DAQ-2025-000004

DAQE-AN159980004-24

{{$d1 }}

Matthew Hyita
Wildcat Sand, LLC
6000 Western Place, Suite 1000
Fort Worth, TX 76107
[e-mail]

Dear Mr. Hyita:

Re: Approval Order: Minor Modification to Approval Order DAQE-AN159980003-21 Increase Sand
Production and Install New Equipment
Project Number: N159980004

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on June 30,
2023. Wildcat Sand, LLC 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 [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as
the DAQE number shown on the upper right-hand corner of this letter. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:DF:jg

cc: TriCounty 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

December 23, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN159980004-24
Minor Modification to Approval Order DAQE-AN159980003-21
Increase Sand Production and Install
New Equipment

Prepared By
Dylan Frederick, Engineer
[phone]
[e-mail]

Issued to
Wildcat Sand, LLC - Uintah County Sand Processing Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

December 23, 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 ................................................................................................................... 13
ACRONYMS ............................................................................................................................... 14

DAQE-AN159980004-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Wildcat Sand, LLC Wildcat Sand, LLC - Uintah County Sand Processing Plant

Mailing Address Physical Address
6000 Western Place, Suite 1000 Section17 T3S R1E
Fort Worth, TX 76107 Uintah County, UT

Source Contact UTM Coordinates
Name: Matthew Hyita 593,455 m Easting
Phone: [phone],453,216 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 1499 (Miscellaneous Nonmetallic Minerals, Except Fuels)

SOURCE INFORMATION
General Description
Wildcat Sand, LLC operates a sand processing facility in the Uinta Basin. The facility receives sandstone
that is crushed and processed in a wet plant to remove fine particulates before finally being sent through a
drying and separation process. The final sand product is sized to customer specifications and shipped
offsite. The plant is designed to process up to 2,628,000 tons of sand per year.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Uinta Basin O3 NAA
Uintah County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
NSPS (Part 60), UUU: Standards of Performance for Calciners and Dryers in Mineral
Industries
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
DAQE-AN159980004-24
Page 4

Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Description
Wildcat Sand, LLC has requested the following modifications:

1. Install a new 38 MMBtu/hr natural gas-fired dryer.
2. Increase production for the existing sand dryer and new dryer to 2,628,000 tons per rolling 12-month
period.

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 28535 42053.00
Carbon Monoxide 60.20 80.28
Nitrogen Oxides 24.32 41.16
Particulate Matter - PM10 29.46 42.05
Particulate Matter - PM2.5 24.49 25.35
Sulfur Dioxide -0.55 0.11
Volatile Organic Compounds 18.12 21.16

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 212
Acrolein (CAS #107028) 131
Formaldehyde (CAS #50000) 1085 1395
Generic HAPs (CAS #GHAPS) 0 117
Hexane (CAS #110543) 806 1199
Methanol (CAS #67561) 64
Change (TPY) Total (TPY)
Total HAPs 1.15 1.56

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]
DAQE-AN159980004-24
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 Sand Processing Facility
II.A.2 Wet Sand Processing Plant *informational purposes only II.A.3 Three (3) Wash Screens Size: 8' X 12' NSPS Applicability: Subpart OOO
II.A.4 Dry Sand Processing Plant II.A.5 Sand Dryer #1 Rating: 40.9 MMBtu/hr Fuel: Natural Gas Control: Baghouse NSPS Applicability: Subpart UUU Rotary Sand Dryer Air Flow Rate: 20,955 acfm
DAQE-AN159980004-24
Page 6

II.A.6 Sand Dryer #2 Rating: 38.0 MMBtu/hr Fuel: Natural Gas Control: Baghouse NSPS Applicability: Subpart UUU Fluid Bed Dryer Air Flow Rate: 50,000 acfm
II.A.7 Three (3) Baghouses Baghouse 1 Controls: Sand Dryer #1
Baghouse is in sequence with cyclone Baghouse 2
Controls: Vibrating Dry Processing Screens
Baghouse 3
Controls: Sand Dryer #2 Baghouse is in sequence with cyclone

II.A.8 Two (2) Cyclones Controls: Sand Dryers Each cyclone is in sequence with a baghouse
II.A.9 Three (3) Vibrating Dry Processing Screens Size: 6' x 25'
Controls: Baghouse
NSPS Applicability: Subpart OOO
II.A.10 One (1) Quad Roll Crusher Rating: 275 tph NSPS Applicability: Subpart OOO
II.A.11 Various Material Handling Equipment
Material Loading, Conveyors, Drop Points NSPS Applicability: Subpart OOO

II.A.12 Three (3) Sand Storage Silos Controls: Bin Vent Filters Stores finished sand product for transport offsite
II.A.13 One (1) Generator Rating: 415 hp
Fuel: Natural Gas
NSPS Applicability: Subpart JJJJ
MACT Applicability: Subpart ZZZZ

II.A.14 One (1) Storage Tank Contents: Fuel Oil Capacity: 5,000 gallons

DAQE-AN159980004-24
Page 7

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not process more than 2,628,000 tons of sand per rolling 12-month
period. [R307-401-8]

II.B.1.a.1 The owner/operator shall: A. Determine the amount of sand processed with purchasing receipts B. Record the amount of sand processed on a daily basis when the plant is in operation C. Use the processing data to calculate a new 12-month total by the last day of each month using data from the previous 12 months D. Keep the purchasing records for all periods the plant is in operation. [R307-401-8]
II.B.1.b The owner/operator shall not allow visible emissions to exceed the following limits:

A. All screens - 7% opacity

B. All crushers - 12% opacity

C. All conveyor transfer points - 7% opacity

D. The dry processing screens baghouse exhaust stack - 7% opacity

E. The dryer baghouse exhaust stacks - 10% opacity

F. The engine exhaust stack - 10% opacity

G. All other points - 20% opacity.

[40 CFR 60 Subpart OOO, 40 CFR 60 Subpart UUU, R307-201-3, R307-401-8]

II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3]
II.B.2 Stack Testing Requirements
II.B.2.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]
II.B.2.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.2.a.2 Testing The owner/operator shall conduct testing according to the approved source test protocol. The Director may reject stack testing results if the test did not follow the approved source test protocol. [R307-401-8]
DAQE-AN159980004-24
Page 8

II.B.2.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.2.a.4 Test Conditions The owner/operator shall conduct all stack testing according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.2.a.5 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. [R307-401-8] II.B.2.a.6 Possible Rejection of Test Results
The Director may reject stack testing results according to R307-165-6. [R307-165-6]
II.B.2.b Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
II.B.2.b.1 Standard Conditions
A. Temperature - 68 degrees Fahrenheit (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method.
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.2.b.2 PM 40 CFR 60, Appendix A, Method 5, or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.2.b.3 Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10. [R307-401-8]

II.B.2.b.4 Filterable PM2.5 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A, or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM2.5. [R307-401-8]
II.B.2.b.5 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]

II.B.2.b.6 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]
DAQE-AN159980004-24
Page 9

II.B.2.b.7 CO 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.3 Sand Processing Equipment Requirements
II.B.3.a The owner/operator shall install enclosures on the vibrating dry processing screens and control emissions with a baghouse. [R307-401-8] II.B.3.b The owner/operator shall install a baghouse with a certified emission rate of 0.01 gr PM10/dscf
and 0.01 gr PM/dscf or less to control the vibrating dry processing screens. [R307-401-8]
II.B.3.b.1 The owner/operator shall keep manufacturer records certifying this emission rate for the lifetime of the equipment. [R307-401-8] II.B.3.c The owner/operator shall install and operate enclosures and water sprays on the conveyors and
conveyor drop points transporting material prior to entering the wet sand processing plant to
maintain the opacity limits in this AO. The owner/operator shall install enclosures on all conveyors and conveyor drop points transporting unsaturated material to maintain the opacity
limits in this AO. [R307-205-4, R307-401-8]

II.B.3.d The owner/operator shall install and operate water sprays to maintain the opacity limits in this AO for the crusher and all storage piles on site. [R307-205-4, R307-401-8]
II.B.3.e The owner/operator shall operate the wet processing plant in such a way that ensures no visible emissions are generated. [R307-401-8]

II.B.4 NSPS Subpart OOO Requirements
II.B.4.a The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site. Performance tests shall meet the limitations specified in Tables
2 and 3 to Subpart OOO. [40 CFR 60 Subpart OOO]

II.B.4.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR 60.675(c). The owner or operator may use methods and procedures specified in 40 CFR 60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c). [40 CFR 60 Subpart OOO]
II.B.4.a.2 The owner/operator shall keep and maintain records of the initial performance test for each
crusher, screen, and conveyor for the life of the equipment. The record of the initial performance test must be made available to the Director or the Director's representative upon request.
[40 CFR 60 Subpart OOO, R307-401-8]

II.B.4.b The owner/operator shall perform monthly periodic inspections to check that water is flowing to water sprays associated with each crusher, screen, and conveyor. If the owner/operator finds that water is not flowing properly during an inspection of the water sprays, the owner/operator shall initiate corrective action within 24 hours and complete corrective action as expediently as practical. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.4.b.1 Records of the water spray inspections shall be maintained in a logbook for all periods when the
plant is in operation. The records shall include the following items:

A. Date the inspections were made

B. Any corrective actions taken

C. Control mechanism used if sprays are not operating.

[40 CFR 60 Subpart OOO, R307-401-8]

DAQE-AN159980004-24
Page 10

II.B.5 Sand Drying Operation Requirements II.B.5.a The owner/operator shall install and operate a baghouse and cyclone system to control particulate
emissions from each sand dryer on site. [R307-401-8]
II.B.5.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The static pressure differential across each baghouse shall be between 2 and 6 inches of water column. [R307-401-8] II.B.5.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. The pressure gauge shall measure the pressure drop in 0.5-inch water column increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. [R307-401-8]

II.B.5.b.2 The owner/operator shall record the reading of the pressure gauge at least once per operating day. [R307-401-8]
II.B.5.c The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s):

***Dryer #1 Baghouse Exhaust Stack***
Pollutant lb/hr grains/dscf ppmv
PM 1.07 0.01
Filterable PM10 1.07 0.01
Filterable PM2.5 1.07 0.01 NOx 4.78 96
CO 5.70 500
***Dryer #2 Baghouse Exhaust Stack***

Pollutant lb/hr grains/dscf ppmv
PM 2.99 0.01
Filterable PM10 2.99 0.01 Filterable PM2.5 2.99 0.01
NOx 3.70 80
CO 10.8 450
[R307-401-8]

II.B.5.c.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. [R307-165-2, R307-401-8]
II.B.5.c.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]

II.B.5.c.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

DAQE-AN159980004-24
Page 11

II.B.6 Stationary Generator Engine Requirements II.B.6.a The owner/operator shall not emit more than the following rates and concentrations from the
indicated emissions unit(s): ***415 hp Generator Exhaust Stack***
Pollutant lb/hr ppmv
NOx 0.92 160 CO 1.8 540 VOC 0.34 86
[R307-401-8]
II.B.6.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. [R307-165-2, R307-401-8] II.B.6.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]
II.B.6.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit at least once every 8,760 hours of use or at least within three (3) years after the date of the most recent stack test of the emission unit, whichever comes first. The Director may require the owner/operator to perform a stack test at any time. [40 CFR 60 Subpart JJJJ, R307-401-8] II.B.7 Haul Roads and Fugitive Dust Requirements
II.B.7.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% at the property boundary. [R307-401-8] II.B.7.a.1 Visible emission determinations for fugitive dust from haul roads and operational areas shall use
procedures similar to Method 9. The normal requirement for observations to be made at
15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle length
behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8]

II.B.7.b The owner/operator shall pave the haul road exiting the facility. The paved section of the haul road shall be no less than 1,151 feet in length. [R307-401-8]
II.B.7.b.1 The paved road length shall be determined through source records or GPS measurements. [R307-401-8]

II.B.7.c An operational vacuum sweeper and water truck shall be made available during each operating day. The owner/operator shall sweep and flush with water all the paved haul roads on site to maintain the opacity limits listed in this AO. If the temperature is below freezing, the owner/operator shall continue to vacuum sweep the road but may stop flushing the paved haul roads with water. Flushing the paved haul road with water shall resume when the temperature is above freezing. If the haul roads are covered with snow or ice, the owner/operator may stop sweeping the paved haul roads. Sweeping the paved haul roads shall resume when the haul roads are cleared from snow and ice. [R307-401-8]
DAQE-AN159980004-24
Page 12

II.B.7.c.1 Records of vacuum sweeping and water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature is below freezing E. Records shall note if the paved haul roads are covered with snow or ice. [R307-401-8] II.B.7.d The owner/operator shall use chemical suppressants such as magnesium chloride and regular
water applications on all unpaved loader routes and wheeled vehicle operational areas to
maintain the opacity limits listed in this AO. [R307-401-8]
II.B.7.e The owner/operator shall use water application or other control options contained in R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust to minimize emissions from fugitive emission sources, including storage piles and disturbed areas, to maintain the opacity limits listed in this AO. [R307-205, R307-401-8]
II.B.7.e.1 Records of water application shall be kept for all periods when the plant is in operation. The records shall include the following items:

A. Date and time water was applied
B. Quantity of water applied
C. Rainfall amount received, if any

D. Records of temperature, if the temperature is below freezing.
[R307-401-8]

II.B.7.f The owner/operator shall not exceed 9 acres of all disturbed area combined. [R307-401-8]
II.B.7.f.1 To determine compliance with the total disturbed areas, the owner/operator shall measure the
total disturbed area at least once every 12 months and shall maintain a record of the total disturbed acres. To determine the disturbed acres on site, the owner/operator shall use aerial
drone survey of each disturbed area on site to calculate each disturbed area on site. Records of
the total disturbed areas shall contain the following:
A. Date of measurements

B. Size of each disturbed area on site

C. Total acres of all disturbed areas combined.

[R307-401-8]

II.B.7.g The owner/operator shall not exceed 7 acres of area for the storage piles combined, with no more than 6 acres outside of enclosures or buildings. [R307-401-8]
DAQE-AN159980004-24
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II.B.7.g.1 To determine compliance with the total storage piles the owner/operator shall measure the total storage pile area at least once every 12 months and shall maintain a record of the total storage pile acres. To determine the storage pile acres on site, the owner/operator shall use aerial drone survey of each storage pile area on site to calculate each storage pile area on site. Records of the total storage pile areas shall contain the following: A. Date of measurements B. Size of each storage pile on site C. Total acres of all storage piles combined. [R307-401-8]
II.B.8 Storage Tank Requirements
II.B.8.a The owner/operator shall install the fuel oil storage tank with submerged fill pipes. The owner/operator shall operate the storage tank in a way that minimizes working and breathing losses from the tank. [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN159980003-21 dated August 11, 2021 Is Derived From NOI dated June 30, 2023 Incorporates Additional Information dated August 24, 2023 Incorporates Additional Information dated October 31, 2023 Incorporates Additional Information dated December 1, 2023 Incorporates Additional Information dated December 4, 2023 Incorporates Additional Information dated March 12, 2024 Incorporates Additional Information dated March 21, 2024 Incorporates Additional Information dated April 22, 2024 Incorporates Additional Information dated May 17, 2024 Incorporates Additional Information dated May 24, 2024 Incorporates Additional Information dated July 15, 2024 Incorporates Additional Information dated August 2, 2024 Incorporates Additional Information dated September 25, 2024 Incorporates Additional Information dated October 17, 2024 Incorporates Additional Information dated October 23, 2024

DAQE-AN159980004-24
Page 14

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-IN159980004-24

November 7, 2024

Matthew Hyita
Wildcat Sand, LLC
6000 Western Place, Suite 1000
Fort Worth, TX 76107
[e-mail]

Dear Mr. Hyita:

Re: Intent to Approve: Minor Modification to Approval Order DAQE-AN159980003-21 Increase
Sand Production and Install New Equipment
Project Number: N159980004

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

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

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DF:jg

cc: TriCounty Health Department

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN159980004-24
Minor Modification to Approval Order DAQE-AN159980003-21
Increase Sand Production and Install New Equipment

Prepared By
Dylan Frederick, Engineer
[phone]
[e-mail]

Issued to
Wildcat Sand, LLC - Uintah County Sand Processing Plant

Issued On
November 7, 2024

{{$s }}

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

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 14
ACRONYMS ............................................................................................................................... 15

DAQE-IN159980004-24
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GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Wildcat Sand, LLC Wildcat Sand, LLC - Uintah County Sand Processing Plant

Mailing Address Physical Address
6000 Western Place, Suite 1000 Section17 T3S R1E
Fort Worth, TX 76107 Uintah County, UT

Source Contact UTM Coordinates
Name: Matthew Hyita 593,455 m Easting
Phone: [phone],453,216 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 1499 (Miscellaneous Nonmetallic Minerals, Except Fuels)

SOURCE INFORMATION
General Description
Wildcat Sand, LLC operates a sand processing facility in the Uinta Basin. The facility receives sandstone
that is crushed and processed in a wet plant to remove fine particulates before finally being sent through a
drying and separation process. The final sand product is sized to customer specifications and shipped off-
site. The plant is designed to process up to 2,628,000 tons of sand per year.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Uinta Basin O3 NAA
Uintah County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
NSPS (Part 60), UUU: Standards of Performance for Calciners and Dryers in Mineral
Industries
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
DAQE-IN159980004-24
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Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Description
Wildcat Sand, LLC has requested the following modifications:

1. Install a new 38 MMBtu/hr natural gas-fired dryer.
2. Increase production for the existing sand dryer and new dryer to 2,628,000 tons per rolling 12-month
period.

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 28535 42053.00
Carbon Monoxide 60.20 80.28
Nitrogen Oxides 24.32 41.16
Particulate Matter - PM10 29.46 42.05
Particulate Matter - PM2.5 24.49 25.35
Sulfur Dioxide -0.55 0.11
Volatile Organic Compounds 18.12 21.16

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 212
Acrolein (CAS #107028) 131
Formaldehyde (CAS #50000) 1085 1395
Generic HAPs (CAS #GHAPS) 0 117
Hexane (CAS #110543) 806 1199
Methanol (CAS #67561) 64
Change (TPY) Total (TPY)
Total HAPs 1.15 1.56

PUBLIC NOTICE STATEMENT

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

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Uintah Basin Standard on November 13, 2024. During the
public comment period the proposal and the evaluation of its impact on air quality will be available for
the public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as
practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.
DAQE-IN159980004-24
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SECTION I: GENERAL PROVISIONS

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

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

DAQE-IN159980004-24
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SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT II.A.1 Sand Processing Facility
II.A.2 Wet Sand Processing Plant *informational purposes only II.A.3 Three (3) Wash Screens Size: 8' X 12' NSPS Applicability: Subpart OOO
II.A.4 Dry Sand Processing Plant II.A.5 Sand Dryer #1 Rating: 40.9 MMBtu/hr Fuel: Natural Gas Control: Baghouse NSPS Applicability: Subpart UUU Rotary Sand Dryer Air Flow Rate: 20,955 acfm
II.A.6 Sand Dryer #2 Rating: 38.0 MMBtu/hr Fuel: Natural Gas Control: Baghouse NSPS Applicability: Subpart UUU Fluid Bed Dryer Air Flow Rate: 50,000 acfm II.A.7 Three (3) Baghouses Baghouse 1 Controls: Sand Dryer #1 Baghouse is in sequence with cyclone Baghouse 2 Controls: Vibrating Dry Processing Screens Baghouse 3 Controls: Sand Dryer #2 Baghouse is in sequence with cyclone
II.A.8 Two (2) Cyclones Controls: Sand Dryers Each cyclone is in sequence with a baghouse II.A.9 Three (3) Vibrating Dry Processing Screens Size: 6' X 25' Controls: Baghouse NSPS Applicability: Subpart OOO
DAQE-IN159980004-24
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II.A.10 One (1) Quad Roll Crusher Rating: 275 tph NSPS Applicability: Subpart OOO II.A.11 Various Material Handling Equipment
Material Loading, Conveyors, Drop Points NSPS Applicability: Subpart OOO
II.A.12 Three (3) Sand Storage Silos Controls: Bin Vent Filters Stores finished sand product for transport offsite
II.A.13 One (1) Generator Rating: 415 hp Fuel: Natural Gas
NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ

II.A.14 One (1) Storage Tank Contents: Fuel Oil Capacity: 5,000 gallons

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not process more than 2,628,000 tons of sand per rolling 12-month period. [R307-401-8]
II.B.1.a.1 The owner/operator shall: A. Determine the amount of sand processed with purchasing receipts. B. Record the amount of sand processed on a daily basis when the plant is in operation. C. Use the processing data to calculate a new 12-month total by the last day of each month using data from the previous 12 months. D. Keep the purchasing records for all periods the plant is in operation. [R307-401-8]
DAQE-IN159980004-24
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II.B.1.b The owner/operator shall not allow visible emissions to exceed the following limits: A. All screens - 7% opacity. B. All crushers - 12% opacity. C. All conveyor transfer points - 7% opacity. D. The dry processing screens baghouse exhaust stack - 7% opacity. E. The dryer baghouse exhaust stacks - 10% opacity. F. The engine exhaust stack - 10% opacity. G. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart UUU, R307-201-3, R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.2 Stack Testing Requirements II.B.2.a The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.2.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.2.a.2 Testing The owner/operator shall conduct testing according to the approved source test protocol. The
Director may reject stack testing results if the test did not follow the approved source test
protocol. [R307-401-8]
II.B.2.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.2.a.4 Test Conditions The owner/operator shall conduct all stack testing according to the test conditions contained in
R307-165-4. [R307-165-4, R307-401-8]

II.B.2.a.5 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. [R307-401-8]
II.B.2.a.6 Possible Rejection of Test Results
The Director may reject stack testing results according to R307-165-6. [R307-165-6]

II.B.2.b Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
DAQE-IN159980004-24
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II.B.2.b.1 Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K). B. Pressure - 29.92 in Hg (101.3 kPa). C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.2.b.2 PM
40 CFR 60, Appendix A, Method 5, or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.2.b.3 Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. [R307-401-8]
II.B.2.b.4 Filterable PM2.5
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are
used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the
filterable particulate emissions shall be considered PM2.5. [R307-401-8]
II.B.2.b.5 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.2.b.6 VOC
40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

II.B.2.b.7 CO 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.3 Sand Processing Equipment Requirements
II.B.3.a The owner/operator shall install enclosures on the vibrating dry processing screens and control emissions with a baghouse. [R307-401-8]
II.B.3.b The owner/operator shall install a baghouse with a certified emission rate of 0.01 gr PM10/dscf and 0.01 gr PM/dscf or less to control the vibrating dry processing screens. [R307-401-8]

II.B.3.b.1 The owner/operator shall keep manufacturer records certifying this emission rate for the lifetime of the equipment. [R307-401-8]
II.B.3.c The owner/operator shall install and operate enclosures and water sprays on the conveyors and
conveyor drop points transporting material prior to entering the wet sand processing plant to
maintain the opacity limits in this AO. The owner/operator shall install enclosures on all
conveyors and conveyor drop points transporting unsaturated material to maintain the opacity
limits in this AO. [R307-205-4, R307-401-8]

II.B.3.d The owner/operator shall install and operate water sprays to maintain the opacity limits in this AO for the crusher and all storage piles on site. [R307-205-4, R307-401-8]
DAQE-IN159980004-24
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II.B.3.e The owner/operator shall operate the wet processing plant in such a way that ensures no visible emissions are generated. [R307-401-8] II.B.4 NSPS Subpart OOO Requirements
II.B.4.a The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site. Performance tests shall meet the limitations specified in Tables 2 and 3 to Subpart OOO. [40 CFR 60 Subpart OOO] II.B.4.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner or operator may use methods and procedures specified in 40 CFR 60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c). [40 CFR 60 Subpart OOO]

II.B.4.a.2 The owner/operator shall keep and maintain records of the initial performance test for each crusher, screen, and conveyor for the life of the equipment. The record of the initial performance test must be made available to the Director or the Director's representative upon request. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.4.b The owner/operator shall perform monthly periodic inspections to check that water is flowing to
water sprays associated with each crusher, screen, and conveyor. If the owner/operator finds that water is not flowing properly during an inspection of the water sprays, the owner/operator shall
initiate corrective action within 24 hours and complete corrective action as expediently as
practical. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.4.b.1 Records of the water spray inspections shall be maintained in a logbook for all periods when the plant is in operation. The records shall include the following items: A. Date the inspections were made. B. Any corrective actions taken. C. Control mechanism used if sprays are not operating. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.5 Sand Drying Operation Requirements
II.B.5.a The owner/operator shall install and operate a baghouse and cyclone system to control particulate emissions from each sand dryer on site. [R307-401-8]
II.B.5.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The static pressure differential across each baghouse
shall be between 2 and 6 inches of water column. [R307-401-8]

II.B.5.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The pressure gauge shall measure the pressure drop in 0.5-inch water column increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. [R307-401-8]
II.B.5.b.2 The owner/operator shall record the reading of the pressure gauge at least once per operating day.
[R307-401-8]

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II.B.5.c The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s): ***Dryer #1 Baghouse Exhaust Stack*** Pollutant lb/hr grains/dscf ppmv PM 1.07 0.01 Filterable PM10 1.07 0.01 Filterable PM2.5 1.07 0.01 NOx 4.78 96 CO 5.70 500 ***Dryer #2 Baghouse Exhaust Stack*** Pollutant lb/hr grains/dscf ppmv PM 2.99 0.01 Filterable PM10 2.99 0.01 Filterable PM2.5 2.99 0.01 NOx 3.70 80 CO 10.8 450 [R307-401-8] II.B.5.c.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. [R307-165-2, R307-401-8]

II.B.5.c.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]
II.B.5.c.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]
II.B.6 Stationary Generator Engine Requirements
II.B.6.a The owner/operator shall not emit more than the following rates and concentrations from the
indicated emissions unit(s):
***415 hp Generator Exhaust Stack***

Pollutant lb/hr ppmv

NOx 0.92 160
CO 1.8 540
VOC 0.34 86

[R307-401-8]

DAQE-IN159980004-24
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II.B.6.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. [R307-165-2, R307-401-8]
II.B.6.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]

II.B.6.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit at least once every 8,760 hours of use or at least within three (3) years after the date of the most recent stack test of the emission unit, whichever comes first. The Director may require the owner/operator to perform a stack test at any time. [40 CFR 60 Subpart JJJJ, R307-401-8]
II.B.7 Haul Roads and Fugitive Dust Requirements
II.B.7.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% at the property boundary. [R307-401-8]
II.B.7.a.1 Visible emission determinations for fugitive dust from haul roads and operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at
15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall
be measured at the densest point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8]

II.B.7.b The owner/operator shall pave the haul road exiting the facility. The paved section of the haul road shall be no less than 1,151 feet in length. [R307-401-8]
II.B.7.b.1 The paved road length shall be determined through source records or GPS measurements.
[R307-401-8]
II.B.7.c An operational vacuum sweeper and water truck shall be made available during each operating day. The owner/operator shall sweep and flush with water all the paved haul roads on site to maintain the opacity limits listed in this AO. If the temperature is below freezing, the owner/operator shall continue to vacuum sweep the road but may stop flushing the paved haul roads with water. Flushing the paved haul road with water shall resume when the temperature is above freezing. If the haul roads are covered with snow or ice, the owner/operator may stop sweeping the paved haul roads. Sweeping the paved haul roads shall resume when the haul roads are cleared from snow and ice. [R307-401-8] II.B.7.c.1 Records of vacuum sweeping and water application shall be kept for all periods when the plant is
in operation. The records shall include the following items:
A. Date and time treatments were made.

B. Number of treatments made and quantity of water applied.

C. Rainfall amount received, if any.

D. Records of temperature, if the temperature is below freezing.

E. Records shall note if the paved haul roads are covered with snow or ice.

[R307-401-8]

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II.B.7.d The owner/operator shall use chemical suppressants such as magnesium chloride and regular water applications on all unpaved loader routes and wheeled vehicle operational areas to maintain the opacity limits listed in this AO. [R307-401-8] II.B.7.e The owner/operator shall use water application or other control options contained in R307-205
Emission Standards: Fugitive Emissions and Fugitive Dust, to minimize emissions from fugitive emission sources, including storage piles and disturbed areas to maintain the opacity limits listed in this AO. [R307-205, R307-401-8]

II.B.7.e.1 Records of water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time water was applied. B. Quantity of water applied. C. Rainfall amount received, if any. D. Records of temperature, if the temperature is below freezing. [R307-401-8] II.B.7.f The owner/operator shall not exceed 9 acres of all disturbed area combined. [R307-401-8]

II.B.7.f.1 To determine compliance with the total disturbed areas, the owner/operator shall measure the total disturbed area at least once every 12 months and shall maintain a record of the total disturbed acres. To determine the disturbed acres on site, the owner/operator shall use aerial drone survey of each disturbed area on site to calculate each disturbed area on site. Records of the total disturbed areas shall contain the following: A. Date of measurements. B. Size of each disturbed area on site. C. Total acres of all disturbed areas combined. [R307-401-8] II.B.7.g The owner/operator shall not exceed seven (7) acres of area for the storage piles combined, with
no more than six (6) acres outside of enclosures or buildings. [R307-401-8]

II.B.7.g.1 To determine compliance with the total storage piles the owner/operator shall measure the total storage pile area at least once every 12 months and shall maintain a record of the total storage pile acres. To determine the storage pile acres on site, the owner/operator shall use aerial drone survey of each storage pile area on site to calculate each storage pile area on site. Records of the total storage pile areas shall contain the following: A. Date of measurements. B. Size of each storage pile on site. C. Total acres of all storage piles combined. [R307-401-8]

DAQE-IN159980004-24
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II.B.8 Storage Tank Requirements II.B.8.a The owner/operator shall install the fuel oil storage tank with submerged fill pipes. The
owner/operator shall operate the storage tank in a way that minimizes working and breathing losses from the tank. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN159980003-21 dated August 11, 2021 Is Derived From NOI dated June 30, 2023 Incorporates Additional Information dated August 24, 2023 Incorporates Additional Information dated October 31, 2023 Incorporates Additional Information dated December 1, 2023 Incorporates Additional Information dated December 4, 2023 Incorporates Additional Information dated March 12, 2024 Incorporates Additional Information dated March 21, 2024 Incorporates Additional Information dated April 22, 2024 Incorporates Additional Information dated May 17, 2024 Incorporates Additional Information dated May 24, 2024 Incorporates Additional Information dated July 15, 2024 Incorporates Additional Information dated August 2, 2024 Incorporates Additional Information dated September 25, 2024 Incorporates Additional Information dated October 17, 2024 Incorporates Additional Information dated October 23, 2024
DAQE-IN159980004-24
Page 15

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

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=== Notes ===
Notice Name: Wildcat Sand, LLC 15998 0004
Order Number: 2871450

Net Subtotal $105.14
Tax 0.00
Amount paid $105.14
Uintah Basin Standard
Publication Name:
Uintah Basin Standard
Publication URL:
Publication City and State:
Roosevelt, UT
Publication County:
Duchesne
Notice Popular Keyword Category:
Notice Keywords:
wildcat
Notice Authentication Number:
202411181102495638731
1761527881
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Notice Publish Date:
Wednesday, November 13, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Location: Wildcat Sand, LLC Wildcat Sand, LLC - Uintah County Sand Processing
Plant - Section17 T3S R1E, Uintah County, UT Project Description: Wildcat Sand, LLC has requested a modification to their approval order to
install a 38 MMBtu/hr natural gas sand dryer and increase production of sand to 2,628,000 tons per year. This request will result in increased
activity across the plant, including increased haul road traffic. No other changes to equipment have occurred as a result of this modification.
The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air
quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period.
The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same
address on or before December 13, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project.
Email comments will also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of
this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a
Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and
was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the
issue. Date of Notice: November 13, 2024 Published in the Uintah Basin Standard November 13, 20242871450
Back

DAQE-NN159980004-24

November 7, 2024

Uintah Basin Standard
Legal Advertising Department
268 South 200 East
Roosevelt, UT 84066

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Uintah Basin Standard
on November 13, 2024.

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

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Uintah County
cc: Uintah Basin Association of Governments

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN159980004-24
Page 2
NOTICE

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

Company Name: Wildcat Sand, LLC
Location: Wildcat Sand, LLC - Uintah County Sand Processing Plant – Section17 T3S
R1E, Uintah County, UT
Project Description: Wildcat Sand, LLC has requested a modification to their approval order to install
a 38 MMBtu/hr natural gas sand dryer and increase production of sand to
2,628,000 tons per year. This request will result in increased activity across the
plant, including increased haul road traffic. No other changes to equipment have
occurred as a result of this modification.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before December 13, 2024, will be considered in
making the final decision on the approval/disapproval of the proposed project. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

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

Date of Notice: November 13, 2024

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

DAQE-

RN159980004 January 31, 2024 Matthew Hyita
Wildcat Sand, LLC 5128 Apache Plume Road, Suite 300 Fort Worth, TX 76109
[e-mail] Dear Matthew Hyita,
Re: Engineer Review: Minor Modification to Increase Sand Production and Install New Equipment Project Number: N159980004 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Wildcat Sand, LLC should complete this review within 10 business days of receipt. Wildcat Sand, LLC should contact Dylan Frederick at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dylan Frederick at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Wildcat Sand, LLC does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Wildcat Sand, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [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 N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N159980004 Owner Name Wildcat Sand, LLC Mailing Address 5128 Apache Plume Road, Suite 300
Fort Worth, TX, 76109 Source Name Wildcat Sand, LLC - Uintah County Sand Processing Plant
Source Location Section17 T3S R1E Uintah County, UT
UTM Projection 593,455 m Easting, 4,453,216 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1499 (Miscellaneous Nonmetallic Minerals, Except Fuels) Source Contact Matthew Hyita Phone Number [phone] Email [e-mail] Billing Contact Matthew Hyita Phone Number [phone]
Email [e-mail] Project Engineer Dylan Frederick, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 30, 2023 Date of Accepted Application December 13, 2023

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 2
SOURCE DESCRIPTION General Description
Wildcat Sand, LLC operates a sand processing facility in the Uinta Basin. The facility receives sandstone that is crushed and processed in a wet plant to remove fine particulates, before finally being sent through a drying and separation process. The final sand product is sized to customer
specifications and shipped off-site. The plant is designed to process up to 2,628,000 tons of sand per year. NSR Classification: Minor Modification at Minor Source Source Classification Located in Uinta Basin O3 NAA, Uintah County Airs Source Size: B
Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
NSPS (Part 60), UUU: Standards of Performance for Calciners and Dryers in Mineral Industries NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Title V (Part 70) Area Source
Project Proposal Minor Modification to Increase Sand Production and Install New Equipment Project Description Wildcat Sand, LLC has requested the following modifications: 1. Install a new 38 MMBtu/hr natural gas-fired burner and a 482 hp (360 kW) natural gas-fired engine 2. Increase production for each sand dryer to 1,314,000 tons per rolling 12-month period.
EMISSION IMPACT ANALYSIS Wildcat Sand, LLC conducted modeling on the 24-hour PM10 NAAQs and 1-hour NO2 NAAQs for all sources at the facility. The model results for the 24-hour PM10 NAAQs concentration were found to be 98.93% of the NAAQS. The model results for the 1-hour NO2 NAAQs concentration were found to be 67.61% of the NAAQS. The DAQ reviewed and accepted the results of the model. Detailed results of the modeling can be
found in the modeling memo DAQE-MN159980004-23.
The source is not required to model for other criteria pollutants and HAPs because the emission increases are
below the modeling thresholds per R307-410-4 and R307-410-5. [Last updated January 3, 2024]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 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 28554 42072.00 Carbon Monoxide 39.18 59.26
Nitrogen Oxides 35.12 51.96
Particulate Matter - PM10 30.89 43.48
Particulate Matter - PM2.5 26.08 26.94
Sulfur Dioxide -0.45 0.21
Volatile Organic Compounds 2.42 5.46 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 248
Acrolein (CAS #107028) 152
Formaldehyde (CAS #50000) 1303 1613
Generic HAPs (CAS #GHAPS) 0 117
Hexane (CAS #110543) 852 1245 Methanol (CAS #67561) 740 Change (TPY) Total (TPY)
Total HAPs 1.65 2.06

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

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding Dryer
Wildcat has proposed the installation of a new dryer. This will increase emissions from sand processing and combustion. Sand processing emissions will increase emissions of PM10 and PM2.5, combustion emissions will increase emissions of NOx, CO, VOCs, HAPs, SO2, PM10, and PM2.5.
To control PM10 and PM2.5 emissions from the dryer, the source has proposed the installation of a fabric filter baghouse with a certified emission concentration of 0.01 gr/scf, in tandem with a cyclone. The fabric filter baghouse will reduce both PM10 and PM2.5 emissions by 99%. This is the highest available control for particulate matter, therefore, no further analysis is necessary.
To control emissions of CO, VOCs, HAPs, and SO2, add on controls targeting these pollutants are limited for industrial dryers. Add-on CO or VOC devices such as oxidation catalysts or incinerators are not commercially available for dryers, and would not be technically or economically feasible to implement due to high incremental costs to install. Generally, these emissions come from incomplete combustion of fuel. Operating the dryer according to manufacturer specifications including regular maintenance will ensure more complete combustion and reduce emissions from the dryer. Use of natural gas as fuel ensures lower HAP and sulfur emissions compared to diesel fuel or other fuel oils. These best practices are considered BACT.
NOx emissions are the primary emission source from the dryers and are considered in depth. Wildcat has proposed the installation of a new dryer (Starjet) with low-NOx burners installed. Other options that provide further NOx reductions were considered, including a dryer with lower NOx emission rates (Megastar) and a low-NOx burner with flue gas recirculation (Megastar+FGR). Both Megastar burners would require a higher heat input rating due to lower dryer efficiency from the low-NOx burner, resulting in increased emissions from combustion. This increase would be necessary to maintain the production rates requested by Wildcat. Additionally, the Megastar burners would require a higher capital investment and significantly higher annual operating costs. The initial incremental capital cost would be $98,851 for the megastar burner, and $197,702 for the megastar with FGR. Wildcat estimates an annual operation and maintenance increase of $26,572 for semi-annual dryer tuning, and an increased cost in natural gas combustion of $40-48/hr. On the lower end, this gives a annualized cost of $367,067/year for operation and maintenance alone.
The low-NOx Megastar burner would reduce annual NOx emissions from 16.34 tons per year to 13.50 tons per year. Combining the 10-year annualized capital cost and the annual operation and maintenance costs, this comes to a cost effectiveness of $159,369/ton NOx removed annually. This is economically infeasible and is not considered further. The low-NOx Megastar burner with FGR would reduce annual NOx emissions from 16.34 tons per year to 6.18 tons per year. The annual cost effectiveness of this reduction is $38,060/ton of NOx
removed. This is economically infeasible and is not considered further. The low-NOx Starjet burner is accepted as BACT. BACT for the dryer will be: 1. Use of a baghouse/cyclone system with a certified emission guarantee of 0.01 gr/scf PM.
2. Installation of a low-NOx burner system guaranteed to emit less than 96 ppm of NOx 3. Manufacturer recommended maintenance, operation, and good combustion practices 4. Use of Natural Gas as Fuel
5. A 10% opacity limit. [Last updated January 17, 2024]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 5

2. BACT review regarding Haul Roads Wildcat Sand operates several haul roads throughout the facility, to account for product transfer through the process and shipping sand product in and out of the facility. Due to the increase in
sand production, increased fugitive emissions of PM10 and PM2.5 will result from increased traffic along the haul roads. To control emissions, the following options were considered in order of control effectiveness:
Paving Roads with Vacuum Sweeping and Watering - 95%
Paving Roads with Sweeping and Watering - 90% Chemical Suppressants and Watering - 85% Watering and Road Base - 80% Watering - 75%
Wildcat sand proposed the use of chemical suppressants and watering. To evaluate the option of more stringent controls, DAQ evaluated the impacts of upgrading to paving with regular vacuum sweeping and watering. The initial cost to pave the haul roads is estimated to be over $1,000,000. Assuming this is the lowest possible cost, and without considering annual repair and maintenance costs, as well as costs
for vacuum sweeping and watering, this number can be annualized to $142,380/year. This is calculated using a 10-year life span and a 7% interest rate, giving as capital recovery factor of 0.14238. The total annual emissions from all haul roads is estimated to be 12.90 tons of PM10 per year. The total emission reductions for paving, watering, and vacuum sweeping the roads would be 8.6 tons per year annually, giving a minimum annual cost effectiveness of $16,556/ton PM10 removed.
Paving with sweeping and watering would require the same capital investment and would only
reduce emissions by 4.3 tons per year, effectively doubling the cost effectiveness. These cost estimates do not consider any annual maintenance costs, which would be higher than average due to the nature of the haul road's locations and truck traffic over the haul roads, or the costs of
bringing in equipment to perform regular sweeping and watering. Paving would also require a portable asphalt plant be sent to the facility, increasing emissions due to asphalt production. For all of these reasons, paving the haul roads is considered economically infeasible.
Chemical suppressants and watering are accepted as the most stringent remaining control
techniques.
BACT for control of PM10 and PM2.5 from the haul roads at the sand processing plant will be the application of chemical suppressants and watering as needed to maintain an opacity of limit of 20%.
[Last updated December 22, 2023] 3. BACT review regarding Storage Piles Fugitive PM10 and PM2.5 emissions occur when wind blows over storage piles of aggregate and sand kept onsite. Control options include water sprays, partial enclosures with water sprays, and compacting material with water sprays. Compacting material is technically infeasible for the
source due to the continuous nature of the process. Installing enclosures is not feasible due to the mobile nature of the process and facility. Storage piles will be moved regularly and material will

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 6
be continuously moved in and out of the storage piles. The source evaluated water sprays with a control efficiency of 50% as a technically feasible option. These are cost effective and technically
feasible to implement, and are BACT for storage piles at the facility. BACT for control of PM10 and PM2.5 from the storage piles is the application of water to maintain opacity at 20% or below. [Last updated January 23, 2024] 4. BACT review regarding Material Handling Wildcat Sand will increase the total amount of sand processed annually, which will increase fugitive PM10 and PM2.5 emissions from handling wet and dry sand. To control emissions from the wet sand process, the following controls were considered in order of control effectiveness: Enclosures venting to a baghouse - 99% - 99.9 % reduction Enclosures with water sprays - 87.5% reduction
Water Sprays - 75% reduction Enclosures - 50% reduction Due to the number of conveyor transfer points and material handling emission points, installation of enclosures venting to one or several baghouses would not be technically or economically
feasible for the operation due to the need for several baghouses or installation of venting systems capable of servicing all fugitive emission points at the plant. The addition of these baghouses would require alteration of the wet and dry processes inherent to the production process, and therefore, this option is no longer considered. Wildcat Sand proposes the installation of enclosures with water sprays for the wet plant. These measures are accepted as BACT. For the Dry plant material handling operations, the sand material is required to operate in a dry process, and therefore cannot use water sprays. The material handling emissions at the J & H
screen will be controlled by a baghouse with a grain loading rate of 0.01 gr/scf. This is the most stringent control available and is accepted as BACT. BACT for control of PM10 and PM2.5 from material handling operations will be the installation of enclosures and water sprays at the wet plant to maintain an opacity limit of 7%, and the installation of a baghouse to control the dry process screens with a emission concentration of 0.01 gr/scf. [Last updated December 22, 2023]
8. BACT review regarding Stationary Engine The 360 kW natural gas engine produces NOx, CO, VOC, SO2, PM10 and PM2.5 emissions due to combustion.
The proposed engine will be compliant with the following NSPS JJJJ standards: NOx: 1.0 g/hp-hr CO: 2.0 g/hp-hr VOC: 0.7 g/hp-hr These certified emission rates are considered BACT for the above criteria pollutants from the engine. Further add-on controls would significantly increase operating costs for small amounts of
emission reductions. For example an SCR is estimated to cost an initial investment of $2,127,689. At a control effectiveness of 85%, it could remove 3.95 tons per year annually. Over a lifespan of 20 years, the cost effectiveness is estimated to be $67,908/ton of NOx removed. This is not considered cost effective, therefore, add-on controls are considered economically infeasible. To control emissions from SO2, PM10, and PM2.5, the natural gas engine can use good combustion practices, which include operating the engine according to manufacturer recommendations, and

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 7
regularly scheduled maintenance to ensure maximum conversion of fuel to CO2 and water. These measures are BACT for the engine.
BACT for the stationary 360 kW engine will be an emission limit of 1.0 g/hp-hr NOx, 2.0 g/hp-hr CO, 0.7 g/hp-hr VOC, and an opacity limit of 10%. [Last updated January 3, 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 N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 8
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 Sand Processing Facility

II.A.2 Wet Sand Processing Plant *informational purposes only
II.A.3 Three (3) Wash Screens Size: 8' X 12' NSPS Applicability: Subpart OOO II.A.4 Dry Sand Processing Plant
II.A.5 Sand Dryer #1 Rating: 40.9 MMBtu/hr Fuel: Natural Gas Control: Baghouse
NSPS Applicability: Subpart UUU II.A.6 NEW Sand Dryer #2 Rating: 38.0 MMBtu/hr Fuel: Natural Gas Control: Baghouse NSPS Applicability: Subpart UUU
II.A.7 Three (3) Baghouses Baghouse 1 Controls: Sand Dryer #1 Baghouse is in sequence with cyclone
Baghouse 2
Controls: Vibrating Dry Processing Screens
Baghouse 3 Controls: Sand Dryer #2 Baghouse is in sequence with cyclone

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 9
II.A.8 NEW Two (2) Cyclones Controls: Sand Dryers Each cyclone is in sequence with a baghouse

II.A.9 Three (3) Vibrating Dry Processing Screens Size: 6' X 25' Controls: Baghouse NSPS Applicability: Subpart OOO
II.A.10 One (1) Quad Roll Crusher Rating: 275 tph NSPS Applicability: Subpart OOO
II.A.11 Various Material Handling Equipment Material Loading, Conveyors, Drop Points NSPS Applicability: Subpart OOO

II.A.12 Three (3) Sand Storage Silos Controls: Bin Vent Filters Stores finished sand product for transport offsite
II.A.13 One (1) Generator Rating: 360 kW (482 hp) Fuel: Natural Gas NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ Manufacturer year: 2014 (NEW)
II.A.14 One (1) Storage Tank Contents: Fuel Oil Capacity: 5,000 gallons

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide Requirements II.B.1.a NEW The owner/operator shall not process more than 2,628,000 tons of sand per rolling 12-month period. [R307-401-8]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 10
II.B.1.a.1 NEW The owner/operator shall:
A. Determine the amount of sand processed with purchasing receipts
B. Record the amount of sand processed on a daily basis, when plant is in operation. C. Use the processing data to calculate a new 12-month total by the last day of each
month using data from the previous 12 months.
D. Keep the purchasing records for all periods the plant is in operation. [R307-401-8]

II.B.1.b NEW The owner/operator shall not allow visible emissions to exceed the following limits:
A. All screens - 7% opacity
B. All crushers - 12% opacity C. All conveyor transfer points - 7% opacity D. The dry processing screens baghouse exhaust stack - 7% opacity E. The dryer baghouse exhaust stacks - 10% opacity F. The engine exhaust stack - 10% opacity
G. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart UUU, R307-201-3, R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3]
II.B.2 Stack Testing Requirements II.B.2.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]
II.B.2.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.2.a.2 Testing The owner/operator shall conduct testing according to the approved source test protocol. The
Director may reject stack testing results if the test did not follow the approved source test protocol. [R307-401-8]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 11
II.B.2.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.2.a.4 Test Conditions The owner/operator shall conduct all stack testing according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]
II.B.2.a.5 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. [R307-401-8] II.B.2.a.6 Possible Rejection of Test Results The Director may reject stack testing results according to R307-165-6. [R307-165-6]

II.B.2.b Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8] II.B.2.b.1 NEW Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.2.b.2 PM
40 CFR 60, Appendix A, Method 5 or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.2.b.3 Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate
emissions, all of the filterable particulate emissions shall be considered PM10. [R307-401-8] II.B.2.b.4 Filterable PM2.5 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-
approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM2.5. [R307-401-8]

II.B.2.b.5 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 12
II.B.2.b.6 VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-
8] II.B.2.b.7 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.3 Sand Processing Equipment Requirements II.B.3.a The owner/operator shall install enclosures on the vibrating dry processing screens and control emissions with a baghouse. [R307-401-8]
II.B.3.b The owner/operator shall install a baghouse with a certified emission rate of 0.01 gr PM10/dscf and 0.01 gr PM/dscf or less to control the vibrating dry processing screens. [R307-401-8] II.B.3.b.1 The owner/operator shall keep manufacturer records certifying this emission rate for the lifetime of the equipment. [R307-401-8]

II.B.3.c The owner/operator shall install and operate enclosures and water sprays on the conveyors and conveyor drop points transporting material prior to entering the wet sand processing plant to maintain the opacity limits in this AO. The owner/operator shall install enclosures on all
conveyors and conveyor drop points transporting unsaturated material to maintain the opacity limits in this AO. [R307-205-4, R307-401-8]
II.B.3.d The owner/operator shall install and operate water sprays to maintain the opacity limits in this AO for the crusher and all storage piles on site. [R307-205-4, R307-401-8] II.B.3.e The owner/operator shall operate the wet processing plant in such a way that ensures no visible emissions are generated. [R307-401-8]
II.B.4 NSPS Subpart OOO Requirements

II.B.4.a The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site. Performance tests shall meet the limitations specified in Tables 2 and 3 to Subpart OOO. [40 CFR 60 Subpart OOO]
II.B.4.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR
60.675(c). The owner or operator may use methods and procedures specified in 40 CFR 60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c). [40 CFR 60 Subpart OOO]
II.B.4.a.2 The owner/operator shall keep and maintain records of the initial performance test for each crusher, screen, and conveyor for the life of the equipment. The record of the initial performance test must be made available to the Director or the Director's representative upon
request. [40 CFR 60 Subpart OOO, R307-401-8] II.B.5 Sand Drying Operation Requirements

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 13
II.B.5.a NEW The owner/operator shall install and operate the dryers with a low-NOx burner system. [R307-401-8]
II.B.5.a.1 NEW The owner/operator shall maintain a manufacturer's guarantee showing the NOx emissions shall not exceed 96 ppm from the dryer burners. [R307-401-8]
II.B.5.b NEW The owner/operator shall install and operate a baghouse and cyclone system to control particulate emissions from each sand dryer on site. [R307-401-8]
II.B.5.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the
differential pressure across each baghouse. The static pressure differential across each baghouse shall be between 2 and 6 inches of water column. [R307-401-8] II.B.5.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The pressure gauge shall measure the pressure drop in 0.5-inch water column increments or less. The pressure gauge shall be calibrated according to the manufacturer's instructions at least once every 12 months. [R307-401-8]
II.B.5.c.2 The owner/operator shall record the reading of the pressure gauge at least once per operating
day. [R307-401-8] II.B.5.d NEW The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s):
***Each Dryer Baghouse Exhaust Stack***
Pollutant lb/hr grains/dscf
PM 1.42 0.01
Filterable PM10 1.42 0.01 Filterable PM2.5 1.42 0.01. [R307-401-8]
II.B.5.d.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. [R307-165-2, R307-401-8]

II.B.5.d.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]

II.B.5.d.3 Test Frequency
The owner/operator shall conduct a stack test on the emission unit within five years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]
II.B.6 Stationary Generator Engine Requirements

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 14
II.B.6.a NEW The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s): ***360 kW Generator Exhaust Stack*** Pollutant lb/hr ppmv NOx 1.06 160 CO 2.13 540
VOC 0.4 86. [R307-401-8] II.B.6.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. [R307-165-2, R307-401-8] II.B.6.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2] II.B.6.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit at least once every 8,760
hours of use or at least within three years after the date of the most recent stack test of the emission unit, whichever comes first. The Director may require the owner/operator to perform a stack test at any time. [40 CFR 60 Subpart JJJJ, R307-401-8]
II.B.7 Haul Roads and Fugitive Dust Requirements II.B.7.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% at the property boundary. [R307-401-8]
II.B.7.a.1 Visible emission determinations for fugitive dust from haul roads and operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle
length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8] II.B.7.b The owner/operator shall use chemical suppressants such as magnesium chloride and regular water applications on all unpaved loader routes and wheeled vehicle operational areas to
maintain the opacity limits listed in this AO. [R307-401-8] II.B.7.c The owner/operator shall use water application or other control options contained in R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust, to minimize emissions from fugitive emission sources, including storage piles and disturbed areas to maintain the opacity limits listed in this AO. [R307-205, R307-401-8]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 15
II.B.7.c.1 NEW Records of water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time water was applied B. Quantity of water applied
C. Rainfall amount received, if any
D. Records of temperature, if the temperature is below freezing. [R307-401-8]

II.B.7.d NEW The owner/operator shall not exceed 14 acres of all disturbed area combined. [R307-401-8] II.B.7.d.1 NEW To determine compliance with the total disturbed areas, the owner/operator shall measure the total disturbed area at least once every 12 months and shall maintain a record of the total disturbed acres. To determine the disturbed acres on site, the owner/operator shall use aerial
drone survey of each disturbed area on site to calculate each disturbed area on site. Records of the total disturbed areas shall contain the following: A. Date of measurements B. Size of each disturbed area on site C. Total acres of all disturbed areas combined. [R307-401-8] II.B.8 Storage Tank Requirements
II.B.8.a The owner/operator shall install the fuel oil storage tank with submerged fill pipes. The owner/operator shall operate the storage tank in a way that minimizes working and breathing
losses from the tank. [R307-401-8]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 16
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes DAQE-AN159980003-21 dated August 11, 2021
Is Derived From NOI dated June 30, 2023 Incorporates Additional Information dated August 24, 2023 Incorporates Additional Information dated October 31, 2023 Incorporates Additional Information dated December 1, 2023 Incorporates Additional Information dated December 4, 2023
REVIEWER COMMENTS 1. Comment regarding Emission Estimations: Emissions are generated from the following sources and estimation methods:
The facility will operate 8760 hours per year.
Material Handling: For two instances of material handling, an input of 300 tph, 2,628,000 tons of
sand material per year, 1 transfer point, average wind speed of 8mph, 5% moisture content were used. For the other four instances, an input of 150 tph, 1,314,000 tons per year, 1 transfer point, average wind speed of 8mph, and 5% moisture content were used. Source submitted DAQ "Material
Handling" Spreadsheet from DAQ website for each instance of material handling.
Sand Dryers: Emissions factors were determined from AP-42 Section Tables 1.4-1 through 1.4-4. The existing dryer is estimated to consume 0.041 MMscf/hr of natural gas, the new dryer will consume 0.037 MMscf/hr. The dryers will both emit NOx at a rate of 5.4 lb/hr and CO at a rate of 5.7 lb/hr, determined from Tarmac dryer data sheet. PM10 and PM 2.5 emissions determined from manufacturer guarantee of 0.01 gr/scf, and a exhaust temperature of 210 F to give an ascf figure of 0.0079 gr/ascf for the first dryer and 0.007 gr/ascf for the second dryer.
Roads: UDAQ "Haul Roads" emissions spreadsheet was used. AP-42 13.2.2 & DAQ Haul Road Guidance are used to determine emissions. Haul road #1: Input of 150 tph, and 1,314,000 tons per year used, empty truck weight of 22 tons, and 43 ton weight load. Haul road length is 662 feet, with chemical suppressants and watering used for control. Haul road #2: Input of 300 tph, 2,628,000 tpy, same truck weight and load weights used, with a haul road length of 1,151 feet. This road is paved and uses watering and vacuum sweeping. Loader route #1: Same inputs as haul road #1, with haul road length of 1,201 feet, using chemical suppressants and watering. Loader route #2: Same inputs as haul road #2, with a haul road length of 1,563 feet, using chemical suppressants and watering. Loader route #3: Same inputs as haul road #1, with haul road length of 1,069 feet, using chemical suppressants and watering.
Material Processing Equipment: UDAQ "Aggregate Processing Equipment" emissions spreadsheet was used. AP-42 Table 11.19.2-2 is used to determine emissions. Inputs of 300 tph and 2,628,000 tpy were used. One crusher, three screens, and 14 conveyor transfer points were used. An additional three conveyor transfer points were used to determine emissions from the storage silos, and four conveyor transfer points for the dry plant #2 conveyors.
Storage Piles: UDAQ "Storage Piles" emissions spread sheet was used. Storage pile #1 used an input

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 17
of 1 acre, storage pile #2 used an input of 2 acres, storage pile #3 used an input of 3 acres, and bag house waste pile #1 used 1 an input of 1 acre.
Disturbed Area: A total area of 14 acres was used as an input to determine emissions from disturbed area. UDAQ "Disturbed Ground" emissions spread sheet was used to determine emissions. Generator: The generator is rated at 360 kW or 482 hp and uses natural gas as fuel. UDAQ "Natural Gas-Fired Engines" emissions spreadsheet was used to determine emissions, using an input of 8760
hours and "4-stroke lean burn". NOx emissions were calculated at 2 g/hp-hr and CO emissions were calculated at 4 g/hp-hr, Storage Tanks: emissions were determined from AP-42 Chapter 7 with a 154,000-gallon annual throughput and 5,000-gallon capacity. The tank has a length of 27 feet and a diameter of 8 feet.
Equations 1-4, 1-13, 1-14, 1-20, 1-21, 1-26, 1-27, and 1-35 are used to determine standing storage losses and working losses. Table 7.1-7 was used to determine inputs for the equation 1-27. [Last updated January 3, 2024] 4. Comment regarding NSPS and MACT applicability: 40 CFR 60 (NSPS) Subpart Kb applies to storage vessels with a capacity greater than or equal to 75
cubic meters that store VOLs (Volatile Organic Liquids). The tank in the AO is less 75 cubic meters (19,800 gallons), with a capacity of 5,000 gallons. Therefore, Subpart Kb does not apply to this facility.
40 CFR 60 (NSPS) Subpart OOO applies to affected facilities in fixed or portable nonmetallic
mineral processing plants. The plant will operate a crusher and screening operation as defined by this subpart and processes a material listed as a nonmetallic mineral in this subpart. Therefore, Subpart OOO applies to this facility. Opacity requirements from this subpart are included in the AO
requirements. Initial testing required by this subpart for all affected facilities are listed in requirements. 40 CFR 60 (NSPS) Subpart UUU applies to each calciner and dryer at a mineral processing plant. Industrial sand is a listed mineral for which processing operations are subject to this regulation. Therefore, NSPS Subpart UUU applies to the dryers at this facility. This subpart requires stack testing for particulate matter from each dryer. 40 CFR 60 (NSPS) Subpart JJJJ applies to owner/operators and manufactures of stationary spark ignition (SI) internal combustion engines (ICE). The engine onsite is a SI ICE and was purchased after July 1, 2008 and is greater than 25 hp. Therefore, Subpart JJJJ applies to the generator.
40 CFR 63 (MACT) subpart ZZZZ applies to owners/operators of stationary RICE at a major or area
sources of HAP emissions. The facility is an area HAP source and the station operates a stationary RICE as defined in this subpart, so Subpart ZZZZ applies to the generator. Compliance with this subpart is met through compliance with NSPS subpart JJJJ. [Last updated December 28, 2023]
5. 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.

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 18
4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is subject to 40 CFR 60 (NSPS) and 40 CFR 63 (MACT) regulations. It is not subject to 40 CFR 61 (NESHAP) regulations. NSPS subpart JJJJ, and MACT subpart ZZZZ exempt a source from Title V requirements, but NSPS OOO and UUU do not. Therefore, Title V is applicable to the facility as an area source. There is no requirement for this source to apply for an initial Title V operating permit under current UDAQ and
EPA rules. The source will be charged applicable Title V fees and Title V funds may be used for inventory and compliance inspections of this source. [Last updated January 3, 2024]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant January 31, 2024 Page 19
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
DAQE-

RN159980004 October 31, 2024 Matthew Hyita
Wildcat Sand, LLC 6000 Western Place, Suite 1000 Fort Worth, TX 76107
[e-mail] Dear Matthew Hyita,
Re: Engineer Review: Minor Modification to DAQE-AN159980003-21 Increase Sand Production and Install New Equipment Project Number: N159980004 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Wildcat Sand, LLC should complete this review within 10 business days of receipt. Wildcat Sand, LLC should contact Dylan Frederick at [phone] if there are questions or concerns
with the review of the draft permit conditions. Upon resolution of your concerns, please email Dylan Frederick at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director.
If Wildcat Sand, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Wildcat Sand, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [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

11/5/2024

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant October 31, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N159980004 Owner Name Wildcat Sand, LLC Mailing Address 6000 Western Place, Suite 1000
Fort Worth, TX, 76107 Source Name Wildcat Sand, LLC - Uintah County Sand Processing Plant
Source Location Section17 T3S R1E Uintah County, UT
UTM Projection 593,455 m Easting, 4,453,216 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1499 (Miscellaneous Nonmetallic Minerals, Except Fuels) Source Contact Matthew Hyita Phone Number [phone] Email [e-mail] Billing Contact Matthew Hyita Phone Number [phone]
Email [e-mail] Project Engineer Dylan Frederick, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 30, 2023 Date of Accepted Application December 13, 2023

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant October 31, 2024 Page 2
SOURCE DESCRIPTION General Description
Wildcat Sand, LLC operates a sand processing facility in the Uinta Basin. The facility receives sandstone that is crushed and processed in a wet plant to remove fine particulates, before finally being sent through a drying and separation process. The final sand product is sized to customer
specifications and shipped off-site. The plant is designed to process up to 2,628,000 tons of sand per year. NSR Classification: Minor Modification at Minor Source Source Classification Located in Uinta Basin O3 NAA, Uintah County Airs Source Size: B
Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
NSPS (Part 60), UUU: Standards of Performance for Calciners and Dryers in Mineral Industries NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Title V (Part 70) Area Source
Project Proposal Minor Modification to DAQE-AN159980003-21 Increase Sand Production and Install New Equipment Project Description Wildcat Sand, LLC has requested the following modifications: 1. Install a new 38 MMBtu/hr natural gas-fired dryer 2. Increase production for the existing sand dryer and new dryer to 2,628,000 tons per rolling 12-
month period. EMISSION IMPACT ANALYSIS
Wildcat Sand, LLC conducted modeling on the 24-hour PM10 NAAQs and 1-hour NO2 NAAQs for all sources at the facility. The model results for the 24-hour PM10 NAAQs concentration were found to be 98.5% of the NAAQS. The model results for the 1-hour NO2 NAAQs concentration were found to be 67.61% of the
NAAQS. The DAQ reviewed and accepted the results of the model. Detailed results of the modeling can be found in the modeling memo DAQE-MN159980004A-24. No restrictions on operations were required as a result of the modeling. The source is not required to model for other criteria pollutants and HAPs because the emission increases are below the modeling thresholds per R307-410-4 and R307-410-5.

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Modeling done for the previous AO showed the source was at 95% of the NAAQS for PM10. This modification doubles the emission rate but does not exceed the modeling thresholds, showing the highest concentration to be
98.93% of the NAAQS. The model was reviewed by DAQ and accepted. The most recent model used uses a more recent 5 years of meteorological data collected at Vernal, as well as more recent PM10 background data collected at Roosevelt, as opposed to the Vernal PM10 background data used in 2021. This model data was evaluated to be a better fit for meteorological conditions at the source. While the impact from PM10 sources does double in the model, the highest background values in the data at the time of the 6th highest value were close to half the value found in the data used previously. Because the new data is a better fit for the source and PM10 impacts from the source are evaluated correctly in the model, the model was accepted. [Last updated September 13, 2024]

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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 28535 42053.00 Carbon Monoxide 60.20 80.28
Nitrogen Oxides 24.32 41.16
Particulate Matter - PM10 29.46 42.05
Particulate Matter - PM2.5 24.49 25.35
Sulfur Dioxide -0.55 0.11
Volatile Organic Compounds 18.12 21.16 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 212
Acrolein (CAS #107028) 131
Formaldehyde (CAS #50000) 1085 1395
Generic HAPs (CAS #GHAPS) 0 117
Hexane (CAS #110543) 806 1199 Methanol (CAS #67561) 64 Change (TPY) Total (TPY)
Total HAPs 1.15 1.56

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

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant October 31, 2024 Page 5
Review of BACT for New/Modified Emission Units 1. BACT review regarding Dryer
Wildcat has proposed to install a new fluidized bed dryer. This will increase emissions from sand processing and combustion. Sand processing emissions will increase emissions of PM10 and PM2.5, combustion emissions will increase emissions of NOx, CO, VOCs, HAPs, SO2, PM10, and PM2.5.
To control PM10 and PM2.5 emissions from the dryer, the source has proposed to install a fabric filter baghouse with a certified emission concentration of 0.01 gr/scf, in tandem with a cyclone. The fabric filter baghouse will reduce both PM10 and PM2.5 emissions by 99%. This is the highest available control for particulate matter; therefore, this is selected as BACT.
To control emissions of CO, VOCs, HAPs, and SO2, there are few commercially available add-on controls targeting these pollutants. The dryer is natural gas-fired and will emit 47.30 tpy of CO, 17.74 tpy VOCs, 0.10 tpy SO2, and 0.3063 tpy of all HAPs. For the highest emitting pollutants, this would be a rate of 10.8 lbs/hr for CO and 4.05 lbs per hour for VOCs. Potential controls include catalyst control technologies such as SCR or oxidizers. However, these are not commercially available for dryers. DAQ is not aware of any published, permitted, or publicly available examples of sand dryers utilizing catalyst control or oxidizer technologies, making them technically infeasible to implement. Generally, emissions of CO, and VOCs come from incomplete combustion of fuel. Operating the dryer according to manufacturer specifications including regular maintenance will ensure more complete combustion and reduce emissions from the dryer. The
estimated emissions above were determined using manufacturer data, thus operating according to these best practices will ensure the equipment operates at the specified emission rates or lower. DAQ researched both BACT clearinghouse searches and permits issued for sand dryers in other states such as Arkansas, Oklahoma, Illinois, Michigan, and Wisconsin. DAQ could not find any examples of sand dryers permitted with manufacturer specific data, and could not verify a lower emission rate or control technology that could be implemented to reduce CO and VOC emissions from this equipment. While these other permits were issued showing lower hourly emission rates for CO and VOCs, these were made with estimates using AP-42 Section 1.4 and 1.5, and did not use manufacturer specific data. Therefore, DAQ concluded there are no other technologies that can be implemented to lower the emission rates on the equipment for these pollutants, therefore, these
best practices are considered BACT.
[Last updated October 24, 2024]
2. BACT review regarding Dryer Pt. 2 Controls for NOx emissions from the dryers are considered below. Wildcat has proposed an emission limit of 80 ppm NOx for the dryer. To further reduce emissions, a low-NOx burner with
flue gas recirculation (Megastar+FGR) was considered. The megastar burner would require a higher heat input rating due to lower dryer efficiency from the low-NOx burner, resulting in increased emissions from combustion. This increase would be necessary to maintain the production rates requested by Wildcat. Additionally, the Megastar burner would require a higher capital investment and significantly higher annual operating costs. The initial incremental capital cost would be $197,702 for the megastar with FGR, which gives an annualized capital cost of $28,149/year. Wildcat estimates an annual operation and maintenance increase of $26,572 for semi-annual dryer tuning, and an increased cost in natural gas combustion of $40-48/hr. On the
lower end, this gives a annualized cost of $367,067/year for operation and maintenance alone.

