DAQ-2024-011074

DAQE-AN100560012-24

{{$d1 }}

Ben Nelson
TTM Technologies, Inc.
710 North 600 West
Logan, UT 84321
[e-mail]

Dear Mr. Nelson:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN100560011-19 to
Replace a Baghouse with a Vacuum System under R307-401-12: Reduction in Air Pollutants
Project Number: N100560012

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on February
22, 2024. TTM Technologies, Inc. must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

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

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:KA:jg

cc: Bear River Health Department

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

September 12, 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-AN100560012-24
Administrative Amendment to Approval Order
DAQE-AN100560011-19 to Replace a Baghouse with a Vacuum
System under R307-401-12: Reduction in Air Pollutants

Prepared By
Katie Andersen, Engineer
[phone]
[e-mail]

Issued to
TTM Technologies, Inc. - Logan Circuit Board Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

September 12, 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 ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-AN100560012-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
TTM Technologies, Inc. TTM Technologies, Inc. - Logan Circuit Board Plant

Mailing Address Physical Address
710 North 600 West 710 North 600 West
Logan, UT 84321 Logan, UT 84321

Source Contact UTM Coordinates
Name: Ben Nelson 429,401 m Easting
Phone: [phone],621,849 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3672 (Printed Circuit Boards)

SOURCE INFORMATION
General Description
TTM Technologies, Inc. (TTM) is the owner/operator of the Logan Circuit Board Plant in Logan, Cache
County. The process starts with a blank circuit board. Circuit board designs are printed or developed onto
films. These films are used to create a map for physical etching and chemical stripping into the board to
create the necessary pathways and attachments. Process baths are used to accomplish the chemical
component of this process. Masks are rolled on by a machine to protect the board and then sealed through
electric oven heating. The Drilling and Routing line is used to sketch additional design pathways onto the
board. The board is then dipped into metal tanks to create electrical pathways. Individual plates are
compiled into one core and then treated through a similar process in the South Building. The completed
circuit panels are packaged and shipped off-site.

NSR Classification
Administrative Amendment

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

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-AN100560012-24
Page 4

MACT (Part 63), WWWWWW: National Emission Standards for Hazardous Air Pollutants:
Area Source Standards for Plating and Polishing Operations

Project Description
TTM requested a modification to AO DAQE-AN100560011-19 for the replacement of the control
baghouse on Equipment ID II.A.25 with two (2) Spencer Vacuum Cleaning Systems. This replacement
results in a net decrease in air pollutant emissions. This project is an administrative amendment for a
reduction in air pollutants (UAC Rule R307-401-12).

SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 4520.00
Carbon Monoxide 0 3.22
Nitrogen Oxides 0 3.73
Particulate Matter - PM10 -2.30 7.92
Particulate Matter - PM2.5 -2.30 7.92
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 0 27.24

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethylene Glycol (CAS #107211) 0 40
Formaldehyde (CAS #50000) 0 196
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 2152
Change (TPY) Total (TPY)
Total HAPs 0 1.19

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the Utah Administrative Code (UAC) Rule 307 (R307) and Title 40 of the Code of Federal Regulations (40 CFR). Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
DAQE-AN100560012-24
Page 5

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

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

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Circuit Board Manufacturing
II.A.2 North Building Circuit Plate Development Processes and Equipment II.A.3 Film Development Rooms Panel film development and silkscreen and film printing
II.A.4 Inner Panel Print Room II.A.5 Three (3) Etch and Strip Lines Panels are chemically etched and cleaned in process tanks Control: Enclosed and North Scrubber
II.A.6 Electroless Dip Tanks Maximum Total Surface Area: 53.40 square feet Control: North Building Scrubber MACT Applicability: Subpart WWWWWW II.A.7 Copper Plating Bath Control: North Building Scrubber
DAQE-AN100560012-24
Page 6

II.A.8 Galvabau Tanks Maximum Total Surface Area: 1,068 square feet Control: North Building Scrubber II.A.9 PAL Nickel Gold Plating
Maximum Total Surface Area: 25.67 square feet Control: North Building Scrubber
II.A.10 Oxide (Circubond) Tanks Maximum Total Surface Area: 15 square feet Control: North Building Scrubber
II.A.11 Mask Development Room Machines apply solder-mask and mask is baked on through electric ovens
II.A.12 Soldering Operations Tin and Lead Solder Bars
II.A.13 Drill and Route
Panel etching and drilling Control: Two (2) Baghouses

II.A.14 Hot Oil and Compression Control: Two (2) cooling towers and 0.005% Drift Eliminators
II.A.15 Waste Treatment Plant
Control: North Building Wet Scrubber
II.A.16 Eight (8) Tetraflouromethane Cylinders Capacity: 70 lbs Each II.A.17 Chemical Warehouse
Miscellaneous storage tanks

II.A.18 One (1) Emergency Generator Rating: 60 kW Manufacturer Date: 1987 Fuel: Natural Gas MACT Applicability: Subpart ZZZZ
II.A.19 South Building Surface Finishing Processes

II.A.20 Film Development and Print Room Outer Panel film development and silkscreen and film printing
II.A.21 Electrolysis Plating Tanks
Control: South Building Wet Scrubber

