source and this section does not apply.

MAJOR SOURCES IN ATTAINMENT OR UNCLASSIFIED
AREAS

MegaDiamond is not a major source therefore this section is not applicable.

MegaDiamond - South Facility
Table #4 - Abrasive Blasting
2185 Tracy Hall Pkwy
Provo, UT 84606
Abrasive Blasting
Blasting Media Kelco Units Guyson Units
Blasting Media Bulk Density (lb/ft3)1 71 91
Blasting Units 1 2
Abrasive Max Hourly Usage (lb/hr) (Kelco)2 0.25 0.50
Abrasive Max Hourly Usage (lb/hr) (Guyson)2 80 80
Abrasive Max Annual Usage (ton/yr) (Kelco)3 255 2,100
Abrasive Max Annual Usage (ton/yr) (Guyson)3
Total PM5 (lbs emissions/1,000 lbs abrasive)Abrasive blasting of unspecified metal parts, controlled with a fabric filter
PM105 (lbs emissions/1,000 lbs abrasive)Sand blasting of mild steel panels - No Control
PM2.55 (lbs emissions/1,000 lbs abrasive)Sand blasting of mild steel panels - No Control
Baghouse Efficiency PM106
Baghouse Efficiency PM2.56
1Silicon Carbide Bulk Density https://irp-cdn.multiscreensite.com/8570e72d/files/uploaded/Bulk%20Density%20Abrasives.pdf
2Silica Carbide flowrate is calculated using AP42 Ch 13 s02-6 Equation 2-1
3Based on 30 minutes an hour, 22 hrs a day, 6 days a week of operation.
4Theoretical flowrate of sand based on 1/4" or 1/2" nozzle and 80 psig at the nozzle AP42 Ch 13 s02-6 Table 2.2
5Emission Factors Taken from AP-42 Ch 13 s02-6 Table 1
6Filters are MERV 15 rated
Calculations
Blaster/Grinder Room
1
Blaster/Grinder Room
2
Blaster/Grinder Room
3 Asphalt Finishing Asphalt Finishing Asphalt Finishing Totals
Blaster Grinder Room Press Alley Press Alley Asphalt Finishing Asphalt Finishing Asphalt Finishing
Hourly Usage Rate lb/hr 273.03 273.03 273.03 2,248.48 2,248.48 2,248.48
Annual Usage Rate ton/yr 469.807 469.807 469.807 3,869.000 3,869.000 3,869.000
PTE Calculations
PM 0.19 0.19 0.19 1.55 1.55 1.55 5.22
PM10 0.18 0.18 0.18 1.46 1.46 1.46 4.92
PM2.5 0.04 0.04 0.04 0.29 0.29 0.29 0.98
PM 0.825 0.825 0.825 6.795 6.795 6.795 22.862
PM10 0.777 0.777 0.777 6.401 6.401 6.401 21.536
PM2.5 0.155 0.155 0.155 1.280 1.280 1.280 4.307
Actual Calculations
PM 0.09 0.09 0.09 0.78 0.78 0.78 2.61
PM10 0.09 0.09 0.09 0.73 0.73 0.73 2.46
PM2.5 0.02 0.02 0.02 0.15 0.15 0.15 0.49
PM 0.324 0.324 0.324 2.670 2.670 2.670 8.981
PM10 0.305 0.305 0.305 2.515 2.515 2.515 8.461
PM2.5 0.061 0.061 0.061 0.503 0.503 0.503 1.692
lb/hr
ton/yr
lb/hr
ton/yr
Baghouse
Location
13
1.3
95%
Silicon Carbide
7
273.03
3,869.000
0.69
106
2,248.48
469.807
90%
Theoretical sand flow through nozzle (lbs/hr)4
Flow Rate per nozzle (cfm)
Nozzles per unit
Nozzle Diameter (in)
Maximum pressure at nozzle (psig)
1/8/2024
Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number
2. Company contact (Name, mailing address, and telephone number)
3. Name and contact of person submitting NOI application (if different than 2)
4. Source Universal Transverse Mercator (UTM) coordinates
5. Source Standard Industrial Classification (SIC) code
6. Area designation (attainment, maintenance, or nonattainment)
7. Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8. Source size determination (Major, Minor, PSD)
9. Current Approval Order(s) and/or Title V Permit numbers
NOI Application Information:[R307-401]
N/A
N/A
A. Air quality analysis (air model, met data, background data, source impact analysis)N/A
Detailed description of the project and source process
Discussion of fuels, raw materials, and products consumed/produced
Description of equipment used in the process and operating schedule
Description of changes to the process, production rates, etc.
Site plan of source with building dimensions, stack parameters, etc.
Best Available Control Technology (BACT) Analysis [R307-401-8]
BACT analysis for all new and modified equipment
Emissions Related Information: [R307-401-2(b)]
Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)
References/assumptions, SDS, for each calculation and pollutant
All speciated HAP emissions (list in lbs/hr)
Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
Alternative site analysis, Major source ownership compliance certification
Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
Visibility impact analysis, Class I area impact N/A
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
MegaDiamond
1/8/24
Page 1 of 1
Form 3 Company____________________
Process Information Site________________________
Utah Division of Air Quality
New Source Review Section
Process Information
1. Name of process:2. End product of this process:
3. Process Description*:
Operating Data
4. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year
5. Percent annual production by quarter:
Winter ________Spring _______
Summer ________Fall _______
6. Maximum Hourly production (indicate units.):
_____________
7. Maximum annual production (indicate units):
________________
8. Type of operation:
Continuous Batch Intermittent
9. If batch, indicate minutes per cycle ________
Minutes between cycles ________
10. Materials and quantities used in process.*
Material Maximum Annual Quantity (indicate units)
11.Process-Emitting Units with pollution control equipment*
Emitting Unit(s)Capacity(s)Manufacture Date(s)
*If additional space is required, please create a spreadsheet or Word processing document and attach to form.