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant October 31, 2024 Page 6
The low-NOx Megastar burner with FGR would reduce annual NOx emissions from 16.34 tons per year to 6.18 tons per year. The annual cost effectiveness of this reduction is $38,060/ton of NOx
removed. This is economically infeasible and is not considered further. DAQ confirmed no other lower emitting dryer burners were available for purchase. BACT for the dryer will be: 1. Use of a baghouse/cyclone system with a certified emission guarantee of 0.01 gr/scf PM.
2. Installation of a natural gas burner system guaranteed to emit 80 ppm or less of NOx 3. Manufacturer recommended maintenance, operation, and good combustion practices 4. A 10% opacity limit. [Last updated October 24, 2024] 3. BACT review regarding Haul Roads Wildcat Sand operates several haul roads throughout the facility for product transfer through the
process and shipping sand product in and out of the facility. Due to the increase in sand production, fugitive emissions of PM10 and PM2.5 will increase from increased traffic along the haul roads. To control emissions, the following options were considered in order of control effectiveness: Paving Roads with Vacuum Sweeping and Watering - 95% Paving Roads with Sweeping and Watering - 90% Chemical Suppressants and Watering - 85% Watering and Road Base - 80% Watering - 75% One main haul road at the facility is already paved. This road is proposed to use vacuum sweeping and watering. As this is the most stringent control available, it is accepted as BACT.
BACT for control of PM10 and PM2.5 from the paved haul roads at the sand processing plant will be the use of vacuum sweeping and watering as needed to maintain an opacity of limit of 20%.
For the other unpaved haul roads, Wildcat proposed the use of chemical suppressants and watering.
To evaluate the option of more stringent controls, DAQ evaluated the impacts of upgrading to paving with regular vacuum sweeping and watering. For the unpaved haul roads, the initial cost to pave the haul roads is estimated to be over $1,000,000. Assuming this is the lowest possible cost, and without considering annual repair and maintenance costs, as well as costs for vacuum sweeping and watering, this number can be annualized to $142,380/year. This is calculated using a 10-year life span and a 7% interest rate, giving as capital recovery factor of 0.14238. The total annual emissions from all haul roads is
estimated to be 13.24 tons of PM10 per year. The total emission reductions for paving, watering, and vacuum sweeping the roads would be 8.83 tons per year annually, giving a minimum annual cost effectiveness of $16,125/ton PM10 removed.
Paving with sweeping and watering would require the same capital investment and would only
reduce emissions by 4.41 tons per year, effectively doubling the cost effectiveness. These cost estimates do not consider any annual maintenance costs. Paving the haul roads is considered economically infeasible. Chemical suppressants and watering are accepted as the most stringent remaining control techniques for the unpaved haul roads.
BACT for control of PM10 and PM2.5 from the unpaved haul roads at the sand processing plant will

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant October 31, 2024 Page 7
be the application of chemical suppressants and watering as needed to maintain an opacity of limit of 20%.
[Last updated October 24, 2024] 4. BACT review regarding Storage Piles Fugitive PM10 and PM2.5 emissions occur when wind blows over storage piles of aggregate and sand kept onsite. Control options include water sprays and partial enclosures with water sprays. Installing enclosures is not feasible due to the mobile nature of the process and facility. Storage piles will be moved regularly and material will be continuously moved in and out of the storage piles. The source evaluated water sprays with a control efficiency of 50% as a technically feasible option. These are cost effective and technically feasible to implement, and are BACT for storage piles at the facility. BACT for control of PM10 and PM2.5 from the storage piles is the application of water to maintain
opacity at 20% or below. [Last updated October 24, 2024] 5. BACT review regarding Sand Processing
Wildcat Sand will increase the total amount of sand processed annually, which will increase fugitive PM10 and PM2.5 emissions from handling wet and dry sand. This will also include the processing of sand through screens and a crusher. To control emissions from the wet sand process,
the following controls were considered in order of control effectiveness: Enclosures venting to a baghouse - 99% - 99.9 % reduction Enclosures with water sprays - 87.5% reduction Water Sprays - 75% reduction
Enclosures - 50% reduction
Due to the number of conveyor transfer points and material handling emission points, installation of enclosures venting to one or several baghouses would not be technically or economically feasible for the operation. The addition of these baghouses would require alteration of the wet and dry processes inherent to the production process, and therefore, this option is no longer considered. Wildcat Sand proposes the installation of enclosures with water sprays for the wet plant. All of the wash screens, crusher and conveyors at the wet plant will operate with water sprays installed.
These measures are accepted as BACT.
For the Dry plant material handling operations, the sand material is required to operate in a dry
process, and therefore cannot use water sprays. The material handling emissions at the dry screens will be controlled by a baghouse with a grain loading rate of 0.01 gr/scf. This control is accepted as BACT.
BACT for control of PM10 and PM2.5 from material handling operations will be the installation of
enclosures and water sprays at the wet plant to maintain an opacity limit of 7% for the screens and conveyor transfer points, and 12% for the crusher. At the dry plant, BACT will be the installation of a baghouse to control the dry process screens with an emission concentration of 0.01 gr/scf and a 10% opacity limit. [Last updated October 24, 2024] 6. BACT review regarding Crushers and Screens The facility operates several wash screens and crushers at the facility. Sand product is processed through this equipment, generating emissions of particulate matter.
The plant operates both a dry and wet process, and different controls are necessary at each process

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due to the nature of the processing plant. At the wet process, all sand material has moisture applied which reduces emissions of fugitive dust. The wet plant operates three screens and a crusher. For
all screens and the crusher operating at the wet plant, wet suppression is inherent in the process and is technically feasible to implement. This process operates in the open without enclosures. Enclosures could be installed to allow for a baghouse to capture emissions, however, this would alter the wet plant process as it would introduce an airflow current to the wet sand before it is sorted by the crushers and screens and sent the drying process. This would reduce moisture and cause changes to the dryers later in the process. Therefore, this option is considered infeasible. BACT for control of PM10 and PM2.5 from the wet plant screens and crushers will be the use of wet suppression to maintain an opacity limit of 12% for the crushers and 7% for the screens. The dry plant operates three vibrating screens. All three screens will be installed with an enclosure leading to a central baghouse. The baghouse will capture all emissions from the dry screens, and
has a manufacturer guarantee for an emission concentration of 0.01 gr/dscf. These measures represent BACT for the dry screens at the facility. BACT for control of PM10 and PM2.5 from the dry process screens will be the installation of a baghouse certified to meet an emission limit of 0.01 gr/dscf or lower and a 7% opacity limit. [Last updated October 24, 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]

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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 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 Sand Processing Facility
II.A.2 Wet Sand Processing Plant *informational purposes only
II.A.3 Three (3) Wash Screens Size: 8' X 12' NSPS Applicability: Subpart OOO
II.A.4 Dry Sand Processing Plant
II.A.5 Sand Dryer #1
Rating: 40.9 MMBtu/hr Fuel: Natural Gas Control: Baghouse NSPS Applicability: Subpart UUU Rotary Sand Dryer Air Flow Rate: 20,955 acfm

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II.A.6 NEW Sand Dryer #2 Rating: 38.0 MMBtu/hr Fuel: Natural Gas
Control: Baghouse NSPS Applicability: Subpart UUU Fluid Bed Dryer
Air Flow Rate: 50,000 acfm II.A.7 Three (3) Baghouses Baghouse 1 Controls: Sand Dryer #1 Baghouse is in sequence with cyclone Baghouse 2 Controls: Vibrating Dry Processing Screens Baghouse 3 Controls: Sand Dryer #2
Baghouse is in sequence with cyclone II.A.8 NEW Two (2) Cyclones Controls: Sand Dryers Each cyclone is in sequence with a baghouse II.A.9 Three (3) Vibrating Dry Processing Screens Size: 6' X 25' Controls: Baghouse NSPS Applicability: Subpart OOO II.A.10 One (1) Quad Roll Crusher Rating: 275 tph NSPS Applicability: Subpart OOO II.A.11 Various Material Handling Equipment Material Loading, Conveyors, Drop Points
NSPS Applicability: Subpart OOO II.A.12 Three (3) Sand Storage Silos Controls: Bin Vent Filters
Stores finished sand product for transport offsite
II.A.13 One (1) Generator Rating: 415 hp Fuel: Natural Gas NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ
II.A.14 One (1) Storage Tank
Contents: Fuel Oil Capacity: 5,000 gallons

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SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-Wide Requirements
II.B.1.a NEW The owner/operator shall not process more than 2,628,000 tons of sand per rolling 12-month period. [R307-401-8] II.B.1.a.1 NEW The owner/operator shall: A. Determine the amount of sand processed with purchasing receipts B. Record the amount of sand processed on a daily basis, when plant is in operation.
C. Use the processing data to calculate a new 12-month total by the last day of each
month using data from the previous 12 months. D. Keep the purchasing records for all periods the plant is in operation. [R307-401-8] II.B.1.b NEW The owner/operator shall not allow visible emissions to exceed the following limits: A. All screens - 7% opacity B. All crushers - 12% opacity
C. All conveyor transfer points - 7% opacity
D. The dry processing screens baghouse exhaust stack - 7% opacity
E. The dryer baghouse exhaust stacks - 10% opacity
F. The engine exhaust stack - 10% opacity G. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart UUU, R307-201-3, R307-401-8]

II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] II.B.2 Stack Testing Requirements
II.B.2.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]

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II.B.2.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.2.a.2 Testing The owner/operator shall conduct testing according to the approved source test protocol. The Director may reject stack testing results if the test did not follow the approved source test protocol. [R307-401-8]
II.B.2.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.2.a.4 Test Conditions The owner/operator shall conduct all stack testing according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]
II.B.2.a.5 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. [R307-401-8] II.B.2.a.6 Possible Rejection of Test Results The Director may reject stack testing results according to R307-165-6. [R307-165-6]
II.B.2.b Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
II.B.2.b.1 NEW Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.2.b.2 PM
40 CFR 60, Appendix A, Method 5 or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

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II.B.2.b.3 Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. [R307-401-8]
II.B.2.b.4 Filterable PM2.5 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM2.5. [R307-401-8] II.B.2.b.5 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.2.b.6 VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.2.b.7 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to
the Director. [R307-401-8] II.B.3 Sand Processing Equipment Requirements II.B.3.a The owner/operator shall install enclosures on the vibrating dry processing screens and control emissions with a baghouse. [R307-401-8]

II.B.3.b The owner/operator shall install a baghouse with a certified emission rate of 0.01 gr PM10/dscf and 0.01 gr PM/dscf or less to control the vibrating dry processing screens. [R307-401-8]
II.B.3.b.1 The owner/operator shall keep manufacturer records certifying this emission rate for the lifetime of the equipment. [R307-401-8]
II.B.3.c The owner/operator shall install and operate enclosures and water sprays on the conveyors and conveyor drop points transporting material prior to entering the wet sand processing plant to maintain the opacity limits in this AO. The owner/operator shall install enclosures on all
conveyors and conveyor drop points transporting unsaturated material to maintain the opacity limits in this AO. [R307-205-4, R307-401-8]
II.B.3.d The owner/operator shall install and operate water sprays to maintain the opacity limits in this
AO for the crusher and all storage piles on site. [R307-205-4, R307-401-8] II.B.3.e The owner/operator shall operate the wet processing plant in such a way that ensures no visible emissions are generated. [R307-401-8]
II.B.4 NSPS Subpart OOO Requirements

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II.B.4.a The owner/operator shall conduct an initial performance test for all crushers, screens, and conveyor transfer points on site. Performance tests shall meet the limitations specified in Tables 2 and 3 to Subpart OOO. [40 CFR 60 Subpart OOO]

II.B.4.a.1 Initial performance tests for fugitive emissions limits shall be conducted according to 40 CFR 60.675(c). The owner or operator may use methods and procedures specified in 40 CFR 60.675(e) as alternatives to the reference methods and procedures specified in 40 CFR 60.675(c). [40 CFR 60 Subpart OOO]
II.B.4.a.2 The owner/operator shall keep and maintain records of the initial performance test for each crusher, screen, and conveyor for the life of the equipment. The record of the initial performance test must be made available to the Director or the Director's representative upon request. [40 CFR 60 Subpart OOO, R307-401-8] II.B.4.b NEW The owner/operator shall perform monthly periodic inspections to check that water is flowing to water sprays associated with each crusher, screen, and conveyor. If the owner/operator finds
that water is not flowing properly during an inspection of the water sprays, the owner/operator shall initiate corrective action within 24 hours and complete corrective action as expediently as practical. [40 CFR 60 Subpart OOO, R307-401-8]
II.B.4.b.1 NEW Records of the water spray inspections shall be maintained in a logbook for all periods when the plant is in operation. The records shall include the following items: A. Date the inspections were made. B. Any corrective actions taken.
C. Control mechanism used if sprays are not operating. [40 CFR 60 Subpart OOO, R307-401-8] II.B.5 Sand Drying Operation Requirements
II.B.5.a
NEW
The owner/operator shall install and operate a baghouse and cyclone system to control
particulate emissions from each sand dryer on site. [R307-401-8] II.B.5.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The static pressure differential across each baghouse shall be between 2 and 6 inches of water column. [R307-401-8]
II.B.5.b.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. The pressure gauge shall measure the pressure drop in 0.5-inch water column increments or less. The pressure gauge shall be calibrated according to the
manufacturer's instructions at least once every 12 months. [R307-401-8] II.B.5.b.2 The owner/operator shall record the reading of the pressure gauge at least once per operating day. [R307-401-8]

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II.B.5.c NEW The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s): ***Dryer #1 Baghouse Exhaust Stack*** Pollutant lb/hr grains/dscf ppmv PM 1.07 0.01 Filterable PM10 1.07 0.01
Filterable PM2.5 1.07 0.01 NOx 4.78 96 CO 5.70 500
***Dryer #2 Baghouse Exhaust Stack*** Pollutant lb/hr grains/dscf ppmv
PM 2.99 0.01
Filterable PM10 2.99 0.01 Filterable PM2.5 2.99 0.01 NOx 3.70 80 CO 10.8 450. [R307-401-8] II.B.5.c.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. [R307-165-2, R307-401-8]
II.B.5.c.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]
II.B.5.c.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

II.B.6 Stationary Generator Engine Requirements

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II.B.6.a NEW The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s): ***415 hp Generator Exhaust Stack*** Pollutant lb/hr ppmv NOx 0.92 160 CO 1.8 540
VOC 0.34 86. [R307-401-8] II.B.6.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. [R307-165-2, R307-401-8] II.B.6.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2] II.B.6.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit at least once every 8,760
hours of use or at least within three years after the date of the most recent stack test of the emission unit, whichever comes first. The Director may require the owner/operator to perform a stack test at any time. [40 CFR 60 Subpart JJJJ, R307-401-8]
II.B.7 Haul Roads and Fugitive Dust Requirements II.B.7.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources to exceed 20% opacity on site and 10% at the property boundary. [R307-401-8]
II.B.7.a.1 Visible emission determinations for fugitive dust from haul roads and operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle
length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8] II.B.7.b NEW The owner/operator shall pave the haul road exiting the facility. The paved section of the haul road shall be no less than 1,151 feet in length. [R307-401-8]

II.B.7.b.1 NEW The paved road length shall be determined through source records or GPS measurements. [R307-401-8]

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II.B.7.c NEW An operational vacuum sweeper and water truck shall be made available during each operating day. The owner/operator shall sweep and flush with water all the paved haul roads on site to maintain the opacity limits listed in this AO. If the temperature is below freezing,
the owner/operator shall continue to vacuum sweep the road but may stop flushing the paved haul roads with water. Flushing the paved haul road with water shall resume when the temperature is above freezing. If the haul roads are covered with snow or ice, the
owner/operator may stop sweeping the paved haul roads. Sweeping the paved haul roads shall resume when the haul roads are cleared from snow and ice. [R307-401-8]
II.B.7.c.1 NEW Records of vacuum sweeping and water application shall be kept for all periods when the plant is in operation. The records shall include the following items:
A. Date and time treatments were made.
B. Number of treatments made and quantity of water applied.
C. Rainfall amount received, if any. D. Records of temperature, if the temperature is below freezing. E. Records shall note if the paved haul roads are covered with snow or ice. [R307-401-8] II.B.7.d The owner/operator shall use chemical suppressants such as magnesium chloride and regular water applications on all unpaved loader routes and wheeled vehicle operational areas to maintain the opacity limits listed in this AO. [R307-401-8] II.B.7.e The owner/operator shall use water application or other control options contained in R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust, to minimize emissions from
fugitive emission sources, including storage piles and disturbed areas to maintain the opacity limits listed in this AO. [R307-205, R307-401-8]
II.B.7.e.1 NEW Records of water application shall be kept for all periods when the plant is in operation. The records shall include the following items:
A. Date and time water was applied
B. Quantity of water applied
C. Rainfall amount received, if any D. Records of temperature, if the temperature is below freezing. [R307-401-8]
II.B.7.f NEW The owner/operator shall not exceed 9 acres of all disturbed area combined. [R307-401-8]

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II.B.7.f.1 NEW To determine compliance with the total disturbed areas, the owner/operator shall measure the total disturbed area at least once every 12 months and shall maintain a record of the total disturbed acres. To determine the disturbed acres on site, the owner/operator shall use aerial
drone survey of each disturbed area on site to calculate each disturbed area on site. Records of the total disturbed areas shall contain the following: A. Date of measurements B. Size of each disturbed area on site C. Total acres of all disturbed areas combined. [R307-401-8] II.B.7.g NEW The owner/operator shall not exceed 7 acres of area for the storage piles combined, with no more than 6 acres outside of enclosures or buildings. [R307-401-8]
II.B.7.g.1
NEW
To determine compliance with the total storage piles the owner/operator shall measure the
total storage pile area at least once every 12 months and shall maintain a record of the total storage pile acres. To determine the storage pile acres on site, the owner/operator shall use aerial drone survey of each storage pile area on site to calculate each storage pile area on site.
Records of the total storage pile areas shall contain the following:
A. Date of measurements
B. Size of each storage pile on site
C. Total acres of all storage piles combined. [R307-401-8]

II.B.8 Storage Tank Requirements

II.B.8.a The owner/operator shall install the fuel oil storage tank with submerged fill pipes. The owner/operator shall operate the storage tank in a way that minimizes working and breathing losses from the tank. [R307-401-8]

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PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes DAQE-AN159980003-21 dated August 11, 2021
Is Derived From NOI dated June 30, 2023 Incorporates Additional Information dated August 24, 2023 Incorporates Additional Information dated October 31, 2023 Incorporates Additional Information dated December 1, 2023 Incorporates Additional Information dated December 4, 2023 Incorporates Additional Information dated March 12, 2024 Incorporates Additional Information dated March 21, 2024 Incorporates Additional Information dated April 22, 2024 Incorporates Additional Information dated May 17, 2024 Incorporates Additional Information dated May 24, 2024 Incorporates Additional Information dated July 15, 2024
Incorporates Additional Information dated August 2, 2024 Incorporates Additional Information dated September 25, 2024 Incorporates Additional Information dated October 17, 2024
Incorporates Additional Information dated October 23, 2024
REVIEWER COMMENTS

1. Comment regarding Emission Estimations: Emissions are generated from the following sources and estimation methods: The facility will operate 8760 hours per year. Sand Dryers: The existing dryer is estimated to consume 0.041 MMscf/hr of natural gas, the new
dryer will consume 0.037 MMscf/hr. The old dryer emits NOx at 96 ppm, while the new one will emit it at a 80 ppm rate. This concentration is converted to an lb/MMBtu emission factor and then multiplied by the dryer heat input to determine the final emission rate in lbs/hr. The rotary sand
dryers will emit CO at a rate of 5.7 lb/hr, determined from Tarmac dryer data sheet. The new dryer CO and VOC emissions were estimated using manufacturer data. Manufacturer data gave a 0.072lb CO/ton of aggregate processed emission factor, and 0.027 lb VOC/ton of aggregate. PM10 and PM
2.5 emissions determined from manufacturer guarantee of 0.01 gr/scf, and a exhaust temperature of 210 F to give an ascf figure of 0.0079 gr/ascf for the first dryer and 0.007 gr/ascf for the second dryer. The dryer air flow rate is multiplied by the gr/ascf figure to determine the mass flow rate, and
is converted into lbs/hr. Because the new dryer is a fluidized bed dryer instead of a rotary dryer, this dryer utilized a higher air flow rate of 50,000 acfm, compared to an air flow rate of 20,955 acfm for the rotary dryer. This higher flow rate for the fluid bed dryer is the cause of the higher estimated emissions of PM10. Emissions factors for all other pollutants were determined from AP-42 Section Tables 1.4-1 through 1.4-4. Roads: AP-42 13.2.2 & DAQ Haul Road Guidance are used to determine emissions. "Haul Road Final Product (HRLDOUT): Inputs of 300 tph, 2,628,000 tpy, an empty truck weight of 22 tons, and
a 43 ton weight load were used, with a haul road length of 1,151 feet. This road is paved and uses watering and vacuum sweeping. This is the main haul road, where incoming shipments of sand are taken into the facility and dropped off at the wet plant. The rest of the haul road is used for shipping

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finished product out of the facility. This haul road connects to the next haul road, HRLOAD. Haul Road - Stockpile #3 (HRLOAD): Inputs of 150 tph, and 1,314,000 tons per year, an empty truck
weight of 22 tons, and a 43 ton weight load were used, with a haul road length of 1,201 feet, using chemical suppressants and watering. Incoming shipments of sand are driven from HRLDOUT to HRLOAD, and the sand is dropped off for processing at the wet plant. The haul road follows a loop before merging back with HRLDOUT. Haul Road - Wet Plant (HRWIP): Inputs of 150 tons per hour, 1,314,000 tons per year, an empty truck weight of 20 tons and a 10 ton load weight were used, with a haul road length of 400 feet, using chemical suppressants and watering. This is the route from storage pile #3 to storage pile #2. After product is deposited at storage pile #2, it is moved via HRDRY to be dried and turned into finished sand product. Haul Road - Dry Plant(HRDRY1 and HRDRY2): Inputs of 150 tons per hour, 1,314,000 tons per year, an empty truck weight of 20 tons and a 10 ton load weight were used with a haul road length of 550 and 200 feet respectively, using chemical suppressants and watering. These are two sections of haul roads between the wet plant exit
and the dry plant entrance. After product exits the dry plant, it is hauled out on HRLDOUT. [Last updated October 1, 2024]
2. Comment regarding Emission Estimations Pt. 2: Material Handling: For two instances of material handling, an input of 300 tph, 2,628,000 tons of sand material per year, 1 transfer point, average wind speed of 8mph, 5% moisture content were
used. These are labeled "Bucket Elevator" and "Loading Wet Plant." For the other three instances, an input of 150 tph, 1,314,000 tons per year, 1 transfer point, average wind speed of 8mph, and 5% moisture content were used. These are labeled "Loading Dry Plant #1" "Loading Dry Plant #2" and "Loading Stockpile #3". AP-42 13.2.4.3 Equation #1 to calculate haul road emissions. Material Processing Equipment: AP-42 Table 11.19.2-2 is used to determine emissions. Inputs of 300 tph and 2,628,000 tpy were used. One crusher, three screens, and 14 conveyor transfer points were used. An additional three conveyor transfer points were used to determine emissions from the
storage silos, and four conveyor transfer points for the dry plant #2 conveyors.
Storage Piles: Storage pile #1 used an input of 1 acre, storage pile #2 used an input of 2 acres, storage pile #3 used an input of 3 acres, and bag house waste pile #1 used 1 an input of 1 acre. Generator: The generator is rated at 415 hp, and uses natural gas as fuel. Uncontrolled emission factors from AP-42 Tables 3.2-1 through 3.2-3 for 4-Stroke Lean Burn Engines were used to estimate emissions for VOCs, SO2, PM, CO2e, and HAPs. Emission rates from NSPS JJJJ Table 1
were used for Non-Emergency SI Lean Burn Natural Gas and LPG engines for NOx, and CO emissions. These give emission rates of 1 g/hp-hr NOx and 2 g/hp-hr CO. Emissions for this engine were recalculated in this modification, which resulted in changes to emission and HAP totals for the engine. Disturbed Area: A total area of 9 acres was used as an input to determine emissions from disturbed area. Emission factors from AP-42 Table 11.9-4 were used to determine emissions from the disturbed area. This is a net decrease from the last approval order, so no BACT analysis is necessary for this source of emissions. Storage Tanks: emissions were determined from AP-42 Chapter 7 with a 154,000-gallon annual throughput and 5,000-gallon capacity. The tank has a length of 27 feet and a diameter of 8 feet. Equations 1-4, 1-13, 1-14, 1-20, 1-21, 1-26, 1-27, and 1-35 are used to determine standing storage
losses and working losses. Table 7.1-7 was used to determine inputs for the equation 1-27. [Last updated August 29, 2024]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant October 31, 2024 Page 21
3. Comment regarding NSPS and MACT applicability: 40 CFR 60 (NSPS) Subpart Kb applies to storage vessels with a capacity greater than or equal to 75
cubic meters that store VOLs (Volatile Organic Liquids). The tank in the AO is less 75 cubic meters (19,800 gallons), with a capacity of 5,000 gallons. Therefore, Subpart Kb does not apply to this facility.
40 CFR 60 (NSPS) Subpart OOO applies to affected facilities in fixed or portable nonmetallic
mineral processing plants. The plant will operate a crusher and screening operation as defined by this subpart and processes a material listed as a nonmetallic mineral in this subpart. Therefore, Subpart OOO applies to this facility. Opacity requirements from this subpart are included in the AO requirements. Initial testing required by this subpart for all affected facilities are listed in requirements. Periodic inspections for water sprays are also included. 40 CFR 60 (NSPS) Subpart UUU applies to each calciner and dryer at a mineral processing plant. Industrial sand is a listed mineral for which processing operations are subject to this regulation. Therefore, NSPS Subpart UUU applies to the dryers at this facility. This subpart requires stack testing for particulate matter from each dryer. 40 CFR 60 (NSPS) Subpart JJJJ applies to owner/operators and manufactures of stationary spark ignition (SI) internal combustion engines (ICE). The engine onsite is a SI ICE and was purchased after July 1, 2008 and is greater than 25 hp. Therefore, Subpart JJJJ applies to the generator.
40 CFR 63 (MACT) subpart ZZZZ applies to owners/operators of stationary RICE at a major or area
sources of HAP emissions. The facility is an area HAP source and the station operates a stationary RICE as defined in this subpart, so Subpart ZZZZ applies to the generator. Compliance with this subpart is met through compliance with NSPS subpart JJJJ. [Last updated July 3, 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. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is subject to 40 CFR 60 (NSPS) and 40 CFR 63 (MACT) regulations. It is not subject to 40 CFR 61 (NESHAP) regulations.
NSPS subpart JJJJ, and MACT subpart ZZZZ exempt a source from Title V requirements, but NSPS OOO and UUU do not. Therefore, Title V is applicable to the facility as an area source. There is no requirement for this source to apply for an initial Title V operating permit under current UDAQ and
EPA rules. The source will be charged applicable Title V fees and Title V funds may be used for inventory and compliance inspections of this source. [Last updated July 3, 2024]
5. Comment regarding Haul Road explanation: There are 5 main haul roads/loader routes at the facility. The names for each haul road are taken from submissions provided by Wildcat. Loader route #3 (HRLOAD) is used by incoming trucks shipping sand into the facility. The shipments of sand are taken to the wet plant loading area. Product is processed in the wet plant and deposited into storage piles #2 and #3. Loader route #2

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant October 31, 2024 Page 22
(HRWIP) is a haul road between wet plant storage piles #2 and #3, and is used to move product to storage pile #3 where it continues along the process. Because product that has been processed in the
wet plant is moved to these two storage piles equally, the haul road between them will only ever require half the total tonnage of the main haul road. Product is transferred via two sections of haul roads (HRDRY1 and HRDRY 2) from the wet plant storage pile #3 to the dry plant entrance. The sand is processed through the dryers at this stage and deposited to the final product area. The final product is shipped out via loader route #1 (HRLDOUT), which is a paved road that exits the facility. The source provided documentation showing the haul load sizes are allowed by UDOT through the shipping company associated with Wildcat. An aerial view of the haul roads at the facility was also provided by Wildcat and is included in the source file. [Last updated October 24, 2024] 6. Comment regarding Dryer emissions and stack testing: The new sand dryer is being permitted with emission rates higher than the previous sand dryer
permitted at the facility. This is due to higher airflow rates inherent to the design of the new fluid bed dryer, and due to the use of manufacturer specific data providing an emission factor to estimate CO and VOC emissions. Other sand dryer have been permitted at other agencies using estimations
from AP-42 chapters 1.4 and 1.5, which give a lower estimated potential to emit. For that reason, stack testing requirements were added to the dryers to ensure the actual emission rates are under the higher estimates for these pollutants. [Last updated October 24, 2024]

Engineer Review N159980004: Wildcat Sand, LLC - Uintah County Sand Processing Plant October 31, 2024 Page 23
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

DAQE-MN159980004A-24

M E M O R A N D U M

TO: Dylan Fredrick, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler

DATE: August 27, 2024

SUBJECT: Modeling Analysis Review for the Notice of Intent for Wildcat Sand, LLC – Uintah
County Sand Processing Plant, Uintah County, Utah
_____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.
I. OBJECTIVE
Wildcat Sand, LLC (Applicant) is seeking an approval order for their Uintah County sand
processing plant located in Uintah County, Utah. The facility receives sandstone that is crushed and
processed in a wet plant to remove fine particulates, before finally being sent through a drying and
separation process. The final sand product is sized to customer specifications and shipped off-site.
The plant is designed to process up to 2,628,000 tons of sand per year.

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility will be in compliance with applicable State and Federal
concentration standards.

II. APPLICABLE RULE(S)

Utah Air Quality Rules:

R307-401-6 Condition for Issuing an Approval Order
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutants in Attainment Areas
R307-410-5 Documentation of Ambient Air Impacts for Hazardous Air Pollutants

III. MODELING METHODOLOGY
A. Applicability
Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. This modeling is part of a modified approval order. The emission rates for PM10, NOx, and Formaldehyde triggered the
requirement to model under R307-410. Modeling was performed by the Applicant.

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

JK
DAQE- MN15998004A-24
Page 2
B. Assumptions

1. Topography/Terrain

The Plant is at an elevation 4975 feet with terrain features that have an affect on
concentration predictions.

a. Zone: 12
b. Approximate Location:
UTM (NAD83): 593455 meters East
4453216 meters North
2. Urban or Rural Area Designation
After a review of the appropriate 7.5 minute quadrangles, it was concluded the area is “rural” for air modeling purposes.
3. Ambient Air
It was determined the Plant boundary used in the AQIA meets the State’s definition of
ambient air.

4. Building Downwash
The source was modeled with the AERMOD model. All structures at the plant were used in
the model to account for their influence on downwash.

5. Meteorology

Five (5) years of off-site surface and upper air data were used in the analysis consisting of
the following:

Surface – Vernal, UT NWS: 2016-2020
Upper Air – Grand Junction, CO NWS: 2016-2020

6. Background
The background concentrations were based on concentrations measured in Roosevelt, Utah.
7. Receptor and Terrain Elevations

The modeling domain used by the Applicant consisted of receptors including property
boundary receptors. This area of the state contains mountainous terrain and the modeling
domain has simple and complex terrain features in the near and far fields. Therefore,
receptor points representing actual terrain elevations from the area were used in the
analysis.
DAQE- MN15998004A-24
Page 3
8. Model and Options

The State-accepted AERMOD model was used to predict air pollutant concentrations under
a simple/complex terrain/wake effect situation. In quantifying concentrations, the
regulatory default option was selected.

9. Air Pollutant Emission Rates

Wildcat Sand, LLC
Source
UTM Coordinates Modeled Emission Rates
Easting Northing PM10
(m) (m) (lb/hr) (tons/yr) hrs/year
SILOTR 593544 4453237 0.002 0.008 8760
DRYER1 593475 4453234 1.420 6.220 8760
DRYER2 593513 4453177 2.990 13.096 8760
HRLDOUT 593793 4453373 0.330 1.445 8760
HRWIP 593292 4453225 0.580 2.540 8760
HRLOAD 593587 4453173 0.900 3.942 8760
SCRNSTK 593472 4453218 0.960 4.205 8760
2NDCRUSH 593368 4453197 0.160 0.701 8760
PILE1 593321 4453146 0.050 0.219 8760
TRNSDP1 593450 4453269 0.090 0.394 8760
TRNSDP2 593452 4453142 0.090 0.394 8760
TRNSWP 593370 4453115 0.180 0.788 8760
TRNSWIP3 593143 4453249 0.090 0.394 8760
PILE2 593325 4453264 0.140 0.613 8760
PILE3 593127 4453180 0.250 1.095 8760
CONVYRS 593366 4453204 0.190 0.832 8760
SILOS 593531 4453230 0.000 0.002 8760
FPGENSET 593232 4453298 0.030 0.131 8760
DISAREA 593441 4453072 0.368 1.614 8760
CONVDRY2 593497 4453170 0.000 0.001 8760
BHWASTE 593454 4453225 0.010 0.044 8760
HRDRY1 593296 4453231 0.800 3.504 8760
HRDRY2 593425 4453202 0.290 1.270 8760
Total 9.921 43.454

DAQE- MN15998004A-24
Page 4
Wildcat Sand, LLC
Source
UTM Coordinates Modeled Emission Rates
Easting Northing NOx
(m) (m) (lb/hr) (tons/yr) hrs/year
DRYER1 593475 4453234 5.40 23.65 8760
DRYER2 593513 4453177 5.40 23.65 8760
FPGENSET 593232 4453298 2.13 9.33 8760
OLDGEN 593509 4453191 0.92 4.03 8760

Total 13.8501 60.6633
Kinder Morgan Altamont East Compressor Station
Source
UTM Coordinates Modeled Emission Rates
Easting Northing NOx
(m) (m) (lb/hr) (tons/yr) hrs/year
KMEAST 564020 4467280 78.19 342.47 8760
Total 78.1904 342.4740
Wildcat Sand, LLC
Source
UTM Coordinates Modeled Emission Rates
Easting Northing Formaldehyde
(m) (m) (lb/hr) (tons/yr) hrs/year
DRYER1 593475 4453234 0.0030 0.013 8760
DRYER2 593513 4453177 0.0028 0.012 8760
FPGENSET 593232 4453298 0.0000 0.000 8760
Total 0.0058 0.0254

DAQE- MN15998004A-24
Page 5
10. Source Location and Parameters
Source Type
Source Parameters
Elev, Ht Temp Flow Dia Sigma-
Y
Sigma-
Z X-Dim Y-
Dim Area
(ft) (m) (ft) (K) (m/s) (m) (m) (m) (m) (m) (m^2)
SILOTR POINT 4966.9 9.1 30.0 0 5.18 0.51 1
DRYER1 POINT 4968.8 9.1 30.0 350 14.45 1.52 1
DRYER2 POINT 4968.5 14.1 46.2 408 26.83 1.02 1
HR2NDEXIT LINE_VOLUME 1
HRLDOUT LINE_VOLUME 1
HRWIP LINE_VOLUME 1
HRLOAD LINE_VOLUME 1
SCRNSTK POINT 4969.1 9.1 29.8 0 2.52 1.89 1
2NDCRUSH VOLUME 4972.3 4.9 16.0 0.14 0.43 0.6106 1
PILE1 AREA_POLY 4974.4 26.5 87.0 2374.3
TRNSDP1 VOLUME 4969.2 4.9 16.0 0.70 0.71 3.0014 1
TRNSDP2 VOLUME 4970.5 4.9 16.0 0.70 0.71 3.0014 1
TRNSWP VOLUME 4973.4 4.9 16.0 0.50 0.50 2.15 1
TRNSWIP3 VOLUME 4978.1 4.9 16.0 0.35 0.71 1.5179 1
PILE2 AREA_POLY 4972.7 18.3 60.0 6150.5
PILE3 AREA_POLY 4976.7 18.3 60.0 11249.7
CONVYRS VOLUME 4972.3 4.6 15.0 1.50 1.50 6.45 1
SILOS POINT 4967.4 3.0 9.8 0 5.18 0.51 1
FPGENSET POINT 4974.7 2.7 8.8 913 7.65 0.30 1
DISAREA AREA_POLY 4977.5 0.0 0.0 72912.6
CONVDRY2 VOLUME 4969.0 4.6 15.0 1.42 1.50 6.1017 1
BHWASTE AREA_POLY 4969.5 1.5 5.0 76.9
HRDRY LINE_VOLUME 1
OLDGEN POINT 4967.8 3.3 10.8 913 7.65 0.30 1
KMEAST POINT 6107.3 9.5 31.2 700 21.19 0.31 1

IV. RESULTS AND CONCLUSIONS

A. National Ambient Air Quality Standards
The below table provides a comparison of the predicted total air quality concentrations with the
NAAQS. The predicted total concentrations are less than the NAAQS.

DAQE- MN15998004A-24
Page 6
Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
NO2
1-
Hour 29.4 7.5 84.3 13.4 127.1 188 67.61%

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-
Hour 97.00 5 50.8 0.0 147.8 150 98.5%

B. Toxic Screening Levels

The model predicted all HAP concentrations to be less than their respective UDAQ - Toxic
Screening Levels (TSL) for each scenario. Based on these results, no further analysis is
required.

Pollutant Period
Prediction TSL Percent
(μg/m3) (μg/m3)
Formaldehyde 1-Hour 0.048 37 0.1%

JK:jg

Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand - Roosevelt Plant
Sand Plant
Emission Calculations
Facility PTE - 8760 hr/yr
PTE (lb/hr) PTE (lb/hr)
Emission
Type Unit
Particulate
Matter <10μ
(PM10)
Nitrogen Oxides
(NOX)
Particulate
Matter <10μ
(PM10)
Particulate
Matter <2.5μ
(PM2.5)
Nitrogen Oxides
(NOX)
Sulfur Oxides
(SOX)
Carbon
Monoxide
(CO)
Volatile Organic
Compounds
(VOC)
Lead
Compounds
Hazardous Air
Pollutants
(HAPs)
Point 01 Bucket Elevator Transfer to Silo** SILOTR 0.0018 0.0079 0.0012
Point 02 Dryer #1 Stack with Baghouse and Cyclone DRYER1 1.0700 4.6900 4.6900
Point 02 Dryer #1 Combustion DRYER1 4.7800 20.9400 0.0000 24.9700 1.9200 0.0001 0.3297
Point 03 Dryer #2 Stack with Baghouse and Cyclone DRYER2 2.9900 13.0900 13.0900
Point 03 Dryer #2 Combustion DRYER2 3.7000 16.2100 0.1000 47.3000 17.7400 0.0001 0.3063
Fugitive 04 Haul Road - Additional Exit from Plant HR2NDEXIT 000
Fugitive 05 Haul Road - Final Product HRLDOUT 0.3300 1.4500 0.1500
Fugitive 06 Haul Road - WIP Pile #2 to WIP Pile #3 HRWIP 0.5800 2.5500 0.2500
Fugitive 07 Haul Road - Haul Truck to Wet Plant HRLOAD 0.9000 3.9400 0.3900
Point 08 J & H Screen Baghouse Stack* SCRNSTK 0.9600 4.2200 4.2200
Fugitive 09 Secondary Crushing 2NDCRUSH 0.1600 0.7100 0.1300
Fugitive 10 Stockpile Pre-Wash Plant PILE1 0.0500 0.2300 0.1200
Fugitive 11 Truck Unloading to Dry Plant #1 TRNSDP1 0.0900 0.3900 0.0600
Fugitive 12 Truck Unloading to Dry Plant #2 TRNSDP2 0.0900 0.3900 0.0600
Fugitive 13 Truck Unloading to Wet Plant TRNSWP 0.1800 0.7900 0.1200
Fugitive 14 Truck Unloading to WIP Pile #3 TRNSWIP3 0.0900 0.3900 0.0600
Fugitive 15 WIP Stockpile #2 PILE2 0.1400 0.5900 0.3100
Fugitive 16 WIP Stockpile #3 PILE3 0.2500 1.0900 0.5600
Fugitive 17 Existing Conveyors and Drop Points CONVYRS 0.1900 0.8500 0.2400
Point 18 Unloading Sand Storage Silos #1 - #3** SILOS 0.0004 0.0018 0.0005
Point 19 Engine - Filter Press[1]FPGENSET 0.0300 0.9100 0.1300 0.1300 4.0100 0.0100 8.0100 1.5000 0.0000 0.9200
Fugitive 20 Disturbed Area DISAREA 0.3900 1.7100 0.2600
Fugitive 21 New Dry Plant #2 Conveyors** CONVDRY2 0.0003 0.0012 0.0003
Fugitive 22 Enclosed Baghouse Waste Collection Area *** BHWASTE 0.0100 0.0500 0.0250
Fugitive 23a Haul Road - Loader to Dry Plant 1 HRDRY1 0.8000 3.5100 0.3500
Fugitive 23b Haul Road - Loader to Dry Plant 2 HRDRY2 0.2900 1.2700 0.1300
Fugitive 24 Fuel Oil Storage Tank TANK1 0.0021
5.05 9.39 22.14 22.13 41.16 0.11 80.28 21.16 0.00 1.56
4.54 0.00 19.91 3.22 0.00 0.00 0.00 0.00 0.00 0.00
9.59 9.39 42.05 25.35 41.16 0.11 80.28 21.16 0.00 1.56
[1] Tier 2 Natural Gas Engine meets 40 CFR 60.4223(e) and Table 1 emission standards
*Based on fabric filter baghouse Manufacturer Gaurantee of 0.005 gr/dscf
** All product handling post dryers are controlled with a dust collector and silo bin vent filter with a control efficiency >99%
*** Baghouse waste is in an enclosed building
Facility PTE (tpy)
Description
Point
Fugitive
Facility PTE
Dylan Frederick <[e-mail]>
Wildcat Sand Information Request 7/9/24
Dylan Frederick <[e-mail]>Wed, Sep 25, 2024 at 4:56 PM
To: Eric Sturm <[e-mail]>
Cc: Alan Humpherys <[e-mail]>, Matt Hyita <[e-mail]>, Sydney Stauffer - ARC <[e-mail]>
Eric,
Thanks for getting these back to me. I'll make sure to look at it and if there's any other changes I need to make I'll try to have them done or discussed with Alan the
morning before our meeting. Thanks for scheduling the meeting as well.
On Wed, Sep 25, 2024 at 4:34 PM Eric Sturm <[e-mail]> wrote:
Dylan,

We are providing some brief comments as aached in Word tracked changes, comments, and notes below. We have not seen a calendar invite yet for next
Tuesday, so we will send a Teams meeng for 3pm. If that me does not work for you and Alan, please propose another me.

Notes:

Wildcat’s mailing address is updated.
II.B.1.a is clarified to 2,628,000 tons produced or dried. There is no limit on wash plant processing, so we understand the annual/12 mo. roll tonnage
limit to be aimed at the dryers and dry plant.
II.B.5.c is commented for both dryers.
Dryer 1 was not modified or included in the NOI; we are curious if the limits added on combuson gases were intenonal.
Dryer 2 limits for CO and VOC seem rather unnecessary on a number of levels given that they are vendor guaranteed rates, and they pose no
risk (or harm) from a source classificaon level or ambient air impact concern.

We can be free to discuss the bulleted notes above and aached comments any me in advance of next Tuesday’s meeng with Alan. Feel free to give me a
call or reach out.

10/11/24, 3:56 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-8580427276899100762&simpl=msg-a:r-8580427276899100762 1/46
Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, September 24, 2024 4:37 PM
To: Eric Sturm <[e-mail]>
Cc: Alan Humpherys <[e-mail]>; Ma Hyita <[e-mail]>; Sydney Stauffer - ARC <[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

Here is an unofficial draft of where I'm at currently. Again, this hasn't been signed off on by management as of yet but this version has addressed a number of the
comments the last review gave. Alan isn't in until October 1st, I'm free most of the day except 10 AM, but I know Alan's a bit busier, I think he may be open 3 or 4
PM on that day depending on how much he has to catch up on.

On Tue, Sep 24, 2024 at 10:19 AM Eric Sturm <[e-mail]> wrote:
Dylan,

Let’s see the dra today and go from there. We will tentavely hold off on meeng in-person assuming the latest dra is provided today.

10/11/24, 3:56 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-8580427276899100762&simpl=msg-a:r-8580427276899100762 2/46
Given we are sll waing on Alan, can you please set up a 30-minute Teams meeng with all of us for Monday, September 30?

Pick any me that works for you and Alan. We will make it work on our end.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Monday, September 23, 2024 5:20 PM
To: Eric Sturm <[e-mail]>
Cc: Alan Humpherys <[e-mail]>; Ma Hyita <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

I should be able to meet Friday too if you can't make it Wednesday. Unfortunately I still haven't gotten Alan's sign off so we won't be able to get a draft to you
this week. What I was referring to was the next draft I'd send to Alan. I can wait for Wednesday afternoon to send the next version out to Alan if you'd like.

On Mon, Sep 23, 2024 at 4:00 PM Eric Sturm <[e-mail]> wrote:
Dylan,

10/11/24, 3:56 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-8580427276899100762&simpl=msg-a:r-8580427276899100762 3/46
Wednesday aernoon could possibly work for us; Ma and I will confirm tomorrow. Would Friday work for you?

Both meengs could be avoided if we see a dra for signature. It sounds like one should be coming today or tomorrow.

Please let us know.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Monday, September 23, 2024 11:30 AM
To: Eric Sturm <[e-mail]>
Cc: Alan Humpherys <[e-mail]>; Ma Hyita <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

I can meet whenever you'd like this week, I should have an updated draft out by the end of tomorrow. I'll be in the office Wednesday, so that day would work
best for me for an in person meeting.

On Mon, Sep 23, 2024 at 10:23 AM Eric Sturm <[e-mail]> wrote:
10/11/24, 3:56 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-8580427276899100762&simpl=msg-a:r-8580427276899100762 4/46
Alan,

Are you in today? Can Alan get us a drat permit for review before or while you’re out of the office?

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Alan Humpherys <[e-mail]>
Sent: Monday, September 23, 2024 11:17 AM
To: Eric Sturm <[e-mail]>
Cc: Dylan Frederick <[e-mail]>; Ma Hyita <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,
I am going to be out of the office for the rest of this week. You can meet and talk with Dylan.

Thanks,
Alan

On Mon, Sep 23, 2024 at 10:01 AM Eric Sturm <[e-mail]> wrote:
10/11/24, 3:56 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-8580427276899100762&simpl=msg-a:r-8580427276899100762 5/46
Dylan, Alan,

Ma Hyita and I would like to meet with you and Alan at your offices no later than Friday. All quesons have been asked and answered for some
me. There is no reason for any further unnecessary delay on Wildcat’s Approval Order.

What is a good day/me for you both to meet in person this week?

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Eric Sturm <[e-mail]>
Sent: Wednesday, September 18, 2024 11:20 AM
To: 'Dylan Frederick' <[e-mail]>; 'Alan Humpherys' <[e-mail]>
Cc: 'Ma Hyita' <[e-mail]>; 'Sydney Stauffer - ARC' <[e-mail]>
Subject: RE: Wildcat Sand Informaon Request 7/9/24

Dylan,

So, I believe this was asked and answered already. The incorrect manufacturer ppm data you are referencing below for CO and VOC was
corrected in the record several months back. That said, if you want to use the lbs/ton of aggregate data, I suppose that is okay.

10/11/24, 3:56 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-8580427276899100762&simpl=msg-a:r-8580427276899100762 6/46
The spreadsheet you sent “Copy of 03 Sand Dryer 2_v5” is fine. Let’s go with that for sake of me.

Can we see the final dra permit for review and signature?

The last dra permit we saw was February 7. We are almost at eight months of management review. We would like to review the next version
and move to public noce.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, September 17, 2024 5:40 PM
To: Alan Humpherys <[e-mail]>
Cc: Eric Sturm <[e-mail]>; Ma Hyita <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

I ran into an issue with the dryer calculations in the last review I got back. Currently the new dryer CO emissions are calculated using AP-42 emission
factors, however, because the manufacturer provided emission data for CO and VOCs, that is the most accurate information we have for the dryer and
we should be calculating emissions based on that data. The manufacturer gave an estimate of 450 ppm CO as well as a "0.072 lbs/ton of aggregate"
emission factor, and 105 ppm VOC and 0.027lbs/ton of aggregate for VOCs. Based on that the new dryer should have higher CO and VOC emissions.
10/11/24, 3:56 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-8580427276899100762&simpl=msg-a:r-8580427276899100762 7/46
Because of the 80 ppm NOx limit we should adjust the NOx emission calculations down as well. I've attached a spreadsheet that has a potential
example of how the emissions could be adjusted. If you have any more specific data or an argument for what the emission rate should be for CO and
VOCs please let me know, because I know the older dryer used manufacturer data to calculate CO emissions as well.

On Tue, Sep 17, 2024 at 12:27 PM Alan Humpherys <[e-mail]> wrote:
Eric,

Dylan is in the office today. You can reach out to him.

Thanks,
Alan

On Mon, Sep 16, 2024 at 3:35 PM Eric Sturm <[e-mail]> wrote:
Alan,

We tried calling Dylan last Friday to follow up. Can we be of any assistance here?

We appreciate your aenon to this maer.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
10/11/24, 3:56 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-8580427276899100762&simpl=msg-a:r-8580427276899100762 8/46
Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Truck Information
Empty Truck Weight 22 tons
Weight of Load 43 tons
Loaded Truck Weight 65 tons
Haul Road Information
Haul Road One-Way Length 1,563 feet
Hourly Vehicle Miles Traveled 4.1 miles
Annual Vehicle Miles Traveled 36,184 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.22 0.90 3.94
PM2.5 0.218 0.022 0.09 0.39
Haul Roads
AP-42 13.2.2 & DAQ
Haul Road Guidance
Paving with Sweeping & Watering - (90% control)
Page 1 of 1
Version 1.0
November 29, 2018
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand - Roosevelt Plant
Sand Plant
Emission Calculations
Facility PTE - 8760 hr/yr
PTE (lb/hr)PTE (lb/hr)
Emission
Type Unit
Particulate
Matter <10μ
(PM10)
Nitrogen Oxides
(NOX)
Particulate
Matter <10μ
(PM10)
Particulate
Matter <2.5μ
(PM2.5)
Nitrogen Oxides
(NOX)
Sulfur Oxides
(SOX)
Carbon
Monoxide
(CO)
Volatile Organic
Compounds
(VOC)
Lead
Compounds
Hazardous Air
Pollutants
(HAPs)
Point 01 Bucket Elevator Transfer to Silo**SILOTR 0.0018 0.0079 0.0012
Point 02 Dryer #1 Stack with Baghouse and Cyclone DRYER1 1.0700 4.6900 4.6900
Point 02 Dryer #1 Combustion DRYER1 4.7800 20.9400 0.0000 24.9700 1.9200 0.0001 0.3297
Point 03 Dryer #2 Stack with Baghouse and Cyclone DRYER2 2.9900 13.0900 13.0900
Point 03 Dryer #2 Combustion DRYER2 4.4400 19.4500 0.1000 13.6300 1.7800 0.0001 0.3063
Fugitive 04 Haul Road - Additional Exit from Plant HR2NDEXIT 0 0 0
Fugitive 05 Haul Road - Final Product HRLDOUT 0.3300 1.4500 0.1500
Fugitive 06 Haul Road - WIP Pile #2 to WIP Pile #3 HRWIP 0.5800 2.5500 0.2500
Fugitive 07 Haul Road - Haul Truck to Wet Plant HRLOAD 0.9000 3.9400 0.3900
Point 08 J & H Screen Baghouse Stack*SCRNSTK 0.9600 4.2200 4.2200
Fugitive 09 Secondary Crushing 2NDCRUSH 0.1600 0.7100 0.1300
Fugitive 10 Stockpile Pre-Wash Plant PILE1 0.0500 0.2300 0.1200
Fugitive 11 Truck Unloading to Dry Plant #1 TRNSDP1 0.0900 0.3900 0.0600
Fugitive 12 Truck Unloading to Dry Plant #2 TRNSDP2 0.0900 0.3900 0.0600
Fugitive 13 Truck Unloading to Wet Plant TRNSWP 0.1800 0.7900 0.1200
Fugitive 14 Truck Unloading to WIP Pile #3 TRNSWIP3 0.0900 0.3900 0.0600
Fugitive 15 WIP Stockpile #2 PILE2 0.1400 0.5900 0.3100
Fugitive 16 WIP Stockpile #3 PILE3 0.2500 1.0900 0.5600
Fugitive 17 Existing Conveyors and Drop Points CONVYRS 0.1900 0.8500 0.2400
Point 18 Unloading Sand Storage Silos #1 - #3**SILOS 0.0004 0.0018 0.0005
Point 19 Engine - Filter Press[1]FPGENSET 0.0300 0.9100 0.1300 0.1300 4.0100 0.0100 8.0100 1.5000 0.0000 0.9200
Fugitive 20 Disturbed Area DISAREA 0.3900 1.7100 0.2600
Fugitive 21 New Dry Plant #2 Conveyors**CONVDRY2 0.0003 0.0012 0.0003
Fugitive 22 Enclosed Baghouse Waste Collection Area ***BHWASTE 0.0100 0.0500 0.0250
Fugitive 23a Haul Road - Loader to Dry Plant 1 HRDRY1 0.8000 3.5100 0.3500
Fugitive 23b Haul Road - Loader to Dry Plant 2 HRDRY2 0.2900 1.2700 0.1300
Fugitive 24 Fuel Oil Storage Tank TANK1 0.0021
5.05 10.13 22.14 22.13 44.40 0.11 46.61 5.20 0.00 1.56
4.54 0.00 19.91 3.22 0.00 0.00 0.00 0.00 0.00 0.00
9.59 10.13 42.05 25.35 44.40 0.11 46.61 5.20 0.00 1.56
[1] Tier 2 Natural Gas Engine meets 40 CFR 60.4223(e) and Table 1 emission standards
*Based on fabric filter baghouse Manufacturer Gaurantee of 0.005 gr/dscf
** All product handling post dryers are controlled with a dust collector and silo bin vent filter with a control efficiency >99%
*** Baghouse waste is in an enclosed building
Facility PTE (tpy)
Description
Point
Fugitive
Facility PTE
Wildcat Sand Air Dispersion Modeling Submitted on 8/2/2024
Wildcat Sand Plant PM10 Modeling Results - 8/1/2024 NOTE:NAAQS for PM10 24-hour can not exceed 150 μg/m3
NAAQS Exceedance
PM 10 - 24-hour - 6th High Comparative receptors
2016-2020 μg/m3 X UTM Y UTM Significant
ALL 146.9309 593803.42 4453126.76
ALL_NOBG 96.08881 593803.42 4453126.76
WILDCAT 96.08881 593803.42 4453126.76
SILOTR 0.01303 593815.76 4453213.92
DRYER1 3.98592 593803.42 4453174.01
DRYER2 2.98417 593613.87 4453457.49
DRYERS 3.99978 593803.42 4453174.01
HRLDOUT 15.20839 593803.42 4453363.00
HRWIP 17.64605 592997.85 4453236.72
HRLOAD 23.71588 593803.42 4453079.51
HRDRY 22.15067 593803.42 4453174.01
HRDRY1 17.77250 593803.42 4453174.01
HRDRY2 8.57482 593803.42 4453079.51
HROADS 57.15670 593803.42 4453126.76
SCRNSTK 11.20425 593803.42 4453079.51
CRUSH 3.71517 593803.42 4453126.76
PILE1 0.12555 593165.76 4452263.92
PILE2 0.38642 593015.76 4453763.92
PILE3 1.09468 592997.85 4453236.72
PILES 1.20169 592997.85 4453236.72
TRNSDP1 2.57272 593815.76 4453213.92
TRNSDP2 2.80979 593803.42 4453079.51
TRNSWP 4.28137 593803.42 4453032.26
TRNSWIP3 4.31626 592997.85 4453236.72
CONVYRS 4.33956 593803.42 4453126.76
SILOS 0.00354 593803.42 4453174.01
FPGENSET 0.17257 593265.76 4453463.92
DISAREA 12.93241 593803.42 4453126.76
CONVDRY2 0.01088 593803.42 4453126.76
BHWASTE 0.42696 593803.42 4453174.01
Specified Receptors
ALL Not Applicable ** Significance levels for 24-hour PM10 are 5.0 μg/m3
Wildcat Sand PM10 (Project) Modeling
Pollutant Averaging Period
NAAQS Level
μg/m3
Modeled Impact
μg/m3
Background
μg/m3
Total w/
Background
* μg/m3
PM10 24-hour 150 96.09 Monthly 146.93
* Background data from the Utah Division of Air Quality - Roosevelt Site - monthly values.
Prepared by Air Regulations Consulting, LLC Page 1 of 1
Production Rates
Hourly Rates 150 tons/hourAnnual Production 1,314,000 tons/year
Loader Information
Empty Loader Weight 20 tons
Weight of Load 10 tonsLoaded Loader Weight 30 tons
Loader Route\ Information
Loader Route One-Way Length 400 feet
Hourly Vehicle Miles Traveled 2.3 miles
Annual Vehicle Miles Traveled 19,909 milesType of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 1.71 0.26 0.58 2.55
PM2.5 0.171 0.026 0.06 0.25
Loader Routes
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
Page 1 of 1 Version 1.0
November 29, 2018
Wind Erosion of Exposed Area
Total Area of Distrubed Ground 9 acres
Emission Factors & Distribution
TSP Emission Factor 0.38
PM10 Content 50%
PM2.5 Content 7.5%
Pollutant
Emission
Factor
(tons/acre-year)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)
PM10 0.19 0.39 1.71
PM2.5 0.03 0.06 0.26
Disturbed Ground
Reference
AP-42 Section 13.2.5.3
AP-42 Table 11.9-4
Page 1 of 1 Version 1.0
November 29, 2018
Production Rates
Hourly Rates 150 tons/hourAnnual Production 1,314,000 tons/year
Loader Information
Empty Loader Weight 20 tons
Weight of Load 10 tonsLoaded Loader Weight 30 tons
Loader Route\ Information
Loader Route One-Way Length 550 feet
Hourly Vehicle Miles Traveled 3.1 miles
Annual Vehicle Miles Traveled 27,375 milesType of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 1.71 0.26 0.80 3.51
PM2.5 0.171 0.026 0.08 0.35
Loader Routes
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
Page 1 of 1 Version 1.0
November 29, 2018
Production Rates
Hourly Rates 150 tons/hourAnnual Production 1,314,000 tons/year
Loader Information
Empty Loader Weight 20 tons
Weight of Load 10 tonsLoaded Loader Weight 30 tons
Loader Route\ Information
Loader Route One-Way Length 200 feet
Hourly Vehicle Miles Traveled 1.1 miles
Annual Vehicle Miles Traveled 9,955 milesType of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 1.71 0.26 0.29 1.27
PM2.5 0.171 0.026 0.03 0.13
Loader Routes
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
Page 1 of 1 Version 1.0
November 29, 2018
Dylan Frederick <[e-mail]>
Wildcat Sand Information Request 7/9/24
Eric Sturm <[e-mail]>Wed, Sep 4, 2024 at 10:12 AM
To: Dylan Frederick <[e-mail]>
Cc: Alan Humpherys <[e-mail]>, Matt Hyita <[e-mail]>, Sydney Stauffer - ARC
<[e-mail]>
Dylan,

There are no updates to submit for Wildcat’s BACT. As the DAQ has it, we already evaluated an 80 ppm NOx from the
dryer burner, and it did not come out as economically feasible on a cost per ton basis. That said, the DAQ believes 80
ppm to be on par with similar dryers (not fluid bed) at similar sites.

Wildcat is okay accepng the 80 ppm, as explained to you on August 21. There is nothing new to submit. Our BACT
analysis evaluated 96 ppm, 80 ppm, and 36 ppm for NOx. If the DAQ wants 80 ppm despite the analysis showing 96
ppm as BACT, Wildcat is not choosing to negoate on this maer.

We gave you approval to move forward over two weeks ago with 80 ppm. You did not ask for anything at that me,
and again, nothing further is needed on your end.

Please let us know when we can see the dra permit.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, September 4, 2024 11:00 AM
To: Eric Sturm <[e-mail]>
Cc: Alan Humpherys <[e-mail]>; Ma Hyita <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:1809282608709642…1/23
Eric,

I've incorporated the new modeling memo into the permit and made updates per the last management review of the
permit. However, I was going through our emails and I'm realizing I never got the addendum to the dryer BACT that was
mentioned on August 2nd. Do you have that submission somewhere?

On Tue, Sep 3, 2024 at 1:09 PM Eric Sturm <[e-mail]> wrote:
Dylan,

We just called and le a voicemail. A call back or email update for Wildcat’s permit would be much appreciated.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Eric Sturm <[e-mail]>
Sent: Monday, August 26, 2024 4:12 PM
To: 'Dylan Frederick' <[e-mail]>
Cc: 'Alan Humpherys' <[e-mail]>; 'Ma Hyita' <[e-mail]>; Sydney Stauffer -
ARC <[e-mail]>
Subject: RE: Wildcat Sand Informaon Request 7/9/24

Dylan,

Is there an update here? Also, if you can, I think it makes the most sense to finish the dra Approval Order
assuming modeling will be fine. I believe there was plenty of room and the changes decreased the impacts.

Eric Sturm
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:1809282608709642…2/23
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, August 21, 2024 4:15 PM
To: Eric Sturm <[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

This project is next in line for review by our modeling team.

On Wed, Aug 21, 2024 at 1:34 PM Dylan Frederick <[e-mail]> wrote:
Eric,

My apologies, I was speaking generally about setting limits, I agree the 80 ppm option makes sense in this context if
you accept that limit and can get the equipment that meets that limit.

On Wed, Aug 21, 2024 at 1:30 PM Eric Sturm <[e-mail]> wrote:
Dylan,

The 80 ppm is not arbitrary. In the BACT analysis, it was next step level down for the Megastar ppm levels. In
addion, it is not arbitrary because it is a BACT limit for a similar unit currently on public noce.

Wildcat’s inial complete NOI is aged to 14 months now. Hopefully the modeling group already completed
their review. Otherwise, it should be at the top of their list.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:1809282608709642…3/23
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, August 21, 2024 2:17 PM
To: Eric Sturm <[e-mail]>
Cc: Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC <[e-mail]>;
Ma Hyita <[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

Regarding the modeling, I haven't gotten an updated memo from our modeling team yet. I will check in with them
to see where it is at. As for the dryer NOx rates, we would want to set the limit at what makes sense for the
equipment given the supporting documentation we've received. If we just set an arbitrary limit then we risk the
source not being able to meet the limit and having to come back and modify the approval order all over again. I
planned on going over the last information received tomorrow and friday, I will get you a more detailed response
then to ensure we've covered everything. Thanks for checking in, I'll be in contact by the end of the week.

Dylan

On Wed, Aug 21, 2024 at 11:20 AM Eric Sturm <[e-mail]> wrote:
Dylan,

It has been close to 3 weeks for the modeling team to review. We assume all is approved, or did they have
any quesons?

Addionally, regarding the NOx rate, the DAQ earlier menoned that Wildcat could accept a lower than
BACT rate of 80 ppm to expedite the final processing. This appears to be the route that a similar sand dryer
site in Utah accepted in their public noce documents (except they have a rotary dryer). Assuming that is
sll an opon for Wildcat, as the DAQ allowed for their competors, then I think Wildcat will opt for that as
well.

If you could confirm, and also let us know status on how soon we could see a dra permit, that would be
great.

Thanks again for your aenon to this project.

Much appreciated.
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:1809282608709642…4/23

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Friday, August 2, 2024 5:15 PM
To: Eric Sturm <[e-mail]>
Cc: Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>; Ma Hyita <[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

We've received your email, I've forwarded these files to the modeling team.

On Fri, Aug 2, 2024 at 10:22 AM Eric Sturm <[e-mail]> wrote:
Good morning, Dylan,

We are pung a read receipt on the email due to the modeling files in zip. As expected, the PM10
impacts went down from the previous modeling. Please see the aached results table and modeling
files which confirm the results.

Notably, we also noced an error in the PTE last shared with the DAQ. HRLOAD was previously calc’d as
unpaved but should have been considered paved. This is corrected and updated in the 3rd and 4th
aachments as well.

For the BACT, the discussion from July 16 (and follow-up emails July 17/18) indicated that a comparison
of Wildcat’s fluid-bed lb/hr for NOx, and gas usage per ton dried, to other recently permied rotary
dryers would suffice. We have that as a brief addendum. This will be provided separately.

Please confirm receipt of this email, and that updated modeling addresses the DAQ’s request from July
16.
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:1809282608709642…5/23

Thank you.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, July 18, 2024 5:48 PM
To: Eric Sturm <[e-mail]>
Cc: Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>; Ma Hyita <[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

Thanks for the update. I don't see any issues with the updated calculaons and the BACT analysis for the
haul roads should be complete. I will look forward to seeing updated modeling and the dryer BACT
update.

On Thu, Jul 18, 2024 at 4:15 PM Eric Sturm <[e-mail]> wrote:
Dylan,

In follow-up from Tuesday’s call, we understand that DAQ agrees with the aached haul road
calculaons. As DAQ requested, ARC is running the PM10 modeling with the updated emission rates.

Also, we are draing a BACT addendum to address Alan’s concerns noted on the call. The concerns
were related to the difference in the fluid bed burner NOx ppms as compared to other similar projects
recently permied in the state. We plan on showing the gas savings and similar lb/hr rates as
compared to these other/similar projects.

We will be in touch tomorrow, hopefully with some model results and updated analyses.
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:1809282608709642…6/23

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Eric Sturm <[e-mail]>
Sent: Monday, July 15, 2024 1:25 PM
To: 'Dylan Frederick' <[e-mail]>
Cc: 'Alan Humpherys' <[e-mail]>; 'Sydney Stauffer - ARC'
<[e-mail]>; 'Ma Hyita' <[e-mail]>
Subject: RE: Wildcat Sand Informaon Request 7/9/24

Dylan,

Please see aached. From review of the roads and loaders with Wildcat and DAQ last week, we
updated the calculaons. We revised the loader weights as requested, but again, we would caveat
that Wildcat did not submit any loader weight modificaons in the NOI. We sll believe this not
applicable, and the previous weights were correct, but to be conservave and show how the
emissions may change with a more tradional loader (20t empty, 30t full), the aachments are being
provided.

I think some confusion was coming from which hopper would be loaded. There are two; one for Dryer
1 and another for Dryer 2. These are now clarified as HRDRY1 and HRDRY2.

In review with Wildcat, HR2NDEXIT was eliminated, and the plans for WIP pile 3 and disturbed area
were ghtened. The lengths are directly in the calculaons and updated overhead. Also, to show the
sitewide PTE with these updates, we are providing the full table for all units. The net change is a slight
decrease in PM2.5 (-0.03 tpy) and slight increase in PM10 (0.84 tpy).

We will plan to review with you at 3:30 pm today. Hope this all makes sense now, but to make sure,
let’s connect quick on Teams.
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:1809282608709642…7/23

Thanks

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Eric Sturm <[e-mail]>
Sent: Friday, July 12, 2024 11:24 AM
To: 'Dylan Frederick' <[e-mail]>; 'Alan Humpherys' <[e-mail]>; 'Sydney
Stauffer - ARC' <[e-mail]>; 'Ma Hyita' <[e-mail]>
Subject: RE: Wildcat Sand Informaon Request 7/9/24

Dylan,

We understand your point of view. Ours is that Wildcat did not propose any change to the loader
equipment, so the quesoning here seems like an unnecessary delay. Nonetheless, because it is being
asked by the DAQ, we will address it.

We should certainly keep the meeng today. The calculaons will not be difficult, but Wildcat cannot
afford to connue this game of email tennis. We want to make sure we are addressing the request in
full and keep everything moving towards public noce.

I will be on Teams at 2:00 pm today. It was made as a reoccurring meeng unl the DAQ’s quesons
are addressed. We are more than happy to add Alan to the call when he returns.

Sincerely.

Eric Sturm
ARC | Principal, Sr. Consultant
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:1809282608709642…8/23
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Friday, July 12, 2024 10:09 AM
To: Eric Sturm <[e-mail]>; Alan Humpherys <[e-mail]>; Sydney
Stauffer - ARC <[e-mail]>; Ma Hyita <[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

The applicaon did ask to change the loader routes, which is what I'm asking about. The calculaons
show 2,628,000 and 1,314,000 tons going over the two loader routes I'm discussing. The last
permit issue limited producon for the facility to 950,000 tons annually. This is an increase in the
materials going over the haul roads from the last approval order.

Also I was wondering if it would be beer to hold off meeng unl Alan returns. We might be able to
address these issues quicker with him here and get the applicaon where it needs to be to be
approved.

On Thu, Jul 11, 2024 at 4:46 PM Eric Sturm <[e-mail]> wrote:
Dylan,

We were not asking you to forgo any review. Like we said, the numbers we provided previously for
the loaders were correct. This applicaon did not request to modify the loaders, so there is no
reason for DAQ or Wildcat to review those.

The FEECO arcle is misleading and needs context. I probably should not have sent that one. But,
as you menoned, the Thermal Kinecs leer should address the #2 in itself.

I would like to chat at 2:00 tomorrow. We disagree that any further haul road calc is needed.

I will send an invite for a 1to1 tomorrow. We can play with calcs if you want, but again, we do not
think that review is within the purview or scope of the requested modificaon.
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:1809282608709642…9/23

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, July 11, 2024 5:28 PM
To: Eric Sturm <[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

There's several issues that haven't been addressed. The main issue is that no calculaons were
provided to support the claims given here. I can't just take sources at their word that they are
reducing emissions with the equipment they are proposing, I need a record to verify your claims.
The haul road calculaons are confusing for me, as yesterday in the call I thought you'd indicated
you'd provide updated calculaons that showed the loader routes with the proper weights, while
removing the emissions from the 'oponal' 2nd exit haul road. If all haul road lengths were reduced
as well, I don't understand the hesitancy to provide updated correct calculaons. All haul road
routes must be evaluated in the context of this modificaon because the amount of material being
transported across the haul roads has increased. UDAQ can't forgo proper review of new sources of
emissions just because the meline is inconvenient. We believe the haul road calculaons as
provided are not accurate and we cannot accept them in their current state, we need an update.
The applicaon will be considered incomplete unl that point. I've done my own calculaon of the
haul road using commonly used loader weights, and I found the emissions could be more than
three mes higher than previously indicated (See aached). If my assessment is incorrect, I need
new informaon that shows that. Addionally, we can't accept an incorrect calculaon because it
was accepted before. If we've found an issue, it's our responsibility to correct that.

The same issue is present with the dryer burner. I can't just accept that the lb/hr rates are lower
when the calculaons Wildcat provided previously show the new dryer and old dryer have similar
heat inputs, fuel consumpon, and emission rates. This arcle also provides a counter argument
that this fuel consumpon argument may not be accurate: https://feeco.com/rotary-dryer-fluid-
bed-dryer-efficiency-comparison/. I'm don't think comparing a rotary dryer to the fluid bed dryer
meets the definion of 'redefining the source' when the facility already employs a rotary dryer for
the same purpose. This implies that this does not "...substanally alter the purpose or basic design
of [the] proposed facility...." This also doesn't make sense if the BACT analysis provided in the
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…10/23
applicaon then goes on to directly compare rotary dryer burner opons to determine BACT for the
fluid bed dryer.

However, I believe the leer provided does provide an argument for why Low-NOX burner
technology may not be praccal for this kind of dryer. And even correcng potenal issues I see
with the cost analysis, I'm sll not finding the 36 ppm burner to be economically feasible. I will
check in with Alan to see if this is sufficient. The soluon may be to stack test in order to get this
equipment approved if Wildcat believes 96 ppm is an aggressive figure to meet.

I will be available tomorrow at 2:00 if you'd like to meet again to discuss, Monday as well. Alan will
be back on Tuesday.

On Thu, Jul 11, 2024 at 12:25 PM Eric Sturm <[e-mail]> wrote:
Dylan,

The variables involved when comparing rotary to fluid-bed prevent us from giving an exact lb/hr
difference, but we can say on average that gas usage is 30 to 50% higher with the rotary. The gas
usage is directly proporonal to the cfm and lb/hr emied out of the stack. So, the difference
between 80 ppm and 96 ppm as being discussed seems a bit shortsighted because that is only a
16.7% reducon on a concentraon basis. But, the fluid-bed saves 30 to 50% on gas, and thus,
reduces NOx and all combuson emissions proporonal to the gas savings.

The BACT analysis would be best served to not consider ppms in a vacuum. And, as we discussed
yesterday, we are not sure if we can make comparisons to rotary dryers as doing so is “redefining
the source” which the EPA Puzzle Book and precipitating EPA guidance does not allow.
Nonetheless, given there are no fluid-bed sand dryers in Utah for comparison, ARC used rotaries
for some semblance of comparison in the BACT.

Geng to the two quesons directly from your email on Tuesday, which were verbally addressed
yesterday:

#1. ARC/Wildcat did not ask for modificaon to the loader weights previously used and
approved in both DAQE-AN159980001-20 and DAQE-IN159980003-21. We understand what was
used previously is accurate. Given Wildcat was not proposing any changes to loaders, we kept
the same weights that were cerfied and approved.

Notably, ARC was overly conservave with road lengths and weights involved. In looking at
updated road plans since the NOI over 12 months ago, some roads have been removed and
shortened. If DAQ is requesng that we adjust loader weights, we calculate that the net effect is
an emission reducon. For simplicity in permit processing/requirements, and keeping within the
confines of this minor source modificaon (and for sake of me), it is probably best to leave
these calculaons as already provided.
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…11/23

#2. First, and primarily, we would like to remind the DAQ of the Thermal Kinecs leer provided
on this topic. 96 ppm for NOx is rather aggressive for fluid-beds given the factors involved. Fluid-
beds are a posive pressure system with excess air to float the bed of sand. The posive
pressure and excess air make low-NOx burners technically and praccally infeasible. We are
again providing the Thermal Kinecs leer as aached.

