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Home My WebLink AboutDAQ-2024-009321 DAQE-AN149310002-24 {{$d1 }} Margaret Marsh Flowers Baking Company of Utah, LLC 1919 Flowers Circle Thomasville, GA 31757 margaret.marsh@flocorp.com Dear Ms. Marsh: Re: Approval Order: Modification to Approval Order DAQE-AN149310001-15 to Update Equipment and Emissions Project Number: N149310002 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on January 13, 2021. Flowers Baking Company of Utah, LLC must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Jake Ries, who can be contacted at (385) 306-6530 or jries@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:JR:jg cc: Salt Lake County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director July 19, 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-AN149310002-24 Modification to Approval Order DAQE-AN149310001-15 to Update Equipment and Emissions Prepared By Jake Ries, Engineer (385) 306-6530 jries@utah.gov Issued to Flowers Baking Company of Utah, LLC Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality July 19, 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 ..................................................................................................................... 9 ACRONYMS ............................................................................................................................... 10 DAQE-AN149310002-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Flowers Bakeries, LLC Flowers Baking Company of Utah, LLC Mailing Address Physical Address 1919 Flowers Circle 6208 Dannon Way Thomasville, GA 31757 West Jordan, UT 84081 Source Contact UTM Coordinates Name: Margaret Marsh 411,897 m Easting Phone: (229) 977-7752 4,493126 m Northing Email: margaret.marsh@flocorp.com Datum NAD83 UTM Zone 12 SIC code 2051 (Bread & Other Bakery Products, Except Cookies & Crackers) SOURCE INFORMATION General Description Flowers Baking Company of Utah, LLC (Flowers) operates a facility that produces bagels, breads, rolls, hamburger buns, hotdog buns, and pitas. The process consists of mixing flour and other ingredients, such as oats and seeds, allowing the dough to rise, forming, and then baking. The raw material, flour, is stored in silos on the outside of the building. Other materials, such as oats, raisins, and seeds, are delivered in bags, totes, or other containers that are stored in the building. NSR Classification Minor Modification at Minor Source Source Classification Located in Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA Salt Lake County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines DAQE-AN149310002-24 Page 4 Project Description The DAQ received an ownership change request dated May 4, 2023. The ownership changed from Papa Pita Bakery to Flowers Baking Company of Utah, LLC. Flowers has requested a modification to AO DAQE-AN149310001-15, dated January 28, 2015, to install two (2) catalytic oxidizers and a muffin oven line, replace a natural gas-fired boiler, and update site-wide PTE. The following updates were made to the AO: 1) Addition of two (2) Catalytic Oxidizers, listed as II.A.3. 2) Addition of one (1) Muffin Line Oven, listed as II.A.8. 3) Addition of one (1) Tortilla Line Oven, listed as II.A.7. 4) Addition of one (1) Flour Silo, listed as II.A.9. 5) Addition of one (1) Bagel Line Boiler, listed as II.A.10. 6) Addition of one (1) natural-gas-fired emergency generator, listed as II.A.11. 7) Addition of six (6) hot water heaters, listed as II.A.12. 8) Replacement of one (1) natural gas-fired boiler (previously listed as II.A.3) with two (2) new natural gas-fired boilers, listed as II.A.2. 9) Updated PTE to account for updated equipment, emission factors, and production. 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 3405 11021.00 Carbon Monoxide 5.76 11.07 Nitrogen Oxides 2.66 8.98 Particulate Matter - PM10 0.52 0.90 Particulate Matter - PM2.5 0.52 0.90 Sulfur Dioxide 0.02 0.06 Volatile Organic Compounds 9.88 28.90 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 180 Change (TPY) Total (TPY) Total HAPs -0.02 0.09 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] DAQE-AN149310002-24 Page 5 I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 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.4 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.5 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307- 150] I.6 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] I.7 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.8 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] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Flowers Baking Company of Utah, LLC II.A.2 Two (2) Natural Gas-Fired Boilers (NEW) Rating: 6.7 MMBtu/hr each Fuel: Natural Gas Contains: Nine (9) ppm Burners II.A.3 Two (2) Catalytic Oxidizers (NEW) Rating: 1.2 MMBtu/hr each Controls: Bagel Tunnel Oven Line and Thins Line Tunnel Oven. II.A.4 Bagel Line Tunnel Oven Rating: 9.8 MMBtu/hr II.A.5 Bread and Bun Line Tunnel Oven Rating: 9.0 MMBtu/hr DAQE-AN149310002-24 Page 6 II.A.6 Thins Line Tunnel Oven Rating: 8.1 MMBtu/hr II.A.7 Tortilla Line Oven (NEW) Rating: 1.0 MMBtu/hr II.A.8 Muffin Line Oven (NEW) Rating: 2.84 MMBtu/hr II.A.9 Four (4) Flour Silos (ONE (1) NEW) Capacity: 130,000 lbs each Closed system Listed for informational purposes only. II.A.10 Bagel Line Boiler (NEW) Rating: 2.5 MMBtu/hr II.A.11 Emergency Power Generator Engine (NEW) Fuel: Natural Gas Rating: 105 hp NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.12 Six (6) Hot Water Heaters (NEW) Rating: 0.38 MMBtu/hr 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 10% opacity from stationary sources. [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.1.b The owner/operator shall not exceed the following consumption limits: A. 166,911 decatherms of natural gas per rolling 12-month period for boilers and ovens. B. 21,444 decatherms of natural gas per rolling 12-month period for catalytic oxidizers. [R307-401-8] II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate new 12-month totals by the 20th day of each month using data from the previous 12 months for natural gas consumption. The owner/operator shall use billing statements or natural gas meter readings from the previous 12-months for natural gas. [R307-401-8] DAQE-AN149310002-24 Page 7 II.B.2 Catalytic Oxidizer Requirements II.B.2.a The owner/operator shall route all exhaust from the Bagel Line Tunnel Oven and Thins Line Tunnel Oven to a catalytic oxidizer at all times during operation. The catalytic oxidizer shall reduce VOC emissions by at least 95%. [R307-401-8] II.B.2.a.1 Compliance Demonstration To demonstrate compliance with the destruction efficiency limitation above, the owner/operator shall perform stack testing on the emissions units according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8] II.B.2.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission units within 180 days after startup of each catalytic oxidizer. [R307-165-2] II.B.2.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission units within five (5) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.2.b.1 Testing and Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.2.b.2 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.2.b.3 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] II.B.2.b.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.2.b.5 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8] II.B.2.b.6 Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8] DAQE-AN149310002-24 Page 8 II.B.2.c Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K). B. Pressure - 29.92 in Hg (101.3 kPa). C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.2.c.1 VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.2.c.2 At all times, while operating the catalytic oxidizers, the owner/operator shall maintain the manufacturer's recommended minimum temperature of 600 °F at each catalyst bed while the oxidizer is operating. [R307-401-8] II.B.2.c.3 The owner/operator shall monitor the catalyst bed temperature with thermocouples permanently located at each catalyst bed. The thermocouples shall be located such that an inspector/operator can safely read the output at any time. [R307-401-8] II.B.2.c.4 The owner/operator shall monitor and record the catalyst bed temperature of each catalyst each operating day. Temperature shall be based on a 3-hour rolling average of data collected every ten (10) minutes. [R307-401-8] II.B.2.c.5 The owner/operator shall calibrate all temperature monitoring equipment according to the manufacturer's instructions at least once every six (6) months. [R307-401-8] II.B.3 VOC Requirements II.B.3.a The owner/operator shall not emit more than 28.90 tons per rolling 12-month period of VOCs from fermenting and baking operations on site. [R307-401-8] II.B.3.a.