DAQ-2025-002434

DAQE-AN143010002-25

{{$d1 }}

Karl Kunz
White Flame, Inc.
125 South 1800 West
Lindon, UT 84042
[e-mail]

Dear Mr. Kunz:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN0143010001-10 for a
10-Year Review and Permit Updates
Project Number: N143010002

The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a 10-year
administrative review of this source and its respective AO. White Flame, Inc. must comply with the
requirements of this AO, all applicable state requirements (R307), and Federal Standards.

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

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:LM:jg

cc: Utah County Health Department

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Tim Davis
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

May 13, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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

APPROVAL ORDER
DAQE-AN143010002-25
Administrative Amendment to Approval Order
DAQE-AN0143010001-10 for a 10-Year Review
and Permit Updates

Prepared By
Lucia Mason, Engineer
[phone]
[e-mail]

Issued to
White Flame, Inc. - Lindon Wood Pellet Manufacturing Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

May 13, 2025
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 ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN143010002-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
White Flame, Inc. White Flame, Inc. - Lindon Wood Pellet Manufacturing Plant

Mailing Address Physical Address
125 South 1800 West 125 South 1800 West
Lindon, UT 84042 Lindon, UT 84042

Source Contact UTM Coordinates
Name: Karl Kunz 435,708 m Easting
Phone: [phone],465,278 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2499 (Wood Products, NEC)

SOURCE INFORMATION
General Description
White Flame, Inc. operates a wood pellet manufacturing facility in Lindon, Utah County. Clean scrap
wood arrives at the facility to be either processed as wood stakes or ground into coarse sawdust and
compressed into wood pellets. Wood to be made into wood stakes is sent through a shaker conveyor to
remove sawdust and odd-sized pieces. Remaining wood is processed into wood pellets using the
following emission-generating equipment: one (1) grinder hog, one (1) hammer mill, one (1) cyclone,
several storage silos, and assorted conveyors. Emissions from the grinder hog, hammermill, and cyclone
are routed through a baghouse. No chemical binders are used in pellet processing. One (1) 12
MMBtu/hour drum dryer is onsite but not currently used. The source is qualified under the small source
exemption rules but has opted to maintain their Approval Order.

NSR Classification
10-Year Review

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

DAQE-AN143010002-25
Page 4

Applicable Federal Standards
None
Project Description
This is an administrative amendment to AO DAQE-AN0143010001-10, dated August 23, 2010. The
DAQ is conducting a 10-year review to update the language, format, and rule applicability of the 2010
AO. Notable changes are listed below:

1) AO DAQE-AN0143010001-10 included requirements regarding mobile engines in conditions
II.B.1.a(B), II.B.1.b(D), and II.B.1.b(E). NSR permits do not regulate mobile equipment. The emissions
and requirements regarding mobile equipment have been removed from this AO.

2) One (1) grinder hog and one (1) hammer mill were included in the facility's 2010 emission estimates
but were not listed as approved equipment in AO DAQE-AN0143010001-10. The grinder hog and
hammer mill have been added to the approved equipment list.

3) PM2.5 and CO2e emissions were not included in AO DAQE-AN0143010001-10 and have been added to
the Summary of Emissions.

4) CO emissions were incorrectly calculated in 2010 and have been corrected. HAP emissions have been
recalculated as well.

SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 2130.00
Carbon Monoxide -0.68 1.48
Nitrogen Oxides -2.53 1.76
Particulate Matter - PM10 -0.18 0.32
Particulate Matter - PM2.5 0 0.32
Sulfur Dioxide -0.16 0.01
Volatile Organic Compounds 0 0.10

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) -1 3
Generic HAPs (CAS #GHAPS) 0 3
Hexane (CAS #110543) 0 64
Change (TPY) Total (TPY)
Total HAPs 0.03 0.03

DAQE-AN143010002-25
Page 5

SECTION I: GENERAL PROVISIONS

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

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Wood Pellet Manufacturing Plant
II.A.2 One (1) Grinder Hog
Control: Baghouse
II.A.3 One (1) Hammer Mill Control: Baghouse
II.A.4 One (1) Cyclone Rating: 5,500 ACFM
Control: Baghouse

DAQE-AN143010002-25
Page 6

II.A.5 One (1) Baghouse Rating: 2,800 ACFM Control for: Grinder Hog (Equipment ID II.A.2) Hammer Mill (Equipment ID II.A.3) Cyclone (Equipment ID II.A.4)
II.A.6 One (1) Drum Dryer Rating: 12 MMBtu/hour
II.A.7 Assorted Conveyors Including One (1) Shaker Conveyor II.A.8 Mobile Equipment
Two (2) Forklifts One (1) Front-end Loader
- Listed for informational purposes only -

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-wide Requirements
II.B.1.a The owner/operator shall produce no more than 72,000 tons of wood pellets per rolling 12-month period. [R307-401-8]

II.B.1.a.1 To determine compliance with the above production limit, the owner/operator shall: A. Determine wood pellet production by scale house records or shipping records B. Record wood pellet production daily C. Use wood pellet production data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep records of wood pellet production for all periods the plant is in operation. [R307-401-8]
II.B.1.b The owner/operator shall in-take no more than 36,000 tons of sawdust per rolling 12-month period. [R307-401-8]

DAQE-AN143010002-25
Page 7

II.B.1.b.1 To determine compliance with the above process limit, the owner/operator shall: A. Determine sawdust in-take by vendors' billings B. Record sawdust in-take daily C. Use sawdust in-take data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep records of sawdust in-take for all periods the plant is in operation. [R307-401-8] II.B.1.c The owner/operator shall consume no more than 35.29 MMBtu of natural gas per rolling
12-month period. [R307-401-8]
II.B.1.c.1 To determine compliance with the above consumption limit, the owner/operator shall: A. Determine natural gas consumption by billing or purchase records B. Record natural gas consumption daily C. Use natural gas consumption data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep records of natural gas consumption for all periods the plant is in operation. [R307-401-8]
II.B.1.d The owner/operator shall only receive scrap wood for processing into wood pellets that is free of
coatings such as varnish, paint, oil, or contaminants. [R307-401-8]
II.B.1.e The owner/operator shall not exceed the following opacity limits: A. All conveyor transfer points - 10% opacity B. All conveyor drop points - 10% opacity C. The baghouse (Equipment ID II.A.5) - 20% opacity. [R307-401-8]
II.B.1.e.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.2 Fugitive Dust Requirements
II.B.2.a The owner/operator shall not allow visible emissions from any fugitive dust source to exceed
20% opacity on site and 10% opacity at the property boundary. [R307-309-5]

II.B.2.a.1 Visible emission determinations 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 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5]
DAQE-AN143010002-25
Page 8

II.B.2.b The owner/operator shall apply water treatment or chemical dust suppression treatment on all areas on site disturbed by mobile equipment to control fugitive dust emissions. Application shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN0143010001-10 dated August 23, 2010 Incorporates Additional Information dated March 12, 2025

DAQE-AN143010002-25
Page 9

ACRONYMS

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

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

DAQE-

RN143010002 May 6, 2025 Karl Kunz
White Flame, Inc. 125 South 1800 West Lindon, UT 84042
[e-mail] Dear Karl Kunz,
Re: Engineer Review - Administrative Amendment to Approval Order (AO) DAQE-AN0143010001-10 for a 10-Year Review and Permit Updates Project Number: N143010002 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. White Flame, Inc. should complete this review within 10 business days of receipt. White Flame, Inc. should contact Lucia Mason at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Lucia Mason at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If White Flame, Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If White Flame, Inc. has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.
Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Tim Davis Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N143010002 Owner Name White Flame, Inc. Mailing Address 125 South 1800 West
Lindon, UT, 84042 Source Name White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant
Source Location 125 South 1800 West Lindon, UT 84042
UTM Projection 435,708 m Easting, 4,465,278 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2499 (Wood Products, NEC) Source Contact Karl Kunz Phone Number [phone] Email [e-mail] Billing Contact Karl Kunz Phone Number [phone]
Email [e-mail] Project Engineer Lucia Mason, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted October 24, 2024 Date of Accepted Application March 12, 2025

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 2
SOURCE DESCRIPTION General Description
White Flame, Inc. operates a wood pellet manufacturing facility in Lindon, Utah County. Clean scrap wood arrives at the facility to be either processed as wood stakes or ground into coarse sawdust and compressed into wood pellets. Wood to be made into wood stakes is sent through a
shaker conveyor to remove sawdust and odd sized pieces. Remaining wood is processed into wood pellets using the following emission generating equipment: one (1) grinder hog, one (1) hammer mill, one (1) cyclone, several storage silos and assorted conveyors. Emissions from the grinder hog, hammermill and cyclone are routed through a baghouse. No chemical binders are used in pellet processing. One (1) 12 MMBtu/hour drum dryer is onsite but not currently used. The source is qualified under the small source exemption rules but has opted to maintain their Approval Order. NSR Classification: 10 Year Review
Source Classification Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA Utah County
Airs Source Size: B Applicable Federal Standards
None Project Proposal Administrative Amendment to Approval Order (AO) DAQE-AN0143010001-10 for a 10-Year Review and Permit Updates
Project Description This is an administrative amendment to Approval Order (AO) DAQE-AN0143010001-10, dated August 23, 2010. The DAQ is conducting a 10-year review to update the language, format, and rule applicability of the 2010 AO. Notable changes are listed below: 1) AO DAQE-AN0143010001-10 included requirements regarding mobile engines in conditions II.B.1.a(B), II.B.1.b(D), and II.B.1.b(E). NSR permits do not regulate mobile equipment. The emissions and requirements regarding mobile equipment have been removed from this AO.
2) One (1) grinder hog and one (1) hammer mill were included in the facility's 2010 emission estimates but were not listed as approved equipment in AO DAQE-AN0143010001-10. The
grinder hog and hammer mill have been added to the approved equipment list. 3) PM2.5 and CO2e emissions were not included in DAQE-AN0143010001-10 and have been
added to the Summary of Emissions. 4) CO emissions were incorrectly calculated in 2010 and have been corrected. HAP emissions
have been recalculated as well.

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 3
EMISSION IMPACT ANALYSIS This is a 10-year review. No changes are being made to equipment or operations. Therefore, modeling is not
required. [Last updated May 6, 2025]

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 4
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 2130.00 Carbon Monoxide -0.68 1.48
Nitrogen Oxides -2.53 1.76
Particulate Matter - PM10 -0.18 0.32
Particulate Matter - PM2.5 0 0.32
Sulfur Dioxide -0.16 0.01
Volatile Organic Compounds 0 0.10 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) -1 3
Generic HAPs (CAS #GHAPS) 0 3
Hexane (CAS #110543) 0 64
Change (TPY) Total (TPY)
Total HAPs 0.03 0.03 Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 5
Review of BACT for New/Modified Emission Units 1. BACT review regarding 10-Year Review
This is a 10-year review. No changes are being made to equipment or operations. Therefore, a BACT analysis is not required. [Last updated March 13, 2025]
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 N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 6
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Wood Pellet Manufacturing Plant
II.A.2 NEW One (1) Grinder Hog Control: Baghouse

II.A.3
NEW
One (1) Hammer Mill
Control: Baghouse
II.A.4 One (1) Cyclone Rating: 5,500 ACFM Control: Baghouse
II.A.5 One (1) Baghouse Rating: 2,800 ACFM Control for:
- Grinder Hog (Equipment ID II.A.2)
- Hammer Mill (Equipment ID II.A.3)
- Cyclone (Equipment ID II.A.4)
II.A.6 One (1) Drum Dryer Rating: 12 MMBtu/hour

II.A.7 Assorted Conveyors
Including One (1) Shaker Conveyor
II.A.8 Mobile Equipment Two (2) Forklifts One (1) Front-end Loader
- Listed for informational purposes only -

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 7
SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 NEW Site-wide Requirements
II.B.1.a NEW The owner/operator shall produce no more than 72,000 tons of wood pellets per rolling 12-month period. [R307-401-8]
II.B.1.a.1
NEW
To determine compliance with the above production limit, the owner/operator shall:
A. Determine wood pellet production by scale house records or shipping records B. Record wood pellet production daily C. Use wood pellet production data to calculate a new 12-month total by the 20th day of
each month using data from the previous 12 months
D. Keep records of wood pellet production for all periods the plant is in operation [R307-401-8]
II.B.1.b NEW The owner/operator shall in-take no more than 36,000 tons of sawdust per rolling 12-month period. [R307-401-8]
II.B.1.b.1 NEW To determine compliance with the above process limit, the owner/operator shall: A. Determine sawdust in-take by vendors' billings
B. Record sawdust in-take daily
C. Use sawdust in-take data to calculate a new 12-month total by the 20th day of each
month using data from the previous 12 months
D. Keep records of sawdust in-take for all periods the plant is in operation
[R307-401-8]

II.B.1.c NEW The owner/operator shall consume no more than 35.29 MMBtu of natural gas per rolling 12-month period. [R307-401-8]

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 8
II.B.1.c.1 NEW To determine compliance with the above consumption limit, the owner/operator shall:
A. Determine natural gas consumption by billing or purchase records
B. Record natural gas consumption daily C. Use natural gas consumption data to calculate a new 12-month total by the 20th day of
each month using data from the previous 12 months
D. Keep records of natural gas consumption for all periods the plant is in operation
[R307-401-8]
II.B.1.d
NEW
The owner/operator shall only receive scrap wood for processing into wood pellets that is free
of coatings such as varnish, paint, oil, or contaminants. [R307-401-8] II.B.1.e NEW The owner/operator shall not exceed the following opacity limits: A. All conveyor transfer points - 10% opacity B. All conveyor drop points - 10% opacity
C. The baghouse (Equipment ID II.A.5) - 20% opacity
[R307-401-8]

II.B.1.e.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.2 NEW Fugitive Dust Requirements
II.B.2.a
NEW
The owner/operator shall not allow visible emissions from any fugitive dust source to exceed
20% opacity on site and 10% opacity at the property boundary. [R307-309-5] II.B.2.a.1 NEW Visible emission determinations 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 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-309-5]

II.B.2.b NEW The owner/operator shall apply water treatment or chemical dust suppression treatment on all areas on site disturbed by mobile equipment to control fugitive dust emissions. Application shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-401-8]

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 9
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN0143010001-10 dated August 23, 2010
Incorporates Additional Information dated March 12, 2025
REVIEWER COMMENTS

1. Comment regarding 10-Year Review: This is a 10-year review. The language and formatting of this AO have been updated to reflect the style of modern permits. PTE values have been moved to a new section of the AO. All contact information has been updated. The source is not modifying and/or installing any equipment. Rule applicability has been reviewed and updated. On January 30, 2025, the source confirmed over the phone that they would like to maintain their AO despite qualifying as a small source under R307-401-9. Notable Equipment Updates: II.A.2 & II.A.3 - Based on the source file associated with the 2010 modification, one (1) grinder hog and one (1) hammer mill were included in the facility's 2010 emission estimates but were not listed
as approved equipment in AO DAQE-AN0143010001-10. On March 12, 2025, the source confirmed over the phone that all emissions from the grinder hog, hammer mill and cyclone are routed to the baghouse. This correlates with the emission calculations done in 2010. The grinder hog and hammer mill have been added to the approved equipment list. II.A.6 - On January 30, 2025, the source confirmed over the phone that the 12 MMBtu/hr drum dryer onsite is not currently in use but that they would like to keep it on their AO in case the dryer is needed in the future. The source currently processes kiln-dried wood. The drum dryer would be needed if the facility began processing woody biomass.
II.A.8 - The source's previous AO listed one (1) front-end loader (DAQE-AN0143010001-10, II.A.5) and two (2) forklifts (DAQE-AN0143010001-10, II.A.6) as approved equipment. Mobile equipment is outside of the scope of NSR permits. The front-end loader and forklifts have been
listed for informational purposes only.
Notable Condition Updates: II.B.2.a & II.B.2.a.1 - General fugitive dust opacity limits have been added to the AO in accordance with R307-309-5. The corresponding monitoring, recordkeeping, and recording requirement has been added as well. II.B.1e (DAQE-AN0143010001-10) - The source changed location in 2010, prompting the permitting update that resulted in their most recent AO. The old AO included a condition requiring
the source to notify the DAQ when they had ceased operations at their former location (site ID 11236). The site associated with the old location was confirmed to be inactive and this condition has been removed as part of this 10-year review. II.B.1.a, & II.B.1.b (DAQE-AN0143010001-10) - The source's previous AO listed several conditions regarding mobile equipment. These conditions included an opacity limit on mobile equipment set in condition II.B.1.a(B), a propane usage limit for a forklift set in condition
II.B.1.b(D), and a limit on the operating hours of the facility's diesel-fueled forklift and loader set in condition II.B.1.b(E). Mobile equipment is outside the scope of NSR permits. The emissions and requirements regarding mobile equipment have been removed from this AO. See engineering review

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 10
"Comment Regarding Emission Calculations" for details regarding the removed emissions. Emission Updates: PM2.5 and CO2e emissions were not included in AO DAQE-AN0143010001-10 and have been added to the Summary of Emissions. CO emissions from the drum dryer were calculated using an incorrect emission factor in 2010 and have been corrected through this 10-year review. HAP emissions for the 12 MMBtu/hr drum dryer were also recalculated. These corrections account for the changes seen in
the Summary of Emissions table. See engineering review "Comment Regarding Emission Calculations" for details. [Last updated May 6, 2025]
2. Comment regarding Emission Calculations: The site's emission breakdown is as follows, in tons per year: Pollutants NOx CO PM10 PM2.5 VOC SO2 HAP ------------------------------------------------------------------------------------------------------------------------- Transfer Points (x7) - - 0.02 0.02 - - - Baghouse Controlled Emissions - - 0.04 0.04 - - - Drub Drier Burner 1.76 1.48 0.13 0.13 0.10 0.01 0.03 REMOVED: Loader, Diesel Engine -1.20 -0.26 -0.09 -0.09 - -0.08 -
REMOVED: Forklift, Diesel Engine -1.17 -0.25 -0.08 -0.08 - -0.08 - REMOVED: Forklift, LPG Engine -0.16 -0.24 -0.00 -0.00 - -0.00 -
------------------------------------------------------------------------------------------------------------------------- Total (Mobile Equipment Removed) 1.76 1.48 0.32 0.32 0.10 0.01 0.03 Except for CO, HAP, and CO2e emissions from the drum dryer, the emission breakdown listed above references the 2010 project file (included in the source file associated with this 10-year review). PM2.5 emissions were conservatively set equal to PM10 emissions. Emissions from the three mobile engines have been removed from the site's PTE. The emission factors and operating parameters used to calculated emissions associated with the drum dryer are listed below. Drum Dryer Emissions: Rating: 12 MMBtu/hr
Operational Hours: 3,000 (2010 project file, included in source file for this 10-year review) Fuel: Natural Gas, Fuel Heating Value: AP-42 1.4 CO: AP-42 Table 1.4-1 CO2, Methane, N2O, CO2e Global Warming Potentials: Ap-42 Table 1.4-2 & Table A-1 to Subpart A of Part 98 HAPs: AP-42 Tables 1.4-3 & 1.4-4
[Last updated May 6, 2025]
3. Comment regarding Federal Standard Applicability: The facility is not subject to 40 CFR 60 (NSPS), 40 CFR 61 (NESHAP) or 40 CFR 63 (MACT)
regulations. [Last updated March 12, 2025] 4. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 11
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 not subject to 40 CFR
60 (NSPS), 40 CFR 61 (NESHAP) or 40 CFR 63 (MACT) regulations. Therefore, Title V does not apply to this facility. [Last updated March 12, 2025]