Although the comparison to rotary dryers is redefining the source, we would note that some
other sand plants can use atmospheric pressure and more gas to meet more aggressive NOx
ppms. We are providing some materials and published arcles explaining the difference
between rotary and fluid-bed. Rotary dryers are easier to operate and can accept/accommodate
more products. Fluid-beds are more difficult to operate and are more material specific, but the
advantage is in the gas efficiency.

Powder & Bulk Solids - https://www.powderbulksolids.com/drying/frac-sand-drying-
methods-rotary-vs-fluid-bed
FEECO - https://feeco.com/rotary-dryer-or-fluid-bed-dryer/
Carrier - https://www.carriervibrating.com/equipment/dryers/aggregate-sand/?utm_agid=
122961654858&utm_term=industrial%20sand%20dryers&utm_campaign=&utm_source=
google&utm_medium=cpc&hsa_acc=9784810565&hsa_cam=12916754048&hsa_grp=
122961654858&hsa_ad=631272690881&hsa_src=g&hsa_tgt=kwd-
300368586716&hsa_kw=industrial%20sand%20dryers&
hsa_mt=p&hsa_net=adwords&hsa_ver=3&gad_source=1&gclid=
CjwKCAjw4ri0BhAvEiwA8oo6F4eYFZqv76nQs5z91pwtXBeNjFWEDPXwrQWv
x0AFYHlz9hzH4OtY7xoCZsEQAvD_BwE

As for the lost drying efficiency that the DAQ is asking us to clarify, we have to defer to third party
experts involved. Hauck/Honeywell was already asked, and they answered this queson, which
was included in the NOI. We will not be asking them again.

To avoid over-answering your two quesons from July 9, please let us know if you need anything
further. The verbal explanaon yesterday and wrien explanaons above are enough to address
your queson and fulfill the permit record. To the extent DAQ might see otherwise, let’s plan to
talk tomorrow and next Monday to follow-up and confirm.

Are you available tomorrow and Monday at 1:00 or 2:00 pm?

If not, please let me know what mes are beer for you.

Eric Sturm
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…12/23
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, July 10, 2024 11:44 AM
To: Eric Sturm <[e-mail]>
Cc: Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>; Ma Hyita <[e-mail]>
Subject: Re: Wildcat Sand Informaon Request 7/9/24

Eric,

Per our call, I did have one last thing to bring up that would be helpful. If the dryer design uses
less fuel, and would result in a lower emission rate despite the NOx concentraon, a supporng
calculaon for this argument would probably be the best way to resolve any issues we might
have. That could be a new calculaon for the dryer or explaining what the lb/hr rate would be
with a more convenonal dryer design. Thanks for calling today I'm hoping this got us on the
path to finishing everything up.

On Wed, Jul 10, 2024 at 8:37 AM Dylan Frederick <[e-mail]> wrote:
Eric,

Alan will not be in the office the rest of this week. I can try my best to take notes today to relay
the explanaons you have. I understand your concerns about the ming, I've tried to address
management concerns each me a new review came back, but regardless of when we find an
issue, if there is an issue that needs to be addressed we have to fix it.

On Tue, Jul 9, 2024 at 9:09 PM Eric Sturm <[e-mail]> wrote:
Dylan,

The answers in February 2024 do have the informaon you need. We can clarify again over
the phone and with an addionalresponse. To the extent the February 2024 answers did
not address your quesons, bringing up a concern 5 months later is rather unreasonable.

9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…13/23
The BACT analysis provided data available informaon from similar dryers, but as
menoned there is no direct comparison to be made. We can explain more on that and
address your quesons by phone tomorrow. Bringing up a concern 12 months aer we
provided the BACT analysis is also unreasonable.

We will send a calendar invite for 10 am tomorrow.

If Alan is not available (or any other reviewer), please let us know another me to
reschedule for tomorrow.

Eric Sturm, ARC

On Tue, Jul 9, 2024, 6:47 PM Dylan Frederick <[e-mail]> wrote:
Eric,
I looked through the responses referenced in February, and it does not have the
informaon we need. To clarify:
The haul road calculaons we are specifically concerned about are for "HRDRY" and
"HRWIP", also called "Haul road - stockpile 3" and "Haul road - Wet plant". These are
calculated as loader routes, but the weight of the loads and the weight of the trucks are
not correct if front end loaders are being used. We need to clarify what equipment is
moving the material across these roads that matches the calculaons, which indicate an
empty weight of 22 tons and a load of 43 tons. Front end loaders would weigh half of
that and would not be able to bear a load of more than double its weight.
Regarding the dryer queson, while the applicaon explains the efficiency argument, the
issue is in the supporng documentaon. It says the manufacturer gave a quote of 54
MMBtu/hr in order to reach the same level of producon for a more efficient dryer. But
this number does not apply to both scenarios of "install a megastar burner for 80 ppm
NOx" and "install a Megastar Burner with Flue Gas Recirculaon for 36 ppm NOx". The
quote was specifically discussing installing a FGR system, and that is also where the "17%
efficiency loss" number is stated. So both numbers apply to the FGR system, but not the
megastar burner on its own. And if the dryer is a unique piece of equipment, the
supporng informaon for the BACT determinaon should be specific to the unique fluid
bed design.

Currently the supporng informaon that jusfied the "Lost Drying Efficiency" poron of
the BACT argument is talking about a completely different burner and system than the
one you're installing, and doesn't necessarily reflect potenal drying losses for installing
ONLY a more efficient burner. Again, it is specifically stang that for a system that uses a
different burner AND FGR, a producon/drying efficiency loss of 17% is expected. For the
proposed 38 MMBtu/hr dryer, that would imply the dryer would need to be sized to
45.78 MMBtu/hr to maintain the same producon rate, which is different than the 54
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…14/23
MMBtu/hr figure used in the BACT explanaon for lost drying efficiency. That is the issue
I'm trying to address here.

So to be clear, I need supporng informaon that states this Fluid Bed Dryer would
experience 17% efficiency losses from upgrading to a more efficient burner (such as the
80 ppm NOx burner menoned in the applicaon), or I need an updated cost analysis
that explains why this opon is economically infeasible without the dryer efficiency
argument included. Otherwise, the applicaon is incomplete as there isn't an explanaon
that we can accept for why 96 ppm is BACT for NOx.

I'm available tomorrow aer 10 AM for a call.

On Tue, Jul 9, 2024 at 3:55 PM Eric Sturm <[e-mail]> wrote:
Dylan, Alan,

We appreciate DAQ’s group effort on the internal reviews, but the quesons below
were already asked and answered in early February. To ask the same quesons five
months later is rather disheartening to see.

Can we schedule a Teams call for tomorrow to discuss and address, again?

If you send us your available mes, we will circulate a calendar invite tonight.

In advance, regarding item #2, the applicaon is clear how the loss in efficiency was
determined. We can answer this again for the Wildcat NOI. There is one other sand
dryer project with the DAQ that we are aware of with similar scruny, but that source
is a rotary dryer and completely different size. Wildcat Dryer #2 is a fluid-bed dryer,
which is a completely different technology. It is unique design, and one that is not
oen used in the industry. The shared discussions with other DAQ engineers are not
applicable. To the extent the DAQ wants to compare projects, we would need to find a
fluid-bed sand dryer in the state. ARC has not found one yet for comparison.

Sincerely.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…15/23
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, July 9, 2024 1:35 PM
To: Eric Sturm <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>; Ma Hyita <[e-mail]>;
Alan Humpherys <[e-mail]>
Subject: Wildcat Sand Informaon Request 7/9/24

Good aernoon,

Per the last management review, here are some quesons we have regarding the
applicaon that need to be addressed.

1. The haul road calculaons do not appear to be correct. The haul roads in the facility
have several routes that are loader routes, but do not use loader route truck weights
or loads for the calculaons. This needs to be explained. If the explanaon is that front
end loaders are not used at the facility, that would need to be enforced in a permit
condion. I need an explanaon for what equipment is being used for these loader
routes so that also can be enforced with a permit condion.

2. In the Dryer BACT analysis, the argument Wildcat presented was that a 54
MMBtu/hr heater would be needed if a LNB or FGR system was installed, and this
argument regarding dryer efficiency was used to determine that 96 ppm was the best
standard that could be achieved. However, the emails from the manufacturer provided
only discuss the addion of a FGR system, not just a LNB system alone when discussing
the 54 MMBtu/hr number. It is also unclear if this is applicable to the fluid bed dryer
design discussed in this applicaon. The same source provided indicates dryer
efficiency drops by 17%, but the calculaons make an assumpon that is equivalent to
assuming a 30% drop in efficiency. These numbers need a direct explanaon if they are
correct, the applicaon does not make it clear how these figures were determined.

I need a clear explanaon for whether the 80 ppm Megastar burner discussed in the
applicaon has the same drying loss as a megastar burner with FGR that equates to 36
ppm. This could substanally affect the cost effecveness numbers determined for this
piece of equipment.

Part of why this took so long was I had discussions with other engineers working on
similar projects, and they've run into the same issues. I need to see the dryer spec
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…16/23
sheets for the currently proposed dryer and the 80 ppm dryer to make a comparison
and verify the dryer efficiency numbers.

One final note, one of the engineers suggested that the soluon could be stack tesng
for the dryers to verify they can meet lower NOx standards of 80 ppm and the other
emission rates provided for the dryers. Please let me know what you think.

--
Dylan Frederick
Environmental Engineer | Minor NSR Secon
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Secon
P: [phone]
airquality.utah.gov
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…17/23

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Secon
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Secon
P: [phone]
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…18/23
airquality.utah.gov

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Secon
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.

--
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…19/23
Dylan Frederick
Environmental Engineer | Minor NSR Secon
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Secon
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.

9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…20/23

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…21/23

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…22/23
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

9/7/24, 2:59 PM State of Utah Mail - Wildcat Sand Information Request 7/9/24
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1809282608709642682&simpl=msg-f:180928260870964…23/23
Map Prepared By:Revision: 2.0 Air Regulations Consulting, LLCDate Prepared: 7/12/2024 Title: Wildcat Sand – Haul Road Description
Legend
Property Boundary
Stockpiles
HR2NDEXIT (N/A)
HRWIP
HRLOAD
HRDRY1 / HRDRY2
HRLDOUT
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand - Roosevelt Plant
Sand Plant
Emission Calculations
Facility PTE - 8760 hr/yr
PTE (lb/hr)PTE (lb/hr)
Emission
Type Unit
Particulate
Matter <10μ
(PM10)
Nitrogen Oxides
(NOX)
Particulate
Matter <10μ
(PM10)
Particulate
Matter <2.5μ
(PM2.5)
Nitrogen Oxides
(NOX)
Sulfur Oxides
(SOX)
Carbon
Monoxide
(CO)
Volatile Organic
Compounds
(VOC)
Lead
Compounds
Hazardous Air
Pollutants
(HAPs)
Point 01 Bucket Elevator Transfer to Silo**SILOTR 0.0018 0.0079 0.0012
Point 02 Dryer #1 Stack with Baghouse and Cyclone DRYER1 1.0700 4.6900 4.6900
Point 02 Dryer #1 Combustion DRYER1 4.7800 20.9400 0.0000 24.9700 1.9200 0.0001 0.3297
Point 03 Dryer #2 Stack with Baghouse and Cyclone DRYER2 2.9900 13.0900 13.0900
Point 03 Dryer #2 Combustion DRYER2 4.4400 19.4500 0.1000 13.6300 1.7800 0.0001 0.3063
Fugitive 04 Haul Road - Additional Exit from Plant HR2NDEXIT 0 0 0
Fugitive 05 Haul Road - Final Product HRLDOUT 0.3300 1.4500 0.1500
Fugitive 06 Haul Road - WIP Pile #2 to WIP Pile #3 HRWIP 0.5800 2.5500 0.2500
Fugitive 07 Haul Road - Loader to Wet Plant HRLOAD 1.3500 5.9100 0.5900
Point 08 J & H Screen Baghouse Stack*SCRNSTK 0.9600 4.2200 4.2200
Fugitive 09 Secondary Crushing 2NDCRUSH 0.1600 0.7100 0.1300
Fugitive 10 Stockpile Pre-Wash Plant PILE1 0.0500 0.2300 0.1200
Fugitive 11 Truck Unloading to Dry Plant #1 TRNSDP1 0.0900 0.3900 0.0600
Fugitive 12 Truck Unloading to Dry Plant #2 TRNSDP2 0.0900 0.3900 0.0600
Fugitive 13 Truck Unloading to Wet Plant TRNSWP 0.1800 0.7900 0.1200
Fugitive 14 Truck Unloading to WIP Pile #3 TRNSWIP3 0.0900 0.3900 0.0600
Fugitive 15 WIP Stockpile #2 PILE2 0.1400 0.5900 0.3100
Fugitive 16 WIP Stockpile #3 PILE3 0.2500 1.0900 0.5600
Fugitive 17 Existing Conveyors and Drop Points CONVYRS 0.1900 0.8500 0.2400
Point 18 Unloading Sand Storage Silos #1 - #3**SILOS 0.0004 0.0018 0.0005
Point 19 Engine - Filter Press[1]FPGENSET 0.0300 0.9100 0.1300 0.1300 4.0100 0.0100 8.0100 1.5000 0.0000 0.9200
Fugitive 20 Disturbed Area DISAREA 0.3900 1.7100 0.2600
Fugitive 21 New Dry Plant #2 Conveyors**CONVDRY2 0.0003 0.0012 0.0003
Fugitive 22 Enclosed Baghouse Waste Collection Area ***BHWASTE 0.0100 0.0500 0.0250
Fugitive 23a Haul Road - Loader to Dry Plant 1 HRDRY1 0.8000 3.5100 0.3500
Fugitive 23b Haul Road - Loader to Dry Plant 2 HRDRY2 0.2900 1.2700 0.1300
Fugitive 24 Fuel Oil Storage Tank TANK1 0.0021
5.05 10.13 22.14 22.13 44.40 0.11 46.61 5.20 0.00 1.56
4.99 0.00 21.88 3.42 0.00 0.00 0.00 0.00 0.00 0.00
10.04 10.13 44.02 25.55 44.40 0.11 46.61 5.20 0.00 1.56
[1] Tier 2 Natural Gas Engine meets 40 CFR 60.4223(e) and Table 1 emission standards
*Based on fabric filter baghouse Manufacturer Gaurantee of 0.005 gr/dscf
** All product handling post dryers are controlled with a dust collector and silo bin vent filter with a control efficiency >99%
*** Baghouse waste is in an enclosed building
Facility PTE (tpy)
Description
Point
Fugitive
Facility PTE
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand PlantRotary Sand Dryer (Fired with Natural Gas)PTE from Sand Drying Controlled via a Cyclone and BaghouseNatural Gas
Sand Throughput*150 tons per hourVolumetric Air Flow 20,955 acfm
Total Heat Input Capacity 40.9 MMBtu/hrTotal Heat Input Capacity 0.040 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)[1]Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0079 1.42 12,446 6.22
PM10**0.0079 1.07 9,373 4.69
PM2.5**0.0079 1.07 9,373 4.69
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate[3]
(lbs/hr)Potential Emission Rate(lbs/year)Potential Emission Rate(tons/year)
Nitrogen Oxides (NOx)50 4.78 41,873 20.94Carbon Monoxide (CO)84 5.70 49,932 24.97
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Total Organic Compounds (TOC)11.0 0.438 3,841 1.92
Sulfur Dioxide (SO2)[3]0.6 0.00 0 0.00
Greenhouse Gas Pollutants (GHG)Emission Factor[4]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 4,784 41,911,086 20,956
Nitrous Oxide (N2O)0.0002 0.0090 79 0.04
Methane (CH4)0.0022 0.0902 790 0.39
Individual Hazardous Air Pollutants (HAP) Emission Factor[5]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.7333 0.0004
Dichlorobenzene 0.0012 0.0000 0.4190 0.0002
Formaldehyde 0.0750 0.0030 26.1904 0.0131
Hexane 1.8000 0.0718 628.5684 0.3143
Lead Compounds 0.0005 0.0000 0.1746 0.0001
Naphthalene 0.0006 0.0000 0.2130 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0308 0.0000
Toluene 0.0034 0.0001 1.1873 0.0006 Arsenic Compounds (ASC)0.0002 0.0000 0.0698 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0042 0.0000
Cadmium Compounds (CDC)0.0011 0.0000 0.3841 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.4889 0.0002
Cobalt Compounds (COC)0.0001 0.0000 0.0293 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1327 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.0908 0.0000
Nickel Compounds (NIC)0.0021 0.0001 0.7333 0.0004
Selenium Compounds (SEC)0.0000 0.0000 0.0084 0.0000Total HAPs 1.8885 0.0753 659.4584 0.3297
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates. Tarmac Baghouse particulate guarantee is at or below a 0.01 gr/dscf.DAQE-AN159980001-20 Permit Limit, lb/hr = 1.07
[4]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMBtu/MMscf.* Capacity of the 150 ton per hour sand dryer is from manufacturer for Tarmac Int., Inc Dryer
[5]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 2.204622622 lb/kg.
**Conservatively assumed that 100% of PM10 is to be PM2.5.
[1]Emission Factors for PM based NSPS UUU emission requirements which includes process and combustion emissions. NSPS requires PM be no greater than 0.025
gr/dscf.
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMbtu/MMscf. [3]Emissions data for SOX and CO from Tarmac Dryer Spec Sheet, 96 ppm NOX
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand Plant
Rotary Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 20,955 acfm
Total Heat Input Capacity 40.9 MMBtu/hr
Total Heat Input Capacity 0.040 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)[1]
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0079 1.42 12,446 6.22
PM10**0.0079 1.07 9,373 4.69
PM2.5**0.0079 1.07 9,373 4.69
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate[3]
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx)50 4.78 41,873 20.94
Carbon Monoxide (CO)84 5.70 49,932 24.97
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Total Organic Compounds (TOC)11.0 0.438 3,841 1.92
Sulfur Dioxide (SO2)[3]0.6 0.00 0 0.00
Greenhouse Gas Pollutants (GHG)Emission Factor[4]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 4,784 41,911,086 20,956
Nitrous Oxide (N2O)0.0002 0.0090 79 0.04
Methane (CH4)0.0022 0.0902 790 0.39
Individual Hazardous Air Pollutants (HAP) Emission Factor[5]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.7333 0.0004
Dichlorobenzene 0.0012 0.0000 0.4190 0.0002
Formaldehyde 0.0750 0.0030 26.1904 0.0131
Hexane 1.8000 0.0718 628.5684 0.3143
Lead Compounds 0.0005 0.0000 0.1746 0.0001
Naphthalene 0.0006 0.0000 0.2130 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0308 0.0000
Toluene 0.0034 0.0001 1.1873 0.0006
Arsenic Compounds (ASC)0.0002 0.0000 0.0698 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0042 0.0000
Cadmium Compounds (CDC)0.0011 0.0000 0.3841 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.4889 0.0002
Cobalt Compounds (COC)0.0001 0.0000 0.0293 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1327 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.0908 0.0000
Nickel Compounds (NIC)0.0021 0.0001 0.7333 0.0004
Selenium Compounds (SEC)0.0000 0.0000 0.0084 0.0000
Total HAPs 1.8885 0.0753 659.4584 0.3297
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates. Tarmac Baghouse particulate guarantee is at or below a 0.01 gr/dscf.
DAQE-AN159980001-20 Permit Limit, lb/hr = 1.07
[4]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMBtu/MMscf.
* Capacity of the 150 ton per hour sand dryer is from manufacturer for Tarmac Int., Inc Dryer
[5]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 2.204622622 lb/kg.
**Conservatively assumed that 100% of PM10 is to be PM2.5.
[1]Emission Factors for PM based NSPS UUU emission requirements which includes process and combustion emissions. NSPS requires PM be no greater than 0.025
gr/dscf.
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMbtu/MMscf.
[3]Emissions data for NOX and CO from Tarmac Dryer Spec Sheet, 96 ppm NOX
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand PlantFluid Bed Sand Dryer (Fired with Natural Gas)PTE from Sand Drying Controlled via a Cyclone and BaghouseNatural Gas
Sand Throughput*150 tons per hourVolumetric Air Flow 50,000 acfm
Total Heat Input Capacity 38.0 MMBtu/hrTotal Heat Input Capacity 0.037 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)[1]Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0070 2.99 26,181 13.09
PM10**0.0070 2.99 26,181 13.09
PM2.5**0.0070 2.99 26,181 13.09
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate[3]
(lbs/hr)Potential Emission Rate(lbs/year)Potential Emission Rate(tons/year)
Nitrogen Oxides (NOx)50 4.44 38,894 19.45
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Monoxide (CO)84 3.11 27,253 13.63Total Organic Compounds (TOC)11.0 0.407 3,569 1.78
Sulfur Dioxide (SO2)0.6 0.02 195 0.10
Greenhouse Gas Pollutants (GHG)Emission Factor[4]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 4,445 38,939,396 19,470
Nitrous Oxide (N2O)0.0002 0.0084 73 0.04
Methane (CH4)0.0022 0.0838 734 0.37
Individual Hazardous Air Pollutants (HAP) Emission Factor[5]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.6813 0.0003
Dichlorobenzene 0.0012 0.0000 0.3893 0.0002
Formaldehyde 0.0750 0.0028 24.3333 0.0122
Hexane 1.8000 0.0667 584.0000 0.2920
Lead Compounds 0.0005 0.0000 0.1622 0.0001
Naphthalene 0.0006 0.0000 0.1979 0.0001 Polycyclic Organic Matter (POM)0.0001 0.0000 0.0286 0.0000
Toluene 0.0034 0.0001 1.1031 0.0006
Arsenic Compounds (ASC)0.0002 0.0000 0.0649 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0039 0.0000
Cadmium Compounds (CDC)0.0011 0.0000 0.3569 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.4542 0.0002
Cobalt Compounds (COC)0.0001 0.0000 0.0273 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1233 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.0844 0.0000 Nickel Compounds (NIC)0.0021 0.0001 0.6813 0.0003
Selenium Compounds (SEC)0.0000 0.0000 0.0078 0.0000Total HAPs 1.8885 0.0699 612.6998 0.3063
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates. Tarmac Baghouse particulate guarantee is at or below a 0.01 gr/dscf.Given exhaust temperature stacks will approximately be 300 F, 0.01 gr/dscf equals 0.007 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+300))]
[4]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMBtu/MMscf.* Capacity of the 150 ton per hour sand dryer is from manufacturer for Fluid Bed Dryer
[5]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 2.204622622 lb/kg.
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
[1]Emission Factors for PM based NSPS UUU emission requirements which includes process and combustion emissions. NSPS requires PM be no greater than 0.025
gr/dscf.
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMbtu/MMscf. [3]Emissions data for NOX at 96 ppm are identical to Sand Dryer 1
Prepared with Assistance from Air Regulations Consulting, LLC
1. The emission calculations as presented are causing confusion. Issues include the old dryer and
new dryer being different sizes but emitting the same emission rate, the HAP totals increasing
significantly from the last permit due to the new engine calculations, and the emission summary
page being difficult to track with all the calculations spread out across different submissions. I
think if you could submit the emission summary with all emission calculations included in the
same attachment that would help a lot.
See attachment in 1. Emission Summary Section
2. The old dryer and the new dryer are calculated to have the same emission rate, but use a different
emission limit in the stack testing condition. Dryer 1 is 1.07 lbs/hr PM10, Dryer 2 is 1.42. The
emission calculations should reflect these emission rates. I’d recommend changing the first dryer’s
PM10 rate to 1.07 lb/hr in the calculations and citing the previous limit in the last permit as the
reference. Otherwise we would need a BACT discussion for the old dryer to raise its stack test
limit. We cannot use a calculation in the NOI then not use it in the AO.
Wildcat is okay with Dryer 1 at 1.07 lbs/hr of PM10. Calculations are updated accordingly in the
following materials. Dryer 2 has always been set at 2.99 lbs/hr of PM10; no changes needed there.
The issue stems from the 1.07 lbs/hr being set incorrectly in the initial permit. Based on the scfm
for Dryer 1, and the BACT being 0.01 gr/dscf, the emission limit should be 1.42 lbs/hr for all filterable
PM/PM10/PM2.5. The stack is saturated, and so it is not possible to run an EPA Test Method 201A
to split the 10 micron portion from the rest of the PM. Wildcat is only able to test for all PM. The
current permit splits the limit between PM and PM10, but in reality, Wildcat can only test for all PM.
The emissions modeling and BACT provided previously justifies the limit changing to 1.42 lbs/hr for
all PM. But, again, Wildcat is okay retaining the 1.07 lb/hr to avoid any further delay in this permit.
Dryer 2 has always been correctly provided in the NOI, BACT, modeling and follow-up questions
from DAQ. The limit is 0.01 gr/dscf, which is consistently the BACT rate for baghouses in Utah.
3. The dryers are slightly different heat ratings and both are 96 ppm NOx. They should have different
NOx/CO emission rates but the calculations state they emit at the same rate. Please revise using
the 96 ppm NOx rate for each dryer.
See attachment in 1. Emission Summary Section
4. The loading and haul roads in particular were a source of confusion. We never got a visual to go
along with the haul road lengths. An explanation for why these haul road lengths are so long is
also needed. I recommend a clear process description to help understand how each part of the
process connects. I’ve attempted an explanation (for the haul roads alone) based on information
I’ve received. That description is attached. Please look it over and let me know if I’ve accurately
described the function of each haul road. I recommend fully clarifying the full process step by step
to help account for each emission source.
See attachment in 2. Haul Road Visual
Prepared with Assistance from Air Regulations Consulting, LLC
1. Emission Summary

UDAQ FORM 5
EMISSIONS INFORMATION

Page 1 of 1
Company___________________________
_____________________________
Form
Emissions Information
Criteria/GHGs/
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants**(**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Wildcat Sand, LLC
Processing Plant
12.59 30.59 43.18
7.16 13.88 21.04
0.86 24.66 25.52
16.84 27.56 44.40
0.66 -0.55 0.11
20.08 26.53 46.61
3.04 2.16 5.20
0.74 -0.74 0.00
0.00 0.00 0.00
13,522.74 28,530.26 42,053.00
93.06 -74.30 18.76
21.01 -20.93 0.08
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
13,518.00 28,553.84 42,071.84
Formaldehyde 0.16 -0.06 0.09 -0.01
Hexane 0.20 0.41 0.61 0.09
Generic HAPs 0.06 0.80 0.86 0.02
0.41 1.15 1.56 0.26

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 1, BUCKET ELEVATOR

Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.18 0.79
PM2.5 0.00009 0.03 0.12
Material Handling
AP-42 13.2.4.3
Equation #1
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 2, SAND DRYER 1

Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand Plant
Rotary Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 20,955 acfm
Total Heat Input Capacity 40.9 MMBtu/hr
Total Heat Input Capacity 0.040 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)[1]
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0079 1.42 12,446 6.22
PM10**0.0079 1.07 9,373 4.69
PM2.5**0.0079 1.07 9,373 4.69
Pollutant Emission Factor[2]
(lb/MMscf)Potential Emission Rate[3]
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx)50 4.78 41,873 20.94
Carbon Monoxide (CO)84 5.70 49,932 24.97
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Total Organic Compounds (TOC)11.0 0.438 3,841 1.92
Sulfur Dioxide (SO2)[3]0.6 0.00 0 0.00
Greenhouse Gas Pollutants (GHG)Emission Factor[4]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 4,784 41,911,086 20,956
Nitrous Oxide (N2O)0.0002 0.0090 79 0.04
Methane (CH4)0.0022 0.0902 790 0.39
Individual Hazardous Air Pollutants (HAP) Emission Factor[5]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.7333 0.0004
Dichlorobenzene 0.0012 0.0000 0.4190 0.0002
Formaldehyde 0.0750 0.0030 26.1904 0.0131
Hexane 1.8000 0.0718 628.5684 0.3143
Lead Compounds 0.0005 0.0000 0.1746 0.0001
Naphthalene 0.0006 0.0000 0.2130 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0308 0.0000
Toluene 0.0034 0.0001 1.1873 0.0006
Arsenic Compounds (ASC)0.0002 0.0000 0.0698 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0042 0.0000
Cadmium Compounds (CDC)0.0011 0.0000 0.3841 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.4889 0.0002
Cobalt Compounds (COC)0.0001 0.0000 0.0293 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1327 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.0908 0.0000
Nickel Compounds (NIC)0.0021 0.0001 0.7333 0.0004
Selenium Compounds (SEC)0.0000 0.0000 0.0084 0.0000
Total HAPs 1.8885 0.0753 659.4584 0.3297
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates. Tarmac Baghouse particulate guarantee is at or below a 0.01 gr/dscf.
DAQE-AN159980001-20 Permit Limit, lb/hr = 1.07
[4]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMBtu/MMscf.
* Capacity of the 150 ton per hour sand dryer is from manufacturer for Tarmac Int., Inc Dryer
[5]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 2.204622622 lb/kg.
**Conservatively assumed that 100% of PM10 is to be PM2.5.
[1]Emission Factors for PM based NSPS UUU emission requirements which includes process and combustion emissions. NSPS requires PM be no greater than 0.025
gr/dscf.
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMbtu/MMscf.
[3]Emissions data for SOX and CO from Tarmac Dryer Spec Sheet, 96 ppm NOX

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 3, SAND DRYER 2

Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand Plant
Fluid Bed Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 50,000 acfm
Total Heat Input Capacity 38.0 MMBtu/hr
Total Heat Input Capacity 0.037 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)[1]
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0070 2.99 26,181 13.09
PM10**0.0070 2.99 26,181 13.09
PM2.5**0.0070 2.99 26,181 13.09
Pollutant Emission Factor[2]
(lb/MMscf)Potential Emission Rate[3]
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx)50 4.44 38,894 19.45
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Monoxide (CO)84 3.11 27,253 13.63
Total Organic Compounds (TOC)11.0 0.407 3,569 1.78
Sulfur Dioxide (SO2)0.6 0.02 195 0.10
Greenhouse Gas Pollutants (GHG)Emission Factor[4]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 4,445 38,939,396 19,470
Nitrous Oxide (N2O)0.0002 0.0084 73 0.04
Methane (CH4)0.0022 0.0838 734 0.37
Individual Hazardous Air Pollutants (HAP) Emission Factor[5]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.6813 0.0003
Dichlorobenzene 0.0012 0.0000 0.3893 0.0002
Formaldehyde 0.0750 0.0028 24.3333 0.0122
Hexane 1.8000 0.0667 584.0000 0.2920
Lead Compounds 0.0005 0.0000 0.1622 0.0001
Naphthalene 0.0006 0.0000 0.1979 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0286 0.0000
Toluene 0.0034 0.0001 1.1031 0.0006
Arsenic Compounds (ASC)0.0002 0.0000 0.0649 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0039 0.0000
Cadmium Compounds (CDC)0.0011 0.0000 0.3569 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.4542 0.0002
Cobalt Compounds (COC)0.0001 0.0000 0.0273 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1233 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.0844 0.0000
Nickel Compounds (NIC)0.0021 0.0001 0.6813 0.0003
Selenium Compounds (SEC)0.0000 0.0000 0.0078 0.0000
Total HAPs 1.8885 0.0699 612.6998 0.3063
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates. Tarmac Baghouse particulate guarantee is at or below a 0.01 gr/dscf.
Given exhaust temperature stacks will approximately be 300 F, 0.01 gr/dscf equals 0.007 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+300))]
[4]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMBtu/MMscf.
* Capacity of the 150 ton per hour sand dryer is from manufacturer for Fluid Bed Dryer
[5]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 2.204622622 lb/kg.
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
[1]Emission Factors for PM based NSPS UUU emission requirements which includes process and combustion emissions. NSPS requires PM be no greater than 0.025
gr/dscf.
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMbtu/MMscf.
[3]Emissions data for NOX at 96 ppm are identical to Sand Dryer 1

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 4, HAUL ROAD – 2ND EXIT

Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Truck Information
Empty Truck Weight 22 tons
Weight of Load 43 tons
Loaded Truck Weight 65 tons
Haul Road Information
Haul Road One-Way Length 662 feet
Hourly Vehicle Miles Traveled 0.9 miles
Annual Vehicle Miles Traveled 7,660 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.33 0.29 1.25
PM2.5 0.218 0.033 0.03 0.13
Haul Roads
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 5, HAUL ROAD – FINAL PRODUCT

Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Truck Information
Empty Truck Weight 22 tons
Weight of Load 43 tons
Loaded Truck Weight 65 tons
Haul Road Information
Haul Road One-Way Length 1,151 feet
Hourly Vehicle Miles Traveled 3.0 miles
Annual Vehicle Miles Traveled 26,644 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.11 0.33 1.45
PM2.5 0.218 0.011 0.03 0.15
Haul Roads
AP-42 13.2.2 & DAQ
Haul Road Guidance
Paving with Vacuum Sweeping & Watering - (95% control)
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 6, HAUL ROAD – STOCKPILE #3

Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Loader Information
Empty Loader Weight 22 tons
Weight of Load 43 tons
Loaded Loader Weight 65 tons
Loader Route\ Information
Loader Route One-Way Length 1,201 feet
Hourly Vehicle Miles Traveled 1.6 miles
Annual Vehicle Miles Traveled 13,902 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.33 0.52 2.27
PM2.5 0.218 0.033 0.05 0.23
Loader Routes
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 7, HAUL ROAD – WET PLANT

Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Loader Information
Empty Loader Weight 22 tons
Weight of Load 43 tons
Loaded Loader Weight 65 tons
Loader Route\ Information
Loader Route One-Way Length 1,563 feet
Hourly Vehicle Miles Traveled 4.1 miles
Annual Vehicle Miles Traveled 36,184 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.33 1.35 5.91
PM2.5 0.218 0.033 0.14 0.59
Loader Routes
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 8, SCREENS
ITEM 9, CRUSHER
ITEM 17, EXISTING CONVEYORS

Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Emission Unit
Number of
Emission
Units
PM10
Emission
Factor
(lb/ton)
PM2.5
Emission
Factor
(lb/ton)Reference
Crushers 1 0.00054 0.00010
Screens 3 0.00074 0.00005
Conveyor Transfer Points 14 4.6E-05 1.3E-05
Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)
PM10 1.02 4.47
PM2.5 0.13 0.57
Emission Unit
PM10
Emission
Rate
(lbs/hr)
PM10
Emission
Total
(tons/year)
PM2.5
Emission
Rate
(lbs/hr)
PM2.5 Emission
Total
(tons/year)
Crushers 0.16 0.71 0.03 0.13
Screens 0.67 2.92 0.05 0.20
Conveyors 0.19 0.85 0.05 0.24
Aggregate Processing Equipment
AP-42
Table 11.19.2-2
Page 1 of 1
Version 1.0
November 29, 2018
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand Plant
J&H Screen Baghouse
PTE from Screen Baghouse
Throughput 150 tons per hour
Volumetric Air Flow 22,500 dscfm
Pollutant Emission Factor[1]
(gr/dscf)
Potential Emission Rate
(lbs/hr)[1]
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.005 0.96 8,447 4.22
PM10**0.005 0.96 8,447 4.22
PM2.5**0.005 0.96 8,447 4.22
BACT suggests the lowest emission rate could be 0.01 gr/dscf filterable particulates.
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
[1]Emission Factors for PM based on fabric filter baghouse Manufacturer Guarantee of 0.005 gr/dscf.

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 10, STORAGE PILE #1

Storage Pile Area
Total Area of Storage Piles 1 acres
Control Efficiency
PM10 Control Efficiency 66%
PM2.5 Control Efficiency 40%
Pollutant
Uncontrolled
Emission
Factor
(lb/acre-day)
Controlled
Emission
Factor
(lb/acre-day)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 6.30 2.14 0.05 0.23 AP-42 Fourth Edition Table 8.19.1-1
PM2.5 1.85 1.11 0.03 0.12 AP-42 Appendix B.2 Table B.2-2
Storage Piles
AP-42 Appendix B.2
Tables B.2-2 & B.2-3
Reference
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 11, LOADING DRY PLANT #1

Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.09 0.39
PM2.5 0.00009 0.01 0.06
Material Handling
AP-42 13.2.4.3
Equation #1
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 12, LOADING DRY PLANT #2

Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.09 0.39
PM2.5 0.00009 0.01 0.06
Material Handling
AP-42 13.2.4.3
Equation #1
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 13, LOADING WET PLANT

Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.18 0.79
PM2.5 0.00009 0.03 0.12
Material Handling
AP-42 13.2.4.3
Equation #1
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 14, LOADING STOCKPILE #3

Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.09 0.39
PM2.5 0.00009 0.01 0.06
Material Handling
AP-42 13.2.4.3
Equation #1
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 15, STORAGE PILE #2

Storage Pile Area
Total Area of Storage Piles 2 acres
Control Efficiency
PM10 Control Efficiency 66%
PM2.5 Control Efficiency 40%
Pollutant
Uncontrolled
Emission
Factor
(lb/acre-day)
Controlled
Emission
Factor
(lb/acre-day)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 6.30 2.14 0.14 0.59 AP-42 Fourth Edition Table 8.19.1-1
PM2.5 1.85 1.11 0.07 0.31 AP-42 Appendix B.2 Table B.2-2
Storage Piles
AP-42 Appendix B.2
Tables B.2-2 & B.2-3
Reference
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 16, STORAGE PILE #3

Storage Pile Area
Total Area of Storage Piles 3 acres
Control Efficiency
PM10 Control Efficiency 66%
PM2.5 Control Efficiency 40%
Pollutant
Uncontrolled
Emission
Factor
(lb/acre-day)
Controlled
Emission
Factor
(lb/acre-day)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 6.30 2.14 0.25 1.09 AP-42 Fourth Edition Table 8.19.1-1
PM2.5 1.85 1.11 0.13 0.56 AP-42 Appendix B.2 Table B.2-2
Storage Piles
AP-42 Appendix B.2
Tables B.2-2 & B.2-3
Reference
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 18, STORAGE SILOS

Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Emission Unit
Number of
Emission
Units
PM10
Emission
Factor
(lb/ton)
PM2.5
Emission
Factor
(lb/ton)Reference
Crushers 0 0.00054 0.00010
Screens 0 0.00074 0.00005
Conveyor Transfer Points 3 4.6E-05 1.3E-05
Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)
PM10 0.04 0.18
PM2.5 0.01 0.05
Emission Unit
PM10
Emission
Rate
(lbs/hr)
PM10
Emission
Total
(tons/year)
PM2.5
Emission
Rate
(lbs/hr)
PM2.5 Emission
Total
(tons/year)
Crushers 0.00 0.00 0.00 0.00
Screens 0.00 0.00 0.00 0.00
Conveyors 0.04 0.18 0.01 0.05
Aggregate Processing Equipment
AP-42
Table 11.19.2-2
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 19, FILTER PRESS ENGINE

Equipment Details
Rating 415 hp = (309.8 kw)
Operational Hours 8,760 hours/year
Engine Type
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission Factor
(lb/MMBtu)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 1.0 0.91 4.01
CO 2.0 1.83 8.01
PM10 9.99E-03 0.03 0.13
PM2.5 9.99E-03 0.03 0.13
VOC 1.18E-01 0.34 1.50
SO2 5.88E-04 0.00 0.01
HAP 0.21 0.92 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission Factor
(lb/MMBtu)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 1.10E+02 320 1,400
Methane (mass basis)25 1.25E+00 4 16
CO2e 1,797
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
1,1,2,2-Tetrachloroethane 4.00E-05 1.16E-04 5.09E-04
1,1,2-Trichloroethane 3.18E-05 9.24E-05 4.05E-04
1,3-Butadiene 2.67E-04 7.76E-04 3.40E-03
1,3-Dichloropropene 2.64E-05 7.67E-05 3.36E-04
2,2,4-Trimethylpentane 2.50E-04 7.26E-04 3.18E-03
2-Methylnaphthalene 3.32E-05 9.64E-05 4.22E-04
Acenaphthene 1.25E-06 3.63E-06 1.59E-05
Acenaphthylene 5.53E-06 1.61E-05 7.04E-05
Acetaldehyde 8.36E-03 2.43E-02 1.06E-01
Acrolein 5.14E-03 1.49E-02 6.54E-02
Benzene 4.40E-04 1.28E-03 5.60E-03
Benzo(b)fluoranthene 1.66E-07 4.82E-07 2.11E-06
Benzo(e)pyrene 4.15E-07 1.21E-06 5.28E-06
benzo(g,h,i)perylene 4.14E-07 1.20E-06 5.27E-06
Biphenyl 2.12E-04 6.16E-04 2.70E-03
Carbon Tetrachloride 3.67E-05 1.07E-04 4.67E-04
Chlorobenzene 3.04E-05 8.83E-05 3.87E-04
Chloroform 2.85E-05 8.28E-05 3.63E-04
Chrysene 6.93E-07 2.01E-06 8.82E-06
Ethylbenzene 3.97E-05 1.15E-04 5.05E-04
Ethylene Dibromide 4.43E-05 1.29E-04 5.64E-04
Fluoranthene 1.11E-06 3.22E-06 1.41E-05
Fluorene 5.67E-06 1.65E-05 7.21E-05
Formaldehyde 5.28E-02 1.53E-01 6.72E-01
Methanol 2.50E-03 7.26E-03 3.18E-02
Methylene Chloride 2.00E-05 5.81E-05 2.54E-04
n-Hexane 1.11E-03 3.22E-03 1.41E-02
Naphthalene 7.44E-05 2.16E-04 9.47E-04
PAH 2.69E-05 7.81E-05 3.42E-04
Phenanthrene 1.04E-05 3.02E-05 1.32E-04
Phenol 2.40E-05 6.97E-05 3.05E-04
Pyrene 1.36E-06 3.95E-06 1.73E-05
Styrene 2.36E-05 6.86E-05 3.00E-04
Tetrachloroethane 2.48E-06 7.20E-06 3.16E-05
Toluene 4.08E-04 1.19E-03 5.19E-03
Vinyl Chloride 1.49E-05 4.33E-05 1.90E-04
Xylene 1.84E-04 5.35E-04 2.34E-03
Emission Factor
(lb/MMBtu)
Natural Gas-Fired Engines
AP-42 Table 3.2-1,
Table 3.2-2, &
Table 3.2-3
AP-42 Table 3.2-1,
Table 3.2-2, &
Table 3.2-3
(Some HAP do not
popluate based on
the type of engine
selected. AP-42
does not list certain
HAP for certain types
of engines.)
Manufacturer Data,
AP-42 Table 3.2-1,
Table 3.2-2, &
Table 3.2-3
4-Stroke Lean-Burn
Emergency Engines should
equal 100 hours of
operation per year
Page 1 of 1 Version 1.1
February 21, 2019

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 20, DISTRUBED AREA

Wind Erosion of Exposed Area
Total Area of Distrubed Ground 14 acres
Emission Factors & Distribution
TSP Emission Factor 0.38
PM10 Content 50%
PM2.5 Content 7.5%
Pollutant
Emission
Factor
(tons/acre-year)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)
PM10 0.19 0.61 2.66
PM2.5 0.03 0.09 0.40
Disturbed Ground
Reference
AP-42 Section 13.2.5.3
AP-42 Table 11.9-4
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 21, DRY PLANT #2 CONVEYORS

Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Emission Unit
Number of
Emission
Units
PM10
Emission
Factor
(lb/ton)
PM2.5
Emission
Factor
(lb/ton)Reference
Crushers 0 0.00054 0.00010
Screens 0 0.00074 0.00005
Conveyor Transfer Points 4 4.6E-05 1.3E-05
Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)
PM10 0.03 0.12
PM2.5 0.01 0.03
Emission Unit
PM10
Emission
Rate
(lbs/hr)
PM10
Emission
Total
(tons/year)
PM2.5
Emission
Rate
(lbs/hr)
PM2.5 Emission
Total
(tons/year)
Crushers 0.00 0.00 0.00 0.00
Screens 0.00 0.00 0.00 0.00
Conveyors 0.03 0.12 0.01 0.03
Aggregate Processing Equipment
AP-42
Table 11.19.2-2
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 22, BAGHOUSE WASTE

Storage Pile Area
Total Area of Storage Piles 1 acres
Control Efficiency
PM10 Control Efficiency 66%
PM2.5 Control Efficiency 40%
Pollutant
Uncontrolled
Emission
Factor
(lb/acre-day)
Controlled
Emission
Factor
(lb/acre-day)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 6.30 2.14 0.04 0.20 AP-42 Fourth Edition Table 8.19.1-1
PM2.5 1.85 1.11 0.02 0.10 AP-42 Appendix B.2 Table B.2-2
Storage Piles
AP-42 Appendix B.2
Tables B.2-2 & B.2-3
Reference
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 23, HAUL ROAD – DRY PLANT

Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Loader Information
Empty Loader Weight 22 tons
Weight of Load 43 tons
Loaded Loader Weight 65 tons
Loader Route\ Information
Loader Route One-Way Length 1,069 feet
Hourly Vehicle Miles Traveled 1.4 miles
Annual Vehicle Miles Traveled 12,374 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.33 0.46 2.02
PM2.5 0.218 0.033 0.05 0.20
Loader Routes
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
Page 1 of 1
Version 1.0
November 29, 2018

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 24, DIESEL TANK BREATHING LOSS

TANKS 4.0.9d
Emissions Report - Detail Format
Tank Indentification and Physical Characteristics
IdentificationUser Identification:Tank1
City:Roosevelt
State:UtahCompany:Wildcat SandType of Tank:Horizontal TankDescription:#2 Fuel Horizontal Tank
Tank Dimensions
Shell Length (ft):27.00Diameter (ft):8.00Volume (gallons):5,000.00
Turnovers:30.80
Net Throughput(gal/yr):154,000.00
Is Tank Heated (y/n):NIs Tank Underground (y/n):N
Paint Characteristics
Shell Color/Shade:White/White
Shell Condition Good
Breather Vent SettingsVacuum Settings (psig):-0.03Pressure Settings (psig)0.03
Meterological Data used in Emissions Calculations: Salt Lake City, Utah (Avg Atmospheric Pressure = 12.64 psia)
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TANKS 4.0.9d
Emissions Report - Detail Format
Liquid Contents of Storage Tank
Tank1 - Horizontal Tank
Roosevelt, Utah
Daily Liquid Surf.Temperature (deg F)
Liquid
BulkTemp Vapor Pressure (psia)VaporMol.LiquidMass VaporMass Mol.Basis for Vapor Pressure
Mixture/Component Month Avg.Min.Max.(deg F)Avg.Min.Max.Weight.Fract.Fract.Weight Calculations
Distillate fuel oil no. 2 All 53.92 47.99 59.86 51.98 0.0053 0.0042 0.0065 130.0000 188.00 Option 1: VP50 = .0045 VP60 = .0065
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TANKS 4.0.9d
Emissions Report - Detail Format
Detail Calculations (AP-42)
Tank1 - Horizontal Tank
Roosevelt, Utah
Annual Emission Calcaulations
Standing Losses (lb):1.6357 Vapor Space Volume (cu ft):864.4382 Vapor Density (lb/cu ft):0.0001 Vapor Space Expansion Factor:0.0416 Vented Vapor Saturation Factor:0.9989
Tank Vapor Space Volume: Vapor Space Volume (cu ft):864.4382 Tank Diameter (ft):8.0000 Effective Diameter (ft):16.5879 Vapor Space Outage (ft):4.0000 Tank Shell Length (ft):27.0000
Vapor Density Vapor Density (lb/cu ft):0.0001
Vapor Molecular Weight (lb/lb-mole):130.0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia):0.0053 Daily Avg. Liquid Surface Temp. (deg. R):513.5939 Daily Average Ambient Temp. (deg. F):51.9625 Ideal Gas Constant R (psia cuft / (lb-mol-deg R)):10.731 Liquid Bulk Temperature (deg. R):511.6525 Tank Paint Solar Absorptance (Shell):0.1700 Daily Total Solar Insulation Factor (Btu/sqft day):1,452.1184
Vapor Space Expansion Factor Vapor Space Expansion Factor:0.0416 Daily Vapor Temperature Range (deg. R):23.7301 Daily Vapor Pressure Range (psia):0.0023 Breather Vent Press. Setting Range(psia):0.0600 Vapor Pressure at Daily Average Liquid Surface Temperature (psia):0.0053
Vapor Pressure at Daily Minimum Liquid Surface Temperature (psia):0.0042 Vapor Pressure at Daily Maximum Liquid Surface Temperature (psia):0.0065 Daily Avg. Liquid Surface Temp. (deg R):513.5939 Daily Min. Liquid Surface Temp. (deg R):507.6614 Daily Max. Liquid Surface Temp. (deg R):519.5264 Daily Ambient Temp. Range (deg. R):23.3583
Vented Vapor Saturation Factor Vented Vapor Saturation Factor:0.9989 Vapor Pressure at Daily Average Liquid: Surface Temperature (psia):0.0053 Vapor Space Outage (ft):4.0000
Working Losses (lb):2.5191 Vapor Molecular Weight (lb/lb-mole):130.0000 Vapor Pressure at Daily Average Liquid
Surface Temperature (psia):0.0053 Annual Net Throughput (gal/yr.):154,000.0000 Annual Turnovers:30.8000 Turnover Factor:1.0000 Tank Diameter (ft):8.0000 Working Loss Product Factor:1.0000
Total Losses (lb):4.1548
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TANKS 4.0.9d
Emissions Report - Detail Format
Individual Tank Emission Totals
Emissions Report for: Annual
Tank1 - Horizontal TankRoosevelt, Utah
Losses(lbs)
Components Working Loss Breathing Loss Total Emissions
Distillate fuel oil no. 2 2.52 1.64 4.15
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FACILITY WIDE
PROPOSED EMISSION CALCULATIONS

Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand - Roosevelt Plant
Sand Plant
Emission Calculations
Facility PTE - 8760 hr/yr
PTE (lb/hr)PTE (lb/hr)
Emission
Type Unit
Particulate
Matter <10μ
(PM10)
Nitrogen Oxides
(NOX)
Particulate
Matter <10μ
(PM10)
Particulate
Matter <2.5μ
(PM2.5)
Nitrogen Oxides
(NOX)
Sulfur Oxides
(SOX)
Carbon
Monoxide
(CO)
Volatile Organic
Compounds
(VOC)
Lead
Compounds
Hazardous Air
Pollutants
(HAPs)
Point 01 Bucket Elevator Transfer to Silo**SILOTR 0.0018 0.0079 0.0012
Point 02 Dryer #1 Stack with Baghouse and Cyclone DRYER1 1.0700 4.6900 4.6900
Point 02 Dryer #1 Combustion DRYER1 4.7800 20.9400 0.0000 24.9700 1.9200 0.0001 0.3297
Point 03 Dryer #2 Stack with Baghouse and Cyclone DRYER2 2.9900 13.0900 13.0900
Point 03 Dryer #2 Combustion DRYER2 4.4400 19.4500 0.1000 13.6300 1.7800 0.0001 0.3063
Fugitive 04 Haul Road - Additional Exit from Plant HR2NDEXIT 0.2900 1.2500 0.1300
Fugitive 05 Haul Road - Final Product HRLDOUT 0.3300 1.4500 0.1500
Fugitive 06 Haul Road - WIP Pile #2 to WIP Pile #3 HRWIP 0.5200 2.2700 0.2300
Fugitive 07 Haul Road - Loader to Wet Plant HRLOAD 1.3500 5.9100 0.5900
Point 08 J & H Screen Baghouse Stack*SCRNSTK 0.9600 4.2200 4.2200
Fugitive 09 Secondary Crushing 2NDCRUSH 0.1600 0.7100 0.1300
Fugitive 10 Stockpile Pre-Wash Plant PILE1 0.0500 0.2300 0.1200
Fugitive 11 Truck Unloading to Dry Plant #1 TRNSDP1 0.0900 0.3900 0.0600
Fugitive 12 Truck Unloading to Dry Plant #2 TRNSDP2 0.0900 0.3900 0.0600
Fugitive 13 Truck Unloading to Wet Plant TRNSWP 0.1800 0.7900 0.1200
Fugitive 14 Truck Unloading to WIP Pile #3 TRNSWIP3 0.0900 0.3900 0.0600
Fugitive 15 WIP Stockpile #2 PILE2 0.1400 0.5900 0.3100
Fugitive 16 WIP Stockpile #3 PILE3 0.2500 1.0900 0.5600
Fugitive 17 Existing Conveyors and Drop Points CONVYRS 0.1900 0.8500 0.2400
Point 18 Unloading Sand Storage Silos #1 - #3**SILOS 0.0004 0.0018 0.0005
Point 19 Engine - Filter Press[1]FPGENSET 0.0300 0.9100 0.1300 0.1300 4.0100 0.0100 8.0100 1.5000 0.0000 0.9200
Fugitive 20 Disturbed Area DISAREA 0.6100 2.6600 0.4000
Fugitive 21 New Dry Plant #2 Conveyors**CONVDRY2 0.0003 0.0012 0.0003
Fugitive 22 Enclosed Baghouse Waste Collection Area ***BHWASTE 0.0100 0.0500 0.0250
Fugitive 23 Haul Road - Loader to Dry Plant HRDRY 0.4600 2.0200 0.2000
Fugitive 24 Fuel Oil Storage Tank TANK1 0.0021
5.05 10.13 22.14 22.13 44.40 0.11 46.61 5.20 0.00 1.56
4.81 0.00 21.04 3.39 0.00 0.00 0.00 0.00 0.00 0.00
9.86 10.13 43.18 25.52 44.40 0.11 46.61 5.20 0.00 1.56
[1] Tier 2 Natural Gas Engine meets 40 CFR 60.4223(e) and Table 1 emission standards
*Based on fabric filter baghouse Manufacturer Gaurantee of 0.005 gr/dscf
** All product handling post dryers are controlled with a dust collector and silo bin vent filter with a control efficiency >99%
*** Baghouse waste is in an enclosed building
Facility PTE (tpy)
Description
Point
Fugitive
Facility PTE
Prepared with Assistance from Air Regulations Consulting, LLC
2. Haul Road Visual
Map Prepared By:Revision: 1.0 Air Regulations Consulting, LLCDate Prepared: 2/21/2024 Title: Wildcat Sand – Haul Road Description
Legend
Property Boundary
Stockpiles
HR2NDEXIT
HRWIP
HRLOAD
HRDRY
HRLDOUT
File Edited by Air Regulations Consulting, LLC
This comment clarifies the process the haul roads use at the facility. There are 5 main
haul roads/loader routes at the facility. The names for each haul road are taken from
submissions provided by Wildcat. Loader route #3 (HRLOAD) is used by incoming
trucks shipping sand into the facility. These are taken to the wet plant loading area.
Product is processed in the wet plant and deposited into storage pile #2. Loader route
#2 (HRWIP) is a haul road between wet plant storage piles #2 and #3. The wet product
is moved from storage pile #3. From there, product is transferred via haul road #2
(HRDRY) from the wet plant to the dry plant entrance. The sand is processed through
the dryers at this stage and deposited to the final product area. The final product is
shipped out via loader route #1 (HRLDOUT), which is a paved road that exits the
facility. Haul road #1 (HR2NDEXIT) is an alternative route out of the facility. This road
only has the capacity to transfer 150 tons of product per hour, and is thus calculated
to process half of the usual amount of product as the other haul roads and loader
routes.

March 20, 2024

Matthew J. Hyita
VP of Operations
Wildcat Sand

In reference to your inquiry for an ultra-low NOX Burner on the Fluid Bed Dryer for your facility. In brief,
ultra-low NOX technologies are not typically feasible on this type of Dryer. A Fluid Bed Dryer is
described as using heated process air to make the Sand or Mineral to react as a fluid. This heated air
removes the moisture from the mineral and moves the mineral from feed to discharge of the
Dryer. This process is very fuel eƯicient because of a very low oƯ gas temperature and very eƯicient
heat transfer from the heated air to the Mineral. The Fluid Bed Dryer operates under about One Pound
of Positive pressure. Typically, Fluid Bed Dryers low NOX numbers because of the excess air required
for Fluidization.
In contrast, a Rotary dryer process usually operates under atmospheric pressure, which can
sometimes use diƯerent burner technologies dependent on the industry. Burners that are designed
for atmospheric pressure systems will not function correctly for the positive pressure required on a
Fluid Bed Dryer.

Sincerely
Scott F. Briel

___________________________________________________
Thermal Kinetics Corporation
Fluid Bed Dryer Designers, Engineers, and Manufactures
751 N Bolingbrook Drive, Building 18
Bolingbrook Il 60440
Disturbed Area: Item 20
Description
Wildcat currently applies watering operations per permit condition II.B.7.c. to decrease
particulate emissions associated with the 10.92 acres of disturbed areas at the facility. The facility
utilizes a water truck to maintain the disturbed areas with enough moisture to mitigate fugitive
dust emissions. The facility plans to increase the disturbed area to 13.99 acres with the increase
of an additional sand dryer; an additional 3.07 acres.
Emissions
Emissions were calculated using the DAQ’s Disturbed Area spreadsheet, utilizing the wind erosion
of exposed areas’ TSP emission factor from AP-42 Table 11.9-4 and AP-42 Section 13.2.5.3 to
calculate particulate matter contents for particles less than 10 micrometers in diameter (PM10)
and particles less than 2.5 micrometers in diameter (PM2.5). The increase in emissions for the
additional disturbance area is 0.58 tons PM10 per year and 0.09 tons PM2.5 per year.
Controls
Control Opportunities Control Efficiencies
Watering exposed areas 70%
Planting vegetation 100%

Technical Feasibility
Water is currently applied to the facility’s disturbed area for the 10.92 acres. Watering at all times
may not always be feasible for Wildcat’s newly established disturbed area due to acreage and
the hot, dry Utah climate. The planting of local vegetation around disturbed areas that are not
reclaimed quickly would reduce particulate emissions. In areas of low disturbance, local
vegetation can be used, and no additional watering would be needed, and the root structure of
the plants would help minimize the availability of particulate matter and return the exposed
areas to native land reducing emissions. Minimal disturbance of the area helps minimize
emissions by reducing the availability of smaller particulate matter at the surface, which can be
present by continual disturbance.
Economic Feasibility
Vegetation
Planting vegetation is applied with a high-pressure hose with a slurry of seed and mulch is
sprayed onto the disturbed area with seeds, also known as hydroseeding. The costs for
hydroseeding can vary, but average around 12 cents per ft2 [1], or $5,227.22 per acre. Given that
Wildcat would require 3.07 acres to be seeded this cost would be $16,058 annually. Vegetation
would control 100% of emissions and 1 acre of exposed area PM10 emissions are 0.19 tons
annually, and PM2.5 emissions are 0.03 tons annually, the cost per ton removed per acre would
be $27,512 and $174,241 respectively.
Pollutant
Emissions
(tpy)
Controlled
Emissions
(tpy)
Initial
Capital Cost
$/ton/acre
Annual O&M
Cost
($/tpy/acre)
10-Year Annualized
Total Cost
($/tpy/acre)
PM10 0.19 0.00 $27,512 $27,512 $30,263
PM2.5 0.03 0.00 $174,241 $174,241 $191,665

Watering
As noted, the facility is watering the 10.92 acres of disturbed area and therefore there is not an
initial capital cost associated with the watering. According to Roosevelt City’s County Water Rates
and Fees [2], the cost is $3 per 1,000 gallons for rates at or more than 60,000 gallons per month.
At 0.09 gallons per ft2 [3] the facility will on average increase the water usage by 378,695 gallons
per month. Annually, it’s estimated that the facility’s updated water usage will cost $13,633.
Pollutant
Emissions
(tpy)
Controlled
Emissions
(tpy)
Initial
Capital Cost
$/ton/acre
Annual O&M
Cost
($/tpy/acre)
10-Year Annualized
Total Cost
($/tpy/acre)
PM10 0.19 0.06 $0 $102,504 $102,504
PM2.5 0.03 0.00 $0 $649,191 $649,191

Findings and Selected Control
The control option that is technically feasible and economically viable is watering the additional
disturbed areas of the facility. Watering will prevent emitting surface particulates and will help
reduce fugitive emissions on site. This option is deemed BACT for exposed and disturbed areas.
Planting vegetation was eliminated due to the economic burden it would place on Wildcat as
they are continually mined and increase the volume of these areas.
Additionally, Wildcat will comply with R307-309 and implement the controls necessary to
maintain the opacity limitations listed in the rule. Maintaining the 20% opacity on site and the

1 https://www.forbes.com/home-improvement/lawn-care/hydroseeding-cost/
2 https://rooseveltcity.com/160/County-Water-Water-Rates-and-Fees
3https://www.corgin.co.uk/overview/dust-
suppression#:~:text=Outdoor%20dust%20suppression%20during%20hot,use%20a%20lot%20less%20water.
10% opacity at the property boundary are considered BACT, common practice demonstrates that
this can be met via minimal disturbance of exposed areas.

AIR REGULATIONS CONSULTING, LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM

March 6, 2024

Dylan Frederick
Environmental Engineer, Minor NSR Section
Division of Air Quality
Utah Department of Environmental Quality
PO Box 144820
Salt Lake City, Utah 84114-4820

[Submitted electronically to [e-mail]]

RE: Response to Management Review Information Request Email Sent February 9, 2024
Wildcat Sand, LLC – Uintah County Sand Processing Plant
DAQE-AN159980003-21
Uintah County, UT

Dear Mr. Dylan Frederick,

Air Regulations Consulting, LLC (ARC), on behalf of Wildcat Sand, LLC (Wildcat), is submitting a response
to the information request from the Utah Department of Environmental Quality’s Division of Air Quality
(DAQ) sent to ARC and Wildcat on February 9, 2024. This information request is in response to the Notice
of Intent (NOI) application submitted on June 30, 2023. A response following each of the requested items
is listed below in bold.

1. It was requested that the engine be evaluated for a lower NOx emission rate. We have seen rates
of 0.5 g/hp-hr NOx from engines that did not require SCR. At the very least we need emission
estimates and cost estimates for an engine that can meet an emission rate of 0.5 g/hp-hr NOx.

Wildcat will not be implementing a new engine and will operate the currently permitted engine.

2. A BACT analysis for Disturbed Area was requested as the total area increased from 10.92 acres to
14.

See attached for a revision to the BACT.

3. We need a clearer explanation of the haul road lengths/loader routes. Management thought the
lengths of the roads were quite long and the diagram provided in the NOI doesn’t label these or
show how each haul road/ loader route fits together. I would recommend a project narrative
explaining the process so we can account for each haul road section.

See attached for a visual of the routes.
Haul Road Description Length
HR2NDEXIT Additional Exit from Plant 201.7 Meters
HRLDOUT Final Product 701.6 Meters
HRWIP WIP Pile #2 to WIP Pile #3 732.4 Meters
HRLOAD Loader to Wet Plant 476.5 Meters
HRDRY WIP to Dry Plant 325.8 Meters
Wildcat Sand, LLC – Uintah County Sand Processing Plant
Information Request Response
March 6, 2024
Page 2

4. Can you explain why haul road #1 on the NOI has an input of 1,314,000 tons per year?

Item 4, Haul Road – 2nd Exit (HR2NDEXIT) is utilized seldomly but has the potential to move
product at a rate of 150 tph. To calculate for PTE, 8,760 hr/yr was utilized to acquire 1,314,000
tph.

5. Which haul road/loader route brings sand into the facility? This goes along with item #3, as its
unclear which haul road/loader route performs which function.

Raw material is transferred via HRLOAD, the emissions are captured in HRLDOUT to avoid
double counting.

6. I will need to add a condition to the approval order for the paved section of the haul road as the
NOI indicates that "Item 5, Haul Road, Final Product" is a paved section of the haul road and
estimates emissions as such. Let me know if this is correct, the condition will require the one way
length of this haul road of 1,151 feet be paved.

Correct.

7. The last permit had a stack testing limit of 1.07 lb/hr for the existing dryer. Why did the lb/hr
increase in this modification?

DAQ is correct, the limit for Dryer 1 is 1.07 lb PM10/hr.

8. It looks like the formaldehyde totals confirmed on 10-25-23 are higher than the totals that were
submitted for modeling? The modeling team showed a 0.00 lb/hr emission rate for the engine
which doesn’t look correct. It should be .178 lb/hr based on the submissions I’ve received. I've
checked in with modeling to see if this needs to be addressed.

DAQ confirmed on a Teams call from February 21, 2024 that no further action is needed at this
time regarding the formaldehyde modeling.

9. Finally, management wanted to ask for an evaluation of other dryer burner options. 96 ppm is the
proposed limit and this seems high for a dryer and isn’t considered a low-NOx option. For
comparison, management has noted that asphalt facilities utilize dryers that can reach 36 ppm
NOx. The proposed dryer is at more than 2.5 times the NOx emission rate of asphalt dryers. At the
very least I could use some understanding on why the difference is so large compared to other
industrial dryers. I was also curious why the analysis states dryer efficiency would be reduced by
17% for Low-NOx burners, but requires a 50% increase in size to accommodate the same
production rate with lower NOx options.

ARC response.

Wildcat Sand, LLC – Uintah County Sand Processing Plant
Information Request Response
March 6, 2024
Page 3

Should the DAQ have any questions regarding the enclosed information, please contact Eric Sturm at
402.817.7887 or [e-mail].

Sincerely,

Eric Sturm Sydney Stauffer
Principal, Sr. Consultant, ARC Sr. Consultant, ARC

Enclosures

Cc: Matthew Hyita, Plant Manager, Wildcat

3/19/24, 10:48 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1793333635536510648&simpl=msg-f:1793333635536510648 1/4
Dylan Frederick <[e-mail]>
Management Review Information Request
Eric Sturm <[e-mail]>Tue, Mar 12, 2024 at 9:10 AM
To: Dylan Frederick <[e-mail]>
Cc: Sydney Stauffer - ARC <[e-mail]>, Matt Hyita <[e-mail]>
Dylan,

It looks like I aached the wrong file last night. Please disregard the previous aachment and use the aached BACT
analysis for the haul roads.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Eric Sturm <[e-mail]>
Sent: Monday, March 11, 2024 9:48 PM
To: 'Dylan Frederick' <[e-mail]>
Cc: Sydney Stauffer - ARC <[e-mail]>; 'Ma Hyita' <[e-mail]>
Subject: RE: Management Review Informaon Request

Dylan,

Following back up regarding the discussion with you and Alan in late February. Items #1-9 were addressed on the
call. Summary of each item below and aached. Wildcat would like to have the NOI put to public noce soon. We
are available all week to address each item again, and this is a top priority. We can meet at your offices to discuss any
remaining quesons.

3/19/24, 10:48 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1793333635536510648&simpl=msg-f:1793333635536510648 2/4
1. It was requested that the engine be evaluated for a lower NOx emission rate. We have seen rates of 0.5 g/hp-hr
NOx from engines that did not require SCR. At the very least we need emission esmates and cost esmates for
an engine that can meet an emission rate of 0.5 g/hp-hr NOx.

Wildcat will not be implemenng a new engine and will operate the currently permied engine. The DAQ can
disregard any modificaon for the engine.

2. A BACT analysis for Disturbed Area was requested as the total area increased from 10.92 acres to 14.

See aached for a revision to the BACT.

3. We need a clearer explanaon of the haul road lengths/loader routes. Management thought the lengths of the
roads were quite long and the diagram provided in the NOI doesn’t label these or show how each haul road/
loader route fits together. I would recommend a project narrave explaining the process so we can account for
each haul road secon.

See aached for a visual of the routes.
Haul Road Descripon Length
HR2NDEXIT Addional Exit from Plant 201.7 Meters
HRLDOUT Final Product 701.6 Meters
HRWIP WIP Pile #2 to WIP Pile #3 732.4 Meters
HRLOAD Loader to Wet Plant 476.5 Meters
HRDRY WIP to Dry Plant 325.8 Meters

4. Can you explain why haul road #1 on the NOI has an input of 1,314,000 tons per year?

Item 4, Haul Road – 2nd Exit (HR2NDEXIT) is ulized seldomly but has the potenal to move product at a rate of 150
tph. To calculate for PTE, 8,760 hr/yr was ulized to acquire 1,314,000 tph.

5. Which haul road/loader route brings sand into the facility? This goes along with item #3, as its unclear which
haul road/loader route performs which funcon.

3/19/24, 10:48 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1793333635536510648&simpl=msg-f:1793333635536510648 3/4
Raw material is transferred via HRLOAD, the emissions are captured in HRLDOUT to avoid double counng.

6. I will need to add a condion to the approval order for the paved secon of the haul road as the NOI indicates
that "Item 5, Haul Road, Final Product" is a paved secon of the haul road and esmates emissions as such. Let
me know if this is correct, the condion will require the one way length of this haul road of 1,151 feet be paved.

Correct.

7. The last permit had a stack tesng limit of 1.07 lb/hr for the exisng dryer. Why did the lb/hr increase in this
modificaon?

DAQ is correct, the limit for Dryer 1 is 1.07 lb PM10/hr.

8. It looks like the formaldehyde totals confirmed on 10-25-23 are higher than the totals that were submied for
modeling? The modeling team showed a 0.00 lb/hr emission rate for the engine which doesn’t look correct. It
should be .178 lb/hr based on the submissions I’ve received. I've checked in with modeling to see if this needs to
be addressed.

DAQ confirmed on a Teams call from February 21, 2024 that no further acon is needed at this me regarding the
formaldehyde modeling.

9. Finally, management wanted to ask for an evaluaon of other dryer burner opons. 96 ppm is the proposed
limit and this seems high for a dryer and isn’t considered a low-NOx opon. For comparison, management has
noted that asphalt facilies ulize dryers that can reach 36 ppm NOx. The proposed dryer is at more than 2.5
mes the NOx emission rate of asphalt dryers. At the very least I could use some understanding on why the
difference is so large compared to other industrial dryers. I was also curious why the analysis states dryer
efficiency would be reduced by 17% for Low-NOx burners, but requires a 50% increase in size to accommodate
the same producon rate with lower NOx opons.

Asphalt dryers are a completely different SIC code. 96 ppm is the lowest NOx rate permied to a minor source for
SIC 1446. The burner used for the referenced 36 ppm NOx cannot be used at Wildcat for mulple reasons;
primarily, the top two reasons are (1), Wildcat is using a fluid bed dryer, which requires certain specifics for
combuson, and (2), Wildcat is not asphalt drying; it is a sand dryer. Either way, the 36 ppm burner is not an
opon for Wildcat in the top down process and cannot be considered on technical and praccal bases.

