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HomeMy WebLinkAboutDAQ-2024-011283 DAQE-AN104520007-24 {{$d1 }} Kari Kovar Cottonwood Mill & Cabinet 12757 South Minuteman Way Draper, UT 84020 kari.kovar@cottonwoodcabinets.com Dear Ms. Kovar: Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN104520006-24 for a 10-Year Review to Update Baghouse Requirements and Equipment List Project Number: N104520007 The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a 10-year administrative review of this source and its respective AO. Cottonwood Mill & Cabinet must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Dylan Frederick, who can be contacted at (385) 306-6529 or dfrederick@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. Sincerely, {{$s }} Bryce C. Bird Director BCB:DF:jg 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 October 17, 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-AN104520007-24 Administrative Amendment to Approval Order DAQE-AN104520006-24 for a 10-Year Review to Update Baghouse Requirements and Equipment List Prepared By Dylan Frederick, Engineer (385) 306-6529 dfrederick@utah.gov Issued to Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality October 17, 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 ..................................................................................... 5 PERMIT HISTORY ..................................................................................................................... 8 ACRONYMS ................................................................................................................................. 9 DAQE-AN104520007-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Cottonwood Mill & Cabinet Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility Mailing Address Physical Address 12757 South Minuteman Way 12757 South Minuteman Way Draper, UT 84020 Draper, UT 84020 Source Contact UTM Coordinates Name: Kari Kovar 424,679 m Easting Phone: (801) 572-6550 4,485,798 m Northing Email: kari.kovar@cottonwoodcabinets.com Datum NAD83 UTM Zone 12 SIC code 2511 (Wood Household Furniture, Except Upholstered) SOURCE INFORMATION General Description Cottonwood Mill & Cabinet operates a cabinet manufacturing facility in Draper, Utah. The facility generates emissions from wood finishing operations as well as wood coating and painting operations from the paint spray booths at the facility. Particulates from wood cutting, planing, and sanding operations are controlled by a vacuum system that routes particulates to internally venting baghouses at the facility. Painting and spraying operations take place in the paint spray booths at the facility and are controlled by particulate arrestor filter systems. NSR Classification 10-Year Review Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA Salt Lake County Airs Source Size: B Applicable Federal Standards None DAQE-AN104520007-24 Page 4 Project Description This administrative amendment is to incorporate updates to the approval order (AO). Cottonwood Mill & Cabinet sent letters to the DAQ indicating the two baghouses previously listed in the AO were replaced with baghouse units that vent internally (DAQE-948-97 and DAQE-494-01). The requirements related to the baghouses were removed from the requirements section as they do not vent to the atmosphere. Additionally, condition II.B.1.e from the previous AO did not apply to any equipment on site, as there are no instruments operating that require calibration at the facility. Therefore, this requirement was removed from the AO. 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) Carbon Monoxide 0 1.00 Nitrogen Oxides 0 1.00 Particulate Matter - PM10 0 1.00 Particulate Matter - PM2.5 0 1.00 Sulfur Dioxide 0 1.00 Volatile Organic Compounds 0 22.55 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 24420 Change (TPY) Total (TPY) Total HAPs 0 12.21 SECTION I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two years. [R307-401-8] DAQE-AN104520007-24 Page 5 I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Cabinet Manufacturing Facility II.A.2 Spray Booth Room II.A.3 One Baghouse Flow Rate: 35,000 CFM *Vents internally, listed for informational purposes only. II.A.4 One Baghouse Return air fabric filter system *Vents internally, 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 have a copy of this AO available on site. The owner/operator shall make a copy of the AO available to the employees who operate the air emission-producing equipment. The owner/operator