Engineer Review N143010002: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant May 6, 2025 Page 12
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
State of Utah
SPENCER J. (`,OX
Governor
DEIDRE HENDERsori'
Lieu[Eliai`t Go\'cmor
Department of Environmental Quality
Tim I)t'vis
Exeoutive I)ircctor
DTVISJ()N Of. AIR QUALITY
Brycc c. Bird
Director
195 North 1950 West . Salt lcke Clt`.. UT
Moulmg Address; PO. Box 144820 . Salt Luke City, UT 841144820
Telephone (Sol) 536-4cOO . Ick (Sol) 536-4()99 . I.D.D (801) 903-3978
wrunv.deq.ulalLgov
Printed on lorl% recycled paper
RN143010002
May 6, 2025
Karl Kunz
White Flare, Inc.
125 South 1800 West
Lindon, ur 84042
[e-mail]
Dear Karl Kunz,
Re: Engineer Review -Administrative Amendment to Approval order (AO)
DAQE-AN0143010001 -10 for a 10-Year Review. and Pemit Updates
Project Number: N143010002
The DAQ requests a company representative review and sign the attached Engineer Review (ER).
This ER identifies all applicable clcments of the New Source Rcview (NSR) permitting program.
White Flame, lnc. should complete this review within 10 business days of receipt.
White Flame: Inc should contact Lucia Mason at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please
Engineer Review N143010002: White Flame, Inc. -Lmdon Wood Pellet Manufactunng Plant
May 6, 2o25
Page 1
email Lucia Mason at [e-mail] the signed cover letter. Upon receipt of the signed
cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director.
If white Flanie, Inc. does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If white Flame, Inc. has concerns that cannot be resolved
Engineer Review N 143010002: White Flame, Inc -Lindon Wood I'ellct Manufactunng Plant
May 6, 2()25
I)age 2
Equipment Details
Rating 12 MMBtu/hour
Operational Hours 3,000 hours/year
Firing Normal
Criteria Pollutant Concentration(ppm)
Emission
Factor(lb/10^6 scf)
Emission
Rate(lbs/hr)
Emission
Total(tons/year)Reference
NOX 100 1.18 1.76
CO 84 0.99 1.48PM107.6 0.09 0.13
PM2.5 7.6 0.09 0.13
SO2 0.6 0.01 0.01
VOC 5.5 0.06 0.10
Lead 0.0005 0.00 0.00
HAP 0.02 0.03 See Below
Green House Gas Pollutant
Global Warming
Potential
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 120,000 1,412 2,118
Methane (mass basis)25 2.3 0.03 0.04
N2O (mass basis)298 2.2 0.03 0.04CO2e2,130
Hazardous Air Pollutant
EmissionRate(lbs/hr)
EmissionTotal(tons/year)Reference
2-Methylnaphthalene 2.40E-05 2.82E-07 4.24E-073-Methylchloranthrene 1.80E-06 2.12E-08 3.18E-08
7,12-Dimethylbenz(a)anthracene 1.60E-05 1.88E-07 2.82E-07
Acenaphthene 1.80E-06 2.12E-08 3.18E-08
Acenaphthylene 1.80E-06 2.12E-08 3.18E-08
Anthracene 2.40E-06 2.82E-08 4.24E-08
Benz(a)anthracene 1.80E-06 2.12E-08 3.18E-08
Benzene 2.10E-03 2.47E-05 3.71E-05
Benzo(a)pyrene 1.20E-06 1.41E-08 2.12E-08Benzo(b)fluoranthene 1.80E-06 2.12E-08 3.18E-08
Benzo(g,h,i)perylene 1.20E-06 1.41E-08 2.12E-08
Benzo(k)fluoranthene 1.80E-06 2.12E-08 3.18E-08
Chrysene 1.80E-06 2.12E-08 3.18E-08
Dibenzo(a,h)anthracene 1.20E-06 1.41E-08 2.12E-08
Dichlorobenzene 1.20E-03 1.41E-05 2.12E-05
Fluoranthene 3.00E-06 3.53E-08 5.29E-08
Fluorene 2.80E-06 3.29E-08 4.94E-08
Formaldehyde 7.50E-02 8.82E-04 0.0013Hexane1.80E+00 2.12E-02 0.0318
Indeno(1,2,3-cd)pyrene 1.80E-06 2.12E-08 3.18E-08Naphthalene6.10E-04 7.18E-06 1.08E-05
Phenanathrene 1.70E-05 2.00E-07 3.00E-07
Pyrene 5.00E-06 5.88E-08 8.82E-08
Toluene 3.40E-03 4.00E-05 6.00E-05
Arsenic 2.00E-04 2.35E-06 3.53E-06
Beryllium 1.20E-05 1.41E-07 2.12E-07Cadmium1.10E-03 1.29E-05 1.94E-05
Chromium 1.40E-03 1.65E-05 2.47E-05
Cobalt 8.40E-05 9.88E-07 1.48E-06
Manganese 3.80E-04 4.47E-06 6.71E-06
Mercury 2.60E-04 3.06E-06 4.59E-06
Nickel 2.10E-03 2.47E-05 3.71E-05
Selenium 2.40E-05 2.82E-07 4.24E-07
AP-42 Table 1.4-4
Natural Gas-Fired Boilers & Heaters
Manufacturer Data
or AP-42 Table 1.4-1
AP-42 Table 1.4-2
AP-42 Table 1.4-2
&
Table A-1 to
Subpart A of Part 98
Emission Factor
(lb/10^6 scf)
AP-42 Table 1.4-3
Page 1 of 16 Version 1.0
November 29, 2018
SUMMARY
Emission Unit PM10 NOx
Unlaoding Trucks Into Raw Material Storage Bunkers 0.022518
Moving Sawdust from Storage Bunkers to Belt Conveyer 0.022518
Transfer of Sawdust from Belt Ocnveyer to Shaker Conveyer 0.022518
Handling Emissions from Shaker Conveyer to Hog Feed Conveyer 0.022518
Transfer po 0.022518
Cat 924F Loader with Diesel Engine 0.09 1.2
JCB 541-70 Forklift with Diesel Engine 0.08 1.17
Allis Chalmers F40-24PS Forklift with LPG Engine 0.00065 0.15549
Hog Process (Baghouse)0
Haldning Emissions from Hog to Loading Traiers 0.022518
Handling Emissions from Loading Trailers to Sawdust Belt 0.022518
Transfer from Dawdust Belt to Hammer Mill (Covered)0
Hammer Mill Process (Baghouse)0
Baghouse 0.036
Drumb Drier Burner (HAPS recalculated in Boiler NG tab)*0.13 1.76
Total 0.49 4.29
NEW PTE (Total without Mobile Equipment)0.32 1.76
AO DAQE-ANO143010001-10 0.50 4.29
Change in Emissions -0.18 -2.53
Controlled Em
CO SOx VOC CO2 CO2e
0.26 0.08 44.51
0.25 0.08 43.47
0.24043 0.0004 7.53473
1.48 0.01 0.1 2117.65 2,130 *CO and CO2e emissions recalcu
2.23 0.17 0.10 2213.16 <-- Match Sums in 2010 AO
1.48 0.01 0.10 2117.65 2130.23
2.16 0.17 0.10
-0.68 -0.16 0.00
mission Estimates from 2010 Source File (tpy)
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
xs epartment of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF AIR QUALITY
Cheryl Heying
Director
August 23, 2010
Karl Kunz
White Flame, Inc.
125 South 1800 West
Lindon, UT 84042
Dear Mr. Kunz:
FILE
D AQE-AN0143010001-10
Re: Approval Order: New Approval Order for the Source at Its New Location
Project Number: N0143010001
The attached document is the Approval Order for the above-referenced project. Future correspondence
on this Approval Order should include the engineer's name as well as the DAQE number as shown on the
upper right-hand corner of this letter. The project engineer for this action is Maung Maung, who may be
reached at [phone].
Sincerely,
M. Cheryl Heying, ExhciftiveSecretary
Utah Air Quality Board
MCH:MM:dn
cc: Utah County Health Department
Document Da e: 08/23/2010
DAQ-2010-0 7126
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]
w’M'w. deq.uiah. gov
Printed on 100% recycled paper
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
APPROVAL ORDER: New Approval Order for the Source
at Its New Location
Prepared By: Maung Mating, Engineer
Phone: [phone]
Email: [e-mail]
APPROVAL ORDER NUMBER
DAQE-AN0143010001-10
Date: August 23, 2010
White Flame, Inc.
Lindon Wood Pellet Manufacturing Plant
Source Contact:
Mr. Karl Kunz Owner and Operator
Phone: [phone]
Executive Secretary
Utah Air Quality Board
Abstract
White Flame, Inc. has requested an AO modification to move its operational facilities to a new site. The
company plans to increase its production at the new place. The old plant will be phased out gradually as
the new plant ramps up its production. The company manufactures wood pellets from sawdust and wood
scraps. The source is qualified under the small source exemption rules. The source opted to receive an
Approval Order.
The company is located in Utah County. Utah County is a NAA of the NAAQS for PM]0. Provo/Orem is
a maintenance area for CO. NSPS, NESHAP and MACT regulations do not apply to this source. Title V
of the CAA does not apply to this source.
The potential to emit total, in tons per year, will be PMi0 = 0.50, NOx = 4.29, CO = 2.16, SOx = 0.17,
VOC = 0.10 and formaldehyde = 0.002.
This air quality AO authorizes the project with the following conditions and failure to comply with any of
the conditions may constitute a violation of this order. This AO is issued to, and applies to the following:
Name of Permittee:Permitted Location:
White Flame, Inc.
125 South 1800 West
Lindon, UT 84042
Lindon Wood Pellet Manufacturing Plant
125 South 1800 West
Lindon, UT 84042
UTM coordinates:
SIC code:
437,544 m Easting, 4,463,676 m Northing, UTM Zone 12
2499 (Wood Products, NEC)
Section I: GENERAL PROVISIONS
1.1 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. [R307-101j
1.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
1.3 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]
1.4 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 Executive Secretary or Executive Secretary'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]
1.5 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
DAQE-ANO143010001-10
Page 3
1.6
I. 7
II. A
II. A. I
II.A.2
II.A.3
II.A.4
II.A. 5
II.A.6
II.A.7
II.B
II.B.l
II.B. 1.a
the Executive Secretary 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]
The owner/operator shall comply with UAC R307-107. General Requirements: Unavoidable
Breakdowns. [R307-107]
The owner/operator shall comply with UAC R307-150 Series. Inventories, Testing and
Monitoring. [R307-150]
Section II: SPECIAL PROVISIONS
The approved installations shall consist of the following equipment:
Wood pellet manufacturing plant
Wood pellet manufacturing from sawdust and wood scraps
One cyclone
The cyclone attached to a fan rated at 5,500 ACFM
Baghouse for Hammer mill process
One Hammer mill with associated cyclone and bag house, rated at 2,800 ACFM
One drum dryer
Dryer supported by a natural gas-fired burner rated at 12 MMBtu per hour
One front-end loader
Caterpiller 924 loader with diesel engine
Two forklifts
JCB 541-70 forklift with diesel engine and Allis Chalmers F40-24PS forklift with LPG
engine
Three conveyors, #1, 2 and 3 for sawdust transfer
Sawdust transfer from storage bunkers to hog: #1 Shaker Conveyor, model number FSCB-30;
#2 Hog discharge conveyor, which is 60 feet long; and #3 conveyor moves the pellets from
the mills to the cooling tower, model number EF Mueller RB9A.
Requirements and Limitations
Requirements and Limitations
Visible emissions from the following emission points shall not exceed the following values:
A All conveyor transfer points - 10% opacity
B All diesel engines - 20% opacity
C All conveyor drop points - 10% opacity
D AQE-ANO143010001 -1 (
Page 4
II.B.l.b
II.B.l.b.l
II.B.l.c
II.B.l.d
II.B.l.e
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]
The following limits shall not be exceeded:
A. Total pellets produced - 72,000 tons per rolling 12-month period
B. Total natural gas usage - 35.29 MMBtu per rolling 12-month period
C. Total sawdust in-take - 36,000 tons per rolling 12-month period
D. Total propane usage - 1,500 gallons per rolling 12-month period
E. Total operating hours for diesel-fueled forklift and loader - 600 each per rolling 12-
month period
[R307-401-8]
Compliance with the limitations shall be determined on a rolling 12-month total. The
owner/operator shall calculate a new 12-month total based on the twentieth day of each month
using data from the previous 12 months. Records of production and usages shall be kept for
all periods when the plant is in operation. Production shall be determined by scale house
records or shipping records. Sawdust in-take shall be determined by vendors' billings. Natural
gas and propane usages shall be determined by billings or purchase records. Hours of
operation shall be determined by supervisor monitoring and maintaining of an operation log.
The records shall be kept on a daily basis. [R307-401-8]
Scrap wood received for processing into wood pellets shall be free of coatings such as varnish,
paint, oil, or contaminants. [R307-401-8]
The owner/operator shall apply water treatment or chemical dust suppression treatment on all
areas on site disturbed by mobile equipment to control fugitive dust emissions. Application
shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-205]
The owner/operator shall notify the Executive Secretary or Executive Secretary's
representative when the new site is fully operational and the operation at old site ceased. The
existing AO DAQE-017-96, dated January 8, 1996 shall be revoked at that time.
[R307-401-18]
DAQE-ANO143010001-10
Page 5
PERMIT HISTORY
This AO is based on the following documents:
Incorporates
Is Derived From
Is Derived From
Additional information dated May 25, 2010
NOI submittal dated February 11, 2010
DAQE-017-96 dated January 8, 1996
ADMINISTRATIVE CODING
The following information is for UDAQ internal classification use only:
Utah County
CDS B
Non attainment or Maintenance Area
D AQE-ANO143010001-10
Page 6
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR
AO
BACT
CAA
CAAA
CDS
CEM
CEMS
CFR
CO
COM
DAQ
DAQE
EPA
FDCP
HAP or HAPs
ITA
LB/HR
MACT
MMBTU
NAA
NAAQS
NESHAP
NOI
NOx
NSPS
NSR
PM10
PM2.5
PSD
PTE
R307
R307-401
so2
Title IV
Title V
TPY
UAC
UDAQ
VOC
Title 40 of the Code of Federal Regulations
Approval Order
Best Available Control Technology
Clean Air Act
Clean Air Act Amendments
Classification Data System (used by EPA to classify sources by size/type)
Continuous emissions monitor
Continuous emissions monitoring system
Code of Federal Regulations
Carbon monoxide
Continuous opacity monitor
Division of Air Quality (typically interchangeable with UDAQ)
This is a document tracking code for internal UDAQ use
Environmental Protection Agency
Fugitive Dust Control Plan
Hazardous air pollutant(s)
Intent to Approve
Pounds per hour
Maximum Achievable Control Technology
Million British Thermal Units
Nonattainment Area
National Ambient Air Quality Standards
National Emission Standards for Hazardous Air Pollutants
Notice of Intent
Oxides of nitrogen
New Source Performance Standard
New Source Review
Particulate matter less than 10 microns in size
Particulate matter less than 2.5 microns in size
Prevention of Significant Deterioration
Potential to Emit
Rules Series 307
Rules Series 307 - Section 401
Sulfur dioxide
Title IV of the Clean Air Act
Title V of the Clean Air Act
Tons per year
Utah Administrative Code
Utah Division of Air Quality (typically interchangeable with DAQ)
Volatile organic compounds
NEW SOURCE REVIEW SECTION
SITE ID # AND PROJEi^i #: NSR0143010001-10
COMPANY NAME: White Flame, Inc.: Lindon Wood Pellet Manufacturing
Plant
REGARDING: New Approval Order for the Source at Its New Location
THE ATTACHED DOCUMENT IS CATEGORIZED AS: (PLEASE CHOOSE ONE)
NEWSPAPER NOTICE (NN)Office Tech signs cover letter of Newspaper Notice
INTENT TO APPROVE (ITA)Cover letter and ITA signed by associated Section Manager
Electronic Copy of ITA sent to Ron Reece
APPROVAL ORDER (AO)Copy of purple sheet and cover letter of AO to Teri Weiss
EXPERIMENTAL AO Copy of purple sheet and cover letter of AO to Teri Weiss
CORRESPONDENCE Signatory varies
SOIL REMEDIATION If associated fee, send copy of purple sheet and letter to Teri Weiss
SALES TAX EXEMPTION (TAX)
SMALL SOURCE EXEMPTION Copy of purple sheet and letter to Teri Weiss
EMISSIONS BANKING LETTER Copy of letter to Camron Harry
NAME CHANGE Copy of purple sheet and letter to Teri Weiss
COPIES TO BE SENT TO THE FOLLOW!]NG PARTIES: (PLEASE CHECK AS THEY APPLY)
Manila File Folder (working file)V Greens Folder
Health Department (see letter for which)EPA - Mike Owens
Compliance (associated Section Manager)Finance - Teri Weiss
Name Change Letters:
Deborah McMurtrie Susan Weisenberg Dave Beatty Brett Wilding, Utah State Tax Commission, Technical Research Unit
Offsets Used?
Copy of document(s) to Camron Harry Enter final Name Change Letters in /engineer/aoname
Copy To:Enter in /engineer/aocond & in AO Log:
(AOs, AO not needed. Replacement in Kind)
NEWSPAPER NOTICE - COPIES TO:
Cities, Counties, Gov. Agencies, & etc./& a copy of
Public Official letter with self-addressed envelope
E-Mail To: [e-mail], Jodie Swanson, Lori
Walker, Debbie Oberndorfer, Bill Sinclair, Beverly
Rasmussen & Jen Burge, Donna Spangler, Ron
Reece, and Kelly Beck
E-Mail copy & Fax to Newspaper Agencies
PSD PROJECTS:
Copy the NOI, Engineering Review, ITA, NOTICE & AO
Send to:
Mike Owens, EPA
Don Banks, Bureau of Land Management
Chris Hocket, U.S. Forest Service
Chris Shaver, National Park Service
TITLE V: Check w/ NSR Engineer for which document(s) to be copied.
REVIEWED BY AND DOCUMENT SIGN OFF DATES:
Completeness determination
Modeling review of ITA
Peer review of project
Section Manager sign off
Public comments received
Branch Manager sign off
June 1, 2010
June 7, 2010
June 3, 2010
June 17, 2010
ff.
Maung Maung
Modeler NSR
John Jenks
Timothy Andrus
Maung Maung
Reginald Olsen
NEW SOURCE REVIEW SECTION
SITE ID # AND PROJEv.1 #: N0143010001-10
COMPANY NAME: White Flame, Inc.: Lindon Wood Pellet Manufacturing
Plant
REGARDING: New Approval Order for the Source at Its New Location
THE ATTACHED DOCUMENT IS CATEGORIZED AS: (PLEASE CHOOSE ONE)
V NEWSPAPER NOTICE (NN) Office Tech signs cover letter of Newspaper Notice
V INTENT TO APPROVE (ITA)Cover letter and ITA signed by associated Section Manager
Electronic Copy of ITA sent to Ron Reece
APPROVAL ORDER (AO)Copy of purple sheet and cover letter of AO to Teri Weiss
EXPERIMENTAL AO Copy of purple sheet and cover letter of AO to Teri Weiss
CORRESPONDENCE Signatory varies
SOIL REMEDIATION If associated fee, send copy of purple sheet and letter to Teri Weiss
SALES TAX EXEMPTION (TAX)
SMALL SOURCE EXEMPTION Copy of purple sheet and letter to Teri Weiss
EMISSIONS BANKING LETTER Copy of letter to Camron Harry
NAME CHANGE Copy of purple sheet and letter to Teri Weiss
COPIES TO BE SENT TO THE FOLLOWENG PARTIES: (PLEASE CHECK AS THEY APPLY)
Vv/Manila File Folder (working file)Greens Folder
/
Health Department (see letter for which)EPA - Mike Owens
£Compliance (associated Section Manager)Finance - Teri Weiss
Name Change Letters:
Deborah McMurtrie Susan Weisenberg Dave Beatty Brett Wilding, Utah State Tax Commission, Technical Research Unit
Offsets Used?
Copy of document(s) to Camron Harry Enter final Name Change Letters in /engineer/aoname
Copy To:Enter in /engineer/aocond & in AO Log:
(AOs, AO not needed, Replacement in Kind)
__
_
_
_
_
_
_
_
_
_
XX
__
_
NEWSPAPER NOTICE - COPIES TO:
/
.✓Cities, Counties, Gov. Agencies, & etc./& a copy of
Public Official letter with self-addressed envelope
E-Mail To: [e-mail], Jodie Swanson, Lori
Walker, Debbie Obemdorfer, Bill Sinclair, Beverly
Rasmussen & Jen Burge, Donna Spangler, Ron
Reece, and Kelly Beck
E-Mail conv & Fax to Newspaper Agencies
PSD PROJECTS:
Copy the NOL Engineering Review, ITA, NOTICE & AO
Send to:
Mike Owens, EPA
Don Banks, Bureau of Land Management
Chris Hocket, U.S. Forest Service
Chris Shaver, National Park Service
TITLE V: Check w/ NSR Engineer for which document(s) to be copied.
3 A/M
REVIEWED BY AND DOCUMENT SIGN OFF DATES:
Completeness determination
Modeling review of ITA
Peer review of project
Section Manager sign off
Public comments received
Branch Manager sign off
June 1, 2010
June 7, 2010
June 3, 2010
Maung Maung
Modeler NSR
John Jenks
Timothy Andrus
Maung Maung
Reginald Olsen
JS9
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF AIR QUALITY
Cheryl Keying
Director
DAQE-INO143010001-10
June 17, 2010
Karl Kunz
White Flame, Inc.
125 South 1800 West
Lindon, UT 84042
Dear Mr. Kunz:
Re: Intent to Approve: New Approval Order for the Source at Its New Location
Project Number: N014301-0001
The attached document is the Intent to Approve for the above-referenced project. The Intent to Approve
is subject to public review. Any comments received shall be considered before an Approval Order 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 Approval Order. An invoice will follow upon issuance of the final
Approval Order.