Eric Sturm
[Quoted text hidden]
3/19/24, 10:48 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1793333635536510648&simpl=msg-f:1793333635536510648 4/4
Disturbed Area BACT.pdf
169K
Equipment Details
Rating 415 hp = (309.8 kw)
Operational Hours 8,760 hours/yearEngine Type
Criteria Pollutant
EmissionStandards
(g/hp-hr)
Emission Factor
(lb/MMBtu)
EmissionRate
(lbs/hr)
EmissionTotal
(tons/year)Reference
NOX 1.0 0.91 4.01
CO 2.0 1.83 8.01
PM10 9.99E-03 0.03 0.13
PM2.5 9.99E-03 0.03 0.13
VOC 1.18E-01 0.34 1.50
SO2 5.88E-04 0.00 0.01
HAP 0.21 0.92 See Below
Green House Gas Pollutant
Global Warming
Potential
Emission Factor
(lb/MMBtu)
EmissionRate
(lbs/hr)
EmissionTotal
(tons/year)Reference
CO2 (mass basis)1 1.10E+02 320 1,400
Methane (mass basis)25 1.25E+00 4 16CO2e1,797
Hazardous Air Pollutant
EmissionRate
(lbs/hr)
EmissionTotal
(tons/year)Reference
1,1,2,2-Tetrachloroethane 4.00E-05 1.16E-04 5.09E-04
1,1,2-Trichloroethane 3.18E-05 9.24E-05 4.05E-041,3-Butadiene 2.67E-04 7.76E-04 3.40E-031,3-Dichloropropene 2.64E-05 7.67E-05 3.36E-04
2,2,4-Trimethylpentane 2.50E-04 7.26E-04 3.18E-03
2-Methylnaphthalene 3.32E-05 9.64E-05 4.22E-04Acenaphthene1.25E-06 3.63E-06 1.59E-05Acenaphthylene5.53E-06 1.61E-05 7.04E-05
Acetaldehyde 8.36E-03 2.43E-02 1.06E-01
Acrolein 5.14E-03 1.49E-02 6.54E-02
Benzene 4.40E-04 1.28E-03 5.60E-03
Benzo(b)fluoranthene 1.66E-07 4.82E-07 2.11E-06Benzo(e)pyrene 4.15E-07 1.21E-06 5.28E-06benzo(g,h,i)perylene 4.14E-07 1.20E-06 5.27E-06
Biphenyl 2.12E-04 6.16E-04 2.70E-03Carbon Tetrachloride 3.67E-05 1.07E-04 4.67E-04Chlorobenzene3.04E-05 8.83E-05 3.87E-04
Chloroform 2.85E-05 8.28E-05 3.63E-04
Chrysene 6.93E-07 2.01E-06 8.82E-06Ethylbenzene3.97E-05 1.15E-04 5.05E-04Ethylene Dibromide 4.43E-05 1.29E-04 5.64E-04
Fluoranthene 1.11E-06 3.22E-06 1.41E-05
Fluorene 5.67E-06 1.65E-05 7.21E-05Formaldehyde5.28E-02 1.53E-01 6.72E-01
Methanol 2.50E-03 7.26E-03 3.18E-02
Methylene Chloride 2.00E-05 5.81E-05 2.54E-04n-Hexane 1.11E-03 3.22E-03 1.41E-02Naphthalene7.44E-05 2.16E-04 9.47E-04
PAH 2.69E-05 7.81E-05 3.42E-04
Phenanthrene 1.04E-05 3.02E-05 1.32E-04Phenol2.40E-05 6.97E-05 3.05E-04Pyrene1.36E-06 3.95E-06 1.73E-05
Styrene 2.36E-05 6.86E-05 3.00E-04Tetrachloroethane2.48E-06 7.20E-06 3.16E-05Toluene4.08E-04 1.19E-03 5.19E-03Vinyl Chloride 1.49E-05 4.33E-05 1.90E-04Xylene1.84E-04 5.35E-04 2.34E-03
Emission Factor
(lb/MMBtu)
Natural Gas-Fired Engines
AP-42 Table 3.2-1,
Table 3.2-2, &Table 3.2-3
AP-42 Table 3.2-1,
Table 3.2-2, &Table 3.2-3
(Some HAP do not
popluate based on the type of engine selected. AP-42 does not list certain
HAP for certain types of engines.)
Manufacturer Data,AP-42 Table 3.2-1,Table 3.2-2, &
Table 3.2-3
4-Stroke Lean-Burn
Emergency Engines should
equal 100 hours of operation per year
Page 1 of 1 Version 1.1
February 21, 2019
Dylan Frederick <[e-mail]>
Management Review Information Request
Eric Sturm <[e-mail]>Fri, May 24, 2024 at 3:00 PM
To: Dylan Frederick <[e-mail]>
Cc: Matt Hyita <[e-mail]>, Alan Humpherys <[e-mail]>, Sydney Stauffer - ARC <[e-mail]>
Dylan,

The calc we provided DAQ is set to the max that DOT allows. The max gross allowable is actually 129,000 lbs. Please see aached, as circled on the first
page. ARC used 129,000 lbs in the haul road calcs given that would be worst case (highest eming scenario). The DAQ calc does not show the decimal
place, so the 65 tons looks like 130,000 lbs, but if the DAQ’s Excel were editable to show more a decimal place, you would see the 129,000 lbs reference.

This is geng a bit out of bounds. Wildcat is UT DOT compliant, as their records show, along with the aachment. Wildcat’s dealings with DOT does not
have a nexus to this permit. The haul road emissions are not an issue.

Nonetheless, because you asked, and we want to keep things moving, Wildcat’s trucking company is providing the latest DOT permit and inspecon.
Notably, Barney Trucking handles all shipments from Wildcat. The first page shows the allowable max gross weight of 129,000 lbs. The next two pages show
the compliant determinaons from DOT.

I’ll be following up by phone to you in a bit.

If you have any more quesons, I’d ask that you call me this aernoon so this can be closed out.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Friday, May 24, 2024 3:08 PM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC <[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

It looks like UDOT regulations require a permit for every trip over 125,000 tons of product (See R909-2-26). If I'm reading this correctly you need a permit for
every trip each truck takes out of the facility at these load weights. If you can provide your permit to show the weights you're approved for that could help clear up
any confusion.

On Fri, May 24, 2024 at 1:00 PM Eric Sturm <[e-mail]> wrote:
Dylan, the numbers provided are correct. Trucks shipped from Wildcat are dual trailer. 23 tons empty, payload of 43 tons, and total weight of 65 tons.

5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:1799969268977973…1/21
Wildcat’s shipping trucks are DOT inspected and approved. Perhaps DAQ’s confusion is due to the dual trailer aspect. DOT allows these types of trucks
for shipping product, and I would add that these are quite common.

I’m going to call you in 15 min to confirm understanding on this, or address further, if needed.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Friday, May 24, 2024 1:28 PM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC <[e-mail]>
Subject: Re: Management Review Informaon Request

Thank you Eric. There was one last issue, we discussed the haul road weights within the facility, that explanation made sense. But wouldn't the weights need
to be different for haul roads exiting the facility? These trucks would be exiting the property and shipping completed product off site correct?

On Thu, May 23, 2024 at 4:42 PM Eric Sturm <[e-mail]> wrote:
Okay, you are correct. There was a Tarmac spec sheet that we had for a similar new 150 tph rotary unit, like Dryer 1. That Tarmac spec had a rate of
5.7 lb/hr for CO, so we used that for Dryer 1.

5.7 lb/hr for CO on Dryer 1 is slightly higher than the AP42 rate. To be conservave, we deferred to the Tarmac CO rate.

If you are okay using that, let’s sck with that. I updated the footnote on the PTE for Dryer 1 to clarify. See aached.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, May 23, 2024 5:04 PM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Management Review Informaon Request

5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:1799969268977973…2/21
This was for Dryer #1. The lb/hr rate in the spreadsheet doesn't seem to match with the AP-42 estimation. I found where the NOx lb/hr rate came from in our
boiler estimation sheets, I just couldn't tell where the CO lb/hr rate came from for dryer #1.
On Thu, May 23, 2024 at 3:02 PM Eric Sturm <[e-mail]> wrote:
Hey Dylan,

Are you asking about Dryer 1 or Dryer 2? My understanding is that the current permit used AP42 for CO emission rates on Dryer 1. We stayed with
that approach for Dryer 2 and this NOI.

We did not see a CO guarantee for this unit. It seems fair to sck with the AP42 emission rate for CO.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, May 23, 2024 3:56 PM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

I've gone over the spreadsheets you sent. I think I understand everything a lot better and the calculations look correct for the most part. I've submitted
some slight edits to clarify the citations and be conservative with the estimates. My one question is where did the CO lb/hr figure come from for the old
dryer? And was there manufacturer specific data for the CO emission rate?

On Thu, May 23, 2024 at 10:49 AM Eric Sturm <[e-mail]> wrote:
Dylan,

For the call we are having right now, and the queson about the haul road. The high weight for the mine truck, as full with payload, is correct.
Although that weight is above DOT standards, the mine truck only stays on the plant/mine site. It does not go on public roads (or when it does, it
is empty). So, it is all compliant with DOT.

If there is anything further to clarify, please let me know.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:1799969268977973…3/21
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, May 23, 2024 11:08 AM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

I can send a google meet invite, does that work for you?

On Thu, May 23, 2024 at 9:11 AM Dylan Frederick <[e-mail]> wrote:
Lets try for 10:30 then. Can you send a Teams invite?

On Thu, May 23, 2024 at 9:04 AM Eric Sturm <[e-mail]> wrote:
Yes

Eric Sturm, ARC

On Thu, May 23, 2024, 10:02 AM Dylan Frederick <[e-mail]> wrote:
Eric,

Does 10:30 or 11 work for you?

On Wed, May 22, 2024 at 3:04 PM Eric Sturm <[e-mail]> wrote:
Hi Dylan,

No worries. Tomorrow is fine. Let me know what works for you, and I will make it happen. Sydney is off tomorrow, so feel free to send
the invite directly to me.

Hope you feel beer soon.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:1799969268977973…4/21
From: Dylan Frederick <[e-mail]>
Sent: Wednesday, May 22, 2024 4:01 PM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

Apologies, I've been sick today with food poisoning. I believe we can still meet tomorrow morning, please let me know what time works for
you.

On Tue, May 21, 2024 at 4:24 PM Eric Sturm <[e-mail]> wrote:
Dylan,

Could we do Wednesday by chance?

If not, we’ll make Thursday morning work.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, May 21, 2024 5:13 PM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

If you'd like I can meet thursday morning. I've gone over the submissions with management and I wanted to double check everything
tomorrow to be ready for our meeting. Will that time work for you?

On Tue, May 21, 2024 at 1:00 PM Eric Sturm <[e-mail]> wrote:
Dylan,

Thank you for the communicaon on Wildcat’s project. If anything comes up today, or there is more we can clarify, please let me
know.

Eric Sturm
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:1799969268977973…5/21
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Friday, May 17, 2024 3:40 PM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Alan Humpherys <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

I can meet with Alan Tuesday to go over this when he gets back into the office. I'll have your responses reviewed at that time, and if we
need further clarification we can have a call to go over any remaining issues. Everything you've sent me seems to address the issues I
mentioned previously. I will contact you Tuesday to let you know if any further work is needed. Thanks for your quick response.

On Fri, May 17, 2024 at 10:43 AM Eric Sturm <[e-mail]> wrote:
Dylan,

Please see aached. Notably, we do not want #2 to hold maers up. Wildcat is okay with Dryer 1 retaining a PM10 limit of 1.07
lbs/hr, but it appears that previously incorrectly set and does not match BACT.

1. Provided/aached.

2. Wildcat is okay with Dryer 1 at 1.07 lbs/hr of PM10. Calculaons are updated accordingly in the aachment.

a. Notably, Wildcat would prefer the emission limit for Dryer 1 be 1.42 for all filterable PM (PM10 and PM2.5
included). This is consistent with BACT being 0.01 gr/dscf and the scfm at Dryer 1. The dryer stack has high
moisture such that a TM201A cannot be performed to determine the PM10 split, so it would be best to have a
single limit of 1.42 for all PM. We modeled PM10 at 1.42 lb/hr, and the BACT is 0.01 gr/dscf. Nonetheless, to
avoid any further delay, Wildcat is okay retaining the 1.07 lbs/hr for PM10 if DAQ would prefer.

b. Dryer 2 PM10 has always been 2.99 lbs/hr, which too matches 0.01 gr/dscf. No changes needed there.

3. Provided/aached.

4. Provided/aached.

Would it be helpful to have call today to review. If so, please send Sydney and me a Teams. We are free rest of day.

Thanks again.

5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:1799969268977973…6/21
Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Eric Sturm <[e-mail]>
Sent: Thursday, May 16, 2024 6:52 PM
To: 'Dylan Frederick' <[e-mail]>
Cc: 'Ma Hyita' <[e-mail]>; 'Alan Humpherys' <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: RE: Management Review Informaon Request

Hi Dylan,

Thank you for the response. We are working on each issue below, and will have each addressed for you in the morning.

Thanks again.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, May 16, 2024 4:15 PM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Alan Humpherys <[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

I got the review back a few days ago and I've been going over the comments to address how to get management approval for thisproject.
The following issues were brought up and I think this is the best way to address each issue:
1. The emission calculations as presented are causing confusion. Issues include the old dryer and new dryer being different sizes
but emitting the same emission rate, the HAP totals increasing significantly from the last permit due to the new engine calculations,
and the emission summary page being difficult to track with all the calculations spread out across different submissions. I think if you
could submit the emission summary with all emission calculations included in the same attachment that would help a lot.
2. The old dryer and the new dryer are calculated to have the same emission rate, but use a different emission limit in the stack
testing condition. Dryer 1 is 1.07 lbs/hr PM10, Dryer 2 is 1.42. The emission calculations should reflect these emission rates. I’d
recommend changing the first dryer’s PM10 rate to 1.07 lb/hr in the calculations and citing the previous limit in the last permit as the
reference. Otherwise we would need a BACT discussion for the old dryer to raise its stack test limit. We cannot use a calculation in
the NOI then not use it in the AO.
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:1799969268977973…7/21
3. The dryers are slightly different heat ratings and both are 96 ppm NOx. They should have different NOx/CO emission rates but the
calculations state they emit at the same rate. Please revise using the 96 ppm NOx rate for each dryer.
4. The loading and haul roads in particular were a source of confusion. We never got a visual to go along with the haul road lengths.
An explanation for why these haul road lengths are so long is also needed. I recommend a clear process description to help
understand how each part of the process connects. I’ve attempted an explanation (for the haul roads alone) based on informationI’ve received. That description is attached. Please look it over and let me know if I’ve accurately described the function of each haul
road. I recommend fully clarifying the full process step by step to help account for each emission source.

On Wed, May 15, 2024 at 4:51 PM Eric Sturm <[e-mail]> wrote:
Hi Dylan,

Checking in, as it has been another week of delay. When you get the chance, please provide a few mes available for you,
Alan, Wildcat, and ARC to meet. We will try to make any day work and will be flexible.

Thanks.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, May 8, 2024 6:16 PM
To: Eric Sturm <[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

I've asked my manager for the last review several times. Not sure what the hold up is, could be he's been busy with other
management duties. I can see about scheduling something for next week, if I get the review back tomorrow I'll either address all
his comments ASAP or forward the permit to you. Let me know if there's a day that works best next week, thanks.

On Wed, May 8, 2024 at 2:48 PM Eric Sturm <[e-mail]> wrote:
Dylan,

Any luck on this? Wildcat would like me to come sit down with the DAQ and finish the process. Could we schedule
something for next week or sometime soon?

Eric Sturm, ARC
m. 402.310.4211

On Fri, Apr 19, 2024, 4:04 PM Dylan Frederick <[e-mail]> wrote:
Eric,

I've been working on the comments my manager provided today, is it possible to provide a final emission summary so I can
confirm the emission totals I have are correct?
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:1799969268977973…8/21

On Thu, Apr 18, 2024 at 4:11 PM Dylan Frederick <[e-mail]> wrote:
Eric,

I asked my manager for an update, just had a short meeting with him. He is trying to get the review back to me today. If
he gets it back to me I'll address any comments he has first thing and let you know where the permit is at.

On Thu, Apr 18, 2024 at 3:26 PM Eric Sturm <[e-mail]> wrote:
Hi Dylan,

We are a week later now. Can we get an update and/or a draft for review?

Eric Sturm, ARC
m. 402.310.4211

On Fri, Apr 12, 2024, 3:05 PM Dylan Frederick <[e-mail]> wrote:
Eric,

I asked my manager where he was at with this review, he said he would be working on it this afternoon. I'll keep you
posted once that is done.

On Wed, Apr 10, 2024 at 12:45 PM Eric Sturm <[e-mail]> wrote:
Hey Dylan,

How are things looking this week? Thanks again for your aenon and work on Wildcat’s NOI. Much
appreciated.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Friday, April 5, 2024 1:41 PM
To: Eric Sturm <[e-mail]>
Cc: Sydney Stauffer - ARC <[e-mail]>; Ma Hyita <[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

Yes, I had sent the permit back for internal reviews since the changes from the management reviews changed
quite a bit from the permit. We should hopefully have all management questions addressed, he just needs to signoff and we can get this permit out. I apologize for the time its taken to get this out, this should hopefully be the last
step before getting to public comment.

5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:1799969268977973…9/21
On Fri, Apr 5, 2024 at 8:04 AM Eric Sturm <[e-mail]> wrote:
Dylan,

When you say “back to management” – are you saying the dra AO might sll have another management
review?

I had thought we already addressed all management quesons, so hopefully, this is only a maer of
collecng the last review on Monday and moving forward towards our review and public noce.

It seems prey unfair how long Wildcat has had to wait given a complete NOI was submied in July 2023.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, April 4, 2024 5:34 PM
To: Eric Sturm <[e-mail]>
Cc: Sydney Stauffer - ARC <[e-mail]>; Ma Hyita
<[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

I'm just waiting on the last reviews of the revised permit. One person is out of town until Monday so that is why
there's been a bit of a delay. I should have this back to management after Monday.

On Thu, Mar 28, 2024 at 1:10 PM Eric Sturm <[e-mail]> wrote:
Dylan, can we get an update? Or, perhaps the dra AO for review?

Again, we are offering to come to your offices to help finalize.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…10/21
From: Dylan Frederick <[e-mail]>
Sent: Thursday, March 21, 2024 4:46 PM
To: Eric Sturm <[e-mail]>
Cc: Sydney Stauffer - ARC <[e-mail]>; Ma Hyita
<[e-mail]>
Subject: Re: Management Review Informaon Request

Thanks Eric, I will add this in and send it for reviews today. I'll keep you posted on where the reviews are at
with the updates we've discussed the past few weeks.

On Thu, Mar 21, 2024 at 3:43 PM Eric Sturm <[e-mail]> wrote:
Hi Dylan,

My apologies for the confusion. You are correct on #1. The engine is 415 hp in DAQE-AN159980003-
21. Please retain the 415 hp in this permit acon.

You are also correct on the emissions be slightly less with retaining the 415 hp (as opposed to what
we submied in the NOI for PTE and modeling). The updated PTE calculaon for the 415 hp engine is
aached. Given the emissions decrease with the 415 hp, modeling is not an issue.

Hope this helps. Please let us know as the DAQ review finishes, and when we might see the dra
again.

Thanks

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, March 21, 2024 3:41 PM
To: Eric Sturm <[e-mail]>
Cc: Sydney Stauffer - ARC <[e-mail]>; Ma Hyita
<[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

I think we've closed out items 2 and 3. For Item 1, I had the last engine at the site as being 415 hp inDAQE-AN159980003-21, whereas this one was 360 kW or 482 hp. So there should be slightly less
combustion emissions from the engine. I just want to make sure the emission totals are accurate, but I'll
have the permit sent back for reviews ASAP.

On Thu, Mar 21, 2024 at 10:25 AM Eric Sturm <[e-mail]> wrote:
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…11/21
Dylan,

For #2, and documentaon regarding the nuances of fluid bed designs, please see the aached
leer from the designer, Thermal Kinecs. Assuming this closes out all three items, can we see an
updated dra of Wildcat’s AO/permit?

We would like to kick start the review and keep things moving. Please let us know.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Eric Sturm <[e-mail]>
Sent: Wednesday, March 20, 2024 6:09 PM
To: 'Dylan Frederick' <[e-mail]>
Cc: 'Sydney Stauffer - ARC' <[e-mail]>; 'Ma Hyita'
<[e-mail]>
Subject: RE: Management Review Informaon Request

Hi Dylan,

To let you know, we are acvely working on a response to your email and will have data to share
tomorrow. On #1, the replacement engine proposed was the same size as the exisng, so there
actually is no change to provide. We double check that to confirm.

On #2, we are geng signed leer statement from the fluid bed dryer manufacturer and specialist.
We should have tomorrow to provide more explanaon on the fluid bed design and burner
funconality.

On #3, yes, due to the exhaust air flow staying the same, the DAQ can leave the PM10 permit limit
for Dryer #1 unchanged.

Thanks again for your aenon to this. If there are any queson on #1 or #3, please let us know.
Otherwise, we will have more on #2 tomorrow.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…12/21
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, March 19, 2024 12:21 PM
To: Eric Sturm <[e-mail]>
Cc: Sydney Stauffer - ARC <[e-mail]>; Ma Hyita
<[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

I've been able to go over the submission and I've incorporated changes where they've been noted. I
have a couple more requests:

1. Since the engine is not changing, could you submit a emission summary table that reflects this
change?

2. I think the explanation on the sand dryer makes sense, but Alan thought it would be helpful to have
a little more information on fluid bed dryers. Can you explain why this particular kind of dryer operates
with higher NOx concentrations than other combustion equipment? Being able to say NOx can't golower due to the design should be the last information we need.

3. Just to confirm, I will keep the dryer #1 stack testing condition at 1.07 lb/hr for PM10, correct?

On Thu, Mar 14, 2024 at 4:50 PM Eric Sturm <[e-mail]> wrote:
Dylan,

Can we get a status update for Wildcat? We would like to get the AO to public noce soon.
Please let me know.

Sincerely.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Eric Sturm <[e-mail]>
Sent: Tuesday, March 12, 2024 10:10 AM
To: 'Dylan Frederick' <[e-mail]>
Cc: 'Sydney Stauffer - ARC' <[e-mail]>; 'Ma Hyita'
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…13/21
<[e-mail]>
Subject: RE: Management Review Informaon Request

Dylan,

It looks like I aached the wrong file last night. Please disregard the previous aachment and
use the aached BACT analysis for the haul roads.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Eric Sturm <[e-mail]>
Sent: Monday, March 11, 2024 9:48 PM
To: 'Dylan Frederick' <[e-mail]>
Cc: Sydney Stauffer - ARC <[e-mail]>; 'Ma Hyita'
<[e-mail]>
Subject: RE: Management Review Informaon Request

Dylan,

Following back up regarding the discussion with you and Alan in late February. Items #1-9 were
addressed on the call. Summary of each item below and aached. Wildcat would like to have
the NOI put to public noce soon. We are available all week to address each item again, and this
is a top priority. We can meet at your offices to discuss any remaining quesons.

1. It was requested that the engine be evaluated for a lower NOx emission rate. We have
seen rates of 0.5 g/hp-hr NOx from engines that did not require SCR. At the very least we
need emission esmates and cost esmates for an engine that can meet an emission rate
of 0.5 g/hp-hr NOx.

Wildcat will not be implemenng a new engine and will operate the currently permied
engine. The DAQ can disregard any modificaon for the engine.

2. A BACT analysis for Disturbed Area was requested as the total area increased from 10.92
acres to 14.

See aached for a revision to the BACT.

3. We need a clearer explanaon of the haul road lengths/loader routes. Management
thought the lengths of the roads were quite long and the diagram provided in the NOI
doesn’t label these or show how each haul road/ loader route fits together. I would
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…14/21
recommend a project narrave explaining the process so we can account for each haul
road secon.

See aached for a visual of the routes.
Haul Road Descripon Length
HR2NDEXIT Addional Exit from Plant 201.7 Meters
HRLDOUT Final Product 701.6 Meters
HRWIP WIP Pile #2 to WIP Pile #3 732.4 Meters
HRLOAD Loader to Wet Plant 476.5 Meters
HRDRY WIP to Dry Plant 325.8 Meters

4. Can you explain why haul road #1 on the NOI has an input of 1,314,000 tons per year?

Item 4, Haul Road – 2nd Exit (HR2NDEXIT) is ulized seldomly but has the potenal to move
product at a rate of 150 tph. To calculate for PTE, 8,760 hr/yr was ulized to acquire 1,314,000
tph.

5. Which haul road/loader route brings sand into the facility? This goes along with item #3,
as its unclear which haul road/loader route performs which funcon.

Raw material is transferred via HRLOAD, the emissions are captured in HRLDOUT to avoid
double counng.

6. I will need to add a condion to the approval order for the paved secon of the haul road
as the NOI indicates that "Item 5, Haul Road, Final Product" is a paved secon of the haul
road and esmates emissions as such. Let me know if this is correct, the condion will
require the one way length of this haul road of 1,151 feet be paved.

Correct.

7. The last permit had a stack tesng limit of 1.07 lb/hr for the exisng dryer. Why did the
lb/hr increase in this modificaon?

DAQ is correct, the limit for Dryer 1 is 1.07 lb PM10/hr.

8. It looks like the formaldehyde totals confirmed on 10-25-23 are higher than the totals that
were submied for modeling? The modeling team showed a 0.00 lb/hr emission rate for
the engine which doesn’t look correct. It should be .178 lb/hr based on the submissions
I’ve received. I've checked in with modeling to see if this needs to be addressed.

DAQ confirmed on a Teams call from February 21, 2024 that no further acon is needed at this
me regarding the formaldehyde modeling.

5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…15/21
9. Finally, management wanted to ask for an evaluaon of other dryer burner opons. 96
ppm is the proposed limit and this seems high for a dryer and isn’t considered a low-NOx
opon. For comparison, management has noted that asphalt facilies ulize dryers that
can reach 36 ppm NOx. The proposed dryer is at more than 2.5 mes the NOx emission
rate of asphalt dryers. At the very least I could use some understanding on why the
difference is so large compared to other industrial dryers. I was also curious why the
analysis states dryer efficiency would be reduced by 17% for Low-NOx burners, but
requires a 50% increase in size to accommodate the same producon rate with lower NOx
opons.

Asphalt dryers are a completely different SIC code. 96 ppm is the lowest NOx rate permied
to a minor source for SIC 1446. The burner used for the referenced 36 ppm NOx cannot be
used at Wildcat for mulple reasons; primarily, the top two reasons are (1), Wildcat is using a
fluid bed dryer, which requires certain specifics for combuson, and (2), Wildcat is not asphalt
drying; it is a sand dryer. Either way, the 36 ppm burner is not an opon for Wildcat in the top
down process and cannot be considered on technical and praccal bases.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, February 15, 2024 4:30 PM
To: Eric Sturm <[e-mail]>
Subject: Re: Management Review Informaon Request

Please include him on the invite, thanks.

On Thu, Feb 15, 2024 at 3:17 PM Eric Sturm <[e-mail]> wrote:
Thanks for the heads up. Let’s do Wednesday aer 1:30. I’ll send a calendar invite. Are you
bringing Alan to the meeng, and do you want me to include him on the invite?

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Thursday, February 15, 2024 3:58 PM
To: Eric Sturm <[e-mail]>
Subject: Re: Management Review Informaon Request
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…16/21

Eric,

Would you have time next week to schedule the meeting so my manager can attend? Looks like
he has time Tuesday after 3, or Wednesday between 11-1, and most of the afternoon Wednesday
after 1:30.

On Wed, Feb 14, 2024 at 4:13 PM Dylan Frederick <[e-mail]> wrote:
Eric,

So sorry for the late notice, my manager will not be here Friday, I just confirmed it with him. I
could schedule something for the afternoon tomorrow if that works for you? Total error on mypart, I didn't see his calendar had him out of the office until today.

On Tue, Feb 13, 2024 at 12:18 PM Dylan Frederick <[e-mail]> wrote:
12 PM mtn time should be good, thank you!

On Tue, Feb 13, 2024 at 12:11 PM Eric Sturm <[e-mail]> wrote:
How about noon or 1 pm mtn?

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, February 13, 2024 1:04 PM
To: Eric Sturm <[e-mail]>
Subject: Re: Management Review Informaon Request

That should be fine, let me know what time you can make.

On Tue, Feb 13, 2024 at 10:32 AM Eric Sturm <[e-mail]> wrote:
Dylan, sorry, I have to provide tesmony on a CO GHG rulemaking Wednesday aer
1:00 pm. How about Friday aernoon?

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…17/21
From: Dylan Frederick <[e-mail]>
Sent: Monday, February 12, 2024 8:24 PM
To: Eric Sturm <[e-mail]>
Subject: Re: Management Review Informaon Request

Eric, I should be able to do any time on Wednesday after 1:00.

On Mon, Feb 12, 2024 at 1:27 PM Eric Sturm <[e-mail]> wrote:
Hi Dylan,

Sorry, I can’t do 3:30 tomorrow. How about some me Wednesday or Friday?

Thanks for the sending the AO for the engine rate. We will take a look at that
and try to gather some costs requested.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Friday, February 9, 2024 5:09 PM
To: Eric Sturm <[e-mail]>
Cc: Ma Hyita <[e-mail]>; Sydney Stauffer - ARC
<[e-mail]>
Subject: Re: Management Review Informaon Request

Eric,

How does Tuesday at 3:30 work? We can also do Wednesday at 11 or another time
that works best for your end. I have Monday's off.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…18/21
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…19/21

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…20/21
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

[e-mail]_20240524_140900_forWildcat.pdf
644K
5/28/24, 9:32 AM State of Utah Mail - Management Review Information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1799969268977973780&simpl=msg-f:179996926897797…21/21

AIR REGULATIONS CONSULTING,LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM

June 30, 2023

Attn: Alan Humphreys
Permits, Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114

[Submitted via electronic copy submittal utahgove.co1.qualtrics.com and to: [e-mail]]

RE: Minor Source NOI Modification for Sand Processing Plant, UAR R307-401-5
Wildcat Sand, LLC – Uintah County Sand Processing Plant
DAQE #IN159980003-21
Uintah County, UT

Dear Mr. Alan Humphreys,

Wildcat Sand, LLC (Wildcat), with assistance from Air Regulations Consulting, LLC (ARC), is submitting a
Notice of Intent (NOI) for a modification to the current Approval Order (AO) DAQE #IN159980003-21
issued to the processing plant in Uintah County, Utah. Wildcat operates a sand processing facility in the
Uinta Basin with drying operations and additional handling equipment located approximately seven (7)
miles to the southeast of Roosevelt, Utah. The facility currently operates a crushing and screening
operation at the wet plant and a sand dryer (Dryer #1) with a 40.9 million British thermal unit per hour
(MMBtu/hr) rated natural gas-fired burner. Wildcat is submitting this NOI application in accordance with
Utah Office of Administrative Rules (UAR) R307-401-5.

This application package is presented to the Utah Department of Environmental Quality, Division of Air
Quality (UDAQ), for the proposed installation of a sand fluid bed dryer (Dryer #2) that will be equipped
with a 38.0 MMBtu/hr natural gas-fired burner. Additional requests with this NOI application include the
increase to the hourly throughput and operating hours of Dryer #1 to 150 tons per hour and 8,760 hours
per year, respectively.

In accordance with Statute 19-2-108(3)(a), a $500 filing fee and $2,200 review fee are needed for the
Minor New Source Review NOI, therefore a check for $2,700 is being provided with the NOI to the Division
of Air Quality. Should the DAQ have any questions regarding the enclosed information, please do not
hesitate to contact Eric Sturm at 402.817.7887 or [e-mail].

Sincerely,

Eric Sturm
ARC Principal, Sr Consultant

Enclosures

Cc: Matthew Hyita, Plant Manager, Wildcat
Sydney Stauffer, Environmental Consultant, ARC
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Sydney Stauffer
Environmental Specialist, ARC
WILDCAT SAND , LLC

NOI MODIFICATION APPLICATION
FOR FLUID BED DRYER AT SAND
PROCESSING PLANT

FACILITY LOCATED AT:
WILDCAT SAND, LLC
UINTAH COUNTY SAND PROCESSING PLANT
ZONE 12 T, 593455.00 M E, 4453216.00 M N
UINTAH COUNTY, UT

SUBMITTED TO:
PERMITS, DIVISION OF AIR QUALITY
P.O. BOX 144820
SALT LAKE CITY, UT 84114

SUBMITTAL DATE:
JUNE 30, 2023

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

UDAQ FORM 1
NOI APPLICATION CHECKLIST

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
6/30/2023

UDAQ FORM 2
COMPANY INFORMATION

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
6/30/2023
6/30/2023
Plant Manager

UDAQ FORM 5
EMISSIONS INFORMATION

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

UDAQ PROCESS-SPECIFIC FORM 4
ITEM 1, BUCKET ELEVATOR

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 1, BUCKET ELEVATOR

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.18 0.79
PM2.5 0.00009 0.03 0.12
Material Handling
AP-42 13.2.4.3
Equation #1
Page 1 of 1
Version 1.0
November 29, 2018
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

UDAQ PROCESS-SPECIFIC FORM 4
ITEM 2, SAND DRYER 1

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 2, SAND DRYER 1

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand Plant
Rotary Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 20,955 acfm
Total Heat Input Capacity 40.9 MMBtu/hr
Total Heat Input Capacity 0.040 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)[1]
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0079 1.42 12,446 6.22
PM10**0.0079 1.42 12,446 6.22
PM2.5**0.0079 1.42 12,446 6.22
Pollutant Emission Factor[2]
(lb/MMscf)Potential Emission Rate[3]
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx)50 5.40 47,304 23.65
Carbon Monoxide (CO)84 5.70 49,932 24.97
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Total Organic Compounds (TOC)11.0 0.438 3,841 1.92
Sulfur Dioxide (SO2)[3]0.6 0.00 0 0.00
Greenhouse Gas Pollutants (GHG)Emission Factor[4]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 4,784 41,911,086 20,956
Nitrous Oxide (N2O)0.0002 0.0090 79 0.04
Methane (CH4)0.0022 0.0902 790 0.39
Individual Hazardous Air Pollutants (HAP) Emission Factor[5]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.7333 0.0004
Dichlorobenzene 0.0012 0.0000 0.4190 0.0002
Formaldehyde 0.0750 0.0030 26.1904 0.0131
Hexane 1.8000 0.0718 628.5684 0.3143
Lead Compounds 0.0005 0.0000 0.1746 0.0001
Naphthalene 0.0006 0.0000 0.2130 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0308 0.0000
Toluene 0.0034 0.0001 1.1873 0.0006
Arsenic Compounds (ASC)0.0002 0.0000 0.0698 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0042 0.0000
Cadmium Compounds (CDC)0.0011 0.0000 0.3841 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.4889 0.0002
Cobalt Compounds (COC)0.0001 0.0000 0.0293 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1327 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.0908 0.0000
Nickel Compounds (NIC)0.0021 0.0001 0.7333 0.0004
Selenium Compounds (SEC)0.0000 0.0000 0.0084 0.0000
Total HAPs 1.8885 0.0753 659.4584 0.3297
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates. Tarmac Baghouse particulate guarantee is at or below a 0.01 gr/dscf.
Given exhaust temperature stacks will approximately be 210 F, 0.01 gr/dscf equals 0.007 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+210))]
[4]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 2.204622622 lb/kg.
[5]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMBtu/MMscf.
* Capacity of the 150 ton per hour sand dryer is from manufacturer for Tarmac Int., Inc Dryer
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
[1]Emission Factors for PM based NSPS UUU emission requirements which includes process and combustion emissions. NSPS requires PM be no greater than 0.025
gr/dscf.
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMbtu/MMscf.
[3]Emissions data for SOX, CO, and NOX from Tarmac Dryer Spec Sheet
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

UDAQ PROCESS INFORMATION FORM 2
ITEM 3, SAND DRYER 2

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

UDAQ PROCESS-SPECIFIC FORM 4
ITEM 3, SAND DRYER 2

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

PROPOSE EMISSIONS FOR MODIFICATION
ITEM 3, SAND DRYER 2

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand Plant
Fluid Bed Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 50,000 acfm
Total Heat Input Capacity 38.0 MMBtu/hr
Total Heat Input Capacity 0.037 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)[1]
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0070 2.99 26,181 13.09
PM10**0.0070 2.99 26,181 13.09
PM2.5**0.0070 2.99 26,181 13.09
Pollutant Emission Factor[2]
(lb/MMscf)Potential Emission Rate[3]
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx)50 5.40 47,304 23.65
Carbon Monoxide (CO)84 5.70 49,932 24.97
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Total Organic Compounds (TOC)11.0 0.407 3,569 1.78
Sulfur Dioxide (SO2)0.6 0.02 195 0.10
Greenhouse Gas Pollutants (GHG)Emission Factor[4]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 4,445 38,939,396 19,470
Nitrous Oxide (N2O)0.0002 0.0084 73 0.04
Methane (CH4)0.0022 0.0838 734 0.37
Individual Hazardous Air Pollutants (HAP) Emission Factor[5]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.6813 0.0003
Dichlorobenzene 0.0012 0.0000 0.3893 0.0002
Formaldehyde 0.0750 0.0028 24.3333 0.0122
Hexane 1.8000 0.0667 584.0000 0.2920
Lead Compounds 0.0005 0.0000 0.1622 0.0001
Naphthalene 0.0006 0.0000 0.1979 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0286 0.0000
Toluene 0.0034 0.0001 1.1031 0.0006
Arsenic Compounds (ASC)0.0002 0.0000 0.0649 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0039 0.0000
Cadmium Compounds (CDC)0.0011 0.0000 0.3569 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.4542 0.0002
Cobalt Compounds (COC)0.0001 0.0000 0.0273 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1233 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.0844 0.0000
Nickel Compounds (NIC)0.0021 0.0001 0.6813 0.0003
Selenium Compounds (SEC)0.0000 0.0000 0.0078 0.0000
Total HAPs 1.8885 0.0699 612.6998 0.3063
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates. Tarmac Baghouse particulate guarantee is at or below a 0.01 gr/dscf.
Given exhaust temperature stacks will approximately be 300 F, 0.01 gr/dscf equals 0.007 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+300))]
[4]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 2.204622622 lb/kg.
[5]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,026 MMBtu/MMscf.
* Capacity of the 150 ton per hour sand dryer is from manufacturer for Fluid Bed Dryer
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
[1]Emission Factors for PM based NSPS UUU emission requirements which includes process and combustion emissions. NSPS requires PM be no greater than 0.025
gr/dscf.
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,050 MMbtu/MMscf.
[3]Emissions data for CO and NOX identical to Sand Dryer 1
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UDAQ PROCESS-SPECIFIC FORM 6
CYCLONE

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DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

UDAQ PROCESS-SPECIFIC FORM 10
FABRIC FILTERS

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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 4, HAUL ROAD – 2ND EXIT

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Truck Information
Empty Truck Weight 22 tons
Weight of Load 43 tons
Loaded Truck Weight 65 tons
Haul Road Information
Haul Road One-Way Length 662 feet
Hourly Vehicle Miles Traveled 0.9 miles
Annual Vehicle Miles Traveled 7,660 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.33 0.29 1.25
PM2.5 0.218 0.033 0.03 0.13
Haul Roads
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 5, HAUL ROAD – FINAL PRODUCT

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Truck Information
Empty Truck Weight 22 tons
Weight of Load 43 tons
Loaded Truck Weight 65 tons
Haul Road Information
Haul Road One-Way Length 1,151 feet
Hourly Vehicle Miles Traveled 3.0 miles
Annual Vehicle Miles Traveled 26,644 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.11 0.33 1.45
PM2.5 0.218 0.011 0.03 0.15
Haul Roads
AP-42 13.2.2 & DAQ
Haul Road Guidance
Paving with Vacuum Sweeping & Watering - (95% control)
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 6, HAUL ROAD – STOCKPILE #3

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Loader Information
Empty Loader Weight 22 tons
Weight of Load 43 tons
Loaded Loader Weight 65 tons
Loader Route\ Information
Loader Route One-Way Length 1,201 feet
Hourly Vehicle Miles Traveled 1.6 miles
Annual Vehicle Miles Traveled 13,902 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.33 0.52 2.27
PM2.5 0.218 0.033 0.05 0.23
Loader Routes
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 7, HAUL ROAD – WET PLANT

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Loader Information
Empty Loader Weight 22 tons
Weight of Load 43 tons
Loaded Loader Weight 65 tons
Loader Route\ Information
Loader Route One-Way Length 1,563 feet
Hourly Vehicle Miles Traveled 4.1 miles
Annual Vehicle Miles Traveled 36,184 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.33 1.35 5.91
PM2.5 0.218 0.033 0.14 0.59
Loader Routes
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
Page 1 of 1
Version 1.0
November 29, 2018
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UDAQ PROCESS-SPECIFIC FORM 15
EXISTING CRUSHER, SCREENS, & CONVEYORS

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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 8, SCREENS
ITEM 9, CRUSHER
ITEM 17, EXISTING CONVEYORS

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Emission Unit
Number of
Emission
Units
PM10
Emission
Factor
(lb/ton)
PM2.5
Emission
Factor
(lb/ton)Reference
Crushers 1 0.00054 0.00010
Screens 3 0.00074 0.00005
Conveyor Transfer Points 14 4.6E-05 1.3E-05
Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)
PM10 1.02 4.47
PM2.5 0.13 0.57
Emission Unit
PM10
Emission
Rate
(lbs/hr)
PM10
Emission
Total
(tons/year)
PM2.5
Emission
Rate
(lbs/hr)
PM2.5 Emission
Total
(tons/year)
Crushers 0.16 0.71 0.03 0.13
Screens 0.67 2.92 0.05 0.20
Conveyors 0.19 0.85 0.05 0.24
Aggregate Processing Equipment
AP-42
Table 11.19.2-2
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 10, STORAGE PILE #1

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Storage Pile Area
Total Area of Storage Piles 1 acres
Control Efficiency
PM10 Control Efficiency 66%
PM2.5 Control Efficiency 40%
Pollutant
Uncontrolled
Emission
Factor
(lb/acre-day)
Controlled
Emission
Factor
(lb/acre-day)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 6.30 2.14 0.05 0.23 AP-42 Fourth Edition Table 8.19.1-1
PM2.5 1.85 1.11 0.03 0.12 AP-42 Appendix B.2 Table B.2-2
Storage Piles
AP-42 Appendix B.2
Tables B.2-2 & B.2-3
Reference
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 11, LOADING DRY PLANT #1

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.09 0.39
PM2.5 0.00009 0.01 0.06
Material Handling
AP-42 13.2.4.3
Equation #1
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 12, LOADING DRY PLANT #2

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.09 0.39
PM2.5 0.00009 0.01 0.06
Material Handling
AP-42 13.2.4.3
Equation #1
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 13, LOADING WET PLANT

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.18 0.79
PM2.5 0.00009 0.03 0.12
Material Handling
AP-42 13.2.4.3
Equation #1
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 14, LOADING STOCKPILE #3

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Variables
Number of Transfer Points 1
Mean Wind Speed 8 mph
Moisture Content 5 %
Pollutant
Emission
Factor
(lb/ton)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 0.00060 0.09 0.39
PM2.5 0.00009 0.01 0.06
Material Handling
AP-42 13.2.4.3
Equation #1
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 15, STORAGE PILE #2

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Storage Pile Area
Total Area of Storage Piles 2 acres
Control Efficiency
PM10 Control Efficiency 66%
PM2.5 Control Efficiency 40%
Pollutant
Uncontrolled
Emission
Factor
(lb/acre-day)
Controlled
Emission
Factor
(lb/acre-day)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 6.30 2.14 0.14 0.59 AP-42 Fourth Edition Table 8.19.1-1
PM2.5 1.85 1.11 0.07 0.31 AP-42 Appendix B.2 Table B.2-2
Storage Piles
AP-42 Appendix B.2
Tables B.2-2 & B.2-3
Reference
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 16, STORAGE PILE #3

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Storage Pile Area
Total Area of Storage Piles 3 acres
Control Efficiency
PM10 Control Efficiency 66%
PM2.5 Control Efficiency 40%
Pollutant
Uncontrolled
Emission
Factor
(lb/acre-day)
Controlled
Emission
Factor
(lb/acre-day)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 6.30 2.14 0.25 1.09 AP-42 Fourth Edition Table 8.19.1-1
PM2.5 1.85 1.11 0.13 0.56 AP-42 Appendix B.2 Table B.2-2
Storage Piles
AP-42 Appendix B.2
Tables B.2-2 & B.2-3
Reference
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 18, STORAGE SILOS

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 300 tons/hour
Annual Production 2,628,000 tons/year
Emission Unit
Number of
Emission
Units
PM10
Emission
Factor
(lb/ton)
PM2.5
Emission
Factor
(lb/ton)Reference
Crushers 0 0.00054 0.00010
Screens 0 0.00074 0.00005
Conveyor Transfer Points 3 4.6E-05 1.3E-05
Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)
PM10 0.04 0.18
PM2.5 0.01 0.05
Emission Unit
PM10
Emission
Rate
(lbs/hr)
PM10
Emission
Total
(tons/year)
PM2.5
Emission
Rate
(lbs/hr)
PM2.5 Emission
Total
(tons/year)
Crushers 0.00 0.00 0.00 0.00
Screens 0.00 0.00 0.00 0.00
Conveyors 0.04 0.18 0.01 0.05
Aggregate Processing Equipment
AP-42
Table 11.19.2-2
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UDAQ PROCESS INFORMATION FORM 4
ITEM 19, FITLER PRESS ENGINE

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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 19, FILTER PRESS ENGINE

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Equipment Details
Rating 482 hp = (360 kw)
Operational Hours 8,760 hours/year
Engine Type
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission Factor
(lb/MMBtu)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 2.0 2.13 9.32
CO 4.0 4.25 18.63
PM10 9.99E-03 0.03 0.15
PM2.5 9.99E-03 0.03 0.15
VOC 1.18E-01 0.40 1.75
SO2 5.88E-04 0.00 0.01
HAP 0.24 1.07 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission Factor
(lb/MMBtu)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 1.10E+02 371 1,627
Methane (mass basis)25 1.25E+00 4 18
CO2e 2,089
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
1,1,2,2-Tetrachloroethane 4.00E-05 1.35E-04 5.92E-04
1,1,2-Trichloroethane 3.18E-05 1.07E-04 4.70E-04
1,3-Butadiene 2.67E-04 9.02E-04 3.95E-03
1,3-Dichloropropene 2.64E-05 8.91E-05 3.90E-04
2,2,4-Trimethylpentane 2.50E-04 8.44E-04 3.70E-03
2-Methylnaphthalene 3.32E-05 1.12E-04 4.91E-04
Acenaphthene 1.25E-06 4.22E-06 1.85E-05
Acenaphthylene 5.53E-06 1.87E-05 8.18E-05
Acetaldehyde 8.36E-03 2.82E-02 1.24E-01
Acrolein 5.14E-03 1.74E-02 7.60E-02
Benzene 4.40E-04 1.49E-03 6.51E-03
Benzo(b)fluoranthene 1.66E-07 5.61E-07 2.46E-06
Benzo(e)pyrene 4.15E-07 1.40E-06 6.14E-06
benzo(g,h,i)perylene 4.14E-07 1.40E-06 6.12E-06
Biphenyl 2.12E-04 7.16E-04 3.14E-03
Carbon Tetrachloride 3.67E-05 1.24E-04 5.43E-04
Chlorobenzene 3.04E-05 1.03E-04 4.50E-04
Chloroform 2.85E-05 9.62E-05 4.22E-04
Chrysene 6.93E-07 2.34E-06 1.02E-05
Ethylbenzene 3.97E-05 1.34E-04 5.87E-04
Ethylene Dibromide 4.43E-05 1.50E-04 6.55E-04
Fluoranthene 1.11E-06 3.75E-06 1.64E-05
Fluorene 5.67E-06 1.91E-05 8.39E-05
Formaldehyde 5.28E-02 1.78E-01 7.81E-01
Methanol 2.50E-03 8.44E-03 3.70E-02
Methylene Chloride 2.00E-05 6.75E-05 2.96E-04
n-Hexane 1.11E-03 3.75E-03 1.64E-02
Naphthalene 7.44E-05 2.51E-04 1.10E-03
PAH 2.69E-05 9.08E-05 3.98E-04
Phenanthrene 1.04E-05 3.51E-05 1.54E-04
Phenol 2.40E-05 8.10E-05 3.55E-04
Pyrene 1.36E-06 4.59E-06 2.01E-05
Styrene 2.36E-05 7.97E-05 3.49E-04
Tetrachloroethane 2.48E-06 8.37E-06 3.67E-05
Toluene 4.08E-04 1.38E-03 6.03E-03
Vinyl Chloride 1.49E-05 5.03E-05 2.20E-04
Xylene 1.84E-04 6.21E-04 2.72E-03
Emission Factor
(lb/MMBtu)
Natural Gas-Fired Engines
AP-42 Table 3.2-1,
Table 3.2-2, &
Table 3.2-3
AP-42 Table 3.2-1,
Table 3.2-2, &
Table 3.2-3
(Some HAP do not
popluate based on
the type of engine
selected. AP-42
does not list certain
HAP for certain types
of engines.)
Manufacturer Data,
AP-42 Table 3.2-1,
Table 3.2-2, &
Table 3.2-3
4-Stroke Lean-Burn
Emergency Engines should
equal 100 hours of
operation per year
Page 1 of 1 Version 1.1
February 21, 2019
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 20, DISTRUBED AREA

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Wind Erosion of Exposed Area
Total Area of Distrubed Ground 14 acres
Emission Factors & Distribution
TSP Emission Factor 0.38
PM10 Content 50%
PM2.5 Content 7.5%
Pollutant
Emission
Factor
(tons/acre-year)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)
PM10 0.19 0.61 2.66
PM2.5 0.03 0.09 0.40
Disturbed Ground
Reference
AP-42 Section 13.2.5.3
AP-42 Table 11.9-4
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UDAQ PROCESS INFORMATION FORM 4
ITEM 21, DRY PLANT #2 CONVEYORS

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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 21, DRY PLANT #2 CONVEYORS

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Emission Unit
Number of
Emission
Units
PM10
Emission
Factor
(lb/ton)
PM2.5
Emission
Factor
(lb/ton)Reference
Crushers 0 0.00054 0.00010
Screens 0 0.00074 0.00005
Conveyor Transfer Points 4 4.6E-05 1.3E-05
Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)
PM10 0.03 0.12
PM2.5 0.01 0.03
Emission Unit
PM10
Emission
Rate
(lbs/hr)
PM10
Emission
Total
(tons/year)
PM2.5
Emission
Rate
(lbs/hr)
PM2.5 Emission
Total
(tons/year)
Crushers 0.00 0.00 0.00 0.00
Screens 0.00 0.00 0.00 0.00
Conveyors 0.03 0.12 0.01 0.03
Aggregate Processing Equipment
AP-42
Table 11.19.2-2
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 22, BAGHOUSE WASTE

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Storage Pile Area
Total Area of Storage Piles 1 acres
Control Efficiency
PM10 Control Efficiency 66%
PM2.5 Control Efficiency 40%
Pollutant
Uncontrolled
Emission
Factor
(lb/acre-day)
Controlled
Emission
Factor
(lb/acre-day)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 6.30 2.14 0.04 0.20 AP-42 Fourth Edition Table 8.19.1-1
PM2.5 1.85 1.11 0.02 0.10 AP-42 Appendix B.2 Table B.2-2
Storage Piles
AP-42 Appendix B.2
Tables B.2-2 & B.2-3
Reference
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Version 1.0
November 29, 2018
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 23, HAUL ROAD – DRY PLANT

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Production Rates
Hourly Rates 150 tons/hour
Annual Production 1,314,000 tons/year
Loader Information
Empty Loader Weight 22 tons
Weight of Load 43 tons
Loaded Loader Weight 65 tons
Loader Route\ Information
Loader Route One-Way Length 1,069 feet
Hourly Vehicle Miles Traveled 1.4 miles
Annual Vehicle Miles Traveled 12,374 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
PM10 2.18 0.33 0.46 2.02
PM2.5 0.218 0.033 0.05 0.20
Loader Routes
AP-42 13.2.2 & DAQ
Haul Road Guidance
Chemical Suppressant & Watering - (85% control)
Page 1 of 1
Version 1.0
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PROPOSE EMISSIONS FOR MODIFICATION
ITEM 24, DIESEL TANK BREATHING LOSS

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TANKS 4.0.9d
Emissions Report - Detail Format
Tank Indentification and Physical Characteristics
IdentificationUser Identification:Tank1
City:Roosevelt
State:UtahCompany:Wildcat SandType of Tank:Horizontal TankDescription:#2 Fuel Horizontal Tank
Tank Dimensions
Shell Length (ft):27.00Diameter (ft):8.00Volume (gallons):5,000.00
Turnovers:30.80
Net Throughput(gal/yr):154,000.00
Is Tank Heated (y/n):NIs Tank Underground (y/n): N
Paint Characteristics
Shell Color/Shade:White/White
Shell Condition Good
Breather Vent SettingsVacuum Settings (psig):-0.03Pressure Settings (psig)0.03
Meterological Data used in Emissions Calculations: Salt Lake City, Utah (Avg Atmospheric Pressure = 12.64 psia)
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TANKS 4.0.9d
Emissions Report - Detail Format
Liquid Contents of Storage Tank
Tank1 - Horizontal Tank
Roosevelt, Utah
Daily Liquid Surf.Temperature (deg F)
Liquid
BulkTemp Vapor Pressure (psia)VaporMol.LiquidMass VaporMass Mol. Basis for Vapor Pressure
Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fract. Weight Calculations
Distillate fuel oil no. 2 All 53.92 47.99 59.86 51.98 0.0053 0.0042 0.0065 130.0000 188.00 Option 1: VP50 = .0045 VP60 = .0065
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TANKS 4.0.9d
Emissions Report - Detail Format
Detail Calculations (AP-42)
Tank1 - Horizontal Tank
Roosevelt, Utah
Annual Emission Calcaulations
Standing Losses (lb):1.6357 Vapor Space Volume (cu ft):864.4382 Vapor Density (lb/cu ft):0.0001 Vapor Space Expansion Factor:0.0416 Vented Vapor Saturation Factor:0.9989
Tank Vapor Space Volume: Vapor Space Volume (cu ft):864.4382 Tank Diameter (ft):8.0000 Effective Diameter (ft):16.5879 Vapor Space Outage (ft):4.0000 Tank Shell Length (ft):27.0000
Vapor Density Vapor Density (lb/cu ft):0.0001
Vapor Molecular Weight (lb/lb-mole):130.0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia):0.0053 Daily Avg. Liquid Surface Temp. (deg. R):513.5939 Daily Average Ambient Temp. (deg. F):51.9625 Ideal Gas Constant R (psia cuft / (lb-mol-deg R)):10.731 Liquid Bulk Temperature (deg. R):511.6525 Tank Paint Solar Absorptance (Shell):0.1700 Daily Total Solar Insulation Factor (Btu/sqft day):1,452.1184
Vapor Space Expansion Factor Vapor Space Expansion Factor:0.0416 Daily Vapor Temperature Range (deg. R):23.7301 Daily Vapor Pressure Range (psia):0.0023 Breather Vent Press. Setting Range(psia):0.0600 Vapor Pressure at Daily Average Liquid Surface Temperature (psia):0.0053
Vapor Pressure at Daily Minimum Liquid Surface Temperature (psia):0.0042 Vapor Pressure at Daily Maximum Liquid Surface Temperature (psia):0.0065 Daily Avg. Liquid Surface Temp. (deg R):513.5939 Daily Min. Liquid Surface Temp. (deg R):507.6614 Daily Max. Liquid Surface Temp. (deg R):519.5264 Daily Ambient Temp. Range (deg. R):23.3583
Vented Vapor Saturation Factor Vented Vapor Saturation Factor:0.9989 Vapor Pressure at Daily Average Liquid: Surface Temperature (psia):0.0053 Vapor Space Outage (ft):4.0000
Working Losses (lb):2.5191 Vapor Molecular Weight (lb/lb-mole):130.0000 Vapor Pressure at Daily Average Liquid
Surface Temperature (psia):0.0053 Annual Net Throughput (gal/yr.):154,000.0000 Annual Turnovers:30.8000 Turnover Factor:1.0000 Tank Diameter (ft):8.0000 Working Loss Product Factor:1.0000
Total Losses (lb):4.1548
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TANKS 4.0.9d
Emissions Report - Detail Format
Individual Tank Emission Totals
Emissions Report for: Annual
Tank1 - Horizontal TankRoosevelt, Utah
Losses(lbs)
Components Working Loss Breathing Loss Total Emissions
Distillate fuel oil no. 2 2.52 1.64 4.15
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FACILITY WIDE
PROPOSED EMISSION CALCULATIONS

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand - Roosevelt Plant
Sand Plant
Emission Calculations
Facility PTE - 8760 hr/yr
PTE (lb/hr)
Emission
Type Unit
Particulate
Matter <10μ
(PM10)
Particulate
Matter <10μ
(PM10)
Particulate
Matter <2.5μ
(PM2.5)
Nitrogen Oxides
(NOX)
Sulfur Oxides
(SOX)
Carbon
Monoxide
(CO)
Volatile Organic
Compounds
(VOC)
Lead
Compounds
Hazardous Air
Pollutants
(HAPs)
Point 01 Bucket Elevator Transfer to Silo**SILOTR 0.0018 0.0079 0.0012
Point 02 Dryer #1 Stack with Baghouse and Cyclone DRYER1 1.4200 6.2200 6.2200
Point 02 Dryer #1 Combustion DRYER1 23.6500 0.0000 24.9700 1.9200 0.0001 0.3297
Point 03 Dryer #2 Stack with Baghouse and Cyclone DRYER2 2.9900 13.0900 13.0900
Point 03 Dryer #2 Combustion DRYER2 23.6500 0.1000 24.9700 1.7900 0.0001 0.3063
Fugitive 04 Haul Road - Additional Exit from Plant HR2NDEXIT 0.2900 1.2500 0.1300
Fugitive 05 Haul Road - Final Product HRLDOUT 0.3300 1.4500 0.1500
Fugitive 06 Haul Road - WIP Pile #2 to WIP Pile #3 HRWIP 0.5200 2.2700 0.2300
Fugitive 07 Haul Road - Loader to Wet Plant HRLOAD 1.3500 5.9100 0.5900
Point 08 J & H Screen Baghouse Stack*SCRNSTK 0.9600 4.2200 4.2200
Fugitive 09 Secondary Crushing 2NDCRUSH 0.1600 0.7100 0.1300
Fugitive 10 Stockpile Pre-Wash Plant PILE1 0.0500 0.2300 0.1200
Fugitive 11 Truck Unloading to Dry Plant #1 TRNSDP1 0.0900 0.3900 0.0600
Fugitive 12 Truck Unloading to Dry Plant #2 TRNSDP2 0.0900 0.3900 0.0600
Fugitive 13 Truck Unloading to Wet Plant TRNSWP 0.1800 0.7900 0.1200
Fugitive 14 Truck Unloading to WIP Pile #3 TRNSWIP3 0.0900 0.3900 0.0600
Fugitive 15 WIP Stockpile #2 PILE2 0.1400 0.5900 0.3100
Fugitive 16 WIP Stockpile #3 PILE3 0.2500 1.0900 0.5600
Fugitive 17 Existing Conveyors and Drop Points CONVYRS 0.1900 0.8500 0.2400
Point 18 Unloading Sand Storage Silos #1 - #3**SILOS 0.0004 0.0018 0.0005
Point 19 Engine - Filter Press[1]FPGENSET 0.0300 0.1500 0.1500 9.3200 0.0100 18.6300 1.7500 0.0000 1.0700
Fugitive 20 Disturbed Area DISAREA 0.6100 2.6600 0.4000
Fugitive 21 New Dry Plant #2 Conveyors**CONVDRY2 0.0003 0.0012 0.0003
Fugitive 22 Enclosed Baghouse Waste Collection Area ***BHWASTE 0.0100 0.0500 0.0250
Fugitive 23 Haul Road - Loader to Dry Plant HRDRY 0.4600 2.0200 0.2000
Fugitive 24 Fuel Oil Storage Tank TANK1 0.0021
5.40 23.69 23.68 56.62 0.11 68.57 5.46 0.00 1.71
4.81 21.04 3.39 0.00 0.00 0.00 0.00 0.00 0.00
9.92 43.48 26.94 56.62 0.11 68.57 5.46 0.00 1.71
[1] Tier 2 Natural Gas Engine meets 40 CFR 60.4223(e) and Table 1 emission standards
*Based on fabric filter baghouse Manufacturer Gaurantee of 0.005 gr/dscf
** All product handling post dryers are controlled with a dust collector and silo bin vent filter with a control efficiency >99%
*** Baghouse waste is in an enclosed building
Facility PTE (tpy)
Description
Point
Fugitive
Facility PTE
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FACILITY LAYOUT

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CONTROL C
A
B
HERE BY M
P
S
90°
180°
270
°
TRUC
K

S
C
A
L
E
0°
FEED CONVEYOR
FEEDER HOPPER
DRY PLANT LINE 2
INCLINE CONVEYOR
WASTE CONVEYOR
Concrete
Area = 2,885 SQ FT
Thick = 10"
#5 Mat 18" O.C.
Pond LinerArea =120,600 SQ FT
R220.5'
N:7,254,687.81E:2,085,562.44Z:0.00LAT:40.22510427LON:109.90566290
N:7,254,658.97E:2,085,515.90Z:0.00LAT:40.22502739LON:109.90583138
N:7,254,715.79E:2,085,515.38Z:0.00LAT:40.22518339LON:109.90582962
R54.7'
Wildcat Sand Plant Wildcat Sand
5482 S 5500 W
Randlett, UT 84063
MSHA ID: 42-02722
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
EPL
EPL
EPL
EPL
EPL
EPL
EPL
EPL
EPL
EPL
CON
T
R
O
L

C
A
B
HERE
B
Y

M
P
S
90
°
18
0
°
27
0
°
TR
U
C
K

S
C
A
L
E
0°
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BACT ANALYSIS

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AIR REGULATIONS CONSULTING, LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM

June 30, 2023

Attn: Alan Humphreys
Permits, Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114

[Submitted via electronic copy submittal utahgove.co1.qualtrics.com and [e-mail]]

RE: Updated BACT Analysis for Dryer #2 and Engine PM, NOX, CO, & VOC Emissions
Wildcat Sand, LLC – Uintah County Sand Processing Plant
DAQE-AN159980003-21
Uintah County, UT

Dear Mr. Alan Humphreys,

On behalf of Wildcat Sand, LLC (Wildcat), Air Regulations Consulting, LLC (ARC) is submitting an
updated Best Available Control Technology (BACT) analysis for the installation of a fluid bed sand
dryer (Dryer #2) as well as a Filter Press Engine (Engine) at the Uintah County Sand Processing
Plant alongside this complete Notice of Intent (NOI) application. This BACT review was performed
pursuant to UAC R307-401-6 and the Division of Air Quality (DAQ or Division) Form 01b for BACT
determinations. Please find the enclosed updated BACT analysis for the DAQ’s review.

Should you have any questions regarding the enclosed information, please contact me at
402.817.7887 or [e-mail].