shall provide instruction to employees as to their responsibilities in operating the equipment according to all of the relevant conditions in this AO. [R307-401-8] II.B.1.b The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source associated with the source or with the control facilities to exceed 10% opacity. [R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and intermittent sources shall use procedures similar to Method 9, but the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. Any time interval with no visible emissions shall not be included. [40 CFR 60 Subpart A, R307-401-8] DAQE-AN104520007-24 Page 6 II.B.1.c The owner/operator shall comply with all applicable requirements of R307-342, "Adhesives and Sealants." [R307-342] II.B.1.d The owner/operator shall comply with all applicable requirements of R307-343, "Wood Furniture Manufacturing Operations." [R307-343] II.B.1.e The owner/operator shall keep a copy of all manufacturers' operating instructions for pollution control equipment and pollution-emitting equipment on site. Manufacturer instructions shall be made available to all employees who operate the equipment and shall be made available to compliance inspectors upon their request. [R307-401-8] II.B.1.f The owner/operator shall install paint arrestor particulate filters on all spray booths. All air exiting the spray booths shall be routed through the arrestor filters before being vented to the atmosphere. [R307-401-8] II.B.2 VOC & HAP Requirements II.B.2.a The owner/operator shall not emit more than the following rate from the Spray Booth Exhaust: Pollutant lb/hr VOC 5.2 [R307-401-8] II.B.2.a.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-401-8] II.B.2.a.2 Test Frequency The owner/operator shall conduct a stack test on the emission unit as required by the Director. The Director may require the owner/operator to perform a stack test at any time. No initial testing is required. [R307-401-8] II.B.2.b The owner/operator shall not allow the VOC content of coatings used in the booth to exceed the limits established in R307-343-4, Table 1. The owner/operator shall not allow high-solids paints to be thinned or otherwise reduced beyond manufacturer’s recommendations. These parameters shall be tested if directed by the Director using the appropriate ASTM method or another method approved by the Director. [R307-401-8] II.B.2.c The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 22.55 tons per rolling 12-month period of VOCs. 9.99 tons per rolling 12-month period of any one HAP. 12.21 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.2.c.1 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] DAQE-AN104520007-24 Page 7 II.B.2.c.2 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]. HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] II.B.2.c.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material. B. The maximum percent by weight of VOCs and each HAP in each material used. C. The density of each material used. D. The volume of each VOC- and HAP-emitting material used. E. The amount of VOCs and the amount of each HAP emitted from each material. F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material. G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] II.B.3 Stack Testing Requirements II.B.3.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.3.a.1 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.3.a.2 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] II.B.3.a.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.3.a.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] DAQE-AN104520007-24 Page 8 II.B.3.a.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.3.a.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.3.b 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.3.b.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] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN104520006-24 dated January 18, 2024 Is Derived From Compliance Notification dated January 22, 2024 Incorporates Additional Information dated September 13, 2024 DAQE-AN104520007-24 Page 9 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- RN104520007 September 20, 2024 Kari Kovar Cottonwood Mill & Cabinet 12757 S Minuteman Way Draper, UT 84020 kari.kovar@cottonwoodcabinets.com Dear Kari Kovar, Re: Engineer Review - 10-Year Review and Permit Updates: Administrative Amendment to Approval Order DAQE-AN104520006-24, dated January 18, 2024, to Update Baghouse Requirements and Equipment List Project Number: N104520007 