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: VOC emission factor (pounds per ton of baked bread) = 0.95Yi + 0.195Ti - 0.5S - O.86ts + 1.9, Where: Yi = initial baker's percent of yeast, Ti = total yeast action time in hours, S = final (spike) baker's percent of yeast, ts = spike time in hours. [R307-401-8] DAQE-AN149310002-24 Page 9 II.B.3.b The owner/operator shall maintain a monthly record of operations. The monthly records shall include: 1) The amount of raw material processed; 2) The percentage of yeast used; 3) The fermentation time; 4) The type of product baked; 5) The emission factor used for each product. [R307-401-8] II.B.4 Boiler Requirements II.B.4.a The owner/operator shall operate the boilers with nine (9) ppm burners. [R307-401-8] II.B.4.b The owner/operator shall use natural gas as fuel in the boilers. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN149310001-15 dated January 28, 2015 Is Derived From NOI dated January 13, 2021 Incorporates Additional information dated June 10, 2021 Incorporates Additional information dated August 1, 2021 Incorporates Additional information dated January 10, 2022 Incorporates Additional Information dated March 27, 2023 Incorporates Additional Information dated August 24, 2023 Incorporates Additional Information dated September 13, 2023 Incorporates Additional Information dated October 4, 2023 Incorporates Additional Information dated November 7, 2023 Incorporates Additional Information dated April 15, 2024 DAQE-AN149310002-24 Page 10 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds The Salt Lake Tribune Publication Name: The Salt Lake Tribune Publication URL: Publication City and State: Salt Lake City, UT Publication County: Salt Lake Notice Popular Keyword Category: Notice Keywords: flowers Notice Authentication Number: 202406101201479355960 1761527914 Notice URL: Back Notice Publish Date: Sunday, June 09, 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: Flowers Bakeries, LLC Location: Flowers Baking Company of Utah, LLC – 6208 Dannon Way, West Jordan, UT Project Description: Flowers Baking Company of Utah, LLC (Flowers) operates a facility that produces bagels, breads, rolls, hamburger buns, hotdog buns, and pitas. The process consists of mixing flour and other ingredients, such as oats and seeds, allowing the dough to rise, forming, and then baking. The raw material, flour, is stored in silos on the outside of the building. Other materials, such as oats, raisins, and seeds, are delivered in bags, totes, or other containers that are stored in the building. Flowers has requested a modification to AO DAQE AN149310001-15, dated January 28, 2015, to install two catalytic oxidizers and a muffin oven line, replace a natural gas-fired boiler, and update site-wide PTE. Facility-wide Potential to Emit was re-evaluated as part of this modification based on the updated equipment list and operation. 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 9, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at jries@utah.gov. 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 9, 2024 SLT0027961 Back DAQE-IN149310002-24 June 6, 2024 Margaret Marsh Flowers Baking Company of Utah, LLC 1919 Flowers Circle Thomasville, GA 31757 margaret.marsh@flocorp.com Dear Ms. Marsh: Re: Intent to Approve: Modification to Approval Order DAQE-AN149310001-15 to Update Equipment and Emissions Project Number: N149310002 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, Jake Ries, as well as the DAQE number as shown on the upper right-hand corner of this letter. Jake Ries, can be reached at (385) 306- 6530 or jries@utah.gov, if you have any questions. Sincerely, {{$s }} Jon L. Black, Manager New Source Review Section JLB:JR:jg cc: Salt Lake County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director * ) ' & — 0 ) C v A ? A C @ D w B F ˜ STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN149310002-24 Modification to Approval Order DAQE-AN149310001-15 to Update Equipment and Emissions Prepared By Jake Ries, Engineer (385) 306-6530 jries@utah.gov Issued to Flowers Baking Company of Utah, LLC Issued On June 6, 2024 {{$s }} New Source Review Section Manager Jon L. Black {{#s=Sig_es_:signer1:signature}} * ) ' & — 0 ) C v A ? A C @ D w B F ˜ TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 PUBLIC NOTICE STATEMENT............................................................................................... 5 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 10 ACRONYMS ............................................................................................................................... 11 DAQE-IN149310002-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Flowers Bakeries, LLC Flowers Baking Company of Utah, LLC Mailing Address Physical Address 1919 Flowers Circle 6208 Dannon Way Thomasville, GA 31757 West Jordan, UT 84081 Source Contact UTM Coordinates Name: Margaret Marsh 411,897 m Easting Phone: (229) 977-7752 4,493126 m Northing Email: margaret.marsh@flocorp.com Datum NAD83 UTM Zone 12 SIC code 2051 (Bread & Other Bakery Products, Except Cookies & Crackers) SOURCE INFORMATION General Description Flowers Baking Company of Utah, LLC (Flowers) operates a facility that produces bagels, breads, rolls, hamburger buns, hotdog buns, and pitas. The process consists of mixing flour and other ingredients, such as oats and seeds, allowing the dough to rise, forming, and then baking. The raw material, flour, is stored in silos on the outside of the building. Other materials, such as oats, raisins, and seeds, are delivered in bags, totes, or other containers that are stored in the building. NSR Classification Minor Modification at Minor Source Source Classification Located in Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA Salt Lake County Airs Source Size: SM Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines DAQE-IN149310002-24 Page 4 Project Description The DAQ received an ownership change request dated May 4, 2023. The ownership changed from Papa Pita Bakery to Flowers Baking Company of Utah, LLC. Flowers has requested a modification to AO DAQE-AN149310001-15, dated January 28, 2015, to install two (2) catalytic oxidizers and a muffin oven line, replace a natural gas-fired boiler, and update site-wide PTE. The following updates were made to the AO: 1) Addition of two (2) Catalytic Oxidizers, listed as II.A.3. 2) Addition of one (1) Muffin Line Oven, listed as II.A.8. 3) Addition of one (1) Tortilla Line Oven, listed as II.A.7. 4) Addition of one (1) Flour Silo, listed as II.A.9. 5) Addition of one (1) Bagel Line Boiler, listed as II.A.10. 6) Addition of one (1) natural gas-fired emergency generator, listed as II.A.11. 7) Addition of six (6) hot water heaters, listed as II.A.12. 7) Replacement of one (1) natural gas-fired boiler (previously listed as II.A.3) with two (2) new natural gas-fired boilers, listed as II.A.2. 8) Updated PTE to account for updated equipment, emission factors, and production. 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 3405 11021.00 Carbon Monoxide 5.76 11.07 Nitrogen Oxides 2.66 8.98 Particulate Matter - PM10 0.52 0.90 Particulate Matter - PM2.5 0.52 0.90 Sulfur Dioxide 0.02 0.06 Volatile Organic Compounds 9.88 28.90 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 180 Change (TPY) Total (TPY) Total HAPs -0.02 0.09 DAQE-IN149310002-24 Page 5 PUBLIC NOTICE STATEMENT The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Salt Lake Tribune and Deseret News on June 9, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received. SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 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.4 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.5 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.6 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] I.7 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] DAQE-IN149310002-24 Page 6 I.8 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] 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 Flowers Baking Company of Utah, LLC II.A.2 Two (2) Natural Gas-Fired Boilers (NEW) Rating: 6.7 MMBtu/hr each Fuel: Natural Gas Contains: 9 ppm Burners II.A.3 Two (2) Catalytic Oxidizers (NEW) Rating: 1.2 MMBtu/hr each Controls: Bagel Tunnel Oven Line and Thins Line Tunnel Oven II.A.4 Bagel Line Tunnel Oven Rating: 9.8 MMBtu/hr II.A.5 Bread and Bun Line Tunnel Oven Rating: 9.0 MMBtu/hr II.A.6 Thins Line Tunnel Oven Rating: 8.1 MMBtu/hr II.A.7 Tortilla Line Oven (NEW) Rating: 1.0 MMBtu/hr II.A.8 Muffin Line Oven (NEW) Rating: 2.84 MMBtu/hr II.A.9 Four (4) Flour Silos (ONE (1) NEW) Capacity: 130,000 lbs each Closed system Listed for informational purposes only. II.A.10 Bagel Line Boiler (NEW) Rating: 2.5 MMBtu/hr II.A.11 Emergency Power Generator Engine (NEW) Fuel: Natural Gas Rating: 105 hp NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ DAQE-IN149310002-24 Page 7 II.A.12 Six (6) Hot Water Heaters (NEW) Rating: 0.38 MMBtu/hr 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. 