Sincerely,

Eric Sturm
Principal, Sr. Consultant, ARC

Enclosures

Cc: Matthew Hyita, Plant Manager, Wildcat
Sydney Stauffer, Environmental Consultant, ARC

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

AIR REGULATIONS CONSULTING, LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM
AIR REGULATIONS CONSULTING, LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM

BACT Analysis for PM, NOX, CO, & VOC Emissions

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Wildcat Dryer BACT Analysis
Section 1
June 2023
_________________________________ Page 1 of 25

1 INTRODUCTION AND BACKGROUND
Wildcat Sand, LLC (Wildcat or Sand Plant) is planning to install a new Starkaire Fluid Bed Dryer
(Dryer #2) drum dryer and a Filter Press Engine (Engine) at the current processing plant, located
approximately seven miles southeast of Roosevelt Main Street, Roosevelt, Utah. Dryer #2 will be
added to an existing aggregate operation that currently crushes, washes, and dries sand; the Sand
Plant is currently operating Dryer #1, a Tarmac dryer, with a 40.9 million British thermal units per
hour (MMBtu/hr) natural gas-fired burner. With the intention of increasing sand production,
Wildcat is planning to add Dryer #2 equipped with a 38.0 MMBtu/hr natural gas-fired burner. The
360-kiloWatt (kW) Engine will be utilized at the filter press, located southeast of the current
tailing ponds. If allowed to operate for 8,760 hours per year, the sand dryers could have the
potential to produce approximately 1,314,000 tons of sand annually, each.[1] The Sand Plant will
have the potential to produce 2,628,000 tons of sand annually. The additional sand dryer is
planned to be controlled with computerized systems for fuel firing and wet sand feed along with
cyclone and baghouse dust collection consistent with the Division’s Utah Administrative Code
(UAC) and the Environmental Protection Agency’s (EPA) federal standards and databases of
technology for new sources.
This report contains analysis of best available control technology (BACT) analysis for particulate
matter (PM), oxides of nitrogen (NOX), carbon monoxide (CO), and volatile organic compounds
(VOC) emissions for the Tarmac rotary sand dryer and the Starkaire fluid bed dryer. For reference,
UAC R307-101-2, defines BACT specifically to the following:
“BACT means an emission limitation and/or other controls to include design,
equipment, work practice, operation standard or combination thereof, based on a
maximum degree of reduction of each pollutant subject to regulation under the
Clean Air Act and/or the Utah Air Conservation Act emitted from or which results
from any emitting installation, which the Air Quality Board, on a case-by-case basis
taking into account energy, environmental and economic impacts and other costs,

[1] 1,314,000 tons equates to 150 tons per hour at 8,760 hours per year which is capable for some rotary sand dryers
with passive control technologies. If burner tuning for emissions of fuel combustion is required, then 8,760 hours
per year, and 1,314,000 tons per year, are not attainable.
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Wildcat Dryer BACT Analysis
Section 1
June 2023
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determines is achievable for such installation through application of production
process and available methods, systems and techniques, including fuel cleaning or
treatment or innovative fuel combustion techniques for control of each such
pollutant. In no event shall application of BACT result in emission of pollutants
which will exceed the emissions allowed by section 111 or 112 of the Clean Air Act.”
As the rule states, Wildcat and ARC are obligated to base proposed BACT on the most effective
engineering techniques and control equipment to minimize emission of air contaminants from
its process to the extent achievable within the industry. Furthermore, based on this definition
and the DAQ’s Form 01b Guidance on BACT, this analysis for Wildcat’s Dryers #1 and #2 and
Engine includes consideration of energy impacts, environmental impacts, economic impacts,
other considerations, and cost calculation. Wildcat and ARC are well versed in the aggregate
drying industry and have been involved in approximately 55 sand dryer projects in ten different
states, including Utah. The proposed BACT for Wildcat follows Form 01b, UAC R307-101-2, EPA
federal standards, and applicability of the sand drying techniques nationwide.
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Wildcat Dryer BACT Analysis
Section 2
June 2023
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2 BACT ANALYSIS
2.1 Non-Dryer Emissions
The construction and operation of Dryer #2 will accommodate increases in sand production, from
950,000 tons of sand per year to 2,628,000 tons of sand per year, and therefore emissions from
other stages in Wildcat’s sand drying operating will also increase. Emissions will increase for each
process equipment at the facility capable of emitting particulate matter, and Wildcat’s sand
dryers and Engine will have a small increase in emissions of nitrogen oxides, VOCs, and carbon
monoxide as well.
1. Haul Road - Loader to Wet Plant – Sand will continue to be delivered to the wet plant via
truck loading. Emissions of PM10 will increase by 4.09 tons per year (tpy), and emissions
of PM2.5 will increase by 0.41 tpy. Wildcat will keep the same haul road control
requirements as had been established in DAQE-AN159980003-21 (the current Approval
Order (AO)) as the best available controls.
2. Truck Unloading to Wet Plant – Sand delivered to the wet plant will continue to be
unloaded from the truck bottoms and transferred by conveyors to the wet plant
processing area. Due to the increase in production, emissions of PM10 will increase by
0.78 tpy, and PM2.5 will increase by 0.11 tpy.
3. Stockpile Pre-Wash Plant – Due to the increase in production, emissions of PM2.5 will
increase by 0.004 tpy. Wildcat is keeping the same control requirements for the sand piles
as had been established under the previous AO.
4. Secondary Crushing – The facility will continue to crush the imported sand to achieve the
desired sizing for the final products. The production will increase from 275 tons per hour
(tph), to 300 tph. Emissions of PM10 will increase by 0.45 tpy, and PM2.5 will increase by
0.08 tpy. Wildcat is keeping the same control requirements for the sand crusher as had
been established under the previous AO.
5. Existing Conveyors and Drop Points – Sand production at the Sand Plant begins with the
wash plant. Emissions of PM10 will increase by 0.66 tpy, and emissions of PM2.5 will
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Wildcat Dryer BACT Analysis
Section 2
June 2023
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increase by 0.19 tpy. Wildcat will keep the same control requirements as had been
established in current AO as the best available controls.
6. WIP Stockpile #2 – The washed stockpile that is currently permitted will increase
emissions for PM10 by 0.43 tpy and PM2.5 by 0.29 tpy. The PILE2 washed stockpile will be
roughly 1.5 acres large. Wildcat is keeping the same control requirements for the
stockpiles as had been established under the previous AO.
7. Haul Road - WIP Pile #2 to WIP Pile #3 – The new haul road will send washed sand to a
new stockpile, PILE3. The PM10 emissions will increase by 2.27 tpy and PM2.5 emissions
will increase by 0.23 tpy from the haul road to PILE3. Wildcat will implement water and
chemical suppressants to control particulate emissions.
8. Truck Unloading to WIP Pile #3 – The emissions for truck unloading to PILE3 will increase
by 0.39 tpy of PM10 and 0.06 tpy PM2.5. The sand that is transferred to PILE3 will have a
5% moisture content.
9. WIP Stockpile #3 – At a maximum, the new stockpile, PILE3, will be roughly 2.75 acres.
The pile will have a 5% moisture content before being transferred to dry plants #1 and #2.
The PM10 emissions will increase by 1.09 tpy, and PM2.5 emissions will increase by 0.56
tpy. Wildcat will apply the same control requirements for the stockpiles as had been
established under the previous AO.
10. Haul Road - Loader to Dry Plant – Emissions of PM10 on this haul road will increase by
1.66 tpy, while emissions of PM2.5 will increase by 0.16 tpy. Wildcat will continue to
implement water and chemical suppressants to control particulate emissions.
11. Truck Unloading to Dry Plant #1 and Dry Plant #2 – The PM10 and PM2.5 emissions from
the transfer of 5% moisture content sand to the dry plants will increase to 0.39 tpy and
0.06 tpy, respectively for each drop point.
12. J&H Screens with Baghouse – The PM10 and PM2.5 emissions from the screens’ fabric filter
baghouse will increase by 2.92 tpy and 4.22 tpy, respectively. Wildcat will maintain the
control requirements as established by the current AO for best available controls.
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Wildcat Dryer BACT Analysis
Section 2
June 2023
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13. Dry Product Handling and Loading – Sand will be dried by the existing Dryer #1 and new
Dryer #2, and the BACT analysis for the sand dryers is addressed later in this document.
All product handling performed after drying the sand is assisted by a dust collector and
silo bin vent filter with a 99% control efficiency. Handling after the sand dryers increases
emissions by 0.0012 tpy of PM10, and 0.0003 tpy of PM2.5.
14. Enclosed Baghouse Waste Collection Area – The facility will keep the baghouse collection
area enclosed. The waste collection will keep the control requirements as established in
the current AO.
15. Bucket Elevator Transfer to Storage Silos and Loadout – The silos are each outfitted with
Silo Venting Collectors, and each will have a loadout spout. Wildcat is maintaining the
control requirements for silos as had been established in the previous AO. The combined
PM10 emissions from the silo transfer and loadout will be 0.052 tpy, and emissions of
PM2.5 will be 0.041 tpy.
16. Haul Road - Final Product – There is a final paved haul road for loading dried products,
which will see increases of 1.12 tpy of PM10 and 0.12 tpy of PM2.5. This haul road will be
maintained with 95% control efficiency, which was established in the previous AO as the
best available technology.
17. Haul Road - Additional Exit from Plant – The facility has an additional exit to the south of
the property. The road is unpaved and has optional use for loadout. The PTE
overestimated the annual usage of this haul road at 1,314,000 tpy. The emissions from
the haul road are 1.46 tpy of PM10 and 0.15 tpy of PM2.5.
18. Disturbed Area – Because this project will increase the amount storage piles, the area of
disturbed ground will increase under this project. The amount of disturbed ground will
increase from 11 to 14 acres, which will see an increase in PM10 emissions by 1.21 tpy and
PM2.5 emissions by 0.25 tpy.
19. Filter Press Engine – The original BACT was submitted with a 416-kW natural gas engine
for emergency generation. The manufacture certifies the Engine to meet the applicable
Environmental Protection Agency’s (EPA) New Source Performance Standards (NSPS)
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Subpart JJJJ for lean burn natural gas engines  75 kW (100 hp), which is BACT for
generators. These federal regulations address NOX, organic emissions, and particulates.
The emissions for PM10 and PM2.5 will increase to 0.15 tpy, each.
In total, emissions of PM10 that are not attributed to the sand dryers will increase under this
project by approximately 24.17 tons per year, and emissions of PM2.5 that are not attributed to
the sand dryers will increase by approximately 7.63 tons per year. The Engine will have NOX
emissions that will be 9.32 tons per year, SOX emissions that will be 0.01 tons per year, and CO
emissions that will be 18.63 tons per year. These processes remain the same as they had under
the previous AO, but for increased production of sand. The control requirements established in
the previous AO will remain as the best available controls under a new permit. For these
processes, Wildcat will maintain the same standards and requirements for emissions controls.
2.2 Potential BACT Options for Dryer #1 and #2
To evaluate energy impacts, environmental impacts, economic impacts, other considerations,
and cost calculations a list of potential emission controls must be comprised, and impacts and
assessments may be calculated per emission control. Form 01b and UAC R307-101-2 are clear in
advising that the application of BACT may not result in emission of pollutants which could exceed
those allowed by Section 111 or 112 of the Clean Air Act (CAA). CAA Section 111 and 112 tasked
the EPA to develop standards of performance for new, modified, and reconstructed sources.
Section 111 relates to standards for criteria pollutants such as PM, NOX, CO, and VOC. Section
112 relates to emissions of hazardous or toxic pollutants, which are not at issue with the Wildcat
rotary dryer nor the fluid bed dryer; moreover, there are no promulgated standards for
nonmetallic drying pursuant to Section 112 nor are hazardous or toxic emissions an area of
concern from sand drying. In contrast, the EPA has been reviewing criteria pollutant emissions
pursuant to Section 111 from nonmetallic industries, like sand processing and drying since the
1970s.
On April 23, 1986, proposed standards of performance for new sources (NSPS) sand drying
pursuant to Section 112, as published in the Code of Federal Regulations, Title 40, (40 CFR)
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Chapter I, Subchapter C, Part 60, Subpart UUU—Standards of Performance for Calciners and
Dryers in Mineral Industries (Subpart UUU). The Subpart UUU standards were heavily reviewed,
commented upon, and finalized in 1992 and 1993. Since 1992, the EPA has reviewed the Subpart
UUU standards every eight years pursuant CAA Section 111(b)(1)(B). Each review process has
resulted in no changes to Subpart UUU, and thus Subpart UUU has been established and
reviewed by EPA over the course of the last 37 years.
“The Administrator shall, at least every 8 years, review and, if appropriate, revise
such standards following the procedure required by this subsection for
promulgation of such standards.”
The established NSPS Subpart UUU standards for new sources has only determined that PM
control techniques are the only reduction in emissions that, “…(taking into account the cost of
achieving such reduction and any non-air quality health and environmental impact and energy
requirements) the Administrator determines has been adequately demonstrated.” Please see CAA
Section 111(a)(1) for the NSPS making process. In the 37 years of review and establishing
adequate emission reduction, only PM control technologies have been demonstrated.
Of the PM control technologies that the NSPS Subpart UUU has established and proven to be
adequately demonstrated, there are dry control devices and wet scrubbers. Again, the NSPS
rulemaking process has not established any control for NOX, CO, or VOC. Acceptable emission
reduction technologies of dry control devices include cyclones,[2] baghouses,[3] and electrostatic
precipitators (ESP).[4] The only wet control device established and demonstrated were wet

[2] Cyclones remove PM by centrifugal and inertial forces induced by forcing particulate laden gas to change direction;
this type of technology is often referred to as pre-cleaners or collectors due their nature of removing large PM before
exhausting to another control device.
[3] A fabric filter or baghouse unit consists of one or more isolated compartments containing rows of fabric bags in
the form of round, flat, or shaped tubes, or pleated cartridges. Particle laden gas passes up along the surface of the
bags then radially through the fabric.
[4] ESP is a PM control device that uses electrical forces to move particles entrained within an exhaust stream onto
collector plates. The particles are given an electrical charge when they pass through a corona; electrodes and high
voltage generate an electrical field forcing particles to collector plates.
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scrubbers.[5] Wildcat and ARC reviewed combustion controls and burner technologies such as
low-NOX burners and/or low-CO burners for potential control of NOX and CO respectively. Other
NOX, CO, and VOC controls could theoretically/potentially include catalyst or catalytic style
control technologies; there are no instances published, permitted, or publicly available of catalyst
or catalytic style control technologies demonstrated in practice for a sand dryer.
Since 1996, EPA’s RACT/BACT/LAER Clearinghouse (RBLC) has made only three documented BACT
determinations. All three BACT determinations were consistent with NSPS Subpart UUU in that
only required PM control technologies were settled upon as BACT and LAER. For reference, the
three RBLC determinations from Oregon, Wisconsin, and California are attached with this BACT
analysis. NOX and CO (and VOC) control technologies were not established in the BACT evaluation
process for sand dryers.
2.2.1 Summary of BACT analysis for FGR
Wildcat offers this clarification of the impacts of installing the sand dryers with or without Flue
Gas Recirculation (FGR) technology to control emissions from the sand drying process. The
purpose of FGR is to reduce NOX emissions by recirculating exhaust gases back into the
combustion chamber. External FGR involves recycling of flue gas back into the firebox as part of
the fuel-air mixture at the burner. Rather than using burner design features to recirculate gases
from within the firebox, FGR uses external ductwork to route a portion of the exhaust stream
back to the inlet side of the dryer. The cleanest fuel that is reasonably delivered to the Wildcat
property is natural gas, which is discussed in Section 2.2.3 (Fuel Consideration). As the dryers are
fueled with pipeline quality natural gas, which is inherently low in nitrogen content, fuel NOX is
not a major contributor. Given that NOX emissions from Dryer #1 and Dryer #2 are calculated to
be 23.65 tpy each, and the facility is already a minor source of NOX emissions, Wildcat would
retain that status under the proposed project. The ten-year annualized cost for installing Dryer
#1 with LNB and without FGR technology is $217,371.43 per ton NOX per year and Dryer #2 is

[5] In wet scrubbing processes, solid particles are removed from a gas stream by transferring them to a liquid. The
liquid most used for wet scrubbing is water.
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$243,929.02 per ton NOX per year, whereas the cost of reducing NOX emissions using the
Megastar LNB with FGR technology would be $61,673.59 and $69,089.80 per ton NOX per year
for Dryer #1 and Dryer #1, respectively, as shown in Tables 3 and 4 in Section 2.2.5 (Economic
Impacts). With the economic and environmental impacts in mind, the FGR is inappropriate for
sand drying from the perspective of energy impact.
2.2.2 Energy Impacts
Energy impacts are the first criteria to consider when conducting BACT analyses. Certain types of
control technologies have inherent energy penalties associated with their use and industry
application. For instance, baghouses and cyclones require energy to generate and regulate air
flow through control devices. These control devices use induced draft fans to pull air from the
source of the pollutants to send the dirty exhaust through adequate control. Based on the
industry application of sand drying already requiring air flow through the unit for adequate
temperature and moisture removal, almost all dryers are pre-designed with an integral cyclone
and baghouse designed as part of the drying system. Other add-on controls such as low-NOX/low-
CO burning, and catalytic type emission controls are not integral or inherent to the design of a
sand dryer.
In contrast, special burners and catalysts to reduce combustion gases are counterproductive to
the sand drying process and typically adversely affect dryer temperature and inefficiently
increase the backpressure and energy needed for sand drying. [6]
A baghouse or fabric filter uses an induced draft fan to pull air through bags or cartridges which
are used as the filter medium. Particulates attach to the bags and coat the bags in a fine layer of
dust. The bags are then cleaned when airflow becomes restricted for re-use in capturing
particulates from the air. A cyclone is often used as a pre-cleaner unit to fabric filter as they would
share flow and energy requires. Cyclones use an induced draft fan to pull air into a cylindrical
tube where centrifugal motion causes particles to hit the side wall of the cyclone and fall out of

[6] Tarmac Quotes SD780R5 and SD-949 comparison of energy needed to dry sand per ton of aggregate. EPA 456/F-
99-006R; https://www3.epa.gov/ttncatc1/dir1/fnoxdoc.pdf.
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the control device and are not released into the ambient air. Clean air is then pushed out through
the exit of the cyclone. An induced draft fan on a cyclone is typically sized smaller than a baghouse
because less energy is required to move air through the system. Based on research of publicly
available vendor data, and manufacturer data provided, it appears that the average-sized
baghouse for a 150 ton per hour sand dryer typically requires approximately 130 horsepower
(HP) of energy usage to maintain airflow. On a kilowatt (kW) basis, 130 HP is approximately 97
kW of energy. The Wildcat dryer models are inherently designed with this air flow to match
cyclone and baghouse requirements. The system is efficiently designed such that the energy
required for the cyclone baghouse tandem is also used to balance air flow for the sand drying
process. Therefore, the maximum energy impact is closer to a zero or nil impact in practice due
to the inherency of dryer-cyclone-baghouse shared air flow.
Another type of PM control is the wet scrubbing processes. This would be where solid dust/sand
particles are removed from a gas stream by adsorbing with a liquid along with condensing back
half particulates. Water is the liquid most used within the aggregate industry for PM wet
scrubbing. A wet scrubber's particulate collection efficiency is directly related to the amount of
energy expended in contacting the gas stream with the scrubber liquid. Most wet scrubbing
systems operate with particulate collection efficiencies near 95 percent whereas fabric filters
usually attain greater than 99 percent control. [7] There are differing energy usage levels for wet
scrubbers. A low energy wet scrubber utilizes pressure drops less than 5 inches of water column
(WC) and is capable of efficiently removing particles greater than about 5-10 micrometers in
diameter. A medium energy scrubber has a pressure drop from 5 to 25 inches of WC. For this, a
typical water pump and fan would require approximately 200 kW of energy (0.682 MMBtu/hr).
A fourth type of PM control device to be analyzed is an electrostatic precipitator (ESP). ESPs use
charged electricity to attract dust particles to the side walls, which are then “rapped” off using
automated hammer-like devices. ESPs are energy-intensive, and the efficiency can vary
depending on the type of dust being collected. ESPs use very high amounts of energy for their

[7] EPA/452/B-02-001; https://www3.epa.gov/ttncatc1/cica/files/cs6ch2.pdf.
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induced draft fans, plate charging, and mechanical rapping. It is difficult to estimate the amount
of energy needed, but the EPA estimates that an ESP equipped on the exhausted of the sand
dryers would have energy usage of 86,000 kW (293 MMBtu/hr) each.[6] For this reason, the
energy impacts deem ESP as infeasible for BACT on a sand dryer.
Low-NOX and low-CO type burning technology would typically require combustion temperature
manipulation and reduction which is usually counterproductive to the sand drying process. For
low-NOX, the combustion temperature may be reduced in several ways with the goal of keeping
the chambers below 1,400 degrees Fahrenheit (°F); this is the temperature at which thermal NOX
formation occurs. Four primary firing techniques to reduce NOX formation include: fuel rich
mixtures to limit the amount of oxygen available; fuel lean mixtures to limit temperature by
diluting energy input; injecting cooled oxygen-depleted flue gas into the combustion air to dilute
energy; and/or injecting cooled flue gas with added fuel. Low-NOX burners are based partially on
these principles. The basic technique is to reduce the temperature of combustion products with
an excess of fuel, air, flue gas, or steam. This methodology is the basis to avoid most of the
nitrogen from becoming ionized at 1,400 °F. [8]
There is an additional methodology to reduce NOX that involves steam injection, which is usually
used in boilers. This is not feasible with sand dryers due to their functionality of removing
moisture from sand. Adding water to the rotary drum to Dryer #1 would drastically decrease the
efficiency of the moisture removal process from the sand.
Typically coupled with and considered as a portion of the low-NOX burner (LNB) is flue gas
recirculation (FGR). Recirculation of cooled dryer exhaust and/or ambient air reduces the
temperature by diluting the oxygen content of combustion chamber air, and by causing heat to
be diluted in a greater mass of flue gas for temperature manipulation. Heat in the flue gas can be
recovered by a venting design and duct work. This reduction of temperature lowers the NOX

[8] EPA 456/F-99-006R; https://www3.epa.gov/ttncatc1/dir1/fnoxdoc.pdf.
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concentration that is generated. Again, if the sand dryer chambers are kept below 1,400 °F, then
the thermal NOX formation will be negligible. [9]
The nature of LNB and FGR tend to be counterintuitive for the sand drying process as high
chambers increase drying efficiency. The goal of LNB and FGR is to reduce temperature in the
combustion chamber. For purposes of energy impacts, third-party engineers would estimate that
dryer efficiency would likely be affected by 17 percent, [10] or approximately 25.5 tons per hour
for a 150 ton per hour dryer. According to burner manufacturer’s Legacy Hauck- Honeywell
Process Solutions/Honeywell Thermal Solutions (HPS/HTS or Honeywell), an FGR would require
a burner of 54 MMBtu/hr to be able to achieve 150 tons per hour drying rate. This needs an
energy increase of 50%. In addition, LNB and FGR would require a 50 HP blower. [11] The blower
energy impact would equate to approximately 37 kW (0.126 MMBtu/hr). The high energy impact
and counterproductivity of LNB and FGR can potentially eliminate these from the BACT
determination for the sand dryers.
Third-party engineers indicated that any low-CO burner (LCB) technology would likely negatively
affect the NOX emission rate, and further, LCB are more expensive and would require more
energy than NOX burner technologies. Given Uintah County is non-attainment for ozone, CO is
innocuous in the formation of ozone and NOX significantly contributes to ozone, ARC assumes
the DAQ would prefer low-NOX technologies be evaluated as opposed to other controls that do
not limit ozone. Moreover, as indicated by third-party engineers, LCB technology is less efficient
and would require more energy than LNB technologies. Thus, LCB technologies are deemed to
be a secondary consideration for BACT given LNB technologies have a lower energy,
environmental, and economic impact, and so if LNB/FGR is later considered as possible for BACT,
than LCB can be revisited and re-evaluated as a BACT on a dryer equipped with LNB/FGR.
CO and VOC emissions from the sand dryer exhaust could theoretically be reduced by an
oxidation catalyst or catalytic style control technologies. These would need to be equipped after

[9] EPA 456/F-99-006R; https://www3.epa.gov/ttncatc1/dir1/fnoxdoc.pdf.
[10] January 28, 2020 LNB and FGR email assessment from Michael G. Blantz, Engineer of Honeywell.
[11] Tarmac Quotes SD780R5 and SD-949 comparison of energy needed to dry sand per ton of aggregate.
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baghouse or filter control to avoid fouling or plugging of the catalyst. As discussed earlier, there
are not publicly available or demonstrated examples of catalyst technology on sand dryers to
control CO and VOC; further, there are not publicly available or demonstrated add-on CO or VOC
exhaust reduction for any sand dryer fired with propane or natural gas. At the direction of the
DAQ, this analysis considers the most reasonable option to control VOC given Uintah County is
non-attainment for ozone, and VOC contributes to ozone. Perhaps most appropriate by
comparison is the 40 CFR Part 63, Subpart ZZZZ Reciprocating Internal Combustion Engine
National Emission Standards for Hazardous Air Pollutants (RICE NESHAP) where gas engine
combustion exhaust is somewhat comparable to sand dryer exhaust. With the RICE NESHAP, EPA
determined that oxidation catalysts for two-stroke lean-burn (2SLB) and four-stroke lean-burn
(4SLB) engines, and non-selective catalytic reduction (NSCR) for four-stroke rich burn (4SRB)
engines are applicable controls for CO and VOC reduction from existing stationary spark ignition
RICE to the extent of close to 70 percent. To determine the validity and costs for these catalytic
control technologies, equipment information was obtained from industry groups [12] and vendors
and manufacturers of spark ignition engine control technology. Catalyst and NSCR require
exhaust to be heated to activate the catalyst; the exhaust post baghouse would require an
additional burner close to 10 MMBtu/hr or 2,930 kW. Further, a considerable amount of
backpressure would be added due to a catalyst or NSCR. For purposes of energy impacts from
backpressure, third-party engineers would estimate that dryer efficiency would likely be affected
close to ten percent; this would equate to an energy impact of 1.8 MMBtu/hr or 527 kW. The
energy impact and additional burners needed for CO and VOC control are infeasible in practice,
and further, these would increase NOX emissions per ton of aggregate dryer.
2.2.3 Fuel Consideration
Natural gas is delivered via pipeline to the Wildcat facility for fuel use for the sand dryers. When
natural gas is utilized, LNB technologies can have less cost and environmental impact than other

[12] NESHAP Emission Control Costs Analysis Background for “Above the Floor” Emission Controls for Gas-Fired RICE,
Innovative Environmental Solutions Inc., October 2009. (EPA-HQ-OAR2008-0708-0279).
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fuels, such as propane. LNB technologies for propane are less researched/developed and
inherently higher with NOX emissions due to chemical properties, therefore natural gas is
cleanest fuel that can be delivered to the facility for sand dryer combustion.
2.2.4 Environmental Impacts
Environmental impacts include any unconventional or unusual impacts of using a control device,
such as the generation of solid or hazardous waste, water discharges, visibility impacts, or
emissions of unregulated pollutants. For example, a wet scrubber may discharge contaminated
water, or a spent catalyst may create hazardous waste. Due to the infeasibility of energy impacts
for catalyst and NSCR technologies, these were eliminated in Section 2.2.2 from BACT, but for a
further example, spent catalyst that could be considered hazardous and would need to be
disposed of, or otherwise handled, every two to four years dependent upon vendor and
technology selected. Environmental impacts or PM and NOX control technologies are evaluated
because other criteria pollutants are not relevant for Wildcat’s sand dryers.
In terms of the plausible control devices for particulates to be used at the sand dryer, a wet
scrubber has the potential to discharge water, although it is very unlikely that this water would
be contaminated because sand is the only agent being sent to the water of a scrubber. In some
cases, discharges of high suspended solids in water from wet scrubbers can be a compliance
concern, but with appropriately handled pond systems, this is usually not an issue. Additionally,
a wet scrubber is not a very good candidate for controlling particulates, as scrubbers are not as
efficient at removing particulates as other control devices specifically meant for particulate
control.
Regarding possible control devices such as a baghouse and cyclone, the material captured by the
control device is not anticipated to be hazardous waste, as it is a recoverable product that Wildcat
can return to the process. Sand coating the bags or filters in a baghouse is not a concern when it
comes to disposal of bags that have aged out of usefulness or malfunctioned. Spent filter bags
are usually sent back to the vendor for recovery or to the landfill as non-hazardous waste.
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LNB with FGR do not collect material or generate waste for environmental impact. Use of LNB
can sometimes have a negative effect on CO and VOC emissions due to loss of ignition and
retarded combustion. This increases CO and VOC emissions rate. As discussed earlier, Uintah
County is more focused on NOX removal from the environment as opposed to CO due to NOX’s
reactivity in the atmosphere, and CO’s lack thereof. LNB with FGR units are projected to have a
useful life close to ten years, so there would be an impact of disposing or recycling spent burner
materials of steel and ceramic.
Furthermore, the 54 MMBtu/hr burner required for the LNB with FGR option[13] increases all
pollutants, including HAP, VOC, CO, greenhouse gases (GHG), and non-filterable PM, except NOX,
by 50 percent from natural gas combustion.[14] This 50 percent increase results from increased
fuel usage required for a burner 50 percent larger than the proposed 38 MMBtu/hr Starjet burner
in comparison to the required 54 MMBtu/hr Megastar burner for the LNB with FGR option.
2.2.5 Economic Impacts
For economic impacts of control equipment, the costs of a baghouse, cyclone, and LNB with FGR
were analyzed, as all other technologies included within Section 2.2 have been previously ruled
as an ineffective or infeasible control equipment at the site for their limited ability to remove
pollutants of interest. This section analyzes the cost of the identified control equipment and the
cost per ton of pollutant control. These numbers are prior to considering any potential taxes or
subsidies on the control equipment, as identified in Form 01b for BACT analysis.
The following tables identify the capital and annual costs of each control technology that would
be incurred to Wildcat if implemented.

[13] January 28, 2020 LNB and FGR email assessment from Michael G. Blantz, Engineer of Honeywell.
[14] ARC and Honeywell emissions analysis and Honeywell ppm and lb/ton of aggregate manufacturer guarantee for
Legacy Hauck/HTP/HTS suite of burners and FGR.
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Table 1: Capital Cost of Control Equipment per Dryer [15]
Control Device Expenditure Item Capital Cost Initial Total Cost
Baghouse
Baghouse $155,189
$176,950
Insulation $21,761
Cyclone
Cyclone $74,101
$101,635 Vortex Breaker $6,312
Cyclone Insulation $21,222
LNB Low-NOX Burner $98,851 $98,851
LNB with FGR
Low-NOX Burner with FGR $172,202
$197,702
Faceplate Mod $25,500

In addition to an initial capital cost, there are annual operating and maintenance (O&M) costs
per control device. In certain cases, there is an expected downtime for the sand dryer to service
and maintain the control device. At least annually, the dryers will need to be shut down to open
the baghouses internally and evaluate filter media for damage or replacement needs. The LNB
and FGR will need to be serviced and tuned to ensure the emission rates provided are being
attained. In both cases, it takes time for shutdown, equipment cooling, maintenance, targeted
tuning and adjustments, and startup. For the baghouse and LNB, each occurrence of inspection
and tuning would be expected to take a full day, or approximately eight hours. Third-party
engineers would estimate that dryer efficiency would likely be affected by 17 percent,[16] or
approximately 25.5 tons per hour, for a 150 ton per hour dryer. According to burner
manufacturer’s Legacy Hauck-Honeywell, an LNB with FGR would require a burner of 54
MMBtu/hr to be able to achieve 150 tons per hour drying rate. These annual O&M and increased
fuel usage costs are further detailed in Table 2.

[15] Tarmac Quotes SD780R5 and SD-949.
[16] January 28, 2020 LNB and FGR email assessment from Michael G. Blantz, Engineer of Honeywell.
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Table 2: Annual Reoccurring Cost to Service Control Equipment per Dryer
Control Device Service Item [17] O&M Cost Total Annual O&M Cost
Baghouse
Filter Media Replacement $30,000 per year
$100,000
Annual Shutdown Insp. $70,000 per year
Cyclone Annual Shutdown Insp. $70,000 per year $70,000
Starjet LNB
Annual Burner Tuning $120,000 per year
$133,286
Annual Expert Tuner $13,286 per year
Megastar LNB
Semiannual Burner Tuning $240,000 per year
$607,067-682,444 Semiannual Expert Tuner $26,572 per year
Lost Drying Efficiency [18] $40-48 per hour
Megastar LNB with
FGR
Semiannual Burner Tuning $240,000 per year
$607,067-$682,444 Semiannual Expert Tuner $26,572 per year
Lost Drying Efficiency [18] $40-48 per hour

Based on the costs of these control devices, Tables 3 through 5 on the following page describes
the pollutant removal efficiencies of each control device and the cost per ton of pollutant control
over the course of the first year of the control device being active. For the purposes of this
analysis, PM, PM10, and PM2.5 have been speciated.

[17] Currently and historically for the last five years, dry sand, silica sells on the market between $50 to $100 per ton.
Wildcat’s dryers are designed to operate at 150 tons per hour without LNB. On an hourly basis, this equates to $7,500
if the minimum price of sand per ton is assumed, 150 ton/hr * $50 = $7,500 per hour. The Service Estimate attached
as supporting documentation plans for two days where the plant will not be running. Expert tuning will be necessary
once per year for the Starjet burner, and twice per year for the Megastar burner. Each O&M outage is expected to
be eight hours, 8 hr * $7,500/hr * two days = $120,000 for each service period.
[18] As explained in Section 2.2.2, LNB and FGR reduce thermal efficiency by approximately a minimum of 17 percent.
Honeywell experts indicate a 54 MMBtu/hr burner would be needed to maintain the 150 tons per hour drying
capacity. For each additional MMBtu/hr of natural gas needed would equate to close to three dollars per hour, if
not more. As an example for Dryer #2, to be conservative, three dollars per MMBtu of natural gas is assumed 16
MMBtu/hr * $3/MMBtu = $48/hr, which could be 8,664 hrs at $48/hr of lost production, 8,664 = 8,760 hr/yr minus
96 hr/yr of O&M, for total of $415,872/yr.
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When gathering an emissions profile for the process at Wildcat, it was conservatively calculated
that PM, PM10, and PM2.5 emission factors were identical for natural gas combustion purposes.
During the process of sand drying, it is more likely that larger particles than PM10 would be
emitted due to the size of sand mined and processed. The PM emission factors were used with a
conservative assumption that 50 percent of emitted PM is for PM10 and PM2.5.
The baghouse was conservatively assumed to have a 99% control efficiency of all particulates.
The cyclone control efficiency was taken from AP-42 Appendix B.2, Table B.2-3 (09/1990, AIRS
code 075) for a single cyclone. Cyclones typically have a larger removal efficiency for larger
particulates based on design. The cut size of a particulate that can be controlled via centrifugal
forces is generally much larger than what can be captured by a physical media like a bag or filter.
Uncontrolled NOX emissions are based upon emission factors from EPA’s AP-42 Tables 1.4 for
Natural Gas Combustion (7/1998) with a conversion factor such that 1,050 MMBtu is 1,000,000
standard cubic foot (MMscf). The controlled NOX rate with LNB and FGR was provided by Tarmac
and Honeywell/Hauck as would be the lowest emitting NOX technology on the market and
specifically designed for the Tarmac sand dryer [19].
Table 3. Controlled Costs of Dollar per Ton of Pollutant Reduced without FGR
Dryer Pollutant
Dryer
Uncontrolled
Emissions
(tons/yr)
Baghouse/
Cyclone & LNB
Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 512.91 312.99 364.28
NOX 16.34 13.50 34,828.27 213,888.61 217,371.43
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 13.50 34,828.27 240,446.19 243,929.02

[19] Tarmac Quotes SD780R5 and SD-949, NOX of Megastar LNB emits at 80 ppm and 0.025 lbs of NOX per ton of sand;
LNB and FGR emits at 36 ppm and 0.011 lbs of NOX per ton of sand for $197,702 capital.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Dryer BACT Analysis
Section 2
June 2023
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Table 4. Controlled Costs of Dollar per Ton of Pollutant Reduced with FGR
Dryer Pollutant
Dryer
Uncontrolled
Emissions
(tons/yr)
Baghouse/
Cyclone & Megastar
& FGR Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 512.91 312.99 364.28
NOX 16.34 6.18 19,451.60 59,728.43 61,673.59
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 6.18 19,451.60 67,144.64 69,089.80

Based upon Tables 3 and 4, the economic ten-year annualized cost for the baghouse and cyclone
tandem is cost effective for BACT. Table 3 considered the O&M and increased fuel from Megastar
LNB without FGR which shows an exorbitantly high for $217,371.43 for Dryer #1 and $243,929.02
for Dryer #2 annualized cost per ton of NOX. Without FGR, the Megastar technology is capable of
potentially removing less than three tons of NOX per year. The emissions from the Megastar LNB
only burner technology was calculated, showing that most of the attributed to additional fuel
required for the Megastar burner; if a thermal efficiency production loss is accounted, the ten-
year annualized cost for LNB is $61,673.59 per ton of NOX removed per year for Dryer #1 and
$69,089.80 per ton of NOX removed per year for Dryer #2, as shown in Table 4. Both economic
scenarios demonstrate that Megastar LNB, and Megastar LNB with FGR are not feasible on a cost
basis which was also alluded to in Section 2.2.2 in evaluation of energy impacts. Thus, the analysis
for Wildcat’s sand dryer deems a cyclone and baghouse tandem is BACT, and the sand dryer is
consistent with, and better than, EPA’s requirements and review pursuant to CAA Section 111;
LNB with FGR is not feasible for Wildcat’s sand dryer based on energy and economic impact.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Dryer BACT Analysis
Section 2
June 2023
_________________________________ Page 20 of 25

2.3 Potential BACT Options for Filter Press Engine
2.3.1 Energy Impacts
Certain types of control technologies have inherent energy penalties associated with their use
and industry application. New, modern engines utilize clean technology that are NSPS site
compliant capable. The use of post-manufacturing add-on controls would require additional
energy consumption for the manufacturing and transport of the Engine as well as the transport
of manpower required for assembly and troubleshooting. It is difficult to estimate the amount of
energy needed, however the low-emissions levels of the Engine deem add-ons infeasible.
2.3.2 Environmental Impacts
Environmental impacts include any unconventional or unusual impacts of using a control device,
such as the generation of solid or hazardous waste, water discharges, visibility impacts, or
emissions of unregulated pollutants. In the case of the natural gas Engine, spent catalyst
reduction agent that could be considered hazardous would need to be disposed of, or otherwise
handled, every two to four years, dependent on vendor and technology selected.
2.3.3 Economic Impacts
Pollutant emissions from the internal combustion engine include NOX, PM10, PM2.5, CO, and VOCs.
Annual operation of the Engine will be 8,760 hours. The potential emissions from the Engine are
provided in Table 5. The following analysis will illustrate that the use of the Engine as supplied by
the manufacturer without any additional emission control methods is recommended due to
meeting or being below the standards for appropriate emissions as outlined in 40 CFR Part 60,
Subpart JJJJ, and any additional control technologies would create an undue cost burden on the
Sand Plant.
Table 5. Internal Combustion Engine Emissions
Component Operating
Hours Size NOX
(tpy)
PM10
(tpy)
PM2.5
(tpy)
SOX
(tpy)
CO
(tpy)
VOC
(tpy)
Engine 8,760 416 kW 9.32 0.15 0.15 0.01 18.63 1.75
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Dryer BACT Analysis
Section 2
June 2023
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Based on research and engineering experience, the control technologies for internal combustion
engines listed in Table 6 were considered for this BACT analysis.
Table 6. Control Technologies for Internal Combustion Engines
Pollutant Control Technology
CO/VOC Oxidation Catalyst
NOX Exhaust Recirculation [1], Selective Catalytic Reduction (SCR), Non-SCR (NSCR), Lean
Combustion (LC), Good Combustion Practices
PM10/PM2.5 Fabric Filters, Dry ESP, Wet ESP, Venturi Scrubber, Good Combustion Practices
[1] Exhaust gas recirculation is not part of the original manufacturer design. Therefore, it is not feasible without
substantial engineering overhaul of the units.

The Engine is subject to the NOX, CO, and VOC standards outlines in Table 1 of 40 CFR Part 60,
Subpart JJJJ for non-emergency spark ignition natural gas engines between 100 hp and 500 hp
manufactured after July 1, 2008. The Engine, as manufactured, meets the standards, therefore,
no additional control technology will be required or used with the Engine.
Table 7. Engine Emission Standards from Table 1, 40 CFR Part 60, Subpart JJJJ
Pollutant JJJJ Standard (g/hp-hr)
CO 4.0
VOC 1.0
NOX 2.0

Non-Selective Catalytic Reduction (NSCR) was evaluated. NSCR is often referred to as a three-
way conversion catalyst system because the catalyst reactor simultaneously reduces NOX, CO and
hydrocarbons, and involves placing a catalyst in the exhaust stream of the Engine. However, NSCR
technology works with rich-burn engines only. Because the Engine is a lean-burn unit, the use of
a NSCR is not applicable.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Dryer BACT Analysis
Section 2
June 2023
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Selective Catalytic Reduction (SCR) is used to reduce NOX emissions from lean-burn engines using
a reducing agent, such as ammonia or urea. SCR systems inject the reduction agent into the lean-
burn exhaust stream. The agent reacts selectively with the flue gas NOX, converting it to
molecular nitrogen (N2), and water vapor (H2O). Control for a SCR system is typically 80-95%
reduction of NOX (EPA, AP-42 Section 3.2).
An oxidation catalyst is a post-combustion technology that has been shown to reduce CO
emissions in lean-burn engines. Ina catalytic oxidation system, CO passes over a catalyst, usually
a noble metal, which oxidizes the CO to CO2 at efficiencies of approximately 90% for 4-stroke
lean-burn engines. When used in conjunction with a SCR system, the CO2, water, and NOX then
enter the SCR catalyst, where the NOX reacts with the reducing agent.
The Engine, using lean combustion technology involves the increase of the air-to-fuel ratio to
lower the peak combustion temperature, thus reducing formation of NOX. Typically, engines
operate at the air-to-fuel ratio of about 20 to 35 pounds of air to pound of fuel. In a typical Lean-
Burn engine, this ratio is increased to 45 to 50. With a conventional spark ignition, the air fuel
ratio can only be increased to a certain point before the onset of lean misfire. To avoid misfire
problems and to ensure complete combustion of very lean mixtures, the engine manufacturers
have developed torch ignition technology and the application of a controlled swirl. Some increase
in fuel consumption and CO and HC emissions results from the slower flame propagation for very
lean mixtures. At optimal setting new lean burn engines can achieve NOX levels of 2 g/hp-hr (gram
per horsepower-hour) or below. This corresponds to an 80 to 90 percent control over
conventional spark plug design engines.
The total estimated capital investment associated with the installation, startup, and equipment
costs of a SCR is $2,127,689 in 2023 dollars, in accordance with EPA’s Cost Reports and Guidance
for Air Pollution Regulations, Section 4, SCR Cost Calculation Spreadsheet (updated 06/12/2019).
This total is calculated based on industry costs collected and validated by the EPA in 2016 and
then adjusted to 2023 dollars on the Chemical Engineering Plant Cost Index (CEPCI). It was
estimated that each catalyst has an operational life of 20,000 hours. Because the Engine will
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Dryer BACT Analysis
Section 2
June 2023
_________________________________ Page 23 of 25

operate 8,760 hours annually, it is determined that significant maintenance activities will be
required every 27 months. Each SCR unit is anticipated to have a use life of 20 years before
requiring complete replacement. With an effectiveness in reducing NOX emissions by 85%, a SCR
would remove an estimated 7.93 tpy. This results in a cost effectiveness of $34,060 per ton of
NOX removed in 2023 dollars.
2.4 Other Considerations
Form 01b for BACT determination guidance from the Division lists 11 “other considerations” for
BACT analyses. Per each consideration listed, Wildcat and ARC are providing response as follows.
1. “When exceeding otherwise appropriate costs by a moderate amount would result in a
substantial additional emissions reduction.”
Based on the analysis in Section 2.2 and 2.2.5 of this BACT determination, the pollution
control cost for PM reduction technologies provides the maximum amount of PM removal.
NOX only has the potential to be reduced by 10.16 tons of NOX per year for each dryer and
7.93 tons of NOX per year for the Engine based upon potential to emit. The small amount is
due to Wildcat’s relatively small burner and Engine in terms of comparison to large industrial
aggregate producers and synthetic minor/major sources of emissions. Wildcat is a natural
minor source of emissions. Additionally, the Engine emissions are below the standards for
appropriate emissions as outline in 40 CFR Part 60, Subpart JJJJ. There are no control
technologies that would result in a substantial additional emissions reduction, therefore the
cost associated with any add-on control technology would be considered substantial and well
beyond a moderate amount.
2. “When a control technology would achieve controls of more than one pollutant (including
HAPs).”
Particulate control equipment does have the ability to remove solid metallic HAPs, however,
it is assumed that any metallic HAP emissions from Dryer #1, Dryer #2, or Engine would be
negligible, and an analysis of metallic HAPs was not included in this determination. A
baghouse is not likely to control any gaseous pollutants. LNB with FGR is not considered to
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Dryer BACT Analysis
Section 2
June 2023
_________________________________ Page 24 of 25

reduce HAPs or any other pollutant besides NOX, and as shown in Section 2.2.1, HAPs are
increased with LNB and FGR. The NSCR is the only control technology available for the Engine
that could reduce NOX and CO, however the technology only works with rich-burn engines.
Because the Engine is a lean-burn unit, use of a NSCR is not appliable.
3. “Where the proposed BACT level would cause a new violation of an applicable NAAQS or PSD
increment. A permit cannot be issued to a source that would cause a new violation of either.”
This BACT will not cause a violation of NAAQS or PSD for any proposed equipment.
4. “When there are legal constraints outside of the Clean Air Act, such as a SIP or state rule,
requiring the application of a more stringent technology than one which otherwise would
have been determined to be BACT.”
There are no additional legal constraints that would require more stringent technology be
used at Dryer #1, Dryer #2, or the Engine.
5. “Any time a permit limit founded in BACT is being considered for revision, a reopening of the
original BACT determination must be made, even if the permit limit is exceeded by less than
the significant amount. Therefore, all controls upstream of the emission point, including
existing controls, must be re-evaluated for BACT.”
Dryer #1 BACT was within AO #DAQE-IN159980003-21, issued July 1, 2021. The Wildcat Dryer
#2 and Engine are new equipment and new BACT determinations; an analysis of existing
equipment is included in Section 2.1.
6. “The cost of all controls, including existing controls and any proposed control improvements,
should be expressed in terms of a single dollar year, preferably the current year. Any proposed
improvements should then be added to that cost, also in today’s dollars.”
The cost of control for Dryers #1 and #2 were determined using the dollar year 2019 and
2020, consistent with vendor quotes collected for the project. The cost of control for the
Engine was determined using dollar year 2023.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Dryer BACT Analysis
Section 2
June 2023
_________________________________ Page 25 of 25

7. “EPA cannot provide a specific cost figure for cost/ton of pollutant removed without
contradicting the PSD definition of BACT. They recognize that a case-by-case evaluation is
inherently judgmental and can be particularly difficult without a cost guideline.”
The impacts of energy and costs of control were determined using EPA emission factors,
control efficiencies, and published studies.
8. “A top-down type of BACT analysis is recommended by EPA and required by Utah.”
A top-down type of BACT analysis was used, and ARC and Wildcat were over inclusive in
considering several control technologies, including CO and VOC not demonstrated in any case
publicly available, permitted, or published.
9. “DAQ will review BACT determination for plants not yet built, if those plants have already
applied for AOs and BACT determinations have already been made or proposed.”
The new Wildcat Dryer #2 and Engine are not yet constructed. The Sand Plant has an issued
AO and BACT determination for the current sand dryer, haul roads, and process equipment.
10. “Utah must ensure that any technically feasible improvements to existing controls that would
fall within the realm of reasonableness be considered, unless the improvement would yield
insignificant additional control.”
All reasonable controls have been considered for this analysis.
11. “In all cases, a complete BACT analysis must be submitted and must consider environmental
and energy, as well as economic impacts, unless an existing BACT determination/approval is
applicable to your source and is acceptable to the DAQ.”
The proposed BACT for Wildcat follows Form 01b, UAC R307-101-2, EPA federal standards,
and capability of the sand drying techniques nationwide.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

Vendor, Emissions, & EPA Supporting Documentation
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Prepared with Air Regulations
Consulting, LLC AssistanceWildcatBURNER: STARJET HONEYWELL/HAUCK
Wildcat Sand Dryer PTE FGR: N/A
Rotary Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 20,955 acfm
Total Heat Input Capacity 40.9 MMBtu/hr
Total Heat Input Capacity 0.039 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0070 1.25 10,973 5.49
PM10**0.0070 1.25 10,973 5.49
PM2.5***0.0070 1.25 10,973 5.49
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx) 100 3.7305 32,679 16.34
Sulfur Dioxide (SO2)0.60 0.0234 205 0.10
Carbon Monoxide (CO)84 3.2720 28,663 14.33
Volatile Organic Compounds (VOC)5.5 0.2142 1,877 0.94
Greenhouse Gas Pollutants (GHG)Emission Factor[2]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 4,784 41,911,095 20,956
Nitrous Oxide (N2O)0.0002 0.0090 79 0.04
Methane (CH4)0.0022 0.0902 790 0.40
Individual Hazardous Air Pollutants (HAP) Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.7166 0.0004
Dichlorobenzene 0.0012 0.0000 0.4095 0.0002
Formaldehyde 0.0750 0.0029 25.5917 0.0128
Hexane 1.8000 0.0701 614.2011 0.3071
Lead Compounds 0.0005 0.0000 0.1706 0.0001
Naphthalene 0.0006 0.0000 0.2081 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0301 0.0000
Toluene 0.0034 0.0001 1.1602 0.0006
Arsenic Compounds (ASC)0.0002 0.0000 0.0682 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0041 0.0000
Cadmium Compounds (CDC)0.0011 0.0000 0.3753 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.4777 0.0002
Cobalt Compounds (COC)0.0001 0.0000 0.0287 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1297 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.0887 0.0000
Nickel Compounds (NIC)0.0021 0.0001 0.7166 0.0004
Selenium Compounds (SEC)0.0000 0.0000 0.0082 0.0000
Total HAPs 1.8885 0.0736 644.3851 0.3222
[1]Emission Factors for PM based NSPS UUU requirements including process and combustion emissions. NSPS requires PM be no greater than 0.025 gr/dscf.
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates.
Given exhaust temperature stacks will approximately be 300 F, 0.01 gr/dscf equals 0.0070 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+300))]
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,050 MMBtu/MMscf.
[3]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 1,050 MMBtu/MMscf.
* Nominal capacity of the 150 ton per hour sand is based upon elevation at the site and assuming sand enters the dryer with 5% moisture.
NOx emission rates adjusted by manufacturer for Honeywell's Starjet Burner, ~96 ppm, ~0.029 lb/ton, without FGR.
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Prepared with Air Regulations
Consulting, LLC AssistanceWildcatBURNER: STARJET HONEYWELL/HAUCK
Wildcat Sand Dryer PTE FGR: N/A
Fluid Bed Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 50,000 acfm
Total Heat Input Capacity 38.0 MMBtu/hr
Total Heat Input Capacity 0.036 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0070 2.99 26,181 13.09
PM10**0.0070 2.99 26,181 13.09
PM2.5***0.0070 2.99 26,181 13.09
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx) 100 3.7305 32,679 16.34
Sulfur Dioxide (SO2)0.60 0.0217 190 0.10
Carbon Monoxide (CO)84 3.0400 26,630 13.32
Volatile Organic Compounds (VOC)5.5 0.1990 1,744 0.87
Greenhouse Gas Pollutants (GHG)Emission Factor[2]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 4,445 38,939,404 19,470
Nitrous Oxide (N2O)0.0002 0.0084 73 0.04
Methane (CH4)0.0022 0.0838 734 0.37
Individual Hazardous Air Pollutants (HAP) Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.6658 0.0003
Dichlorobenzene 0.0012 0.0000 0.3804 0.0002
Formaldehyde 0.0750 0.0027 23.7771 0.0119
Hexane 1.8000 0.0651 570.6514 0.2853
Lead Compounds 0.0005 0.0000 0.1585 0.0001
Naphthalene 0.0006 0.0000 0.1934 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0280 0.0000
Toluene 0.0034 0.0001 1.0779 0.0005
Arsenic Compounds (ASC)0.0002 0.0000 0.0634 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0038 0.0000
Cadmium Compounds (CDC)0.0011 0.0000 0.3487 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.4438 0.0002
Cobalt Compounds (COC)0.0001 0.0000 0.0266 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1205 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.0824 0.0000
Nickel Compounds (NIC)0.0021 0.0001 0.6658 0.0003
Selenium Compounds (SEC)0.0000 0.0000 0.0076 0.0000
Total HAPs 1.8885 0.0683 598.6952 0.2993
[1]Emission Factors for PM based NSPS UUU requirements including process and combustion emissions. NSPS requires PM be no greater than 0.025 gr/dscf.
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates.
Given exhaust temperature stacks will approximately be 300 F, 0.01 gr/dscf equals 0.0070 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+300))]
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,050 MMBtu/MMscf.
[3]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 1,050 MMBtu/MMscf.
* Nominal capacity of the 150 ton per hour sand is based upon elevation at the site and assuming sand enters the dryer with 5% moisture.
NOx emission rates adjusted by manufacturer for Honeywell's Starjet Burner, ~96 ppm, ~0.029 lb/ton, without FGR.
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

From: Honeywell Thermal Solutions
Subject: Expected Emissions Starjet Series Burner
Honeywell Thermal Solutions makes the following statement of expected emissions levels for the products of
combustion from the Legacy Hauck Starjet series open fired burners, for use in Aggregate Drying.

Expected emissions are as follows:
Natural Gas Fired StarJet Emissions *

@3% O2 @7% O2 @19% O2
NOx < 96 PPM < 75 PPM < 10 PPM 0.02 lbs/ton of aggregate
CO < 500 PPM < 388 PPM < 53 PPM 0.0 2 lbs/ton of aggregate
VOC < 105 PPM < 82 PPM < 11 PPM 0.0 lbs/ton of aggregate
***
SOx** None None None

Liquid Propane Fired StarJet Emissions *

@3% O2 @7% O2 @19% O2
NOx < 130 PPM < 101 PPM < 14 PPM 0.0 lbs/ton of aggregate
CO < 600 PPM < 466 PPM < 64 PPM 0.1 lbs/ton of aggregate
VOC < 105 PPM < 82 PPM < 11 PPM 0.0 lbs/ton of aggregate
***
SOx** None None None

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
* Emissions are provided in 1) Parts Per Million (PPM) on dry volumetric basis corrected to specified % O2 and
Higher Heating Value (HHV) of the fuel, and 2) lbs/ton of aggregate based on gross heat input of 2 5,000 BTU/ton of
aggregate. Emissions in lbs/ton of aggregate will vary if a different gross heat input value is used.
** SOx emissions for Natural Gas or Liquid Propane firing should be negligible based on the assumptions that the
fuel contains no sulfur, and the combustion air and Aggregate Drying process contain no sulfur/sulfur containing
compounds.
SOx emissions for all Fuel Oil firing are based on a maximum conversion of 50% of fuel-bound sulfur with the
remaining 50% assumed contained in the final product.
*** VOC weight is based on Propane, C3H8.
**** SOx weight for No. 2 Fuel Oil is based on SO2 and a maximum of 0.2 weight % sulfur in the fuel.
SOx weight for Waste Derived Liquid Fuel Oil and Residual Fuel Oil firing is based on SO2 and a maximum of
0.36 weight % sulfur in the fuel.

Regards,
Honeywell Thermal Solutions

Michael G. Blantz
Sales Engineer, Asphalt

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Prepared with Air Regulations
Consulting, LLC AssistanceWildcatBURNER: MEGASTAR HONEYWELL/HAUCK
Wildcat Sand Dryer PTE FGR: N/A, & MEGASTAR REQUIRES 54 MMBTU/HR
Rotary Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 20,955 acfm
Total Heat Input Capacity 54.0 MMBtu/hr
Total Heat Input Capacity 0.051 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0070 1.25 10,973 5.49
PM10**0.0070 1.25 10,973 5.49
PM2.5***0.0070 1.25 10,973 5.49
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx) 100 3.0825 27,003 13.50
Sulfur Dioxide (SO2)0.60 0.0309 270 0.14
Carbon Monoxide (CO)84 4.3200 37,843 18.92
Volatile Organic Compounds (VOC)5.5 0.2829 2,478 1.24
Greenhouse Gas Pollutants (GHG)Emission Factor[2]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 6,317 55,334,942 27,667
Nitrous Oxide (N2O)0.0002 0.0119 104 0.05
Methane (CH4)0.0022 0.1191 1,043 0.52
Individual Hazardous Air Pollutants (HAP) Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.9461 0.0005
Dichlorobenzene 0.0012 0.0001 0.5406 0.0003
Formaldehyde 0.0750 0.0039 33.7886 0.0169
Hexane 1.8000 0.0926 810.9257 0.4055
Lead Compounds 0.0005 0.0000 0.2253 0.0001
Naphthalene 0.0006 0.0000 0.2748 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0397 0.0000
Toluene 0.0034 0.0002 1.5317 0.0008
Arsenic Compounds (ASC)0.0002 0.0000 0.0901 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0054 0.0000
Cadmium Compounds (CDC)0.0011 0.0001 0.4956 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.6307 0.0003
Cobalt Compounds (COC)0.0001 0.0000 0.0378 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1712 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.1171 0.0001
Nickel Compounds (NIC)0.0021 0.0001 0.9461 0.0005
Selenium Compounds (SEC)0.0000 0.0000 0.0108 0.0000
Total HAPs 1.8885 0.0971 850.7774 0.4254
[1]Emission Factors for PM based NSPS UUU requirements including process and combustion emissions. NSPS requires PM be no greater than 0.025 gr/dscf.
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates.
Given exhaust temperature stacks will approximately be 300 F, 0.01 gr/dscf equals 0.0070 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+300))]
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,050 MMBtu/MMscf.
[3]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 1,050 MMBtu/MMscf.
* Nominal capacity of the 150 ton per hour sand is based upon elevation at the site and assuming sand enters the dryer with 5% moisture
NOx emission rates adjusted by manufacturer for Honeywell's Megastar Burner, ~80 ppm, ~0.021 lb/ton, without FGR.
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Prepared with Air Regulations
Consulting, LLC AssistanceWildcatBURNER: MEGASTAR HONEYWELL/HAUCK
Wildcat Sand Dryer PTE FGR: N/A, & MEGASTAR REQUIRES 54 MMBTU/HR
Fluid Bed Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 50,000 acfm
Total Heat Input Capacity 54.0 MMBtu/hr
Total Heat Input Capacity 0.051 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0070 2.99 26,181 13.09
PM10**0.0070 2.99 26,181 13.09
PM2.5***0.0070 2.99 26,181 13.09
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx) 100 3.0825 27,003 13.50
Sulfur Dioxide (SO2)0.60 0.0309 270 0.14
Carbon Monoxide (CO)84 4.3200 37,843 18.92
Volatile Organic Compounds (VOC)5.5 0.2829 2,478 1.24
Greenhouse Gas Pollutants (GHG)Emission Factor[2]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 6,317 55,334,942 27,667
Nitrous Oxide (N2O)0.0002 0.0119 104 0.05
Methane (CH4)0.0022 0.1191 1,043 0.52
Individual Hazardous Air Pollutants (HAP) Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.9461 0.0005
Dichlorobenzene 0.0012 0.0001 0.5406 0.0003
Formaldehyde 0.0750 0.0039 33.7886 0.0169
Hexane 1.8000 0.0926 810.9257 0.4055
Lead Compounds 0.0005 0.0000 0.2253 0.0001
Naphthalene 0.0006 0.0000 0.2748 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0397 0.0000
Toluene 0.0034 0.0002 1.5317 0.0008
Arsenic Compounds (ASC)0.0002 0.0000 0.0901 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0054 0.0000
Cadmium Compounds (CDC)0.0011 0.0001 0.4956 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.6307 0.0003
Cobalt Compounds (COC)0.0001 0.0000 0.0378 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1712 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.1171 0.0001
Nickel Compounds (NIC)0.0021 0.0001 0.9461 0.0005
Selenium Compounds (SEC)0.0000 0.0000 0.0108 0.0000
Total HAPs 1.8885 0.0971 850.7774 0.4254
[1]Emission Factors for PM based NSPS UUU requirements including process and combustion emissions. NSPS requires PM be no greater than 0.025 gr/dscf.
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates.
Given exhaust temperature stacks will approximately be 300 F, 0.01 gr/dscf equals 0.0070 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+300))]
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,050 MMBtu/MMscf.
[3]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 1,050 MMBtu/MMscf.
* Nominal capacity of the 150 ton per hour sand is based upon elevation at the site and assuming sand enters the dryer with 5% moisture
NOx emission rates adjusted by manufacturer for Honeywell's Megastar Burner, ~80 ppm, ~0.021 lb/ton, without FGR.
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
:
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Prepared with Air Regulations
Consulting, LLC AssistanceWildcatBURNER: MEGASTAR HONEYWELL/HAUCK
Wildcat Sand Dryer PTE FGR: INCLUDED & REQUIRES 54 MMBTU/HR
Rotary Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 20,955 acfm
Total Heat Input Capacity 54.0 MMBtu/hr
Total Heat Input Capacity 0.051 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0070 1.25 10,973 5.49
PM10**0.0070 1.25 10,973 5.49
PM2.5***0.0070 1.25 10,973 5.49
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx) 100 1.4100 12,352 6.18
Sulfur Dioxide (SO2)0.60 0.0309 270 0.14
Carbon Monoxide (CO)84 4.3200 37,843 18.92
Volatile Organic Compounds (VOC)5.5 0.2829 2,478 1.24
Greenhouse Gas Pollutants (GHG)Emission Factor[2]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 6,317 55,334,942 27,667
Nitrous Oxide (N2O)0.0002 0.0119 104 0.05
Methane (CH4)0.0022 0.1191 1,043 0.52
Individual Hazardous Air Pollutants (HAP) Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.9461 0.0005
Dichlorobenzene 0.0012 0.0001 0.5406 0.0003
Formaldehyde 0.0750 0.0039 33.7886 0.0169
Hexane 1.8000 0.0926 810.9257 0.4055
Lead Compounds 0.0005 0.0000 0.2253 0.0001
Naphthalene 0.0006 0.0000 0.2748 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0397 0.0000
Toluene 0.0034 0.0002 1.5317 0.0008
Arsenic Compounds (ASC)0.0002 0.0000 0.0901 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0054 0.0000
Cadmium Compounds (CDC)0.0011 0.0001 0.4956 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.6307 0.0003
Cobalt Compounds (COC)0.0001 0.0000 0.0378 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1712 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.1171 0.0001
Nickel Compounds (NIC)0.0021 0.0001 0.9461 0.0005
Selenium Compounds (SEC)0.0000 0.0000 0.0108 0.0000
Total HAPs 1.8885 0.0971 850.7774 0.4254
[1]Emission Factors for PM based NSPS UUU requirements including process and combustion emissions. NSPS requires PM be no greater than 0.025 gr/dscf.
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates.
Given exhaust temperature stacks will approximately be 300 F, 0.01 gr/dscf equals 0.0070 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+300))]
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,050 MMBtu/MMscf.
[3]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 1,050 MMBtu/MMscf.
* Nominal capacity of the 150 ton per hour sand is based upon elevation at the site and assuming sand enters the dryer with 5% moisture.
NOx emission rates adjusted by manufacturer for Honeywell's Megastar Burner, ~36 ppm, ~0.010 lb/ton, with FGR.
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Prepared with Air Regulations
Consulting, LLC AssistanceWildcatBURNER: MEGASTAR HONEYWELL/HAUCK
Wildcat Sand Dryer PTE FGR: INCLUDED & REQUIRES 54 MMBTU/HR
Fluid Bed Sand Dryer (Fired with Natural Gas)
PTE from Sand Drying Controlled via a Cyclone and Baghouse
Natural Gas
Sand Throughput*150 tons per hour
Volumetric Air Flow 50,000 acfm
Total Heat Input Capacity 54.0 MMBtu/hr
Total Heat Input Capacity 0.051 MMscf/hr
Pollutant Emission Factor[1]
(gr/acf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Particulate Matter (PM)0.0070 2.99 26,181 13.09
PM10**0.0070 2.99 26,181 13.09
PM2.5***0.0070 2.99 26,181 13.09
Pollutant Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Nitrogen Oxides (NOx) 100 1.4100 12,352 6.18
Sulfur Dioxide (SO2)0.60 0.0309 270 0.14
Carbon Monoxide (CO)84 4.3200 37,843 18.92
Volatile Organic Compounds (VOC)5.5 0.2829 2,478 1.24
Greenhouse Gas Pollutants (GHG)Emission Factor[2]
(lb/MMBtu)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Carbon Dioxide (CO2)117 6,317 55,334,942 27,667
Nitrous Oxide (N2O)0.0002 0.0119 104 0.05
Methane (CH4)0.0022 0.1191 1,043 0.52
Individual Hazardous Air Pollutants (HAP) Emission Factor[2]
(lb/MMscf)
Potential Emission Rate
(lbs/hr)
Potential Emission Rate
(lbs/year)
Potential Emission Rate
(tons/year)
Benzene 0.0021 0.0001 0.9461 0.0005
Dichlorobenzene 0.0012 0.0001 0.5406 0.0003
Formaldehyde 0.0750 0.0039 33.7886 0.0169
Hexane 1.8000 0.0926 810.9257 0.4055
Lead Compounds 0.0005 0.0000 0.2253 0.0001
Naphthalene 0.0006 0.0000 0.2748 0.0001
Polycyclic Organic Matter (POM)0.0001 0.0000 0.0397 0.0000
Toluene 0.0034 0.0002 1.5317 0.0008
Arsenic Compounds (ASC)0.0002 0.0000 0.0901 0.0000
Beryllium Compounds (BEC)0.0000 0.0000 0.0054 0.0000
Cadmium Compounds (CDC)0.0011 0.0001 0.4956 0.0002
Chromium Compounds (CRC)0.0014 0.0001 0.6307 0.0003
Cobalt Compounds (COC)0.0001 0.0000 0.0378 0.0000
Manganese Compounds (MNC)0.0004 0.0000 0.1712 0.0001
Mercury Compounds (HGC)0.0003 0.0000 0.1171 0.0001
Nickel Compounds (NIC)0.0021 0.0001 0.9461 0.0005
Selenium Compounds (SEC)0.0000 0.0000 0.0108 0.0000
Total HAPs 1.8885 0.0971 850.7774 0.4254
[1]Emission Factors for PM based NSPS UUU requirements including process and combustion emissions. NSPS requires PM be no greater than 0.025 gr/dscf.
BACT suggests the lowest emission rate could 0.01 gr/dscf filterable particulates.
Given exhaust temperature stacks will approximately be 300 F, 0.01 gr/dscf equals 0.0070 gr/acf. [gr/acf = gr/dscf * ((460+70)/(460+300))]
[2]Emission Factor from AP-42 Tables 1.4 for Natural Gas Combustion (7/98). Conversion Factor: 1,050 MMBtu/MMscf.
[3]GHG emissions factors are from 40 CFR Part 98 Subpart C, Table C-1 and C-2. Conversion Factor: 1,050 MMBtu/MMscf.
* Nominal capacity of the 150 ton per hour sand is based upon elevation at the site and assuming sand enters the dryer with 5% moisture.
NOx emission rates adjusted by manufacturer for Honeywell's Megastar Burner, ~36 ppm, ~0.010 lb/ton, with FGR.
**Conservatively assumed that 100% of PM is to be filterable PM10/2.5.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

World Leader in Asphalt, Sand & Bulk Thermal
Drying Systems
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

SAND, AGGREGATE & BULK THERMAL DRYING SYSTEMS
Quote: SD-949 Date: 12/06/2019 Page: 2 of 9
CONTACT US AT: PHONE: [phone] FAX: [phone]
P.O. Box 2270 LEES SUMMIT, MO 64063
Email:[e-mail]
WEB SITE: www.tarmacinc.com
Mike Cina
Total Excavating LLC
141 State Road 35N
River Falls, WI 54022
Cell Mike: 715 821-1866
Main: 715-426-1777
Dear Mr. Cina:
Tarmac Int., Inc. is pleased to quote Honeywell s lowest NOx burner for Liquid Propane, the MegaStar Model 50
with FGR (Flue Gas Recirculation) unit. Comes with Variable frequency drive 50 hp blower motor. BCS7000
burner control system with plc.
Changes to your existing faceplate:
You will need the following
1. Add new Dryer Ring to the shell 30-7564
2. New burner faceplate wldt 30-7559
3. New seals 30-7561
4. New Burner support frame 30-7560
Installation: TBD
If you would like to purchase this equipment, please sign this page and return with down payment.
Sincerely,
Randy Nuttall
Account Manager
Cc: Ronald E. Heap - President
Tarmac Int., Inc.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

SAND, AGGREGATE & BULK THERMAL DRYING SYSTEMS
Quote: SD-949 Date: 12/06/2019 Page: 3 of 9
CONTACT US AT: PHONE: [phone] FAX: [phone]
P.O. Box 2270 LEES SUMMIT, MO 64063
Email: [e-mail]
WEB SITE: www.tarmacinc.com
Starjet
MegaStar
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

SAND, AGGREGATE & BULK THERMAL DRYING SYSTEMS
Quote: SD-949 Date: 12/06/2019 Page: 4 of 9
CONTACT US AT: PHONE: [phone] FAX: [phone]
P.O. Box 2270 LEES SUMMIT, MO 64063
Email: [e-mail]
WEB SITE: www.tarmacinc.com
Prices
ITEM QTY DESCRIPTION PRICE OPT
1 PKG MEGASTAR MODEL 50 WITH FGR (FLUE GAS
RECIRCULATION) UNIT 172,202
2 PKG FACEPLATE MODIFICATIONS 25,500
3 PKG INSTALLATION- TBD (Dryer Insulation will also need to
be cut back for new seal location)
Total Price Without Options $ 197,702

ESTIMATED DELIVERY IS 12 TO 14 WEEKS FROM RECEIPT OF DOWN PAYMENT AND SIGNED
ORDER. THIS QUOTATION IS SUBJECT TO THE ATTACHED TERMS AND CONDITIONS.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

SAND, AGGREGATE & BULK THERMAL DRYING SYSTEMS
Quote: SD-949 Date: 12/06/2019 Page: 5 of 9
CONTACT US AT: PHONE: [phone] FAX: [phone]
P.O. Box 2270 LEES SUMMIT, MO 64063
Email: [e-mail]
WEB SITE: www.tarmacinc.com
ADDITIONAL REQUIREMENTS BY CUSTOMER

1.
feed rate of material into the dryer
2. All state and local engineering approvals and certificates, permits for air emissions, construction, and other
local, state, and country permits for installation/operation of the plant
3. Local, state, or country taxes and duties
4. Freight costs from points of origin to shops and to Buyer
5. Site preparation, including support including concrete footings, piers, for equipment frames, design of all
concrete footings and piers. Tarmac to supply foundation locations with kip loadings
6. Equipment, cranes, man lifts, and general tools required for installation of equipment
7. Electrical power wire to the main disconnect of main breaker(s). Field wire for power, grounding, and
instruments. Cable tray, conduit, or piping above or below grade to support and shield field wire
8. Compressed air piping, fittings, and regulators from the air source to the equipment requiring compressed
air. Piping from pressure gauges to equipment
9. Local to the equipment electrical disconnects (stop controls at individual pieces of equipment) if required
10. Lubricating grease and oil for all bearings and reducers
11. Interconnecting fuel piping from source to fuel valve(s) of burner, regulator, block valve fuel trains for
main and pilot, propane tank for pilot fuel if propane fuel is used for pilot
12. Clean water at required pressure for any soil conditioner, venturi, quench, and scrubber(s)
13. Start-up/calibration service for: feed bin, screen deck, weigh conveyor, dryer burner, oxidizer burner, heat
exchanger, compressor, dryer, baghouse, bucket elevator, silos, truck scale, controls
14. Properly sized transformer from main power. Low voltage transformer(s). Sizing should be done by the
local power company or the generator supplier to include the motors for the plant, motor sequence starting,
across the line starters, soft starts, and VFDs
15. External main electrical disconnect outside the control house if locally required
16. Continuous Emission Monitoring Equipment on the stack.
17.
18. Any service or item not part of this contract
051817

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

SAND, AGGREGATE & BULK THERMAL DRYING SYSTEMS
Quote: SD-949 Date: 12/06/2019 Page: 6 of 9
CONTACT US AT: PHONE: [phone] FAX: [phone]
P.O. Box 2270 LEES SUMMIT, MO 64063
Email: [e-mail]
WEB SITE: www.tarmacinc.com
TERMS AND CONDITIONS
Payments: NEW EQUIPMENT: Twenty five percent (25%) of the total purchase price is to be paid by Buyer before Seller will commence
any work. Installment payment of twenty five percent (25%) will be paid when the equipment is twenty five percent (25%) complete, twenty
five percent (25%) will be paid when the equipment is fifty percent (50%) complete. The balance will be due on Tender of Delivery, when
ready to ship. USED EQUIPMENT: fifty percent (50%) of the total purchase price is to be paid by Buyer before Seller will commence
any work. Seller will invoice the Buyer fifty percent (50%) of the equipment purchase price and is due on receipt Interest will be charged
on overdue payments at the rate of 1.833% per month, if permitted by law, otherwise, at the highest lawful rate. If Buyer fails to make any
payments as agreed to, shows evidence of a changed financial condition, or, fails to perform any of its obligations, Seller may suspend its
performance, without prejudice to any claims for damages Seller may be entitled to make, until satisfactory terms, conditions and security
are received by Seller. In addition, Seller shall have such other rights and remedies as are provided herein and/or allowed to an aggrieved
Down payment(s) are not refundable.
2. Taxes. The amount of any present or future tax based on the sale, use, or contract price of the equipment covered hereunder shall be paid
by Buyer unless otherwise included in the sale price. Buyer shall indemnify and hold Seller harmless from any such tax, and any interest
and penalties thereon, and any claims, demands or legal proceedings (including the costs, expenses and reasonable attorney's fees incurred
in connection with the defense of any such matter). Seller shall also receive interest on the amount of taxes paid at the rate of 1.833% per
month if permitted by law, otherwise, at the highest lawful rate from the date of payment of the taxes by Seller to the date of Buyer's
reimbursement to Seller of these taxes.
3. Tender of Delivery and Shipment. The equipment is sold "F.O.B." place of shipment. Tender of delivery by Seller to Buyer shall occur
at the place of shipment when Seller gives Buyer notice that the equipment is complete. Seller is authorized to make the necessary
arrangements with a carrier for both the delivery of the equipment to the carrier and the transportation by the carrier to Buyer. Buyer shall
furnish notification reasonably necessary to enable the carrier to make proper delivery at the destination, and Buyer must furnish facilities
reasonably suited to the receipt of the equipment. Risk of loss and title to the equipment shall pass to Buyer upon tender of delivery by
Seller to the carrier at the place of shipment. Buyer shall bear the cost of shipment, unless otherwise agreed to in writing by Seller. Claims
on account of error or shortage will not be considered unless made immediately on receipt of shipment. The items of material as shown on
the invoice, packing list, and bill of lading shall govern settlements in all cases unless such notice of shortage is immediately reported to
both the agent of the delivering carrier and to Seller so that the alleged shortage can be verified.
4. Delays in Performance and Shipment. In addition to delays agreed to or caused by Buyer, Seller shall also be excused for delays in
performance which result, in whole or in part, from strikes, lockouts or other differences with employees or any cause beyond the control
of the Seller including, but not limited to, fire, earthquake, flood or windstorm, war, terrorism, riot, or embargoes, delays, losses or damages
in transportation, or shortage or delay in receipt of cars, fuel, labor or material. If any such event occurs, the time of completion shall be
extended accordingly. Buyer may, at its option, request a delay in the scheduled shipment date at no penalty provided the request is made
one hundred eighty (180) days prior to the scheduled shipment date. Should such a delay occur, Buyer shall pay for the balance of the sales
price when completed, irrespective of the shipment date. At Seller's sole option, the equipment may be stored at Buyer's risk and expense.
5. Security Interest and Default. Buyer hereby grants Seller a security interest in the equipment purchased and the proceeds thereof, which
shall continue until payment in full of the purchase price for such equipment, payment of any rental which may be charged for Buyer's use
of axles, fifth wheels and other equipment furnished by Seller to transport equipment purchased to its permanent site and payment and
performance by Buyer of all of its other obligations hereunder. Upon Buyer's default in making any such payment, or in the performance
of its other obligation hereunder, Seller shall have all of the rights and remedies of an aggrieved seller and of a secured party after default
under the Uniform Commercial Code (the "Code"), in addition to all other rights provided by the Agreement and by operation of law. Buyer
shall pay Seller, in addition to the interest on overdue payments specified in Paragraph 1 herein and all damages as allowed by law,
reasonable attorney's fees and other costs of Seller incurred in enforcing any of Seller's rights or remedies under the Agreement and the
Code. The equipment purchased shall remain personal property and shall not be considered a fixture or a part of any real estate on which
it may be located.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

SAND, AGGREGATE & BULK THERMAL DRYING SYSTEMS
Quote: SD-949 Date: 12/06/2019 Page: 7 of 9
CONTACT US AT: PHONE: [phone] FAX: [phone]
P.O. Box 2270 LEES SUMMIT, MO 64063
Email: [e-mail]
WEB SITE: www.tarmacinc.com
6. Transportation of Equipment. It shall be Buyer's responsibility to determine whether the equipment is intended for permanent installation,
or whether it is intended to remain portable. Regardless, Buyer shall also be responsible for compliance with all applicable transportation,
motor vehicle and safety laws. Buyer shall obtain any necessary licenses and/or permits and meet all federal, state, and local requirements.
ment is at Buyer's risk and Seller shall in no way be held responsible for damage,
site or from
job site to job site. Buyer shall indemnify and hold Seller harmless from all claims, demands or legal proceedings (including the expenses
and reasonable attorney's fees incurred in connection therewith) which may be made or brought against Seller in connection with Buyer's
failure to com
7. Warranties. Seller warrants to the original Buyer that all new equipment and material manufactured or designed by it shall be free from
material defects in design and fabrication for a period of one (1) year from date of shipment. All new equipment, components thereof and
material not manufactured or designed by Seller shall carry only such warranty, if any, as is expressly given by the manufacturer or designer
thereof. Seller makes no other express warranty. No express warranty given shall extend beyond the original Buyer. The foregoing express
warranties are given in lieu of all other warranties, including any implied warranty of merchantability and/or fitness for a particular
purpose, which are expressly disclaimed. There are no warranties, which extend beyond the description on the face hereof. Seller
shall not be liable for damages caused by abrasion, corrosion, excessive temperature, condensation of moisture, chemical attack, fire,
explosion, improper operation contrary to the instruction given by Seller or other manufacturer, insufficient maintenance, circumstances
beyond the control of Seller or operation of the equipment under substantially different conditions than those anticipated by Seller or stated
in the specifications.
8. Limitations of Remedies. Buyer's sole and exclusive remedy for breach of any warranty or any other obligation of Seller related to the
sale of equipment hereunder shall be the right to require Seller to repair or replace the defective equipment. Buyer shall be responsible for
disassembling and returning any defective equipment to a place to be designated by Seller for such repair or replacement. In the event that
r sole and exclusive
remedy shall be the right to recover the amount paid to Seller for the defective equipment, less any prior warranty allowance given and the
reasonable value of any use made of the equipment by Buyer. The defective equipment must first be returned to the control of Seller, at
Buyer's cost, and any resale of the same by Seller can be done without notice to Buyer. Before any breach or warranty claim can be made
by Buyer, timely written notice specifying the particulars of the claimed defect or breach must be promptly given by Buyer to Seller within
sixty (60) days of Buyer's discovery or constructive knowledge of the same, whichever comes first. Failure to do so shall be deemed a
waiver of the claim. Under no circumstance shall Buyer be entitled to any incidental or consequential damages. Any warranty allowance
given by Seller to Buyer for any necessary and reasonable repairs or alterations to the equipment by Buyer within the warranty period shall

9. Used Equipment. If the equipment sold by Seller to Buyer is used, such equipment (even if refurbished) is sold "as is wh
representation or warranty of any kind. If the transaction involves trade-in equipment, Buyer represents and warrants that any such
equipment is wholly and individually owned by Buyer; that the equipment is free and clear of all liens and encumbrances; and that Buyer
has the right to and does hereby convey all its right, title, and interest in the same to Seller. Delivery, transportation and receipt of such
equipment shall be mutually agreed to by the parties in writing. Final payment is due on invoice. Failure to make final payment within
seven (7) business days of receipt of invoice will cause cancellation of the order and loss of any down payment given to Seller.
10. Installation. Buyer shall be solely responsible, at its expense, for the proper installation and erection of the equipment purchased, unless
drawings to
aid Buyer with installation or support of the equipment, Seller expressly disclaims any warranties with respect to such installation and
support. Buyer shall indemnify, defend and hold Seller harmless from all claims, demands or legal proceedings (including the expenses
and reasonable attorney's fees incurred in connection therewith) which may be made or brought against Seller in connection with damage
or personal injury arising out of improper installation, erection, start-up, or operation of the equipment.
11. Cancellation. NEW EQUIPMENT: If Buyer desires to cancel its order prior to shipment, it may do so but only with the prior written
consent of Seller. No such conditional cancellation will be considered by Seller unless Buyer agrees to first pay to Seller: a cancellation
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

SAND, AGGREGATE & BULK THERMAL DRYING SYSTEMS
Quote: SD-949 Date: 12/06/2019 Page: 8 of 9
CONTACT US AT: PHONE: [phone] FAX: [phone]
P.O. Box 2270 LEES SUMMIT, MO 64063
Email: [e-mail]
WEB SITE: www.tarmacinc.com
fee equal to no less than 20% of the full purchase price, a fee for all engineering completed (at $75.00 per hour), a fee equal to all parts
purchased and a fee equal to the percentage of the completed equipment up to the date of the conditional cancellation. In addition, Buyer
must agree to abandon any down payments. USED EQUIPMENT: If the Buyer desires to cancel its order prior to tender of delivery, it
may do so but only with the prior written consent of Seller. No such conditional cancellation will be considered by Seller unless Buyer
agrees to first pay to Seller: a cancellation fee in cash equal to no less than 20% of the full purchase price, a fee to cover the cost of any
refurbishment to the equipment, a fee for all engineering work completed (at $75.00 per hour), a fee equal to all parts purchased, and a fee
equal to the percentage of any equipment refurbishment completed up to the date of the conditional cancellation. In addition, Buyer must
agree to abandon any down payments. No cancellation of an order for new or used equipment will be considered after tender of delivery by
Seller.
12. Integration and Assignment. The final written proposal or bid of Seller, these Terms and Conditions, any separate written warranty
given by an authorized representative of Seller a
made in or by
s, any prior dealings between the parties or any representation by any agent, employee or representative of
Seller which is not contained in any of the above-referenced documents shall not supplement or explain, nor shall it be considered a part of
the Agreement. The Buyer may not assign any of its rights or obligations under the Agreement without the prior written consent of Seller
13. Acceptance, Applicable Law and Modification. deemed
accepted by Buyer and shall be the Agreement between the parties upon receipt by Seller of a down payment from Buyer. Any term or
condition submitted by Buyer to Seller (whether in a solicitation for bids, acceptance or in a purchase order) which is in addition to or
me a part of
the Agreement unless such term or condition is agreed to in writing by Seller. The Agreement shall be governed by Missouri law. Any
modified
only by a writing signed by Buyer and Seller.
s proposal or bid, any financial or business information about Seller, and all technical information, data,
specifications, plans, designs, drawings, know-
proprietary infor y
and to take reasonable precautions against disclosure of said Information to third parties. Buyer further agrees that the Information shall be
performance
of the Agreement. Any other use of the Information is prohibited.
15. Arbitration of Disputes. Any controversy or claim arising out of or relating to this Agreement shall be settled by arbitration in Kansas
City, Missouri in accordance with the Commercial Arbitration Rules of the American Arbitration Association. In any such arbitration the
arbitrator(s) must follow the law. Judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction
thereof. THIS AGREEMENT CONTAINS A BINDING ARBITRATION PROVISION WHICH MAY BE ENFORCED BY THE
PARTIES.