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. Cottonwood Mill & Cabinet should complete this review within 10 business days of receipt. Cottonwood Mill & Cabinet should contact Dylan Frederick at (385) 306-6529 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dylan Frederick at dfrederick@utah.gov 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 Cottonwood Mill & Cabinet does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Cottonwood Mill & Cabinet 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 N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N104520007 Owner Name Cottonwood Mill & Cabinet Mailing Address 12757 S Minuteman Way Draper, UT, 84020 Source Name Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility Source Location 12757 S Minuteman Way Draper, UT 84020 UTM Projection 424,679 m Easting, 4,485,798 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2511 (Wood Household Furniture, Except Upholstered) Source Contact Kari Kovar Phone Number (801) 572-6550 Email kari.kovar@cottonwoodcabinets.com Billing Contact Kari Kovar Phone Number (801) 572-6550 Email kari.kovar@cottonwoodcabinets.com Project Engineer Dylan Frederick, Engineer Phone Number (385) 306-6529 Email dfrederick@utah.gov Notice of Intent (NOI) Submitted January 30, 2024 Date of Accepted Application August 13, 2024 Engineer Review N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 Page 2 SOURCE DESCRIPTION General Description Cottonwood Mill and Cabinet operates a cabinet manufacturing Facility in Draper, Utah. The facility generates emissions from wood finishing operations, as well as wood coating and painting operations from the paint spray booths at the facility. Particulates from wood cutting, plaining, and sanding operations are controlled by a vacuum system that routes particulates to internally venting baghouses at the facility. Painting and Spraying operations take place in the paint spray booths at the facility, and are controlled by particulate arrestor filter systems. NSR Classification: 10 Year Review Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA Salt Lake County Airs Source Size: B Applicable Federal Standards N/A Project Proposal Administrative Amendment to Approval Order DAQE-AN104520006-24, dated January 18, 2024, to Update Baghouse Requirements and Equipment List Project Description This administrative amendment is to incorporate updates to the approval order (AO). Cottonwood Mill and Cabinet sent letters to the DAQ indicating the two baghouses previously listed in the AO were replaced with baghouse units that vent internally (DAQE-948-97 and DAQE-494-01). The requirements related to the baghouses were removed from the requirements section as they do not vent to the atmosphere. Additionally, condition II.B.1.e from the previous AO did not apply to any equipment on site, as there are no instruments operating that require calibration at the facility. Therefore, this requirement was removed from the AO. EMISSION IMPACT ANALYSIS This is an administrative amendment for a 10-year review. No changes to emissions are being made at this time and equipment has been removed from the approval order; therefore, modeling is not required. [Last updated August 13, 2024] Engineer Review N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 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) Carbon Monoxide 0 1.00 Nitrogen Oxides 0 1.00 Particulate Matter - PM10 0 1.00 Particulate Matter - PM2.5 0 1.00 Sulfur Dioxide 0 1.00 Volatile Organic Compounds 0 22.55 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Generic HAPs (CAS #GHAPS) 0 24420 Change (TPY) Total (TPY) Total HAPs 0 12.21 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding BACT This is an administrative amendment; no new equipment is being added and emissions are unchanged. Therefore, a BACT analysis is not required. [Last updated August 13, 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] 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 N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 Page 5 SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Cabinet Manufacturing Facility II.A.2 Spray Booth Room II.A.3 One (1) Baghouse Flow Rate: 35,000 CFM *Vents internally, listed for informational purposes only II.A.4 One (1) Baghouse Return air fabric filter system *Vents internally, listed for informational purposes only SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site Wide Requirements II.B.1.a NEW The owner/operator shall have a copy of this AO