Future correspondence on this Intent to Approve should include the engineer's name as well as the DAQE
number as shown on the upper right-hand corner of this letter. The project engineer for this action is
Maung Maung, who may be reached at [phone].
Sincerely,
Timothy R. Andrus, Manager
New Source Review Section
TRA:MM:sa
cc: Utah County Health Department
195 North 1950 West • Salt Lake City, UT
Mailing Address' P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T D D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
INTENT TO APPROVE: New Approval Order for the Source at
Its New Location
Prepared by: Maung Maung, Engineer
Phone: [phone]
Email: [e-mail]
INTENT TO APPROVE NUMBER
DAQE-IN0143010001-10
Date: June 17, 2010
White Flame, Inc.
Lindon Wood Pellet Manufacturing Plant
Source Contact:
Mr. Karl Kunz, Owner and Operator
Phone: [phone]
Timothy R. Andrus, Manager
Minor New Source Review Section
Utah Division of Air Quality
ABSTRACT
White Flame, Inc. has requested an AO modification to move its operational facilities to a new site. The
company plans to increase its production at the new place. The old plant will be phased out gradually as
the new plant ramps up its production. The company manufactures wood pellets from sawdust and wood
scraps. The source is qualified under the small source exemption rules. The source opted to receive an
AO.
The company is located in Utah County. Utah County is a NAA of the NAAQS for PMi0. Provo/Orem is
a maintenance area for CO. NSPS, NESHAP, and MACT regulations do not apply to this source. Title V
of the CAA does not apply to this source.
The potential to emit total, in tons per year, will be PM10 = 0.50, NOx = 4.29, CO = 2.16, SOx = 0.17,
VOC = 0.10 and formaldehyde = 0.002.
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 Executive Secretary
of the Utah Air Quality Board.
A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in The Daily Herald on June 22, 2010. 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, 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.
Name of Permittee:Permitted Location:
White Flame, Inc.
125 South 1800 West
Lindon, UT 84042
Lindon Wood Pellet Manufacturing Plant
125 South 1800 West
Lindon, UT 84042
UTM coordinates: 437,544 m Easting, 4,463,676 m Northing, UTM Zone 12
SIC code: 2499 (Wood Products, NEC)
Section I: GENERAL PROVISIONS
1.1 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]
1.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
1.3 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]
D AQE-INO143010001-10
Page 3
1.4 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 Executive Secretary or Executive Secretary'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]
1.5 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 Executive Secretary 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]
1.6 The owner/operator shall comply with UAC R307-107. General Requirements: Unavoidable
Breakdowns. [R307-107]
1.7 The owner/operator shall comply with UAC R307-150 Series. Inventories, Testing and Monitoring.
[R307-150]
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II. A. 1 Wood pellet manufacturing plant
Wood pellet manufacturing from sawdust and wood scraps
II.A.2 One cyclone
The cyclone attached to a fan rated at 5,500 ACFM
II.A.3 Baghouse for Hammer mill process
One Hammer mill with associated cyclone and bag house, rated at 2,800 ACFM
II.A.4 One drum dryer
Dryer supported by a natural gas-fired burner rated at 12 MMBtu per hour
II.A. 5 One front-end loader
Caterpillar 924 loader with diesel engine
II.A.6 Two forklifts
JCB 541-70 forklift with diesel engine and Allis Chalmers F40-24PS forklift with LPG engine
II.A.7 Three conveyors, #1, 2 and 3 for sawdust transfer
Sawdust transfer from storage bunkers to hog: #1 Shaker Conveyor, model number FSCB-30;
#2 Hog discharge conveyor, which is 60 feet long; and #3 conveyor moves the pellets from
the mills to the cooling tower, model number EF Mueller RB9A.
DAQE-INO143010001-10
Page 4
II.B
II.B.l
II.B.l.a
II.B.l.b
II.B.l.b.l
II.B.Lc
ILB.l.d
n.B.l.e
Requirements and Limitations
Requirements and Limitations
Visible emissions from the following emission points shall not exceed the following values:
A. All conveyor transfer points - 10% opacity
B. All diesel engines - 20% opacity
C. All conveyor drop points - 10% opacity
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]
The following limits shall not be exceeded:
A. Total pellets produced - 72,000 tons per rolling 12-month period
B. Total natural gas usage - 35.29 MMBtu per rolling 12-month period
C. Total sawdust in-take - 36,000 tons per rolling 12-month period
D. Total propane usage - 1,500 gallons per rolling 12-month period
E. Total operating hours for diesel-fueled forklift and loader - 600 each per rolling 12-
month period
[R307-401-8]
Compliance with the limitations shall be determined on a rolling 12-month total. The owner/
operator shall calculate a new 12-month total based on the twentieth day of each month using
data from the previous 12 months. Records of production and usages shall be kept for all
periods when the plant is in operation. Production shall be determined by scale house records
or shipping records. Sawdust in-take shall be determined by vendors' billings. Natural gas and
propane usages shall be determined by billings or purchase records. Hours of operation shall
be determined by supervisor monitoring and maintaining of an operation log. The records shall
be kept on a daily basis. [R307-401-8]
Scrap wood received for processing into wood pellets shall be free of coatings such as varnish,
paint, oil, or contaminants. [R307-401-8]
The owner/operator shall apply water treatment or chemical dust suppression treatment on all
areas on site disturbed by mobile equipment to control fugitive dust emissions. Application
shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-205]
The owner/operator shall notify the Executive Secretary or Executive Secretary's representative
when the new site is fully operational and the operation at old site ceased. The existing AO
DAQE-017-96, dated January 8, 1996 shall be revoked at that time. [R307-401-18]
DAQE-INO143010001-10
Page 5
PERMIT HISTORY
The final AO will be based on the following documents:
Incorporates
Is Derived From
Is Derived From
Additional information dated May 25, 2010
NOI submittal dated February 11, 2010
DAQE-017-96 dated January 8, 1996
ADMINISTRATIVE CODING
The following information is for UDAQ internal classification use only:
Utah County
CDS B
Nonattainment or Maintenance Area
DAQE-INO143010001-10
Page 6
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR
AO
BACT
CAA
CAAA
CDS
CEM
CEMS
CFR
CO
COM
DAQ
DAQE
EPA
FDCP
HAP or HAPs
ITA
LB/HR
MACT
MMBTU
NAA
NAAQS
NESHAP
NOI
NOx
NSPS
NSR
PM10
PM2.5
PSD
PTE
R307
R307-401
so2
Title IV
Title V
TPY
UAC
UDAQ
VOC
Title 40 of the Code of Federal Regulations
Approval Order
Best Available Control Technology
Clean Air Act
Clean Air Act Amendments
Classification Data System (used by EPA to classify sources by size/type)
Continuous emissions monitor
Continuous emissions monitoring system
Code of Federal Regulations
Carbon monoxide
Continuous opacity monitor
Division of Air Quality (typically interchangeable with UDAQ)
This is a document tracking code for internal UDAQ use
Environmental Protection Agency
Fugitive Dust Control Plan
Hazardous air pollutant(s)
Intent to Approve
Pounds per hour
Maximum Achievable Control Technology
Million British Thermal Units
Nonattainment Area
National Ambient Air Quality Standards
National Emission Standards for Hazardous Air Pollutants
Notice of Intent
Oxides of nitrogen
New Source Performance Standard
New Source Review
Particulate matter less than 10 microns in size
Particulate matter less than 2.5 microns in size
Prevention of Significant Deterioration
Potential to Emit
Rules Series 307
Rules Series 307 - Section 401
Sulfur dioxide
Title IV of the Clean Air Act
Title V of the Clean Air Act
Tons per year
Utah Administrative Code
Utah Division of Air Quality (typically interchangeable with DAQ)
Volatile organic compounds
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
epartment of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF AIR QUALITY
Cheryl Heying
Director
DAQE-NNO143010001-10
June 17, 2010
The Daily Herald
Legal Advertising Dept
1555 N 200 W
Provo, UT 84601
RE: Legal Notice of Intent to Approve
This letter will confirm the authorization to publish the attached NOTICE in The Daily Herald on June
22, 2010.
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.
Sincerely,
Sharon Anderson
Office Technician
Utah Division of Air Quality
Enclosure
cc: Mountainland Association of Governments
Utah County
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T D D. [phone]
■ D AQE-NNO143010001-10
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 Executive Secretary, Utah Air
Quality Board:
Company Name: White Flame, Inc.
Location: White Flame, Inc.: Lindon Wood Pellet Manufacturing Plant - 125 South 1800
West, Lindon, UT, Utah County
Project Description: White Flame, Inc. has requested an Approval Order (AO) modification to move its
operational facilities to a new site. The company plans to increase its production
at the new place. The old plant will be phased out gradually as the new plant
ramps up its production. The company manufactures wood pellets from sawdust
and wood scraps. The source is qualified under the small source exemption rules.
The source opted to receive an AO.
The company is located in Utah County. Utah County is a nonattainment area
(NAA) of the National Ambient Air Quality Standards (NAAQS) for PMi0.
Provo/Orem is a maintenance area for CO. New Source Performance Standard
(NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP),
and Maximum Achievable Control Technology (MACT) regulations do not apply
to this source. Title V of the Clean Air Act (CAA) does not apply to this source.
The potential to emit total, in tons per year, will be PM10 = 0.50, NOx = 4.29,
CO = 2.16, SOx = 0.17, VOC - 0.10 and formaldehyde = 0.002.
The completed engineering evaluation and air quality impact analysis showed that the proposed project
meets the requirements of federal air quality regulations and the State air quality rules. The Executive
Secretary intends to issue an AO pending a 30-day public comment period. The project proposal, estimate
of the effect on local air quality and draft AO are available for public inspection and comment at the Utah
Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84114-4820. Written comments
received by the Division at this same address on or before July 22, 2010 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 Executive Secretary at the Division in writing within
15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.
Date of Notice: June 22, 2010
Page 1 of 3Re: Legal Notice to be Published in rT'u'' Daily Herald on June 22, 2010
Sharon Anderson - Re: Legal Not o be Published in The Daily Heral June 22, 2010
From: DH Legals <[e-mail]>
To: Sharon Anderson <[e-mail]>
Date: 6/17/2010 11:59 AM
Subject: Re: Legal Notice to be Published in The Daily Herald on June 22, 2010
Just letting you know that I received your request for a legal notice and I will send back a cost and copy for you to look over. Thank you!
Morgan Bassett
Daily Herald Communications
www.heraldextra.com
Legal Notice Department
Phone: [phone]
Fax: [phone]
email: [e-mail]
address: 1555 N. Freedom Boulevard
P.O. Box 717
Provo, UT 84603-0717
Looking for a GREAT DEAL? Fan us at
www.facebook.com/DailyHeraldDeals
Local (lews, irtformaiidn, advertising
First.
Today. Tomorrow,
On 6/17/10 8:11 AM, "Sharon Anderson" <[e-mail]> wrote:
Please publish the following notice on June 22, 2010.
If you can, please reply to this email to confirm receipt of this request.
Thank you.
DAQE-N NO 143010001-10
June 17, 2010
The Daily Herald
file://C:\Documents and Settings\Sharonanderson\Local Settings\Temp\XPgrpwise\4ClAOE12EQDOMAI... 6/17/2010
Page 2 of 3
’ Legal Advertising Dept
1555 N 200 W
Provo, UT 84601
RE: Legal Notice of Intent to Approve
Re: Legal Notice to be Published in "ru'' Daily Herald on June 22, 2010
This letter will confirm the authorization to publish the attached NOTICE in The Daily Herald on
June 22, 2010,
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.
Sincerely,
Sharon Anderson
Office Technician
Utah Division of Air Quality
Enclosure
cc: Mountainland Association of Governments
Utah County
NOTICE
A Notice of Intent for the following project submitted in accordance with §R307-401-l, Utah
Administrative Code (UAC), has been received for consideration by the Executive Secretary, Utah Air Quality
Board:
Company Name: White Flame, Inc.
Location: White Flame, Inc.: Lindon Wood Pellet Manufacturing Plant - 125 South 1800 West,
Lindon, UT, Utah County
Project Description: White Flame, Inc. has requested an Approval Order (AO) modification to move its
operational facilities to a new site. The company plans to increase its production at the new place. The old plant
will be phased out gradually as the new plant ramps up its production. The company manufactures wood pellets
from sawdust and wood scraps. The source is qualified under the small source exemption rules. The source opted
to receive an AO.
The company is located in Utah County. Utah County is a nonattainment area (NAA) of the National Ambient Air
Quality Standards (NAAQS) for PM10. Provo/Orem is a maintenance area for CO. New Source Performance
Standard (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), and Maximum Achievable
Control Technology (MACT) regulations do not apply to this source. Title V of the Clean Air Act (CAA) does not
apply to this source.
The potential to emit total, in tons per year, will be PM10 = 0.50, NOx = 4.29,
file://C:\Documents and Settings\Sharonanderson\Local Settings\Temp\XPgrpwise\4ClAOE12EQDOMAI... 6/17/2010
Re: Legal Notice to be Published in Tu~ Daily Herald on June 22, 2010 Page 3 of 3
CO = 2.16, SOx = 0.17, VOC = 0.10 and formaldehyde = 0.002.
The completed engineering evaluation and air quality impact analysis showed that the proposed
project meets the requirements of federal air quality regulations and the State air quality rules.
The Executive Secretary intends to issue an AO pending a 30-day public comment period. The project proposal,
estimate of the effect on local air quality and draft AO are available for public inspection and comment at the Utah
Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84114-4820. Written comments received by the
Division at this same address on or before July 22, 2010 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 Executive Secretary at the Division in writing within 15 days of publication of this
notice, a hearing will be held in accordance with R307-401-7, UAC.
Date of Notice: June 22, 2010
file://C:YDocuments and Settings\Sharonanderson\Local Settings\Temp\XPgrpwise\4Cl AOE12EQDOMAI... 6/17/2010
Date Jan.25,2010Utah Division of Air Quality
New Source Review Section
Form 1
General Information ; 5 ow c>p GUA! f7V
Application for: □ Initial Approval Order 0 Approval Order Modification
AN APPROVAL ORDER MUST BE ISSUED BEFORE ANY CONSTRUCTION OR INSTALLATION CAN BEGIN. This is not a
stand alone document. Please refer to the Permit Application Instructions for specific details required to complete the
application. Please print or type all information requested. All information requested must be completed and submitted before
an engineering review can be initiated. If you have any questions, contact the Division of Air Quality at [phone] and ask
to speak with a New Source Review Engineer. Written inquiries may be addressed to: Division of Air Quality, New Source
Review Section, P.O. Box 144820, Salt Lake City, Utah 84114-4820.
Applicable base fee for engineering review and filing fee must be submitted with the application.
7“
impar
General Owner and Facility Information
1 y Corfipany name and address:X White^F^ame, Inc.
v* $ Scuta . 1800 West
V IriMQn^TTtah 84042
Phone No.: ( gQl) 765-1195
Fax No.: ( 801) 765-1161
2. Company contact for environmental matters:
Workman-Mi 11 er
550 North Main, STE 302
Logan, Utah 84321
Phone No.: (435)7153-7006
___Eg*.Nq„___(435)752-1689____^______________
4. Owners name and address: ^
Wayne Field, Kai^Kunz, Kenneth Kunz,
Gary Sandberg, Wayne Thornock
Utah 84042
Fax no.: (80^) 765-1161_____________________
3. Facility name and address (if different from above):
Same as above
Phone no.: (
Fax no.: ( )
)
5. County where the facility is located in:
Utah
6. Latitude & longitude, and/or UTM coordinates of plant:
40.335046 111.757221
7. Directions to plant or Installation (street address and/or directions to site) (include U.S. Coast and Geodetic Survey
map if necessary): From Interstate 1-15, take 1600 North Exit, go west to Geneva Road,
then go to 200 South in Lindon, and then turn left. Travel west on 200 South to
1800/1900 West and turn right. Business jtf first building on right.\*»
8. Identify any current Approval Order(s):
AO# DAQE-017-96 Date Jan. 8, 1996 AO#Date
AO#Date AO#Date
AO#Date AO#Date
9. If request for modification, permit # to be modified: DAQE # 01 7-96 DATED: 01/ 08/ 96
10. Type of business at this facility: Wood pellet manufacturer
11. Total company employees greater than 100?12. Standard Industrial Classification Code
□ Yes Sc No
2_4_0_0_
Page 1 of 4
Approval Order Application
Form 1 (Continued)
13. Application for:
! □ New construction
□ Existing equipment operating without permit
□ Change of permit condition
□ Modification
□ Permanent site for Portable Approval Order
KK Change of location
14. For new construction or modification, enter estimated start date: 8/1 /09 Estimated completion date: 8/1 /10
15. For change of permittee, location or condition, enter 16. For existing equipment in operation without prior permit,
date of occurrence: 2009-2010 enter initial operation date: na
17. Has facility been modified or the capacity increased since November 29, 1969: S Yes □ No
Process Information
18. Site plan of facility (Attach as Appendix A):
19. Flow diagram of entire process to include flow rates and other applicable information (Attach as Appendix B):
20. Detailed written process and equipment description. (Attach as Appendix C)
Description must include:
Process/Equip specific form(s) identified in the instructions
Fuels and their use Equipment used in process Description of product(s)
Raw materials used Operation schedules Description of changes to process (if applicable)
Production rates(including daily/seasonal variances)
21. Does this application contain justifiable confidential data? ^ffiYes □ No
Emissions Information
22. Complete and attach Form 1d, Emissions Information
Include Material Safety Data Sheets for all chemicals or compounds that may be emitted to the atmophere.
23. Identify on the site plan (see #18 above) all emissions points, building dimensions, stack parameters, etc.
Air Pollution Control Equipment Information
24. List all air pollution control equipment and include equipment specific forms identified in the instructions.
Attach as Appendix D.
25. List and describe all compliance monitoring devices and/or activities (such as CEM, pressure gages). Attach as
Appendix E.