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 10% opacity from stationary sources. [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.1.b The owner/operator shall not exceed the following consumption limits: A. 166,911 decatherms of natural gas per rolling 12-month period for boilers and ovens. B. 21,444 decatherms of natural gas per rolling 12-month period for catalytic oxidizers. [R307-401-8] II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate new 12-month totals by the 20th day of each month using data from the previous 12 months for natural gas consumption. The owner/operator shall use billing statements or natural gas meter readings from the previous 12 months for natural gas. [R307-401-8] II.B.2 Catalytic Oxidizer Requirements II.B.2.a The owner/operator shall route all exhaust from the Bagel Line Tunnel Oven and Thins Line Tunnel Oven to a catalytic oxidizer at all times during operation. The catalytic oxidizer shall reduce VOC emissions by at least 95%. [R307-401-8] II.B.2.a.1 Compliance Demonstration To demonstrate compliance with the destruction efficiency limitation above, the owner/operator shall perform stack testing on the emissions units according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8] II.B.2.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission units within 180 days after the startup of each catalytic oxidizer. [R307-165-2] II.B.2.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission units within five (5) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] DAQE-IN149310002-24 Page 8 II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.2.b.1 Testing and Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.2.b.2 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.2.b.3 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] II.B.2.b.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.2.b.5 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8] II.B.2.b.6 Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8] II.B.2.c Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K). B. Pressure - 29.92 in Hg (101.3 kPa). C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.2.c.1 VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.2.c.2 At all times, while operating the catalytic oxidizers, the owner/operator shall maintain the manufacturer's recommended minimum temperature of 600°F at each catalyst bed while the oxidizer is operating. [R307-401-8] II.B.2.c.3 The owner/operator shall monitor the catalyst bed temperature with thermocouples permanently located at each catalyst bed. The thermocouples shall be located such that an inspector/operator can safely read the output at any time. [R307-401-8] DAQE-IN149310002-24 Page 9 II.B.2.c.4 The owner/operator shall monitor and record the catalyst bed temperature of each catalyst each operating day. Temperature shall be based on a 3-hour rolling average of data collected every ten (10) minutes. [R307-401-8] II.B.2.c.5 The owner/operator shall calibrate all temperature monitoring equipment according to the manufacturer's instructions at least once every six (6) months. [R307-401-8] II.B.3 VOC Requirements II.B.3.a The owner/operator shall not emit more than 28.90 tons per rolling 12-month period of VOCs from fermenting and baking operations on site. [R307-401-8] II.B.3.a.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: VOC emission factor (pounds per ton of baked bread) = 0.95Yi + 0.195Ti - 0.5S - O.86ts + 1.9, Where: Yi = initial baker's percent of yeast, Ti = total yeast action time in hours, S = final (spike) baker's percent of yeast, ts = spike time in hours. [R307-401-8] II.B.3.b The owner/operator shall maintain a monthly record of operations. The monthly records shall include: 1) The amount of raw material processed; 2) The percentage of yeast used; 3) The fermentation time; 4) The type of product baked; 5) The emission factor used for each product. [R307-401-8] II.B.4 Boiler Requirements II.B.4.a The owner/operator shall operate the boilers with nine (9) ppm burners. [R307-401-8] II.B.4.b The owner/operator shall use natural gas as fuel in the boilers. [R307-401-8] DAQE-IN149310002-24 Page 10 PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN149310001-15 dated January 28, 2015 Is Derived From NOI dated January 13, 2021 Incorporates Additional information dated June 10, 2021 Incorporates Additional information dated August 1, 2021 Incorporates Additional information dated January 10, 2022 Incorporates Additional Information dated March 27, 2023 Incorporates Additional Information dated August 24, 2023 Incorporates Additional Information dated September 13, 2023 Incorporates Additional Information dated October 4, 2023 Incorporates Additional Information dated November 7, 2023 Incorporates Additional Information dated April 15, 2024 DAQE-IN149310002-24 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-NN149310002-24 June 6, 2024 Salt Lake Tribune and Deseret News Legal Advertising Dept. P.O. Box 704055 West Valley City, UT 84170 Acct #9001399880 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and Deseret News on June 9, 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 (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Salt Lake County cc: Wasatch Front Regional Council 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director DAQE-NN149310002-24 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: Flowers Bakeries, LLC Location: Flowers Baking Company of Utah, LLC – 6208 Dannon Way, West Jordan, UT Project Description: Flowers Baking Company of Utah, LLC (Flowers) operates a facility that produces bagels, breads, rolls, hamburger buns, hotdog buns, and pitas. The process consists of mixing flour and other ingredients, such as oats and seeds, allowing the dough to rise, forming, and then baking. The raw material, flour, is stored in silos on the outside of the building. Other materials, such as oats, raisins, and seeds, are delivered in bags, totes, or other containers that are stored in the building. Flowers has requested a modification to AO DAQE- AN149310001-15, dated January 28, 2015, to install two catalytic oxidizers and a muffin oven line, replace a natural gas-fired boiler, and update site-wide PTE. Facility-wide Potential to Emit was re-evaluated as part of this modification based on the updated equipment list and operation. 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 9, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at jries@utah.gov. 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 9, 2024 {{#s=Sig_es_:signer1:signature}} DAQE- RN149310002 June 4, 2024 Margaret Marsh Flowers Bakeries, LLC 1919 Flowers Circle Thomasville, GA 31757 margaret.marsh@flocorp.com Dear Margaret Marsh, Re: Engineer Review: Modification to Approval Order DAQE-AN149310001-15 to Update Equipment and Emissions Project Number: N149310002 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. Flowers Bakeries, LLC should complete this review within 10 business days of receipt. Flowers Bakeries, LLC should contact Jake Ries at (385) 306-6530 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Jake Ries at jries@utah.gov 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 Flowers Bakeries, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Flowers Bakeries, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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 N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N149310002 Owner Name Flowers Bakeries, LLC Mailing Address 1919 Flowers Circle Thomasville, GA, 31757 Source Name Flowers Baking Co. of Utah, LLC Source Location 6208 Dannon Way West Jordan, UT 84081 UTM Projection 411,897 m Easting, 4,493126 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2051 (Bread & Other Bakery Products, Except Cookies & Crackers) Source Contact Margaret Marsh Phone Number (229) 977-7752 Email margaret.marsh@flocorp.com Billing Contact Margaret Marsh Phone Number 229-977-7752 Email margaret.marsh@flocorp.com Project Engineer Jake Ries, Engineer Phone Number (385) 306-6530 Email jries@utah.gov Notice of Intent (NOI) Submitted January 13, 2021 Date of Accepted Application April 15, 2024 Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 2 SOURCE DESCRIPTION General Description Flowers Baking Co. of Utah, LLC (Flowers) operates a facility that produces bagels, breads, rolls, hamburger and hotdogs buns and pitas. The process consists of mixing of flour and other ingredients, such as oats and seeds, allowing the dough to rise, forming and then baking. The raw material flour is stored in silos on the outside of the building. Other materials such as oats, raisins and seeds are delivered in bags, totes or other containers are stored in the building. NSR Classification: Minor Modification at Minor Source Source Classification Located in Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA, Salt Lake County Airs Source Size: SM Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal Modification to Approval Order DAQE-AN149310001-15 to Update Equipment and Emissions Project Description The DAQ received an ownership change request dated May 4, 2023. The ownership changed from Papa Pita Bakery to Flowers Baking Co. of Utah, LLC. Flowers has requested a modification to AO DAQE-AN149310001-15, dated January 28, 2015, to install two catalytic oxidizers and a muffin oven line, replace a natural gas-fired boiler, and update site-wide PTE. The following updates were made to the AO: 1) Addition of two Catalytic Oxidizers, listed as II.A.3 2) Addition of one Muffin Line Oven, listed as II.A.8 3) Addition of one Tortilla Line Oven, listed as II.A.7 4) Addition of one Flour Silo, listed as II.A.9 5) Addition of one Bagel Line Boiler, listed as II.A.10 6) Addition of