available on site. The owner/operator shall make a copy of the AO available to the employees who operate the air emission producing equipment. The owner/operator shall provide instruction to employees as to their responsibilities in operating the equipment according to all of the relevant conditions in this AO. [R307-401-8] II.B.1.b The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source associated with the source or with the control facilities to exceed 10% opacity. [R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and intermittent sources shall use procedures similar to Method 9, but the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. Any time interval with no visible emissions shall not be included. [40 CFR 60 Subpart A, R307-401-8] II.B.1.c The owner/operator shall comply with all applicable requirements of R307-342 "Adhesives and Sealants". [R307-342] Engineer Review N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 Page 6 II.B.1.d The owner/operator shall comply with all applicable requirements of R307-343 "Wood Furniture Manufacturing Operations". [R307-343] II.B.1.e The owner/operator shall keep a copy of all manufacturers' operating instructions for pollution control equipment and pollution emitting equipment on site. Manufacturer instructions shall be made available to all employees who operate the equipment and shall be made available to compliance inspectors upon their request. [R307-401-8] II.B.1.f NEW The owner/operator shall install paint arrestor particulate filters on all spray booths. All air exiting the spray booths shall be routed through the arrestor filters before being vented to the atmosphere. [R307-401-8] II.B.2 VOC & HAP Requirements II.B.2.a The owner/operator shall not emit more than the following rate from the Spray Booth Exhaust: Pollutant lb/hr VOC 5.2 [R307-401-8] II.B.2.a.1 NEW Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-401-8] II.B.2.a.2 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit as required by the Director. The Director may require the owner/operator to perform a stack test at any time. No initial testing is required. [R307-401-8] II.B.2.b The owner/operator shall not allow the VOC content of coatings used in the booth to exceed the limits established in R307-343-4, Table 1. The owner/operator shall not allow high solids paints to be thinned or otherwise reduced beyond manufacturers recommendations. These parameters shall be tested if directed by the Director using the appropriate ASTM method or another method approved by the Director. [R307-401-8] II.B.2.c The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 22.55 tons per rolling 12-month period of VOCs 9.99 tons per rolling 12-month period of any one (1) HAP 12.21 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.2.c.1 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] Engineer Review N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 Page 7 II.B.2.c.2 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] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] II.B.2.c.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons) [R307-401-8] II.B.3 Stack Testing Requirements II.B.3.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.3.a.1 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.3.a.2 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] II.B.3.a.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] Engineer Review N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 Page 8 II.B.3.a.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.3.a.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.3.a.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.3.b 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.3.b.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] Engineer Review N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 Page 9 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN104520006-24 dated January 18, 2024 Is Derived From Compliance Notification dated January 22, 2024 Incorporates Additional Information dated September 13, 2024 REVIEWER COMMENTS 1. Comment regarding 10-year Review: This administrative amendment is to incorporate corrections to the approval order. The previous approval order was not reviewed by compliance prior to issuance. This approval order incorporates the following changes based on comments from compliance: Equipment items II.A.3 and II.A.4 were removed and replaced with baghouses that vent internally. Condition II.B.4.a was also removed as it is not