MegaDiamond
South Facility
Entire Site Cutting/Grinders for
O&G Industry
Refer to the permit report and Form 2's following this section for details
regarding the process descriptions.
22
6
52
25%
25%
25%
25%
Abrasive Blasting 13,017 TPY grit
Granite Cutting, Grinders, and Press Debris N/A
Solvent Cleaning 4,000 lbs solvent
Emergency Generator 10KW 8/1/99
HVAC Equipment 6.482 MMBtu/hr
Page 1 of 1
Company___________________________
_____________________________
Form
Emissions Information
Criteria/GHGs/
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants**(**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
MegaDiamond
South Facility
5.25 7.47 12.72
2.87 -2.40 0.47
5.25 0.71 5.96
2.90 -0.10 2.80
0.02 0.00 0.02
2.45 -0.08 2.37
2.93 -1.20 1.73
2.93 -1.20 1.73
0.00 0.00 0.00
3451.56 -111.42 3340.14
1.65 -0.05 1.60
18.85 -0.60 18.25
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
3471.40 -109.97 3361.03
Methanol 1.20 -1.20 0.00 -1.60
Miscellaneous Gas Combustion 0.05 0.00 0.05 0.00
1.25 -1.20 0.05 -1.60
Utah Division of Air Quality
New Source Review Section
Form 2
Process Information
Process Data
Operating Data
1/8/24
South Facility
MegaDiamond
Abrasive Blaster Prepared Parts
Abrasive Blaster
1/4" 80 psi 273 lbs/hr/unit
X
X
22
X
6
52
25%
25%
25%
25%
X
Blasting Grit Surface Preparation 470 tons / yr / unit
Note that a majority of this is recaptured
and recycled or disposed of.
Kelco
CH-30-C NOD/C
Unknown
Process
Form 2 (Continued)
Stack Data
Emissions Calculations (PTE)
Cartridge Baghouse
Donaldson - Torit
Particulate Matter
0.532 lbs/hr
95% for PM10 90% for PM2.5
95% for PM10 90% for PM2.5
SV-001 N/A
13.5
X
X
X
12"20"
70 4000 2400
0.53 2.332 0.11 0.466
Utah Division of Air Quality
New Source Review Section
Form 2
Process Information
Process Data
Operating Data
1/8/24
South Facility
MegaDiamond
Abrasive Blaster - Asphalt Prepared Parts
Abrasive Blaster
1/2" 80 psi 2,248 lbs/hr/unit
X
X
22
X
6
52
25%
25%
25%
25%
X
Blasting Grit Surface Preparation 3,869 tons / yr / unit
Note that a majority of this is recaptured
and recycled or disposed of.
60,000 parts
0%
Process
Form 2 (Continued)
Stack Data
Emissions Calculations (PTE)
Cartridge Baghouse
Festool w/ OneIde Air System
Cleantex 36 E
Particulate Matter
4.385 lbs/hr
Indoor Fugitive N/A
IF-001 N/A
X
X
70
4.38 19.204
N/A
N/A N/A
0.88 3.841
95% for PM10 90% for PM2.5
95% for PM10 90% for PM2.5
Utah Division of Air Quality
New Source Review Section
Form 2
Process Information
Process Data
Operating Data
1/8/24
South Facility
MegaDiamond
Solvent Cleaning Clean Parts / Areas
N/A
X
X
24
X
6
52
25%
25%
25%
25%
X
Isopropanol Cleaning 3,000 lbs / year
Room Fugitives
Dry Lubricant Lubrication 1,000 lbs / year
60,000 parts
Process
Form 2 (Continued)
Stack Data
Emissions Calculations (PTE)
N/A
IF-004 N/A
X
X
X
3.56 1.570
N/A
N/A N/A N/A
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
Gas Stream Characteristics
Equipment Information and Filter Characteristics
Emissions Calculations (PTE)
MegaDiamond
South Facility
Abrasive Blasting Units
4,000
4,000 4,000 4,000 N/A Varies 0.016
68 Deg F
0.27 0.916 0.05 0.183
13.5
12x20
22
3440
Donaldson Torit
12.74 2.2 6
X
MERV 15NanoFiberX
1/8/24
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
Gas Stream Characteristics
Equipment Information and Filter Characteristics
Emissions Calculations (PTE)
MegaDiamond
South Facility
Abrasive Blasters in Asphalt Area
N/A Varies 0.016
68 Deg F
Vents Indoors
22
3440
2.19 7.545 0.44 1.509
Donalson - Torit
12.74 2.2 6
X
MERV 15NanoFiberX
1/8/24
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
Gas Stream Characteristics
Equipment Information and Filter Characteristics
Emissions Calculations (PTE)
MegaDiamond
North Facility
Granite Cutting Unit
4,500
4,500 4,500 4,500 Varies 0.016
N/A
68 Deg F
12
20.5 x 26
1700
0.62 0.525
8
Donaldson Torit
X NanoFiber
12.74 2.2 6
X
MERV 15
1/8/24
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
Gas Stream Characteristics
Equipment Information and Filter Characteristics
Emissions Calculations (PTE)
MegaDiamond
South Facility
Miscellaneous Grinders for parts
4,000
4,000 4,000 4,000 Varies 0.016
N/A
68 Deg F
25
18
22
6600
0.55 1.810
Airflow Systems F-240
X NanoFiber Merv 15
12.74 2.2 6
X
1/8/24
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
Gas Stream Characteristics
Equipment Information and Filter Characteristics
Emissions Calculations (PTE)
Grinders for Miscellaneous Processes
4,000
4,000
4,000 0.016N/A
68 Deg F
Varies
Vents Indoors
22
6600
0.55 1.810
MegaDiamond
South Facility
4,000
Vents Indoors
Airflow Systems F-240
1/8/24
12.74 2.2 6
MERV 15NanoFiber
X
X
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
Gas Stream Characteristics
Equipment Information and Filter Characteristics
Emissions Calculations (PTE)
MegaDiamond
South Facility
Controls the areas around the presses to pick up debris.
380
380 380 380 N/A Varies 0.016
68 Deg F
0.0630.05
2400
Vents Indoors
Vents Indoors
Donaldson Torit TD-573
12.74 2.2 6
X
MERV 15XNanoFiber
1/8/24
Utah Division of Air Quality
New Source Review Section Company _______________________
Site/Source _____________________
Form 10 Date __________________________
Fabric Filters (Baghouses)