one natural-gas fired emergency generator, listed as II.A.11 7) Addition of six hot water heaters, listed as II.A.12 7) Replacement of one natural gas-fired boiler (previously listed as II.A.3) with two new natural gas-fired boilers, listed as II.A.2 8) Updated PTE to account for updated equipment, emission factors, and production. EMISSION IMPACT ANALYSIS All criteria pollutants and HAPs emissions are below the modeling thresholds contained in R307-410-4 and R307-410-5. Therefore, no modeling is required at this time. [Last updated November 7, 2023] Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 3 Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 4 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 3405 11021.00 Carbon Monoxide 5.76 11.07 Nitrogen Oxides 2.66 8.98 Particulate Matter - PM10 0.52 0.90 Particulate Matter - PM2.5 0.52 0.90 Sulfur Dioxide 0.02 0.06 Volatile Organic Compounds 9.88 28.90 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 180 Change (TPY) Total (TPY) Total HAPs -0.02 0.09 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 5 Review of BACT for New/Modified Emission Units 1. BACT review regarding Ovens The source has proposed the addition of an oven rated at 2.84 MMBtu/hr to produce muffins. The Muffin Oven will bake varying bread formulas that emit VOC emissions. The operation of this oven is inconsistent due to the varying formulas and muffin production needs. The source has proposed the addition of catalytic oxidizers of other ovens, but due to the inconsistency of the Muffin Oven operation, a catalytic oxidizer has been determined to be technically infeasible. The DAQ has determined BACT to be to conduct manufacturer recommended maintenance and testing, and good work practices. [Last updated April 22, 2024] 2. BACT review regarding Natural-gas Fired Boilers The source has proposed the replacement of the existing natural gas-fired boiler with two new natural gas-fired boilers rated at 6.7 MMBtu/hr each. While during normal operation, only one new boiler will be used at a time, there may be scenarios where it may be necessary to run both. The new boilers are equipped with 9 ppm burners. The DAQ has determined BACT to be to conduct manufacturer recommended maintenance, and good work practices. [Last updated May 14, 2024] 3. BACT review regarding Emergency Generator Engine The source has proposed the installation of a natural gas-fired emergency generator engine. Emissions from the engine will be NOx and CO. As the engine is limited to 100 hours of non- emergency operation per year, no control operations were determined to be economically feasible. DAQ has determined BACT to be good combustion practices and conducting manufacturer recommended maintenance and testing. [Last updated May 14, 2024] SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 6 I.3 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.4 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.5 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307- 150] I.6 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] I.7 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.8 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] 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 Flowers Baking Co. of Utah, LLC II.A.2 NEW Two Natural Gas-Fired Boilers (NEW) Rating: 6.7 MMBtu/hr each Fuel: Natural Gas Contains: 9 ppm Burners Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 7 II.A.3 NEW Two Catalytic Oxidizers (NEW) Rating: 1.2 MMBtu/hr each Controls: Bagel Tunnel Oven Line and Thins Line Tunnel Oven II.A.4 Bagel Line Tunnel Oven Rating: 9.8 MMBtu/hr II.A.5 Bread and Bun Line Tunnel Oven Rating: 9.0 MMBtu/hr II.A.6 Thins Line Tunnel Oven Rating: 8.1 MMBtu/hr II.A.7 NEW Tortilla Line Oven (NEW) Rating: 1.0 MMBtu/hr II.A.8 NEW Muffin Line Oven (NEW) Rating: 2.84 MMBtu/hr II.A.9 Four Flour Silos (ONE NEW) Capacity: 130,000 lbs each Closed system Listed for informational purposes only. II.A.10 NEW Bagel Line Boiler (NEW) Rating: 2.5 MMBtu/hr II.A.11 NEW Emergency Power Generator Engine (NEW) Fuel: Natural Gas Rating: 105 hp NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.12 NEW Six Hot Water Heaters (NEW) Rating: 0.38 MMBtu/hr 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 NEW Site-wide Requirements Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 8 II.B.1.a NEW The owner/operator shall not allow visible emissions to exceed 10% opacity from stationary sources. [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.1.b NEW The owner/operator shall not exceed the following consumption limits: A. 166,911 decatherms of natural gas per rolling 12-month period for boilers and ovens. B. 21,444 decatherms of natural gas per rolling 12-month period for catalytic oxidizers. [R307-401-8] II.B.1.b.1 NEW To determine compliance with a rolling 12-month total, the owner/operator shall calculate new 12-month totals by the 20th day of each month using data from the previous 12 months for natural gas consumption. The owner/operator shall use billing statements or natural gas meter readings from the previous 12-months for natural gas. [R307-401-8] II.B.2 NEW Catalytic Oxidizer Requirements II.B.2.a NEW The owner/operator shall route all exhaust from the Bagel Line Tunnel Oven and Thins Line Tunnel Oven to a catalytic oxidizer at all times during operation. The catalytic oxidizer shall reduce VOC emissions by at least 95%. [R307-401-8] II.B.2.a.1 NEW Compliance Demonstration To demonstrate compliance with the destruction efficiency limitation above, the owner/operator shall perform stack testing on the emissions units according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8] II.B.2.a.2 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission units within 180 days after startup of each catalytic oxidizer. [R307-165-2] II.B.2.a.3 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the date of the most recent stack test of the emission units. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] II.B.2.b NEW The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.2.b.1 NEW Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 9 II.B.2.b.2 NEW Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.2.b.3 NEW Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] II.B.2.b.4 NEW Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.2.b.5 NEW Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8] II.B.2.b.6 NEW Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8] II.B.2.c NEW Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.2.c.1 NEW VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.2.c.2 NEW At all times while operating the catalytic oxidizers, the owner/operator shall maintain the manufacturer's recommended minimum temperature of 600℉ at each catalyst bed while the oxidizer is operating. [R307-401-8] II.B.2.c.3 NEW The owner/operator shall monitor the catalyst bed temperature with thermocouples permanently located at each catalyst bed. The thermocouples shall be located such that an inspector/operator can safely read the output at any time. [R307-401-8] Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 10 II.B.2.c.4 NEW The owner/operator shall monitor and record the catalyst bed temperature of each catalyst each operating day. Temperature shall be based on a 3-hour rolling average of data collected every ten minutes. [R307-401-8] II.B.2.c.5 NEW The owner/operator shall calibrate all temperature monitoring equipment according to the manufacturer's instructions at least once every 6 months. [R307-401-8] II.B.3 NEW VOC Requirements II.B.3.a NEW The owner/operator shall not emit more than 28.90 tons per rolling 12-month period of VOCs from fermenting and baking operations on site. [R307-401-8] II.B.3.a.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: VOC emission factor (pounds per ton of baked bread) = 0.95Yi + 0.195Ti - 0.5S - O.86ts + 1.9, Where: Yi = initial baker's percent of yeast, Ti = total yeast action time in hours, S = final (spike) baker's percent of yeast, ts = spike time in hours. [R307-401-8] II.B.3.b NEW The owner/operator shall maintain a monthly record of operations. The monthly records shall include: 1) The amount of raw material processed; 2) The percentage of yeast used; 3) The fermentation time; 4) The type of product baked; 5) The emission factor used for each product. [R307-401-8] II.B.4 NEW Boiler Requirements II.B.4.a NEW The owner/operator shall operate the boilers with 9 ppm burners. [R307-401-8] II.B.4.b NEW The owner/operator shall use natural gas as fuel in the boilers. [R307-401-8] Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 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-AN149310001-15 dated January 28, 2015 Is Derived From NOI dated January 13, 2021 Incorporates Additional information dated June 10, 2021 Incorporates Additional information dated August 1, 2021 Incorporates Additional information dated January 10, 2022 Incorporates Additional Information dated March 27, 2023 Incorporates Additional Information dated August 24, 2023 Incorporates Additional Information dated September 13, 2023 Incorporates Additional Information dated October 4, 2023 Incorporates Additional Information dated November 7, 