applicable due to the baghouses venting internally. Notification for these replacements were acknowledged in DAQE-948-97 and DAQE-494-01, and the equipment list was updated according to these letters. Finally, condition II.B.1.e of the previous AO was removed as there was not operating any instruments that needed calibration. Therefore, this condition was unnecessary for the approval order as it was not enforcing any emission limitation or method for reducing emissions. Currently, the approval order requires stack testing for the paint booths on site. This limit is likely not necessary for the paint booth operation at the facility, and it is recommended this limit be removed in future modifications. It is not being removed in this administrative amendment as that would relax a limit on the source without a BACT review. [Last updated August 21, 2024] 2. Comment regarding NSPS and MACT Review: The facility does not have equipment or operations that relate to any Subpart listed in 40 CFR 60 (NSPS). 40 CFR 63 (MACT) Subpart JJ applies to manufacturers of wood furniture or wood furniture components and that is located at a plant site that is a major source. The facility is not a major source for HAPs, and meets the exemption criteria listed in 40 CFR 63.800 paragraphs (b)(1),(b)(2), and (b)(3). Therefore, this subpart is not applicable to this facility. 40 CFR 63 (MACT) Subpart HHHHHH applies to area sources of HAPs that perform spray application of coating to motor vehicles and mobile equipment, or coatings containing the HAPs targeted by the subpart applied to plastic and/or metal substrate on a part or product. This facility does not perform spray applications to motor vehicles or mobile equipment, and only applies coatings to wood furniture products. Therefore, this subpart is not applicable to this facility. [Last updated August 13, 2024] Engineer Review N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 Page 10 3. 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. 4. Any Title IV affected source. This source is not a major source, or a Title IV affected source. The facility is not subject to 40 CFR 60 (NSPS), 40 CFR 61 (NESHAP) or 40 CFR 63 (MACT) regulations. There are no other reasons why this source would be required to obtain a Title V permit; therefore, Title V does not apply to this facility as per R307-415-4(2)(c). [Last updated August 13, 2024] Engineer Review N104520007: Cottonwood Mill & Cabinet - Cabinet Manufacturing Facility September 20, 2024 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 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 Dylan Frederick <dfrederick@utah.gov> Fwd: DAQE 6 messages Chad Gilgen <cgilgen@utah.gov>Mon, Jan 22, 2024 at 9:42 AM To: Alan Humpherys <ahumpherys@utah.gov>, Dylan Frederick <dfrederick@utah.gov> Hi Alan and Dylan, I received notification of this final 10-year review being finalized. This one was not sent to me for a compliance review or I would have provided a few comments. I inspected the source in 2017 and 2022 and observed both of the baghouses have been permanently removed and replaced with a system that vents internally. This information was further confirmed during their 2023 inspection. Here is the evaluation from my 2022 memo for what is now listed as II.A.3 and II.A.4. C. - 1 custom baghouse rated at 9,000 ACFM and D. - 1 custom baghouse rated at 15,700 ACFM have both been replaced per two letters (DAQE-948-97 and DAQE-494-01) which can be found in the source file. Both replacement baghouses vent internally. AO condition II.B.4.a is also not applicable since these baghouses vent internally. Section II.B.2 and conditions II.B.3.a through II.B.3.a.2 which, as currently written, are going to now require stack testing every five years. This section should have been removed from this updated AO. These are standard paint booths. Here is the evaluation from my 2022 memo: The source operates five, three-sided paint booths in one enclosed room with positive air across from the paint booths and negative air being pulled through the filter banks. Each paint booth was observed with paint arrestor particulate filters. The source indicated the filters are checked regularly and changed out as needed. Also, their 2020 emissions inventory put all of their actual emissions below 5 TPY. Another item of review is AO condition II.B.1.e. From what I remember, this source doesn't operate any instruments that need to be calibrated. The only thing I can think of that this would apply to would be something like a Dwyer inclined manometer which are sometimes associated with paint booth filter banks but are pretty much just used to let the source know when it's time to change the particulate filters. I also don't recall if they had anything like this installed on their paint booths. For reference, I have attached the 2022 and 2023 memos. Thanks and let me know what we need to do to get this AO updated to reflect current source operations. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. ---------- Forwarded message --------- From: Jeree Greenwood <jereeg@utah.gov> Date: Thu, Jan 18, 2024 at 3:29 PM 8/13/24, 12:35 PM State of Utah Mail - Fwd: DAQE https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1788809640076084800&simpl=msg-f:178880964007608480…1/4 Subject: DAQE To: Chad Gilgen <cgilgen@utah.gov> Cc: David Beatty <dbeatty@utah.gov> Attached please find your copy of DAQE-AN104520006-24, notice for Cottonwood Mill & Cabinet. Thanks, Jeree -- Jeree Greenwood Office Technician II | Minor NSR Section M: (385) 306-6514 airquality.utah.gov 3 attachments DAQE-AN104520006-24.pdf 316K DAQC-652-22.pdf 2425K C-330-23.pdf 1537K Alan Humpherys <ahumpherys@utah.gov>Mon, Jan 22, 2024 at 10:16 AM To: Chad Gilgen <cgilgen@utah.gov> Cc: Dylan Frederick <dfrederick@utah.gov> Chad, I'm sorry that you were not included in this review. I'll talk to my staff to make sure they include you in their reviews. As far as this source goes, I'll have Dylan reach out to the source with your concerns. If the source qualifies as a SSE, they may elect to go that route. We'll keep you posted. Thanks, Alan [Quoted text hidden] 8/13/24, 12:35 PM State of Utah Mail - Fwd: DAQE https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1788809640076084800&simpl=msg-f:178880964007608480…2/4 -- Alan Humpherys Manager | Minor NSR Section P: (385) 306-6520 F: (801) 536-4099 airquality.utah.gov [Quoted text hidden] Alan Humpherys <ahumpherys@utah.gov>Mon, Jan 22, 2024 at 10:17 AM To: Dylan Frederick <dfrederick@utah.gov> Dylan, Please reach out to the source and see how they would like to proceed regarding Chad's comments. If the source wants to make updates, we can conduct another 10-year review. Thanks, Alan [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Mon, Jan 22, 2024 at 2:12 PM To: Alan Humpherys <ahumpherys@utah.gov> Cc: Dylan Frederick <dfrederick@utah.gov> Hi Alan, That sounds great. Thanks for letting me know. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. On Mon, Jan 22, 2024 at 10:16 AM Alan Humpherys <ahumpherys@utah.gov> wrote: [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Tue, Jan 23, 2024 at 9:23 AM To: Chad Gilgen <cgilgen@utah.gov> Cc: Alan Humpherys <ahumpherys@utah.gov> Hey Chad, Apologies for not getting this review out to you. I've reached out to the source to ask about fixing some of the issues you mentioned. [Quoted text hidden] 8/13/24, 12:35 PM State of Utah Mail - Fwd: DAQE https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1788809640076084800&simpl=msg-f:178880964007608480…3/4 -- Dylan Frederick Environmental Engineer | Minor NSR Section P: (385) 306-6529 airquality.utah.gov [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Wed, Jan 24, 2024 at 12:06 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Alan Humpherys <ahumpherys@utah.gov> Hi Dylan, Thanks for the update. I appreciate it. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 8/13/24, 12:35 PM State of Utah Mail - Fwd: DAQE https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1788809640076084800&simpl=msg-f:178880964007608480…4/4 Dylan Frederick <dfrederick@utah.gov> Air Quality Permit Update Cottonwood Mill and Cabinet 8 messages Dylan Frederick <dfrederick@utah.gov>Fri, Sep 6, 2024 at 11:32 AM To: Kari Kovar <kari.kovar@cottonwoodcabinets.com>, David Whittenburg <dwhittenburg@cottonwoodcabinets.com> Good Afternoon, At the beginning of the year we updated the approval order Cottonwood Mill and Cabinet has with the division of air quality. Our compliance team requested some updates be made after reviewing the AO. I've started fixing the AO and I'm almost done with the updates, but I wanted to ask for confirmation that the two baghouses that were in the previous AO can be removed. Currently, I only have a spray booth room, a baghouse rated 35,000 cfm and a second baghouse, both of which vent internally in the equipment list. Are we ok to proceed with that change to the equipment list? -- Dylan Frederick Environmental Engineer | Minor NSR Section P: (385) 306-6529 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Kari Kovar <kari.kovar@cottonwoodcabinets.com>Mon, Sep 9, 2024 at 1:33 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Dylan   Can we please chat quickly with you to make sure that we are understanding the request + implications?    