Hot Air Solder Level (HASL) Tanks
Maximum Total Surface Area: 22.5 square feet

ENIG Tanks
Maximum Total Surface Area: 46.04 square feet

Silver Tanks
Maximum Total Surface Area: 15.33 square feet

DAQE-AN100560012-24
Page 7

II.A.22 Strip and Etch Line Control: South Building Wet Scrubber II.A.23 Organic Finish Line (ENTEK) Maximum Total Surface Area: 22.5 square feet
Control: Blower and South Building Wet Scrubber
II.A.24 Hand Plating/Magnastrip Tanks Maximum Total Surface Area: 128.13 square feet Control: North Building Scrubber II.A.25 Routing
Finishing Line drilling Control: Two (2) Spencer Vacuum Cleaning Systems (NEW)
II.A.26 Waste Treatment Plant Control: South Building Wet Scrubber
II.A.27 Two (2) Large Waste Treatment Tanks
Vertical Fixed Roof
(1) North Building Tank
Capacity: 44,000 Gallons
(2) South Building Tank
Capacity: 44,000 gallons
II.A.28 Two (2) Small Waste Treatment Tanks Vertical Fixed Roof (1) North Building Tank Capacity: 13,200 Gallons (2) South Building Tank Capacity: 13,200 Gallons II.A.29 Various Natural Gas-Fired Boilers
Rating: < 5 MMBtu/hr Each

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 on site to exceed 10% opacity. [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 route all emissions from the Routing operations to the designated vacuum cleaning system before venting to the atmosphere to control particulate emissions. [R307-401-8]

DAQE-AN100560012-24
Page 8

II.B.2 Drill and Route Baghouse Conditions II.B.2.a The owner/operator shall route all emissions from the Drill and Route operations to the designated baghouse before venting to the atmosphere to control particulate emissions. [R307-401-8]
II.B.2.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure drop across each baghouse. [R307-401-8] II.B.2.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8]
II.B.2.b.2 The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8] II.B.2.c During operation of the baghouses, the owner/operator shall maintain the static pressure drop across each baghouse between 2.0 to 5.0 inches of water column. [R307-401-8]
II.B.2.c.1 The owner/operator shall record the pressure drop at least once per operating day while the baghouse is operating. [R307-401-8] II.B.2.c.2 The owner/operator shall maintain the following records of the pressure drop readings: A. Unit identification; B. Date of reading; C. Daily static pressure drop readings. [R307-401-8]
II.B.2.d At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the gauges. [R307-401-8] II.B.2.d.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8]
II.B.3 Scrubber Requirements II.B.3.a The owner/operator shall route emissions from the north and south building to their respective wet scrubber as listed in II.A before venting to the atmosphere, as indicated below: North Building Scrubber South Building Scrubber II.A.5 Three (3) Etch and Strip Lines II.A.21 Electrolysis Plating Tanks II.A.6 Electroless Dip Tank II.A.22 Strip and Etch Line II.A.7 Copper Plating Bath II.A.23 Organic Finish Line II.A.8 Galvabau Tanks II.A.26 Waste Treatment Plant II.A.9 PAL Nickel Gold Plating II.A.10 Oxide (Circubond) Tanks II.A.15 Waste Treatment Plant II.A.24 Hand Plating/ Magnastrip Tanks. [R307-401-8]
II.B.3.b The owner/operator shall ensure that the effluent from each scrubber is maintained at or above a 7 pH. [R307-401-8]
DAQE-AN100560012-24
Page 9

II.B.3.b.1 The owner/operator shall record the pH value at least once per operating day. [R307-401-8]
II.B.4 VOC Requirements
II.B.4.a The owner/operator shall not emit more than 12.22 tons per rolling 12-month period of VOCs from on-site evaporative sources (painting, printing, coating/solder masks, and/or cleaning) vented to the atmosphere, excluding process tanks. [R307-401-8] II.B.4.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:
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]

II.B.4.a.2 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC-emitting material. B. The maximum percent by weight of VOCs in each material used. C. The density of each material used. D. The volume of each VOC-emitting material used. E. The amount of VOCs emitted from each material. F. The total amount of VOCs emitted from all materials (in tons). [R307-401-8] II.B.4.b The owner/operator shall comply with all applicable requirements of UAC R307-304: Solvent
Cleaning. [R307-304]

II.B.5 Emergency Engine Requirements II.B.5.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used. B. The duration of operation in hours. C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.b The owner/operator shall only use natural gas as fuel in the emergency engine. [R307-401-8]

DAQE-AN100560012-24
Page 10

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN100560011-19 dated November 26, 2019 Is Derived From NOI dated February 22, 2024 Incorporates Additional Information dated June 4, 2024

DAQE-AN100560012-24
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-
RN100560012 August 23, 2024 Ben Nelson TTM Technologies, Inc. 710 North 600 West Logan, UT 84321 [e-mail] Dear Ben Nelson, Re: Engineer Review: Administrative Amendment to Approval Order DAQE-AN100560011-19 to Replace a Baghouse with a Vacuum System under R307-401-12: Reduction in Air Pollutants Project Number: N100560012 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 (NSR) permitting program. TTM Technologies, Inc. should complete this review within 10 business days of receipt. TTM Technologies, Inc. should contact Katie Andersen at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Katie Andersen at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If TTM Technologies, Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If TTM Technologies, Inc. has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 1
UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW
SOURCE INFORMATION Project Number N100560012 Owner Name TTM Technologies, Inc. Mailing Address 710 North 600 West Logan, UT, 84321 Source Name TTM Technologies, Inc.- Logan Circuit Board Plant Source Location 710 North 600 West Logan, UT 84321 UTM Projection 429,401 m Easting, 4,621,849 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3672 (Printed Circuit Boards) Source Contact Ben Nelson Phone Number [phone] Email [e-mail] Billing Contact Ben Nelson Phone Number [phone] Email [e-mail] Project Engineer Katie Andersen, Engineer Phone Number [phone] Email [e-mail] Notice of Intent (NOI) Submitted February 22, 2024 Date of Accepted Application June 6, 2024