2023 Incorporates Additional Information dated April 15, 2024 REVIEWER COMMENTS 1. Comment regarding Emission Calculations: The source corrected a previous emission calculations error for the fermenting and baking process. VOC emissions have now been calculated for fermenting and baking by using AP-42 Section 9.9.6 emission factors, actual bread baked per line, and a conservative PTE safety factor. The Bagel Line Oven and Thin Line Oven also utilize a 95% control efficiency from the proposed Catalytic Oxidizers. Emissions from natural gas consumption have been calculated using the boiler rating of 6.7 MMBtu/hr and AP-42 Tables 1.4-2, 1.4-3, and 1.4-4. [Last updated April 22, 2024] 2. Comment regarding Catalytic Oxidizers: The source has proposed the addition of two catalytic oxidizers. These oxidizers will control the VOC emissions from the Bagel and Thin Lines and will operate with a control efficiency of 95%. The addition of these oxidizers will reduce the VOC PTE from 97.24 to 28.90 tpy. [Last updated April 22, 2024] 3. Comment regarding Condition II.B.2.a: Condition II.B.2.a sets a VOC emissions limit of 28.90 tons per rolling 12-month period for fermenting and baking operations on site. Flowers will only be able to meet this limit once the proposed catalytic oxidizers are installed and have been operated for 12 months. Condition I.8 require the source to submit documentation of the status of construction of the oxidizers within 18 months. If the source has trouble with the procurement/installation of the oxidizers, they may request an extension for construction. [Last updated June 4, 2024] 4. Comment regarding NSPS and MACT Applicability: 40 CFR 60 (NSPS) Subpart Dc applies to owners and operators of steam generating units with ratings greater than 10 MMBtu/hr. Steam generating unit is defined as a device that combusts any fuel and produces steam or heats water or heats any heat transfer medium. Flowers has various boilers that are less than 10 Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 2024 Page 12 MMBtu/hr. Flowers is not subject to this subpart. 40 CFR 63 (MACT) Subpart JJJJJJ applies to owners and operators of an industrial, commercial, or institutional boiler that is located at, or is part of, an area source of HAPs. An industrial boiler is defined as any boiler used in manufacturing, processing, mining, and refining or an other industry to provide steam, hot water, and/or electricity. Gas-fired boilers are exempt from this subpart. Flowers is not subject to this subpart because the source has only gas-fired boilers. [Last updated April 22, 2024] 5. 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 requirements under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This operation is not a major source and is not a Title IV source. Flowers is subject to NSPS Subpart Dc but is not subject to any emission limit requirements, therefore, this facility is not subject to Title V requirements. [Last updated April 22, 2024] Engineer Review N149310002: Flowers Baking Co. of Utah, LLC June 4, 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 Memorandum 4246 South Riverboat Road Taylorsville, Utah 84123 385-474-8000 www.jacobs.com Subject Papa Pita Bakery NOI Best Available Control Analysis Attention Jake Ries/UDAQ From Allison Beck /Jacobs Date April 23, 2024 Copies to Moha Parikh/Jacobs, Margaret Ann Marsh/Flowers, Lara Freeman/Flowers 1. Background On April 23, 2024, the Utah Division of Air Quality (UDAQ) requested that a Best Available Control Technology (BACT) analysis be performed for PM, NOx , and VOC emissions associated with the natural gas-fired emergency generator located at Flowers Baking Co. of Utah’s Papa Pita Bakery. Utah has adopted the emissions control BACT process described in 40 Code of Federal Regulations 52.21(j) and incorporated by reference into Utah Administrative Code R307 -405-11. 2. Natural Gas-Fired Emergency Generator BACT Analysis The following details the BACT analysis for the 105 hp natural gas-fired emergency backup generator.  Step 1—Identify All Control Technologies . Technologies identified for control of PM, VOC and HAP in the RBLC are as follows: - Good combustion practices - Limited hours of operation - Regular preventative maintenance - Complia nce with Subpart JJJJ  Step 2—Eliminate Technically Infeasible Options. Not applicable, as all options are technically feasible  Step 3 and Step 4—Rank Remaining Control Technologies by Control Effectiveness and Evaluate the Most Effective Controls. Not applicable, as all control technologies are feasible.  Step 5—Select BACT. Flowers identifies use of good combustion practices, limited hours of operation, regular preventative maintenance, and compliance with New Source Performance Standards, Subpart JJJJ as BACT. The operation of the emergency generator will be limited to 100 hours per year for testing and maintenance. Utah Division of Air Quality Company____________________________ New Source Review Section Site/Source__________________________ Date____________________ Form 2 Process Information Process Data 1. Name of process: 2. End product of this process: 3. Primary process equipment: _______________ Manufacturer:__________________________________ Make or model: _________________________ Identification #: ________________________________ Capacity of equipment (lbs/hr): Year installed:__________________________________ Rated _____________ Max.____________ (Add additional sheets as needed) 4. Method of exhaust ventilation: □ Stack □ Window fan □ Roof vent □ Other, describe _______________________ Are there multiple exhausts: □ Yes □ No Operating Data 5. Maximum operating schedule: __________ hrs/day __________days/week __________weeks/year 6. Percent annual production by quarter: Winter ________ Spring _______ Summer ________ Fall ________ 7. Hourly production rates (lbs.): Average ________ Maximum ________ 8. Maximum annual production (indicate units): __________________ Projected percent annual increase in production: __________________ 9. Type of operation: □ Continuous □ Batch □ Intermittent 10. If batch, indicate minutes per cycle ________ Minutes between cycles ________ 11. Materials used in process Raw Materials Principal Use Amounts (Specify Units) Page 1 of 3 Page 2 of 3 Process Form 2 (Continued) 12. Control equipment (attach additional pages if necessary) Item Primary Collector Secondary Collector a. Type b. Manufacturer c. Model d. Year installed e. Serial or ID# f. Pollutant controlled g. Controlled pollutant emission rate (if known) h. Pressure drop across control device i. Design efficiency j. Operating efficiency Stack Data (attach additional pages if necessary) 13. Stack identification: 14. Height: Above roof ________ft Above ground ________ft 15. Are other sources vented to this stack: □ Yes □ No If yes, identify sources: 16. □ Round, top inside diameter dimension _________ □ Rectangular, top inside dimensions length ________ x width ________ 17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min 18. Continuous monitoring equipment: □ yes □ no If yes, indicate: Type ____________________ Manufacturer _________________________________ Make or Model ____________ Pollutant(s) monitored __________________________ Emissions Calculations (PTE) 19. Calculated emissions for this device PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr CO2 ___________ Tons/yr CH4 _____________ Tons/yr N2O ____________Tons/yr HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate) Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix. Page 3 of 3 Instructions Note: 1. Submit this form in conjunction with Form 1. 2. Call the Division of Air Quality (DAQ) at (801) 536-4000 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! This is a general form regarding processes and should be completed by all sources. Please answer all questions. If the item does not apply to the source operations write “n/a”. If the answer is not known write "unknown". 1. Indicate the generally accepted name for the process (i.e., asphalt batching, glass manufacturing, oil refining, etc.). 2. Specify the end product of this process (i.e., asphaltic concrete, benzene, soaps, etc.). 3. Indicate the specific process equipment for this form along with the manufacturer, model number, identifying name or code year it was or will be installed, and rated (normal) and maximum capacity of equipment. 4. Indicate the method of exhaust ventilation and indicate if there are more than one exhausts. 5. Complete the process equipment's normal operating schedule in hours per day, days per week, and weeks per year. 6. Complete the percent annual production by season for a year’s production of finished units. The four seasons should total to 100%. 7. Specify the average and maximum hourly production rates in pounds. The average is the year's production rate divided by the total yearly hours of production or operation. 8. Specify the annual production for this process equipment and indicate the appropriate units. Estimate the annual increase in production. 9. Check whether the process is continuous, intermittent, or batch. A batch operation normally has significant down time between completion and startup of each operation or cycle. 