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
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Previous Page
COMPREHENSIVE REPORT
Report Date:12/16/2019
Facility Information
RBLC ID:WI-0161 (final) Date Determination
Last Updated:07/28/2003
Corporate/Company Name:AARROW CAST Permit Number:96SDD050
Facility Name:AARROW CAST Permit Date:10/01/1998 (actual)
Facility Contact:MICHAEL JENSEN FRS Number:110000421197
Facility Description: SIC Code:3322
Permit Type:D: Both B (Add new process to existing facility) &C (Modify process at existing
facility) NAICS Code:459005
Permit URL:
EPA Region:5 COUNTRY:USA
Facility County:SHAWANO
Facility State:WI
Facility ZIP Code:54166
Permit Issued By:WISCONSIN DEPT OF NATURAL RESOURCES; AIR MGMT. PROGRAM (Agency Name)
MS. KRISTIN HART(Agency Contact) [phone] [e-mail]
Other Agency Contact Info:STEVEN D DUNN
WI
608-267-0566
Permit Notes:START UP AND COMPLIANCE DaTES NOT AVAILABLE.

Process/Pollutant Information
PROCESS
NAME:
COLD BOX CORE, AMINE GASSING, P03, S03
Process Type: 81.440 (Sand, Core & Mold Making Processes)
Primary Fuel:
Throughput:
Process Notes: AMINE GASSING OF URETHANE cold box core
POLLUTANT NAME:Volatile Organic Compounds (VOC)
CAS Number:VOC
Test Method:Unspecified
Pollutant Group(s):( Volatile Organic Compounds (VOC) )
Emission Limit 1:98.0000 % REDUCTION amine gassing step
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(A) WET SCRUBBER
Est. % Efficiency:98.000
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:BACT FOR THE CORE MANUFACTURING PROCESS HAS BEEN DETERMINED TO BE 98% CONTROL
OF AMINE GAS EMISSIONS FROM THE AMINE GASSING STEP IN THE MANUFACTURE OF
URETHANE COLD BOX CORES.

Process/Pollutant Information
PROCESS
NAME:
CORE MANUFACTURING, P11, S06
Process Type: 81.440 (Sand, Core & Mold Making Processes)
Primary Fuel:
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Throughput:
Process Notes:
POLLUTANT NAME:Volatile Organic Compounds (VOC)
CAS Number:VOC
Test Method:Unspecified
Pollutant Group(s):( Volatile Organic Compounds (VOC) )
Emission Limit 1: See POLLUTANT Note
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(N)
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:BACT FOR THIS PORTION OF THE CORE MANUFACTURING PROCESS IS NO CONTROL. NO
EMISSION LIMITS PROVIDED.

Process/Pollutant Information
PROCESS
NAME:
CORE WASH OVEN, S07
Process Type: 13.300 (Gaseous Fuel & Gaseous Fuel Mixtures (¿100 million BTU/H))
Primary Fuel: NATURAL GAS
Throughput: 10.00 MMBTU/H
Process Notes: Limit required for PM and VE only
POLLUTANT NAME:Particulate Matter (PM)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.1500 LB/MMBTU
Emission Limit 2:
Standard Emission:0.1500 LB/MMBTU
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(P) BACT FOR THIS PROCESS IS THE COMBUSTION OF NATURAL GAS.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Visible Emissions (VE)
CAS Number:VE
Test Method:Unspecified
Pollutant Group(s):
Emission Limit 1:20.0000 % OPACITY
Emission Limit 2:
Standard Emission:20.0000 % OPACITY
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(P) BACT FOR THIS PROCESS IS COMBUSTION OF NATURAL GAS
Est. % Efficiency:
Cost Effectiveness:0 $/ton
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
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Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS
NAME:
SAND DRYER, P08, S08
Process Type: 90.024 (Non-metallic Mineral Processing (except 90.011, 90.019, 90.017, 90.026))
Primary Fuel:
Throughput:
Process Notes: BACT for PM and VE only.
POLLUTANT NAME:Particulate Matter (PM)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.0980 LB/H
Emission Limit 2:0.0002 LB/LB LB PM / LB GAS
Standard Emission: NOT AVAILABLE
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(A) BIN VENT COLLECTOR.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:Limits in gr/dscf not available. BACT FOR THIS PROCESS IS DETERMINED TO BE A PM EMISSION
RATE OF 0.098 LB/H COMPLIANCE WITH THE EMISSION LIMIT IS DEMONSTRATED THROUGH
PROPER OPERATION OF THE VENT COLLECTOR.

POLLUTANT NAME:Visible Emissions (VE)
CAS Number:VE
Test Method:Unspecified
Pollutant Group(s):
Emission Limit 1:20.0000 % OPACITY
Emission Limit 2:
Standard Emission:20.0000 % OPACITY
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(A) BIN VENT COLLECTOR
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS
NAME:
SAND STORAGE SILOS -P20, S20A & P20, S20B
Process Type: 90.024 (Non-metallic Mineral Processing (except 90.011, 90.019, 90.017, 90.026))
Primary Fuel:
Throughput:
Process Notes:
POLLUTANT NAME:Particulate Matter (PM)
CAS Number:PM
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Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.1000 LB/H
Emission Limit 2:0.0002 LB/LB lb PM/ lb gas
Standard Emission: NOT AVAILABLE
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(A) BIN VENT COLLECTOR
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:No other emission limits available. BACT FOR THIS PROCESS HAS BEEN DETERMINED TO BE A
PARTICULATE EMISSION RATE OF 0.1 LB/H BY MANUFACTURING & OPERATING A BIN VENT
COLLECTOR ON THE OUTLET OF THIS PROCESS.

POLLUTANT NAME:Visible Emissions (VE)
CAS Number:VE
Test Method:Unspecified
Pollutant Group(s):
Emission Limit 1:20.0000 % OPACITY
Emission Limit 2:
Standard Emission:20.0000 % OPACITY
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(A) BIN VENT COLLECTOR
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS
NAME:
SAND HANDLING, P22, S22
Process Type: 90.024 (Non-metallic Mineral Processing (except 90.011, 90.019, 90.017, 90.026))
Primary Fuel:
Throughput:
Process Notes:
POLLUTANT NAME:Particulate Matter (PM)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.0050 GR/DSCF
Emission Limit 2:7.9300 LB/H
Standard Emission:0.0050 GR/DSCF
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(A) BAG HOUSE
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
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POLLUTANT NAME:Visible Emissions (VE)
CAS Number:VE
Test Method:Unspecified
Pollutant Group(s):
Emission Limit 1:20.0000 % OPACITY
Emission Limit 2:
Standard Emission:20.0000 % OPACITY
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(A) BAGHOUSE
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS
NAME:
MOLD RELEASE AGENT & MOLD COATING APPL, P23, S23
Process Type: 81.440 (Sand, Core & Mold Making Processes)
Primary Fuel:
Throughput:
Process Notes: BACT and LACT for this process is limit on usage and VOC content of mold release and mold coating compounds. No emission rate limits were
defined.
POLLUTANT NAME:Volatile Organic Compounds (VOC)
CAS Number:VOC
Test Method:Unspecified
Pollutant Group(s):( Volatile Organic Compounds (VOC) )
Emission Limit 1: See POLLUTANT Note
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(P) BACT AND LACT IS NO ADD-ON CONTROL, USAGE OF MOLD COATING AND RELEASE IS
LIMITED TO NO MORE THAN 20,000 LB/MO; AND COMPOUNDS SHALL CONTAIN NO MORE THAN
60% VOC BY WT.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:BACT AND LACT IS NO ADD-ON CONTROL, USAGE OF MOLD COATING AND RELEASE IS
LIMITED TO NO MORE THAN 20,000 LB/MO; AND COMPOUNDS SHALL CONTAIN NO MORE THAN
60% VOC BY WT.

Process/Pollutant Information
PROCESS
NAME:
POURING, COOLING AND SHAKE OUT, P25 & P26, S22
Process Type: 81.450 (Casting & Pouring Processes)
Primary Fuel:
Throughput: 15.00 T/H
Process Notes:
POLLUTANT NAME:Particulate Matter (PM)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
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Emission Limit 1:0.0500 GR/ACF
Emission Limit 2:7.7100 LB/H
Standard Emission:0.0500 GR/DSCF
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(N) BAGHOUSE.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Formaldehyde
CAS Number:50-00-0
Test Method:Unspecified
Pollutant Group(s):( Hazardous Air Pollutants (HAP) , Organic Compounds (all) , Volatile Organic Compounds (VOC) )
Emission Limit 1:0.1400 LB/H
Emission Limit 2:93.0000 LB/MO
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) BACT IS SAND SYSTEM OPTIMIZATION, DEFINED AS REDUCTION OF ORGANIC EMISSIONS
TO THE GREATEST EXTENT POSSIBLE.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Carbon Monoxide
CAS Number:630-08-0
Test Method:Unspecified
Pollutant Group(s):( InOrganic Compounds )
Emission Limit 1:5.0000 LB/T of metal
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) SAND SYSTEM OPTIMIZATION
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Benzene
CAS Number:71-43-2
Test Method:Unspecified
Pollutant Group(s):( Hazardous Air Pollutants (HAP) , Organic Compounds (all) , Organic Non-HAP Compounds , Volatile Organic
Compounds (VOC) )
Emission Limit 1:2.7000 LB/H
Emission Limit 2:1620.0000 LB/MO
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
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Control Method:(P) BACT FOR THIS PROCESS IS THE SAND SYSTEM OPTIMIZATION - DEFINED AS THE
REDUCTION OF ORGANIC EMISSIONS, TO THE GREATEST EXTENT POSSIBLE.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Volatile Organic Compounds (VOC)
CAS Number:VOC
Test Method:Unspecified
Pollutant Group(s):( Volatile Organic Compounds (VOC) )
Emission Limit 1:2.2000 LB/T for p26
Emission Limit 2:0.3500 LB/T for p25
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) BACT IS SAND SYSTEM OPTIMIZATION, DEFINED AS REDUCTION OF ORGANIC EMISSIONS
TO THE GREATEST EXTENT POSSIBLE.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Visible Emissions (VE)
CAS Number:VE
Test Method:Unspecified
Pollutant Group(s):
Emission Limit 1:20.0000 % OPACITY
Emission Limit 2:
Standard Emission:20.0000 % OPACITY
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(A) BAGHOUSE
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS
NAME:
ELECTRIC INDUCTION FURNACES, P24, S24 (6)
Process Type: 81.420 (Induction Furnaces)
Primary Fuel:
Throughput:
Process Notes: Limits for PM and VE only. This process represents two stacks which vent the exisitng nine tons of melt capacity and the "new" nine tons of melt
capacity
POLLUTANT NAME:Particulate Matter (PM)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.0100 GR/CF
Emission Limit 2:8.5700 LB/H
Standard Emission:0.0100 GR/DSCF
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Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(A) BAGHOUSE
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Visible Emissions (VE)
CAS Number:VE
Test Method:Unspecified
Pollutant Group(s):
Emission Limit 1:20.0000 % OPACITY
Emission Limit 2:
Standard Emission:20.0000 % OPACITY
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:BACT-PSD
Other Applicable Requirements:
Control Method:(A) BAGHOUSE
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS
NAME:
EXISTING SAND HANDLING & SHAKEOUT, P32, P36, S12
Process Type: 81.460 (Shake Out Processes)
Primary Fuel:
Throughput:
Process Notes:
POLLUTANT NAME:Benzene
CAS Number:71-43-2
Test Method:Unspecified
Pollutant Group(s):( Hazardous Air Pollutants (HAP) , Organic Compounds (all) , Organic Non-HAP Compounds , Volatile Organic
Compounds (VOC) )
Emission Limit 1:1.8000 LB/H
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) PROCESS RELATED CHANGES: SAND SYSTEM AND CORE REFORMULATIONS, SAND SYSTEM
PRACTICES AND OXIDATION ENHANCEMENT.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:Additional limits: 11,107 lb/yr and 925 lb/mo.

POLLUTANT NAME:Formaldehyde
CAS Number:50-00-0
Test Method:Unspecified
Pollutant Group(s):( Hazardous Air Pollutants (HAP) , Organic Compounds (all) , Volatile Organic Compounds (VOC) )
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Emission Limit 1: see notes
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) PROCESS RELATED CHANGES: SAND SYSTEM AND CORE REFORMULATIONS, SAND SYSTEM
PRACTICES AND OXIDATION ENHANCEMENT.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:BACT is controls. No emission rate limits defined.

POLLUTANT NAME:Visible Emissions (VE)
CAS Number:VE
Test Method:Unspecified
Pollutant Group(s):
Emission Limit 1:20.0000 % OPACITY
Emission Limit 2:
Standard Emission:20.0000 % OPACITY
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(A) BAGHOUSE
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Volatile Organic Compounds (VOC)
CAS Number:VOC
Test Method:Unspecified
Pollutant Group(s):( Volatile Organic Compounds (VOC) )
Emission Limit 1:2.2000 LB/T
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) LIMIT ON AMOUNT OF METAL POURED.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Particulate Matter (PM)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:3.5000 LB/H
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(A) BAGHOUSE
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
12/16/2019 Format RBLC Report
https://cfpub.epa.gov/rblc/index.cfm?action=Reports.ReportComprehensiveReport&ReportFormat=txt 10/10
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:Limit is defined in lb/h. Standardized emission limit unit is not available.

Previous Page
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
12/16/2019 Format RBLC Report
https://cfpub.epa.gov/rblc/index.cfm?action=Reports.ReportComprehensiveReport&ReportFormat=txt 1/5
Previous Page
COMPREHENSIVE REPORT
Report Date:12/16/2019
Facility Information
RBLC ID:OR-0042 (final) Date Determination
Last Updated:05/14/2004
Corporate/Company Name:Eagle-Picher Filtration & Minerals, Inc. Permit Number:23-0007
Facility Name:EAGLE- PICHER VALE, OREGON PLANT Permit Date:05/23/2003 (actual)
Facility Contact:LITA HUMPHREYS 775-824-
7603 [e-mail] FRS Number:
Facility Description:THIS PLANT IS A DIATOMACEOUS EARTH PROCESSING PLANT. RAW
ORE IS TRUCKED FROM THE MINE AND IS CRUSHED, MILLED, AND
CLASSIFIED. SODA ASH IS THEN ADDED TO THE ORE AND THE
MIXTURE IS FED INTO A KILN FOR CALCINING. THE CALCINED
MATERIAL IS THEN CRUSHED AND CLASSIFIED INTO VARIOUS FILTER
AID PRODUCTS.
SIC Code:1481
Permit Type:A: New/Greenfield Facility NAICS Code:213115
Permit URL:
EPA Region:10 COUNTRY:USA
Facility County:MALHEUR
Facility State:OR
Facility ZIP Code:89510
Permit Issued By:OREGON DEPT OF ENVIRONMENTAL QUALITY (Agency Name)
JILL INAHARA(Agency Contact) [phone] [e-mail]
Other Agency Contact Info:PETER BREWER
OR
[phone]
Permit Notes:
Affected Boundaries:Boundary Type:Class 1 Area State:Boundary:Distance:
CLASS1 OR Eagle Cap 100km - 50km
CLASS1 ID Hells Canyon 100km - 50km
CLASS1 ID Sawtooth 100km - 50km
CLASS1 OR Strawberry Mountain 100km - 50km
Facility-wide Emissions:Pollutant Name:Facility-wide Emissions Increase:
Carbon Monoxide 151.0000 (Tons/Year)
Nitrogen Oxides (NOx)61.0000 (Tons/Year)
Particulate Matter (PM)54.0000 (Tons/Year)
Sulfur Oxides (SOx)323.0000 (Tons/Year)
Volatile Organic Compounds (VOC)39.0000 (Tons/Year)

Process/Pollutant Information
PROCESS
NAME:
DRYER 1/CALCINER 1
Process Type: 90.024 (Non-metallic Mineral Processing (except 90.011, 90.019, 90.017, 90.026))
Primary Fuel: NATURAL GAS
Throughput: 2990400.00 LB/WK
Process Notes: Throughput is DRY LBS/WEEK OF ORE
POLLUTANT NAME:Visible Emissions (VE)
CAS Number:VE
Test Method:Unspecified
Pollutant Group(s):
Emission Limit 1:20.0000 % OPACITY
Emission Limit 2:
Standard Emission:20.0000 % OPACITY
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:N/A
Other Applicable Requirements:SIP
Control Method:(A) BAUMCO MODEL 2-5116-4.510P PULSE-JET BAGHOUSE, AIR TO CLOTH RATIO IS 1.7:1
Est. % Efficiency:
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
12/16/2019 Format RBLC Report
https://cfpub.epa.gov/rblc/index.cfm?action=Reports.ReportComprehensiveReport&ReportFormat=txt 2/5
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

POLLUTANT NAME:Nitrogen Oxides (NOx)
CAS Number:10102
Test Method:Unspecified
Pollutant Group(s):( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1:6.6000 LB/H 3-hr average
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) GOOD COMBUSTION CONTROL
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

POLLUTANT NAME:Carbon Monoxide
CAS Number:630-08-0
Test Method:Unspecified
Pollutant Group(s):( InOrganic Compounds )
Emission Limit 1:19.7000 LB/H 3-hour average
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) GOOD COMBUSTION CONTROL
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

POLLUTANT NAME:Particulate Matter (PM)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.1000 GR/DSCF
Emission Limit 2:
Standard Emission:0.1000 GR/DSCF
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:N/A
Other Applicable Requirements:SIP
Control Method:(A) BAUMCO MODEL 2-5116-4.510P PULSE-JET BAGHOUSE, AIR TO CLOTH RATIO IS 1.7:1
Est. % Efficiency:98.000
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

POLLUTANT NAME:Sulfur Dioxide (SO2)
CAS Number:7446-09-5
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
12/16/2019 Format RBLC Report
https://cfpub.epa.gov/rblc/index.cfm?action=Reports.ReportComprehensiveReport&ReportFormat=txt 3/5
Test Method:Unspecified
Pollutant Group(s):( InOrganic Compounds , Oxides of Sulfur (SOx) )
Emission Limit 1:60.0000 % REDUCTION
Emission Limit 2:5.6000 LB/T LB SO2/TON PRODUCT, 28-day average
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) OXIDIZED, LOW SULFUR ORES CAN BE OBTAINED BY SELECTIVE MINING OF THE UPPER
STRATA OF THE DEPOSITS. SULFUR IS PRESENT IN RAW DE ORES AT VARYING LEVELS
DEPENDING ON THE PARTICULAR GEOLOGIC FORMATION.
Est. % Efficiency:60.000
Cost Effectiveness:254 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS
NAME:
DRYER 2/CALCINER 2
Process Type: 90.024 (Non-metallic Mineral Processing (except 90.011, 90.019, 90.017, 90.026))
Primary Fuel: NATURAL GAS
Throughput: 3124800.00 LB/WK
Process Notes: throughput is DRY LBS/WEEK ORE
POLLUTANT NAME:Particulate matter, filterable (FPM)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.0400 GR/DSCF
Emission Limit 2:
Standard Emission:0.0400 GR/DSCF
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:N/A
Other Applicable Requirements:NSPS
Control Method:(A) BAGHOUSE
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

POLLUTANT NAME:Visible Emissions (VE)
CAS Number:VE
Test Method:Unspecified
Pollutant Group(s):
Emission Limit 1:10.0000 % OPACITY NSPS
Emission Limit 2:20.0000 % OPACITY SIP
Standard Emission:10.0000 % OPACITY
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:N/A
Other Applicable Requirements:NSPS
Control Method:(A) FABRIC FILTER MODEL 289-10 PULSE-JET BAGHOUSE WITH AIR TO CLOTH RATIO OF 2:1
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:Two opacity limits: 20% for PM SIP, 10% for PM filterable NSPS

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
12/16/2019 Format RBLC Report
https://cfpub.epa.gov/rblc/index.cfm?action=Reports.ReportComprehensiveReport&ReportFormat=txt 4/5
POLLUTANT NAME:Particulate Matter (PM)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.1000 GR/DSCF
Emission Limit 2:
Standard Emission:0.1000 GR/DSCF
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:N/A
Other Applicable Requirements:SIP
Control Method:(A) FABRIC FILTER MODEL 289-10 PULSE-JET BAGHOUSE WITH AIR TO CLOTH RATIO OF 2.0:1
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

POLLUTANT NAME:Nitrogen Oxides (NOx)
CAS Number:10102
Test Method:Unspecified
Pollutant Group(s):( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1:7.1000 LB/H 3-hour average
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) GOOD COMBUSTION PRACTICES
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

POLLUTANT NAME:Carbon Monoxide
CAS Number:630-08-0
Test Method:Unspecified
Pollutant Group(s):( InOrganic Compounds )
Emission Limit 1:21.4000 LB/H
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) GOOD COMBUSTION PRACTICES
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

POLLUTANT NAME:Sulfur Dioxide (SO2)
CAS Number:7446-09-5
Test Method:Unspecified
Pollutant Group(s):( InOrganic Compounds , Oxides of Sulfur (SOx) )
Emission Limit 1:60.0000 %SO2 REDUCTION
Emission Limit 2:5.6000 LB/T PRODUCT SO2
Standard Emission:
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
12/16/2019 Format RBLC Report
https://cfpub.epa.gov/rblc/index.cfm?action=Reports.ReportComprehensiveReport&ReportFormat=txt 5/5
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:Other Case-by-Case
Other Applicable Requirements:
Control Method:(P) OXIDIZED, LOW SULFUR ORES CAN BE OBTAINED BY SELECTIVE MINING THE UPPER
STRATA OF THE DEPOSITS. SULFUR IS PRESENT IN RAW DE ORES AT VARYING LEVELS
DEPENDING ON THE PARTICULAR GEOLOGIC FORMATION PROCESS
Est. % Efficiency:60.000
Cost Effectiveness:254 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Yes
Pollutant/Compliance Notes:

Previous Page
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
12/16/2019 Format RBLC Report
https://cfpub.epa.gov/rblc/index.cfm?action=Reports.ReportComprehensiveReport&ReportFormat=txt 1/2
Previous Page
COMPREHENSIVE REPORT
Report Date:12/16/2019
Facility Information
RBLC ID:CA-0729 (final) Date Determination
Last Updated:12/18/2001
Corporate/Company Name:BASALITE BLOCK Permit Number:N-1051-13-0
Facility Name:BASALITE BLOCK Permit Date:06/21/1996 (actual)
Facility Contact: FRS Number:110017403282
Facility Description: SIC Code:3271
Permit Type:U: Unspecified NAICS Code:
Permit URL:
EPA Region:9 COUNTRY:USA
Facility County:
Facility State:CA
Facility ZIP Code:
Permit Issued By:SAN JOAQUIN VALLEY APCD - CENTRAL REGIONAL OFFICE, CA (Agency Name)
Other Agency Contact Info:SEYED SADREDIN
CA
[phone]
Permit Notes:CAPCOA BACT CLEARINGHOUSE NO. A370-737-97

Process/Pollutant Information
PROCESS
NAME:
SAND DRIER
Process Type: 90.024 (Non-metallic Mineral Processing (except 90.011, 90.019, 90.017, 90.026))
Primary Fuel: NATURAL GAS
Throughput: 18.00 MMBTU/H
Process Notes: CARMAN INDUSTRIES MODEL FBP-1102HT
POLLUTANT NAME:Particulate matter, filterable < 10 µ (FPM10)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.0085 LB/TON
Emission Limit 2:6.8000 LB/DAY
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:LAER
Other Applicable Requirements:
Control Method:(A) BAGHOUSE WITH FABRIC FILTERS. FABRIC FILTERS MODEL462-12.
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME:Nitrogen Oxides (NOx)
CAS Number:10102
Test Method:Unspecified
Pollutant Group(s):( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1:0.1000 LB/MMBTU
Emission Limit 2:39.9000 LB/DAY
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:LAER
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
12/16/2019 Format RBLC Report
https://cfpub.epa.gov/rblc/index.cfm?action=Reports.ReportComprehensiveReport&ReportFormat=txt 2/2
Other Applicable Requirements:
Control Method:(P) NATURAL GAS FIRING
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS
NAME:
DRY MIX CONCRETE/CEMENT BAGGING MACHINE
Process Type: 90.006 (Cement Manufacturing (except 90.028))
Primary Fuel:
Throughput: 1292.00 TONS/HR
Process Notes: CAPCOA BACT CLEARINGHOUSE NO. A390-738-97
POLLUTANT NAME:Particulate matter, filterable < 10 µ (FPM10)
CAS Number:PM
Test Method:Unspecified
Pollutant Group(s):( Particulate Matter (PM) )
Emission Limit 1:0.0052 LB/TON
Emission Limit 2:6.7000 LB/DAY
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis:LAER
Other Applicable Requirements:
Control Method:(A) MIKRO PUL MODEL 90-8 BAGHOUSE WITH FABRIC FILTERS
Est. % Efficiency:
Cost Effectiveness:0 $/ton
Incremental Cost Effectiveness:0 $/ton
Compliance Verified:Unknown
Pollutant/Compliance Notes:

Previous Page
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

SAND, AGGREGATE & BULK THERMAL DRYING SYSTEMS
Quote: SD-949 Date: 12/06/2019 Page: 9 of 9
CONTACT US AT: PHONE: [phone] FAX: [phone]
P.O. Box 2270 LEES SUMMIT, MO 64063
Email: [e-mail]
WEB SITE: www.tarmacinc.com
Signature Page
__________________________________________/_________________
Ronald E. Heap Date
Position: President
Tarmac International, Inc.
Seller
__________________________________________/_________________
_____________________ Date
Position: _____________
Company: ______________________________
Buyer
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Tarmac International Inc. SERVICE ESTIMATE
Customer Date
Mobile Estimate #
Office Contact
Email Mobile
Company Job Reference
Qty
2 2,500$
2 400$
3 2,250$
3 150$
3 375$
0 -$
Mileage Out 498 279$
Mileage Back 817 458$
Flight (est.)0 -$
0 6,875$
Date
/ /
Description of Pricing - Tarmac Technician
Workday estimate given is based on a 10 to 12-hour day at the job site
Includes tools, jacks, fixtures, and consumables necessary to accomplish intended work.
Travel day cost is for driving or flying.
Meals & miscellaneous expenses
Lodging is billed at cost (estimate given)
Car rental is billed at cost (estimate given)
IRS standard mileage rate. Applicable only if Tarmac drives to the job site.
Flight is billed at cost (estimate given)
Note:
down
running
All utilities will be required for full commissioning.Note:
Align trunnions
Travel days
Daily car rental & fuel
125.00$
Daily rate - support equip.200.00$
This estimate does not include rental equipment such as telehandlers or manlifts, or replacement parts.
Signed Acceptance or Purchase Order:
125.00$
Daily per diem
650.00$ Flight (est.)
Mileage
750.00$
1,250.00$
0.560$
Daily lodging (est.)
Address XXX XXX XXX
Wright, WY 82732
Estimated Total
Car rental & fuel (est.)
Tarmac tech travel in from Utah
Tentative service plan:
3-Jun Inspect burner installation, check safeties,
check gas train.
Burner tech travel to Wyoming
4-Jun Commission burner.
4-Jun
5-Jun
--Intentionally left blank--
6-Jun
052721 Total Excavating Wright, WY
Todd Murchison
651.304.0345
Total Excavating
5/28/21
50.00$
Notes:
3)--Intentionally left blank--
2)
Burner commissioning and tunning including checking safeties, ensuring correct piping, starting & testing, and final checks with material.
1)
Zero & align the trunnions on customers dryer.
Reason(s) for service request
Chris Kuselek
715-760-1708
[e-mail]
Plant Status
Daily travel rate
Daily working rate
Per diem days
Lodging (est.)
13,286$
Title
NA
2-Jun NATarmac technician
Burner tech - all in
Support equipment
down
Extra day included in schedule for
contingency. Will not bill for if not used.NA
5/28/2021
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

MANUFACTURER SPECIFICATION SHEETS

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
EPA Certified / Stationary Emergency
OUTPUT POWER OPTIONS Natural Gas
STANDBY RATING
LP Vapor
STANDBY RATING
sKVA
Make Voltage Alternator Phase Hertz kW/kVA Amps kW/kVA Amps 30%VoltageDip
Stamford 600 HCI534C17 3 60 400/500 482 295/396 355 1360
277/480 HCI534C311 3 60 400/500 602 295/369 444 1480
120/208 HCI534C311 3 60 400/500 1390 295/369 1025 1145
120/240 HCI534C311 3 60 400/500 1204 295/369 888 1145
120/240 HCI534C311 1 60 210/210 875 210/210 875 765
Stamford 277/480 HCI534D311 3 60 400/500 602 295/369 444 1750
120/208 HCI534D311 3 60 400/500 1390 295/369 1025 1390
120/240 HCI534D311 3 60 400/500 1204 295/369 888 1390
120/240 HCI534D311 1 60 230/230 958 230/230 958 930
Marathon 600 433PSL6248 3 60 400/500 482 295/369 355 1380
277/480 433CSL6220 3 60 400/500 602 295/369 444 1469
120/208 433CSL6220 3 60 400/500 1390 295/369 1025 1103
120/240 433CSL6220 3 60 400/500 1204 295/369 888 1103
120/240 433CSL6220 1 60 241/241 1004 241/241 1004 430
947 Industrial Park Drive • Clinton, MS 39056 • Phone [phone] • Fax [phone] • www.taylorpower.com
TG400DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
application and engineering data
®
Engine Data
Manufacturer PSI
Model 21.9L
Aspiration Turbocharged
Arrangement V-12, 4-Cycle
Firing Order 1-12-5-8-3-10-6-7-2-11-4-9
Displacement: L (in.³)21.9 (1338.0)
Bore: mm (in.)128.00 (5.04)
Stroke: mm (in.)142.00 (5.59)
Compression Ratio 10.5:1
Gross Horsepower: Natural Gas
LP Vapor
684
472
BMEP: psi (kPa) Natural Gas
LP Vapor
225.00 (1551.32)
155.00 (1068.70)
Rated RPM 1800
Governor Isochronous
Speed Regulation ±0.50%
Engine Liquid Capacity
Oil System: qt. (L)38.5 (36.5)
Cooling Capacity: gal (L)50.1 (189.6)
Engine Electrical
Electric Volts: DC 24
Cold Cranking Amps 1100
Battery(s) Required 2
Fuel System
Fuel Supply Size: Natural Gas
LP Vapor
3.00” NPT
3.00” NPT
Supply Pressure: in. H₂O (kPa) 7-11 (1.74-2.74)
Air Requirements
Air Filter(s) Type Dry
Combustion Air Flow: CFM (m³/min) 968 (27)
Maximum Air Intake Restriction
Clean: in. H₂O (kPa)3.00 (1.24)
Dirty: in. H₂O (kPa)15.00 (3.74)
Radiator Air Flow: CFM (m³/min) 40,000 (1133)
Exhaust System
Gas Temperature: °F (°C)1382 (750)
Gas Flow: CFM (m³/min)2995.0 (84.8)
Max Back Pressure: in. H₂O (kPa) 40.9 (10.2)
Filters and Quantity
Air Cleaner Quantity 1
Oil Filter(s) Quantity 1
Fuel Consumption - Natural Gas
At 100% of Power Rating: CFH (m³/hr)4231 (119.8)
At 75% of Power Rating: CFH (m³/hr)3298 (93.4)
At 50% of Power Rating: CFH (m³/hr)2317 (65.6)
At 25% of Power Rating: CFH (m³/hr)1413 (40.0)
Fuel Consumption - LP Vapor
At 100% of Power Rating: CFH (m³/hr)1409 (39.9)
At 75% of Power Rating: CFH (m³/hr)1201 (34.0)
At 50% of Power Rating: CFH (m³/hr)809 (22.9)
At 25% of Power Rating: CFH (m³/hr)512 (14.5)
GENERAL GUIDELINES FOR DERATION:Altitude: Derate 0.5% per 100m (328 ft.) Elevation above 1000m (3279 ft.) Temperature: Derate 1.0% per 10°C (18°F) temperature
above 25°C (77°F)
RATINGS:All three-phase units are rated at 0.8 power factor. All single-phase units are rated at 1.0 power factor.
125°RATINGS:125° apply to installations served by a reliable utility source. The standby rating is applicable to varying loads for the duration of a power outage. There is no
overload capability for this rating. Ratings are in accordance with ISO-3046/1, BS 5514, AS 2789, and DIN 6271.For limited running time and base load ratings consult the
factory. The generator set manufacturer reserves the right to change the design or specifications without notice and without any obligation or liability whatsoever.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
®®
alternator and controller data
Control Panels
DeepSea 7310 MKII
Simultaneous Use of RS232 & RS485
Modbus RTU Support
Fully Configurable Using USB, RS232 &
RS485
IP65 Rating
6 Programmable Inputs & 8 Outputs
UL & cUL Listed and CE Certified
Taylor Analog
Automatic CANBUS Engine Control
Gauge Zeroing on Shutdown
Auto-Off-Manual Control Switch
Oil Pressure, Water Temperature, Battery
Voltage and RPM Gauges
AC Voltage, Frequency, Percent of Load,
and Run-Time Metering
LED Status Lights
Basler DGC2020
SAE J1939 Engine ECU Communications
4 Programmable Inputs & 10 Outputs
Modbus Communications With RS485
UL Recognized, CSA & CE Certified
IP 54 Front Panel Rating
NFPA 110 Level 1 Compatible
Manual Override Keyswitch
DGC2020HD Variant Available
Alternator Data
Manufacturer Marathon
Type PMG
Insulation Class NEMA N
Temperature Rise 125°C Standby
Hertz 60
RPM 1800
Amortisseur Windings Full
CFM Cooling Required 800
Voltage Regulator DVR2400 PM500
Sensing Three Phase Three Phase
Voltage Regulation 0.25% 0.25%
Features
• NEMA MG1-32, BS5000, and IEC 34-1 compliant;
CE & CSA Certified and UL Listed
• Self-ventilated and drip proof construction
• Two-thirds pitch stator and skewed rotor
• Wet wound, epoxied field windings
• Designed to withstand overspeeds of up to 125%
• Hybrid analog/digital voltage regulator
• Under frequency protection
• Under frequency indication light
• Less than one cycle response time
• Over excitation protection
• Over excitation indication light
• Easy access front-panel adjustments
• Over voltage protection shutdown
Alternator Data
Manufacturer Stamford
Type PMG
Insulation Class NEMA H
Temperature Rise 125°C Standby
Hertz 60
RPM 1800
Amortisseur Windings Full
CFM Cooling Required 2780
Voltage Regulator MX341 MX321
Sensing Single PhaseThree Phase
Voltage Regulation 1.0% 0.50%
Features
• BS EN 60034, BS5000, VDE 0530, NEMA MG1-32,
IEC34, CSA C22.2-100, and AS1359 complaint
• IP23 enclosure
• Dynamically balanced to exceed BS6861:Part 1 Grade 2.5
vibration standard
• Quality assurance to BS EN ISO 9001
• Self-ventilated and Drip proof construction
• Two-thirds pitch stator and skewed rotor
• Heavy duty bearings
• Fully guarded
• Overexcitation protection
• Under frequency protection
• Analog input
• Overvoltage protection
• Paralleling compatible
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
standard features and options
®
Controller Options
DGC2020HD Controller
Fiber Optic Ethernet (DGC2020HD)
RS-232 Port & Generator Protection (DGC2020)
Flush or Surface Mount Remote Annunciator
Remote Mount Break Glass E-Stop Switch
Warranty
2 Year Standard
5 Year Comprehensive
Miscellaneous Options:
Generator Strip Heater Pad Type Battery Heater
Spring Isolators Battery Heater Blanket
Line Circuit Breaker Oil Pan Heater
Standard Features:
Heavy Duty Steel Base Battery Charger
Vibration Isolators Block Heater
Oil Drain Valve with Extension Factory Powder Coating
Coolant Drain Kit Factory Load Test
High Ambient Unit Mounted Radiator Owner’s Manual
Open Unit
Options:
• Radiator Duct Flange
• Flex Exhaust
• Critical Silencer
Overall Size: 140”L x 90”W x 98”H
Approximate Weight: 11,250 lbs.
Note: Dimensions and weights reflect standard
open unit with no options and are subject to
change.
Standard Enclosed Unit
Options:
• Sound Attenuated Enclosure
• Load Center, Lights & GFI Receptacle
Overall Size: 186”L x 90”W x 106”H
Approximate Weight: 13,500 lbs.
Note: Dimensions and weights reflect standard
enclosed unit with no options and are subject to
change.
Note: The above drawings are provided for reference only and should not be used for planning installation.
Contact your local distributor for more information.04/23
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
GENERAL DATA
• Water-cooled, turbo-charged, air-to-air inter-cooled,
stoichiometric with replaceable wet cylinder liners
• Cast iron block & heads, 10.5:1 compression ratio,
overhead valve/2V configuration
• Crankshaft gear-driven oil system with cartridge-type
filter, belt-driven centrifugal water pump
• 24VDC Starter and Alternator
• CANBUS J1939 interface
• 3-Way Catalytic Converter
• UL-recognized air filtration
• Integrated knock sensing and control
• Full ECU engine control with coil-on-plug variable timing ignition
• Engine protection for oil pressure, coolant level, coolant
temperature, fuel pressure, over-speed
The PSI HD 21.9L is a U.S. EPA-certified natural gas and
propane engine developed from the block up to be a
reliable and durable power unit. Built upon a proven
marine-diesel grade block, the 12-cylinder V-Configuration,
turbocharged and after-cooled engine features
replaceable wet liners and water-cooled exhaust.
Superior engine performance is driven by an ECU that
integrates and coordinates all critical functions including:
Governor, Variable Ignition Timing, Air Fuel Ratio Control,
Knock Suppression and Engine Protection.
PSI is the market leader in providing heavy-duty products. PSI
has seven models in its HD product lineup with displacements of
8.1L, 11.1L, 14.6L, 18.3L, 21.9L and 29.2L. These engines are an
extension of the PSI product line, which is based upon blocks from
650cc to 8.8L. All PSI engines feature the same fuel systems and
controls, simplifying your application development and support.
21.9 L INDUSTRIALSTATIONARY
90.3 in / 2,294 mm
83.6 in2,124 mm
75.3 in / 1,914 mm
FEATURES
• U.S. EPA-Certified and CARB-Compliant, Industrial Stationary
• 50C Ambient Cooling Capacity
• UL2200-Compliant or Listed Components
• MasterTrak Telematics service (included for 1 year)
GENERATION 2 ENHANCEMENTS
• Enhancements for prime & continuous power
• Dual Fuel Auto Switch-Over
• Brushless Alternators
• Serpentine, Self-Tensioning Fan Belt
• Advanced diagnostics for improved up-time
PSI 21.9-LITER ENGINE DATA
Model Number
Cylinders
Induction system
Combustion system
Cooling system
Displacement
Compression ratio
Bore & Stroke
Fuel Type
Direction of rotation
Dry Weight
D219L
90˚, V-12
Turbocharged & air-to-air charge cooled
Spark-ignited
Water-cooled
1,338 cid (21,561 cc)
10.5:1
5.04 in x 5.59 in (128 mm x 142 mm)
Natural Gas / Propane
Anti-clockwise viewed on flywheel
3,638 lb (1,650 kg)
kWe
Standby*
Prime*
NG
LPG
NG
LPG
1500 RPM
410 kWe
262 kWe
369 kWe
236 kWe
1800 RPM
450 kWe
315 kWe
405 kWe
284 kWe
(standard radiator shown)
*Assumes 10% losses for fans and genset. Ratings subject to PSI application and duty cycle guidelines.
Doosan PSI LLC 1465 Hamilton Parkway, Itasca, IL 60143 USA
T: 888-643-6373 • F: 847-886-4162 • doosanpsi.com
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Air/Gas PropertiesDescriptionPerformance
Design Temperature
Inlet Temperature
Altitude above sea level
Outlet Velocity
Standard Power
Standard SP
--
Drive method . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Wheel Diameter
Discharge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Rotation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Arrangement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Width . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Quantity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
HIB
Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .490
SWSI
8
Class . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24
CCW
TAU
55.1
Direct
Percentage width . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .85%
Percentage diameter . . . . . . . . . . . . . . . . . . . . . . . . .100%
70
330.60
Inlet Pressure 0.000
Oper. Power
Static Efficiency . . . . . . . . . . . . . . . . . . . . . . . . . .
5100
77.66%
36.191
Estimated Density274.05
Max RPM for Class . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Total Efficiency . . . . . . . . . . . . . . . . . . . . . . . . . .
70
Tip Speed
0.0622
Outlet Area
Operating SP
RPM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
25472
1790
5451
81.63%
8.256
45,000
30.000
1765
CFM . . . . . . . . . . . . .
(in WC) . . . . . . . . . . . . .
(in WC) . . . . . . . . . . . .
(FPM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
BHP . . . . . . . . . . . . . . . . . . . .
BHP . . . . . . . . . . . . . . .
(sq.ft) . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(FPM) . . . . . . . . . . . . . . . . . . . . . . .(in) . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(°F) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(°F) . . . . . . . . . . . . . . . . . . . . . . . .
(lb/ft³) . . . . . . .
(ft) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(in WC) . . . . . . . . . . . . . . . . . . .
Motor position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Volumetric Flow
FEI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
FEP (KW) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
System FEI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
System FEP (KW) . . . . . . . . . . . . . . . . . . . . . . . . .
1.31
212.43
1.31
212.43
Gas Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Operating air
Motor Data
Power (HP) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .300
Enclosure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .TEFC
Speed (RPM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1800
Voltage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .460V
Frame Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .449T
Phase . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3
Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60Hz
Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Modifiers
Apply Compressibility, Width 85%.
*To estimate dBA level for ducted inlet and ducted outlet (into and out of the room) type installation, deduct 20 from the LwA value
Using a directivity factor of 1.Estimated Sound Pressure based on free field, spherical (Q = 1) radiation at stated distance.shown.
Definitions:
Estimated sound pressure level in dBA
(re: 0.0002 microbar) based on a single
* ducted installation:
dBA
LwA The overall (single value) fan sound power level, 'A' weighted.
-12
The environment for each fan installation influences its measured sound value, therefore dBA levels cannot be
guaranteed. Consult AMCA Publication 303 for further details. A fan's dBA is influenced by nearby reflective surfaces.
Sound
Sound Power Levels in dB re.10 Watts:
531ftDistance in
100104114dBA at inletLevel at Inlet
Octave Bands
123
LwA
11494
87
99105
65
109111
43
114
2
117
1
FAN DETAILS
Customer:
Job ID:
Starkaire
Job Name:
JC-22-10-28-01a
November 01, 2022Date:
Tag:Fluidizing Blower
Page 1 of 7
All quotations per Twin City Fan Terms and Conditions found at www.tcf.com/terms-and-conditions
Ver 10.2 July 2022 - Created 10-28-2022 Updated 11-01-2022 Owner Joe Carden Industrial Air Source
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
FAN DETAILS
Customer:
Job ID:
Starkaire
Job Name:
JC-22-10-28-01a
November 01, 2022Date:
Tag:Fluidizing Blower
Pricing Detail
IncludedHIB 490, Class 24, Arrangement 8 Bare fan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedAccess Door - Bolted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedDrain W/ Plug . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedFlange - Inlet, Punched . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedFlange - Outlet, Punched . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedGuard - Shaft & Bearing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedSplit Housing - Pie Shaped . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedShaft Seal - Std Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedSpecial Width Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedCoupling 1090T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedMotor 300 HP 1800 RPM 460V 3Ph 60Hz TEFC - Premium Induction 449T . . . . . . . . . . . . . . . . . . . . . . . . . . .
Special Motor
With Shaft Grounding and NDE Insulated Bearing
WEG W22 - 30018ET3G449T-W22 + B-230 + B-260 or similar
5100FASL
IncludedGuard - Coupling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedMount TCF Motor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedMount Coupling - Both Halves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
$60,855
$60,855
Extended Weight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8,968 lb
Extended Selling Price . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Total Selling Price Each . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8,968 lbEach Weight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Page 2 of 7
All quotations per Twin City Fan Terms and Conditions found at www.tcf.com/terms-and-conditions
Ver 10.2 July 2022 - Created 10-28-2022 Updated 11-01-2022 Owner Joe Carden Industrial Air Source
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Air/Gas PropertiesDescriptionPerformance
Design Temperature
Inlet Temperature
Altitude above sea level
Outlet Velocity
Standard Power
Standard SP
--
Drive method . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Wheel Diameter
Discharge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Rotation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Arrangement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Width . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Quantity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
TBNA
Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27012
SWSI
4
Class . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .HP
CW
TAU
27.5
Direct
Percentage width . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .100%
Percentage diameter . . . . . . . . . . . . . . . . . . . . . . . . .100%
70
77.07
Inlet Pressure 0.000
Oper. Power
Static Efficiency . . . . . . . . . . . . . . . . . . . . . . . . . .
5100
61.19%
48.254
Estimated Density63.89
Max RPM for Class . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Total Efficiency . . . . . . . . . . . . . . . . . . . . . . . . . .
70
Tip Speed
0.0622
Outlet Area
Operating SP
RPM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
25004
3600
7898
66.12%
0.785
6,200
40.000
3473
CFM . . . . . . . . . . . . . . . . . .
(in WC) . . . . . . . . . . . . .
(in WC) . . . . . . . . . . . .
(FPM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
BHP . . . . . . . . . . . . . . . . . . . . . . . . .
BHP . . . . . . . . . . . . . . . . . . .
(sq.ft) . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(FPM) . . . . . . . . . . . . . . . . . . . . . . .(in) . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(°F) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(°F) . . . . . . . . . . . . . . . . . . . . . . . .
(lb/ft³) . . . . . . .
(ft) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(in WC) . . . . . . . . . . . . . . . . . . .
Motor position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Volumetric Flow
FEI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
FEP (KW) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
System FEI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
System FEP (KW) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.09
50.67
1.09
50.67
Gas Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Operating air
Motor Data
Power (HP) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .75
Enclosure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .TEFC
Speed (RPM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3600
Voltage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .230/460V
Frame Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .365TS
Phase . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3
Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .0Hz
Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Modifiers
Apply Compressibility.
*To estimate dBA level for ducted inlet and ducted outlet (into and out of the room) type installation, deduct 20 from the LwA value
Using a directivity factor of 1.Estimated Sound Pressure based on free field, spherical (Q = 1) radiation at stated distance.shown.
Definitions:
Estimated sound pressure level in dBA
(re: 0.0002 microbar) based on a single
* ducted installation:
dBA
LwA The overall (single value) fan sound power level, 'A' weighted.
-12
The environment for each fan installation influences its measured sound value, therefore dBA levels cannot be
guaranteed. Consult AMCA Publication 303 for further details. A fan's dBA is influenced by nearby reflective surfaces.
Sound
Sound Power Levels in dB re.10 Watts:
531ftDistance in
96100110dBA at inletLevel at Inlet
Octave Bands
105
LwA
11093
87
9698
65
107106
43
106
2
106
1
FAN DETAILS
Customer:
Job ID:
Starkaire
Job Name:
JC-22-10-28-01a
November 01, 2022Date:
Tag:Combustion Blower
Page 3 of 7
All quotations per Twin City Fan Terms and Conditions found at www.tcf.com/terms-and-conditions
Ver 10.2 July 2022 - Created 10-28-2022 Updated 11-01-2022 Owner Joe Carden Industrial Air Source
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
FAN DETAILS
Customer:
Job ID:
Starkaire
Job Name:
JC-22-10-28-01a
November 01, 2022Date:
Tag:Combustion Blower
Pricing Detail
IncludedTBNA 27012, Class HP, Arrangement 4 Bare fan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedDrain W/ Plug . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedFlange - Inlet, Punched . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedFlange - Outlet, Punched . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedShaft Closure Plate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedMotor 75 HP 3600 RPM 230/460V 3Ph 60Hz TEFC - Premium Induction 365TS . . . . . . . . . . . . . . . . . . . . . . .
Weg W22 - 07536ET3E365TS-W22 or similar
5100FASL
IncludedMount TCF Motor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
$13,851
$13,851
Extended Weight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1,719 lb
Extended Selling Price . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Total Selling Price Each . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1,719 lbEach Weight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Page 4 of 7
All quotations per Twin City Fan Terms and Conditions found at www.tcf.com/terms-and-conditions
Ver 10.2 July 2022 - Created 10-28-2022 Updated 11-01-2022 Owner Joe Carden Industrial Air Source
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Air/Gas PropertiesDescriptionPerformance
Design Temperature
Inlet Temperature
Altitude above sea level
Outlet Velocity
Standard Power
Standard SP
--
Drive method . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Wheel Diameter
Discharge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Rotation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Arrangement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Width . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Quantity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
BCS
Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .402
SWSI
4
Class . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17
CCW
BAU
42.3
Direct
Percentage width . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .105%
Percentage diameter . . . . . . . . . . . . . . . . . . . . . . . . .105%
70
157.35
Inlet Pressure 0.000
Oper. Power
Static Efficiency . . . . . . . . . . . . . . . . . . . . . . . . . .
5100
72.52%
14.476
Estimated Density130.43
Max RPM for Class . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Total Efficiency . . . . . . . . . . . . . . . . . . . . . . . . . .
70
Tip Speed
0.0622
Outlet Area
Operating SP
RPM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
19230
1802
5281
81.21%
9.467
50,000
12.000
1738
CFM . . . . . . . . . . . . .
(in WC) . . . . . . . . . . . . .
(in WC) . . . . . . . . . . . .
(FPM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
BHP . . . . . . . . . . . . . . . . . . . .
BHP . . . . . . . . . . . . . . .
(sq.ft) . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(FPM) . . . . . . . . . . . . . . . . . . . . . . .(in) . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(°F) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(°F) . . . . . . . . . . . . . . . . . . . . . . . .
(lb/ft³) . . . . . . .
(ft) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(in WC) . . . . . . . . . . . . . . . . . . .
Motor position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Volumetric Flow
FEI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
FEP (KW) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
System FEI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
System FEP (KW) . . . . . . . . . . . . . . . . . . . . . . . . .
1.32
101.16
1.32
101.16
Gas Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Operating air
Motor Data
Power (HP) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .150
Enclosure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .TEFC
Speed (RPM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1800
Voltage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .460V
Frame Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .445T
Phase . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3
Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .60Hz
Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Induction
Modifiers
Apply Compressibility, Width 105%, Diameter 105%.
*To estimate dBA level for ducted inlet and ducted outlet (into and out of the room) type installation, deduct 20 from the LwA value
Using a directivity factor of 1.Estimated Sound Pressure based on free field, spherical (Q = 1) radiation at stated distance.shown.
Definitions:
Estimated sound pressure level in dBA
(re: 0.0002 microbar) based on a single
* ducted installation:
dBA
LwA The overall (single value) fan sound power level, 'A' weighted.
-12
The environment for each fan installation influences its measured sound value, therefore dBA levels cannot be
guaranteed. Consult AMCA Publication 303 for further details. A fan's dBA is influenced by nearby reflective surfaces.
Sound
Sound Power Levels in dB re.10 Watts:
531ftDistance in
98102112dBA at inletLevel at Inlet
Octave Bands
103
LwA
11291
87
97102
65
103112
43
112
2
102
1
FAN DETAILS
Customer:
Job ID:
Starkaire
Job Name:
JC-22-10-28-01a
November 01, 2022Date:
Tag:Exhaust Fan
Page 5 of 7
All quotations per Twin City Fan Terms and Conditions found at www.tcf.com/terms-and-conditions
Ver 10.2 July 2022 - Created 10-28-2022 Updated 11-01-2022 Owner Joe Carden Industrial Air Source
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
FAN DETAILS
Customer:
Job ID:
Starkaire
Job Name:
JC-22-10-28-01a
November 01, 2022Date:
Tag:Exhaust Fan
Pricing Detail
IncludedBCS 402, Class 17, Arrangement 4 Bare fan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedAccess Door - Bolted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedDrain W/ Plug . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedFlange - Inlet, Punched . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedFlange - Outlet, Punched . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedShaft Seal - Std Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedSpecial Width Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedSpecial Diameter Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
IncludedMotor 150 HP 1800 RPM 460V 3Ph 60Hz TEFC - Premium Induction 445T . . . . . . . . . . . . . . . . . . . . . . . . . . .
With Shaft Grounding Ring
WEG W22 - 15018ET3GRB445T-W22 * B-230 or similar
5100FASL
IncludedMount TCF Motor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
$24,513
$24,513
Extended Weight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2,003 lb
Extended Selling Price . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Total Selling Price Each . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2,003 lbEach Weight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Page 6 of 7
All quotations per Twin City Fan Terms and Conditions found at www.tcf.com/terms-and-conditions
Ver 10.2 July 2022 - Created 10-28-2022 Updated 11-01-2022 Owner Joe Carden Industrial Air Source
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
AMCA Statements
Tag: Fluidizing Blower
No AMCA Statements
Tag: Combustion Blower
No AMCA Statements
1. Twin City Fan certifies that the model BCS is licensed to bear the AMCA Seal. The ratings shown
are based on tests and procedures performed in accordance with AMCA Publication 211 and AMCA
Publication 311 and comply with the requirements of the AMCA Certified Ratings Program.
2. Performance certified is for Installation Type B & D: Free or ducted inlet, Ducted outlet.
3. Power rating (BHP) does not include transmission losses.
4. The AMCA licensed air performance data has been modified for installation, appurtenances or
accessories, etc. not included in the certified data. The modified performance is not AMCA licensed
but is provided to aid in selection and applications of the product.
5. The sound power level ratings shown are in decibels, referred to 10 E-12 watts calculated per
AMCA Standard 301.
6. Values shown are for inlet Lwi and LwiA sound power levels for Installation Type B: Free inlet,
Ducted outlet.
7. Ratings do not include the effects of duct end correction.
8. The A-weighted sound ratings shown have been calculated per AMCA Standard 301.
9. dBA levels are not licensed by AMCA International.
Tag:Exhaust Fan
Fan Energy Index (FEI) is an overall efficiency (wire-to-air) metric which includes not only the impact of
the fan efficiency, but also each of the drive components used to operate the fan.
Fan Electrical Input Power (FEP) is the amount of power of a given fan at an operating point
characterized by a value of flow and pressure.
Regulation Statements
FAN DETAILS
Customer:
Job ID:
Starkaire
Job Name:
JC-22-10-28-01a
November 01, 2022Date:
Page 7 of 7
All quotations per Twin City Fan Terms and Conditions found at www.tcf.com/terms-and-conditions
Ver 10.2 July 2022 - Created 10-28-2022 Updated 11-01-2022 Owner Joe Carden Industrial Air Source
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
THERMAL ROTARY SAND DRYING PLANTS
Page: 1 of 1
CONTACT US AT: PHONE: [phone] FAX: [phone]
PO BOX 2270 LEES SUMMIT, MO 64063
E-mail: [e-mail] Website: www.tarmacinc.com

Richard Brannon
Wildcat Minerals LLC
Email: [e-mail]
Date 05/22/21

Richard,
Tarmac International, Inc.’s baghouses as used is drying aggregate and sand are capable of
meeting at or below a .01 grain loading per standard cubic foot. In order for the baghouse to work at these levels the baghouse must be maintained and cleaned. Part of maintenance is completing a black light test where any failed or leaking bags can be
found and replaced. Also, cleaning the surfaces of the clean air plenum including the under side
of the doors, tubesheet, and side walls should be done yearly and before a stack test or after replacing bags. Also, any flanges between the dirty air plenum and the exhaust stack must be caulked and bolted tight. Running a pressure drop across the tube sheet at 4” WC is a must, as the dust on the bags is integral to the baghouse filtering out particulate. Pulsing should be at 80
psig with a pulse interval at no greater than every 10 seconds.
The baghouse must also be sized correctly with a low air to cloth ratio if the material being dried, is fine material. In the case of the Wildcat baghouse and system purchased from Black Mountain, that dryer, cyclone pre-dust collector, baghouse size, ductwork, and ID fan size are
well balanced and the air to cloth ratio is below a 4.0:1, which is an excellent air to cloth ratio.
In conclusion, with correct installation, maintenance, and operation the baghouse particulate emissions will be at .01 or below. Regards,
Ron Heap President
Tarmac International, Inc.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

EMISSIONS MODELING
AIR QUALITY IMPACTS ANALYSIS

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
WILDCAT SAND , LLC

AIR QUALITY IMPACT ANALYSIS –
PERMIT MODIFICATION FOR
F LUID BED SAND DRYER

FACILITY LOCATED AT:
40.223957°, -109.901884°
5482 S. 5500 E
RANDLETT, UT 84063

MODELING SUBMITTED TO:
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
UTAH DIVISION OF AIR QUALITY – AIR DISPERSION MODELING TEAM
P.O. BOX 144820
SALT LAKE CITY, UT 84114

SUBMITTAL DATE:
JUNE 30, 2023

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Section 1
June 2023
Page ii of v

Prepared for:

Wildcat Sand
5128 Apache Plume Rd., Suite 300
Fort Worth, TX 76109

Facility Physical Location:
Wildcat Sand Plant
Section 17, T3S, R1E, Uintah County, UT
UTM Zone 12, 593455.00 m Easting, 4453216.00 m Northing

Prepared by:

Air Regulations Consulting, LLC
5455 Red Rock Lane, Suite 13
Lincoln, NE 68516
Phone: [phone]
Web: http://www.airregconsulting.com/

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Section 1
June 2023
Page iii of v

1 AIR QUALITY IMPACT ANALYSIS SUBMITTAL

Title: AIR QUALITY IMPACT ANALYSIS FOR PERMIT MODIFICATION APPLICATION

Organization: Wildcat Sand, LLC

Revision Date: June 30, 2023, v1.0

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Environmental Specialist, ARC
6/30/2023
Sydney Stauffer
Wildcat Sand AQIA
Section 2
June 2023
Page iv of v

2 TABLE OF CONTENTS
SECTION
1 AIR QUALITY IMPACT ANALYSIS SUBMITTAL .......................................................................... III
2 TABLE OF CONTENTS ............................................................................................................ IV
3 EXECUTIVE SUMMARY ........................................................................................................... 1
3.1 Air Quality Impact ............................................................................................................... 1
4 PROJECT DESCRIPTION AND BACKGROUND ............................................................................ 4
4.1 General Facility/Project Description ................................................................................... 4
4.2 Location of Facility .............................................................................................................. 4
5 MODELING ANALYSES APPLICABILITY ..................................................................................... 5
5.1 Modeling Analyses Overview .............................................................................................. 5
5.2 Applicable Standards .......................................................................................................... 6
5.3 Criteria Pollutant Modeling Applicability ............................................................................ 6
6 MODELED EMISSION SOURCES ............................................................................................... 7
6.1 Emission Sources................................................................................................................. 7
6.2 Criteria Pollutants ............................................................................................................... 8
6.2.1 Modeled Emission Rates for Cumulative Impact Analyses .................................... 8
6.3 Emission Release Parameters ............................................................................................. 9
7 MODELING METHODOLOGY ................................................................................................. 12
7.1 Model Selection ................................................................................................................ 13
7.2 Model Options .................................................................................................................. 13
7.3 Meteorological Data ......................................................................................................... 13
7.4 Effects of Terrain ............................................................................................................... 13
7.5 Facility Layout ................................................................................................................... 13
7.6 Effects of Building Downwash .......................................................................................... 14
7.7 Ambient Air Boundary ...................................................................................................... 14
7.8 Receptor Network ............................................................................................................. 14
7.8.1 Boundary Receptors ............................................................................................ 14
7.8.2 Fine Grid ............................................................................................................... 15
7.8.3 Intermediate Grid ................................................................................................ 15
7.8.4 Coarse Grid #1...................................................................................................... 15
7.8.5 Coarse Grid #2...................................................................................................... 15
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Section 2
June 2023
Page v of v

7.8.6 Coarse Grid #3...................................................................................................... 15
7.9 Background Concentrations ............................................................................................. 15
8 RESULTS AND DISCUSSION ................................................................................................... 17
8.1 Criteria Pollutant Impact Results ...................................................................................... 17
8.1.1 Cumulative NAAQS Impact Analysis .................................................................... 17
9 QUALITY ASSURANCE / CONTROL ......................................................................................... 18
10 REFERENCES ........................................................................................................................ 19

APPENDICES
Appendix A – Facility Map
Appendix B – Cumulative Source Parameters
Appendix C – Meteorological Analysis
Appendix D – Receptor Domain
Appendix E – Cumulative NAAQS and UDAQ Impact Analysis Isopleth – PM10
Appendix F – Cumulative NAAQS and UDAQ Impact Analysis Isopleth – NOX

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Section 3
June 2023
_________________________________Page 1 of 18

P a g e 1
3 EXECUTIVE SUMMARY
Wildcat Sand, LLC (Wildcat or Facility) operates a sand processing facility in the Uinta Basin with drying
operations with additional handling equipment located approximately seven (7) miles to the southeast of
Roosevelt, Utah. Wildcat is planning to install a second sand dryer to increase operations, as well as remove
hourly and production limits that are currently implemented in Approval Order (AO) DAQE-AN159980003-21.
The additional sand dryer will be equipped with a 38.0 million British thermal unit per hour (MMBtu/hr) natural
gas burner.
The Facility is located in Northeast Utah in Uintah County. The Facility has emission sources capable of producing
Particulates less than 10 micrometers in diameter (PM10), Particulates less than 2.5 micrometers in diameter
(PM2.5), Nitrogen Oxides (NOX), Sulfur Dioxide (SO2), Carbon Monoxide (CO), and Volatile Organic Compounds
(VOC). However, the VOC, PM2.5, SO2, and CO emissions are negligible from the modeling standpoint, thus, the
impacts for PM10 and NO2 are reviewed in this ambient air quality impact analysis (AQIA). The maximum ambient
air quality impacts for the proposed changes to the Facility are shown in Table 3-1.
This AQIA is being submitted to the Utah Department of Environmental Quality, Division of Air Quality (UDAQ)
for review with a minor source Notice of Intent (NOI) and modification application to AO DAQE-AN159980003-
21. This AQIA was prepared in accordance with the Utah Division of Air Quality Emissions Impact Assessment
Guidelines, revised March 3, 2013. The AQIA evaluated the ambient air impacts from the proposed source
emissions in comparison to the National Ambient Air Quality Standards (NAAQS), and Utah Ambient Air Quality
Standards for PM10 and NO2.
3.1 Air Quality Impact
Ambient air quality impacts of the Wildcat sand plant are assessed through dispersion modeling. Dispersion
models calculate the ambient air quality impacts of the project emissions at various receptors. Impacts are
typically categorized as local (i.e., at, or within 30 miles of, the project property line) or regional (30 miles or
more from the project).
In order to evaluate the local and nearby ambient air quality impacts, the AERMOD dispersion model was used
with five years (2016 - 2020) of meteorological data from the Vernal KVEL ASOS meteorological station, and the
Grand Junction National Weather Service Office upper air station. The proposed project emissions were assessed
alone and then combined with the background concentrations of pollutants in the area.
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Section 3
June 2023
_________________________________Page 2 of 18

P a g e 2
The criteria pollutants modeling results are presented in Table 3-1. The dispersion modeling results demonstrate
that the Facility will not cause or contribute to an exceedance of NAAQS.
Table 3-1 shows the maximum modeled impacts for PM10 and NO2 from the cumulative modeling analysis for
the Wildcat sand plant. The table includes the combined impact with the background concentrations for PM10
and NO2 from Roosevelt station.

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Section 3
June 2023
_________________________________Page 3 of 18

P a g e 3
TABLE 3-1: MAXIMUM AMBIENT AIR QUALITY IMPACTS
Criteria
Pollutant
Averaging
Time
Maximum
Modeled
Conc.
Significant
Impact
Level (SIL)
Exceeds SIL
Background
(µg/m3)
Total Conc.
(Background +
Cumulative) (µg/m3)
NAAQ
Standard
(µg/m3)
Exceeds
NAAQS or
UDAQ AAQS
% of NAAQS
or UDAQ
AAQS
PM10 24-hour 100.82 5.0 Yes Monthly 148.47 150 No 98.98%
NO2 1-hour 69.16 7.5 Yes Monthly 117.22 188 No 62.35%
Notes:
(1) Maximum impact for PM10 24-hr impacts is based on the 6th highest high over the five-year period.
(2) Maximum impact for NOX 1-hr impacts is based on the 8th highest high over the five-year period.
(3) Meteorological Dataset – Surface Met Data (Vernal KVEL ASOS), and Upper Air Data (Grand Junction NWS) for the years 2016-2020.