Since your original email, Dave has retired. Dan Rees, SVP Operations, has replaced him. I’ve included him on this email so that we can ensure we are all on the same page + answering your question(s) correctly.   Can you please resend the original report along with your email so that we can refamiliarize ourselves with the document? Also, please suggest a few dates/times that work for you to chat.  I’m hopeful this is a 15 minute conversation.   Thanks 9/13/24, 5:04 PM State of Utah Mail - Air Quality Permit Update Cottonwood Mill and Cabinet https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-6092263493187025447&simpl=msg-a:r-21189070011691…1/5 Kari   KARI KOVAR | President + CEO 319.538.5389 12757 S. Minuteman Dr., Draper, UT 84020 www.cottonwoodcabinets.com From: Dylan Frederick <dfrederick@utah.gov> Date: Friday, September 6, 2024 at 11:32 AM To: Kari Kovar <kari.kovar@cottonwoodcabinets.com>, David Whittenburg - Converted to Shared (20240705) <david.whittenburg@cottonwoodcabinets.com> Subject: Air Quality Permit Update Cottonwood Mill and Cabinet Good Afternoon, At the beginning of the year we updated the approval order Cottonwood Mill and Cabinet has with the division of air quality. Our compliance team requested some updates be made after reviewing the AO. I've started fixing the AO and I'm almost done with the updates, but I wanted to ask for confirmation that the two baghouses that were in the previous AO can be removed. Currently, I only have a spray booth room, a baghouse rated 35,000 cfm and a second baghouse, both of which vent internally in the equipment list. Are we ok to proceed with that change to the equipment list? -- Image removed by sender. Division Name Dylan Frederick Environmental Engineer | Minor NSR Section P: (385) 306-6529 airquality.utah.gov Image remov ed by sender. Image remov ed by sender. [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Mon, Sep 9, 2024 at 2:49 PM 9/13/24, 5:04 PM State of Utah Mail - Air Quality Permit Update Cottonwood Mill and Cabinet https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-6092263493187025447&simpl=msg-a:r-21189070011691…2/5 To: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Kari and Dan, I should be available for a call the rest of today, anytime tomorrow except for 10 AM, and Wednesday 10AM - 11 AM and 12PM onwards. [Quoted text hidden] -- Dylan Frederick Environmental Engineer | Minor NSR Section P: (385) 306-6529 airquality.utah.gov [Quoted text hidden] Kari Kovar <kari.kovar@cottonwoodcabinets.com>Tue, Sep 10, 2024 at 9:33 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Dylan I just set up a Team’s meeng for tomorrow aernoon at 2:45 p.m. I’m hoping that this works for you. If not, please suggest a new me. Thank you! Kari KARI KOVAR | President + CEO 319.538.5389 12757 S. Minuteman Dr., Draper, UT 84020 www.cottonwoodcabinets.com [Quoted text hidden] 9/13/24, 5:04 PM State of Utah Mail - Air Quality Permit Update Cottonwood Mill and Cabinet https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-6092263493187025447&simpl=msg-a:r-21189070011691…3/5 [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] Good Afternoon, [Quoted text hidden] Error! Filename not specified.Dylan Frederick Environmental Engineer | Minor NSR Section P: (385) 306-6529 airquality.utah.gov Error! Filename not specified. Error! Filename not specified. Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Wed, Sep 11, 2024 at 8:42 AM To: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Kari, I'll see you at 2:45.Thanks for setting the meeting up [Quoted text hidden] -- Dylan Frederick Environmental Engineer | Minor NSR Section P: (385) 306-6529 airquality.utah.gov [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Wed, Sep 11, 2024 at 2:54 PM 9/13/24, 5:04 PM State of Utah Mail - Air Quality Permit Update Cottonwood Mill and Cabinet https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-6092263493187025447&simpl=msg-a:r-21189070011691…4/5 To: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Kari and Dan, Here is the unofficial draft of the permit. I just need confirmation that the change to the equipment list is correct and acceptable on your end. Thanks for your help! [Quoted text