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 2
SOURCE DESCRIPTION General Description TTM Technologies, Inc. (TTM) is the owner/operator of the Logan Circuit board Plant in Logan, Cache County. The process starts with a blank circuit board. Circuit board designs are printed or developed onto films. These films are used to create a map for physical etching and chemical stripping into the board to create the necessary pathways and attachments. Process baths are used to accomplish the chemical component of this process. Masks are rolled on by a machine to protect the board, and then sealed through electric oven heating. The Drilling and Routing line is used to sketch additional design pathways onto the board. The board is then dipped into metal tanks to create electrical pathways. Individual plates are compiled into one core and then treated through a similar process in the South Building. The completed circuit panels are packaged and shipped off site. NSR Classification: Administrative Amendment Source Classification Located in Attainment Area Cache County Airs Source Size: B Applicable Federal Standards MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines MACT (Part 63), WWWWWW: National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations Project Proposal Administrative Amendment to Approval Order DAQE-AN100560011-19 to Replace a Baghouse with a Vacuum System under R307-401-12: Reduction in Air Pollutants Project Description TTM requested a modification to AO DAQE-AN100560011-19 for the replacement of the control baghouse on Equipment ID II.A.25 with two (2) Spencer Vacuum Cleaning Systems. This replacement results in a net decrease in air pollutant emissions. This project is an administrative amendment for a reduction in air pollutants (UAC Rule R307-401-12). EMISSION IMPACT ANALYSIS No criteria air pollutants and/or HAPs emissions are increasing. Therefore, no modeling is required at this time. [Last updated June 5, 2024]

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 3
SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 4520.00
Carbon Monoxide 0 3.22 Nitrogen Oxides 0 3.73 Particulate Matter - PM10 -2.30 7.92 Particulate Matter - PM2.5 -2.30 7.92
Sulfur Dioxide 0 0.02 Volatile Organic Compounds 0 27.24 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethylene Glycol (CAS #107211) 0 40
Formaldehyde (CAS #50000) 0 196 Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 2152 Change (TPY) Total (TPY) Total HAPs 0 1.19
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding Circuit Board Manufacturing This project is an administrative amendment for a reduction in air pollutants (UAC Rule R307-401-12). Under UAC R307-401-12(1), the source is not required to submit a notice of intent. Therefore, no BACT is required at this time. [Last updated June 6, 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 Utah Administrative Code (UAC) Rule 307 (R307) and Title 40 of the Code of Federal Regulations (40 CFR). Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 5
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Circuit Board Manufacturing II.A.2 North Building Circuit Plate Development Processes and Equipment
II.A.3 Film Development Rooms Panel film development and silkscreen and film printing
II.A.4 Inner Panel Print Room
II.A.5 Three (3) Etch and Strip Lines Panels are chemically etched and cleaned in process tanks Control: Enclosed and North Scrubber II.A.6 Electroless Dip Tanks Maximum Total Surface Area: 53.40 square feet Control: North Building Scrubber MACT Applicability: Subpart WWWWWW
II.A.7 Copper Plating Bath Control: North Building Scrubber
II.A.8 Galvabau Tanks Maximum Total Surface Area: 1,068 square feet Control: North Building Scrubber II.A.9 PAL Nickel Gold Plating Maximum Total Surface Area: 25.67 square feet Control: North Building Scrubber II.A.10 Oxide (Circubond) Tanks Maximum Total Surface Area: 15 square feet Control: North Building Scrubber

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 6
II.A.11 Mask Development Room Machines apply solder-mask and mask is baked on through electric ovens II.A.12 Soldering Operations Tin and Lead Solder Bars II.A.13 Drill and Route Panel etching and drilling Control: Two (2) Baghouses
II.A.14 Hot Oil and Compression Control: Two (2) cooling towers and 0.005% Drift Eliminators
II.A.15 Waste Treatment Plant Control: North Building Wet Scrubber
II.A.16 Eight (8) Tetraflouromethane Cylinders Capacity: 70 lbs Each II.A.17 Chemical Warehouse Miscellaneous storage tanks II.A.18 One (1) Emergency Generator Rating: 60 kW Manufacturer Date: 1987 Fuel: Natural Gas MACT Applicability: Subpart ZZZZ
II.A.19 South Building Surface Finishing Processes II.A.20 Film Development and Print Room Outer Panel film development and silkscreen and film printing II.A.21 Electrolysis Plating Tanks Control: South Building Wet Scrubber Hot Air Solder Level (HASL) Tanks Maximum Total Surface Area: 22.5 square feet ENIG Tanks Maximum Total Surface Area: 46.04 square feet Silver Tanks Maximum Total Surface Area: 15.33 square feet II.A.22 Strip and Etch Line Control: South Building Wet Scrubber