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Section 4
June 2023
_________________________________Page 4 of 18

P a g e 4
4 PROJECT DESCRIPTION AND BACKGROUND
Wildcat Sand (Wildcat) is a sand processing plant that is planning to install an additional (1) sand dryer
and increase current operational handling at the sand processing facility that is located approximately
seven (7) miles to the southeast of Roosevelt, Utah. The current sand dryer is equipped with a 40.9 million
British thermal unit per hour (MMBtu/hr) natural gas-fired burner, and the additional sand dryer will be
equipped with a 38.0 MMBtu/hr natural gas-fired burner.
4.1 General Facility/Project Description
The Wildcat facility is a sand processing plant that produces high-quality sand for the oil and gas industry
as well as other markets. The Facility is located roughly seven (7) miles southeast of Roosevelt, Uintah
County, UT. The Facility has emission sources of Particulates less than 10 micrometers in diameter (PM10),
Particulates less than 2.5 micrometers in diameter (PM2.5), Nitrogen Oxides (NOX), Sulfur Dioxide (SO2),
Carbon Monoxide (CO), and Volatile Organic Compounds (VOC).
The sand plant with washing and screening operations currently has a 40.9 MMBtu/hr natural gas-fired
burner for the rotary sand dryer and is planning to install a 38.0 MMBtu/hr natural gas-fired burner for
the proposed fluid bed sand dryer.
4.2 Location of Facility
The Wildcat plant is located in Uintah County, Utah, which is designated as attainment or unclassifiable
for all criteria pollutants, except for ozone, which is marginal status for the area. The main entrance to the
Facility is located at UTM 4453372.27 N by 593801.10 E, Zone 12 T, NAD83. The surrounding area is a rural
area with terrain between 4,800 and 5,200 feet above mean sea level (MSL). A Plant Layout Map, detailing
the property boundary and surrounding area, is provided in Appendix A.

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Section 5
June 2023
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5 MODELING ANALYSES APPLICABILITY
5.1 Modeling Analyses Overview
An analysis confirming that the Wildcat Sand Plant will remain in compliance with applicable air quality
standards is generally required with an air permit application. This is typically done through an air
dispersion modeling analysis.
The general approach for determining applicability and compliance with air quality standards is
summarized below:
• All emission sources at the Facility identified in the NSR application that emit a criteria pollutant
are to be considered in the evaluation.
• PTE emission rates, both in terms of maximum hourly and annual average hourly, are calculated
and compared to respective screening emission levels to identify pollutants of concern.
• Pollutants of concern are identified as those which have a PTE emission rate exceeding the
respective screening emission levels listed in UDAQ dispersion modeling guidance or UDAQ
regulations.
• Pollutants of concern must be included in an air dispersion modeling analysis. All other emitted
pollutants are deemed to be in compliance with the applicable ambient air quality standard or
allowable ambient concentration based on screening.
• For the pollutants of concern, all sources contributing to the PTE emissions of these pollutants
must be included in dispersion modeling and compared to the SIL.
• For the pollutants of concern above the SIL, all sources contributing to the PTE and Facility
emissions of these pollutants must be included in dispersion modeling and compared to the
NAAQS.
• Results from the dispersion modeling are compared to the applicable air quality standards to
determine the facility’s air quality compliance status. For criteria pollutants, ambient background
concentrations are added to the model results before comparing to the regulatory limit.
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5.2 Applicable Standards
Criteria pollutant National Ambient Air Quality Standards (NAAQS) and UDAQ Ambient Air Quality
Standards (UDAQ AAQS) are listed in Table 5-1, along with significant impact levels (SILs).
TABLE 5-1: APPLICABLE REGULATORY LIMITS
Pollutant
Averaging
Period
Significant Impact
Levels (g/m3) a
Regulatory Limit
(g/m3)
Modeled Design Value Used b
PM10 c 24-hour 5.0 150 High 6th High d
NO2 1-hour 7.5 188 High 8th High d
a Micrograms/cubic meter.
b Modeled design values are calculated for each ambient air receptor.
c Particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers.
d Concentration at any modeled receptor when using five years of meteorological data.
5.3 Criteria Pollutant Modeling Applicability
The Wildcat Sand Plant is composed of emission sources capable of producing total suspend particulate
(TSP), particulate matter smaller than ten microns in size (PM10), particulate matter smaller than 2.5
microns in size (PM2.5), Nitrogen Dioxide (NO2), Carbon Monoxide (CO), and Sulfur Dioxide (SO2). PM10 and
NO2 are the pollutants of concern for modeling purposes. The results of the preliminary analysis for PM10
and NOX emissions exceeded the applicable Significant Impact Levels (“SILs”) and, therefore, required a
cumulative analysis to demonstrate compliance with the NAAQS. The following sources operate at the
facility:
• Transfer and Unloading of Silos #1 - #3
• J & H Screen with Baghouse
• Haul Road – Additional Exit from Plant
• Haul Road – WIP Pile #2 to WIP Pile #3
• Haul Road – Final Product
• Haul Road – Loader to Dry Plant
• Haul Road – Loader to Wet Plant
• Secondary Crusher
• Conveyors and Drop Points
• Truck Unloading to Dry Plant #1
• Truck Unloading to Dry Plant #2
• Truck Unloading to Wet Plant
• Truck Unloading to WIP Pile #3
• Storage Pile – Pre-Wash Plant
• Storage Pile – WIP Stockpile #2
• Storage Pile – WIP Stockpile #3
• 40.9 MMBtu/hr Natural Gas-Fired Sand Dryer#1
• 38.0 MMBtu/hr Natural Gas-Fired Sand Dryer#2
• 360 kW Filter Press Generator
• Dry Plant #2 Material Handling
• Covered Baghouse Waste Collection Area
• Disturbed Area
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6 MODELED EMISSION SOURCES
6.1 Emission Sources
A description of each of the emission sources for the Wildcat Facility is summarized in Table 6-1. Emission
rates, expressed as PTE, are included in the tables within Section 6.2.1 of this AQIA. The PTE listed is
equivalent to operating the process on a yearly basis (8,760 hours per year). Wildcat is submitting a permit
modification application that will include the Facility’s emissions potential and calculations.
TABLE 6-1: EMISSION SOURCES FOR THE WILDCAT SAND PLANT
Emission Source Description Source Type
SILOTR Bucket Elevator Transfer to Silo Point
DRYER1 Dryer #1 Stack with Baghouse and Cyclone Point
DRYER2 Dryer #2 Stack with Baghouse and Cyclone Point
SCRNSTK J & H Screen Baghouse Exhaust Stack Point
SILOS Unloading Sand Storage Silos #1-#3 Point
FPGENSET Engine – Filter Press Point
2NDCRUSH Secondary Crushing Volume
TRNSDP1 Truck Unloading to Dry Plant #1 Volume
TRNSDP2 Truck Unloading to Dry Plant #2 Volume
TRNSWP Truck Unloading to Wet Plant Volume
TRNSWIP3 Truck Unloading to WIP Pile #3 Volume
HR2NDEXIT Haul Road – Additional Exit from Plant Line Volume
HRLDOUT Haul Road – Final Product Line Volume
HRWIP Haul Road – WIP Pile #2 to WIP Pile #3 Line Volume
HRLOAD Haul Road – Loader to Wet Plant Line Volume
HRDRY Haul Road – Loader to Dry Plant Line Volume
PILE1 Stockpile Pre-Wash Plant Area-Polygon
PILE2 WIP Stockpile #2 Area-Polygon
PILE3 WIP Stockpile #3 Area-Polygon
DISAREA Disturbed Area Area-Polygon
BHWASTE Covered Baghouse Waste Collection Area Area-Polygon
CONVYRS Conveyors and Drop Points Area-Polygon
CONVDRY2 Dry Plant #2 Conveyors Area-Polygon
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6.2 Criteria Pollutants
The Wildcat facility is comprised of emission sources capable of emitting PM10, PM2.5, CO, SO2, NO2, and
VOC. The pollutants of concern for modeling purposes are PM10 and NO2. A cumulative analysis to
demonstrate compliance with the NAAQS was done for PM10 and NO2.
6.2.1 Modeled Emission Rates for Cumulative Impact Analyses
The PTE for the source at the Wildcat facility are summarized in Tables 6-2, 6-3, 6-4, and 6-5. Emission
rates, expressed as PTE, are included in the permit modification application for the facility and are
provided in Appendix B. There was no unique handling of emissions in the modeling. All hours of the day
and the year were modeled for the Wildcat Sand Plant.
Tables 6-2, 6-3, 6-4, and 6-5 lists criteria pollutant emissions rates used in the Cumulative analyses.
TABLE 6-2: MODELED POINT SOURCE EMISSIONS RATES FOR CUMULATIVE ANALYSES
Stack
ID
PM10
(lb/hr)
NOX
(lb/hr)
SILOTR 0.0018 --
DRYER1 1.42 5.40
DRYER2 2.99 5.40
SCRNSTK 0.96 --
SILOS 0.0004 --
FPGENSET 0.03 2.13

TABLE 6-3: MODELED VOLUME SOURCE EMISSIONS RATES FOR CUMULATIVE ANALYSES
Stack
ID
PM10
(lb/hr)
NOX
(lb/hr)
2NDCRUSH 0.16 --
TRNSDP1 0.09 --
TRNSDP2 0.09 --
TRNSWP 0.18 --
TRNSWIP3 0.09 --

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TABLE 6-4: MODELED AREA SOURCE EMISSIONS RATES FOR CUMULATIVE ANALYSES
Stack
ID
PM10
(lb/hr)
NOX
(lb/hr)
PILE1 0.05 --
PILE2 0.14 --
PILE3 0.25 --
DISAREA 0.61 --
BHWASTE 0.01 --
CONVYRS 0.19 --
CONVDRY2 0.0003 --

TABLE 6-5: MODELED LINE VOLUME SOURCE EMISSIONS RATES FOR CUMULATIVE ANALYSES
Stack
ID
PM10
(lb/hr)
NOX
(lb/hr)
HR2NDEXIT 0.29 --
HRLDOUT 0.33 --
HRWIP 0.52 --
HRLOAD 1.35 --
HRDRY 0.46 --

6.3 Emission Release Parameters
The Wildcat facility includes emissions from point, area, volume, and line volume sources at the site. Table
6-6 lists stack parameters for the point sources. Table 6-7 lists parameters for the volume and line volume
sources. Table 6-8 lists parameters for the area sources. Source descriptions can be found in Table 6-1.

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TABLE 6-6: WILDCAT FACILITY POINT SOURCE STACK PARAMETERS
Release
Point
Description
UTMa
Coordinates Stack
Height
(m)
Stack Gas
Flow
Temp.
(K)c
Stack Gas
Flow
Velocity
(m/sec)d
Modeled
Stack
Diameter
(m)
Orient.
Of
Releasee Easting-X
(m)b
Northing-Y
(m)
SILOTR Transfer to Silos 593543.62 4453237.11 9.14 0.00 5.18 0.509 V
DRYER1 Dryer #1 Stack 593475.45 4453233.68 9.14 349.82 14.45 1.524 V
DRYER2 Dryer #2 Stack 593512.75 4453176.90 14.07 408.15 26.83 1.016 V
SCRNSTK Screen Baghouse 593472.39 4453218.29 9.09 0.00 2.52 1.890 H
SILOS Unloading Silos 593530.59 4453230.11 3.00 0.00 5.18 0.509 V
FPGENSET Engine-Filter Press 593231.59 4453298.00 2.69 1023.15 684.16 0.305 V
a. Universal Transverse Mercator.
b. Meters.
c. Kelvin.
d. Meters per second.
e. Vertical uninterrupted, rain-capped, or horizontal release.

TABLE 6-7: WILDCAT FACILITY VOLUME AND LINE VOLUME SOURCE RELEASE PARAMETERS
Source Description
UTMa
Coordinates Release
Height
(m)
Horizontal
Dimension
(m)
Vertical
Dimension
(m) Easting - X
(m)
Northing - Y
(m)
2NDCRUSH Secondary Crushing 593368.11 4453196.73 4.88 0.14 0.43
TRNSDP1 Truck Unloading - Dry Plant #1 593449.90 4453269.12 4.88 0.70 0.71
TRNSDP2 Truck Unloading - Dry Plant #2 593451.53 4453141.97 4.88 0.70 0.71
TRNSWP Truck Unloading - Wet Plant 593369.56 4453115.11 4.88 0.50 0.50
TRNSWIP3 Truck Unloading - WIP Pile #3 593083.52 4453308.57 4.88 0.35 0.71
HR2NDEXIT Haul Road - 2nd Exit from Plant 593394.40 4453074.27 3.40 -- --
HRLDOUT Haul Road - Final Product 593793.42 4453373.37 3.40 -- --
HRLOAD Haul Road - Loader to Wet Plant 593587.39 4453172.71 3.40 -- --
HRWIP Haul Road - WIP #2 to WIP #3 593291.29 4453213.54 3.40 -- --
HRDRY Haul Road - Loader to Dry Plant 593295.21 4453223.34 3.40 -- --
a. Universal Transverse Mercator
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TABLE 6-8: WILDCAT FACILITY AREA SOURCE RELEASE PARAMETERS
Source Description
UTMa
Coordinates
Release
Height
(m)
Vertical
Dimension
(m) Easting - X
(m)
Northing - Y
(m)
PILE1 Stockpile Pre-Wash Plant 593321.32 4453146.01 26.52 0.00
PILE2 WIP Stockpile #2 593324.56 4453263.72 18.29 0.00
PILE3 WIP Stockpile #3 593096.18 4453381.15 18.29 0.00
DISAREA Disturbed Area 593073.04 4453380.83 0.00 0.00
BHWASTE Covered Baghouse Waste Area 593454.02 4453224.82 1.52 0.00
CONVYRS Conveyors and Drop Points 593366.13 4453203.78 4.57 0.00
CONVDRY2 Dry Plant #2 Conveyors 593497.38 4453169.95 4.57 0.00
a. Universal Transverse Mercator

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7 MODELING METHODOLOGY
The summary of the modeling components for the AQIA can be found in Table 7-1. The details for the various modeling components are provided
in the following sections.
TABLE 7-1: MODELING PARAMETERS
Parameter Description/Values Documentation/Addition Description
General Facility Location Uintah County, Utah The area surrounding Roosevelt, Utah is partial non-attainment for Ozone as marginal.
Model AERMOD AERMOD with the PRIME downwash algorithm, version 22112.
Meteorological Data KVEL_2016-20.sfc
surface data
KVEL_2016-20.pfl
upper air data
The meteorological model input files for this project were developed by UDAQ. See Section 7.3 of
this report for additional details of the meteorological data.
Terrain Considered 3-dimensional receptor coordinates were obtained from USGS National Elevation Dataset (NED)
files and were used to establish elevation of ground level receptors. AERMAP was used to
determine each receptor elevation and hill height scale.
Building Downwash Considered Plume downwash was considered for the structures associated with the facility. BPIP-PRIME was
used to evaluate building dimensions for consideration of downwash effects in AERMOD.
Receptor Grid NAAQS Full Impact Analyses
Boundary Receptors 50-meter spacing along the ambient air boundary / property line.
Fine Grid 50-meter spacing in a 500-meter (easting) by 500-meter (northing) grid centered on the facility
Intermediate Grid 100-meter spacing in a 1,500-meter (easting) by 1,500-meter (northing) grid centered on the facility
Coarse Grid #1 250-meter spacing in a 3,000-meter (easting) by 3,000-meter (northing) grid centered on the facility
Coarse Grid #2 500-meter spacing in a 5,000-meter (easting) by 5,000-meter (northing) grid centered on the facility
Coarse Grid #3 1,000-meter spacing in a 11,000-meter (easting) by 11,000-meter (northing) grid centered on the
facility
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7.1 Model Selection
The Wildcat Facility incorporates emission sources including point, volume, line volume, and area sources.
Therefore, the emissions were modeled with EPA’s recommended guideline model, AERMOD, Version
22112, to evaluate air dispersion from multiple sources.
All pollutants were modeled using default regulatory modeling options. The USGS National Elevation
Dataset (NED) files were processed for the elevation data in the modeling using the AERMAP software,
Version 18081.
7.2 Model Options
The AERMOD regulatory settings of PM10 24-hour was selected for the PM10 analysis. The AERMOD
regulatory settings of NO2 1-hour was selected for the NOX analysis.
7.3 Meteorological Data
The AERMOD model was run using the five-year period (2016 – 2020) of meteorological data considered
representative of the climatology and topography of the facility location. The surface station data is from
the Vernal ASOS meteorological station – Vernal, Utah (KVEL) – which is approximately 25 miles to the
north-northeast of the Wildcat Facility. The upper air data is from the Grand Junction National Weather
Service Office – Grand Junction, Colorado, which is approximately 105 miles southeast of the Wildcat
Facility. This data set was processed by UDAQ using the AERMET program. The wind rose is attached in
Appendix C.
7.4 Effects of Terrain
The terrain surrounding the Wildcat site is relatively hilly. The surrounding terrain consists of various
ridges, and Ouray School Canal is along the south-southeast boundary. The Elevated Terrain mode was
used. Receptor elevations were entered based on elevations obtained from one (1) arc second (30 meter)
USGS National Elevation Dataset (NED) files. The datum of the NED files was UTM Zone 12 T NAD83.
7.5 Facility Layout
The Wildcat facility is located in Uintah County, Utah, which is designated as attainment or unclassifiable
for all criteria pollutants, except for ozone, which is marginal status for the area. The main entrance to the
Facility is located at UTM 4453372.27 N by 593801.10 E, Zone 12 T, NAD83. The surrounding area is a rural
area with terrain between 4,800 and 5,200 feet above mean sea level (MSL). A Plant Layout Map, detailing
the property boundary and surrounding area, is provided in Appendix A.
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7.6 Effects of Building Downwash
Based on the as-built facility design, buildings and/or structures can cause potential influences on normal
atmospheric flow in the immediate vicinity of the emission sources. Therefore, potential building
downwash was addressed by utilizing the Plume Rise Modeling Enhancement (PRIME) algorithms
contained within AERMOD to evaluate GEP stack heights and building dimensions. Table 7-2 summarizes
the building parameters used.
TABLE 7-2: WILDCAT FACILITY MODELED CIRCLE BUILDING PARAMETERS
UTM
Easting
UTM
Northing
Elev. Height Radius X Length Y Length Rotation
Angle
ID Description (m) (m) (m) (m) (m) (m) (m) Degrees
SILO1 Storage Silo #1 593517.56 4453223.11 1514.13 27.81 10.67 -- -- --
SILO2 Storage Silo #2 593530.59 4453230.11 1514.04 27.81 10.67 -- -- --
SILO3 Storage Silo #3 593543.62 4453237.11 1513.82 27.81 10.67 -- -- --
7.7 Ambient Air Boundary
Wildcat controls the facility boundary around the processing areas from the general public. Wildcat
installed signage around the property that includes “no trespassing” signs. General public access is
impeded to the south by a steep ridgeline that acts as a natural physical barrier. As well as a ridge to the
north of the facility that acts as a natural physical barrier. In addition, any visitors must check in at the
office when coming onto the property.
7.8 Receptor Network
The following grid resolutions were based on guidance provided by UDAQ, to sufficiently demonstrate
that areas of maximum impact from the emission sources remain below the applicable standards. On-site
receptors were disabled.
7.8.1 Boundary Receptors
Boundary receptors were placed along the entire property boundary every 50 meters in linear distance.
The ambient air boundary of the Facility is the property boundary and natural physical barrier of the
Wildcat Facility. The Wildcat Facility layout is provided in Appendix A. The receptor grid is provided in
Appendix D.
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7.8.2 Fine Grid
A fine grid of receptors was placed at 50-meter spacing, from the center of the emission sources outward
to 500 meters in all directions from the property boundary.
7.8.3 Intermediate Grid
An intermediate grid of receptors was placed at 100-meter spacing, from 500 meters outward to 1,500
meters in all directions from the property boundary.
7.8.4 Coarse Grid #1
A coarse grid of receptors was placed at 250-meter spacing, from 1,500 meters outward to 3,000 meters
in all directions from the property boundary.
7.8.5 Coarse Grid #2
A coarse grid of receptors was placed at 500-meter spacing, from 3,000 meters outward to 5,000 meters
in all directions.
7.8.6 Coarse Grid #3
A coarse grid of receptors was placed at 1,000-meter spacing, from 5,000 meters outward to 11,000
meters in all directions.
7.9 Background Concentrations
The modeled site is in Uintah County in Northeast Utah. The Wildcat Facility operates in an area that is
primarily rural. The 24-hour PM10, 1-hour NO2 and Ozone background data were provided by the UDAQ.
TABLE 7-4: PM10 BACKGROUND DATA (µg/m3)
Month 2021 2022 2023 Max Background
January 21 48 48
February 24 50 50
March 22 22
April 41 41
May 43 43
June 68 68
July 25 25
August 22 22
September 35 35
October 11 66 66
November 20 25 25
December 22 51 51
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TABLE 7-5: NO2 BACKGROUND DATA (PPB)
Month 2020 2021 2022 Max Background
January 26.8 25.8 26.9 26.5
February 26.8 25.2 30.8 27.6
March 17.2 17.6 21.8 18.9
April 18.7 12.5 19.9 17.0
May 10.2 11.6 16.6 12.8
June 8.7 14.7 15.3 12.9
July 9.5 17.3 16.9 14.6
August 17.0 20.5 19.4 19.0
September 19.6 14.8 21.5 18.6
October 18.1 14.8 24.5 19.1
November 18.8 20.3 25.0 21.4
December 24.1 24.6 40.3 29.7

TABLE 7-5: OZONE BACKGROUND DATA (PPM)
Month 2020 2021 2022 Max Background
January 0.065 0.074 0.044 0.061
February 0.059 0.067 0.072 0.066
March 0.056 0.065 0.066 0.062
April 0.058 0.064 0.063 0.062
May 0.068 0.068 0.063 0.066
June 0.065 0.069 0.071 0.068
July 0.067 0.079 0.069 0.072
August 0.082 0.083 0.067 0.077
September 0.062 0.075 0.063 0.067
October 0.067 0.057 0.052 0.059
November 0.053 0.047 0.047 0.049
December 0.058 0.045 0.059 0.054
Note:
PM10 Max 24-Hour, NO2 98% Max 1-Hour, and Ozone Max 1-Hour by Month data provided by UDAQ from the
Roosevelt Station

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8 RESULTS AND DISCUSSION
The dispersion modeling results presented in this AQIA demonstrate that the proposed emissions at the
Wildcat Facility will comply with all applicable UDAQ and National Ambient Air Quality Standards.
8.1 Criteria Pollutant Impact Results
The modeled concentrations of criteria pollutants were compared to the National Ambient Air Quality
Standards to demonstrate that the impacts will not cause or contribute to an exceedance of the NAAQS.
8.1.1 Cumulative NAAQS Impact Analysis
The cumulative modeling analysis was used to determine that the emissions from the sources at the
Wildcat Facility will not cause a violation of the National Ambient Air Quality Standards. The pollutants
modeled for the Cumulative NAAQS Impact Analysis were PM10 and NO2. Because there was an
exceedance of the SILs, further cumulative analysis was required on a pollutant-by-pollutant basis. The
dispersion modeling results show that the emissions of the Wildcat Facility will comply with all applicable
UDAQ and National Ambient Air Quality Standards.
8.1.1.1 Particulate Matter (PM10) Impact Analysis
The modeled emission rates and parameters for these emissions sources are listed in Appendix B. The
model inputs are provided in the AERMOD input and output files. The PM10 maximum modeled impacts,
when added to the background concentrations, are below the NAAQS. The modeling results are
summarized in Table 8-1. The Isopleths of the PM10 Cumulative Analysis can be found in Appendix E.
8.1.1.2 Nitrous Oxide (NO2) Impact Analysis
The modeled inputs are provided in the AWERMOD input and output files. The NO2 maximum modeled
impacts, when added to the background concentrations, are below the NAAQS, as shown in Table 8-1.
The Isopleths of the NO2 Cumulative Analysis can be found in Appendix F.
TABLE 8-1: RESULTS FOR CUMULATIVE NAAQS IMPACT ANALYSES
Pollutant Averaging
Period
Modeled Design
Concentration
(µg/m3)a
Background
Concentration
(µg/m3)
Total Impact
(µg/m3)
NAAQS
(µg/m3)
PM10 24-hour 100.82 Monthly 148.47 150
NO2 1-hour 69.16 Monthly 117.22 188
a. Micrograms/cubic meter
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9 QUALITY ASSURANCE / CONTROL
The quality assurance methods that took place for the modeling of the Wildcat Facility included peer
review of the emission rates, stack parameters, and source locations following the modeling runs for
Cumulative Analysis. Peer and client review took place on all of the modeling results and the AQIA reports.

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10 REFERENCES
1.) EPA, 2000. Meteorological Monitoring Guidance for Regulatory Modeling Applications.
EPA Publication No. EPA-454/R-99-005. U.S. Environmental Protection Agency, Research
Triangle Park, NC.

2.) EPA, 2019. User’s Guide For The AMS/EPA Regulatory Model-AERMOD. EPA Publication
No. EPA-454/B-16-011. U.S. Environmental Protection Agency, Research Triangle Park,
NC.

3.) EPA’s SCRAM Web site: http://www.epa.gov/scram/meteorological-guidance.

4.) EPA, 1985. Guideline for Determination of Good Engineering Practice Stack Height
(Technical Support Document for the Stack Height Regulations. EPA Publication No. EPA-
450/4-80-023R. U.S. Environmental Protection Agency, Research Triangle Park, NC

5.) EPA, 2018. Guidance on Significant Impact Levels for Ozone and Fine Particles in the
Prevention of Significant Deterioration Permitting Program. EPA Guidance. U.S.
Environmental Protection Agency, Research Triangle Park, NC.
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A-1

Appendix A – Facility Map

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Map
Prepared By:Revision: 2.0 Air Regulations Consulting, LLCDate Prepared: 6/12/2023 Title: Wildcat Sand, LLC –Facility Layout
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B-1

Appendix B – Cumulative Source Parameters

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Modeling Review Summary
Facility Name:Wildcat Sand Plant
Facility ID #:
County:Uintah
Nearby town:Roosevelt
Model used:AERMOD 22112
Surface data used:Vernal 2016-2020
Upper air data used:Grand Junction/Walker Field 2016-2020
Air boundary in model:Yes
Modeling input data:Wildcat Roosevelt Sand Plant 24-HR PM10 1-HR NO2
Wildcat Sand Plant - Project (point)
Emission point Emission point UTM X UTM Y Elevation Stack height Temperature Velocity Diameter PM10 NO2
Model ID description meters meters meters meters degrees K meters/sec meters lb/hr lb/hr
SILOTR Bucket Elevator Transfer to Silo 593543.62 4453237.11 1513.90 9.14 0.00 5.18 0.509 0.0018
DRYER1 Dryer #1 Stack with Baghouse and Cyclone 593475.45 4453233.68 1514.50 9.14 349.82 14.45 1.524 1.42 5.40
DRYER2 Dryer #2 Stack with Baghouse and Cyclone 593512.75 4453176.90 1514.40 14.07 408.15 26.83 1.016 2.99 5.40
SCRNSTK J & H Screen Baghouse Exhaust Stack 593472.39 4453218.29 1514.59 9.09 0.00 2.52 1.890 0.96
SILOS Unloading Sand Storage Silos #1 - #3 593530.59 4453230.11 1514.05 3.00 0.00 5.18 0.509 0.0004
FPGENSET Engine - Filter Press 593231.59 4453298.00 1516.30 2.69 912.59 7.65 0.305 0.03 2.13
Wildcat Sand Mine - Project (volume)
Emission point Emission point UTM X UTM Y Elevation Init. Lat.Init. Vert.Release PM10 NO2
Model ID description meters meters meters Dimension (m)Dimension (m)Height (m)lb/hr lb/hr
2NDCRUSH Secondary Crushing 593368.11 4453196.73 1515.57 0.14 0.43 4.88 0.16
TRNSDP1 Truck Unloading to Dry Plant #1 593449.90 4453269.12 1514.62 0.70 0.71 4.88 0.09
TRNSDP2 Truck Unloading to Dry Plant #2 593451.53 4453141.97 1514.62 0.70 0.71 4.88 0.09
TRNSWP Truck Unloading to Wet Plant 593369.56 4453115.11 1515.90 0.50 0.50 4.88 0.18
TRNSWIP3 Truck Unloading to WIP Pile #3 593083.52 4453308.57 1517.34 0.35 0.71 4.88 0.09
Wildcat Sand Mine - Project (line volume)
Emission point Emission point UTM X UTM Y Elevation Init. Lat.Init. Vert.Release PM10 NO2
Model ID description meters meters meters Dimension (m)Dimension (m)Height (m)lb/hr lb/hr
HR2NDEXIT Haul Road - Additional Exit from Plant 593394.40 4453074.27 1515.97 ----3.40 0.29
HRLDOUT Haul Road - Final Product 593793.42 4453373.37 1511.78 ----3.40 0.33
HRWIP Haul Road - WIP Pile #2 to WIP Pile #3 593291.29 4453213.54 1516.29 ----3.40 0.52
HRLOAD Haul Road - Loader to Wet Plant 593587.39 4453172.71 1513.79 ----3.40 1.35
HRDRY Haul Road - Loader to Dry Plant 593295.21 4453223.34 1516.08 ----3.40 0.46
Wildcat Sand Mine (area - polygon)
Emission point Emission point UTM X UTM Y Elevation Length of the X Side Length of the Y Side Init. Vert.Release PM10 NO2
Model ID description meters meters meters Dimension (m)Dimension (m)Dimension (m)Height (m)lb/hr lb/hr
PILE1 Stockpile Pre-Wash Plant 593321.32 4453146.01 1516.21 ----0.00 26.52 0.05
PILE2 WIP Stockpile #2 593324.56 4453263.72 1515.68 ----0.00 18.29 0.14
PILE3 WIP Stockpile #3 593096.18 4453381.15 1516.91 ----0.00 18.29 0.25
DISAREA Disturbed Area 593073.04 4453380.83 1517.14 ----0.00 0.00 0.61
BHWASTE Covered Baghouse Waste Collection Area 593454.02 4453224.82 1514.71 ----0.00 1.52 0.01
CONVYRS Conveyors and Drop Points 593366.13 4453203.78 1515.57 ----0.00 4.57 0.19
CONVDRY2 Dry Plant #2 Conveyors 593497.38 4453169.95 1514.54 ----0.00 4.57 0.0003
Wildcat Sand Mine - Project NAAQS Modeling
Pollutant Averaging Period
NAAQS Level
μg/m3
Significant
Impact Level
μg/m3
Modeled
Impact
μg/m3
Total w/ Background*
μg/m3
PM10 24-hour 150 5.00 100.82 148.47
NO2 1-hour 188 7.50 69.16 117.22
* Background data from the Utah Division of Air Quality - Roosevelt - monthly values.
Prepared by Air Regulations Consulting, LLC Page 1 of 1
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Appendix C
June 2023
_________________________________

C-1

Appendix C – Meteorological Analysis

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
WRPLOT View - Lakes Environmental Software
WIND ROSE PLOT:
KVEL - 2016 - 2020
Vernal ASOS Meteorological Station
COMMENTS:COMPANY NAME:
ARC
MODELER:
Sydney Stauffer
DATE:
5/18/2023
PROJECT NO.:
NORTH
SOUTH
WEST EAST
1.81%
3.62%
5.43%
7.24%
9.05%
WIND SPEED
(Knots)
>= 21.58
17.11 - 21.58
11.08 - 17.11
7.00 - 11.08
4.08 - 7.00
0.97 - 4.08
Calms: 1.22%
TOTAL COUNT:
43609 hrs.
CALM WINDS:
1.22%
DATA PERIOD:
Start Date: 1/1/2016 - 00:00
End Date: 12/31/2020 - 23:59
AVG. WIND SPEED:
5.25 Knots
DISPLAY:
Wind Speed
Direction (blowing from)
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Appendix D
June 2023
_________________________________

D-1

Appendix D – Receptor Domain

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Appendix D
June 2023
_________________________________

D-2

Figure D-1: Wildcat Facility Modeling Receptor Domain
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Appendix D
June 2023
_________________________________

D-3

Figure D-2: Wildcat Facility Modeling Facility Boundary Domain
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Appendix E
June 2023
_________________________________

E-1

Appendix E – Cumulative NAAQS and UDAQ Impact Analysis Isopleth – PM10

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Appendix E
June 2023
_________________________________

E-2

Figure E-1: 6th High PM10 – 24-hour (2016-2020) Isopleth Cumulative Impacts with Background

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Appendix F
June 2023
_________________________________

E-1

Appendix F – Cumulative NAAQS and UDAQ Impact Analysis Isopleth – NO2

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand AQIA
Appendix F
June 2023
_________________________________

F-2

Figure F-1: 8th High NO2 – 1-hour (2016-2020) Isopleth Cumulative Impacts with Background

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

EMISSIONS MODELING
FORMALDEHYDE MODELING RESULTS

DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7
Wildcat Sand
Formaldehyde Modeling
Emission Rate 0.003 lb/hr Emission Rate 0.0028 lb/hr Emission Rate 0.178 lb/hr
Air Flow Rate 20,955 DSCFM 0.01823 μg/m3 Air Flow Rate 50,000 DSCFM 0.000461 μg/m3 Air Flow Rate 40,000 DSCFM 11.93 μg/m3 11.95 μg/m3
0.00 mg/m3 0.00 mg/m3 0.01 mg/m3 0.01 mg/m3
Molecular Weight - Air 29 g/mol Molecular Weight - Air 29 g/mol Molecular Weight - Air 29 g/mol
MW - Formaldehyde 30.026 g/mol MW - Formaldehyde 30.026 g/mol MW - Formaldehyde 30.026 g/mol
ETF - Formaldehyde[1]0.154 m3lb/mg-hr 0.00 mg/m3 ETF - Formaldehyde[1]0.154 m3lb/mg-hr 0.00 mg/m3 ETF - Formaldehyde[1]0.154 m3lb/mg-hr 0.01 mg/m3 0.01 mg/m3
0.03 PPMv 0.01 PPMv 0.95 PPMv
0.75 ppm 0.75 ppm 0.75 ppm 0.75 ppm
0.04 mg/m3 0.92 mg/m3 0.01 mg/m3 0.92 mg/m3 1.17 mg/m3 0.92 mg/m3 0.92 mg/m3
Formaldehyde Rate 0.07962 m3lb/mg-hr Formaldehyde Rate 0.18998 m3lb/mg-hr Formaldehyde Rate 0.15198 m3lb/mg-hr
Modeling Required?Exceed?NO Modeling Required?Exceed?NO Modeling Required?Exceed?NO Exceed?NO
[1]Emission Threshold Factor: Vertically-Unrestricted Emission Release Points, 50 meters or less distance to property, Table 2, R307-410-5(1)(c)(i)(C)
8-hr TWA
NO
mg/m3 = 0.0409 x ppm x 30.026
PPMv = lb/hr/(MW x DSCFM x (1.554 x 10^-7))
1-hr Model Results
8-hr Model Results
8-hr TWA
0.7 Factor
mg/m3 = 0.0409 x ppm x 30.026
YES
Sand Dryer 1 Sand Dryer 2 Filter Press Engine
1-hr Model Results
8-hr Model Results
0.7 Factor
PPMv = lb/hr/(MW x DSCFM x (1.554 x 10^-7))
8-hr TWA
mg/m3 = 0.0409 x ppm x 30.026
NO
1-hr Model Results
8-hr Model Results
0.7 Factor
PPMv = lb/hr/(MW x DSCFM x (1.554 x 10^-7))
1-hr Model Results
8-hr Model Results
0.7 Factor
8-hr TWA
TOTAL
Prepared with assistance from Air Regulations Consulting, LLC
DocuSign Envelope ID: CBEFC1AA-76A1-4660-9E78-B63319ECDEC7

DAQE-MN159980004-23

M E M O R A N D U M

TO: Dylan Fredrick, NSR Engineer
FROM: Jason Krebs, Air Quality Modeler
DATE: August 17, 2023
SUBJECT: Modeling Analysis Review for the Notice of Intent for Wildcat Sand, LLC – Uintah County Sand Processing Plant, Uintah County, Utah
_____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.
I. OBJECTIVE
Wildcat Sand, LLC (Applicant) is seeking an approval order for their Uintah County sand
processing plant located in Uintah County, Utah.

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility will be in compliance with applicable State and Federal
concentration standards.

II. APPLICABLE RULE(S)
Utah Air Quality Rules:
R307-401-6 Condition for Issuing an Approval Order R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutants in Attainment Areas
R307-410-5 Documentation of Ambient Air Impacts for Hazardous Air Pollutants
III. MODELING METHODOLOGY

A. Applicability

Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. This modeling is part of a modified approval order. The emission rates for PM10, NOx, and Formaldehyde triggered the
requirement to model under R307-410. Modeling was performed by the Applicant.

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

JK
DAQE- MN15998004-23
Page 2
B. Assumptions

1. Topography/Terrain

The Plant is at an elevation 4975 feet with terrain features that have an affect on
concentration predictions.

a. Zone: 12
b. Approximate Location:
UTM (NAD83): 593455 meters East
4453216 meters North
2. Urban or Rural Area Designation
After a review of the appropriate 7.5-minute quadrangles, it was concluded the area is “rural” for air modeling purposes.
3. Ambient Air
It was determined the Plant boundary used in the AQIA meets the State’s definition of
ambient air.

4. Building Downwash
The source was modeled with the AERMOD model. All structures at the plant were used in
the model to account for their influence on downwash.

5. Meteorology

Five (5) years of off-site surface and upper air data were used in the analysis consisting of
the following:

Surface – Vernal, UT NWS: 2016-2020
Upper Air – Grand Junction, CO NWS: 2016-2020

6. Background
The background concentrations were based on concentrations measured in Roosevelt, Utah.
7. Receptor and Terrain Elevations

The modeling domain used by the Applicant consisted of receptors including property
boundary receptors. This area of the state contains mountainous terrain and the modeling
domain has simple and complex terrain features in the near and far fields. Therefore,
receptor points representing actual terrain elevations from the area were used in the
analysis.
DAQE- MN15998004-23
Page 3
8. Model and Options

The State-accepted AERMOD model was used to predict air pollutant concentrations under
a simple/complex terrain/wake effect situation. In quantifying concentrations, the
regulatory default option was selected.

9. Air Pollutant Emission Rates

Wildcat Sand, LLC
Source
UTM Coordinates Modeled Emission Rates
Easting Northing PM10
(m) (m) (lb/hr) (tons/yr) hrs/year
SILOTR 593544 4453237 0.0018 0.008 8760
DRYER1 593475 4453234 1.4200 6.220 8760
DRYER2 593513 4453177 2.9900 13.096 8760
HR2NDEXIT 593394 4453074 0.2900 1.270 8760
HRLDOUT 593793 4453373 0.3300 1.445 8760
HRWIP 593291 4453214 0.5200 2.278 8760
HRLOAD 593587 4453173 1.3500 5.913 8760
SCRNSTK 593472 4453218 0.9600 4.205 8760
2NDCRUSH 593368 4453197 0.1600 0.701 8760
PILE1 593321 4453146 0.0500 0.219 8760
TRNSDP1 593450 4453269 0.0900 0.394 8760
TRNSDP2 593452 4453142 0.0900 0.394 8760
TRNSWP 593370 4453115 0.1800 0.788 8760
TRNSWIP3 593084 4453309 0.0900 0.394 8760
PILE2 593325 4453264 0.1400 0.613 8760
PILE3 593096 4453381 0.2500 1.095 8760
CONVYRS 593366 4453204 0.1900 0.832 8760
SILOS 593531 4453230 0.0004 0.002 8760
FPGENSET 593232 4453298 0.0300 0.131 8760
DISAREA 593073 4453381 0.6100 2.672 8760
CONVDRY2 593497 4453170 0.0003 0.001 8760
BHWASTE 593454 4453225 0.0100 0.044 8760
HRDRY 593295 4453223 0.4600 2.015 8760
OLDGEN 593509 4453191 0.0000 0.000 8760
Total 10.2125 44.7309

DAQE- MN15998004-23
Page 4
Wildcat Sand, LLC
Source
UTM Coordinates Modeled Emission Rates
Easting Northing NOx
(m) (m) (lb/hr) (tons/yr) hrs/year
DRYER1 593475 4453234 5.4000 23.652 8760
DRYER2 593513 4453177 5.4000 23.652 8760
FPGENSET 593232 4453298 2.1300 9.329 8760
OLDGEN 593509 4453191 0.9200 4.030 8760
Total 13.8501 60.6633
Kinder Morgan Altamont East Compressor Station
Source
UTM Coordinates Modeled Emission Rates
Easting Northing NOx
(m) (m) (lb/hr) (tons/yr) hrs/year
KMEAST 564020 4467280 78.1904 342.474 8760
Total 78.1904 342.4740
Wildcat Sand, LLC
Source
UTM Coordinates Modeled Emission Rates
Easting Northing Formaldehyde
(m) (m) (lb/hr) (tons/yr) hrs/year
DRYER1 593475 4453234 0.0030 0.013 8760
DRYER2 593513 4453177 0.0028 0.012 8760
FPGENSET 593232 4453298 0.0000 0.000 8760
Total 0.0058 0.0254
10. Source Location and Parameters
Source Type
Source Parameters
Elev, Ht Temp Flow Dia Sigma-
Y
Sigma-
Z
X-
Dim
Y-
Dim Area
(ft) (m) (ft) (K) (m/s) (m) (m) (m) (m) (m) (m^2)
SILOTR POINT 4966.9 9.1 30.0 0 5.18 0.51 1
DRYER1 POINT 4968.8 9.1 30.0 350 14.45 1.52 1
DRYER2 POINT 4968.5 14.1 46.2 408 26.83 1.02 1
DAQE- MN15998004-23
Page 5
HR2NDEXIT LINE_VOLUME 1
HRLDOUT LINE_VOLUME 1
HRWIP LINE_VOLUME 1
HRLOAD LINE_VOLUME 1
SCRNSTK POINT 4969.1 9.1 29.8 0 2.52 1.89 1
2NDCRUSH VOLUME 4972.3 4.9 16.0 0.14 0.43 0.6106 1
PILE1 AREA_POLY 4974.4 26.5 87.0 2374.3
TRNSDP1 VOLUME 4969.2 4.9 16.0 0.70 0.71 3.0014 1
TRNSDP2 VOLUME 4970.5 4.9 16.0 0.70 0.71 3.0014 1
TRNSWP VOLUME 4973.4 4.9 16.0 0.50 0.50 2.15 1
TRNSWIP3 VOLUME 4978.1 4.9 16.0 0.35 0.71 1.5179 1
PILE2 AREA_POLY 4972.7 18.3 60.0 6150.5
PILE3 AREA_POLY 4976.7 18.3 60.0 11249.7
CONVYRS VOLUME 4972.3 4.6 15.0 1.50 1.50 6.45 1
SILOS POINT 4967.4 3.0 9.8 0 5.18 0.51 1
FPGENSET POINT 4974.7 2.7 8.8 913 7.65 0.30 1
DISAREA AREA_POLY 4977.5 0.0 0.0 72912.6
CONVDRY2 VOLUME 4969.0 4.6 15.0 1.42 1.50 6.1017 1
BHWASTE AREA_POLY 4969.5 1.5 5.0 76.9
HRDRY LINE_VOLUME 1
OLDGEN POINT 4967.8 3.3 10.8 913 7.65 0.30 1
KMEAST POINT 6107.3 9.5 31.2 700 21.19 0.31 1

IV. RESULTS AND CONCLUSIONS

A. National Ambient Air Quality Standards

The below table provides a comparison of the predicted total air quality concentrations with the NAAQS. The predicted total concentrations are less than the NAAQS.

Air Pollutant Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
NO2 1-Hour 29.4 7.5 84.3 13.4 127.1 188 67.61%

Air
Pollutant
Period Prediction Class II
Significant
Background Nearby
Sources*
Total NAAQS Percent
DAQE- MN15998004-23
Page 6
Impact
Level
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-
Hour 100.70 5 47.7 0.0 148.4 150 98.93%
B. Toxic Screening Levels

The model predicted all HAP concentrations to be less than their respective UDAQ - Toxic
Screening Levels (TSL) for each scenario. Based on these results, no further analysis is
required.

Pollutant Period Prediction TSL Percent
(μg/m3) (μg/m3)
Formaldehyde 1-Hour 0.048 37 0.1%

JK:jg

GENERAL DATA
• Water-cooled, turbo-charged, air-to-air inter-cooled,
stoichiometric with replaceable wet cylinder liners
• Cast iron block & heads, 10.5:1 compression ratio,
overhead valve/2V configuration
• Crankshaft gear-driven oil system with cartridge-type
filter, belt-driven centrifugal water pump
• 24VDC Starter and Alternator
• CANBUS J1939 interface
• 3-Way Catalytic Converter
• UL-recognized air filtration
• Integrated knock sensing and control
• Full ECU engine control with coil-on-plug variable timing ignition
• Engine protection for oil pressure, coolant level, coolant
temperature, fuel pressure, over-speed
The PSI HD 21.9L is a U.S. EPA-certified natural gas and
propane engine developed from the block up to be a
reliable and durable power unit. Built upon a proven
marine-diesel grade block, the 12-cylinder V-Configuration,
turbocharged and after-cooled engine features
replaceable wet liners and water-cooled exhaust.
Superior engine performance is driven by an ECU that
integrates and coordinates all critical functions including:
Governor, Variable Ignition Timing, Air Fuel Ratio Control,
Knock Suppression and Engine Protection.
PSI is the market leader in providing heavy-duty products. PSI
has seven models in its HD product lineup with displacements of
8.1L, 11.1L, 14.6L, 18.3L, 21.9L and 29.2L. These engines are an
extension of the PSI product line, which is based upon blocks from
650cc to 8.8L. All PSI engines feature the same fuel systems and
controls, simplifying your application development and support.
21.9 L INDUSTRIALSTATIONARY
90.3 in / 2,294 mm
83.6 in2,124 mm
75.3 in / 1,914 mm
FEATURES
• U.S. EPA-Certified and CARB-Compliant, Industrial Stationary
• 50C Ambient Cooling Capacity
• UL2200-Compliant or Listed Components
• MasterTrak Telematics service (included for 1 year)
GENERATION 2 ENHANCEMENTS
• Enhancements for prime & continuous power
• Dual Fuel Auto Switch-Over
• Brushless Alternators
• Serpentine, Self-Tensioning Fan Belt
• Advanced diagnostics for improved up-time
PSI 21.9-LITER ENGINE DATA
Model Number
Cylinders
Induction system
Combustion system
Cooling system
Displacement
Compression ratio
Bore & Stroke
Fuel Type
Direction of rotation
Dry Weight
D219L
90˚, V-12
Turbocharged & air-to-air charge cooled
Spark-ignited
Water-cooled
1,338 cid (21,561 cc)
10.5:1
5.04 in x 5.59 in (128 mm x 142 mm)
Natural Gas / Propane
Anti-clockwise viewed on flywheel
3,638 lb (1,650 kg)
kWe
Standby*
Prime*
NG
LPG
NG
LPG
1500 RPM
410 kWe
262 kWe
369 kWe
236 kWe
1800 RPM
450 kWe
315 kWe
405 kWe
284 kWe
(standard radiator shown)
*Assumes 10% losses for fans and genset. Ratings subject to PSI application and duty cycle guidelines.
Doosan PSI LLC 1465 Hamilton Parkway, Itasca, IL 60143 USA
T: 888-643-6373 • F: 847-886-4162 • doosanpsi.com
1/31/24, 3:35 PM State of Utah Mail - Wildcat Sand information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-8403414719130889070&simpl=msg-a:r-8403414719130…1/1
Dylan Frederick <[e-mail]>
Wildcat Sand information Request
Dylan Frederick <[e-mail]>Wed, Oct 25, 2023 at 6:57 AM
To: Eric Sturm <[e-mail]>
Cc: Matt Hyita <[e-mail]>, Sydney Stauffer - ARC <[e-mail]>
Eric,
Thanks for reaching out. I've got some more requests for this application to consider it complete:
1. I found an error in the emission summary, there doesn't seem to be SO2 emissions added for the old dryer. I think
it's supposed to 0.1 tpy, please fix this error.
2. I can't tell what the emissions are supposed to be calculated at for the dryers. In the original NOI, they are listed at
23.65 tpy each for NOx. In the new BACT section, they are listed at 16.35, but this doesn't seem to match the emission
factor and natural gas consumption rate given in these tables. I also don't understand why the emissions for the dryers
are considered the same when they have slightly different ratings.

3. Can you confirm I have the correct HAP totals for the following pollutants for the facility? Perhaps a HAPs summary
table would be helpful here as well.
Hexanes - 0.6227 tpy
Acrolein - 0.076 tpy
Formaldehyde - 0.8063 tpy
Methanol - 0.370 tpy
Acetaldehyde - 0.124 tpy.
4. The BACT section for material handling on the last BACT submission cuts off before making a conclusion. I think the
intention was for it to state water sprays as BACT, but can you fix this section so it's clear?"
5. The BACT section for the Dryer burners is very confusing as written, and I'm not sure if the right calculations are
presented in this section. For example, the current section says the uncontrolled emissions are 16.34 tpy, but as stated
above and in the written explanation preceding these calculations, the uncontrolled total is supposed to be 23.65.
Additionally, does the starjet LNB option have the same heating efficiency issues that the FGR burners do? I'm referring to
the necessary increase in dryer size to reach the requested 150 ton per hour sand drying rate. I think there was a
miscommunication here, as the new table "without loss" removed the cost of increased use of natural gas, which can be
included in the economic impacts section, but still includes the "annual burner tuning" figure, which is based entirely on
potential lost profit from shutdown time while the burner is tuned, which is what I intended to say was what should be
removed from the tables. I can see why this might be considered a "Local Economic Impact" per EPA guidance, but I think
that is supposed to be considered separately on its own merits, as to avoid altering the economics of a project
substantially enough that the project would no longer be considered. In terms of considering the cost effectiveness of a
control technology, I should be evaluating the incremental cost of upgrading to a new technology. This brings up my final
point, which is I'm not sure that the incremental cost is being given, as I don't see the cost figure for the uncontrolled
burner included in the analysis. There isn't a cost listed for the burner as is without LNB or FGR technology, and the direct
cost of the upgraded technologies should be evaluated minus the cost of the existing burner, so that only the increased
cost to upgrade is considered in the evaluation.
There is a lot to discuss with point #5, so I think it would be worth having a video call to go over everything there. Please
let me know if there is a time this week where we can discuss these changes to the application. Some of these issues
come from the fact that I don't have the spreadsheets that these calculations were done in, so if possible it might be worth
including those with the next submission for this application. Thank you,
Dylan
[Quoted text hidden]
1/31/24, 3:37 PM State of Utah Mail - Wildcat Sand information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1784114771899122962&simpl=msg-f:1784114771899122…1/14
Dylan Frederick <[e-mail]>
Wildcat Sand information Request
Eric Sturm <[e-mail]>Fri, Dec 1, 2023 at 2:00 PM
To: Dylan Frederick <[e-mail]>, Sydney Stauffer <[e-mail]>
Hi Dylan,

The engine was manufactured in 2014. It appears we may have grabbed the wrong line of emission rates from the NSPS
JJJJ’s Table 1. Sorry for the confusion on that.

Then engine can meet the 2011 standards and is certified to do so. We can revise the BACT/Application and emission
calculations accordingly.

This should not take us too long. After we address this, will the DAQ need anything further?

Thanks.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Friday, December 1, 2023 10:45 AM
To: Sydney Stauffer <[e-mail]>
Cc: Eric Sturm <[e-mail]>
Subject: Re: Wildcat Sand information Request

Eric and Sydney,

I've found one final issue that needs to be addressed with the application before the application can be considered
complete. The current proposal for the engine is to replace the previous 415 hp engine with a 482 hp (360 kW) engine.
When was this engine manufactured? The BACT analysis given in the application/BACT addendums state that the
emission rates in NSPS JJJJ are 2 g/hp-hr NOx, and 4 g/hp-hr CO, but according to Table 1 where these rates are taken
from, this standard could be 1 gp/hp-hr NOx and 2 g/hp-hr CO if manufactured after the applicability date listed in this
1/31/24, 3:37 PM State of Utah Mail - Wildcat Sand information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1784114771899122962&simpl=msg-f:1784114771899122…2/14
section. Moreover, it would be best to consider the feasibility of this emission rate or purchase of an engine that can meet
this emission limit regardless, since the limits established in this subpart are more than a decade old and it's reasonable
to assume these standards are technically feasible to achieve by now. If this is not possible for Wildcat Sand, we would
need an economic analysis to determine why this emission rate is not feasible for this engine. Finally, if the lower
emission rate is reasonable, I would request the emission calculations for the engine be resubmitted to adjust to the new
NOx, CO, and PM emission rates. Feel free to reach out for a meeting time to discuss this request. Thank you for your
help with this issue,

Dylan

On Fri, Nov 3, 2023 at 9:35 AM Sydney Stauffer <[e-mail]> wrote:
Good morning, Dylan,

Thank you for meeting with Eric and me on Tuesday to discuss the comments you sent on October 25. Please see the
attached document with the responses and the updated tables as discussed on the call.

Thank you and enjoy your weekend,

Sydney Stauffer
ARC | Environmental Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.416.8416
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, October 31, 2023 10:55 AM
To: Eric Sturm <[e-mail]>
Cc: Sydney Stauffer <[e-mail]>; Matt Hyita <[e-mail]>
Subject: Re: Wildcat Sand information Request

Eric,

I can do 2pm today if you're still open at that time.

On Mon, Oct 30, 2023 at 6:46 PM Eric Sturm <[e-mail]> wrote:
Hey Dylan, it looks like I can't do Wednesday. Sorry, something popped up. Can we do 11am or 2pm tomorrow
(Tuesday)?
Eric Sturm, ARC
m. 402.310.4211
EPA Certified / Stationary Emergency
OUTPUT POWER OPTIONS Natural Gas
STANDBY RATING
LP Vapor
STANDBY RATING
sKVA
Make Voltage Alternator Phase Hertz kW/kVA Amps kW/kVA Amps 30%VoltageDip
Stamford 600 HCI534C17 3 60 400/500 482 295/396 355 1360
277/480 HCI534C311 3 60 400/500 602 295/369 444 1480
120/208 HCI534C311 3 60 400/500 1390 295/369 1025 1145
120/240 HCI534C311 3 60 400/500 1204 295/369 888 1145
120/240 HCI534C311 1 60 210/210 875 210/210 875 765
Stamford 277/480 HCI534D311 3 60 400/500 602 295/369 444 1750
120/208 HCI534D311 3 60 400/500 1390 295/369 1025 1390
120/240 HCI534D311 3 60 400/500 1204 295/369 888 1390
120/240 HCI534D311 1 60 230/230 958 230/230 958 930
Marathon 600 433PSL6248 3 60 400/500 482 295/369 355 1380
277/480 433CSL6220 3 60 400/500 602 295/369 444 1469
120/208 433CSL6220 3 60 400/500 1390 295/369 1025 1103
120/240 433CSL6220 3 60 400/500 1204 295/369 888 1103
120/240 433CSL6220 1 60 241/241 1004 241/241 1004 430
947 Industrial Park Drive • Clinton, MS 39056 • Phone [phone] • Fax [phone] • www.taylorpower.com
TG400
application and engineering data
®
Engine Data
Manufacturer PSI
Model 21.9L
Aspiration Turbocharged
Arrangement V-12, 4-Cycle
Firing Order 1-12-5-8-3-10-6-7-2-11-4-9
Displacement: L (in.³)21.9 (1338.0)
Bore: mm (in.)128.00 (5.04)
Stroke: mm (in.)142.00 (5.59)
Compression Ratio 10.5:1
Gross Horsepower: Natural Gas
LP Vapor
684
472
BMEP: psi (kPa) Natural Gas
LP Vapor
225.00 (1551.32)
155.00 (1068.70)
Rated RPM 1800
Governor Isochronous
Speed Regulation ±0.50%
Engine Liquid Capacity
Oil System: qt. (L)38.5 (36.5)
Cooling Capacity: gal (L)50.1 (189.6)
Engine Electrical
Electric Volts: DC 24
Cold Cranking Amps 1100
Battery(s) Required 2
Fuel System
Fuel Supply Size: Natural Gas
LP Vapor
3.00” NPT
3.00” NPT
Supply Pressure: in. H₂O (kPa)7-11 (1.74-2.74)
Air Requirements
Air Filter(s) Type Dry
Combustion Air Flow: CFM (m³/min)968 (27)
Maximum Air Intake Restriction
Clean: in. H₂O (kPa)3.00 (1.24)
Dirty: in. H₂O (kPa)15.00 (3.74)
Radiator Air Flow: CFM (m³/min)40,000 (1133)
Exhaust System
Gas Temperature: °F (°C)1382 (750)
Gas Flow: CFM (m³/min)2995.0 (84.8)
Max Back Pressure: in. H₂O (kPa)40.9 (10.2)
Filters and Quantity
Air Cleaner Quantity 1
Oil Filter(s) Quantity 1
Fuel Consumption - Natural Gas
At 100% of Power Rating: CFH (m³/hr)4231 (119.8)
At 75% of Power Rating: CFH (m³/hr)3298 (93.4)
At 50% of Power Rating: CFH (m³/hr)2317 (65.6)
At 25% of Power Rating: CFH (m³/hr)1413 (40.0)
Fuel Consumption - LP Vapor
At 100% of Power Rating: CFH (m³/hr)1409 (39.9)
At 75% of Power Rating: CFH (m³/hr)1201 (34.0)
At 50% of Power Rating: CFH (m³/hr)809 (22.9)
At 25% of Power Rating: CFH (m³/hr)512 (14.5)
GENERAL GUIDELINES FOR DERATION: Altitude: Derate 0.5% per 100m (328 ft.) Elevation above 1000m (3279 ft.) Temperature: Derate 1.0% per 10°C (18°F) temperature
above 25°C (77°F)
RATINGS: All three-phase units are rated at 0.8 power factor. All single-phase units are rated at 1.0 power factor.
125°RATINGS: 125° apply to installations served by a reliable utility source. The standby rating is applicable to varying loads for the duration of a power outage. There is no
overload capability for this rating. Ratings are in accordance with ISO-3046/1, BS 5514, AS 2789, and DIN 6271.For limited running time and base load ratings consult the
factory. The generator set manufacturer reserves the right to change the design or specifications without notice and without any obligation or liability whatsoever.
®®
alternator and controller data
Control Panels
DeepSea 7310 MKII
Simultaneous Use of RS232 & RS485
Modbus RTU Support
Fully Configurable Using USB, RS232 &
RS485
IP65 Rating
6 Programmable Inputs & 8 Outputs
UL & cUL Listed and CE Certified
Taylor Analog
Automatic CANBUS Engine Control
Gauge Zeroing on Shutdown
Auto-Off-Manual Control Switch
Oil Pressure, Water Temperature, Battery
Voltage and RPM Gauges
AC Voltage, Frequency, Percent of Load,
and Run-Time Metering
LED Status Lights
Basler DGC2020
SAE J1939 Engine ECU Communications
4 Programmable Inputs & 10 Outputs
Modbus Communications With RS485
UL Recognized, CSA & CE Certified
IP 54 Front Panel Rating
NFPA 110 Level 1 Compatible
Manual Override Keyswitch
DGC2020HD Variant Available
Alternator Data
Manufacturer Marathon
Type PMG
Insulation Class NEMA N
Temperature Rise 125°C Standby
Hertz 60
RPM 1800
Amortisseur Windings Full
CFM Cooling Required 800
Voltage Regulator DVR2400 PM500
Sensing Three Phase Three Phase
Voltage Regulation 0.25%0.25%
Features
• NEMA MG1-32, BS5000, and IEC 34-1 compliant;
CE & CSA Certified and UL Listed
• Self-ventilated and drip proof construction
• Two-thirds pitch stator and skewed rotor
• Wet wound, epoxied field windings
• Designed to withstand overspeeds of up to 125%
• Hybrid analog/digital voltage regulator
• Under frequency protection
• Under frequency indication light
• Less than one cycle response time
• Over excitation protection
• Over excitation indication light
• Easy access front-panel adjustments
• Over voltage protection shutdown
Alternator Data
Manufacturer Stamford
Type PMG
Insulation Class NEMA H
Temperature Rise 125°C Standby
Hertz 60
RPM 1800
Amortisseur Windings Full
CFM Cooling Required 2780
Voltage Regulator MX341 MX321
Sensing Single Phase Three Phase
Voltage Regulation 1.0%0.50%
Features
• BS EN 60034, BS5000, VDE 0530, NEMA MG1-32,
IEC34, CSA C22.2-100, and AS1359 complaint
• IP23 enclosure
• Dynamically balanced to exceed BS6861:Part 1 Grade 2.5
vibration standard
• Quality assurance to BS EN ISO 9001
• Self-ventilated and Drip proof construction
• Two-thirds pitch stator and skewed rotor
• Heavy duty bearings
• Fully guarded
• Overexcitation protection
• Under frequency protection
• Analog input
• Overvoltage protection
• Paralleling compatible
standard features and options
®
Controller Options
DGC2020HD Controller
Fiber Optic Ethernet (DGC2020HD)
RS-232 Port & Generator Protection (DGC2020)
Flush or Surface Mount Remote Annunciator
Remote Mount Break Glass E-Stop Switch
Warranty
2 Year Standard
5 Year Comprehensive
Miscellaneous Options:
Generator Strip Heater Pad Type Battery Heater
Spring Isolators Battery Heater Blanket
Line Circuit Breaker Oil Pan Heater
Standard Features:
Heavy Duty Steel Base Battery Charger
Vibration Isolators Block Heater
Oil Drain Valve with Extension Factory Powder Coating
Coolant Drain Kit Factory Load Test
High Ambient Unit Mounted Radiator Owner’s Manual
Open Unit
Options:
• Radiator Duct Flange
• Flex Exhaust
• Critical Silencer
Overall Size: 140”L x 90”W x 98”H
Approximate Weight: 11,250 lbs.
Note: Dimensions and weights reflect standard
open unit with no options and are subject to
change.
Standard Enclosed Unit
Options:
• Sound Attenuated Enclosure
• Load Center, Lights & GFI Receptacle
Overall Size: 186”L x 90”W x 106”H
Approximate Weight: 13,500 lbs.
Note: Dimensions and weights reflect standard
enclosed unit with no options and are subject to
change.
Note: The above drawings are provided for reference only and should not be used for planning installation.
Contact your local distributor for more information.04/23
1/31/24, 3:31 PM State of Utah Mail - Wildcat Sand information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1789563792212908980&simpl=msg-f:1789563792212908…1/17
Dylan Frederick <[e-mail]>
Wildcat Sand information Request
Eric Sturm <[e-mail]>Tue, Jan 30, 2024 at 5:30 PM
To: Dylan Frederick <[e-mail]>
Cc: Sydney Stauffer <[e-mail]>, Matt Hyita <[e-mail]>
Hi Dylan,

Thanks for sending these over. Answers below. Could you also send us your dra permit for review? It would
probably be helpful for us to start reviewing now.

1. Yes, each dryer has a cyclone before the baghouse.
2. The baghouse systems are separate; 2 dryers and 2 baghouses, with separate roung so that only 1 baghouse
is controlling 1 dryer.

Hope that helps.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
.VCF | LinkedIn

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 30, 2024 5:07 PM
To: Eric Sturm <[e-mail]>
Cc: Sydney Stauffer <[e-mail]>
Subject: Re: Wildcat Sand informaon Request

Hey all,
1/31/24, 3:31 PM State of Utah Mail - Wildcat Sand information Request
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1789563792212908980&simpl=msg-f:1789563792212908…2/17

I got the compliance review back, and they had a couple questions I wanted to run by you to confirm so I can move the
permit along.

1. I've added a cyclone to the equipment list as the application noted the cyclone is in sequence with a baghouse to
control the dryers, is this correct?

2. Is there a baghouse on each sand dryer? Or are both dryers routing to the same baghouse/dryer system?

3. Compliance indicated the Fuel Oil storage tank mentioned in the permit was found to be 1,000 gallons in the last
inspection done for the facility. Is that the correct size, or is the correct size 5,000 gallons?

Thank you for any help you can provide

On Wed, Jan 24, 2024 at 2:23 PM Dylan Frederick <[e-mail]> wrote:
Hey all,

Sorry for taking a bit to get back to you. The project is currently being reviewed by compliance, and will be ready for
management review soon. If everything goes smoothly I should have this project out to public comment by the first
week of February. I will keep you updated if anything changes.

On Thu, Dec 28, 2023 at 11:35 AM Eric Sturm <[e-mail]> wrote:
Dylan,

Happy holidays. Hope you are doing well. We wanted to touch base and see how things are going. Could we get
an update on Wildcat’s AO – are we close to having something for review?

We would like to get this to public notice in early January. If there is anything holding you up that you need from us,
please let us know.

Best.