Baghouse Description
1. Briefly describe the process controlled by this baghouse:

Gas Stream Characteristics
2. Flow Rate (acfm):

4. Particulate Loading (grain/scf)
Design Max

Average
Expected

3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F): 7. Fan Requirements (hp) (ft3/min)

Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.) 12. Number of Bags: 13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□ Nomex nylon
□ Polyester
□ Acrylics
□ Fiber glass
□ Cotton
□ Teflon
□ ___________
14. Filtering
Efficiency
Rating:

_________%
15. Air to Cloth
Ratio:

______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□ Reverse Air □ Shaker
□ Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Page 2 of 2

Instructions - Form 10 Fabric Filters (Baghouses)

NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.

2. Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in
filling out this form. Ask to speak with a New Source Review engineer. We will be glad to
help!

1. Describe the process equipment that the filter controls, what product is being controlled, particle size
data (if available), i.e., cement silo, grain silo, nuisance dust in work place, process control with high
dust potential, etc.
2. The maximum and design exhaust gas flow rates through the filter control device in actual cubic feet
per minute (ACFM). Check literature or call the sales agent.
3. The water/moisture content of the gas stream going through the filter.
4. The amount of particulate in the gas stream going into the filter and the amount coming out if available.
Outlet default value = 0.016 grains PM10/dscf.
5. The pressure drop range across the system. Usually given in the literature in inches of water.
6. The temperature of the gas stream entering the filter system in degrees Fahrenheit.
7. The horse power of the fan used to move the gas stream and/or the flow rate of the fan in ft3/min.
8. Name of the manufacturer of the filter equipment and the model number if available.
9. Check the type of filter bag material or fill in the blank. Check literature or call the sales agent.
10. The diameter of the bags in the system. Check literature or call the sales agent.
11. The length of the bags in the system. Check literature or call the sales agent.
12. The number of bags. Check literature or call the sales agent.
13. The height to the top of the stack from ground level and the stack inside diameter.
14. The filtering efficiency rating that the manufacturer quotes. Check literature or call the sales agent.
15. The ratio of the flow rate of air to the cloth area (A/C).
16. The number of hours that the process equipment is in operation, maximum per day and per year.
17. The way in which the filters bags are cleaned. Check the appropriate box.
18. Supply calculations for all criteria pollutants and HAPs. Use AP42 or Manufacturers data to complete
your calculations.

U:\aq\ENGINEER\GENERIC\Forms 2010\Form10 Baghouses.doc
Revised 12/20/10

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-6072261923508…1/44
Dungan Adams <[e-mail]>
NOI Received for MegaDiamond South Facility
15 messages
Dungan Adams <[e-mail]>Thu, Jan 25, 2024 at 3:53 PM
To: [e-mail]
Cc: [e-mail], Amanda Fleenor <[e-mail]>
Hi Nathan,
The Utah Division of Air Quality has received MegaDiamond's updated NOI for a modification to their South Facility on
January 10th, 2024. I am reviewing the NOI and will reach out in the following days if I have any questions or concerns.
Thanks,
Dungan
--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
Dungan Adams <[e-mail]>Mon, Jan 29, 2024 at 4:30 PM
To: [e-mail]
Cc: [e-mail], Amanda Fleenor <[e-mail]>
Hi Nathan,
Page 29 of the modification NOI application (Form 5, Emissions Information) lists different permitted emissions than what
I see in the DAQ's records. I've attached the active Approval Order (AO) so you can see what is currently permitted for the
facility. I'm thinking what is listed as "Permitted Emissions" are the emissions estimates from the original NOI that was
submitted back in August 2023. Nothing needs to be resubmitted, I just wanted to make sure that we are on the same
page in case this changes anything on your end.
Thanks,
Dungan
[Quoted text hidden]
DAQE-AN160750001-22.pdf
527K
Borowick, Nathan <[e-mail]>Tue, Jan 30, 2024 at 8:08 AM
To: Dungan Adams <[e-mail]>
Cc: "Larson, Chris" <[e-mail]>, Amanda Fleenor <[e-mail]>
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-6072261923508…2/44
Dungan,

The emissions we had listed as “Permitted Emissions” came from the previous air permit application that was submitted
for the South Facility in 2021.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