26. Submit modeling for the project if required. See attached instructions.
27. Attach as Appendix F your proposal of what air pollution control devices, if any, or operating practices represents Best
Available Control Technology. Discuss and evaluate all air pollution control technologies relevant to your situation or
process.
28. I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based^dnTeas^nable inquiry made by me and to the best of my knowledge and belief.
Signature: f ry(sk {,/}_________________Title: Vtiite Flame Inc., President
JUT f- ~ 1 y'yV £ /
29. (30. Telephone Number:30. Datetanuary 25, 2010
Karl Kunz ^( ) 801-765-1195
Name (Type or print)
Page 2 of 4
Utah Division of Air Quality
Form 1 - Appendix C
New Source Review Section
Process Information
Information collected at previous location in Orem, Utah (Wood Pellet Works, 186 North
1600 West, Orem, Utah 84057).
#20
O •
(L»
vA
Process Equipment 1 ' ^ {^ '
Unloading of wood scrap onto concrete pad from trucks j
Conveying of wood scrap o { ^ ^ P ^ (
One Blow Hog with associated cyclone - 5,500 ACFM S'
One Hammer Mill with associated cyclone and bag house ( err o /,
Three pellet mills and baggers located inside facility building } o
One pellet cooler
One 75 hp fan
One 40 hp fan
(All venting inside building)
Forklift^)-
F £ ^ c,cf c(>^
Raw Materials used:
Wood
Production rate:
24,000 Ibs./hour
Operation schedule:
24 hours/day, 7 day week
Description of product:
Wood pellets for wood burning stoves
*.
y
*
'
*
*
a
o
Utah Dnr.sion of Air Quality
New Source Review Section
Form 2
Process Information
Site/Source____________________
Date January 25, 2010
Company White Flame Inc.
Process Data
1. Name of process:
Wood processinq
2. End product of this process:
Wood pellets for wood burninq stoves
3. Primary process equipment
Make or model:
Manufacturer:
Identification #:
Capacity of equipment (Ibs/hr): Year installed:
Rated Max. „ . . ,See attachment(Add additional sheets as needed)
4. Method of exhaust ventilation:
n Stack □ Window fan □ Roof vent □ Other, describe Baa House
Are there multiple exhausts: □ Yes K No
Operating Data
5. Maximum operating schedule:
24 hrs/dav
7 davs/week
weeks/vear
6. Percent annual production by quarter: (tons)
Winter 6579 Sprinq 6570
Summer 6570 Fall 6570
7. Hourly production rates (lbs.):
Averaae 24,000 Maximum same
8. Maximum Annual production (indicate units):
105,120 tons
Projected percent annual increase in production:
9. Type of operation: cx Continuous
□ Batch
□ Intermittent
10. If batch, indicate minutes per cycle na
Minutes between cycles na !
11 Materials Used in Process
Raw Materials Principal Use Amounts
(Specify Units)
Wood Manufacture of wood pellets 105,120 tons/year
Page 1 of 3
Process
Form 2 (Continued)
White Flame Inc.
12.Control Equipment (attach additional pages if necessary)
Item Primary Collector Secondary Collector
a. Type Process system is connected to a Cyclone unit
b. Manufacturer
c. Model
d. Year installed
e. Serial or ID#
f. Pollutant controlled
g. Controlled pollutant emission
rate (if known)
h. Pressure drop across control
device
i. Design efficiency
j. Operating efficiency
Stack Data
(attach additional pages if necessary)
13. Stack identification:
na
14. Heiaht: Above roof na ft
Above around na ft
15. Are other sources vented to this stack:
□ Yes No
If yes, identify sources:
16. □ Round, top inside diameter dimension
30" x 26 3/4”
□ Rectangular, top inside dimensions
lenath x width
17. Exitoas: Temoerature 6000cfm°F Volume acfm Velocity ft/min
18. Continuous monitoring equipment: □ yes no na
If yes, indicate: Type______^Manufacturer na
Make or Model naPollutant(s) monitored na
Emissions Calculations (PTE)
Calculated emissions for this device na
PMio Lbs/hr fabi Tons/vr NOx Lbs/hr Tons/yr
sox Lbs/hr Tons/vr VOC Lbs/hr Tons/yr
HAPs Lbs/hr (speciate)Tons/yr (speciate)
Submit calculations as an appendix.
Page 2 of 3
Utah Division of Air Quality
New Source Review Section
Form 1d
Emissions Information
Site/Source__________________
Date Jan. 25, 2010
Company White Flame Inc.
Please print neatly or type all information requested. All information must be truthful, accurate and complete before
we can process your application. If you have any questions, call [phone] and ask to speak with a New
Source Review engineer. Written inquiries may be addressed to: Division of Air Quality, NSR Section, P.O. Box
144820, Salt Lake City, Utah 84114-4820.
Table 1. Proposed Emissions
Pollutant Permitted Emissions
(tons/year)
Emissions Increases
(tons/year)
Proposed Emissions
(tons/year)
PMio 8.69 na 8.69
S02
NOx
CO
VOC
Hazardous
Air Pollutants (total)
Hazardous Air
Pollutants (list
individually) (attach
additional sheet if
needed)
other pollutants (list)
(attach additional
sheet if needed)
Page 1 of 4
White Flame Inc.Utah Division of Air Quality
Approval Order Application
Form Id
Emissions Information
Table 2. Controlled and Uncontrolled Emissions
Pollutant Controlled Emissions (tons/year)Uncontrolled Emissions (tons/year)
PM-io
8.69 0
so2
NOx
CO
VOC
Hazardous Air Pollutants (total)
Hazardous Air Pollutants (list
individually) (attach additional sheet if
needed)
other pollutants (list) (attach
additional sheet if needed)
Page 2 of 4
Utah Division of Air Quality
Approval Order Application
Form 1d
Emissions Information
Table 3. Hourly HAP Emissions
Hazardous Air Pollutants (list individually) Maximum emission rate (Ibs/hour)
Page 3 of 4
Utah Division of Air Quality
New Source Review Section
Form 6
Cyclone
Company White Flame, Inc.
Site/Source Linden, Utah
Date 3-0 fO____
j Equipment Information
1. Manufacturer: Custom built
Model no.: none - custom built
Diameter 7.5 ft., height 20.5 ft.
2. Type of cyclone: □ wet dry
H Single □ Multiple: number
□ In series: number
3. Type of particulate:4. Efficiency of cyclone:
At desian maximum: %
At averaoe ©Deration: %
Particulate size:
microns
(mean geometric diameter)
5. Pressure drop through cyclone (inches water):6. Method of handling material removed: Fal 1 s
through air lock on bottom of cyclone
Gas Stream Characteristics
7. Particulate grain loading:
Inlet:
8. Total flow rate (acfm):
Desian maximum: 13,500
Outlet:Averaoe expected: 11/000
9. Gas stream temperature (°F):
Emissions Calculations (PTE)
10. Calculated emissions for this device
PMm Lbs/hr 8.69rons/vr
Submit calculations as an appendix.
Instructions
NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2. Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in filling out this
form. Ask to speak with a New Source Review engineer. We will be glad to help!
1. Fill in the cyclone manufacturer's name and model number.
2. Indicate the type of cyclone being used.
3. Supply what the material is being controlled, and its mean geometric diameter in microns (jj.).
4. Fill in the efficiency of the cyclone at the maximum and average operating levels.
5. Indicate the pressure drop through the cyclone (inches water).
6. Describe the method of handling the material removed by the cyclone.
7. Indicate the gas stream particulate grain loading at inlet and outlet.
8. Specify the flow rate in actual cubic feet per minute at the design maximum and average.
9. Specify the gas stream temperature as it goes through the cyclone.
10. Supply calculations for all criteria pollutants. Use AP42 or Manufacturers data to complete your calculations.
U:\aq\ENGINEER\GENERIC\Form06.doc 05-11 -06
Estimating Emissions From
Generation and Combustion
Of “Waste” Wood
DRAFT
Some conventions and assumptions used by NC DAQ in evaluating permit
applications and emission inventory submittals.
July 15, 1998 First Draft
Prepared for
NC DENR
Division of Air Quality
by
Wood Waste and Furniture Emissions Task Force
Table of Contents
Background ............................................................................................................................................................................. 1
NOTICE: ........................................................................................................................................................................ 1
Logging and Other In-Forest Operations ........................................................................................................................ 1
General ............................................................................................................................................................................. 1
Sawing, Planing and Woodworking (Lumber) Operations.............................................................................................2
General Description and Comments.............................................................................................................................2
Emission Factors and Assumptions for Lumber and Woodworking....................................................................3
Kiln Drying ................................................................................................................................................................................4
General Description and Comments.............................................................................................................................4
Emission Factors and Assumptions.............................................................................................................................4
Burning Waste Wood in Boilers...........................................................................................................................................4
General Description and Comments.............................................................................................................................5
Emission Factors and Assumptions.............................................................................................................................5
Burning Wood Waste in Incinerators ..................................................................................................................................5
General Description and Comments.............................................................................................................................5
Emission Factors and Assumptions.............................................................................................................................5
Open Burning of Wood Waste .............................................................................................................................................5
General Description and Comments.............................................................................................................................5
Emission Factors and Assumptions.............................................................................................................................5
Appendix of Miscellaneous Wood Related Facts.............................................................................................................6
Wood Waste Emissions
Background
North Carolina is blessed to have an abundance of natural resources and a number of important related
industries. One of these is the forest products industry which is closely related to furniture making, paper
manufacure and lumber used for home construction, either in it’s natural form or in manufactured
products such as oriented strand board, chip board, etc. Due to the nature of the processes, air pollutants
may be emitted as a consequence. These emissions begin at the harvesting stage and may continue
through the manufacture of the final consumer products. Many of these operations are of a nature that
makes the estimation of emissions from them very difficult. Many of the processes and operations are
covered in EPA’s Compilation of Air Pollutant Emission Factors (AP-42), which stands as the basic
reference. However, from time to time that document may not adequately address process, specific
practices and assumptions or may not include the latest information needed. In such cases, guidelines for
assumptions and exceptions may need to be defined. This is the purpose of this document. This
document may be updated from time to time as needed to reflect the dynamic process of improving
emission estimates as new information and data are generated or otherwise become available for public
use.
This report is is intended to provide increased consistency among various offices of DAQ. Other
documents may be developed if needed. Please provide any comments and critiques or recommendations
on this document, or similar other needs to the Planning Section, Division of Air Quality, PO Box 29580,
Raleigh, NC 27626-0580 or to [e-mail].
NOTICE:
Emission factors are guidelines that may provide reasonable estimates for groups of
facilities, but which may not always be accurate for individual facilities or processes. The
guidelines and assumptions presented here are intended for use by staff of the NC Division
of Air Quality, along with other information that the Division may aquire, for review and
evaluation of emission estimates and information submitted by point sources in NC for
purposes of permit application and/or emission inventory requirements. This document is
provided to the public as an indicator of the nature of what the Division uses in such
evaluations. This collection of guidance and assumptions (including such information that
is also provided in spreadsheets and/or the Division’s Internet web pages) does not relieve
an individual or company from the legal responsibility for using the best available
information at the time of submittal for estimation of emissions. Inclusion of information
herein does not mean that it is indeed the latest information at any time in the future.
Logging and Other In-Forest Operations
General
Currently there is little to no information or data on air emissions from logging and other related
operations, nor is there reason to believe that these are a significant air emissions problem. The only
possible exception might be fugitive dust from logging roads and other transport operations. This topic is
1
Wood Waste Emissions
mentioned here only for completenes, consistency and clarity. Biogenic emissions from growing plants
(including trees) are considered separately and are identified as a significant contributor to ozone in the
Southeast, but are also not intended to be covered by this document.
From the logging operations, wood may be transported to conventional saw mills, chippers, pulp
operations, plywood manufacturing mills and other such facilities. Some of these operations are
discussed below.
Sawing, Planing and Woodworking (Lumber) Operations
General Description and Comments
Sawing, planing and woodworking cover a wide range of operations. Basic saw mills may be set up
temporarily in the field near logging operations or be permanent complex facilities. Woodworking
operations generally refers to those which take planed and sized wood to final products through fine
sawing, joining, milling, etc. which generate finer sized dusts.The emitting processes however are similar
in a general sense. Unfortuantely, there is no current section in AP-42 which covers even basic
lumber operations, partially due to the general lack of test data and related information. The discussions
below define some of the assumptions and crude extrapolations that are used in lieu of better and more
definative literature or test information.
Some common woodworking/lumber terms and definitions1:
AIR-DRY: (1) Solid wood products: Dried (seasoned) by exposure to the open air without artificial heat.
Moisture content of air dried wood depends upon relative humidity, temeprature and length of drying
period. Lumber thoroughly air dried is commonly considered to have a moisture content of approximately
12% (O.D. wt. Basis). Air-dried wood fiber is commonly considered to be about 5 to 8% m.c. (O.D. wt.
Basis). (2) Pulp and paper: Composed of 90% solidand 10% water.
AIR-DRY TON: (A.D.T.) For wood pulp, an air dry ton is usually defined as a quantity of pulp which
weighs 2000 lbs, 90% of which is wood fiver and 10% of which is moisture. Thus an air diry ton
contains 1800 of pulp (ovendry basis) and 200 lbs. Of water. In terms fo wood bfiber content, one air -
dry ton equals 0.9 ovendry tons. Moisture content of an air -dry ton is 10%.
BOARD FEET: (bd. Ft.) Nominally, a rough-sawn, green board 1 in. X 12 in. X 1 ft., or equivalent.
Used as a log measure and measure of sawn lumber.
BONE DRY: Having zero percent moisture content. Also: Ovendry.
BONE DRY TON: (B.D.T.) A quantity of wood pulp or residue which would weigh 2000 lbs. at zero
percent moisture content. Also: Ovendry ton.
BONE DRY TON: (B.D.U.) - A quantity of wood residue which would weigh 2400 lbs. at zero percent
moisture content.
CORD: A measure of roundwood or pulpwood representing a stack of such wood 4 ft. X 4 ft. X 8 ft. or
128 cubic feet.
CUNIT: (CCF) One hundred cubic feet of solid wood. Used as a log measure or as a measure of solid
wood content.
HOGGED FUEL: A mix of wood residues such as sawdust, planer shavings, and sometimes coarsely
broken-down bark and solid wood chunks produced in the manufacture of wood productrs and normally
2
Wood Waste Emissions
used as fuel.
KILN-DRY: Dried (seasoned) wby exposure to artificial heat and humidity under controlled conditions
in a kiln. American lumber standards specify that seasoned lumber must have no more than 19%
moisture content (m.c.). Lumber dried to 15% m.c. or less is grade stamped “MC 15". Veneer is
commonly dried to about 2-5% m.c. All moisture contents are on an ovendry weight basis.
ROUNDWOOD: Logs, poles,piling, and cordwood of any size with or without bark.
WANE: Presence of bark or absence of wood, due to any cause, on the edge or comer of a piece of
lumber.
YIELD: (1) Forest Products Industries: The quantity of product recovered from a given quantity of raw
material input. (2) Forest Mensuration: An estimate of the amount of wood which may be harvested from
a particular type of forest stand (by species, site, stocking and management regime) at various ages.
Emission Factors and Assumptions for Lumber and Woodworking
Planing and other Woodworking: An April 26, 1995 memo from Laura Butler through Alan Klimek to
the Regional Air Quality Supervisors and others, an April 18, 1996 memo from Laura Butler, similarly
addressed, along with a July 15, 1997 memo from Tammie Watkins of the Mooresville Regional Office
are basic references considered valid for DAQ assumptions for woodworking operations. A summary of
the main technical points of those memos is provided below:
• 80% of sawing and planing emissions generated are >100 micrometers in aerodynamic particle size
and not considered regulated.
• PM-10 replaced PM as the regulated pollutant October 16, 1995 for Title V review and billing
purposes. PM-100 is still considered for 2Q.0102 purposes and 2D emission standards.
• Plant-specific PM-10 information normally takes precedence over generalized emission factor types
of information, but all such information should be used in recognition of the other.
• Knife planers generate larger particles than abrasive planers, abrasive planers being more
appropriately grouped with sanders.