Eric Sturm
ARC | Principal, Sr. Consultant
W: https://airregconsulting.com
P: 402.817.7887
M: 402.310.4211
Equipment Details
Rating 482 hp = (360 kw)
Operational Hours 8,760 hours/year
Engine Type
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission Factor
(lb/MMBtu)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 1.0 1.06 4.66
CO 2.0 2.13 9.32
PM10 9.99E-03 0.03 0.15
PM2.5 9.99E-03 0.03 0.15
VOC 1.18E-01 0.40 1.75
SO2 5.88E-04 0.00 0.01
HAP 0.24 1.07 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission Factor
(lb/MMBtu)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 1.10E+02 371 1,627
Methane (mass basis)25 1.25E+00 4 18
CO2e 2,089
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
1,1,2,2-Tetrachloroethane 4.00E-05 1.35E-04 5.92E-04
1,1,2-Trichloroethane 3.18E-05 1.07E-04 4.70E-04
1,3-Butadiene 2.67E-04 9.02E-04 3.95E-03
1,3-Dichloropropene 2.64E-05 8.91E-05 3.90E-04
2,2,4-Trimethylpentane 2.50E-04 8.44E-04 3.70E-03
2-Methylnaphthalene 3.32E-05 1.12E-04 4.91E-04
Acenaphthene 1.25E-06 4.22E-06 1.85E-05
Acenaphthylene 5.53E-06 1.87E-05 8.18E-05
Acetaldehyde 8.36E-03 2.82E-02 1.24E-01
Acrolein 5.14E-03 1.74E-02 7.60E-02
Benzene 4.40E-04 1.49E-03 6.51E-03
Benzo(b)fluoranthene 1.66E-07 5.61E-07 2.46E-06
Benzo(e)pyrene 4.15E-07 1.40E-06 6.14E-06
benzo(g,h,i)perylene 4.14E-07 1.40E-06 6.12E-06
Biphenyl 2.12E-04 7.16E-04 3.14E-03
Carbon Tetrachloride 3.67E-05 1.24E-04 5.43E-04
Chlorobenzene 3.04E-05 1.03E-04 4.50E-04
Chloroform 2.85E-05 9.62E-05 4.22E-04
Chrysene 6.93E-07 2.34E-06 1.02E-05
Ethylbenzene 3.97E-05 1.34E-04 5.87E-04
Ethylene Dibromide 4.43E-05 1.50E-04 6.55E-04
Fluoranthene 1.11E-06 3.75E-06 1.64E-05
Fluorene 5.67E-06 1.91E-05 8.39E-05
Formaldehyde 5.28E-02 1.78E-01 7.81E-01
Methanol 2.50E-03 8.44E-03 3.70E-02
Methylene Chloride 2.00E-05 6.75E-05 2.96E-04
n-Hexane 1.11E-03 3.75E-03 1.64E-02
Naphthalene 7.44E-05 2.51E-04 1.10E-03
PAH 2.69E-05 9.08E-05 3.98E-04
Phenanthrene 1.04E-05 3.51E-05 1.54E-04
Phenol 2.40E-05 8.10E-05 3.55E-04
Pyrene 1.36E-06 4.59E-06 2.01E-05
Styrene 2.36E-05 7.97E-05 3.49E-04
Tetrachloroethane 2.48E-06 8.37E-06 3.67E-05
Toluene 4.08E-04 1.38E-03 6.03E-03
Vinyl Chloride 1.49E-05 5.03E-05 2.20E-04
Xylene 1.84E-04 6.21E-04 2.72E-03
Emission Factor
(lb/MMBtu)
Natural Gas-Fired Engines
AP-42 Table 3.2-1,
Table 3.2-2, &
Table 3.2-3
AP-42 Table 3.2-1,
Table 3.2-2, &
Table 3.2-3
(Some HAP do not
popluate based on
the type of engine
selected. AP-42
does not list certain
HAP for certain types
of engines.)
Manufacturer Data,
AP-42 Table 3.2-1,
Table 3.2-2, &
Table 3.2-3
4-Stroke Lean-Burn
Emergency Engines should
equal 100 hours of
operation per year
Page 1 of 1 Version 1.1
February 21, 2019
Prepared with Air Regulations
Consulting, LLC AssistanceWildcat Sand - Roosevelt Plant
Sand Plant
Emission Calculations
Facility PTE - 8760 hr/yr
PTE (lb/hr)
Emission
Type Unit
Particulate
Matter <10μ
(PM10)
Particulate
Matter <10μ
(PM10)
Particulate
Matter <2.5μ
(PM2.5)
Nitrogen Oxides
(NOX)
Sulfur Oxides
(SOX)
Carbon
Monoxide
(CO)
Volatile Organic
Compounds
(VOC)
Lead
Compounds
Hazardous Air
Pollutants
(HAPs)
Point 01 Bucket Elevator Transfer to Silo**SILOTR 0.0018 0.0079 0.0012
Point 02 Dryer #1 Stack with Baghouse and Cyclone DRYER1 1.4200 6.2200 6.2200
Point 02 Dryer #1 Combustion DRYER1 23.6500 0.0000 24.9700 1.9200 0.0001 0.3297
Point 03 Dryer #2 Stack with Baghouse and Cyclone DRYER2 2.9900 13.0900 13.0900
Point 03 Dryer #2 Combustion DRYER2 23.6500 0.1000 24.9700 1.7900 0.0001 0.3063
Fugitive 04 Haul Road - Additional Exit from Plant HR2NDEXIT 0.2900 1.2500 0.1300
Fugitive 05 Haul Road - Final Product HRLDOUT 0.3300 1.4500 0.1500
Fugitive 06 Haul Road - WIP Pile #2 to WIP Pile #3 HRWIP 0.5200 2.2700 0.2300
Fugitive 07 Haul Road - Loader to Wet Plant HRLOAD 1.3500 5.9100 0.5900
Point 08 J & H Screen Baghouse Stack*SCRNSTK 0.9600 4.2200 4.2200
Fugitive 09 Secondary Crushing 2NDCRUSH 0.1600 0.7100 0.1300
Fugitive 10 Stockpile Pre-Wash Plant PILE1 0.0500 0.2300 0.1200
Fugitive 11 Truck Unloading to Dry Plant #1 TRNSDP1 0.0900 0.3900 0.0600
Fugitive 12 Truck Unloading to Dry Plant #2 TRNSDP2 0.0900 0.3900 0.0600
Fugitive 13 Truck Unloading to Wet Plant TRNSWP 0.1800 0.7900 0.1200
Fugitive 14 Truck Unloading to WIP Pile #3 TRNSWIP3 0.0900 0.3900 0.0600
Fugitive 15 WIP Stockpile #2 PILE2 0.1400 0.5900 0.3100
Fugitive 16 WIP Stockpile #3 PILE3 0.2500 1.0900 0.5600
Fugitive 17 Existing Conveyors and Drop Points CONVYRS 0.1900 0.8500 0.2400
Point 18 Unloading Sand Storage Silos #1 - #3**SILOS 0.0004 0.0018 0.0005
Point 19 Engine - Filter Press[1]FPGENSET 0.0300 0.1500 0.1500 4.6600 0.0100 9.3200 1.7500 0.0000 1.0700
Fugitive 20 Disturbed Area DISAREA 0.6100 2.6600 0.4000
Fugitive 21 New Dry Plant #2 Conveyors**CONVDRY2 0.0003 0.0012 0.0003
Fugitive 22 Enclosed Baghouse Waste Collection Area ***BHWASTE 0.0100 0.0500 0.0250
Fugitive 23 Haul Road - Loader to Dry Plant HRDRY 0.4600 2.0200 0.2000
Fugitive 24 Fuel Oil Storage Tank TANK1 0.0021
5.40 23.69 23.68 51.96 0.11 59.26 5.46 0.00 1.71
4.81 21.04 3.39 0.00 0.00 0.00 0.00 0.00 0.00
9.92 43.48 26.94 51.96 0.11 59.26 5.46 0.00 1.71
[1] Tier 2 Natural Gas Engine meets 40 CFR 60.4223(e) and Table 1 emission standards
*Based on fabric filter baghouse Manufacturer Gaurantee of 0.005 gr/dscf
** All product handling post dryers are controlled with a dust collector and silo bin vent filter with a control efficiency >99%
*** Baghouse waste is in an enclosed building
Facility PTE (tpy)
Description
Point
Fugitive
Facility PTE
Page 1 of 1
Company___________________________
_____________________________
Form
Emissions Information
Criteria/GHGs/
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants**(**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Wildcat Sand, LLC
Processing Plant
12.59 30.89 43.48
7.16 13.88 21.04
0.86 26.08 26.94
16.84 35.12 51.96
0.66 -0.55 0.11
20.08 39.18 59.26
3.04 2.42 5.46
0.74 -0.74 0.00
0.00 0.00 0.00
13,522.74 28,530.26 42,053.00
93.06 -74.30 18.76
21.01 -20.93 0.08
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
13,518.00 28,553.84 42,071.84
Formaldehyde 0.16 0.65 0.81 0.15
Hexane 0.20 0.43 0.62 0.10
Generic HAPs 0.06 0.20 0.26 0.05
0.41 1.28 1.69 0.29
Wildcat BACT Analysis, v.3
Section 2
December 2023
Page 1 of 3
2.3 Potential BACT Options for Filter Press Engine: Item 19
2.3.1 Energy Impacts
Certain types of control technologies have inherent energy penalties associated with their use
and industry application. New, modern engines utilize clean technology that are NSPS site
compliant capable. The use of post-manufacturing add-on controls would require additional
energy consumption for the manufacturing and transport of the Engine as well as the transport
of manpower required for assembly and troubleshooting. It is difficult to estimate the amount of
energy needed, however the low-emissions levels of the Engine deem add-ons infeasible.
2.3.2 Environmental Impacts
Environmental impacts include any unconventional or unusual impacts of using a control device,
such as the generation of solid or hazardous waste, water discharges, visibility impacts, or
emissions of unregulated pollutants. In the case of the natural gas Engine, spent catalyst
reduction agent that could be considered hazardous would need to be disposed of, or otherwise
handled, every two to four years, dependent on vendor and technology selected.
2.3.3 Economic Impacts
Pollutant emissions from the internal combustion engine include NOX, PM10, PM2.5, CO, and VOCs.
Annual operation of the Engine will be 8,760 hours. The potential emissions from the Engine are
provided in Table 8. The following analysis will illustrate that the use of the Engine as supplied by
the manufacturer without any additional emission control methods is recommended due to
meeting or being below the standards for appropriate emissions as outlined in 40 CFR Part 60,
Subpart JJJJ and any additional control technologies would create an undue cost burden on the
Sand Plant.
Table 8. Internal Combustion Engine Emissions
Component Operating
Hours Size NOX
(tpy)
PM10
(tpy)
PM2.5
(tpy)
SOX
(tpy)
CO
(tpy)
VOC
(tpy)
Engine 8,760 416 kW 4.66 0.15 0.15 0.01 9.32 1.75
Based on research and engineering experience, the control technologies for internal combustion
engines listed in Table 9 were considered for this BACT analysis.
Wildcat BACT Analysis, v.3
Section 2
December 2023
Page 2 of 3
Table 9. Control Technologies for Internal Combustion Engines
Pollutant Control Technology
CO/VOC Oxidation Catalyst
NOX Exhaust Recirculation [1], Selective Catalytic Reduction (SCR), Non-SCR (NSCR), Lean
Combustion (LC), Good Combustion Practices
PM10/PM2.5 Fabric Filters, Dry ESP, Wet ESP, Venturi Scrubber, Good Combustion Practices
The Engine is subject to the NOX, CO, and VOC standards outlines in Table 1 of 40 CFR Part 60,
Subpart JJJJ for non-emergency spark ignition natural gas engines between 100 hp and 500 hp
manufactured after January 1, 2011. The Engine, as manufactured, meets the standards,
therefore, no additional control technology will be required or used with the Engine.
Table 10. Engine Emission Standards from Table 1, 40 CFR Part 60, Subpart JJJJ
Pollutant JJJJ Standard (g/hp-hr)
CO 2.0
VOC 0.7
NOX 1.0
Non-Selective Catalytic Reduction (NSCR) was evaluated. NSCR is often referred to as a three-
way conversion catalyst system because the catalyst reactor simultaneously reduces NOX, CO,
and hydrocarbons, and involves placing a catalyst in the exhaust stream of the Engine. However,
NSCR technology works with rich-burn engines only. Because the Engine is a lean-burn unit, the
use of an NSCR is not applicable.
Selective Catalytic Reduction (SCR) is used to reduce NOX emissions from lean-burn engines using
a reducing agent, such as ammonia or urea. SCR systems inject the reduction agent into the lean-
burn exhaust stream. The agent reacts selectively with the flue gas NOX, converting it to
molecular nitrogen (N2), and water vapor (H2O). Control for an SCR system is typically an 80-95%
reduction of NOX (EPA, AP-42 Section 3.2).

1 Exhaust gas recirculation is not part of the original manufacturer design. Therefore, it is not feasible without
substantial engineering overhaul of the units.
Wildcat BACT Analysis, v.3
Section 2
December 2023
Page 3 of 3
An oxidation catalyst is a post-combustion technology that has been shown to reduce CO
emissions in lean-burn engines. In a catalytic oxidation system, CO passes over a catalyst, usually
a noble metal, which oxidizes the CO to CO2 at efficiencies of approximately 90% for 4-stroke
lean-burn engines. When used in conjunction with a SCR system, the CO2, water, and NOX then
enter the SCR catalyst, where the NOX reacts with the reducing agent.
The Engine, using lean combustion technology involves the increase of the air-to-fuel ratio to
lower the peak combustion temperature, thus reducing the formation of NOX. Typically, engines
operate at the air-to-fuel ratio of about 20 to 35 pounds of air to pound of fuel. In a typical Lean-
Burn engine, this ratio is increased to 45 to 50. With a conventional spark ignition, the air-fuel
ratio can only be increased to a certain point before the onset of lean misfire. To avoid misfire
problems and to ensure complete combustion of very lean mixtures, the engine manufacturers
have developed torch ignition technology and the application of a controlled swirl. Some increase
in fuel consumption and CO and HC emissions results from the slower flame propagation for very
lean mixtures. At optimal setting new lean burn engines can achieve NOX levels of 1 g/hp-hr (gram
per horsepower-hour) or below. This corresponds to an 80 to 90 percent control over
conventional spark plug design engines.
The total estimated capital investment associated with the installation, startup, and equipment
costs of a SCR is $2,127,689 in 2023 dollars, in accordance with EPA’s Cost Reports and Guidance
for Air Pollution Regulations, Section 4, SCR Cost Calculation Spreadsheet (updated 06/12/2019).
This total is calculated based on industry costs collected and validated by the EPA in 2016 and
then adjusted to 2023 dollars on the Chemical Engineering Plant Cost Index (CEPCI). It was
estimated that each catalyst has an operational life of 20,000 hours. Because the Engine will
operate 8,760 hours annually, it is determined that significant maintenance activities will be
required every 27 months. Each SCR unit is anticipated to have a use life of 20 years before
requiring complete replacement. With an effectiveness in reducing NOX emissions by 85%, a SCR
would remove an estimated 3.95 tpy. This results in a cost-effectiveness of $67,908 per ton of
NOX removed in 2023 dollars.
Prepared by Air Regulations Consulting, LLC
1. I found an error in the emission summary, there doesn't seem to be SO2 emissions added for the old
dryer. I think it's supposed to 0.1 tpy, please fix this error.
Section 2 of the Tarmac Manufacturer Specifications (page 7) notes the 0.00 lb/hr SOX emissions rate.
2. I can't tell what the emissions are supposed to be calculated at for the dryers. In the original NOI, they
are listed at 23.65 tpy each for NOx. In the new BACT section, they are listed at 16.35, but this doesn't
seem to match the emission factor and natural gas consumption rate given in these tables. I also don't
understand why the emissions for the dryers are considered the same when they have slightly different
ratings.
The maximum PTE for Dryer 1 and Dryer 2 are each 23.65 tpy, based on the Manufacturer Specs. The
facility would like to be permitted for the absolute maximum potential. Per note [3] in the PTE calcs for
Sand Dryer 2, it notes that the emissions data for CO and NOX are identical to Sand Dryer 1.
3. Can you confirm I have the correct HAP totals for the following pollutants for the facility? Perhaps a
HAPs summary table would be helpful here as well.
Hexanes - 0.6227 tpy CORRECT
Acrolein - 0.076 tpy CORRECT
Formaldehyde - 0.8063 tpy CORRECT
Methanol - 0.370 tpy CORRECT
Acetaldehyde - 0.124 tpy. CORRECT
4. The BACT section for material handling on the last BACT submission cuts off before making a
conclusion. I think the intention was for it to state water sprays as BACT, but can you fix this section so
it's clear?"
Please note that the conclusion for the material handling section is as follows, “All other sand conveyor
transfers require the product to be dry, and potential PM emissions at the sand dryers and J & H screens
are handled by associated Fabric Filter Baghouses. The remaining transfers are of sand products, that
predominantly exceed 105 Microns particle size thus, PM emissions are not anticipated.”
5. The BACT section for the Dryer burners is very confusing as written, and I'm not sure if the right
calculations are presented in this section. For example, the current section says the uncontrolled
emissions are 16.34 tpy, but as stated above and in the written explanation preceding these
calculations, the uncontrolled total is supposed to be 23.65. Additionally, does the starjet LNB option
have the same heating efficiency issues that the FGR burners do?
No, the LNB will be able to handle the 150 tph workload.
I'm referring to the necessary increase in dryer size to reach the requested 150 ton per hour sand drying
rate. I think there was a miscommunication here, as the new table "without loss" removed the cost of
increased use of natural gas, which can be included in the economic impacts section, but still includes
the "annual burner tuning" figure, which is based entirely on potential lost profit from shutdown time
while the burner is tuned, which is what I intended to say was what should be removed from the tables.
I can see why this might be considered a "Local Economic Impact" per EPA guidance, but I think that is
supposed to be considered separately on its own merits, as to avoid altering the economics of a project
Prepared by Air Regulations Consulting, LLC
substantially enough that the project would no longer be considered. In terms of considering the cost
effectiveness of a control technology, I should be evaluating the incremental cost of upgrading to a new
technology. This brings up my final point, which is I'm not sure that the incremental cost is being given,
as I don't see the cost figure for the uncontrolled burner included in the analysis. There isn't a cost listed
for the burner as is without LNB or FGR technology, and the direct cost of the upgraded technologies
should be evaluated minus the cost of the existing burner, so that only the increased cost to upgrade is
considered in the evaluation.
ARC will make the requested edits to the “without loss” tables for clarity. Wildcat Sand is and will be
utilizing LNBs for Dryer 1 and Dryer 2, therefore, an analysis without an LNB will not be considered.

Prepared by Air Regulations Consulting, LLC
Table 5a: Annual Reoccurring Cost to Service Control Equipment per Dryer, with Loss
Control Device Service Item O&M Cost Total Annual O&M Cost
Baghouse
Filter Media Replacement $30,000 per year
$100,000 Annual Shutdown Insp. $70,000 per year
Cyclone Annual Shutdown Insp. $70,000 per year $70,000
Starjet LNB
Annual Burner Tuning $120,000 per year
$133,286 Annual Expert Tuner $13,286 per year
Megastar LNB
Semiannual Burner Tuning $240,000 per year
$607,067-$682,444 Semiannual Expert Tuner $26,572 per year
Lost Drying Efficiency $40-48 per hour
Megastar LNB with
FGR
Semiannual Burner Tuning $240,000 per year
$607,067-$682,444 Semiannual Expert Tuner $26,572 per year
Lost Drying Efficiency $40-48 per hour
Table 5b: Annual Reoccurring Cost to Service Control Equipment per Dryer, without Loss
Control Device Service Item O&M Cost Total Annual O&M Cost
Baghouse
Filter Media Replacement $30,000 per year
$100,000 Annual Shutdown Insp. $70,000 per year
Cyclone Annual Shutdown Insp. $70,000 per year $70,000
Starjet LNB Annual Expert Tuner $13,286 per year $13,286
Megastar LNB
Semiannual Expert Tuner $26,572 per year
$367,067-$442,444 Lost Drying Efficiency/hr $40-48 per hour
Megastar LNB with
FGR
Semiannual Expert Tuner $26,572 per year
$367,067-$442,444 Lost Drying Efficiency/hr $40-48 per hour
Table 6a. Controlled Costs of Dollar per Ton of Pollutant Reduced without FGR, with Loss
Dryer Pollutant
Dryer LNB
Emissions
(tons/yr)
Baghouse/
Cyclone & Megastar
LNB Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 - 312.99 312.99
NOX 16.34 13.50 - 213,888.61 213,888.61
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 13.50 34,828.27 240,446.19 243,929.02
Prepared by Air Regulations Consulting, LLC
Table 6b. Controlled Costs of Dollar per Ton of Pollutant Reduced without FGR, without Loss
Dryer Pollutant
Dryer LNB
Emissions
(tons/yr)
Baghouse/
Cyclone & Megastar
LNB Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 - 312.99 312.99
NOX 16.34 13.50 - 129,329.16 129,329.16
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 13.50 34,828.27 155,886.75 159,369.57
Table 7a. Controlled Costs of Dollar per Ton of Pollutant Reduced with FGR, with Loss
Dryer Pollutant
Dryer LNB
Emissions
(tons/yr)
Baghouse/
Cyclone & Megastar
LNB Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 364.00 312.99 349.39
NOX 16.34 6.18 19,451.60 59,728.43 61,673.59
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 6.18 19,451.60 67,144.64 69,089.80
Table 7b. Controlled Costs of Dollar per Ton of Pollutant Reduced with FGR, without Loss
Dryer Pollutant
Dryer LNB
Emissions
(tons/yr)
Baghouse/
Cyclone & Megastar
LNB Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 364.00 312.99 349.39
NOX 16.34 6.18 19,451.60 36,115.19 38,060.35
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 6.18 19,451.60 43,531.40 45,476.56

AIR REGULATIONS CONSULTING, LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM

August 22, 2023

Attn: Dylan Frederick
Environmental Engineer
Minor NSR Section
Permits, Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114

[Submitted via electronic copy submittal [e-mail]]

RE: Addendum to BACT Analysis for Dryer #2 & Engine PM, NOX, CO, & VOC Emissions
Wildcat Sand, LLC – Uintah County Sand Processing Plant
DAQE-AN159980003-21
Uintah County, UT

Dear Mr. Dylan Frederick,

On behalf of Wildcat Sand, LLC (Wildcat), Air Regulations Consulting, LLC (ARC) is submitting an
updated Best Available Control Technology (BACT) analysis for the installation of a fluid bed sand
dryer (Dryer #2) as well as a Filter Press Engine (Engine) at the Uintah County Sand Processing
Plant alongside this complete Notice of Intent (NOI) application. This BACT review was performed
pursuant to UAC R307-401-6 and the Division of Air Quality (DAQ or Division) Form 01b for BACT
determinations. Please find the enclosed addendum to the BACT analysis for the DAQ’s review.

Based on our call between DAQ and ARC representatives on July 28, 2023, the following edits
were implemented:
• Updates to all controls for the non-dryer emissions based on increase in total plant-wide
production and operation.
• Included versions of Tables 5 through 7 to remove the lost production component even
though ARC disagrees with the DAQ’s assessment that BACT does not account for lost
production.
• Removed CO and VOC ppm from the supporting documents as AP-42 applies.

AIR REGULATIONS CONSULTING, LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM
AIR REGULATIONS CONSULTING, LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM

Should you have any questions regarding the enclosed information, please contact me at
402.817.7887 or [e-mail].

Sincerely,

Eric Sturm
Principal, Sr. Consultant, ARC

Enclosures

Cc: Matthew Hyita, Plant Manager, Wildcat
Sydney Stauffer, Environmental Consultant, ARC

Date:
2023.08.24
22:31:45 -05'00'

AIR REGULATIONS CONSULTING, LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM
AIR REGULATIONS CONSULTING, LLC•5455 RED ROCK LN, STE 13, LINCOLN, NE 68516•402.817.7887•AIRREGCONSULTING.COM

BACT Analysis for PM, NOX, CO, & VOC Emissions

Wildcat BACT Analysis
Section 1
August 2023
_________________________________ Page 1 of 27

1 INTRODUCTION AND BACKGROUND
Wildcat Sand, LLC (Wildcat or Sand Plant) is planning to install a new Starkaire Fluid Bed Dryer
(Dryer #2) drum dryer and a Filter Press Engine (Engine) at the current processing plant, located
approximately seven miles southeast of Roosevelt Main Street, Roosevelt, Utah. Dryer #2 will be
added to an existing aggregate operation that currently crushes, washes, and dries sand; the Sand
Plant is currently operating Dryer #1, a Tarmac dryer, with a 40.9 million British thermal units per
hour (MMBtu/hr) natural gas-fired burner. With the intention of increasing sand production,
Wildcat is planning to add Dryer #2 equipped with a 38.0 MMBtu/hr natural gas-fired burner. The
360-kiloWatt (kW) Engine will be utilized at the filter press, located southeast of the current
tailing ponds. If allowed to operate for 8,760 hours per year, the sand dryers could have the
potential to produce approximately 1,314,000 tons of sand annually, each.[1] The Sand Plant will
have the potential to produce 2,628,000 tons of sand annually. The additional sand dryer is
planned to be controlled with computerized systems for fuel firing and wet sand feed along with
cyclone and baghouse dust collection consistent with the Division’s Utah Administrative Code
(UAC) and the Environmental Protection Agency’s (EPA) federal standards and databases of
technology for new sources.
This report contains analysis of best available control technology (BACT) analysis for particulate
matter (PM), oxides of nitrogen (NOX), carbon monoxide (CO), and volatile organic compounds
(VOC) emissions for the Tarmac rotary sand dryer and the Starkaire fluid bed dryer. For reference,
UAC R307-101-2, defines BACT specifically to the following:
“BACT means an emission limitation and/or other controls to include design,
equipment, work practice, operation standard or combination thereof, based on a
maximum degree of reduction of each pollutant subject to regulation under the
Clean Air Act and/or the Utah Air Conservation Act emitted from or which results
from any emitting installation, which the Air Quality Board, on a case-by-case basis
taking into account energy, environmental and economic impacts and other costs,

[1] 1,314,000 tons equates to 150 tons per hour at 8,760 hours per year which is capable for some rotary sand dryers
with passive control technologies. If burner tuning for emissions of fuel combustion is required, then 8,760 hours
per year, and 1,314,000 tons per year, are not attainable.
Wildcat BACT Analysis
Section 1
August 2023
_________________________________ Page 2 of 27

determines is achievable for such installation through application of production
process and available methods, systems and techniques, including fuel cleaning or
treatment or innovative fuel combustion techniques for control of each such
pollutant. In no event shall application of BACT result in emission of pollutants
which will exceed the emissions allowed by section 111 or 112 of the Clean Air Act.”
As the rule states, Wildcat and ARC are obligated to base proposed BACT on the most effective
engineering techniques and control equipment to minimize emission of air contaminants from
its process to the extent achievable within the industry. Furthermore, based on this definition
and the DAQ’s Form 01b Guidance on BACT, this analysis for Wildcat’s Dryers #1 and #2 and
Engine includes consideration of energy impacts, environmental impacts, economic impacts,
other considerations, and cost calculation. Wildcat and ARC are well versed in the aggregate
drying industry and have been involved in approximately 55 sand dryer projects in ten different
states, including Utah. The proposed BACT for Wildcat follows Form 01b, UAC R307-101-2, EPA
federal standards, and applicability of the sand drying techniques nationwide.
Wildcat BACT Analysis
Section 2
August 2023
_________________________________ Page 3 of 27

2 BACT ANALYSIS
2.1 Non-Dryer Emissions
The construction and operation of Dryer #2 will accommodate increases in sand production, from
950,000 tons of sand per year to 2,628,000 tons of sand per year, and therefore emissions from
other stages in Wildcat’s sand drying operating will also increase. Emissions will increase for each
process equipment at the facility capable of emitting particulate matter, and Wildcat’s sand
dryers and Engine will have a small increase in emissions of nitrogen oxides, VOCs, and carbon
monoxide as well.
2.1.1 Haul Road Emissions: Item 04, Item 05, Item 06, Item 07, Item 20, and Item 23
Wildcat currently applies chemical suppressant on the haul roads as well as watering to decrease
particulate emissions associated with material hauling. The loadout haul road located closest to
the main entrance is paved. The current haul roads and the planned haul roads are unpaved.
The Facility’s remote location would require a mobile concrete or asphalt batch plant near the
site to meet the needs of paving the plant’s haul roads. The cost and environmental and energy
impacts would be extreme compared to the cost of the current control method of watering and
chemical suppression. A mobile batch plant would not be able to pipe a sustainable source of fuel
associated with the asphalt or concrete production and therefore fuel such as diesel would be
utilized for the energy required to operate. The facility currently implements the controls that
meet 85% efficiency, as shown in Table 1. The addition of sweeping as a control is also infeasible
as the fuel for the vehicle would be diesel and the maintenance and equipment cost out-way the
5-10% of additional control efficiency that is recognized by the Utah Department of Air Quality
(UDAQ).
The available and technically feasible control alternatives for fugitive emissions from unpaved
haul roads are ranked in Table 1 according to control efficiency. Although paved roads with
vacuum sweeping or street sweeping with watering yield the best control efficiency, the use of
chemical suppressant and water is the most cataloged BACT determination for fugitive emissions
from haul roads.
Wildcat BACT Analysis
Section 2
August 2023
_________________________________ Page 4 of 27

Table 1: Control Alternative Rankings for Fugitive Emission Sources
Control Alternative Control Efficiency (%)[2]
Paved Roads with Vacuum Sweeping and Watering 95
Paved Roads with Sweeping and Watering 90
Chemical Suppressant and Watering 85
Basic Watering and Road Base 75
Basic Watering 70
Paving roads at the Wildcat Sand facility are uneconomical due to the truck route areas involving
tight turning radiuses for the haulers that will be utilizing the roads. Trailer pups need to break
traction with the surface to follow the towing truck. This action adds an unnecessary stress on
the paved surface and causes a quicker turnaround time for repairs. For this reason, the high
initial cost along with the high maintenance cost of paving make paving impracticable. The use
of paved surfaces has seasonal disadvantages in climates with snow or freezing rain. The smooth
surface of asphalt offers little resistance to the development of ice or snow causing the roadway
to become slick until corrective measures can be deployed. Because chemical suppressants and
water sprays on roads constructed of compacted road base have been commonly and
successfully applied to control fugitive emissions from unpaved road surfaces, Wildcat Sand
assumes no significant energy, environmental, or economic impacts will prevent their selection
as BACT. Please note that the maximum speed limit on this haul road will be limited to 10 mph.
If Wildcat paved all unpaved haul roads, the total area would be 60,283.46 square feet. It is
assumed that repairs would need to be completed annually to avoid additional costs of damage
to trucks and tires due to potholes and normal wear and tear. The cost accounting for design,
grading, construction, labor, delivery costs to the remote facility, and additional costs associated
with paving is predictably estimated to be over $1,000,000.

[2] Control Efficiency Ratings from UDAQ’s guidance memorandum: Emission Factors for Paved and Unpaved Haul
Roads (January 12, 2015)
Wildcat BACT Analysis
Section 2
August 2023
_________________________________ Page 5 of 27

Wildcat Sand proposes to control fugitive particulate emissions from the unpaved haul roads by
applying dust suppressant(s) annually and watering as needed to maintain surface moisture
and/or prevent excessive visible emissions.
2.1.2 Wet Plant Emissions: Item 09, Item 10, Item 13, Item 14, Item 15, Item 16, and Item 17
1. Exposed Areas
Once construction of the new wet storage pile is completed, the wet plant’s remaining exposed
areas will be the haul roads, addressed in section 2.1.1.
2. Stockpiles
Fugitive emission sources at the wet plant may include storage piles. Based on USEPA’s
RACT/BACT/LAER Clearinghouse (RBLC) database search, the following control alternatives are
considered available and technically feasible for fugitive emissions sources: water sprays, and
compaction that minimize visible emissions. No other control alternatives were listed for any
fugitive emissions sources from storage activities. For the purposes of this NOI, it is assumed that
any other particulate control approaches are either technically infeasible or would not be
considered BACT.
Table 2: Control Alternative Rankings for Non-Fugitive Emission Sources
Control Alternative Control Efficiency (%)[3]
Water Sprays 50
As shown in Table 2, the available and technically feasible control alternatives for fugitive
emissions sources are ranked according to control efficiency. The use of water sprays with
compaction, the top-ranked control alternative, is also the only listed BACT determination for
fugitive emissions from storage activities with a control efficiency of 90%. For storage piles,
Wildcat Sand assumes that the use of water sprays prior to stacking in the wet plant storage piles
is necessarily very efficient.

[3] Control Efficiency Ratings from Nevada Bureau of Air Pollution Control: Emission Control Technology – Control
Efficiency Ratings; and USEPA draft Technical Background Document for Control of Fugitive Dust at Cement
Manufacturing Plants (1998).
Wildcat BACT Analysis
Section 2
August 2023
_________________________________ Page 6 of 27

It is not technically feasible to compact the material in the storage piles, as material is virtually
continuously removed as the process continues or fine materials excluded by the process is
removed back to the place of origin for backfill in the final reclamation. Wildcat Sand assumes no
control efficiency except for the moisture content of the material that comprises the stockpile.
Water sprays are utilized throughout the wet plant process and therefore, Wildcat Sand assumes
that no additional controls are necessary for the stockpiles. Controlling fugitive particulate
emissions from the storage piles by applying water as needed will sufficiently maintain surface
moisture and prevent excessive visible emissions.
3. Material Handling
Non-fugitive emission sources classified as material handling include conveyor belt transfer
points. Typical control alternatives include partial or total enclosure of the process, water sprays,
and fabric filter baghouses. In the RBLC, no control alternatives are listed as BACT for one or more
sand handling, or conveying processes, based on similar processes on the RBLC database search
for process 90.011-coal handling/processing/preparation/cleaning, from 2009 to 2019). No other
control technologies were listed for the non-fugitive sources in Wildcat Sand’s surface sand-
handling system. For the purposes of this NOI, it is assumed that any other particulate control
approaches are either technically infeasible or would not be considered BACT.
Table 3 presents the ranking of available and technically feasible control alternatives for non-
fugitive emissions sources based on control efficiency.
Table 3: Control Alternative Rankings for Non-Fugitive Emission Sources
Control Alternative Control Efficiency (%)
Enclosure Vented to Fabric Filter Baghouse[4] 99.9 to 99.9
Enclosure with Water Spray[5] 87.5
Water Spray[6] 75
Enclosure[9] 50

[4] Baghouse control efficiencies represent the range of values listed in USEPA’s RBLC database for Process No. 90.011
between 2009-2019.
[5] Calculated as the combined control efficiency of enclosure and water spray (See Below)
[6] Control efficiency ratings provided by Nevada Bureau of Air Pollution Control (Dec. 2011)
Wildcat BACT Analysis
Section 2
August 2023
_________________________________ Page 7 of 27

The Wildcat Sand plant has many transfer points in varying locations, therefore enclosures
vented to a baghouse, or several baghouses is not economically feasible.
Wildcat Sand assumes no significant energy, environmental or economic impacts will prevent the
selection as BACT since enclosures with water sprays have been commonly and successfully
applied to material handling facilities.
Wildcat provides enclosures and utilizes water sprays for material handling that occurs prior to
wet processing. The material handling that occurs post wet processing does not require
additional control due to the inherent moisture content. All other sand conveyor
2.1.3 Dry Plant Emissions: Item 01, Item 08, Item 11, Item 12, Item 18, Item 21, and Item 22
1. Exposed Areas
Once construction of the new dry plant is completed, the dry plant’s remaining exposed areas
will consist of the haul roads, addressed in section 2.1.1.
2. Stockpiles
The stockpiles at the Wildcat Sand Processing Plant are part of the wet plant process, discussed
in Section 2.1.2.2.
3. Material Handling
All sand conveyor transfers, other than the material handling discussed in Section 2.1.2.3, require
the product to be dry and potential PM emissions at the sand dryers and J & H screens are
handled by associated fabric filter baghouses. The remaining sand product transfers
predominately exceed 105-micron particle size; thus, PM emissions are not anticipated.
2.1.4 Filter Press Engine
The original BACT was submitted with a 416-kW natural gas engine for emergency generation.
The manufacture certifies the Engine to meet the applicable Environmental Protection Agency’s
(EPA) New Source Performance Standards (NSPS) Subpart JJJJ for lean burn natural gas engines
 75 kW (100 hp), which is BACT for generators. These federal regulations address NOX, organic
emissions, and particulates. The emissions for PM10 and PM2.5 will increase to 0.15 tpy, each.
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In total, emissions of PM10 that are not attributed to the sand dryers will increase under this
project by approximately 24.17 tons per year, and emissions of PM2.5 that are not attributed to
the sand dryers will increase by approximately 7.63 tons per year. The Engine will have NOX
emissions that will be 9.32 tons per year, SOX emissions that will be 0.01 tons per year, and CO
emissions that will be 18.63 tons per year. These processes remain the same as they had under
the previous AO, but for increased production of sand. The control requirements established in
the previous AO will remain as the best available controls under a new permit. For these
processes, Wildcat will maintain the same standards and requirements for emissions controls.
2.2 Potential BACT Options for Dryer #1 and #2: Item 02 and Item 03
To evaluate energy impacts, environmental impacts, economic impacts, other considerations,
and cost calculations a list of potential emission controls must be comprised, and impacts and
assessments may be calculated per emission control. Form 01b and UAC R307-101-2 are clear in
advising that the application of BACT may not result in emission of pollutants which could exceed
those allowed by Section 111 or 112 of the Clean Air Act (CAA). CAA Section 111 and 112 tasked
the EPA to develop standards of performance for new, modified, and reconstructed sources.
Section 111 relates to standards for criteria pollutants such as PM, NOX, CO, and VOC. Section
112 relates to emissions of hazardous or toxic pollutants, which are not an issue with the Wildcat
rotary dryer nor the fluid bed dryer; moreover, there are no promulgated standards for
nonmetallic drying pursuant to Section 112 nor are hazardous or toxic emissions an area of
concern from sand drying. In contrast, the EPA has been reviewing criteria pollutant emissions
pursuant to Section 111 from nonmetallic industries, like sand processing and drying since the
1970s.
On April 23, 1986, proposed standards of performance for new sources (NSPS) sand drying
pursuant to Section 112, as published in the Code of Federal Regulations, Title 40, (40 CFR)
Chapter I, Subchapter C, Part 60, Subpart UUU—Standards of Performance for Calciners and
Dryers in Mineral Industries (Subpart UUU). The Subpart UUU standards were heavily reviewed,
commented upon, and finalized in 1992 and 1993. Since 1992, the EPA has reviewed the Subpart
UUU standards every eight years pursuant CAA Section 111(b)(1)(B). Each review process has
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resulted in no changes to Subpart UUU, and thus Subpart UUU has been established and
reviewed by EPA over the course of the last 37 years.
“The Administrator shall, at least every 8 years, review and, if appropriate, revise
such standards following the procedure required by this subsection for
promulgation of such standards.”
The established NSPS Subpart UUU standards for new sources has only determined that PM
control techniques are the only reduction in emissions that, “…(taking into account the cost of
achieving such reduction and any non-air quality health and environmental impact and energy
requirements) the Administrator determines has been adequately demonstrated.” Please see CAA
Section 111(a)(1) for the NSPS making process. In the 37 years of review and establishing
adequate emission reduction, only PM control technologies have been demonstrated.
Of the PM control technologies that the NSPS Subpart UUU has established and proven to be
adequately demonstrated, there are dry control devices and wet scrubbers. Again, the NSPS
rulemaking process has not established any control for NOX, CO, or VOC. Acceptable emission
reduction technologies of dry control devices include cyclones,[7] baghouses,[8] and electrostatic
precipitators (ESP).[9] The only wet control device established and demonstrated were wet
scrubbers.[10] Wildcat and ARC reviewed combustion controls and burner technologies such as
low-NOX burners and/or low-CO burners for potential control of NOX and CO respectively. Other
NOX, CO, and VOC controls could theoretically/potentially include catalyst or catalytic style
control technologies; there are no instances published, permitted, or publicly available of catalyst
or catalytic style control technologies demonstrated in practice for a sand dryer.

[7] Cyclones remove PM by centrifugal and inertial forces induced by forcing particulate laden gas to change direction;
this type of technology is often referred to as pre-cleaners or collectors due their nature of removing large PM before
exhausting to another control device.
[8] A fabric filter or baghouse unit consists of one or more isolated compartments containing rows of fabric bags in
the form of round, flat, or shaped tubes, or pleated cartridges. Particle laden gas passes up along the surface of the
bags then radially through the fabric.
[9] ESP is a PM control device that uses electrical forces to move particles entrained within an exhaust stream onto
collector plates. The particles are given an electrical charge when they pass through a corona; electrodes and high
voltage generate an electrical field forcing particles to collector plates.
[10] In wet scrubbing processes, solid particles are removed from a gas stream by transferring them to a liquid. The
liquid most used for wet scrubbing is water.
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Since 1996, USEPA’s RBLC has made only three documented BACT determinations. All three BACT
determinations were consistent with NSPS Subpart UUU in that only required PM control
technologies were settled upon as BACT and LAER. For reference, the three RBLC determinations
from Oregon, Wisconsin, and California are attached with this BACT analysis. NOX and CO (and
VOC) control technologies were not established in the BACT evaluation process for sand dryers.
2.2.1 Summary of BACT analysis for FGR
Wildcat offers this clarification of the impacts of installing the sand dryers with or without Flue
Gas Recirculation (FGR) technology to control emissions from the sand drying process. The
purpose of FGR is to reduce NOX emissions by recirculating exhaust gases back into the
combustion chamber. External FGR involves recycling of flue gas back into the firebox as part of
the fuel-air mixture at the burner. Rather than using burner design features to recirculate gases
from within the firebox, FGR uses external ductwork to route a portion of the exhaust stream
back to the inlet side of the dryer. The cleanest fuel that is reasonably delivered to the Wildcat
property is natural gas, which is discussed in Section 2.2.3 (Fuel Consideration). As the dryers are
fueled with pipeline quality natural gas, which is inherently low in nitrogen content, fuel NOX is
not a major contributor. Given that NOX emissions from Dryer #1 and Dryer #2 are calculated to
be 23.65 tpy each, and the facility is already a minor source of NOX emissions, Wildcat would
retain that status under the proposed project. The ten-year annualized cost for installing Dryer
#1 with LNB and without FGR technology is $217,371.43 per ton NOX per year and Dryer #2 is
$243,929.02 per ton NOX per year, whereas the cost of reducing NOX emissions using the
Megastar LNB with FGR technology would be $61,673.59 and $69,089.80 per ton NOX per year
for Dryer #1 and Dryer #1, respectively, as shown in Tables 6 and 7 in Section 2.2.5 (Economic
Impacts). With the economic and environmental impacts in mind, the FGR is inappropriate for
sand drying from the perspective of energy impact.
2.2.2 Energy Impacts
Energy impacts are the first criteria to consider when conducting BACT analyses. Certain types of
control technologies have inherent energy penalties associated with their use and industry
application. For instance, baghouses and cyclones require energy to generate and regulate air
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flow through control devices. These control devices use induced draft fans to pull air from the
source of the pollutants to send the dirty exhaust through adequate control. Based on the
industry application of sand drying already requiring air flow through the unit for adequate
temperature and moisture removal, almost all dryers are pre-designed with an integral cyclone
and baghouse designed as part of the drying system. Other add-on controls such as low-NOX/low-
CO burning, and catalytic type emission controls are not integral or inherent to the design of a
sand dryer.
In contrast, special burners and catalysts to reduce combustion gases are counterproductive to
the sand drying process and typically adversely affect dryer temperature and inefficiently
increase the backpressure and energy needed for sand drying. [11]
A baghouse or fabric filter uses an induced draft fan to pull air through bags or cartridges which
are used as the filter medium. Particulates attach to the bags and coat the bags in a fine layer of
dust. The bags are then cleaned when airflow becomes restricted for re-use in capturing
particulates from the air. A cyclone is often used as a pre-cleaner unit to fabric filter as they would
share flow and energy requires. Cyclones use an induced draft fan to pull air into a cylindrical
tube where centrifugal motion causes particles to hit the side wall of the cyclone and fall out of
the control device and are not released into the ambient air. Clean air is then pushed out through
the exit of the cyclone. An induced draft fan on a cyclone is typically sized smaller than a baghouse
because less energy is required to move air through the system. Based on research of publicly
available vendor data, and manufacturer data provided, it appears that the average-sized
baghouse for a 150 ton per hour sand dryer typically requires approximately 130 horsepower
(HP) of energy usage to maintain airflow. On a kilowatt (kW) basis, 130 HP is approximately 97
kW of energy. The Wildcat dryer models are inherently designed with this air flow to match
cyclone and baghouse requirements. The system is efficiently designed such that the energy
required for the cyclone baghouse tandem is also used to balance air flow for the sand drying

[11] Tarmac Quotes SD780R5 and SD-949 comparison of energy needed to dry sand per ton of aggregate. EPA 456/F-
99-006R; https://www3.epa.gov/ttncatc1/dir1/fnoxdoc.pdf.
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process. Therefore, the maximum energy impact is closer to a zero or nil impact in practice due
to the inherency of dryer-cyclone-baghouse shared air flow.
Another type of PM control is the wet scrubbing processes. This would be where solid dust/sand
particles are removed from a gas stream by adsorbing with a liquid along with condensing back
half particulates. Water is the liquid most used within the aggregate industry for PM wet
scrubbing. A wet scrubber's particulate collection efficiency is directly related to the amount of
energy expended in contacting the gas stream with the scrubber liquid. Most wet scrubbing
systems operate with particulate collection efficiencies near 95 percent whereas fabric filters
usually attain greater than 99 percent control. [12] There are differing energy usage levels for wet
scrubbers. A low energy wet scrubber utilizes pressure drops less than 5 inches of water column
(WC) and is capable of efficiently removing particles greater than about 5-10 micrometers in
diameter. A medium energy scrubber has a pressure drop from 5 to 25 inches of WC. For this, a
typical water pump and fan would require approximately 200 kW of energy (0.682 MMBtu/hr).
A fourth type of PM control device to be analyzed is an electrostatic precipitator (ESP). ESPs use
charged electricity to attract dust particles to the side walls, which are then “rapped” off using
automated hammer-like devices. ESPs are energy-intensive, and the efficiency can vary
depending on the type of dust being collected. ESPs use very high amounts of energy for their
induced draft fans, plate charging, and mechanical rapping. It is difficult to estimate the amount
of energy needed, but the EPA estimates that an ESP equipped on the exhausted of the sand
dryers would have energy usage of 86,000 kW (293 MMBtu/hr) each.[6] For this reason, the
energy impacts deem ESP as infeasible for BACT on a sand dryer.
Low-NOX and low-CO type burning technology would typically require combustion temperature
manipulation and reduction which is usually counterproductive to the sand drying process. For
low-NOX, the combustion temperature may be reduced in several ways with the goal of keeping
the chambers below 1,400 degrees Fahrenheit (°F); this is the temperature at which thermal NOX
formation occurs. Four primary firing techniques to reduce NOX formation include: fuel rich

[12] EPA/452/B-02-001; https://www3.epa.gov/ttncatc1/cica/files/cs6ch2.pdf.
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mixtures to limit the amount of oxygen available; fuel lean mixtures to limit temperature by
diluting energy input; injecting cooled oxygen-depleted flue gas into the combustion air to dilute
energy; and/or injecting cooled flue gas with added fuel. Low-NOX burners are based partially on
these principles. The basic technique is to reduce the temperature of combustion products with
an excess of fuel, air, flue gas, or steam. This methodology is the basis to avoid most of the
nitrogen from becoming ionized at 1,400 °F. [13]
There is an additional methodology to reduce NOX that involves steam injection, which is usually
used in boilers. This is not feasible with sand dryers due to their functionality of removing
moisture from sand. Adding water to the rotary drum to Dryer #1 would drastically decrease the
efficiency of the moisture removal process from the sand.
Typically coupled with and considered as a portion of the low-NOX burner (LNB) is flue gas
recirculation (FGR). Recirculation of cooled dryer exhaust and/or ambient air reduces the
temperature by diluting the oxygen content of combustion chamber air, and by causing heat to
be diluted in a greater mass of flue gas for temperature manipulation. Heat in the flue gas can be
recovered by a venting design and duct work. This reduction of temperature lowers the NOX
concentration that is generated. Again, if the sand dryer chambers are kept below 1,400 °F, then
the thermal NOX formation will be negligible. [14]
The nature of LNB and FGR tend to be counterintuitive for the sand drying process as high
chambers increase drying efficiency. The goal of LNB and FGR is to reduce temperature in the
combustion chamber. For purposes of energy impacts, third-party engineers would estimate that
dryer efficiency would likely be affected by 17 percent, [15] or approximately 25.5 tons per hour
for a 150 ton per hour dryer. According to burner manufacturer’s Legacy Hauck- Honeywell
Process Solutions/Honeywell Thermal Solutions (HPS/HTS or Honeywell), an FGR would require
a burner of 54 MMBtu/hr to be able to achieve 150 tons per hour drying rate. This needs an
energy increase of 50%. In addition, LNB and FGR would require a 50 HP blower. [16] The blower

[13] EPA 456/F-99-006R; https://www3.epa.gov/ttncatc1/dir1/fnoxdoc.pdf.
[14] EPA 456/F-99-006R; https://www3.epa.gov/ttncatc1/dir1/fnoxdoc.pdf.
[15] January 28, 2020 LNB and FGR email assessment from Michael G. Blantz, Engineer of Honeywell.
[16] Tarmac Quotes SD780R5 and SD-949 comparison of energy needed to dry sand per ton of aggregate.
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energy impact would equate to approximately 37 kW (0.126 MMBtu/hr). The high energy impact
and counterproductivity of LNB and FGR can potentially eliminate these from the BACT
determination for the sand dryers.
Third-party engineers indicated that any low-CO burner (LCB) technology would likely negatively
affect the NOX emission rate, and further, LCB are more expensive and would require more
energy than NOX burner technologies. Given Uintah County is non-attainment for ozone, CO is
innocuous in the formation of ozone and NOX significantly contributes to ozone, ARC assumes
the DAQ would prefer low-NOX technologies be evaluated as opposed to other controls that do
not limit ozone. Moreover, as indicated by third-party engineers, LCB technology is less efficient
and would require more energy than LNB technologies. Thus, LCB technologies are deemed to
be a secondary consideration for BACT given LNB technologies have a lower energy,
environmental, and economic impact, and so if LNB/FGR is later considered as possible for BACT,
than LCB can be revisited and re-evaluated as a BACT on a dryer equipped with LNB/FGR.
CO and VOC emissions from the sand dryer exhaust could theoretically be reduced by an
oxidation catalyst or catalytic style control technologies. These would need to be equipped after
baghouse or filter control to avoid fouling or plugging of the catalyst. As discussed earlier, there
are not publicly available or demonstrated examples of catalyst technology on sand dryers to
control CO and VOC; further, there are not publicly available or demonstrated add-on CO or VOC
exhaust reduction for any sand dryer fired with propane or natural gas. At the direction of the
DAQ, this analysis considers the most reasonable option to control VOC given Uintah County is
non-attainment for ozone, and VOC contributes to ozone. Perhaps most appropriate by
comparison is the 40 CFR Part 63, Subpart ZZZZ Reciprocating Internal Combustion Engine
National Emission Standards for Hazardous Air Pollutants (RICE NESHAP) where gas engine
combustion exhaust is somewhat comparable to sand dryer exhaust. With the RICE NESHAP, EPA
determined that oxidation catalysts for two-stroke lean-burn (2SLB) and four-stroke lean-burn
(4SLB) engines, and non-selective catalytic reduction (NSCR) for four-stroke rich burn (4SRB)
engines are applicable controls for CO and VOC reduction from existing stationary spark ignition
RICE to the extent of close to 70 percent. To determine the validity and costs for these catalytic
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control technologies, equipment information was obtained from industry groups [17] and vendors
and manufacturers of spark ignition engine control technology. Catalyst and NSCR require
exhaust to be heated to activate the catalyst; the exhaust post baghouse would require an
additional burner close to 10 MMBtu/hr or 2,930 kW. Further, a considerable amount of
backpressure would be added due to a catalyst or NSCR. For purposes of energy impacts from
backpressure, third-party engineers would estimate that dryer efficiency would likely be affected
close to ten percent; this would equate to an energy impact of 1.8 MMBtu/hr or 527 kW. The
energy impact and additional burners needed for CO and VOC control are infeasible in practice,
and further, these would increase NOX emissions per ton of aggregate dryer.
2.2.3 Fuel Consideration
Natural gas is delivered via pipeline to the Wildcat facility for fuel use for the sand dryers. When
natural gas is utilized, LNB technologies can have less cost and environmental impact than other
fuels, such as propane. LNB technologies for propane are less researched/developed and
inherently higher with NOX emissions due to chemical properties, therefore natural gas is
cleanest fuel that can be delivered to the facility for sand dryer combustion.
2.2.4 Environmental Impacts
Environmental impacts include any unconventional or unusual impacts of using a control device,
such as the generation of solid or hazardous waste, water discharges, visibility impacts, or
emissions of unregulated pollutants. For example, a wet scrubber may discharge contaminated
water, or a spent catalyst may create hazardous waste. Due to the infeasibility of energy impacts
for catalyst and NSCR technologies, these were eliminated in Section 2.2.2 from BACT, but for a
further example, spent catalyst that could be considered hazardous and would need to be
disposed of, or otherwise handled, every two to four years dependent upon vendor and
technology selected. Environmental impacts or PM and NOX control technologies are evaluated
because other criteria pollutants are not relevant for Wildcat’s sand dryers.

[17] NESHAP Emission Control Costs Analysis Background for “Above the Floor” Emission Controls for Gas-Fired RICE,
Innovative Environmental Solutions Inc., October 2009. (EPA-HQ-OAR2008-0708-0279).
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In terms of the plausible control devices for particulates to be used at the sand dryer, a wet
scrubber has the potential to discharge water, although it is very unlikely that this water would
be contaminated because sand is the only agent being sent to the water of a scrubber. In some
cases, discharges of high suspended solids in water from wet scrubbers can be a compliance
concern, but with appropriately handled pond systems, this is usually not an issue. Additionally,
a wet scrubber is not a very good candidate for controlling particulates, as scrubbers are not as
efficient at removing particulates as other control devices specifically meant for particulate
control.
Regarding possible control devices such as a baghouse and cyclone, the material captured by the
control device is not anticipated to be hazardous waste, as it is a recoverable product that Wildcat
can return to the process. Sand coating the bags or filters in a baghouse is not a concern when it
comes to disposal of bags that have aged out of usefulness or malfunctioned. Spent filter bags
are usually sent back to the vendor for recovery or to the landfill as non-hazardous waste.
LNB with FGR do not collect material or generate waste for environmental impact. Use of LNB
can sometimes have a negative effect on CO and VOC emissions due to loss of ignition and
retarded combustion. This increases CO and VOC emissions rate. As discussed earlier, Uintah
County is more focused on NOX removal from the environment as opposed to CO due to NOX’s
reactivity in the atmosphere, and CO’s lack thereof. LNB with FGR units are projected to have a
useful life close to ten years, so there would be an impact of disposing or recycling spent burner
materials of steel and ceramic.
Furthermore, the 54 MMBtu/hr burner required for the LNB with FGR option[18] increases all
pollutants, including HAP, VOC, CO, greenhouse gases (GHG), and non-filterable PM, except NOX,
by 50 percent from natural gas combustion.[19] This 50 percent increase results from increased
fuel usage required for a burner 50 percent larger than the proposed 38 MMBtu/hr Starjet burner
in comparison to the required 54 MMBtu/hr Megastar burner for the LNB with FGR option.

[18] January 28, 2020 LNB and FGR email assessment from Michael G. Blantz, Engineer of Honeywell.
[19] ARC and Honeywell emissions analysis and Honeywell ppm and lb/ton of aggregate manufacturer guarantee for
Legacy Hauck/HTP/HTS suite of burners and FGR.
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2.2.5 Economic Impacts
For economic impacts of control equipment, the costs of a baghouse, cyclone, and LNB with FGR
were analyzed, as all other technologies included within Section 2.2 have been previously ruled
as an ineffective or infeasible control equipment at the site for their limited ability to remove
pollutants of interest. This section analyzes the cost of the identified control equipment and the
cost per ton of pollutant control. These numbers are prior to considering any potential taxes or
subsidies on the control equipment, as identified in Form 01b for BACT analysis.
The following tables identify the capital and annual costs of each control technology that would
be incurred to Wildcat if implemented.
Table 4: Capital Cost of Control Equipment per Dryer [20]
Control Device Expenditure Item Capital Cost Initial Total Cost
Baghouse Baghouse $155,189 $176,950 Insulation $21,761
Cyclone
Cyclone $74,101
$101,635 Vortex Breaker $6,312
Cyclone Insulation $21,222
LNB Low-NOX Burner $98,851 $98,851
LNB with FGR Low-NOX Burner with FGR $172,202 $197,702 Faceplate Mod $25,500
In addition to an initial capital cost, there are annual operating and maintenance (O&M) costs
per control device. In certain cases, there is an expected downtime for the sand dryer to service
and maintain the control device. At least annually, the dryers will need to be shut down to open
the baghouses internally and evaluate filter media for damage or replacement needs. The LNB
and FGR will need to be serviced and tuned to ensure the emission rates provided are being
attained. In both cases, it takes time for shutdown, equipment cooling, maintenance, targeted
tuning and adjustments, and startup. For the baghouse and LNB, each occurrence of inspection
and tuning would be expected to take a full day, or approximately eight hours. Third-party

[20] Tarmac Quotes SD780R5 and SD-949.
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engineers would estimate that dryer efficiency would likely be affected by 17 percent,[21] or
approximately 25.5 tons per hour, for a 150 ton per hour dryer. According to burner
manufacturer’s Legacy Hauck-Honeywell, an LNB with FGR would require a burner of 54
MMBtu/hr to be able to achieve 150 tons per hour drying rate. These annual O&M and increased
fuel usage costs are further detailed in Table 5a.
Table 5a: Annual Reoccurring Cost to Service Control Equipment per Dryer with Hourly Loss
Control Device Service Item [22] O&M Cost Total Annual O&M Cost
Baghouse Filter Media Replacement $30,000 per year $100,000 Annual Shutdown Insp. $70,000 per year
Cyclone Annual Shutdown Insp. $70,000 per year $70,000
Starjet LNB
Annual Burner Tuning $120,000 per year
$133,286 Annual Expert Tuner $13,286 per year
Megastar LNB
Semiannual Burner Tuning $240,000 per year
$607,067-682,444 Semiannual Expert Tuner $26,572 per year
Lost Drying Efficiency [26] $40-48 per hour
Megastar LNB with
FGR
Semiannual Burner Tuning $240,000 per year
$607,067-$682,444 Semiannual Expert Tuner $26,572 per year
Lost Drying Efficiency [23] $40-48 per hour

[21] January 28, 2020 LNB and FGR email assessment from Michael G. Blantz, Engineer of Honeywell.
[22] Currently and historically for the last five years, dry sand, silica sells on the market between $50 to $100 per ton.
Wildcat’s dryers are designed to operate at 150 tons per hour without LNB. On an hourly basis, this equates to $7,500
if the minimum price of sand per ton is assumed, 150 ton/hr * $50 = $7,500 per hour. The Service Estimate attached
as supporting documentation plans for two days where the plant will not be running. Expert tuning will be necessary
once per year for the Starjet burner, and twice per year for the Megastar burner. Each O&M outage is expected to
be eight hours, 8 hr * $7,500/hr * two days = $120,000 for each service period.
[23] As explained in Section 2.2.2, LNB and FGR reduce thermal efficiency by approximately a minimum of 17 percent.
Honeywell experts indicate a 54 MMBtu/hr burner would be needed to maintain the 150 tons per hour drying
capacity. For each additional MMBtu/hr of natural gas needed would equate to close to three dollars per hour, if
not more. As an example for Dryer #2, to be conservative, three dollars per MMBtu of natural gas is assumed 16
MMBtu/hr * $3/MMBtu = $48/hr, which could be 8,664 hrs at $48/hr of lost production, 8,664 = 8,760 hr/yr minus
96 hr/yr of O&M, for total of $415,872/yr.
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Table 5b: Annual Reoccurring Cost to Service Control Equipment per Dryer without Loss
Control Device Service Item O&M Cost Total Annual O&M Cost
Baghouse
Filter Media Replacement $30,000 per year
$100,000 Annual Shutdown Insp. $70,000 per year
Cyclone Annual Shutdown Insp. $70,000 per year $70,000
Starjet LNB
Annual Burner Tuning $120,000 per year
$133,286 Annual Expert Tuner $13,286 per year
Megastar LNB
Semiannual Burner Tuning $240,000 per year
$266,572 Semiannual Expert Tuner $26,572 per year
Megastar LNB with
FGR
Semiannual Burner Tuning $120,000 per year
$266,572 Semiannual Expert Tuner $26,572 per year
Table 5b details the annual O&M cost for each control device without the hourly production loss
component. Furthermore, based on the costs of these control devices, Tables 6 through 7 on the
following page describes the pollutant removal efficiencies of each control device and the cost
per ton of pollutant control over the course of the first year of the control device being active.
For the purposes of this analysis, PM, PM10, and PM2.5 have been speciated.
When gathering an emissions profile for the process at Wildcat, it was conservatively calculated
that PM, PM10, and PM2.5 emission factors were identical for natural gas combustion purposes.
During the process of sand drying, it is more likely that larger particles than PM10 would be
emitted due to the size of sand mined and processed. The PM emission factors were used with a
conservative assumption that 50 percent of emitted PM is for PM10 and PM2.5.
The baghouse was conservatively assumed to have a 99% control efficiency of all particulates.
The cyclone control efficiency was taken from AP-42 Appendix B.2, Table B.2-3 (09/1990, AIRS
code 075) for a single cyclone. Cyclones typically have a larger removal efficiency for larger
particulates based on design. The cut size of a particulate that can be controlled via centrifugal
forces is generally much larger than what can be captured by a physical media like a bag or filter.
Uncontrolled NOX emissions are based upon emission factors from EPA’s AP-42 Tables 1.4 for
Natural Gas Combustion (7/1998) with a conversion factor such that 1,050 MMBtu is 1,000,000
standard cubic foot (MMscf). The controlled NOX rate with LNB and FGR was provided by Tarmac
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and Honeywell/Hauck as would be the lowest emitting NOX technology on the market and
specifically designed for the Tarmac sand dryer [24].
Table 6a. Controlled Costs of Dollar per Ton of Pollutant Reduced without FGR with Hourly Loss
Dryer Pollutant
Dryer
Uncontrolled
Emissions
(tons/yr)
Baghouse/
Cyclone & LNB
Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 512.91 312.99 364.28
NOX 16.34 13.50 34,828.27 213,888.61 217,371.43
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 13.50 34,828.27 240,449.19 243,929.02
Table 6b. Controlled Costs of Dollar per Ton of Pollutant Reduced without FGR without Loss[25]
Dryer Pollutant
Dryer
Uncontrolled
Emissions
(tons/yr)
Baghouse/
Cyclone & LNB
Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 512.91 312.99 364.28
NOX 16.34 13.50 34,828.27 93,921.59 97,404.41
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 13.50 34,828.27 93,921.59 97,404.41

[24] Tarmac Quotes SD780R5 and SD-949, NOX of Megastar LNB emits at 80 ppm and 0.025 lbs of NOX per ton of sand;
LNB and FGR emits at 36 ppm and 0.011 lbs of NOX per ton of sand for $197,702 capital.
25 Table 6b and 7b are included at the Division’s Request. ARC does not agree that BACT does not include production
loss.
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Table 7a. Controlled Costs of Dollar per Ton of Pollutant Reduced with FGR with Hourly Loss
Dryer Pollutant
Dryer
Uncontrolled
Emissions
(tons/yr)
Baghouse/
Cyclone & Megastar
& FGR Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 512.91 312.99 364.28
NOX 16.34 6.18 19,451.60 59,728.43 61,673.59
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 6.18 19,451.60 67,144.64 69,089.80
Table 7b. Controlled Costs of Dollar per Ton of Pollutant Reduced with FGR without Loss[25]
Dryer Pollutant
Dryer
Uncontrolled
Emissions
(tons/yr)
Baghouse/
Cyclone & Megastar
& FGR Controlled
Emissions
(tons/yr)
Initial
Capital
Cost
($/ton)
Annual O&M
& Added Fuel
Cost
($/ton/yr)
10-Year Annualized
Capital & O&M Total
Cost
($/ton/yr)
Dryer #1
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 548.63 5.49 512.91 312.99 364.28
NOX 16.34 6.18 19,451.60 26,227.62 28,172.78
Dryer #2
PM/PM10/PM2.5
(FILTERABLE PM ONLY) 1,309.06 13.09 214.96 131.18 152.67
NOX 16.34 6.18 19,451.60 26,227.62 28,172.78
Based upon Tables 6 and 7, the economic ten-year annualized cost for the baghouse and cyclone
tandem is cost effective for BACT. When considering the O&M and increased fuel from Megastar
LNB without FGR as shown in Table 5a, the 10-year annualized capital and O&M cost would be
$217,371.43 for Dryer #1 and $243,929.02 for Dryer #2 per ton of NOX. Without FGR, the
Megastar technology is capable of potentially removing less than three tons of NOX per year. The
emissions from the Megastar LNB only burner technology was calculated, showing that most of
the attributed to additional fuel required for the Megastar burner; if a thermal efficiency
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production loss is accounted, the ten-year annualized cost for LNB is $61,673.59 per ton of NOX
removed per year for Dryer #1 and $69,089.80 per ton of NOX removed per year for Dryer #2.
These economic scenarios demonstrate that Megastar LNB, and Megastar LNB with FGR are not
feasible on a cost basis which was also alluded to in Section 2.2.2 in evaluation of energy impacts.
Thus, the analysis for Wildcat’s sand dryer deems a cyclone and baghouse tandem is BACT, and
the sand dryer is consistent with, and better than, EPA’s requirements and review pursuant to
CAA Section 111; LNB with FGR is not feasible for Wildcat’s sand dryer based on energy and
economic impact.
2.3 Potential BACT Options for Filter Press Engine: Item 19
2.3.1 Energy Impacts
Certain types of control technologies have inherent energy penalties associated with their use
and industry application. New, modern engines utilize clean technology that are NSPS site
compliant capable. The use of post-manufacturing add-on controls would require additional
energy consumption for the manufacturing and transport of the Engine as well as the transport
of manpower required for assembly and troubleshooting. It is difficult to estimate the amount of
energy needed, however the low-emissions levels of the Engine deem add-ons infeasible.
2.3.2 Environmental Impacts
Environmental impacts include any unconventional or unusual impacts of using a control device,
such as the generation of solid or hazardous waste, water discharges, visibility impacts, or
emissions of unregulated pollutants. In the case of the natural gas Engine, spent catalyst
reduction agent that could be considered hazardous would need to be disposed of, or otherwise
handled, every two to four years, dependent on vendor and technology selected.
2.3.3 Economic Impacts
Pollutant emissions from the internal combustion engine include NOX, PM10, PM2.5, CO, and VOCs.
Annual operation of the Engine will be 8,760 hours. The potential emissions from the Engine are
provided in Table 8. The following analysis will illustrate that the use of the Engine as supplied by
the manufacturer without any additional emission control methods is recommended due to
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meeting or being below the standards for appropriate emissions as outlined in 40 CFR Part 60,
Subpart JJJJ, and any additional control technologies would create an undue cost burden on the
Sand Plant.
Table 8. Internal Combustion Engine Emissions
Component Operating
Hours Size NOX
(tpy)
PM10
(tpy)
PM2.5
(tpy)
SOX
(tpy)
CO
(tpy)
VOC
(tpy)
Engine 8,760 416 kW 9.32 0.15 0.15 0.01 18.63 1.75
Based on research and engineering experience, the control technologies for internal combustion
engines listed in Table 9 were considered for this BACT analysis.
Table 9. Control Technologies for Internal Combustion Engines
Pollutant Control Technology
CO/VOC Oxidation Catalyst
NOX Exhaust Recirculation [26], Selective Catalytic Reduction (SCR), Non-SCR (NSCR), Lean
Combustion (LC), Good Combustion Practices
PM10/PM2.5 Fabric Filters, Dry ESP, Wet ESP, Venturi Scrubber, Good Combustion Practices
The Engine is subject to the NOX, CO, and VOC standards outlines in Table 1 of 40 CFR Part 60,
Subpart JJJJ for non-emergency spark ignition natural gas engines between 100 hp and 500 hp
manufactured after July 1, 2008. The Engine, as manufactured, meets the standards, therefore,
no additional control technology will be required or used with the Engine.
Table 10. Engine Emission Standards from Table 1, 40 CFR Part 60, Subpart JJJJ
Pollutant JJJJ Standard (g/hp-hr)
CO 4.0
VOC 1.0
NOX 2.0

26 Exhaust gas recirculation is not part of the original manufacturer design. Therefore, it is not feasible without
substantial engineering overhaul of the units
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Non-Selective Catalytic Reduction (NSCR) was evaluated. NSCR is often referred to as a three-
way conversion catalyst system because the catalyst reactor simultaneously reduces NOX, CO and
hydrocarbons, and involves placing a catalyst in the exhaust stream of the Engine. However, NSCR
technology works with rich-burn engines only. Because the Engine is a lean-burn unit, the use of
a NSCR is not applicable.
Selective Catalytic Reduction (SCR) is used to reduce NOX emissions from lean-burn engines using
a reducing agent, such as ammonia or urea. SCR systems inject the reduction agent into the lean-
burn exhaust stream. The agent reacts selectively with the flue gas NOX, converting it to
molecular nitrogen (N2), and water vapor (H2O). Control for a SCR system is typically 80-95%
reduction of NOX (EPA, AP-42 Section 3.2).
An oxidation catalyst is a post-combustion technology that has been shown to reduce CO
emissions in lean-burn engines. Ina catalytic oxidation system, CO passes over a catalyst, usually
a noble metal, which oxidizes the CO to CO2 at efficiencies of approximately 90% for 4-stroke
lean-burn engines. When used in conjunction with a SCR system, the CO2, water, and NOX then
enter the SCR catalyst, where the NOX reacts with the reducing agent.
The Engine, using lean combustion technology involves the increase of the air-to-fuel ratio to
lower the peak combustion temperature, thus reducing formation of NOX. Typically, engines
operate at the air-to-fuel ratio of about 20 to 35 pounds of air to pound of fuel. In a typical Lean-
Burn engine, this ratio is increased to 45 to 50. With a conventional spark ignition, the air fuel
ratio can only be increased to a certain point before the onset of lean misfire. To avoid misfire
problems and to ensure complete combustion of very lean mixtures, the engine manufacturers
have developed torch ignition technology and the application of a controlled swirl. Some increase
in fuel consumption and CO and HC emissions results from the slower flame propagation for very
lean mixtures. At optimal setting new lean burn engines can achieve NOX levels of 2 g/hp-hr (gram
per horsepower-hour) or below. This corresponds to an 80 to 90 percent control over
conventional spark plug design engines.
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The total estimated capital investment associated with the installation, startup, and equipment
costs of a SCR is $2,127,689 in 2023 dollars, in accordance with EPA’s Cost Reports and Guidance
for Air Pollution Regulations, Section 4, SCR Cost Calculation Spreadsheet (updated 06/12/2019).
This total is calculated based on industry costs collected and validated by the EPA in 2016 and
then adjusted to 2023 dollars on the Chemical Engineering Plant Cost Index (CEPCI). It was
estimated that each catalyst has an operational life of 20,000 hours. Because the Engine will
operate 8,760 hours annually, it is determined that significant maintenance activities will be
required every 27 months. Each SCR unit is anticipated to have a use life of 20 years before
requiring complete replacement. With an effectiveness in reducing NOX emissions by 85%, a SCR
would remove an estimated 7.93 tpy. This results in a cost effectiveness of $34,060 per ton of
NOX removed in 2023 dollars.
2.4 Other Considerations
Form 01b for BACT determination guidance from the Division lists 11 “other considerations” for
BACT analyses. Per each consideration listed, Wildcat and ARC are providing response as follows.
1. “When exceeding otherwise appropriate costs by a moderate amount would result in a
substantial additional emissions reduction.”
Based on the analysis of this BACT determination, the pollution control cost for PM reduction
technologies provides the maximum amount of PM removal. NOX only has the potential to
be reduced by 10.16 tons of NOX per year for each dryer and 7.93 tons of NOX per year for
the Engine based upon potential to emit. The small amount is due to Wildcat’s relatively small
burner and Engine in terms of comparison to large industrial aggregate producers and
synthetic minor/major sources of emissions. Wildcat is a natural minor source of emissions.
Additionally, the Engine emissions are below the standards for appropriate emissions as
outline in 40 CFR Part 60, Subpart JJJJ. There are no control technologies that would result in
a substantial additional emissions reduction, therefore the cost associated with any add-on
control technology would be considered substantial and well beyond a moderate amount.

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2. “When a control technology would achieve controls of more than one pollutant (including
HAPs).”
Particulate control equipment does have the ability to remove solid metallic HAPs, however,
it is assumed that any metallic HAP emissions from Dryer #1, Dryer #2, or Engine would be
negligible, and an analysis of metallic HAPs was not included in this determination. A
baghouse is not likely to control any gaseous pollutants. LNB with FGR is not considered to
reduce HAPs or any other pollutant besides NOX, and as shown in Section 2.2.1, HAPs are
increased with LNB and FGR. The NSCR is the only control technology available for the Engine
that could reduce NOX and CO, however the technology only works with rich-burn engines.
Because the Engine is a lean-burn unit, use of a NSCR is not appliable.
3. “Where the proposed BACT level would cause a new violation of an applicable NAAQS or PSD
increment. A permit cannot be issued to a source that would cause a new violation of either.”
This BACT will not cause a violation of NAAQS or PSD for any proposed equipment.
4. “When there are legal constraints outside of the Clean Air Act, such as a SIP or state rule,
requiring the application of a more stringent technology than one which otherwise would
have been determined to be BACT.”
There are no additional legal constraints that would require more stringent technology for
the equipment analyzed in this BACT report.
5. “Any time a permit limit founded in BACT is being considered for revision, a reopening of the
original BACT determination must be made, even if the permit limit is exceeded by less than
the significant amount. Therefore, all controls upstream of the emission point, including
existing controls, must be re-evaluated for BACT.”
Dryer #1 BACT was within AO #DAQE-IN159980003-21, issued July 1, 2021. The Wildcat Dryer
#2 and Engine are new equipment and new BACT determinations; an analysis of existing
equipment is included in Section 2.1.
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6. “The cost of all controls, including existing controls and any proposed control improvements,
should be expressed in terms of a single dollar year, preferably the current year. Any proposed
improvements should then be added to that cost, also in today’s dollars.”
The cost of control for Dryers #1 and #2 were determined using the dollar year 2019 and
2020, consistent with vendor quotes collected for the project. The cost of control for the
Engine was determined using dollar year 2023.
7. “EPA cannot provide a specific cost figure for cost/ton of pollutant removed without
contradicting the PSD definition of BACT. They recognize that a case-by-case evaluation is
inherently judgmental and can be particularly difficult without a cost guideline.”
The impacts of energy and costs of control were determined using EPA emission factors,
control efficiencies, and published studies.
8. “A top-down type of BACT analysis is recommended by EPA and required by Utah.”
A top-down type of BACT analysis was used, and ARC and Wildcat were over inclusive in
considering several control technologies, including CO and VOC not demonstrated in any case
publicly available, permitted, or published.
9. “DAQ will review BACT determination for plants not yet built, if those plants have already
applied for AOs and BACT determinations have already been made or proposed.”
The new Wildcat Dryer #2 and Engine are not yet constructed. The Sand Plant has an issued
AO and BACT determination for the current sand dryer, haul roads, and process equipment.
10. “Utah must ensure that any technically feasible improvements to existing controls that would
fall within the realm of reasonableness be considered, unless the improvement would yield
insignificant additional control.”
All reasonable controls have been considered for this analysis.
11. “In all cases, a complete BACT analysis must be submitted and must consider environmental
and energy, as well as economic impacts, unless an existing BACT determination/approval is
applicable to your source and is acceptable to the DAQ.”
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The proposed BACT for Wildcat follows Form 01b, UAC R307-101-2, EPA federal standards,
and capability of the sand drying techniques nationwide.

Vendor, Emissions, & EPA Supporting Documentation