[Quoted text hidden]
Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services delivered with
responsiveness, resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the hyperlink, please e-mail
sender.
Dungan Adams <[e-mail]>Tue, Jan 30, 2024 at 9:32 AM
To: "Borowick, Nathan" <[e-mail]>
Cc: "Larson, Chris" <[e-mail]>, Amanda Fleenor <[e-mail]>
Nathan,
Thank you for clarifying.
I realized I sent over the incorrect Approval Order (AO) in my initial email -- I accidentally attached the AO for the North
Facility. I've attached the correct active AO for the South Facility. Please take a look at the AO and make sure it is clear
what is currently permitted as this is the AO that will be modified, not the application that was submitted in 2021.
Sorry for any confusion this caused and let me know if you have any questions.
Thanks,
Dungan
[Quoted text hidden]
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-6072261923508…3/44
DAQE-AN160760001-22.pdf
529K
Dungan Adams <[e-mail]>Wed, Feb 7, 2024 at 12:24 PM
To: "Borowick, Nathan" <[e-mail]>
Cc: "Larson, Chris" <[e-mail]>, Amanda Fleenor <[e-mail]>
Hi Nathan,
I have another quick question about the NOI. As part of the modification, MegaDiamond is adding two (2) abrasive
blasting units to the blaster grinder room of the facility. This brings the total to seven (7) abrasive blasting units, some of
which are Kelco units and some of which are Guyson units.
Could you specify how many of each type of unit are present? Each Kelco unit produces 0.324 tpy of PM and each
Guyson unit produces 2.670 tpy of PM. The combined emissions from these processes is listed at 8.98 tpy of PM, but I
wasn't able to get to this number. All combinations of seven units that I tried produced either higher or lower emissions
than 8.98 tpy of PM. On page 15 of the NOI it looks like the emissions were calculated using three (3) Kelco units and
three (3) Guyson units, which would mean one unit is missing.
Please take a look and let me know if you have any questions.
Thanks,
Dungan
[Quoted text hidden]
Borowick, Nathan <[e-mail]>Wed, Feb 7, 2024 at 12:56 PM
To: Dungan Adams <[e-mail]>
Cc: "Larson, Chris" <[e-mail]>, Amanda Fleenor <[e-mail]>
Dungan,

There are 3 each of the Guyson and Kelco units. The seventh unit is the glass bead blasting unit, which is included in the
previous AO, which has insignificant emissions.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-6072261923508…4/44

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 1:25 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

I have another quick question about the NOI. As part of the modification, MegaDiamond is adding two (2) abrasive
blasting units to the blaster grinder room of the facility. This brings the total to seven (7) abrasive blasting units, some of
which are Kelco units and some of which are Guyson units.

Could you specify how many of each type of unit are present? Each Kelco unit produces 0.324 tpy of PM and each
Guyson unit produces 2.670 tpy of PM. The combined emissions from these processes is listed at 8.98 tpy of PM, but I
wasn't able to get to this number. All combinations of seven units that I tried produced either higher or lower emissions
than 8.98 tpy of PM. On page 15 of the NOI it looks like the emissions were calculated using three (3) Kelco units and
three (3) Guyson units, which would mean one unit is missing.

Please take a look and let me know if you have any questions.

Thanks,
Dungan

On Tue, Jan 30, 2024 at 9:32 AM Dungan Adams <[e-mail]> wrote:
Nathan,

Thank you for clarifying.

I realized I sent over the incorrect Approval Order (AO) in my initial email -- I accidentally attached the AO for the North
Facility. I've attached the correct active AO for the South Facility. Please take a look at the AO and make sure it is clear
what is currently permitted as this is the AO that will be modified, not the application that was submitted in 2021.

Sorry for any confusion this caused and let me know if you have any questions.

Thanks,
Dungan

On Tue, Jan 30, 2024 at 8:08 AM Borowick, Nathan <[e-mail]> wrote:
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-6072261923508…5/44
Dungan,

The emissions we had listed as “Permitted Emissions” came from the previous air permit application that was
submitted for the South Facility in 2021.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Monday, January 29, 2024 5:31 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

Page 29 of the modification NOI application (Form 5, Emissions Information) lists different permitted emissions than
what I see in the DAQ's records. I've attached the active Approval Order (AO) so you can see what is currently
permitted for the facility. I'm thinking what is listed as "Permitted Emissions" are the emissions estimates from the
original NOI that was submitted back in August 2023. Nothing needs to be resubmitted, I just wanted to make sure
that we are on the same page in case this changes anything on your end.

Thanks,
Dungan

On Thu, Jan 25, 2024 at 3:53 PM Dungan Adams <[e-mail]> wrote:
Hi Nathan,
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-6072261923508…6/44

The Utah Division of Air Quality has received MegaDiamond's updated NOI for a modification to their South
Facility on January 10th, 2024. I am reviewing the NOI and will reach out in the following days if I have any
questions or concerns.

Thanks,
Dungan

--

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

--

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-6072261923508…7/44
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services delivered
with responsiveness, resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the hyperlink,
please e-mail sender.

--

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

--
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-6072261923508…8/44

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

Dungan Adams <[e-mail]>Wed, Feb 7, 2024 at 1:32 PM
To: "Borowick, Nathan" <[e-mail]>
Cc: "Larson, Chris" <[e-mail]>, Amanda Fleenor <[e-mail]>
Nathan,
Please provide emission calculations or justification that all emissions from the bead blasting unit are zero. I wasn't able to
find this information in the project file for the active AO. If the emissions are non-zero then we need to include them in the
sitewide PTE.
Thanks,
Dungan
[Quoted text hidden]
Borowick, Nathan <[e-mail]>Wed, Feb 7, 2024 at 2:19 PM
To: Dungan Adams <[e-mail]>
Cc: "Larson, Chris" <[e-mail]>, Amanda Fleenor <[e-mail]>
Dungan,

Please see attached for the form 10 that was previously submitted to the state. Calculated emissions are on the bottoms
of page one and were counted as insignificant in the previous permit application. These emissions were calculated by
using 0.016 grains/scf at 250 SCFM at the outlet. If you need more information, please let us know and we can reach
back out to the site.