• Knife planers used on “green wood” (>19% moisture)generate chips or emissions that are not
considered regulated, even if a device is used to capture the chips, and does not need to be permitted.
• Knife planers used on dry wood (<19/5 moisture):For the uncontrolled emission stream into the
control device, = 2.6% of inlet loading to control device is assumed to be PM. Apply appropriate
control device efficiency to the 2.6% result when developing permit estimates (Cyclone may be up to
95% efficient on the very largest particles, but much less, perhaps even lower than 50% on smaller
particles; bag filter assumptions of 99% are generally acceptable estimates, but determination of
control efficiency must be determined on a case by case basis considering all the variables at the
facility.).
Typical percentages of wood waste:
• Rough sawing = 20%
• Fine sawing = 30%
• Sanding = 20%
• Molding (hQg) - 4Q%
• Total = 100%
3
Wood Waste Emissions
Other Assumptions addressed in the memos are as follows:
Woodworking Process % of Wood Dust
Regulated as PM
(<100 micrometers)
% of Wood Dust*
Regulated as PM-10
(PM-44, as a surrogate)
Sanding 76 23.8
Fine Sawing (band saws, etc)31 0.37
Rough Sawing (saw milling, etc.)18 1.89
Milling (hog)10 Not Included- assume 0
Molding 5.2 0
Planing 2.6 0
Wood Shaving 0.56 Not Included, assume 0
*Note that PM 2.5 is generally expected to be a small portion of the PM-10. Efforts to measure these fine
particles from these operations are desperately needed, especially if areas of the state are monitored to be
in non-attainment status.
Related common assumptions accepted but not in the formal memos include:
• 1 Board foot = 2.6 pounds (pine).
• 1 Board foot = 3.4 pounds (hardwood).
• Frame shop has 20% waste.
• Case Goods shop has 65% waste.
• Yield is the amount of raw lumber received that actually becomes finished product. For typical
furniture operations, this will be about 45%. However this figure is generally tracked very carefully
by plant management and is probably available within tolerances of a percent and thus should be
determined on a case by case basis.
Additionally, some have made calculations based on width of saw blades and linear feet sawed, which can
generate some idea of volume and weight of wood sawdust that is generated. These procedures, while
crude can give an approximation of the total volumes generated and are useful for such purposes.
Regions and reviewers are cautioned about "blind acceptance" of typical control efficiencies being
applicable in all situations. Approximate particulate matter control efficiencies (PM - 95%, PM 10-95%,
PM2.5 -80%) were provided by Michael Koerschner of the ARO at the request of David Stout, Broyhill
Furniture Industries, Inc., during a 2/4/98 telephone conversation regarding control efficiencies by
multicyclones, and have become sited on many occasions. The efficiencies quoted by Mr. Koerschner are
from Table C.2-3 "Typical Collection Efficiencies of Various Particulate Control Devices" of AP-42 for a
"multiple cyclone w/o fly ash reinjection." During the elephone conversation, Mr. Koerschner expressed
his opinion that these numbers appeared to be high (based on data we've seen) and do not apply
specifically to wood-fired boilers. Therefore, the DAQ does not blindly accept the application of "typical
control efficiencies. This was restated to the AFMA in Keith Overcash’s May 27, 1998 letter to Andy
4
Wood Waste Emissions
Counts of the AFMA which was authored as a result of questions in AFMA’s March 31, 1998 letter on
how to estimate emissions, assumptions, etc..
Kiln Drying
General Description and Comments
Wood is often kiln dried. This process is not currently described by AP-42, but is basically a process
which results in green or (semi-)air dried wood being stacked into large rooms or containers which are
then raised to high temperature (>212 degrees F) to drive off the moinsture in the wood. See various
definitions of terms in the Lumber/Woodworking section proceeding. During the drying process.
Volatile organic compounds (VOCs) are also expelled. Thus the process results in the emission of VOC
from the kiln and the emissions from the fueling operation which is often gas or distillate oil. Estimates
should be made, therefore, for both of these pollutants. However, if the operation is a small isolated kiln
operating on a random schedule, the emissions may well be below the threshold requiring a permit.(????)
Emission Factors and Assumptions
This process has been handled inconsistently in North Carolina, largely because there has not been a good
set of accepted and standardized information widely available. The main two sources of different data to
date have been from WSRO and WaRO efforts.
EPA and NCCASI are currently working on developing emission factors for lumber kiln operations, but,
there appear to be little to no data that can be used for such a process.Currently, in Keith Overcash’s May
27, 1998 letter to AFMA, previously cited, we indicate an effort is underway to come up with some better
information that we would use, presumably, until the EPA efforts are completed. His September 3 memo
further elaborated on the position and indicated that in the interim before these studies were done, we
would accept 2.11 for pine and 0.211 for hardwood initially, for 1997 submittals, but afterward, if the
studies were not completed by the end of 1998, DAQ would insist upon consistent use of 3.4 pounds of
VOC per thousand board feet for steam heated kilns, based on limited tests of a plant in WaRO. This was
intended to be improved upon and expanded by us in the mean while and one of the improvements is to
get the VOC on an actual mass basis, instead of “as carbon.”
Betsy Huddleston spoke with David Word with NCASI at a conferencein July about the VOC as carbon
problem. Their study results of VOC emissions from kilns is due to be published in a report by the end of
1998. He noted that right now if we were to be converting to total VOC using a surrogate, we should
probably use alpha-pinene, which has been suggested before to me. Alpha pinene makes up to 50% of
the VOC content. Note that this is for SOFTWOODS only. David said there is NOTHING to his
knowledge out there to pick a surrogate for hardwoods. Would be a task for sure.lt would be a good idea
to wait until the report is published before implementing the big clean up on kiln emissions. There was a
scheduled talk on this subject for today and Richard Lasater is there to take notes. I'll make sure they get
forwarded to you as well
5
Page 2 of 2
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Project To Do List
Project Engineer: fol» _______________
Peer Engineer: <JQ t__________
DB Person
G Check the Master File Mailing Address
C Check for Organization Link to AI
C Enter project into PROJECT 2008
Project Engineer A/
,16 lLi3^l0<>e>l
Enter Project into Tempo for Project Number
Enter NOI Date in to the Work Activity Log (WAL)
'£-1(to ■
^ ^ ^
Notify DB Person of project number
DB Person
□ Assigns Peer in TEMPO
Project Engineer
□ Generate Engineering Review (using the AIR in the Regulatory Program
field and the correct year)
G Notify Modeling if increase in emissions
D Give Compliance completed engineering review
a
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*»-£ S.
UTAH DIVISION OF AIR QUALITY
SOURCE PLAN REVIEW
Karl Kunz Project Number: NO 143010001
White Flame, Inc.
125 South 1800 West
Lindon, UT 84042
RE: New Approval Order for the Source at Its New Location
Utah County; CDS B;Nonattainment or Maintenance Area
Review Engineer:
Date:
Maung Maung
June 2, 2010
Notice of Intent Submitted:Febmary 11, 2010
Plant Contact:
Phone Number:
Fax Number:
Source Location:
Karl Kunz
[phone]
[phone]
125 South 1800 West, Lindon, UT
Utah County
4,463,676 m Northing. 437.544 m Easting, UTM Zone 12
UTM Datum: NAD83
DAQ requests that a company/corporation official read the attached draft/proposed Plan Review with
Recommended Approval Order Conditions. If this person does not understand or does not agree with the
conditions, the review engineer should be contacted within five days after receipt of the Plan Review. If
this person agrees with the Plan Review and Recommended Approval Order Conditions, this person
should sign below and return (FAX # [phone]) within 10 days after receipt of the conditions. If the
review engineer is not contacted within 10 days, the review engineer shall assume that the
company/corporation official agrees with this Plan Review and will process the Plan Review towards
final approval. A public comment period wjll be^quiredj^efore the Approval Order can be issued.
Applicant Contact
'i/nature & Date)
Engineering Review NSR0143010001: White Flame, Inc.: Lindon Wood Pellet Manufacturing Plant - New Approval Order for
the Source at Its New Location
June 2,2010
Page 1
<N0 DATA FOUND>
Engineering Review NSR0143010001: White Flame, Inc.: Lindon Wood Pellet Manufacturing Plant - New Approval Order for
the Source at Its New Location
June 2, 2010
Page 2
ABSTRACT
White Flame, Inc. has rcsquested an AO modification to move its operational facilities to a new site. The
company plans to increase its production at the new place. The old plant will be phased out gradually as
the new plant ramps up its production. The company manufactures wood pellets from sawdust and wood
scraps.
The company is located in Utah County. Utah County is a NAA of the NAAQS for PMi0. Provo/Orem
area is a maintenance for CO. NSPS, NESHAP and MACT regulations do not apply to this source. Title
V of the CAA does not apply to this source.
The potential to emit total, in tons per year, will be PMi0 = 0.50, NOx = 4.29, CO = 2.16, SOx = 0.17,
VOC = 0.10 and formal dehvde = 0.002.
SOURCE SPECIFIC DESIGNATIONS
Applicable Programs:
Nonattainment or Maintenance Area, Subpart Utah County PM]„ NAA applies to Wood pellets
manufacturing
Permit History:
When issued, the approval order shall supersede or will be based on the following documents:
Incorporates Additional information dated May 25, 2010
Is Derived From NOI submittal dated February 11, 2010
Is Derived From DAQE-017-96 dated January 8, 1996
Nonattainment or Maintenance Areas Impacted:
Utah County PM],, NAA
SUMMARY OF NOTICE OF INTENT INFORMATION
Description of Proposal:
Changes: The company is moving its operational site to a new location, and it plans to increase
production of pellets.
Summary of Emission Changes and Totals:
The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible. All values given are in tons per year.
Estimated Criteria Pollutant Potential Emissions
C arbon Monoxide 2.16 tons/yr
Nitrogen Oxides 4.29 tons/yr
Particulate Matter - PM]0 0.50 tons/yr
Sulfur Dioxide 0.17 tons/yr
Engineering Review NSR0143010001: White Flame, Inc.: Linden Wood Pellet Manufacturing Plant - New Approval Order for
the Source at Its New Location
June 2,2010
Page 3
Volatile Organic Compounds 0.10 tons/yr
Estimated Hazardous Air Pollutant Potential Emissions
Formaldehyde (CAS #50000) 0.0020 tons/yr
Total hazardous air pollutants .002 tons/yr
Review of Best Available Control Technology:
1. BACT review regarding One Blow Hog fan - Baghouse
Baghouse has a control efficiency of 99.95 % and it meets BACT requirement. [Last updated
June 2, 2010]
Modeling Results:
There will be no air dispersion modeling. [Last updated June 2, 2010]
I Engineering Review NSR0143010001: White Flame, Inc.: Lindon Wood Pellet Manufacturing Plant - New Approval Order for
the Source at Its New Location
June 2,2010
Page 4
RECOMMENDED APPROVAL ORDER CONDITIONS
The intent is to issue an air quality Approval Order (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 order. The AO will be issued to and will apply to the following:
Name of Permittee:Permitted Location:
White Flame, Inc.
125 South 1800 West
Lindon, UT 84042
White Flame, Inc.: Lindon Wood Pellet
Manufacturing Plant
125 South 1800 West
Lindon. UT 84042
UTM coordinates:
SIC code:
437.544 m Easting, 4,463,676 m Northing. UTM Zone 12
2499 (Wood Products, NEC)
Section I: GENERAL PROVISIONS
1.1 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]
1.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
1.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [ R307-401-11
1.4 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 Executive Secretary or Executive Secretary'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]
1.5 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 Executive
Secretary 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]
1.6 The owner/operator shall comply with UAC R307-107. General Requirements: Unavoidable
Breakdowns. [R307-107]
1.7 The owner/operator shall comply with UAC R307-150 Series. Inventories, Testing and
Monitoring. [R307-150]
Engineering Review NSR0143010001: White Flame, Inc.: Lindon Wood Pellet Manufacturing Plant - New Approval Order for
the Source at Its New Location
June 2,2010
Page 5
Section M: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A 1 Wood pellet manufacturing plant
Wood pellets manufacturing from sawdust and wood scraps
II.A.2 One Blow Hog fan
One fan. rated at 5,500 ACFM, associated with cyclone
II.A 3 Baghouse for Hammer mill process
One Hammer mill with associated cyclone and bag house, rated at 2,800 ACFM
II.A.4 One drum dryer
Dryer supported by a natural gas fired burner rated at 12 MM Btu per hour
II.A 5 One frontend loader
Cat 924 loader with diesel engine
II.A.6 Two forklifts
JCB 541-70 forklift with diesel engine and Allis Chalmers F40-24PS forklift with LPG engine
II A 7 Three conveyors, #1,2, and 3 for sawdust transfer
Sawdust transfer from storage bunkers to hog: #1 Shaker Conveyor, model number FSCB-30,
#2 Hog discharge conveyor which is 60 feet long and #3 conveyor moves the pellets from the
mills to the cooling tower, model number EF Mueller RB9A.
H.B Requirements and Limitations
II.B 1 Requirements and Limitations
II.B. 1 .a Visible emissions from the following emission points shall not exceed the following values:
A All conveyor transfer points - 10% opacity
B All diesel engines - 20% opacity
C All conveyor drop points - 10% opacity
Opacity odservations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8] '
II.B. 1 ,b The following limits shall not be exceeded:
A. Total pellets produced - 72,000 tons per rolling 12-month period
B. Total natural gas usage - 35.29 MMBtu per rolling 12-month period
C. Total sawdust in-take - 36,000 tons per rolling 12-month period
D. Total propane usage - 1,500 gallons per rolling 12-month period
E. Total operating hours for diesel fueled forklift and loader - 600 each per rolling 12-
month period
. [R3 07-401-8]
II.B. 1 b. 1 Compliance with the limitations shall be determined on a rolling 12-month total. The
owner/operator shall calculate a new 12-month total based on the twentieth day of each month
using data from the previous 12 months. Records of production and usages shall be kept for all
periods when the plant is in operation. Production shall be determined by scale house records or
Engineering Review NSR0143010001: White Flame, Inc.: Lindon Wood Pellet Manufacturing Plant - New Approval Order for
the Source at Its New Location
June 2,2010
Page 6
shipping records. Sawdust in-take shall be determined by vendors billings. Natural gas and
propane usages shall be determined by billings or purchase records. Hours of operation shall be
determined by superv isor monitoring and maintaining of an operation log. The records shall be
kept on a daily basis. [R307-401-8]
II.B. l.c Scrap wood received for processing into wood pellets shall be free of coatings such as varnish,
paint, oil, or contaminants. |R307-401-8]
II.B. 1 .d The owner/operator shall apply water treatment or chemical dust suppression treatment on all
areas on site disturbed by mobile equipment to control fugitive dust emissions. Application
shall be applied to ensure the opacity limits in this AO are not exceeded. [R307-205]
II.B. 1 e The owner/operator shall notify the Executive Secretary or Executive Secretary's representative
when the new site is fully operational and the operation at old site ceased. The existing AO
DAQE-017-96, dated January 8, 1996 shall be revoked at that time. [R307-401-18j
<NO DATA FOUND>
Engineering Review NSRO143010001: White Flame, Inc.: Linden Wood Pellet Manufacturing Plant - New Approval Order for
the Source at Its New Location
June 2, 2010
Page 7
REVIEWER COMMENTS
The AO will be based on the following documents:
Incorporates Additional information dated May 25, 2010
Is Derived From NOI submittal dated February 11, 2010
Is Derived From DAQE-017-96 dated January 8, 1996
I. Comment on an item originating in regarding Wood pellet manufacturing plant
The source is actually a small source if it wants to pursue. : The source wants to get an
approval order [Last updated June 2, 2010]
Engineering Review NSR0143010001: White Flame, Inc.: Lindon Wood Pellet Manufacturing Plant - New Approval Order for
the Source at Its New Location
June 2,2010
Page 8
ACRONYMS
The following lists commonly used acronyms and their associated translations as they apply to this
document:
40 CFR
AO
BACT
CAA
CAAA
CDS
CEM
CEMS
CFR
CO
COM
DAQ
DAQE
EPA
FDCP
HAP or HAPs
ITA
LB/HR
MACT
MMBTU
MMBTU/hr
NAA
NAAQS
NESHAP
NOI
NOx
NSPS
NSR
PMio
PM25
PSD
PTE
R307
R307-401
S02
Title IV
Title V
TPY
UAC
UDAQ
VOC
Title 40 of the Code of Federal Regulations
Approval Order
Best Available Control Technology
Clean Air Act
Clean Air Act Amendments
Classification Data System (used by EPA to classify sources by size/type)
Continuous emissions monitor
Continuous emissions monitoring system
Code of Federal Regulations
Carbon monoxide
Continuous opacity monitor
Division of Air Quality (typically interchangeable with UDAQ)
This is a document tracking code for internal UDAQ use
Environmental Protection Agency
Fugitive Dust Control Plan
Hazardous air pollutant(s)
Intent to Approve
Pounds per hour
Maximum Achievable Control Technology
Million British Thermal Units
Million British Thermal Units per hour (heat input rate)
Nonattainment Area
National Ambient Air Quality Standards
National Emission Standards for Hazardous Air Pollutants
Notice of Intent
Oxides of nitrogen
New Source Performance Standard
New Source Review
Particulate matter less than 10 microns in size
Particulate matter less than 2.5 microns 111 size
Prevention of Significant Deterioration
Potential to Emit
Rules Series 307
Rules Series 307 - Section 401
Sulfur dioxide
Title IV of the Clean Air Act
Title V of the Clean Air Act
Tons per year
Utah Administrative Code
Utah Division of Air Quality (typically interchangeable with DAQ)
Volatile organic compounds
Engineering Review NSR0143010001: White Flame, Inc.: Lindon Wood Pellet Manufacturing Plant - New Approval Order for
the Source at Its New Location
June 2,2010
Page 9
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF AIR QUALITY
Cheryl Keying
Director
DAQE-GNO143010001-10
February 17, 2010
White Flame, Inc.
125 South 1800 West
Lindon, UT 84042
Dear Sir:
I have received your application to modify your current Approval Order (AO).
Please submit your emissions calculation to justify your proposal. Your calculations show no emissions
increase, while your production has gone up 100 fold. Your submittal, as it is, is not complete.