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 7
II.A.23 Organic Finish Line (ENTEK) Maximum Total Surface Area: 22.5 square feet Control: Blower and South Building Wet Scrubber II.A.24 Hand Plating/ Magnastrip Tanks Maximum Total Surface Area: 128.13 square feet Control: North Building Scrubber
II.A.25 NEW Routing Finishing Line drilling Control: Two (2) Spencer Vacuum Cleaning Systems (NEW) II.A.26 Waste Treatment Plant Control: South Building Wet Scrubber II.A.27 Two (2) Large Waste Treatment Tanks Vertical Fixed Roof (1) North Building Tank Capacity: 44,000 Gallons (2) South Building Tank Capacity: 44,000 gallons II.A.28 Two (2) Small Waste Treatment Tanks Vertical Fixed Roof (1) North Building Tank Capacity: 13,200 Gallons (2) South Building Tank Capacity: 13,200 Gallons II.A.29 Various Natural Gas-Fired Boilers Rating: < 5 MMBtu/hr Each
SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions on site to exceed 10% opacity. [R307-401-8]
Commented [KA1]: Manually Add

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 8
II.B.1.a.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b NEW The owner/operator shall route all emissions from the Routing operations to the designated vacuum cleaning system before venting to the atmosphere to control particulate emissions. [R307-401-8] II.B.2 NEW Drill and Route Baghouse Conditions
II.B.2.a NEW The owner/operator shall route all emissions from the Drill and Route operations to the designated baghouse before venting to the atmosphere to control particulate emissions. [R307-401-8]
II.B.2.b NEW The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure drop across each baghouse. [R307-401-8]
II.B.2.b.1 NEW The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.2.b.2 NEW The pressure gauge shall measure the pressure drop in 1-inch water column increments or less. [R307-401-8] II.B.2.c NEW During operation of the baghouses, the owner/operator shall maintain the static pressure drop across each baghouse between 2.0 to 5.0 inches of water column. [R307-401-8] II.B.2.c.1 NEW The owner/operator shall record the pressure drop at least once per operating day while the baghouse is operating. [R307-401-8] II.B.2.c.2 NEW The owner/operator shall maintain the following records of the pressure drop readings: A. Unit identification; B. Date of reading; C. Daily static pressure drop readings. [R307-401-8] II.B.2.d NEW At least once every 12 months, the owner/operator shall calibrate the pressure gauges in accordance with the manufacturer's instructions or replace the gauges. [R307-401-8] II.B.2.d.1 NEW The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] II.B.3 NEW Scrubber Requirements

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 9
II.B.3.a NEW The owner/operator shall route emissions from the north and south building to their respective wet scrubber as listed in II.A before venting to the atmosphere, as indicated below:
North Building Scrubber South Building Scrubber
II.A.5 Three (3) Etch and Strip Lines II.A.21 Electrolysis Plating Tanks
II.A.6 Electroless Dip Tank II.A.22 Strip and Etch Line II.A.7 Copper Plating Bath II.A.23 Organic Finish Line
II.A.8 Galvabau Tanks II.A.25 Waste Treatment Plant
II.A.9 PAL Nickel Gold Plating
II.A.10 Oxide (Circubond) Tanks
II.A.14 Waste Treatment Plant II.A.24 Hand Plating/ Magnastrip Tanks. [R307-401-8]
II.B.3.b The owner/operator shall ensure that the effluent from each scrubber is maintained at or above a 7 pH. [R307-401-8] II.B.3.b.1 The owner/operator shall record the pH value at least once per operating day. [R307-401-8] II.B.4 VOC Requirements
II.B.4.a The owner/operator shall not emit more than 12.22 tons per rolling 12-month period of VOCs from on-site evaporative sources (painting, printing, coating/solder masks, and/or cleaning) vented to the atmosphere, excluding process tanks. [R307-401-8] II.B.4.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: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]
II.B.4.a.2 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC-emitting material B. The maximum percent by weight of VOCs in each material used C. The density of each material used D. The volume of each VOC-emitting material used E. The amount of VOCs emitted from each material F. The total amount of VOCs emitted from all materials (in tons). [R307-401-8] II.B.4.b NEW The owner/operator shall comply with all applicable requirements of UAC R307-304: Solvent Cleaning. [R307-304] II.B.5 Emergency Engine Requirements

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 10
II.B.5.a NEW The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5.a.1 NEW To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following:
A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5.b The owner/operator shall only use natural gas as fuel in the emergency engine. [R307-401-8]