Thanks,

Nathan Borowick
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-6072261923508…9/44
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 2:32 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Nathan,

Please provide emission calculations or justification that all emissions from the bead blasting unit are zero. I wasn't able to
find this information in the project file for the active AO. If the emissions are non-zero then we need to include them in the
sitewide PTE.

Thanks,
Dungan

On Wed, Feb 7, 2024 at 12:56 PM Borowick, Nathan <[e-mail]> wrote:
Dungan,

There are 3 each of the Guyson and Kelco units. The seventh unit is the glass bead blasting unit, which is included in
the previous AO, which has insignificant emissions.

Thanks,

Nathan Borowick
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…10/44
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 1:25 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

I have another quick question about the NOI. As part of the modification, MegaDiamond is adding two (2) abrasive
blasting units to the blaster grinder room of the facility. This brings the total to seven (7) abrasive blasting units, some of
which are Kelco units and some of which are Guyson units.

Could you specify how many of each type of unit are present? Each Kelco unit produces 0.324 tpy of PM and each
Guyson unit produces 2.670 tpy of PM. The combined emissions from these processes is listed at 8.98 tpy of PM, but I
wasn't able to get to this number. All combinations of seven units that I tried produced either higher or lower emissions
than 8.98 tpy of PM. On page 15 of the NOI it looks like the emissions were calculated using three (3) Kelco units and
three (3) Guyson units, which would mean one unit is missing.

Please take a look and let me know if you have any questions.

Thanks,
Dungan

On Tue, Jan 30, 2024 at 9:32 AM Dungan Adams <[e-mail]> wrote:
Nathan,

Thank you for clarifying.

I realized I sent over the incorrect Approval Order (AO) in my initial email -- I accidentally attached the AO for the
North Facility. I've attached the correct active AO for the South Facility. Please take a look at the AO and make sure
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…11/44
it is clear what is currently permitted as this is the AO that will be modified, not the application that was submitted in
2021.

Sorry for any confusion this caused and let me know if you have any questions.

Thanks,
Dungan

On Tue, Jan 30, 2024 at 8:08 AM Borowick, Nathan <[e-mail]> wrote:
Dungan,

The emissions we had listed as “Permitted Emissions” came from the previous air permit application that was
submitted for the South Facility in 2021.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Monday, January 29, 2024 5:31 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…12/44
Page 29 of the modification NOI application (Form 5, Emissions Information) lists different permitted emissions
than what I see in the DAQ's records. I've attached the active Approval Order (AO) so you can see what is
currently permitted for the facility. I'm thinking what is listed as "Permitted Emissions" are the emissions estimates
from the original NOI that was submitted back in August 2023. Nothing needs to be resubmitted, I just wanted to
make sure that we are on the same page in case this changes anything on your end.

Thanks,
Dungan

On Thu, Jan 25, 2024 at 3:53 PM Dungan Adams <[e-mail]> wrote:
Hi Nathan,

The Utah Division of Air Quality has received MegaDiamond's updated NOI for a modification to their South
Facility on January 10th, 2024. I am reviewing the NOI and will reach out in the following days if I have any
questions or concerns.

Thanks,
Dungan

--

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

--
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…13/44

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

Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services
delivered with responsiveness, resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the hyperlink,
please e-mail sender.

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…14/44
airquality.utah.gov

--

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

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…15/44
M: [phone]
airquality.utah.gov

Glass Bead Baghouse South.pdf
136K
Dungan Adams <[e-mail]>Wed, Feb 7, 2024 at 2:22 PM
To: "Borowick, Nathan" <[e-mail]>
Nathan,
Thank you. I will add these PM emissions to the site-wide totals.
Thanks,
Dungan
[Quoted text hidden]
Borowick, Nathan <[e-mail]>Wed, Feb 28, 2024 at 8:45 AM
To: Dungan Adams <[e-mail]>
Good morning Dungan,

I just wanted to check in quick and see where we were at in the approval process for MegaDiamond’s recently submitted
NOI. Let me know if you need anything to help the process along.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…16/44
From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 3:22 PM
To: Borowick, Nathan <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Nathan,

Thank you. I will add these PM emissions to the site-wide totals.

Thanks,
Dungan

On Wed, Feb 7, 2024 at 2:19 PM Borowick, Nathan <[e-mail]> wrote:
Dungan,

Please see attached for the form 10 that was previously submitted to the state. Calculated emissions are on the
bottoms of page one and were counted as insignificant in the previous permit application. These emissions were
calculated by using 0.016 grains/scf at 250 SCFM at the outlet. If you need more information, please let us know and
we can reach back out to the site.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 2:32 PM
To: Borowick, Nathan <[e-mail]>
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…17/44
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Nathan,

Please provide emission calculations or justification that all emissions from the bead blasting unit are zero. I wasn't
able to find this information in the project file for the active AO. If the emissions are non-zero then we need to include
them in the sitewide PTE.

Thanks,
Dungan

On Wed, Feb 7, 2024 at 12:56 PM Borowick, Nathan <[e-mail]> wrote:
Dungan,

There are 3 each of the Guyson and Kelco units. The seventh unit is the glass bead blasting unit, which is included
in the previous AO, which has insignificant emissions.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 1:25 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…18/44
Hi Nathan,

I have another quick question about the NOI. As part of the modification, MegaDiamond is adding two (2) abrasive
blasting units to the blaster grinder room of the facility. This brings the total to seven (7) abrasive blasting units,
some of which are Kelco units and some of which are Guyson units.