I can be reached at [phone].
Sincerely,
M. Maung, Environmenta Engineer
Minor New Source Review Section
MM/sa
150 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.ulah.gov
Printed on !00% recycled p;iper
NEW SOURCE REVIEW SECTI™
SITE ID # AND PROJE^ i #: N0143010001-10
COMPANY NAME: White Flame, Inc.: Lindon Wood Pellet Manufacturing
Plant
REGARDING: <NO DATA FOUND>
THE ATTACHED DOCUMENT IS CATEGORIZED AS: (PLEASE CHOOSE ONE)
NEWSPAPER NOTICE (NN)Office Tech signs cover letter of Newspaper Notice
INTENT TO APPROVE (ITA)Cover letter and ITA signed by associated Section Manager
Electronic Copy of ITA sent to Ron Reece
APPROVAL ORDER (AO)Copy of purple sheet and cover letter of AO to Teri Weiss
^EXPERIMENTAL AO Copy of purple sheet and cover letter of AO to Teri Weiss
/
CORRESPONDENCE Signatory varies
SOIL REMEDIATION If associated fee, send copy of purple sheet and letter to Teri Weiss
SALES TAX EXEMPTION (TAX)
SMALL SOURCE EXEMPTION Copy of purple sheet and letter to Teri Weiss
EMISSIONS BANKING LETTER Copy of letter to Camron Harry
NAME CHANGE Copy of purple sheet and letter to Teri Weiss
COPIES TO BE SENT TO THE FOLLOWING PARTIES:(PLEASE CHECK AS THEY APPLY)
V Manila File Folder (working file)4 Greens Folder
Health Department (see letter for which)EPA - Mike Owens
Compliance (associated Section Manager)Finance - Teri Weiss
Name Change Letters:
Deborah McMurtrie Susan Weisenberg Dave Beatty Brett Wilding, Utah State Tax Commission, Technical Research Unit
Offsets Used? Copy of document(s) should be
sent to Camron Harry Enter final Name Change Letters in /engineer/aoname
Copy To:Enter in /engineer/aocond & in AO Log:
(AOs, AO not needed, Replacement in Kind)
NEWSPAPER NOTICE - COPIES TO:
Cities, Counties, Gov. Agencies, & etc./& a copy of
Public Official letter with self-addressed envelope
E-Mail To: [e-mail], Jodie Swanson, Lori
Walker, Debbie Obemdorfer, Bill Sinclair, Beverly
Rasmussen & Jen Burge, Donna Spangler, Ron
Reece, and Kelly Beck
E-Mail copy & Fax to Newspaper Agencies
PSD PROJECTS:
Copy the NOI, Engineering Review, ITA, NOTICE & AO
Send to:
Mike Owens, EPA
Don Banks, Bureau of Land Management
Chris Hocket, U.S. Forest Service
Chris Shaver, National Park Service
TITLE V: Check w/ NSR Engineer for which document(s) to be copied.
REVIEWED BY AND DOCUMENT SIGN OFF DATES:
Date NOI Declared Complete
Date ITA Reviewed by Modeling
Date Peer Reviewed
Section Manager Sign Off
Public Comments Received
Branch Manager Sign Off
Maung Maung
Modeler NSR
John Jenks
Timothy Andrus
Maung Maung
Reginald Olsen
White Flame Incorporated
125 South 1800 West
Lindon, Utah 84042
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attention: M. Maung, Environmental Engineer
State of Utah
Department of Environmental Quality
Division of Air Quality
150 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
t ENvi^our/,r>'
\
i»
I
ff
or
FEB 2 2 2010
Of* QU/-! ■'1
Dear Sirs:
This letter is written to supplement the information provided to the Division of Air Quality
(February 11, 2010) in regard to the new Air Quality application for White Flame Inc. The
previous permit (DAQE-017-96, January 8, 1996) was for their previous location at 186 North
1600 West, in Orem, Utah 84057. The name of the company at that time was Wood Pellet
Works. At the present time White Flame Inc., (new company name) is in the process of moving
their facility to their new location at 125 South 1800 West in Lindon, Utah 84042. This move
should be complete by August of 1910. At the present time, wood pellets are still being
manufactured during the transition from one facility to the other.
White Flame Inc., makes only wood products. At this time the plant primarily manufactures
wood pellets for use in wood burning stoves. The new facility is a much improved operation than
the plant at the Orem location. This includes a computer managed system that has remote sensors
to all parts of the pellet manufacturing operation. This computer management system allows
White Flame to control the pellet quality at all stages of the manufacturing process. This facility
is licensed for commercial operation by the Occupancy and Zoning Compliance Office in Orem.
In addition, a second Orem permit is a standard Business License. In December of 2009, White j
Flame made an application with the U. S. Department of Agriculture for their certification as a
“Qualified Biomass Conversion Facility’ for the Biomass Crop Assistance Program (BCAP).
co
7
CPppAC ^
White Flame Inc., does not use combustion equipment for their wood pellet manufacturing.
Motors used inside of the plant are electrical. Facility equipment that uses diesel fuel, primarily in
the outside operation of the plant includes a fork lift and a front-end loader. Also, there is no
outside venting of the machinery used in the operation and dust generated is contained in the bag
house. The maximum PMio emissions is estimated to be 4-6 tons per year from the wood pellet e m ' ^
plant. —
The “Blow Hog” and associated “Cyclone” unit do not have serial or model numbers as this
equipment is custom built by Utah County businesses. The “Blow Hog” has an estimated 5,500
ACFM. The inside cooler fan (40 hp) is rated at 9600 dm. The electric fan the blows air from
the sawdust bin to the “Bag House” is a 75 hp fan rated at 13,000 dm. The Bag House is
approximately 10 feet square by 20 feet tall. This Bag House has sixteen bags that collects small
particles of wood. The bags are emptied into 50 gallon barrels each day. Lids are then placed on
each barrel before they are disposed of.
The final wood pellets are packaged in 40 pound plastic bags. These bags are stacked 50 bags per
pallet or one ton of pellets per pallet. The pallet and bags are then shrink wrapped to hold the
bags in place. Some bagged pellets are sold to businesses, and bagged pellets are also made
available to individual home owners for use in their stoves. These pellets are usually sold by the
ton.
Included with this cover letter is a schematic diagram of the plant and the operations carried out
there.
If additional information is needed in relation to the Air Quality Application, please let us know.
' V.Voi L!£lL~
Gar W. Workman
435-760-2619
881-3495
Email: www.workmanmiHerenterprises.com
"435-890-8612
435-753-7006
[e-mail]
*
Utah Division of Air Quality
Form 1 - Appendix A
General Owner and Facility Information
Process Information
18. Site plan of the White Flame Inc., facility
*
4^
Utah Division of Air Quality
Form 1 - Appendix A
General Owner and Facility Information
Process Information
18. Site plan of the White Flame Inc., facility
4
Fax Transmission
Utah State Division of Air Quality
150 N. 1950 W.
P.O.Box 144820
Salt Lake City, UT 84114-4820
801-536-4000
Fax: [phone]
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Material Handling Emission Estimates
Bulldozing Emission Factor Calculations
Equipment:
Type of Emission:
Process:
Aggregate Production:
Aggregate Production Schedule:
Emission Factors for Bulldozing (using the equation for bulldozing overburden in AP-42; Table 11.9-1)
E.F.2.5 =(.105) (5.7)*(s)A1,2/(M)A1.3
It is assumed that PM2.5 is 10.5% of PM30
E.F.PM10 = (0.75)*(1.0)*(s)A1,5/(M)A1.4
It is assumed that PM 10 is 75% of PM 15
E.F. = Emission factor
s = material silt content %= 4.8
M = material moisture content %= 4
Table C-1: Bulldozing Emissions Calculations
Pollutant Hrs/yr E.F.Units Emissions Units
PM10 1,750 1.133 Ib/hr 0.991 tons/yr
PM2.5 1,750 0.114 Ib/hr 0.100 tons/yr
Appendix C-1 Page 1 of 1
Emissions Factor Calculations for Material Handling
PM10
(.75)*(1.0)0.75
(MA1.4)6.964404506
(1,5/(MA1.4)0.215380942
(s)A(1.5/(MA1.4)1.401930161
(0.75)*(1.0)*{s)A(1.5/(MA1.4)1.051447621
PM2.5
(.105)*(5.7)0.5985
(MA1.3)6.062866266
(1,2/(MA1.3)0.197926187
(s)A(1.2/(MA1.3)1.364066302
(0.105)*(5.7)*(s)A(1.2/(MA1.3)0.816393682
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Fax Transmission
Utah State Division of Air Quality
150 N. 1950 W.
P.O. BOX 144820
Salt Lake City, UT 84114*4820
801-536-4000
Fax: 801-536^1099
To: fcftKL From: fa AUNT
agency: co^tf Flspr^e. Trjr ^Phone#: %o{~£3C<-L(
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Date Faxed: 3
time: (fP€or/
Initials: OfttY)
Dear Mr Maung,
In response to our conversation requesting more detail on how we arrived at the total tonnage of
PM10 discharges, this document shows how the totals were derived.
There are three motorized pieces of equipment: A Cat 924F loader with a 125 hp diesel engine
which will operate 600 hours per year for a total PM10 emission of 0.105 tons per year. A JCB
541-70 forklift with a 125 hp diesel engine which will operate 600 hours per year for a total PM10
emissions of 0.105 tons per year. An Allis Chalmers F40-24PS forklift with a 40 hp LPG engine
has an estimated PMI0 annual emission of 0.0004 tons.
Following the diagram of the plant and the processes the was sent to you earlier, the PMI0
emissions are estimated as follows: (1) The loading belt receives wood pieces and sawdust with
particle sizes larger than PM10 and no processing occurs to reduce particle size. No PM]0 is
emitted. (2) A shaker conveyor sorts wood pieces and sawdust. Wood pieces go to the hog in-
feed belt and sawdust goes to the overhead auger system so no processing occurs to reduce
particle size. No PM10 is emitted. (3) The hog in-feed belt carries wood pieces that are greater
than 0.5 inch with no processing to reduce particle size. No PM10 is emitted. (4) The hog is a
sealed unit the reduces wood particle size to coarse sawdust. The sealed unit emits no PM10. (5)
The hog discharge conveyor transfers the coarse sawdust from the hog to the overhead auger
system. A minimal amount of PM10 may be emitted at this transfer point. It is estimated that up to
1 ton of PM10 per year might be emitted. (6) An overhead auger system transfers coarse sawdust
to various short term storage areas. There maybe minimal PM]0 emissions at transfer points. It is
estimated that a maximum of 1 ton of PM,0 might be emitted annually. (7) Dust hoods # 1 and #2
are estimated to emit 1.88 tons of PM]0 per year. (8) A hammer-mill in-feed belt is shielded so no
PMI0 is emitted. (9) The hammer-mill is sealed so no PM10 is emitted. (10) Air-ducts are sealed.
No PMI0 is emitted. (11) The sawdust hopper is sealed so no PM10 is emitted. (12) Pellet mills 1,
2, and 3 are sealed so no PM10 is emitted. (13) A drag conveyer moves pellets from mills to pellet
cooler. No PMI0 is emitted. (14) The pellet cooler blows cool air through the pellets to remove
moisture form the hot pellets. No PM10 is emitted. (15) The pellet screener removes defective
pellets before bagging. No PM]0 is emitted. (16) The bagger puts pellets into 40 pound bags and
seals the bags. No PM]0 is emitted. (17) Fans from sawdust hopper are sealed and deliver PM]0 to
the bag house for capture. No PMI0 is emitted. (18) The dryer is a wood fired drum dryer used to
reduce moisture content before pelleting. The dryer will operate 3,000 hour per year and emits
4.5 tons of PM10 per year. (19) The bag house is designed to capture 99.5% of particles 0.5
microns is size. It is estimated that the bag house will emit 0.1 tons of PM]0 per year.
This information is summarized in the table on the following page.
Tracking of wood and wood products at White Flame
and possible PM]0 discharge. Estimates based on
three eight hour shifts per day
PM10 Possible Source Tons of PM1()/year
Equipment
Large diesel loader.................
Small diesel fork lift..............
Propane fork lift....................
Loading (blanks) belt............................
Shaker conveyor.....................................
Hog in-feed belt......................................
Hog..............................................................
Hog discharge conveyor......................
Overhead auger system........................
Dust hoods #1 and #2............................
Hammer mill in-feed belt....................
Hammer mill............................................
Air ducts..............................................
Sawdust hopper.....................................
Mill, 1,2,3..............................................
Drag conveyor........................................
Pellet cooler..........................................
Pellet screener........................................
Bagger......................................................
Fans from sawdust hopper.................
Dryer........................................................
Bag house (bags 99.5% efficient)....
0.105
0.105
0.0004125
0
0
0
0
1.0
1.0
1.88
0
0
0
0
0
0
0
0
0
0
4.5
0.1
^ feV
Total estimated emissions PM10.. 8.69 tons per year
Note: no outside venting of machinery used in operations.
7fl i -
. CVu
Print Form
WOOD PRODUCTS MANUFACTURING (SAWMILLS & MILLWORK) FORM AQGP-110
ASSIGNMENT TO GENERAL AIR CONTAMINANT DISCHARGE PERMITS ANSWER SHEET
Source Category Description:
Sawmill and millwork facilities producing 25,000 or more board feet per shift of finished product and veneer
peeling and plywood manufacturing. Activities include sawing, debarking, chipping, planing, sanding, veneer
production, kiln drying, cabinet and structural wood manufacturing, surface coating,, and supporting activities such
as material conveyors (mechanical and pneumatic), veneer dryers, plywood presses and boilers.
1. Qualifications: For each qualification statement listed below, answer “yes” or “no” in the far right column.
a. Do your facility operations meet the description provided above?
b. Is a completed Form AQ 220 attached?
c. Does the facility use a steam-generating boiler? (If yes, a completed Form AQ 224 (if
hogged fuel fired) or Form AQ 208 (for gas, diesel, or oil fired) must be attached.)
d. Are wood-drying kilns used? (If yes, a completed Form AQ 225 must be attached.)
e. Are cyclones used? (If yes, a completed Form AQ 226 must be attached.)
f. Does the facility have a veneer dryer? (If yes, a completed Form AQ 221 must be attached.)
g. Does the facility apply paint or other type of coating onto products? (If yes, a completed
Form AQ 211 must be attached.)
h. Are there any additional operations onsite, other than wood products manufacturing? (If yes,
, provide a brief description below.)
i. Is the facility currently in compliance with DEQ regulations?
j. Have there been any violations in the last 5 years?
k. If there have been violations, have they been resolved?
1. Does the facility have the proper land use approvals? Stationary Sources must attach a
j; completed Land Use Compatibility Statement.
2. Additional Comments:
Oregon Department of Environmental Quality
General Air Contaminant Discharge Permit Application
Page 1
Revised 12/17/07
WOOD PRODUCTS MANUFACTURING (SAWMILLS & MILLWORK)
ASSIGNMENT TO GENERAL AIR CONTAMINANT DISCHARGE PERMITS
FORM AQGP-110
ANSWER SHEET
b. Cyclones and Target Boxes:
Device
Steam Kiln
Lumber Species
Projected Annual
Production (MBF) (1)
Douglas Fir
Ponderosa Pine
Pollutant
PM/PM 10
VOC
Hemlock
PM/PM 10
VOC
PM/PMhj
VOC
Emission Factor (2)
0.02 Ib/MBF (3)
0.6 Ib/MBF (4), (5)
0.02 Ib/MBF (6)
1.7 Ib/MBF (3)
0.04 Ib/MBF (3)
0.33 Ib/MBF (3)
Emissions
(tons/yr)
Electric Kiln Any Species | j VOC 0.81 Ib/MBF 0
(1)MBF stands for 1,000 board feet
(2)Use source specific data, if available. VOC factors are on a propane basis.
(3)OSU studies
(4)NCASI/University of Idaho study
(5)Average of sap and heart wood
(6)Assumed to equal emissions for Douglas Fir
Oregon Department of Environmental Quality
General Air Contaminant Discharge Permit Application
Page 4
Revised 12/17/07
White Flame Inc.
125 South 1800 West
Lindon, Utah 84042
Telephone: [phone]
Memorandum to:State of Utah
Department of Environmental Quality
Division of Air Quality
150 North 1950 West
P. O. Box 144820
Salt Lake City, Utah 84114
Subject:Application for DEQ Air Quality Permit
From:Gar W. Workman
Gilbert D. Miller
White Flame, Inc.
Clock Tower Plaza, STE 302
550 North Main
Date:
Logan, Utah 84321
Telephone: [phone]
Email: www.workmanmillerenterprises.com
f i «t>
January 11,2009 f
42 y ! '
The new address for this facility is:
White Flame Inc.
Karl Kunz, President
125 South 1800 West
Lindon, Utah 84042
Telephone: [phone]
i is 1 11A
(801) 336H000 Voice
(801) 53<5-W99 Pk
(801) 3364414 T D D.
DEPARTMENT OP ENVIRONMEN'L’AL QUALITY
DIVISION OF AIR QUALi rY
150 North 1930 W®it
P.O. Bo* 144820
5aK Uke Qty. Utth 841144820
i
FILE COPY
Runell A. Roberts \;
DAQE-017-96
January 8, 1996 I I v'vk
Lynn Bratt, Vice President
Wood Pellet Works
168 North 1600 West
Orem, Utah 84057
Dear Mr. Bratt:
Re: Approval Order for Pellet Manufacturing Process
Utah County, CDS-B
The attached document is an Approval Order for the above referenced project
Future correspondence on this Approval Order should include the engineers name as well as the DAUB
number as sliown on the upper right-hand corner of tills letter. Please direct any technical questions you may
" ‘-reached at (801) 536^1096.
RAR:DC:dn
cc: City/County Health Department of Utah County
Mike Owens. EPA Region VI11
11.1 11'..'. wU t sJui.' <UvJijwui cl („uuij iuu lU'OU mi unw i .
DAQE-017-96
i
Abstract
’? H-i- ■
V r Wotid Pellet Mtkx has submitted a Notice of Intent Dated March 20, 1995, for a wood pellet manufacturing operation to be located in Orem, Utah county. The proposed facility will consist of scrap wood receiving, loading grinding and pelletizing operations. The use of cyclone collectors and a bag house as well as water sprays at fugitive emission points will be used to meet the best available control technology
(BACT) requirements of the Utah Air Conservation Rules. This source is not a title V Operating Permits)
source.
General Conditiom;
1. Tliis Approval Order (AO) applies lo Uic following company:
Wood Pellet Works
186 North 1600 West
Orem, Utah 84057
The equipment listed below in tills AO sbnll be o|K;inted nl the following location:
PLANT LOCATION:
Universal Transverse Mercator (UTM) Coordinate System:
(4,460,000) metere NortiUng, (440,000) meters Easting
2. Definitions of terms, abbreviations, and references used in this AO conform to those used in
the UACR, Utah Administrative Codes (UAC), mid Series 40 of the Code of Federal
Regulations (40 CFR). These definitions take precedence unless specifically defined
otherwise herein.
3. Wood Pellet Works shall install and operate (ho wood pelletizing facility according to the
information submitted in the Notice of Intent dated March 20, 1995, and additional
information submitted to the Executive Secretary dated June 30, 1995.
4. Acopyofthis AO shall be posted on site. 'Hie AO shrill he available to die employees who
operate the air emission producing equipment, llicae employees shall receive instruction as
to tiieir responsibilities In operating the equipment according to nil of the relevant conditions
listed bdow.
5. The approved installations shall consist of the following equipment and/or processes:
0.
Unloading of wood scrap onto concrete pad
Conveying of wood scrap
One Blow Hog with associated cyclone - V'0o ACFM
One Hammer Mill with associated cyclone and baghorree - 2,R()<) A(TM
One pellet mill and baggers JiMrnted Ire He ti,r' fi'cdity buiMing
(And venting insidiuiie building) n ^
- Fc^v - ;fe ~ ^ 1 ^ ^ ^