hidden] RN104520007-24.rtf 1509K Dylan Frederick <dfrederick@utah.gov>Fri, Sep 13, 2024 at 4:34 PM To: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Hey all, Have you had a chance to look at the change to the equipment list yet? [Quoted text hidden] Dan Rees <dan.rees@cottonwoodcabinets.com>Fri, Sep 13, 2024 at 5:02 PM To: Dylan Frederick <dfrederick@utah.gov>, Kari Kovar <kari.kovar@cottonwoodcabinets.com> Hi Dylan, Everything looks good. Thank you! DAN REES | Senior Vice President of Operations 801.462.3144 12757 S. Minuteman Dr., Draper, UT 84020 www.cottonwoodcabinets.com From: Dylan Frederick <dfrederick@utah.gov> Sent: Friday, September 13, 2024 4:34:48 PM [Quoted text hidden] [Quoted text hidden] 9/13/24, 5:04 PM State of Utah Mail - Air Quality Permit Update Cottonwood Mill and Cabinet https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-6092263493187025447&simpl=msg-a:r-21189070011691…5/5 -- Dylan Frederick Environmental Engineer | Minor NSR Section P: (385) 306-6529 airquality.utah.gov [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Wed, Sep 11, 2024 at 2:54 PM To: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Kari and Dan, Here is the unofficial draft of the permit. I just need confirmation that the change to the equipment list is correct and acceptable on your end. Thanks for your help! [Quoted text hidden] RN104520007-24.rtf 1509K Dylan Frederick <dfrederick@utah.gov>Fri, Sep 13, 2024 at 4:34 PM To: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Hey all, Have you had a chance to look at the change to the equipment list yet? [Quoted text hidden] Dan Rees <dan.rees@cottonwoodcabinets.com>Fri, Sep 13, 2024 at 5:02 PM To: Dylan Frederick <dfrederick@utah.gov>, Kari Kovar <kari.kovar@cottonwoodcabinets.com> Hi Dylan, Everything looks good. Thank you! 10/8/24, 4:06 PM State of Utah Mail - Air Quality Permit Update Cottonwood Mill and Cabinet https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-6092263493187025447&simpl=msg-a:r-2118907001169128305&simpl=msg-f:1809748252702455506&simpl…6/9 DAN REES | Senior Vice President of Operations 801.462.3144 12757 S. Minuteman Dr., Draper, UT 84020 www.cottonwoodcabinets.com From: Dylan Frederick <dfrederick@utah.gov> Sent: Friday, September 13, 2024 4:34:48 PM [Quoted text hidden] [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Mon, Sep 23, 2024 at 1:08 PM To: Dan Rees <dan.rees@cottonwoodcabinets.com> Cc: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Hey all, I have the final approval order ready for your review. Please take a look at this and if everything looks good please return the cover page with a signature on it, thank you! [Quoted text hidden] RN104520007-24.rtf 1514K Dylan Frederick <dfrederick@utah.gov>Wed, Oct 2, 2024 at 9:58 AM To: Dan Rees <dan.rees@cottonwoodcabinets.com> Cc: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Hey all, Have you had a chance to review the draft? [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Tue, Oct 8, 2024 at 3:47 PM To: Dan Rees <dan.rees@cottonwoodcabinets.com> Cc: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Good afternoon, 10/8/24, 4:06 PM State of Utah Mail - Air Quality Permit Update Cottonwood Mill and Cabinet https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-6092263493187025447&simpl=msg-a:r-2118907001169128305&simpl=msg-f:1809748252702455506&simpl…7/9 I just wanted to check in one last time and see if you can get a signature to me for the updated Approval Order I sent on the 23rd. I will need to move on without your signature if I don't get your review back soon and issue the permit. [Quoted text hidden] Kari Kovar <kari.kovar@cottonwoodcabinets.com>Tue, Oct 8, 2024 at 3:58 PM To: Dylan Frederick <dfrederick@utah.gov> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Dylan, Please consider this as our approval. Let us know if you need anything else from me. Thank you! Kari KARI KOVAR | President + CEO 319.538.5389 12757 S. Minuteman Dr., Draper, UT 84020 www.cottonwoodcabinets.com [Quoted text hidden] Dylan Frederick <dfrederick@utah.gov>Tue, Oct 8, 2024 at 4:03 PM To: Kari Kovar <kari.kovar@cottonwoodcabinets.com> Cc: Dan Rees <dan.rees@cottonwoodcabinets.com> Kari, Thank you, I'll have the updated permit sent forward for final approval. Dylan 10/8/24, 4:06 PM State of Utah Mail - Air Quality Permit Update Cottonwood Mill and Cabinet https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-6092263493187025447&simpl=msg-a:r-2118907001169128305&simpl=msg-f:1809748252702455506&simpl…8/9