Could you specify how many of each type of unit are present? Each Kelco unit produces 0.324 tpy of PM and each
Guyson unit produces 2.670 tpy of PM. The combined emissions from these processes is listed at 8.98 tpy of
PM, but I wasn't able to get to this number. All combinations of seven units that I tried produced either higher or
lower emissions than 8.98 tpy of PM. On page 15 of the NOI it looks like the emissions were calculated using three
(3) Kelco units and three (3) Guyson units, which would mean one unit is missing.

Please take a look and let me know if you have any questions.

Thanks,
Dungan

On Tue, Jan 30, 2024 at 9:32 AM Dungan Adams <[e-mail]> wrote:
Nathan,

Thank you for clarifying.

I realized I sent over the incorrect Approval Order (AO) in my initial email -- I accidentally attached the AO for the
North Facility. I've attached the correct active AO for the South Facility. Please take a look at the AO and make
sure it is clear what is currently permitted as this is the AO that will be modified, not the application that was
submitted in 2021.

Sorry for any confusion this caused and let me know if you have any questions.

Thanks,
Dungan

On Tue, Jan 30, 2024 at 8:08 AM Borowick, Nathan <[e-mail]> wrote:
Dungan,

The emissions we had listed as “Permitted Emissions” came from the previous air permit application that was
submitted for the South Facility in 2021.

Thanks,
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…19/44

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Monday, January 29, 2024 5:31 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

Page 29 of the modification NOI application (Form 5, Emissions Information) lists different permitted emissions
than what I see in the DAQ's records. I've attached the active Approval Order (AO) so you can see what is
currently permitted for the facility. I'm thinking what is listed as "Permitted Emissions" are the emissions
estimates from the original NOI that was submitted back in August 2023. Nothing needs to be resubmitted, I
just wanted to make sure that we are on the same page in case this changes anything on your end.

Thanks,
Dungan

On Thu, Jan 25, 2024 at 3:53 PM Dungan Adams <[e-mail]> wrote:
Hi Nathan,

The Utah Division of Air Quality has received MegaDiamond's updated NOI for a modification to their South
Facility on January 10th, 2024. I am reviewing the NOI and will reach out in the following days if I have any
questions or concerns.

Thanks,
Dungan
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…20/44

--

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

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…21/44

Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services
delivered with responsiveness, resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the hyperlink,
please e-mail sender.

--

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

--

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…22/44
Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

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

--
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…23/44

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

Dungan Adams <[e-mail]>Wed, Feb 28, 2024 at 9:26 AM
To: "Borowick, Nathan" <[e-mail]>
Hi Nathan,
Thanks for reaching out. I should have the Engineering Review (ER) for this project finalized in the next week or so. Then
the ER will go through a series of internal reviews before it is sent to you. Once the ER is reviewed by you, it will go
through a 30 day public comment period, and then the final AO will be issued.
Let me know if you have any questions.
Thanks,
Dungan
[Quoted text hidden]
Borowick, Nathan <[e-mail]>Wed, Feb 28, 2024 at 9:40 AM
To: Dungan Adams <[e-mail]>
Dungan,

Thanks for getting back to me. I’ll let you know if I have further questions!

Best,

Nathan Borowick
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…24/44
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 28, 2024 10:27 AM
To: Borowick, Nathan <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

Thanks for reaching out. I should have the Engineering Review (ER) for this project finalized in the next week or so. Then
the ER will go through a series of internal reviews before it is sent to you. Once the ER is reviewed by you, it will go
through a 30 day public comment period, and then the final AO will be issued.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Feb 28, 2024 at 8:45 AM Borowick, Nathan <[e-mail]> wrote:
Good morning Dungan,

I just wanted to check in quick and see where we were at in the approval process for MegaDiamond’s recently
submitted NOI. Let me know if you need anything to help the process along.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…25/44
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 3:22 PM
To: Borowick, Nathan <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Nathan,

Thank you. I will add these PM emissions to the site-wide totals.

Thanks,
Dungan

On Wed, Feb 7, 2024 at 2:19 PM Borowick, Nathan <[e-mail]> wrote:
Dungan,

Please see attached for the form 10 that was previously submitted to the state. Calculated emissions are on the
bottoms of page one and were counted as insignificant in the previous permit application. These emissions were
calculated by using 0.016 grains/scf at 250 SCFM at the outlet. If you need more information, please let us know and
we can reach back out to the site.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…26/44

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 2:32 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Nathan,

Please provide emission calculations or justification that all emissions from the bead blasting unit are zero. I wasn't
able to find this information in the project file for the active AO. If the emissions are non-zero then we need to include
them in the sitewide PTE.

Thanks,
Dungan

On Wed, Feb 7, 2024 at 12:56 PM Borowick, Nathan <[e-mail]> wrote:
Dungan,

There are 3 each of the Guyson and Kelco units. The seventh unit is the glass bead blasting unit, which is
included in the previous AO, which has insignificant emissions.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…27/44

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 1:25 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

I have another quick question about the NOI. As part of the modification, MegaDiamond is adding two (2) abrasive
blasting units to the blaster grinder room of the facility. This brings the total to seven (7) abrasive blasting units,
some of which are Kelco units and some of which are Guyson units.

Could you specify how many of each type of unit are present? Each Kelco unit produces 0.324 tpy of PM and
each Guyson unit produces 2.670 tpy of PM. The combined emissions from these processes is listed at 8.98 tpy
of PM, but I wasn't able to get to this number. All combinations of seven units that I tried produced either higher or
lower emissions than 8.98 tpy of PM. On page 15 of the NOI it looks like the emissions were calculated using
three (3) Kelco units and three (3) Guyson units, which would mean one unit is missing.