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 11
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN100560011-19 dated November 26, 2019 Is Derived From NOI dated February 22, 2024 Incorporates Additional Information dated June 4, 2024
REVIEWER COMMENTS 1. Comment regarding Reduction in Air Pollutants: For the requested Administrative Amendment, TTM has submitted new emissions for this site. The changes in emissions are for the replacement of the existing Rout Baghouse with two (2) Spencer Vacuum Cleaning Systems. TTM has submitted for these changes under R307-401-12. R307-401-12 applies to owners or operators of a stationary source of air pollutants that reduce or eliminate air pollutants. The change must not increase the potential to emit of any air pollutant or cause emissions of any new air pollutant. The proposed changes have resulted in a total reduction in site-wide PTE. Therefore, this amendment qualifies as a Reduction in Air Pollutants. TTM has requested the replacement of the control baghouse listed under II.A.25 Routing with two (2) Spencer Vacuum Cleaning Systems. The baghouse and the Spencer Vacuums are assumed to operate 8,760 hours annually to process the Route and Drill lines on site. Emission factors are from Manufacturer Data and the guidance from UDAQ Form 10. The main cause of this reduction in air pollutants stems from the decrease in the flow rates through the new filters. The existing baghouse operates at 5,500 scfm, while the new vacuum system operates at 840 scfm per vacuum. The total change in air flowrate is a decrease of 3,820 scfm. The equipment replacement results in a reduction of 2.30 tpy PM10 and 2.30 tpy PM2.5. [Last updated August 14, 2024] 2. Comment regarding Emission Estimates: Emissions were estimated from the following sources: The emissions estimated for the existing baghouse used the outlet default value of 0.016 grains PM10/dscf recommended by the DAQ on Form 10 Fabric Filters (Baghouses). This outlet default value is the same value used by the source when calculating emissions for the baghouse for the 2019 permit modification. The system emitted air flowrate is approximately 5,500 scfm based on conversations between the source and representatives from the American Vacuum Company and SPE Filters Inc. The existing filters are 20 micron. The emissions for the Spencer Vacuum Cleaning Systems were calculated using the same outlet default value of 0.016 grains PM10/dscf. The vacuum cleaning systems have a flow rate of 840 scfm. The filters used in the vacuum cleaning system are HEPA (1 micron). [Last updated June 10, 2024] 3. Comment regarding NSPS and MACT Applicability: National Emission Standards for Hazardous Air Pollutants: Subpart WWWWWW for Area Source Standards for Plating and Polishing Operations. This Subpart applies to plating and polishing facilities that are an area source of HAP emissions that engages in electroless plating. TTM using electroless plating in its circuit board manufacturing process and is therefore subject to this subpart. Among other compliance and recordkeeping

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 2024 Page 12
requirements, this subpart requires the use of a wetting agent/fume suppressant in electroplating tanks, capture and exhaust of emissions through a scrubber, as well as applicable management practices. NSPS Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines This Subpart applies to owners, and operators of stationary spark ignition (SI) internal combustion engines (ICE) that commence construction after June 12, 2006. The on-site emergency engine was manufactured and installed in 1987. This subpart does not apply. MACT Subpart ZZZZ -National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines This Subpart is applicable to owners/operators of stationary RICE at a major or area sources of HAP emissions. The provisions of MACT Subpart ZZZZ are applicable to the engine on site. Therefore, MACT Subpart ZZZZ applies to this facility. [Last updated June 25, 2024] 4. Comment regarding Title V: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source; 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants; or 4. Any Title IV affected source This facility is not a major source and is not a Title IV source; however, the facility is subject to 40 CFR 63 MACT Subparts A, ZZZZ, and WWWWWW regulations. The applicable Subparts each exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. There are no other reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not apply to this facility. [Last updated June 25, 2024]