Tire Executive Secretary shall benotified in writing upon stnjt-np of tlie inrlnlEiion, as nn
initial compliance inspection is required. Eighteen months fiom die dale of Uric AO the
Executive Secretary shall lie notified in writing of tire, slntm of construed on/in stall alien if
HO
>
7$ H
Gii
U/i“dL-dliuu lull JU'UU nil Ulirt
DAQE-017-96
Page 3
constraction/installaliou i« notcon.ple.ed. At tl.MU.ne the Executive Secccuy xhull rcqui.e
" n"u.e continuous cousttucUon/instMinU,,,, of the operM.on tm.l .nay revoke
the AO in accordance with R3U/-l-3.1.-*\ UAC.
I Jmltatlona and rroccdurca
7. Emissions to the Mmosphere from U.c indicnlcd emission point slu.ll nut exceed die following
rates and concentrations:
8.
Pollutant
PMt0 ...
Source: JJlow Uog Cyclone
Ih/hr ginins/dscL
(68^, 29.92 in llg)
UPindi'
(3% Oj dry)
PqIIuUuiI
PMI0 ...
.0.75 .................................."
Source: Hommer Mill Cyclone
Mil gmius/dscL
(68T, 29.92 in Hg)
ppiurtx
(3^0, dry)
0.40 0.02
Stack tesUng to show compliance with the emission limitations slated in the above condition
shall be perfonned as specified below:
A. Emission 'I'cRting
Point Eoliunml Status Erequcucy.
Blow Hog Cyclone PMin .............X_____
Hdmmer Mill Cyclone PM,n ■............ X ....
n Tesiine ^Status (To be applied above)
lest
♦ No initial testing is required. However, lire Executive Secretary may reqmre
testing at any time in accordance with R307-1-3 A1. UAC. Ibe source shall
be tested if directed by tire Executive Secretary.
X Test if directed by the Executive Secretary. TesLs mayl& required it Uic
source is suspected to f>e in violation will! other conditions of this AO. (//
the estimated amount of pollutant is hr low levels considered safe by the
Division Of Air QuaMy. du-n no periodic tests are required)
C. Nutificalion
■Hie flpplicnnt Khali provide n 11 ,d .do tcM dmc M Inw. 45 day, helmc .lm
(CBt. A pretest confcroncc slmll he IwM if directed by the Exccotnc Sec.cta.). it
Khali be ltel.1 at lea»t 30 duys beforo Hie lea! Iretwccii Hie owi.ci/opcralor. tl.e I. si. i.
and the Executive Secretary. Tbc emission, point slmll be designed to conform lo the
Wvl-dl -£UUU IUL lUiOU HU UIIW Min HU, (JUKMU4UUU I . Utj
Jiremcnts of 40 CFR 60, Appendix A, xi 1, and OccuiMiiionni Safety and
Health Administration (OSHA) or Mine Safety and Health Administration (MSIIA)
approved access shall be provided to the test location.
D. EMio
For stacks in which no liquid drops are picsent, die following metliods sliall be used:
40 CFR 51, Appendix M, Metliods 201 or20l(L The back half condensibles shall
also be tested using the method specified by the Executive Secretary. All particulate
captured sliall be consideredrMuy
For stacks in which liquid drops me present, metliods to eliminate the liquid diops
should be exploretL If no reasonable method to eliminate the drops exists, Uien the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e
as appropriate. The back half condensible'i sliall also be tested using the method
specified by the Executive Secretary. The portion of the front half of the catch
considered PMI0 sliall be based on information in AP-42, Appendix C or other data
acceptable to the Executive Secretary.
The back half condensibles shall not be used for compliance demonstration but sliall
be used for inventory purposes.
E. Sample Location
40 CFR 60. Appendix A, Method 1
F. JMumctnc.Flow Rate
40 CFR 60, Appendix A, Method 2
G Calculations
To determine mass emission rotes (Ib/lir, etc.), the pollutant concentration as
determined by die appropriate methods above shall be multiplied by the volumetric
flow rate and any necessary conversion factors determined by die Executive
Secretary to give the results in the specified units of tlie emission limitation.
H. Nc^SQurcaDpcxalion
Fora new source/emission point, (he production rate during oil compliance testing
shall be no less than 90% of the production rale listed in this AO. If tlie maximum
AO allowable production rate has not beer, aclucved at the time of die test, die
following procedure sliall be followed:
1) Testing sliall be at no less than 90% of the production rale achieved to date.
2) If the test is passed, the new maximum allowable production rate shall l>e
110% of the tested achieved rate. This new allowable maximum production
rate shall remain in effect until successfully tested at a higher rate.
3)The owrier/operator slmll request a higher production rate when necessary.
Testing at no less than 90% of the higher rate shall be conducted. A new
mardtnum production rate (110% of the new rate) will then be allowed if the
test is successful. This process inay be repealed until the maximum AO
production rale is achieved.
1. Existing SQuicEOperatiou
For an existing source/emission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the
previous three (3) years.
9. Visible emissions from the following emission points shaJl not exceed the following values:
A. All screens -10% opacity
B. All conveyor transfer points -10% opacity
C. All diesel engines - 20% opacity
D. Conveyor drop points -10% opacity
Opacity observations of emissions from stationary sources sludl be conducted according to
40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and intermittent
, sources shall use procedures similar to Method 9, but the requirement for observations to be
made at 13-second intervals over a six-minute period shall not apply.
10. The following production limits shall not be exceeded without prior approval in accordance
with R307-1-3.I, UAC:
A. 1600 tons of wood pellets manufactured per rolling 12-month period
B. 2080 hours per rolling 12-monlh period.
Compliance with die annual limitations shall !>e determined on a rolling 12-monlh total. 1 he
owner/operator shall calculate a new 12-month total based on lire first day of each mouth
using dala from die previous 12 months. Records of consuniption/prodtiction shall be kept
for all periods when die plant is in operation. Records of consumption/pnxluctioti. including
rolling 12-month totals shall be made available to Uic Executive Secretary or his
representative upon request, and shall include a period of two years ending with the date of
the request Production shall be determined by ot>eiator records. Records shall be kept on
a daily basis. Hours of operation shall l>c determined by su|)ervisnr monitoring and
maintaining of an operations log.
, II. Scrap wood received for processing into wood pcIletK shall be free of coatings sucli as
; varnish, paint, oil, or other conumiinants.
Roads and Fugitives
12. Visible emissions from haul-road traffic and mobile equipment in operational areas Khali not
exceed 20% opacity. Visible emissions determinations for traJiic sources shall use
procedures similar to McUiod 9. The requirement for observations to be made at 15-second
intervals over a six-miuute period shall not apply. Six points, distributed along llic length of
the haul road or in die operational area, shall be chosen by the Executive Secretary or his
uol cl tiuUu Oil iu»jU mi uin I 1 in ii<J. OUi JOU'lUJO I . U I
- v Page 6
represent jve. An opacity reading shall lie mode at & >int when a vehicle passes the
selected points. Opacity readings shall be mode one-half the velucic length or greater belli ml
the vehicle and at approximately one-half the height of tire vehicle or greater. The
accumulated six readings shall be averaged for the compliance value.
13. Water sprays or chemical dust suppression sprays slinll be installed ot the following points
located outside of the facility building to control fugitive dust emissions:
A. All screens
B. All conveyor transfer points
The sprays shall operate whenever dry conditions warrant or as determined necessary by the
Executive Secretary.
14. The moisture content of the material shall be maintained at a minimum of 4.0% by weight.
The moisture content shall be tested if directed by Uie Executive Secretary using the
appropriate ASTM method.
15. The storage piles shall be watered to minimize generation of fugitive dusts as dry conditions
warrant or as determined necessary by the Executive Secretary.
16. Eighteen months from tire date of this AO tlw Executive Secretary shall be notified in writing
of the status of construction of this project If construction is complete and operation has
commenced a notice is not required.
17. All records referenced in thii AO or in applicable NSPS or NESHAP, which are required lo
be kept by the owner/operator, shall be made available to tlie Executive Secretary or his
representative upon request. Examples of records to be kept at diis source shall include the
following as applicable:
*
A. Production rate (Condition number 10)
B. Hours of operation (Condition number 10)
18. All installations and facilities authorized by tliis AO shall be adequately and properly
maintained. All pollution control vendor recommended equipment shall be installer!,
maintained, and operated. Instructions from the vendor or established mrintenance practices
that maximize pollution control shall be used. A copy of all manulacturciV operating
instructions for pollution control equipment and pollution emitting equipment shall be kept
on site. These instructions shall be available lo all employees who operate die equipment oikI
shall be made available to compliance Inspectors upon tlieir request.
19. The owner/operator sliall comply with R307-1-4.7, UAC. This rule addresses unavoidable
breakdown repotting requirements. Tlie owner/o|>cmtoc shall cnlculatr/cRtimfite the excess
emissions whenever a breakdown occurs. Tlie trial of cxccrs emissions shall be reported lo
the Executive Secretary as directed for each calendar year.
Any future modifications to the equipment approved by this cmlrr must also be approved in accordance with
R3U7-I-3.1.1, UAC.
utu-dl^UUti IUh 10:50 AH DAQ •AX NO, AU15304099 U8
DAQB-017-96 ^
Page 7 ^
Hiis AO in no w»y release* the owner or operaloc f«Mii«ny liabilily for compUance wiUi allollicr applicable
federal, stale, and local regulations including Uie UACR.
Annual emissions for this source (the entire planl.) are cuneittly calculated at liie following vulues:
Eoilulaui 'Xsmln
A.
B.
Particulate
PMW ....
8.69
8.69
Iliese calculations are for the purposes of <k“nnl"^'^l'e ^th^UACR!^^^''0^8^ for
Deterioration and Nonattainment area major source requirements of the U ali y
purposes of determining compliance.
Approved Byy
Russell A. Roberts, Executive Sccrctaiy
vUt^h Air Quality Board
iflnlTib
?**»
i
3Brazilian Oangress of IT
- TrsnctiI&ss T%choology
1st No^Dig Latm Amenean EdBiioa
A
i1 %
Central i HBM.:
RENCHLESS I IT Vsf i S:
F«UA3:Y 13 ~ 1 5 2008
Sag Paulo - SP - Braze.
• United States Environmental Protection Agency (US ERA)
• Establishes national standards - assessment, research and
education
• Provides information on pollutants, approved testing
methodologies & research outputs
• US EPA document AP42
- Reports and background data to arrive at Emission Factors (EF)
• Section 3.3 of AP42 - gasoline & diesel engines <600hp
3r^ Brazil an Oengrass of IT
- Tr g non; ess Toe nofogy
1st No^Dig laim American Edition
> : : V > v. < :■A Trenchless City
f'mmmr 13 - 15, 2008
$ad Paulo - SP * Bi.Azn.
EF - a tool to estimate air pollutants released
Expressed as:
- Weight of pollutant / (unit weight or volume or distance °r duration)
General equation for calculating emissions from EF is:
E = A*EF*1-ER
Too
where,E - emissions (lbs, grams, etc)
A - activity rate
EF - uncontrolled emission factor
ER - overall emission reduction efficiency %
(product of removal efficiency and capture efficiency)
3rt? BraiiUan CDegress of IT
« Technology
15? No*Dig Laim American Edition
A Trenchless Csty
fHKU,«r 13- 15, 2008
Sao Eaulo - SP - 8sas
• US ERA document AP42 classifies pollutants
• Criteria pollutants & their precursors
• Hazardous air pollutants
• Greenhouse gases
Air Pollutants '
Sulfur dioxide (SOx)Title III of Clean Air
Act - identifies more
than 100 pollutants
Carbon dioxide (C02)
Nitrogen oxides (NOx)
Carbon Monoxide (CO)Methane (CH4)
Lead (Pb)
Ozone (03)Nitrous oxide (N20)
Particulate matter <1Gfj (PM-10)
oox.x.NX.v-t-y-x-:;:
3!1? Brazhiian Cregress of IT
' Tn^ncrness Tschooiogv
- Thermal dissociation & reaction of Nitrogen (N2) & Oxygen (02)
- Fuel NOx stems from the reaction of fuel bound nitrogen
compounds with Oxygen (02)
- Hydrocarbons (HC) discharged from unburned and partially
burned fuel
- Partially burned HC from
• poor air and fuel homogeneity
• incorrect fuel/air ratios
• excessively large fuel droplets
• low cylinder temperature
?<m&n
Bra ? in an Goograss of IT
* Iraneoless Tachoonagy
1st No’Dig tatio Amariean idHiors
C ntiAL Theme:
February 13 - 15, 2008
Sag Paulo - SP - Bnmi
Colorless, odorless, inert gas
Reaction of CO to carbon-di-oxide (C02) incomplete due to
• Lack of combustion oxygen (02)
• Gas temperature is too low
• Residence time in cylinder is too short
Q
I: W :5 A W vi™ i u-ate ivi atter {
- White smoke
• Liquid particles - cold start, idling, low load operation
- Blue smoke
• Lubricating oil leaks past piston rings & gets partially burnt
- Black smoke
• Clustered carbon particles (soot) in regions of oxygen deficiency
......^:-.v .v......
3ft? BrazHian of IT
- T r inc nIess TscB o o f ogy
Is5 No*Dig tatm Amenean EdBsoa
Cemimi. Theme:
A Trenchless City
FTiBiyMY 13- 15, 2008
Sad Paulo ~ SP - Bnmi
- Function of sulfur content in the fuel
- Fuel oxidized to S02
- Forms sulfates by reaction with bases (metals)
- Sulfates contribute to
• Particulate matter less than <10|j PM-10)
• Visibility reduction
* Carbon Dioxide (C02)
- Slightly toxic, odorless, colorless, greenhouse gas
- Combustion of fuel carbon
- Heats up the earth’s atmosphere by absorbing IR radiations
- Mixes with water & forms corrosive carbonic acid
8ra>?j;iian Gangress of TT
■ T r ® n e r? i e s § T s c h e o i 0 g y
1st No-Dig tatm American MiMn
CfNmi Thims:
VRENCHLESS ^
Fmmmr' 13 - 15, 2008
Sad rAEiio - $P ^ BtMii
Most common method
- Fd -Factor method
To determine emission factors (EF) from stack (fuel) concentration
CO concentration can be correlated to heat input rate
Heat content is closely related to carbon content in the fuel
EF in units of pounds (lbs) per British thermal Unit (BTU) [or] pounds
(lbs) per weight or volume of fuel
Three methods under F-Factor
- Fd factor method {Dry F-Factor method}
- Fw factor method {Wet F-Factor method}
- Fc factor method {Carbon F-Factor method}
3{*$ Bra>?hiian Congress of TT
‘ TrsncrHess Toe^ooiogy
1S? No^Dig Latin American Edmcm
%v!;
Central Theme:
A Trenchless City
February 13 - 15, 2008
Sad Pauls - SP * B%mi
Same principle as Fd Factor method except that
- Effluent gas & oxygen cone, are determined on wet basis
Fw=
Quantity of wet effluent gas is a constant
Gross calorific value of fuel (GCV)
With the determination of
Cw - wet basis measurement of pollutant cone.
%02w- percent oxygen content in effluent stream
Bwa- moisture content of air supplied for combustion
20.9Emission Rate EF = C>. * F» *{20.9(l - Ara)"%6>2„}
3!45 Congress of IT
* T r §neft less Tscho o I og y
1$- No^Dig Latin American Edifkm
U-?ttral ! HEME:
A Trenchless City
February 1 3 ^ 15, 2008
Sac Paulo - SP - Mmi
m m
For a given fuel category,
_ Volume of carbon dioxide produced jS a constant
c_ Heat content of the fuel
Dilution correction = Theoretical carbon dioxide
Measured carbon dioxide
With the determination of
1) Pollutant cone.2) Percent C02
Dry - Cd Wet-CW
Emission Rate EF = Cd * Fc *
Dry - %C02d
1 ’ = G, *FC*
%COid
Wet - C02w
100
XCOln
Am&n
3;:;? B rax Mian Congress of IT
« Tre non les s Technology
1st Ho*Dig Latin American Edition
Cemtral Theme:
A Trenchless City
¥mmm( 13— 15, 2008
$Ao Paulo - SP - B%mi
• For a given fuel category;
Quantity of dry effluent gas
Fd= ------------------------------------------------, is a constant
Gross calorific value of fuel (GCV)
• Excess air correction factor:
Where,
Cd- dry basis measurement of
pollutant concentration
%02d- percent dry oxygen content
If moisture content of flue gas (Bws) is in effluent stream
Emission Rate EF = Cd * Fd *20.9
(20.9-%02A
known then,
Emission Rate EF = G, * Fd *20.9
{20.9(l - Bws)~ %02d)
Am Art
3;t* BraxiUan Congress of IT
« Trsnc^isss Tec Zoology
1st No^Dig taim Amcncan Bditlom
Cemtral Theme:
“renchless City
¥mmmf 13 ~ 15, .2008
Sad Paulo - SP - Baaol
Frf = 106 *
(5.57%// +1.53%C + 0.57%S + 0.14%^ - Q.46%0)
................................................" GO'
F„. = 106*
(5.57%// +1.53%C + 0.57%S + 0.14%yV - 0.46%Q + 0.21//2G)
GO' ^..............~..............................
Fc 106*
(0.321%C)
GCV
where
H,C,S,N,0,H20 are concentrations by weight expressed in percentage
GCV - Gross calorific value in Btu/lb
• Calculation of Fw must include the free water in the ultimate analysis.
Bra:?Hri^ Congress of IT
' T r b n € h i e s $ T % c n o o i o g y
1st Ho^Dig Lalm Amsncan Edstfor?
TChi;'? nMiiM-
Trenchless City
¥mmm 13- 15, 2008
Sao pA-iso SP ■' %nmi.
All equipment operates to complete it’s particular task
and not for the entire duration of the project
» Time of operation for each equipment differs
An installation project is a combination of many such
activities
—► Many equipment may be required
Emission from each equipment differs due to
- Fuel type
- Engine power
- Usage period
- Load factor (power actually used divided by power available)
'Amm%
Braziflun Gang re$s o f IT
‘ Trs n e h! ess T@ e h a o 5 0 gy
1st N:o*Dig talm ArȤ?ican Edit'loft
Cehtral
A Trenchless
f £«UMr 1 3 - 1'
• Depth of 1.5 m
• Length of 30 m
• 300mm diameter pipe installation
1.5 m 300mm pipe
30 m
◄---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------►
;Vt>>>>yAX;v-X->X-
OrazHisn Congress of IT
- trtrieniess Technology
i$t No^Dig Latin American Edition
i: f '
A Trenchless Cry
F£wj,w 13- 15, 2008
Sao Paus-o - SP - Brmii.
• Section 3.3 of AP42 - Emission factors (EF) for
equipment <600hp
• Two kinds of EF for diesel engines
- Based on fuel intake
• Quantity of fuel burnt for the activity is difficult to measure
• The fuel consumed is proportional to the load on the engine
- Based on power output
• Operator of the equipment is aware of the load on the engine
• Avg. power of the engine for a particular activity can be determined
• Fuel Intake is proportional to the power output
• EF based on power output, is used in the calculations
3ft? Br&iit'mn Ganpess of IT
* ! r ® n c h. less T e e h ft o i o g y
1st Ho*Dig lalm Arnsrioan Ediffoft
REN CHS
R: a i : $J, PU..& «:V >t. < :* • Ly >'Vc
Fsbrumv 13 •
Sad Paulo «
15, 2008
SP - Bwil
• Assumptions:
- Native soil excavation
- Urban environment
- No crossing of utilities underground
- New pipe installation
- Site restrictions to dump the spoils at site
- Operating hp of the same equipment is same in each
construction method
Operating hp skill of the operator
- Calculation of the installation / operating times only
S'15 Brazilian of IT
« Trenc^iess Tseheo?ogy
1$J No^Dig iBim American HcNfion
EH"
vV- y-vla w TV
Ftbrivjy 13 - 15, 2008
Sad Paulo - SP - Bba/b.
CAT420E
89hp
CAT924G
129hp
Peterbilt-330
300hp
CAT CS323C
83hp
. ^.vjw. JugilfcA^.
%
M,
300mm
pipe
Required trench width - 1.2m
Installation duration - 20 hrs
Bra/Hiao Gongress of TT
- Irene fii&ss Tech no jo gy
1st Ho*Dig Latin American Edslfom
ARBITRAL j HEA4I:
A Trenchless City
FmwK 13 - 15, 2008
Sao Paisio «!>P - Bsabl
• Trench width is 1.2m