Please take a look and let me know if you have any questions.

Thanks,
Dungan

On Tue, Jan 30, 2024 at 9:32 AM Dungan Adams <[e-mail]> wrote:
Nathan,

Thank you for clarifying.

I realized I sent over the incorrect Approval Order (AO) in my initial email -- I accidentally attached the AO for
the North Facility. I've attached the correct active AO for the South Facility. Please take a look at the AO and
make sure it is clear what is currently permitted as this is the AO that will be modified, not the application that
was submitted in 2021.

Sorry for any confusion this caused and let me know if you have any questions.

Thanks,
Dungan

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…28/44

On Tue, Jan 30, 2024 at 8:08 AM Borowick, Nathan <[e-mail]> wrote:
Dungan,

The emissions we had listed as “Permitted Emissions” came from the previous air permit application that
was submitted for the South Facility in 2021.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Monday, January 29, 2024 5:31 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

Page 29 of the modification NOI application (Form 5, Emissions Information) lists different permitted
emissions than what I see in the DAQ's records. I've attached the active Approval Order (AO) so you can
see what is currently permitted for the facility. I'm thinking what is listed as "Permitted Emissions" are the
emissions estimates from the original NOI that was submitted back in August 2023. Nothing needs to be
resubmitted, I just wanted to make sure that we are on the same page in case this changes anything on your
end.

Thanks,
Dungan

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…29/44
On Thu, Jan 25, 2024 at 3:53 PM Dungan Adams <[e-mail]> wrote:
Hi Nathan,

The Utah Division of Air Quality has received MegaDiamond's updated NOI for a modification to their
South Facility on January 10th, 2024. I am reviewing the NOI and will reach out in the following days if I
have any questions or concerns.

Thanks,
Dungan

--

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

--

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…30/44

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

Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services
delivered with responsiveness, resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the
hyperlink, please e-mail sender.

--

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

--
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…31/44

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

--

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

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…32/44

--

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

--

Dungan Adams
Environmental Engineer I | Minor NSR Section
M: [phone]
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…33/44
airquality.utah.gov

Dungan Adams <[e-mail]>Fri, Mar 1, 2024 at 1:25 PM
To: "Borowick, Nathan" <[e-mail]>
Nathan,
Quick question. Is the emergency generator a rich-burn or lean-burn four-stroke engine? The emission factors used in the
current NOI (Page 17, Table #6) are rich-burn, the note below the table and the previous NOI say the emission factors are
lean-burn.
Thanks,
Dungan
[Quoted text hidden]
Borowick, Nathan <[e-mail]>Fri, Mar 1, 2024 at 3:35 PM
To: Dungan Adams <[e-mail]>
Dungan,

The emergency engine is rich burn. The listed emissions factors are corrected but the caption is mislabeled. Going
through old files, it looks like the same thing happened in the previous NOI.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Friday, March 1, 2024 2:26 PM
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…34/44
To: Borowick, Nathan <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Nathan,

Quick question. Is the emergency generator a rich-burn or lean-burn four-stroke engine? The emission factors used in the
current NOI (Page 17, Table #6) are rich-burn, the note below the table and the previous NOI say the emission factors are
lean-burn.

Thanks,
Dungan

On Wed, Feb 28, 2024 at 9:40 AM Borowick, Nathan <[e-mail]> wrote:
Dungan,

Thanks for getting back to me. I’ll let you know if I have further questions!

Best,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 28, 2024 10:27 AM
To: Borowick, Nathan <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…35/44

Thanks for reaching out. I should have the Engineering Review (ER) for this project finalized in the next week or so.
Then the ER will go through a series of internal reviews before it is sent to you. Once the ER is reviewed by you, it will
go through a 30 day public comment period, and then the final AO will be issued.

Let me know if you have any questions.

Thanks,
Dungan

On Wed, Feb 28, 2024 at 8:45 AM Borowick, Nathan <[e-mail]> wrote:
Good morning Dungan,

I just wanted to check in quick and see where we were at in the approval process for MegaDiamond’s recently
submitted NOI. Let me know if you need anything to help the process along.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 3:22 PM
To: Borowick, Nathan <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Nathan,

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…36/44
Thank you. I will add these PM emissions to the site-wide totals.

Thanks,
Dungan

On Wed, Feb 7, 2024 at 2:19 PM Borowick, Nathan <[e-mail]> wrote:
Dungan,

Please see attached for the form 10 that was previously submitted to the state. Calculated emissions are on the
bottoms of page one and were counted as insignificant in the previous permit application. These emissions were
calculated by using 0.016 grains/scf at 250 SCFM at the outlet. If you need more information, please let us know
and we can reach back out to the site.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 2:32 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Nathan,

Please provide emission calculations or justification that all emissions from the bead blasting unit are zero. I
wasn't able to find this information in the project file for the active AO. If the emissions are non-zero then we need
to include them in the sitewide PTE.
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…37/44

Thanks,
Dungan

On Wed, Feb 7, 2024 at 12:56 PM Borowick, Nathan <[e-mail]> wrote:
Dungan,

There are 3 each of the Guyson and Kelco units. The seventh unit is the glass bead blasting unit, which is
included in the previous AO, which has insignificant emissions.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Wednesday, February 7, 2024 1:25 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

I have another quick question about the NOI. As part of the modification, MegaDiamond is adding two (2)
abrasive blasting units to the blaster grinder room of the facility. This brings the total to seven (7) abrasive
blasting units, some of which are Kelco units and some of which are Guyson units.