Engineer Review N100560012: TTM Technologies, Inc.- Logan Circuit Board Plant August 14, 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
Total PM Baghouse Emissions
Parameter Value UnitsNew7.617 tpyOld9.911 tpy
2.295 decrease to make in TEMPO
7.925 Total to be read in TEMPO
Main Baghouse 1A (Route)
Parameter Value UnitsEmission Grainloading1 0.016 gr/scfAir Flowrate2 840 scfmAnnual Operating Hours 8,760 hr/yrPM/PM10/PM2.5 Hourly Emissions 0.115 lb/hrPM/PM10/PM2.5 Annual Emissions3 0.505 tpy1 Fabric filter grain loading assumed to be equivalent to the UDAQ BACT limit.
2 Per drawings provided by The Spencer Turbine Company 3 Calculation methodology:
Main Baghouse 1B (Route)
Parameter Value UnitsEmission Grainloading1 0.016 gr/scfAir Flowrate2 840 scfmAnnual Operating Hours 8,760 hr/yrPM/PM10/PM2.5 Hourly Emissions 0.115 lb/hrPM/PM10/PM2.5 Annual Emissions3 0.505 tpy1 Fabric filter grain loading assumed to be equivalent to the UDAQ BACT limit.2 Per drawings provided by The Spencer Turbine Company 3 Calculation methodology: 3820
Main Baghouse 2 (Drill)
Parameter Value UnitsEmission Grainloading1 0.016 gr/scfAir Flowrate2 5,500 scfmAnnual Operating Hours 8,760 hr/yrPM/PM10/PM2.5 Hourly Emissions 0.754 lb/hrPM/PM10/PM2.5 Annual Emissions3 3.304 tpy1 Fabric filter grain loading assumed to be equivalent to the UDAQ BACT limit.2 Based on conversation with Jack Person at American Vacuum Co. and Mark Sternita at CPE Filters Inc. on 8/18/2016 the baghouse capacity is 3 Calculation methodology:
Quick Turn Baghouse
Parameter Value UnitsEmission Grainloading1 0.016 gr/scfAir Flowrate2 5,500 scfmAnnual Operating Hours 8,760 hr/yrPM/PM10/PM2.5 Hourly Emissions 0.754 lb/hrPM/PM10/PM2.5 Annual Emissions3 3.304 tpy1 Fabric filter grain loading assumed to be equivalent to the UDAQ BACT limit.2 Based on conversation with Jack Person at American Vacuum Co. and Mark Sternita at CPE Filters Inc. on 8/18/2016 the baghouse capacity is 3 Calculation methodology:
Emission Inventory Update
Appendix Table C-13. Main Baghouse 1 (Drill and Route)
Parameter Value UnitsFabric Filter Efficiency1 0.016 gr/scfAir Flowrate2 5,500 scfmAnnual Operating Hours 8,760 hr/yrPM/PM10/PM2.5 Hourly Emissions 0.754 lb/hrPM/PM10/PM2.5 Annual Emissions3 3.304 tpy1 Fabric filter grain loading assumed to be equivalent to the UDAQ BACT limit.
2 Based on conversation with Jack Person at American Vacuum Co. and Mark Sternita at CPE Filters Inc. on 8/18/2016 the baghouse capacity is approximately 5,500 scfm. 3 Calculation methodology:
TTM Technologies Page 8 of 10 Trinity Consultants
Emission Inventory Update
Appendix Table C-14. Main Baghouse 2 (Drill and Route)
Parameter Value UnitsFabric Filter Efficiency1 0.016 gr/scfAir Flowrate2 5,500 scfmAnnual Operating Hours 8,760 hr/yrPM/PM10/PM2.5 Hourly Emissions 0.754 lb/hrPM/PM10/PM2.5 Annual Emissions3 3.304 tpy1 Fabric filter grain loading assumed to be equivalent to the UDAQ BACT limit.2 Based on conversation with Jack Person at American Vacuum Co. and Mark Sternita at CPE Filters Inc. on 8/18/2016 the baghouse capacity is approximately 5,500 scfm. 3 Calculation methodology:
TTM Technologies Page 9 of 10 Trinity Consultants
Emission Inventory Update
Appendix Table C-15. Quick Turn Baghouse
Parameter Value UnitsFabric Filter Efficiency1 0.016 gr/scfAir Flowrate2 5,500 scfmAnnual Operating Hours 8,760 hr/yrPM/PM10/PM2.5 Hourly Emissions 0.754 lb/hrPM/PM10/PM2.5 Annual Emissions3 3.304 tpy1 Fabric filter grain loading assumed to be equivalent to the UDAQ BACT limit.2 Based on conversation with Jack Person at American Vacuum Co. and Mark Sternita at CPE Filters Inc. on 8/18/2016 the baghouse capacity is approximately 5,500 scfm. 3 Calculation methodology:
TTM Technologies Page 10 of 10 Trinity Consultants
6/5/24, 12:58 PM State of Utah Mail - Division of Air Quality Baghouse Replacement
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7346459083711939903&simpl=msg-a:r-4012745494160…1/8
Katie Andersen <[e-mail]>
Division of Air Quality Baghouse Replacement
24 messages
Katie Andersen <[e-mail]>Tue, Feb 27, 2024 at 10:23 AM
To: [e-mail]
Hello Jackie,
The DEQ Division of Air Quality received your letter regarding replacing the baghouse that is connected to the Rout
Department with two Spencer Vacuum Cleaning Systems.
Based on the information provided in the letter, there are two possible ways of updating the existing permit (DAQE-
AN100560011-19). The first is a Replacement in Kind which allows for existing process equipment or pollution control
equipment to be replaced if the potential to emit of the equipment is the same or lower, the number of emission points or
emitting units is the same or lower, no additional types of air pollutants are emitted as a result of the replacement, the new
equipment is identical or functionally equivalent to the replaced equipment, the replaced equipment is permanently
removed from the source, the replacement process does not trigger NSPS or NESHAP, and the replacement does not
violate other provisions in Title R307 (Air Quality).
The second is through a Reduction in Air Pollutants which allows a change in the equipment if there is a reduction or
elimination of air pollutants. For this, the project must not increase the potential to emit or cause emissions of any new air
pollutant.
Since you will be replacing one baghouse with two vacuum cleaning units, it sounds like the best course of action is a
Reduction in Air Pollutants. For this option, I will need information regarding the old and new systems.
Please provide the emission estimates for both the current Baghouse and the new Spencer Vacuum Cleaning Systems.
Please also provide information regarding flow rates, filtration efficiencies, and any other information that shows this
replacement will reduce air pollution emission.
Please let me know if you have any questions.
Cheers,
Katie
--

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
Nelson, Ben <[e-mail]>Wed, Feb 28, 2024 at 10:05 AM
To: Katie Andersen <[e-mail]>
6/5/24, 12:58 PM State of Utah Mail - Division of Air Quality Baghouse Replacement
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7346459083711939903&simpl=msg-a:r-4012745494160…2/8
Hi Kae,

I wanted to introduce myself as the acng EHS Manager of TTM-Logan. I will be your contact going forward on this.
Thank you very much for the informaon on how correctly permit these new collectors. I am under the belief that
both systems operate at 99.7% capture efficiency, and therefore no net reducon. I will review the equipment
specificaons and revert back.