10. If batch, complete the minutes per production cycle and minutes between the production cycles. A "cycle" refers to the time the equipment is in operation. 11. List all general types of raw materials employed in the process, indicate the principle use (i.e., product, binder, catalyst, fuel, etc.) and specify the normal amount used in pounds per hours, tons per year, etc. 12. If your control device is not listed below complete items a through j. If your process includes any of the control devices listed below, please indicate which ones and submit the associated forms with your application. The primary collector and secondary collector refer to separate control devices or equipment for collecting similar or different air pollutants. If there is a third collector, complete the same data for that collector on a separate sheet. Addition information may be attached. Complete the proper form listed below for any air pollution control device: ___ Form 3 Afterburners ___ Form 4 Flares ___ Form 5 Adsorption Unit ___ Form 6 Cyclone ___ Form 7 Condenser ___ Form 8 Electrostatic Precipitators ___ Form 9 Scrubber ___ Form 10 Fabric Filter (Baghouse) 13. Indicate the company's identification for the stack or exhaust. 14. Specify the stack's or exhaust's height, in feet (ft.) above ground and above the attached roof. 15. Indicate if other sources are also vented to this same stack or exhaust and identify those sources. 16. Specify the inside dimensions of the stack or exhaust at the outlet to the atmosphere. 17. Complete the specifications of the stack's or exhaust's exit gas. (Temperature in degrees Fahrenheit, volume flow rate in actual cubic feet per minute, and velocity in feet per minute.) If the properties of the exit gas vary, use the average values. 18. Indicate if the stack or exhaust is equipped with air pollution monitoring equipment. If so, specify the type, manufacturer, make or model, and the pollutant or pollutants monitored. 19. Supply calculations for all criteria pollutants and HAPs. Use manufacturers’ data or AP-42 to complete your calculations. f:\aq\engineer\generic\Forms 2010\Form02 Process Information.doc Revised 12/20/10 Utah Division of Air Quality Company____________________________ New Source Review Section Site/Source__________________________ Date____________________ Form 2 Process Information Process Data 1. Name of process: 2. End product of this process: 3. Primary process equipment: _______________ Manufacturer:__________________________________ Make or model: _________________________ Identification #: ________________________________ Capacity of equipment (lbs/hr): Year installed:__________________________________ Rated _____________ Max.____________ (Add additional sheets as needed) 4. Method of exhaust ventilation: □ Stack □ Window fan □ Roof vent □ Other, describe _______________________ Are there multiple exhausts: □ Yes □ No Operating Data 5. Maximum operating schedule: __________ hrs/day __________days/week __________weeks/year 6. Percent annual production by quarter: Winter ________ Spring _______ Summer ________ Fall ________ 7. Hourly production rates (lbs.): Average ________ Maximum ________ 8. Maximum annual production (indicate units): __________________ Projected percent annual increase in production: __________________ 9. Type of operation: □ Continuous □ Batch □ Intermittent 10. If batch, indicate minutes per cycle ________ Minutes between cycles ________ 11. Materials used in process Raw Materials Principal Use Amounts (Specify Units) Page 1 of 3 Page 2 of 3 Process Form 2 (Continued) 12. Control equipment (attach additional pages if necessary) Item Primary Collector Secondary Collector a. Type b. Manufacturer c. Model d. Year installed e. Serial or ID# f. Pollutant controlled g. Controlled pollutant emission rate (if known) h. Pressure drop across control device i. Design efficiency j. Operating efficiency Stack Data (attach additional pages if necessary) 13. Stack identification: 14. Height: Above roof ________ft Above ground ________ft 15. Are other sources vented to this stack: □ Yes □ No If yes, identify sources: 16. □ Round, top inside diameter dimension _________ □ Rectangular, top inside dimensions length ________ x width ________ 17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min 18. Continuous monitoring equipment: □ yes □ no If yes, indicate: Type ____________________ Manufacturer _________________________________ Make or Model ____________ Pollutant(s) monitored __________________________ Emissions Calculations (PTE) 19. Calculated emissions for this device PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr CO2 ___________ Tons/yr CH4 _____________ Tons/yr N2O ____________Tons/yr HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate) Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix. Page 3 of 3 Instructions Note: 1. Submit this form in conjunction with Form 1. 2. Call the Division of Air Quality (DAQ) at (801) 536-4000 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! This is a general form regarding processes and should be completed by all sources. Please answer all questions. If the item does not apply to the source operations write “n/a”. If the answer is not known write "unknown". 1. Indicate the generally accepted name for the process (i.e., asphalt batching, glass manufacturing, oil refining, etc.). 2. Specify the end product of this process (i.e., asphaltic concrete, benzene, soaps, etc.). 3. Indicate the specific process equipment for this form along with the manufacturer, model number, identifying name or code year it was or will be installed, and rated (normal) and maximum capacity of equipment. 4. Indicate the method of exhaust ventilation and indicate if there are more than one exhausts. 5. Complete the process equipment's normal operating schedule in hours per day, days per week, and weeks per year. 6. Complete the percent annual production by season for a year’s production of finished units. The four seasons should total to 100%. 7. Specify the average and maximum hourly production rates in pounds. The average is the year's production rate divided by the total yearly hours of production or operation. 8. Specify the annual production for this process equipment and indicate the appropriate units. Estimate the annual increase in production. 9. Check whether the process is continuous, intermittent, or batch. A batch operation normally has significant down time between completion and startup of each operation or cycle. 10. If batch, complete the minutes per production cycle and minutes between the production cycles. A "cycle" refers to the time the equipment is in operation. 11. List all general types of raw materials employed in the process, indicate the principle use (i.e., product, binder, catalyst, fuel, etc.) and specify the normal amount used in pounds per hours, tons per year, etc. 12. If your control device is not listed below complete items a through j. If your process includes any of the control devices listed below, please indicate which ones and submit the associated forms with your application. The primary collector and secondary collector refer to separate control devices or equipment for collecting similar or different air pollutants. If there is a third collector, complete the same data for that collector on a separate sheet. Addition information may be attached. Complete the proper form listed below for any air pollution control device: ___ Form 3 Afterburners ___ Form 4 Flares ___ Form 5 Adsorption Unit ___ Form 6 Cyclone ___ Form 7 Condenser ___ Form 8 Electrostatic Precipitators ___ Form 9 Scrubber ___ Form 10 Fabric Filter (Baghouse) 13. Indicate the company's identification for the stack or exhaust. 14. Specify the stack's or exhaust's height, in feet (ft.) above ground and above the attached roof. 15. Indicate if other sources are also vented to this same stack or exhaust and identify those sources. 16. Specify the inside dimensions of the stack or exhaust at the outlet to the atmosphere. 17. Complete the specifications of the stack's or exhaust's exit gas. (Temperature in degrees Fahrenheit, volume flow rate in actual cubic feet per minute, and velocity in feet per minute.) If the properties of the exit gas vary, use the average values. 18. Indicate if the stack or exhaust is equipped with air pollution monitoring equipment. If so, specify the type, manufacturer, make or model, and the pollutant or pollutants monitored. 19. Supply calculations for all criteria pollutants and HAPs. Use manufacturers’ data or AP-42 to complete your calculations. f:\aq\engineer\generic\Forms 2010\Form02 Process Information.doc Revised 12/20/10 Utah Division of Air Quality Company____________________________ New Source Review Section Site/Source__________________________ Date____________________ Form 2 Process Information Process Data 1. Name of process: 2. End product of this process: 3. Primary process equipment: _______________ Manufacturer:__________________________________ Make or model: _________________________ Identification #: ________________________________ Capacity of equipment (lbs/hr): Year installed:__________________________________ Rated _____________ Max.