Could you specify how many of each type of unit are present? Each Kelco unit produces 0.324 tpy of PM and
each Guyson unit produces 2.670 tpy of PM. The combined emissions from these processes is listed at 8.98
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…38/44
tpy of PM, but I wasn't able to get to this number. All combinations of seven units that I tried produced either
higher or lower emissions than 8.98 tpy of PM. On page 15 of the NOI it looks like the emissions were
calculated using three (3) Kelco units and three (3) Guyson units, which would mean one unit is missing.

Please take a look and let me know if you have any questions.

Thanks,
Dungan

On Tue, Jan 30, 2024 at 9:32 AM Dungan Adams <[e-mail]> wrote:
Nathan,

Thank you for clarifying.

I realized I sent over the incorrect Approval Order (AO) in my initial email -- I accidentally attached the AO for
the North Facility. I've attached the correct active AO for the South Facility. Please take a look at the AO and
make sure it is clear what is currently permitted as this is the AO that will be modified, not the application
that was submitted in 2021.

Sorry for any confusion this caused and let me know if you have any questions.

Thanks,
Dungan

On Tue, Jan 30, 2024 at 8:08 AM Borowick, Nathan <[e-mail]> wrote:
Dungan,

The emissions we had listed as “Permitted Emissions” came from the previous air permit application that
was submitted for the South Facility in 2021.

Thanks,

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…39/44
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

From: Dungan Adams <[e-mail]>
Sent: Monday, January 29, 2024 5:31 PM
To: Borowick, Nathan <[e-mail]>
Cc: Larson, Chris <[e-mail]>; Amanda Fleenor <[e-mail]>
Subject: Re: NOI Received for MegaDiamond South Facility

Hi Nathan,

Page 29 of the modification NOI application (Form 5, Emissions Information) lists different permitted
emissions than what I see in the DAQ's records. I've attached the active Approval Order (AO) so you can
see what is currently permitted for the facility. I'm thinking what is listed as "Permitted Emissions" are the
emissions estimates from the original NOI that was submitted back in August 2023. Nothing needs to be
resubmitted, I just wanted to make sure that we are on the same page in case this changes anything on
your end.

Thanks,
Dungan

On Thu, Jan 25, 2024 at 3:53 PM Dungan Adams <[e-mail]> wrote:
Hi Nathan,

The Utah Division of Air Quality has received MegaDiamond's updated NOI for a modification to their
South Facility on January 10th, 2024. I am reviewing the NOI and will reach out in the following days if I
have any questions or concerns.

Thanks,
Dungan

--
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…40/44

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

--

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

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…41/44
Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services
delivered with responsiveness, resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the
hyperlink, please e-mail sender.

--

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

--

Dungan Adams
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…42/44
Environmental Engineer I | Minor NSR Section
M: [phone]
airquality.utah.gov

--

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

--

3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…43/44

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

--

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

--
3/11/24, 5:20 PM State of Utah Mail - NOI Received for MegaDiamond South Facility
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-a:r8957815003436214929&simpl=msg-a:r-607226192350…44/44

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

Dungan Adams <[e-mail]>Mon, Mar 4, 2024 at 8:58 AM
To: "Borowick, Nathan" <[e-mail]>
Great, thanks for confirming.
-Dungan
[Quoted text hidden]
1/10/24, 3:50 PM State of Utah Mail - Fwd: MegaDiamond South Facility Air Permit Application
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1787730728380695614&simpl=msg-f:1787730692724400872&simpl=…1/2
Dungan Adams <[e-mail]>
Fwd: MegaDiamond South Facility Air Permit Application
2 messages
Alan Humpherys <[e-mail]>Wed, Jan 10, 2024 at 1:53 PM
To: Dungan Adams <[e-mail]>
Dungan,
Please see the attached information for MegaDiamond. If you have any questions, please let me know.
Thanks,
Alan
---------- Forwarded message ---------
From: Borowick, Nathan <[e-mail]>
Date: Wed, Jan 10, 2024 at 11:52 AM
Subject: MegaDiamond South Facility Air Permit Application
To: Alan Humpherys <[e-mail]>
Cc: Larson, Chris <[e-mail]>, Amanda Fleenor <[e-mail]>
Good afternoon Alan,

Please see the attached pdf for an electronic copy of MegaDiamond’s Air Permit Application for their South Facility in
Provo, for your records. A paper copy is on the way in the mail with the following UPS Tracking number:
1Z0W913E029229334.

Feel free to reach out to either myself or Chris Larson (cc’d) if you have any questions.

Thanks, and have a good day.

Nathan Borowick
Field Environmental Engineer I Environmental
13400 15th Avenue North I Minneapolis, Minnesota 55441
D [phone] I F [phone] I M [phone]
[e-mail] I Terracon.com

1/10/24, 3:50 PM State of Utah Mail - Fwd: MegaDiamond South Facility Air Permit Application
https://mail.google.com/mail/u/0/?ik=c52f18613a&view=pt&search=all&permthid=thread-f:1787730728380695614&simpl=msg-f:1787730692724400872&simpl=…2/2

Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services delivered with
responsiveness, resourcefulness, and reliability.
Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access the hyperlink, please e-mail
sender.
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
MegaDiamond South Facility Air Permit Application.pdf
8545K
Alan Humpherys <[e-mail]>Wed, Jan 10, 2024 at 1:54 PM
To: "Borowick, Nathan" <[e-mail]>
Cc: "Larson, Chris" <[e-mail]>, Amanda Fleenor <[e-mail]>, Dungan Adams
<[e-mail]>
Nathan,
I appreciate you sending this in. I've assigned Dungan Adams to start processing your application. If you have any
questions in the meantime, please let Dungan or me know.
Thanks,
Alan
[Quoted text hidden]