Thanks again,
Ben

Ben Nelson | Regional Director, EHSS – North Region | TTM Technologies
503.952.6223 - Cell | www.ttm.com | [e-mail]

From: Kae Andersen <[e-mail]>
Sent: Tuesday, February 27, 2024 9:23 AM
To: Tolboe, Jackie <[e-mail]>
Subject: Division of Air Quality Baghouse Replacement

NOTICE: This email originated from outside of TTM. Do not click links or open attachments unless you know
the content is safe. NEVER enter network credentials into a website from an email link.
[Quoted text hidden]

Katie Andersen
[Quoted text hidden]
M: [phone]
airquality.utah.gov [airquality.utah.gov]

NOTICE: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged
information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient,
please contact the sender by reply email and destroy all copies of the original message.
6/5/24, 12:58 PM State of Utah Mail - Division of Air Quality Baghouse Replacement
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7346459083711939903&simpl=msg-a:r-4012745494160…3/8
Katie Andersen <[e-mail]>Thu, Mar 7, 2024 at 9:41 AM
To: "Nelson, Ben" <[e-mail]>
Hi Ben,
It is nice to get in contact with you! I will add your contact information on our side of things.
Please let me know if you have any questions.
Cheers,
Katie Andersen
[Quoted text hidden]
Katie Andersen <[e-mail]>Thu, Mar 21, 2024 at 8:56 AM
To: "Nelson, Ben" <[e-mail]>
Hi Ben,
I'm following up with you regarding the letter that TTM sent to the Division of Air Quality (DAQ) with respect to the
baghouse replacement. Without the specifications requested previously, the project may not move forward. Please send
the specifications for the existing baghouse and the potential replacement vacuum cleaning systems.
Please let me know if you have any questions.
Cheers,
Katie Andersen
On Wed, Feb 28, 2024 at 10:05 AM Nelson, Ben <[e-mail]> wrote:
[Quoted text hidden]
Nelson, Ben <[e-mail]>Thu, Mar 21, 2024 at 11:48 AM
To: Katie Andersen <[e-mail]>
Hi Kae,

I apologize as I misinterpreted what was previously requested. Let me track those documents down. I know that
Jackie had found them.

Again, I’m sorry for my misunderstanding.

Thanks,
Ben
[Quoted text hidden]
[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Mar 26, 2024 at 9:02 AM
To: "Nelson, Ben" <[e-mail]>
Thank you Ben!
6/5/24, 12:58 PM State of Utah Mail - Division of Air Quality Baghouse Replacement
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7346459083711939903&simpl=msg-a:r-4012745494160…4/8
Let me know if you have any questions,
Cheers,
Katie Andersen
[Quoted text hidden]
Nelson, Ben <[e-mail]>Tue, Apr 2, 2024 at 4:05 PM
To: Katie Andersen <[e-mail]>
Hi Kae,

Quick update. I finally tracked down the spec sheet on the filters used. I’m verifying capture efficiency from the
manufacture currently.
[Quoted text hidden]
[Quoted text hidden]
Katie Andersen <[e-mail]>Thu, Apr 4, 2024 at 8:31 AM
To: "Nelson, Ben" <[e-mail]>
Ben,
Thank you for the update! Once you verify the efficiencies, I'd love to see the spec sheets!
Cheers,
Katie Andersen
[Quoted text hidden]
Katie Andersen <[e-mail]>Fri, Apr 19, 2024 at 12:43 PM
To: "Nelson, Ben" <[e-mail]>
Ben,
Have you been able to verify capture efficiencies from the manufacturer?
Cheers,
Katie Andersen
[Quoted text hidden]
Nelson, Ben <[e-mail]>Fri, Apr 19, 2024 at 11:35 PM
To: Katie Andersen <[e-mail]>
Hi Katie,
We have the current. We have been hung up on getting capture efficiency of the existing from the supplier. We called
again earlier today and were told the technical contact will be back on Monday. We will provide you a response by
Tuesday morning at the latest.
Thank you,
Ben
From: Kae Andersen <[e-mail]>
Sent: Friday, April 19, 2024 11:43:09 AM
[Quoted text hidden]

[Quoted text hidden]
6/5/24, 12:58 PM State of Utah Mail - Division of Air Quality Baghouse Replacement
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7346459083711939903&simpl=msg-a:r-4012745494160…5/8
Katie Andersen <[e-mail]>Thu, Apr 25, 2024 at 8:06 AM
To: "Nelson, Ben" <[e-mail]>
Ben,
I will keep an eye out for those efficiencies then!
Cheers,
Katie Andersen
[Quoted text hidden]
Nelson, Ben <[e-mail]>Thu, Apr 25, 2024 at 8:30 AM
To: Katie Andersen <[e-mail]>
Hi Kae,

We were informed that the exisng filters were 20 micron. The new filters are HEPA (1 micron). How would you like
us to provide the informaon?
[Quoted text hidden]
[Quoted text hidden]
Katie Andersen <[e-mail]>Thu, Apr 25, 2024 at 8:41 AM
To: "Nelson, Ben" <[e-mail]>
Ben,
If you could provide the specification sheets and the emission estimates for both the baghouse and the vacuum system,
that would be great. PDFs of the spec sheets are sufficient. Emission estimates in the form of an excel sheet would be
preferable.
Please let me know if you have any questions.
Cheers,
Katie Andersen
[Quoted text hidden]
Nelson, Ben <[e-mail]>Thu, Apr 25, 2024 at 8:43 AM
To: Katie Andersen <[e-mail]>
Cc: "Hobbs, Jaren" <[e-mail]>
Hi Kae,

Thank you, we will put it together.
[Quoted text hidden]
[Quoted text hidden]
Nelson, Ben <[e-mail]>Mon, May 6, 2024 at 10:40 AM
To: Katie Andersen <[e-mail]>
Hello Kae,
6/5/24, 12:58 PM State of Utah Mail - Division of Air Quality Baghouse Replacement
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7346459083711939903&simpl=msg-a:r-4012745494160…6/8