____________ (Add additional sheets as needed) 4. Method of exhaust ventilation: □ Stack □ Window fan □ Roof vent □ Other, describe _______________________ Are there multiple exhausts: □ Yes □ No Operating Data 5. Maximum operating schedule: __________ hrs/day __________days/week __________weeks/year 6. Percent annual production by quarter: Winter ________ Spring _______ Summer ________ Fall ________ 7. Hourly production rates (lbs.): Average ________ Maximum ________ 8. Maximum annual production (indicate units): __________________ Projected percent annual increase in production: __________________ 9. Type of operation: □ Continuous □ Batch □ Intermittent 10. If batch, indicate minutes per cycle ________ Minutes between cycles ________ 11. Materials used in process Raw Materials Principal Use Amounts (Specify Units) Page 1 of 3 Page 2 of 3 Process Form 2 (Continued) 12. Control equipment (attach additional pages if necessary) Item Primary Collector Secondary Collector a. Type b. Manufacturer c. Model d. Year installed e. Serial or ID# f. Pollutant controlled g. Controlled pollutant emission rate (if known) h. Pressure drop across control device i. Design efficiency j. Operating efficiency Stack Data (attach additional pages if necessary) 13. Stack identification: 14. Height: Above roof ________ft Above ground ________ft 15. Are other sources vented to this stack: □ Yes □ No If yes, identify sources: 16. □ Round, top inside diameter dimension _________ □ Rectangular, top inside dimensions length ________ x width ________ 17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min 18. Continuous monitoring equipment: □ yes □ no If yes, indicate: Type ____________________ Manufacturer _________________________________ Make or Model ____________ Pollutant(s) monitored __________________________ Emissions Calculations (PTE) 19. Calculated emissions for this device PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr CO2 ___________ Tons/yr CH4 _____________ Tons/yr N2O ____________Tons/yr HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate) Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix. Page 3 of 3 Instructions Note: 1. Submit this form in conjunction with Form 1. 2. Call the Division of Air Quality (DAQ) at (801) 536-4000 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! This is a general form regarding processes and should be completed by all sources. Please answer all questions. If the item does not apply to the source operations write “n/a”. If the answer is not known write "unknown". 1. Indicate the generally accepted name for the process (i.e., asphalt batching, glass manufacturing, oil refining, etc.). 2. Specify the end product of this process (i.e., asphaltic concrete, benzene, soaps, etc.). 3. Indicate the specific process equipment for this form along with the manufacturer, model number, identifying name or code year it was or will be installed, and rated (normal) and maximum capacity of equipment. 4. Indicate the method of exhaust ventilation and indicate if there are more than one exhausts. 5. Complete the process equipment's normal operating schedule in hours per day, days per week, and weeks per year. 6. Complete the percent annual production by season for a year’s production of finished units. The four seasons should total to 100%. 7. Specify the average and maximum hourly production rates in pounds. The average is the year's production rate divided by the total yearly hours of production or operation. 8. Specify the annual production for this process equipment and indicate the appropriate units. Estimate the annual increase in production. 9. Check whether the process is continuous, intermittent, or batch. A batch operation normally has significant down time between completion and startup of each operation or cycle. 10. If batch, complete the minutes per production cycle and minutes between the production cycles. A "cycle" refers to the time the equipment is in operation. 11. List all general types of raw materials employed in the process, indicate the principle use (i.e., product, binder, catalyst, fuel, etc.) and specify the normal amount used in pounds per hours, tons per year, etc. 12. If your control device is not listed below complete items a through j. If your process includes any of the control devices listed below, please indicate which ones and submit the associated forms with your application. The primary collector and secondary collector refer to separate control devices or equipment for collecting similar or different air pollutants. If there is a third collector, complete the same data for that collector on a separate sheet. Addition information may be attached. Complete the proper form listed below for any air pollution control device: ___ Form 3 Afterburners ___ Form 4 Flares ___ Form 5 Adsorption Unit ___ Form 6 Cyclone ___ Form 7 Condenser ___ Form 8 Electrostatic Precipitators ___ Form 9 Scrubber ___ Form 10 Fabric Filter (Baghouse) 13. Indicate the company's identification for the stack or exhaust. 14. Specify the stack's or exhaust's height, in feet (ft.) above ground and above the attached roof. 15. Indicate if other sources are also vented to this same stack or exhaust and identify those sources. 16. Specify the inside dimensions of the stack or exhaust at the outlet to the atmosphere. 17. Complete the specifications of the stack's or exhaust's exit gas. (Temperature in degrees Fahrenheit, volume flow rate in actual cubic feet per minute, and velocity in feet per minute.) If the properties of the exit gas vary, use the average values. 18. Indicate if the stack or exhaust is equipped with air pollution monitoring equipment. If so, specify the type, manufacturer, make or model, and the pollutant or pollutants monitored. 19. Supply calculations for all criteria pollutants and HAPs. Use manufacturers’ data or AP-42 to complete your calculations. f:\aq\engineer\generic\Forms 2010\Form02 Process Information.doc Revised 12/20/10 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r2726107…1/13 Jacob Ries <jries@utah.gov> Papa Pita NOI Submittal Review Jacob Ries <jries@utah.gov>Thu, Sep 9, 2021 at 8:13 AM To: Will Durrant <Will.Durrant@papapita.net> Hi Will, Thank you for the quick meeting a little while ago! As we discussed, I have attached a BACT Analysis Guidance and an example document to help you with completing a BACT analysis. Could you also send over the emission calculations for the muffin line? Feel free to reach out if you have any questions or would like help with anything. Thank you, On Thu, Sep 9, 2021 at 7:54 AM Will Durrant <Will.Durrant@papapita.net> wrote: Jacob, Can we plan on a phone call? You can call me at my desk 801-523-4410 or if you have a call in number if you will let me know and I can call in…. Thank you, Will Durrant Plant Manager Papa Pita Bakery 6208 West Dannon Way West Jordan, UT 84081 (801) 523-4410 Direct Line (801) 971-6865 Cell (801) 280-7373 Fax will.durrant@papapita.net 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r2726107…2/13 The information contained in this message and any attachment may be proprietary, confidential, and privileged or subject to the work product doctrine and thus protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Papa Pita Bakery immediately by replying to this message or calling (801) 523-4400 and deleting it and all copies and backups thereof. Thank you From: Jacob Ries <jries@utah.gov> Sent: Thursday, September 09, 2021 7:41 AM To: Will Durrant <Will.Durrant@papapita.net> Subject: Re: Papa Pita NOI Submittal Review CAUTION:!! This is an external email. STOP and THINK before you click !! Good morning Will, I should've asked sooner, would you like to do a phone call or a video call? If you'd like to do a video call, what platform works best for you? Thank you! On Tue, Sep 7, 2021 at 9:30 AM Will Durrant <Will.Durrant@papapita.net> wrote: Yes. I will plan on 8am on Thursday…. Thank you, Will Durrant Plant Manager Papa Pita Bakery 6208 West Dannon Way West Jordan, UT 84081 (801) 523-4410 Direct Line (801) 971-6865 Cell (801) 280-7373 Fax will.durrant@papapita.net 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r2726107…3/13 The information contained in this message and any attachment may be proprietary, confidential, and privileged or subject to the work product doctrine and thus protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Papa Pita Bakery immediately by replying to this message or calling (801) 523-4400 and deleting it and all copies and backups thereof. Thank you From: Jacob Ries <jries@utah.gov> Sent: Tuesday, September 07, 2021 9:27 AM To: Will Durrant <Will.Durrant@papapita.net> Subject: Re: Papa Pita NOI Submittal Review CAUTION:!! This is an external email. STOP and THINK before you click !! Hi Will, Hope you had a good weekend! Can we do Thursday at 8 am? Thank you! On Mon, Sep 6, 2021 at 12:00 PM Will Durrant <Will.Durrant@papapita.net> wrote: Jacob, Can when do this on Wednesday or Thursday this week? Morning are usually best for me before 9:30 am but if that time doesn't work let me know…. Thank you, Will Durrant Plant Manager Papa Pita Bakery 6208 West Dannon Way West Jordan, UT 84081 (801) 523-4410 Direct Line (801) 971-6865 Cell (801) 280-7373 Fax will.durrant@papapita.net 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r2726107…4/13 The information contained in this message and any attachment may be proprietary, confidential, and privileged or subject to the work product doctrine and thus protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Papa Pita Bakery immediately by replying to this message or calling (801) 523-4400 and deleting it and all copies and backups thereof. Thank you From: Jacob Ries <jries@utah.gov> Sent: Tuesday, August 31, 2021 9:07 AM To: Will Durrant <Will.Durrant@papapita.net> Subject: Re: Papa Pita NOI Submittal Review CAUTION:!! This is an external email. STOP and THINK before you click !! Hi Will, Would you like to set up a meeting this week to talk about the additional information? Thank you! On Tue, Aug 3, 2021 at 9:00 AM Jacob Ries <jries@utah.gov> wrote: Good morning Will, Thanks for getting this information to me! I am available for a meeting any time this week after 10 a.m. each day. I am not working Friday however! Please let me know what works best for you. Thank you! On Sun, Aug 1, 2021 at 5:54 PM Will Durrant <Will.Durrant@papapita.net> wrote: Jacob, If you have sometime this week to review these forms with me I would appreciate it…. 