• Production of CAT 420E backhoe is
- 10.4 cu.yd/hr - excavation
- 10 cu.yd/hr - backfill
• CAT 924G loader bucket capacity is 2.2 cu.yd.
- Loading time per bucket = 1 min & 2 min set-up time
• Peterbilt-330 Haul truck capacity 12 cu.yd
- Time to unload = 5 min
• Compaction (CAT323C) in 4 layers @ 1 hr/1 ft layer
• Only operating time
i&mmt
3rts Brazilian Cangress of TT
‘ Trencftless T8ehftoIogy
Ts; Ho*Dig Latm American MHWn
7
A Trenchless City
f £r«u«Y 13 . 15, 2008
Sad Paulo - SP - 8sA>::ii.
Equipment Used - Usage (%) & Load Factor (%)
Installation Time 20 hrs
Equipment Operating time Usage/Total
time Load Factor
Backhoe 16.0 hrs 80.0%90%
Loader 3.3 hrs 16.3%80%
Truck 10.4 hrs 51.9% 75%
Compactor 4.0 hrs 20.0%90%
zmmt
34^ Braxillao Congress of IT
« T r $ n c o 1 & s s I s e f? n o t o g y
1st No*Dig Latin American Edition
Central Theme:
A Trenchless City
¥mwjm' 13 - 15, .2008
$ao Paulo - $P - B$mu.
Pollutant
Emission
Factor
(Diesel)
(Ib/hp-hr)
Backhoe
CAT-420E
Truck
Peterbilt-330
Compactor
CAT-CS-323C Total
XUsage
* Total
time
(lb)
Power
89hp
(Ib/hr)
Load
90%
(Ib/hr)
Usage
80%
(Ib/hr)
Power
280hp
(Ib/hr)
Load
75%
(Ib/hr)
Usage
52%
(Ib/hr)
Power
83hp
(Ib/hr)
Load
90%
(Ib/hr)
Usage
20%
(Ib/hr)
NOx 0.031 2.8 2.5 2.0 8.7 6.5 3.4 2.6 2.3 0.5 127.0
CO 6.68E-03 o.e 0.5 0.4 1.9 1.4 0.7 0.6 0.5 0.1 27.4
SOx 2.05E-03 0.2 0.2 0.1 0.6 0.4 0.2 0.2 0.2 0.0 8.4
PM-10 2.20E-03 0.2 0.2 0.1 0.6 0.5 0.2 0.2 0.2 0.0 9.0
co2 1.15 102.4 92.1 73.7 322.0 241.5 125.4 95.5 85.9 17.2 4712.7
Aldehydes 4.63E-04 0.0 0.0 0.0 0.1 0.1 0.1 0.0 0.0 0.0 1.9
TOC
Exhaust 2.47E-03 0.2 0.2 0.2 0.7 0.5 0.3 0.2 0.2 0.0 10.1
Evaporative 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Crankcase 4.41 E-05 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2
Refueling 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Zf* Bra^iHan Congress of TT
« Trsnclvless Tschoosogy
1$s No*Dig tatm Amencan Editors
'T,
A T:
N: kAL u-it-Mt:
A I RENCHLESS CiTY
Februaiy 13 - 15, 2008
Sac Paolo - SP - B^a/h,
300mm pipe
Vermeer MX240 - 22 hp
750 gal mixing tank
30m
◄-----------------------------------------------------------------------------------------------------------------------------------------------------►
No trench required
Installation duration - 1.5 hrs
3*Brazman Congress of IT
‘ Irene n I e s § Tee N o 0! 0 g y
1st No*Dig tatm Amanean Edison
CEHTRAL T'-ii-;.' ;
A Trenchless City
Fssswary 13 - 15, 2008
Sac Paui.o - SP - 8*a»i.
No trench
Vermeer D24x40 Series II Drill rig
- 1.5 hrs for 30m pilot bore and pullback
Vermeer MX240 Mixing system
- To reduce soil friction
- To suspend / transport cuttings
- To stabilize the bore hole
Mixing system operates for the entire duration of the
drilling rig
Only operating time
3ri? Brazilian Congress of IT
« T r s ncft1e s § Tec fto o l sgy
1st No*Dig Lalm American Bdiffom
Central Theme:
A Trenchless City
FcBcuiAxv 13- 15, 2008
$ao Paulo - $P - Bmam
Equipment used - Usage (%) & Load Factor (%)
Installation Time 1.50 hrs
Equipment Operating Time Usage/Total
Time
Load
Factor
Drilling Rig 1.50 hrs 100.0%50%
Mixing System 1.50 hrs 100.0%70%
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Emission Vermeer D24X40 Vermeer MX240 Total
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*Total
time
(lb)
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(Ib/hp-hr) 125hp
(Ib/hr)
Load
50%
(Ib/hr)
Usage Power
100% 22hp
(lb) (Ib/hr)
Load
70%
(Ib/hr)
Usage
100%
(lb)
NOx 0.031 3.88 1.94 1.94 0.68 0.48 0.48 3.62
CO 6.68E-03 0.84 0.42 0.42 0.15 0.10 0.10 0.78
SOx 2.05E-03 0.26 0.13 0.13 0.05 0.03 0.03 0.24
PM-10 2.20E-03 0.28 0.14 0.14 0.05 0.03 0.03 0.26
CNOO 1.15 143.75 71.88 71.88 25.30 17.71 17.71 134.38
Aldehydes 4.63E-04 0.06 0.03 0.03 0.01 0.01 0.01 0.05
TOC
Exhaust 2.47E-03 0.31 0.15 0.15 0.05 0.04 0.04 0.29
Evaporative 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Crankcase 4.41 E-05 0.01 0.00 0.00 0.00 0.00 0.00 0.01
Refueling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
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HDD
Emissions
(Ib/hp-hr)(ib) (ib)
NOx 0.031 127.00 3.62
CO 6.68E-03 27.40 0.78
Sox 2.05E-03 8.40 0.24
PM-10 2.20E-03 9.00 0.26
C02 1.15 4712.70 134.38
Aldehydes 4.63E-04 1.90 0.05
TOC
Exhaust 2.47E-03 10.10 0.29
Evaporative 0.00 0.00 0.00
Crankcase 4.41 E-05 0.20 0.01
Refueling 0.00 0.00 0.00
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- Limited equipment on site
- Faster installation
- Limited movement of equipment
at site
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Environmental sensitivity
Cost effective and sustainability
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cut construction
Influences method selection during the design
stage of the project
Quantification of pollution from construction
activities necessary to identify offsets
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(5/25/2010) Maung Maung - White Flame emissions calculations pdf
I
♦
Page 1
From:
To:
CC:
Date:
Subject:
Attachments:
"Gil Miller" <[e-mail]>
<[e-mail]>
<git@wo rkmanmillerenterprises.com>
5/25/2010 1:44 PM
White Flame emissions calculations pdf
Emissions Calculations.pdf
Dear Mr. Maung,
As per our conversation this morning, I have attached the pdf of the
calculations we covered this morning with the changes you said needed to be
made.
I talk with Mr. Karl Kunz President of White Flame after our conversation.
He is contacting the manufacture of the bags used in the bag-house to
document the efficiency at 99.5% as used in the calculations for the
emissions from the bag-house. I will forward the information to you as soon
as I receive it.
(!)
U>-
Thank you for your professional and courteous help in completing White
Flame's application.
Sincerely,
Gil Miller
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Storage of Raw Materials: Raw materials are stored in concrete bunkers and covered with traps.
Calculation of PM10 per year from sawdust delivered to plant.
From Montana DEQ - OP2589-02 Decl.pdf Page18 section A.3.b PM10 content of sawdust is 0.36 Ibs/ton uncontrolled.
White Flame receives sawdust from cabinet and truss manufactures that have cyclone control systems.
Assumed the cyclones remove 60% of PM10 and another 15% is lost due to handling and transportation losses before arrival at White Flame.
Uncontrolled Sawdust Content Controlled Controlled PM 10 content lbs per ton
0.36 Lbs/ton 0.25 0.09
White Flame to receive 36,000 tons of sawdust per year
Calculation of handling emission of PM10 from unloading trucks into raw material storage bunkers
From Montana DEQ - OP2589-02 Decl.pdf Page18 section A.8 PM10 emission is 1.39% of PM10 in sawdust
0.005/.36
Ibs/ton PM10
0.09
1.39%
EF
0.0139
Total tons of Sawdust Flandled Total PM10 Emission tons per Year
36000
|£ <7 (T)
Calculation of handling emission of PM10 from moving sawdust from'shortagejDunkers to belt conveyer
From Montana DEQ - QP2589-02 Decl.pdf Page18 section A.8 PM 10 emission is 1.39% of PM 10 in sawdust
0.022518
0.005/.36
Ibs/ton PM 10 EF
0.09
1.39%
Total tons of Sawdust Handled Total PM10 Emission tons per Year
0.0139 36000 0.022518
Calculation of handling emission of PM 10 from transfer of sawdust from belt conveyer to shaker conveye£)
From Montana DEQ - QP2589-02 Decl.pdf PagelS section A.8 PM10 emission is 1.39% of PM10 in sawdust
0.005/.36
Ibs/ton PM10 EF
0.09
1.39%
Total tons of Sawdust Handled Total PM10 Emission tons per Year
0.0139 36000 0.022518
* 2X4X9 wood trim pieces are removed bundled and sold to finger-jointer company
<£)
Calculation of handling emission of PM 10 from shaker conveyer to hog in feed conveyer
From Montana DEQ - QP2589-02 Decl.pdf PagelS section A.8 PM10 emission is 1.39% of PM10 in sawdust
0.005/.36 1.39%
lbs/tonPM10 EF Total tons of Sawdust Handled Total PM10 Emission tons per Year
0.09 0.0139 36000 0.022518<32
Calculation of handling emission of PM10 from hog in feed conveyer to hog
From Montana DEQ - QP2589-02 Decl.pdf PagelS section A.8 PM10 emission is 1.39% of PM10 in sawdust
0.005/.36 1.39%
Ibs/ton PM10 EF Total tons of Sawdust Handled Total PM10 Emission tons per Year
0.09 0.0139 36000 0.022518
Emissions Calculation
Diesel and LPG Equipment
Cat 924F Loader with Diesel Engine \'A
Emissions Factor* HP Output**Hours of use per year Total lbs of emissions per year Tons of emissions per year
PM10 0.0022 129 600 170.28 0.09
NOx 0.031 129 600 2,399.40 1.20
CO 0.00668 129 600 517.03 0.26
SOx 0.00205 129 600 158.67 0.08
C02 1.15 129 600 89,010.00 44.51
*AP42 Table 3.3-1
(Ib/hp-hr)
(power out put)
** 60% of HP rating
Wood is lighter than
sand and gravel thus uses
less power
JCB 541-70 Forklift with Diesel Engine
Emissions Factor* HP Output**Hours of use per year Total lbs of emissions per year Tons of emissions per year
PM10 0.0022 126 600 166.32 0.08
NOx 0.031 126 600 2,343.60 1.17
CO 0.00668 126 600 505.01 0.25
SOx 0.00205 126 600 154.98 0.08
C02 1.15 126 600 86,940.00 43.47
*AP42 Table 3.3-1
(Ib/hp-hr)
(power out put)
** 60% of HP rating
Wood is lighter than
sand and gravel thus uses
less power
Allis Chalmers F40-24PS Forklift with LPG Engine
Calculations of MMBTU per year
Gallons of propane used per year BTU/gallon Total BTU/ year MMBTU/year
1500 91330 136995000
Emissions Factor*MMBTU/Year Total lbs of emissions per year Tons of emissions per year
PM10 0.0095 136.995 1.30145 0.00065
NOx 2.27 136.995 310.97865 0.15549
CO 3.51 136.995 480.85245 0.24043
SOx 0.000588 136.995 0.08055 0.00004
C02 110 136.995 15,069.45000 7.53473
136.995
*AP42 Table 3.2-3
(Ib/MMBTU)
The hog processes wood pieces into 1 inch minus chip. From Estimating Emissions from generation and combustion of "Waste" Wood
July 15, 1998 by Wood Waste and Furniture Emissions Task Force page 4 table milling (hog) is assumed to have 0% PM10
air from hog is piped to bag-house
Calculation of handling emission of PM10 from hog to loading trailers
From Montana DEQ - OP2589-02 Decl.pdf Page18 section A.8 PM10 emission is 1.39% of PM10 in sawdust
0.005/.36 1.39%
Ibs/ton PM 10 EF Total tons of Sawdust Flandled Total PM10 Emission tons per Year
0.09 0.0139 36000 0.022518
Calculation of handling emission of PM10 from loading trailers to sawdust belt
From Montana DEQ - OP2589-02 Decl.pdf PagelS section A.8 PM10 emission is 1.39% of PM10 in sawdust
0.005/.36 1.39%
Ibs/ton PM 10 EF Total tons of Sawdust Handled Total PM10 Emission tons per Year
0.09 0.0139 36000 0.022518
The transfer from sawdust belt to hammer mill in feed belt is covered. The air is piped from dust cover to bag-house.
The hammer mill processes wood pieces into 5/16 inch minus chip. From Estimating Emissions from generation and combustion of "Waste" Wood
July 15, 1998 by Wood Waste and Furniture Emissions Task Force page 4 table milling is assumed to have 0% PM10
air from hammer mill is piped to bag-house
Bag-house: the bag-house has sixteen (16) bag. The bags have a pore size of 0.5 microns. The bag-house is rated at 40,000 cfm.
From Oregon Department of Environmental Quality General Air Contaminant Discharge Permit Application Page 4
calculated the PM 10 emissions from the bag-house to be 0.036 tons per year.
EF Control Factor Tons of product per year Total PM10 Emission ton per year
0.001 (1-.995) 72,000 0.036
The pellet mill processes 5/16 inch minus wood pieces into 3/8 inch diameter pellet^From Estimating Emissions from generation and
combustion of "Waste" Wood July 15, 1998 by Wood Waste and Furniture Emissions Task Force page 4 table milling is assumed to have 0% PM10
* the pelleting process does not use any chemical binders. Pressure from screws forces wood chips into a narrowing tube causing the wood chip to heat,
the heat softens th^figdeSfend cellulose and the pressure forces the chip together as they are pushed through the dies.
>. The ligdens arta'cellulose hold the pellets together.
-5=^ /rjKiuv
The cooling tower cools the pellets form 200 degrees Farenheit to near ambient temperature.
A 9,500 cfm fan blows ambient outside air through the pellets to cool them and keep them from sweating.
It is assumed that 0% PM10 is emitted
When they are cooled they go through a screener to remove undersized pellets and pieces.
The undersized pellets and pieces are returned to the pellet mill and a reprocessed.
The quality pellets go to the bagger
It is assumed that 0% PM 10 is emitted
The bagger puts the peNgts into 40 pound bags and seals the bags.
The bag are placed on'pallets of 50 bags and put in storage until they are shipped.
Natural Gas Fired Burner for drum dryer.
A 12 MMBtu/hr Natural Gas Fire Burner is to be install to dry dead woody biomass from forests to make pellets.
Currently pellets are made from kiln dried wood waste for cabinet and truss manufacturers so no drying is needed.
However, future growth requires additional sources of raw materials to make pellets.
It is calculated that 50% of total production will need to be dried. This comes to 36,000 tons.
The temperature in the drum dryer about 375 degrees Fareneheit.
Calculation of emissions from the burner are as follows:
Assume average Btu content per standard cubic foot of NG is 1020 from AP42 Chapter 1.4.1
Assume the burner will operate 3,000 hour per year
Assume the burner uses 12 MMBtu/hr
Calculation of MMBtu per year
MMBtu/hr Total Hours Total MMBtu/yr
12 3,000 36000
Calculation cubic feet per MMBtu
Btu/MMBtu Btu/scf scf/MMBtu
1000000 1020 980.39
Calculation scf used per year
MMBtu/year scf/MMBtu 10A6 scf /yr
36000 980.39 35.29
Calculation of emissions from the burner are as follows:EF from table 1.4-1 and 1.4-2
EF lbs/10A6 10A6 scf/yr Tons of emission per year
NOx 100 35.29 1.76
CO 80 35.29 1.41
C02 120000 35.29 2,117.65
Lead 0.0005 35.29 0.00
PM Total 7.6 35.29 0.13
S02 0.6 35.29 0.01
TOC 11 35.29 0.19
Methane 2.3 35.29 0.04
VOC 5.5 35.29 0.10
Emissions Total Tons per Year
PM10 0.50
NOx 4.29
CO 2.16
SOx 0.17
C02 2,213.16
—
.
(6/1/2010) Maung Maung - White Flame conveyor information Page 1
From:
To:
Date:
Subject:
"Gil Miller" <[e-mail]>
'"Maung Maung"' <[e-mail]>
6/1/2010 9:20 AM
White Flame conveyor information
Dear Mr. Maung,
The conveyor information you requested follows.
Conveyor 1
Is the Shaker Conveyor on the diagram. It is a Model FSCB-30.
Conveyor 2
Is the Hog Discharge Conveyor on the diagram. It is a Redline 60 foot
conveyor. It does not have a model number.
Conveyor 3
Is the Drag conveyor on the diagram. It moves the pellets from the mills to
the cooling tower. It is a EF Mueller RB9A.
If you need anything else let me know.
Thanks for your help.
Gil Miller
Lucia Mason <[e-mail]>
Periodic Permit Updates (UT Division of Air Quality), 14301: White Flame, Inc.- Lindon Wood Pellet
Manufacturing Plant
5 messages
Lucia Mason <[e-mail]>Tue, Oct 29, 2024 at 12:52 PM
To: "[e-mail]" <[e-mail]>
Hi Karl,
The Division of Air Quality is conducting a 10-year review of the Approval Order associated with White Flame Inc.'s Lindon Wood Pellet Manufacturing Plant (site
14301). Please provide the following contact information for the site:
1. Site: physical address, phone number, and email (if applicable)
2. Company: physical address, billing address, phone number, fax number (if applicable) and email
3. Environmental contact: physical address, mailing address, phone number, fax number (if applicable) and email
4. Billing contact: (if different from environmental contact): physical address, phone number, fax number (if applicable) and email
5. Name on Approval Order: (if different from environmental contact): physical address, mailing address, phone number, fax number (if applicable) and
email
Please reach out with any questions. You can reach me by email or by phone at [phone].
Thanks,
Lucia
Lucia Mason <[e-mail]>Fri, Nov 22, 2024 at 2:46 PM
To: "[e-mail]" <[e-mail]>
Hi Karl,
As per our phone conversation today I'm replying to my earlier email.
On the phone you talked about submitting an application to modify the operating hours of some equipment permitted in your current AO. You're welcome to reach
out with questions regarding your application or the application processes. You can contact me by email or by phone at [phone].
Alternatively, you're welcome to schedule a pre-NOI meeting to discuss your application further. You can do so at the following link: https://utconcierge.
qualtrics.com/jfe/form/SV_dopwfGzXwNaCjhc
I'm going to pause the 10-year review project addressed in my first email while you work through your modification application.
Let me know if you have any questions.
3/13/25, 1:35 PM State of Utah Mail - Periodic Permit Updates (UT Division of Air Quality), 14301: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r4635717358917320147&simpl=msg-a:r-4651030765112348483&simpl=msg-a:r-2748356016259745140&sim…1/3
Best,
Lucia
[Quoted text hidden]
Lucia Mason <[e-mail]>Fri, Dec 27, 2024 at 1:36 PM
To: "[e-mail]" <[e-mail]>
Hi Karl,
Let me know if you have any updates on the status of this AO.
Happy holidays!
Lucia
[Quoted text hidden]
Lucia Mason <[e-mail]>Thu, Jan 30, 2025 at 1:11 PM
To: "[e-mail]" <[e-mail]>
3/13/25, 1:35 PM State of Utah Mail - Periodic Permit Updates (UT Division of Air Quality), 14301: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r4635717358917320147&simpl=msg-a:r-4651030765112348483&simpl=msg-a:r-2748356016259745140&sim…2/3
Hi Karl,
Please read through the list of items we talked about on the phone earlier today and confirm that you approve of the following actions regarding your permit:
1. I'll plan on leaving the front-end loader (Equipment ID II.A.5) and forklifts (II.A.6) listed on your current permit for informational purposes only. However, I will
remove the condition limiting the equipment's operational hours to 600 hours per year (II.B.1.b.E) as it is not standard for the DAQ to permit mobile
equipment.
2. The drum dryer is onsite but not connected to natural gas. I'll keep it on your permit in the event that White Flame chooses to install it.
3. There is no propane usage at the facility. I'll remove condition II.B.1b.D which limits propane usage.
4. Not all of the three conveyors listed in equipment ID II.A.7 are not in use but all will remain on the permit in case White Flame chooses to reconfigure
operations.
Additionally, as part of the 10-year review process the DAQ will need the following updated contact information:
1. Site: physical address, site coordinates, phone number, and email (if applicable)
2. Company: physical address, billing address, phone number, and email
3. Environmental contact: name, physical address, mailing address, phone number, and email
4. Billing contact: (if different from environmental contact): name, physical address, phone number, and email
Please reach out with any questions. You can reach me by email or by phone at [phone].
Best,
Lucia
[Quoted text hidden]
white flame <[e-mail]>Tue, Mar 11, 2025 at 10:03 AM
To: Lucia Mason <[e-mail]>
Site: 125 S 1800 W Lindon Utah 84042 Coordinates: 86PV+66P Phone Number 801 765-1151
Contact: Karl Kunz 801 765 1151
Billing Address: 125 S 1800 W Lindon UT 84042
[Quoted text hidden]
3/13/25, 1:35 PM State of Utah Mail - Periodic Permit Updates (UT Division of Air Quality), 14301: White Flame, Inc.- Lindon Wood Pellet Manufacturing Plant
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r4635717358917320147&simpl=msg-a:r-4651030765112348483&simpl=msg-a:r-2748356016259745140&sim…3/3