I le you a VM early last week. I believe that we have everything needed to move forward. Do you have a few mins
this week to discuss?
[Quoted text hidden]
[Quoted text hidden]
Katie Andersen <[e-mail]>Mon, May 6, 2024 at 10:55 AM
To: "Nelson, Ben" <[e-mail]>
Ben,
I have time to discuss moving forward tomorrow or Wednesday. Which day works best? Afternoons work the best for me.
Cheers,
Katie Andersen
[Quoted text hidden]
Nelson, Ben <[e-mail]>Mon, May 6, 2024 at 10:59 AM
To: Katie Andersen <[e-mail]>
Hi Kae,

Let’s do Wednesday. I’m free aer 1 pm.
[Quoted text hidden]
[Quoted text hidden]
Katie Andersen <[e-mail]>Mon, May 6, 2024 at 11:06 AM
To: "Nelson, Ben" <[e-mail]>
Ben,
I'll send you a calendar invite for 1:30pm.
Cheers,
Katie Andersen
[Quoted text hidden]
Nelson, Ben <[e-mail]>Mon, May 13, 2024 at 9:38 AM
To: Katie Andersen <[e-mail]>
Hello Kae,

Thanks for meeng with me last week. As discussed, I’m including the current calculaons, specificaon sheet for
new collectors, and a narrave with explanaon below.

Calculations utilized for the existing air permit for baghouse particulate matter (PM) annual emissions were
performed using the UDAQ BACT limit for emission grain loading per UDAQ Form 10. System emitted air
flowrate was based on conversations with representatives from American Vacuum Company and CPE Filters Inc.
6/5/24, 12:58 PM State of Utah Mail - Division of Air Quality Baghouse Replacement
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7346459083711939903&simpl=msg-a:r-4012745494160…7/8

For the new calculations relating to the proposed Spencer Vacuum Cleaning Systems baghouse, the same
emission grain loading value is used. The emitted airflow rate is based on technical drawings from The Spencer
Turbine Company of the new system blowers (see attached 2024_South_Baghouse_Blower_Spec.pdf). For
calculations of the new configuration, the Drill and Route Baghouse identifiers are changed to specify which
system, as they are no longer the same. The Drill baghouse system is unchanged.

The Route baghouse is now broken into two separate calculations to represent the two units replacing a single
unit.
Calculated baghouse PM emissions with the proposed system are reduced by approximately 22%.
[Quoted text hidden]
[Quoted text hidden]
2 attachments
2024_Baghouse_Emission_Calculations_NewVsOld.xlsx
38K
2024_South_Baghouse_Blower_Spec.pdf
404K
Katie Andersen <[e-mail]>Thu, May 16, 2024 at 10:51 AM
To: "Nelson, Ben" <[e-mail]>
Hi Ben,
I see you used the default outlet value for the particulate loading on the fabric filters (The emission grain loading and the
fabric filter efficiency). Can you provide the particulate loading values from the manufacturer? Or the amount of particulate
matter in the gas stream that is going into the filters?
We'd like to make sure that the systems you are going to use will be able to meet those assumptions.
Cheers,
Katie Andersen
[Quoted text hidden]
Nelson, Ben <[e-mail]>Tue, May 21, 2024 at 3:18 PM
To: Katie Andersen <[e-mail]>
Hi Kae,

I don’t have a good esmate on the grain loading. I could esmate the loading by the amount collected. We believe
the filter efficiency is HEPA but used the default because we were unable to get any confirmaon from the
manufacture. This info coupled with the decreased flow rate, we know this is a reducon.

How should we proceed?
[Quoted text hidden]
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, May 22, 2024 at 2:28 PM
To: "Nelson, Ben" <[e-mail]>
6/5/24, 12:58 PM State of Utah Mail - Division of Air Quality Baghouse Replacement
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-7346459083711939903&simpl=msg-a:r-4012745494160…8/8
Hi Ben,
Do either of the systems have designed emission rates? The manufacturers would know for sure. At the least, do the
Spencer Vacuums have emission rates?
Without manufacturing data, it may be tricky to calculate the loadings. Estimating the loadings by the amount collected
would be a good way to do it. You can estimate the loadings by looking at how much is collected per certain amount of
product created/used. Doing this for both the old and the new system would definitely show the reduction.
I do apologize for my repeated questions. I'd like to be able to clearly show anyone who looks at the calculations that this
is a reduction.
Cheers,
Katie
[Quoted text hidden]
Nelson, Ben <[e-mail]>Thu, May 23, 2024 at 9:11 AM
To: Katie Andersen <[e-mail]>
Hi Kae,

We will get the necessary informaon.
[Quoted text hidden]
[Quoted text hidden]
Nelson, Ben <[e-mail]>Tue, Jun 4, 2024 at 5:23 PM
To: Katie Andersen <[e-mail]>
Hi Kae,

We’ve had more than a few conversaons with Manufacturer’s and unable to get any confirmaon on emission rates.
The system is essenally a blower and a bag. When we call and speak with the bag manufacturer, they are unwilling
to comment on filter efficiency.

If I go back to our last permit, it used the default UDAQ value. If I use that same UDAQ value for the new system with
less exhaust capacity, wouldn’t that show a clear reducon.

Thanks for your help in geng this resolved. I’m sorry we’re not able to get the info from Spencer.

Ben
[Quoted text hidden]
[Quoted text hidden]