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r2726107…5/13 I modified the Muffin line paper work I submitted previously and have included the Boiler spreadsheet you pointed me 2 for calculation purposes but I wanted to make sure I fill out the correct form for the boilers….. Thank you, Will Durrant Plant Manager Papa Pita Bakery 6208 West Dannon Way West Jordan, UT 84081 (801) 523-4410 Direct Line (801) 971-6865 Cell (801) 280-7373 Fax will.durrant@papapita.net The information contained in this message and any attachment may be proprietary, confidential, and privileged or subject to the work product doctrine and thus protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Papa Pita Bakery immediately by replying to this message or calling (801) 523-4400 and deleting it and all copies and backups thereof. Thank you From: Jacob Ries <jries@utah.gov> Sent: Tuesday, July 27, 2021 8:20 AM To: Will Durrant <Will.Durrant@papapita.net> Subject: Re: Papa Pita NOI Submittal Review CAUTION:!! This is an external email. STOP and THINK before you click !! Good morning Will, Hope you are doing well! How is the additional information coming along? Is there anything I can help with? 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r2726107…6/13 Thank you! On Thu, Jun 17, 2021 at 1:43 PM Jacob Ries <jries@utah.gov> wrote: Hi Will, Thank you for the meeting today! As we discussed, I have attached the boiler emission spreadsheet and a couple of BACT Analysis guidance/examples to help you with the rest of the requested information. Please let me know if you have any questions or would like any assistance with this. I look forward to hearing from you! Emission Calculation Spreadsheets: https://deq.utah.gov/air-quality/emissions-calculations- spreadsheets Thank you! On Tue, Jun 15, 2021 at 9:31 AM Jacob Ries <jries@utah.gov> wrote: Hi Will, Thanks for reaching out! I'm available for a discussion at 1 pm on Thursday. See you then! Thank you! On Tue, Jun 15, 2021 at 10:17 AM Will Durrant <Will.Durrant@papapita.net> wrote: Hi Jacob, I am not sure if you saw this email. I wanted to know if you have any time tomorrow or Thursday we could have a call to answer a few questions? Thank you, Will Durrant Plant Manager Papa Pita Bakery 6208 West Dannon Way West Jordan, UT 84081 (801) 523-4410 Direct Line (801) 971-6865 Cell (801) 280-7373 Fax will.durrant@papapita.net 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r2726107…7/13 The information contained in this message and any attachment may be proprietary, confidential, and privileged or subject to the work product doctrine and thus protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Papa Pita Bakery immediately by replying to this message or calling (801) 523-4400 and deleting it and all copies and backups thereof. Thank you From: Will Durrant Sent: Thursday, June 10, 2021 3:39 PM To: 'Jacob Ries' <jries@utah.gov> Subject: RE: Papa Pita NOI Submittal Review Hi Jacob, Thanks for forwarding this email to me….. I have attached some of the forms but have questions to make sure I completing them correctly….. Form # 3 I filled this out but it saying this for New permit only? Form # 4 Section 7 asking for New or Modified materials used? We are using the same basic ingredients as for the other products we produce Flour, Water, Sugar, Yeast Etc.… Is this what this form is looking for? If so estimated annual usage of each of these ingredients? Section 8 is asking for new or modified process emitting units? I am assuming this is referring to the oven this product is baked in? Form #5 I wanted to discuss with and our Plant Maintenance Engineer…. I am out of the office on Friday but wanted to see if I can set up a call for next week to go over these….The best day for our Plant Maintenance Engineer would be a Wednesday or Thursday if you have sometime either of those days? Thank you, Will Durrant 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r2726107…8/13 Plant Manager Papa Pita Bakery 6208 West Dannon Way West Jordan, UT 84081 (801) 523-4410 Direct Line (801) 971-6865 Cell (801) 280-7373 Fax will.durrant@papapita.net The information contained in this message and any attachment may be proprietary, confidential, and privileged or subject to the work product doctrine and thus protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Papa Pita Bakery immediately by replying to this message or calling (801) 523-4400 and deleting it and all copies and backups thereof. Thank you From: Jacob Ries <jries@utah.gov> Sent: Tuesday, June 08, 2021 5:48 AM To: Will Durrant <Will.Durrant@papapita.net> Subject: Fwd: Papa Pita NOI Submittal Review CAUTION:!! This is an external email. STOP and THINK before you click !! Good morning Will, Thank you for getting back to me yesterday! As we discussed, here is the information I requested back when the NOI was submitted. Please let me know if you have any questions or would like any assistance with the forms. Thank you, Jake Ries ---------- Forwarded message --------- From: Jacob Ries <jries@utah.gov> Date: Wed, Jan 13, 2021 at 12:35 PM 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r2726107…9/13 Subject: Papa Pita NOI Submittal Review To: <will.durrant@papapita.net> Hi Will, My name is Jake Ries and I am an environmental engineer with Utah Division of Air Quality (DAQ). I have been tasked with reviewing the Papa Pita Bakery NOI submitted on 1/06/21. The review process, the steps and anticipated timelines for the permitting process are: · Review of Minimal Application Requirement and Additional Information Request – 30 days from NOI received · Technical Review and Drafting Engineering Review (ER) - 30 days from date of complete NOI · Internal reviews (peer, modeling, compliance) - 14 days from completed draft ER · Source Review - 10 days for source to review ER and draft permit conditions · Start of Public Comment Period - 7 days from source approval of ER · Public Comment Period - 30 days (potential extension up to 30 days if requested) · Final AO - 14 days from end of public comment period The timelines above are estimates, and listed for your reference only. Actual timelines may change depending on staff work load, project complexity, public comments received, etc. At the moment, I have a few projects ahead of this one, but I will do my best to match the timeline above! I have noticed that there is information missing for this to be a complete NOI. The forms below will help you gather the information this is necessary for the permitting process. Form 1 - NOI Checklist Form 2 - Company Information Form 3 - Process Information Form 4 - Project Information Form 5 - Emissions Information Filling out these forms will help me better review this project and understand what is going on. Please let me know if you need any help with these forms or if you have any questions! Thank you! -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r272610…10/13 airquality.utah.gov -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 airquality.utah.gov -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 airquality.utah.gov -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r272610…11/13 airquality.utah.gov -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 airquality.utah.gov -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 airquality.utah.gov -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r272610…12/13 airquality.utah.gov -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 airquality.utah.gov -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 airquality.utah.gov -- Jake Ries Environmental Engineer | Minor NSR Section P: (385) 306-6530 airquality.utah.gov 2 attachments 11/7/23, 10:50 AM State of Utah Mail - Papa Pita NOI Submittal Review https://mail.google.com/mail/u/0/?ik=c29116e69f&view=pt&search=all&permmsgid=msg-a:r2726107396033981849&dsqt=1&simpl=msg-a:r272610…13/13 BACT Analysis Guide.pdf 51K BACT for Small Sources.docx 400K