DAQ-2025-002516

Pitman Farms, Utah Division PO Box 308 Moroni, UT 84646 www.norbest.com
Pitman Farms, Utah Division
P.O. Box 308
350 South 300 West
Moroni, Utah 84646
Telephone: [phone]
Fax: [phone]
May 20, 2025
To: Chad Gilgen
Manager
Minor Source Compliance Section
Utah Department of Air Quality
195 North 1950 West
Salt Lake City, Utah 84114-4820
Re: Compliance Advisory Letter received on 5/20/2025
This letter is provided in response to the compliance advisory letter received on 5/20/2025, following a permit
review inspection conducted on 3/20/2025. The advisory letter states potential violations of conditions II.B.2.a
and II.B.3.a of our approval order, DAQE-AN159570002-22. Our response to the stated potential violations is
as follows:
1.“…the 29.3 MMBtu/hr boiler was operated for 5,287 hours between March 2024 and February 2025.”
Following the March compliance inspection, as we were gathering data on the hours of use to provide to
the inspector, we found that we had exceeded the hours for the boiler between March 2024 and February
2025. Upon understanding of the exceedance, we immediately investigated and found two issues which
lead to the exceedance.
First, miscommunication occurred between our boiler / maintenance staff which led them to
misunderstand that our three small boilers were to be operated at a 4,000 hour a year limit or less. That
misunderstanding has been corrected.
Second, we have had functionality issues with our large Indeck (51 MMBtu/hr) boiler which has
required it to be operated at a lesser rate while assessment, repairs and work has been performed on it
and which ultimately has led to its discontinued use. This review has determined that to return the boiler
to proper functionality will require significant time and resources which we are unable to perform at this
time. Therefore, we have determined to discontinue use of the boiler until such time as we can complete
the repairs and work necessary (this discontinuation of use will also delay permit required stacking
testing, which was noted in a letter to the state on 4/15/2025). We anticipate this boiler being out of
operation until at least November of this year, if not longer.
While this boiler is unused it will be necessary to use the other three boilers (including the 29.3
MMBtu/hr boiler) at a higher rate than normal. To help alleviate the loss of use of the Indeck boiler, and
minimize the need for increased use of the other three boilers, we are in the process of obtaining another
boiler which will be an 800 HP 30 ppm Nox (26.78 MMBTU/hr) unit. Our plan is to remove the Indeck
boiler from our permit and replace it with this new boiler as allowed by R307-401-12. We anticipate
REVIEWED
Initials: DDR Date: 20/May/2025
Compliance Status: CA ResponseFile#: 15957 (B1)

Pitman Farms, Utah Division PO Box 308 Moroni, UT 84646 www.norbest.com

this new boiler being installed and in operation within the next two months, at which time we will seek
modification of the permit.

Once we can make the repairs needed to the Indeck boiler, we would then look to modify / update our
permit again, adding back the Indeck boiler and looking to remove one or more of the older boilers.

Finally, once we found the hours exceedance, we also reviewed each boiler against the NOx emissions
limits of the permit (with our environmental contractor), to assess compliance. Per our calculations we
maintained compliance with the emissions limits at 13.01 versus the permit limit of 15.92.

2. “The pressure drop monitoring equipment for the feather and meat mill baghouse was not calibrated in
the past twelve months. Pressure readings provided indicated that the baghouse operated at times
outside of the permitted range between 2.0 and 6.0 inches of water column.”

Following the March compliance inspection, as we were gathering data for the pressure readings, we
found that the monitoring equipment had not been calibrated within the past year as well as some
operational times outside of the permit (2.0 and 6.0) range.

We immediately met with the individual charged with calibrating the unit and found that he did not have
the current equipment needed to perform the calibration. The equipment needed for the calibration was
purchased and the calibration was performed in April (2025).

To ensure proper operation, including calibration, of the equipment moving forward, review of the
associated equipment and readings will be accomplished at least monthly with any issues found
promptly addressed.

If you have any other additional questions or concerns, please let us know.

Sincerely,

Luke Freeman
Safety and Quality Assurance Director
Pitman Farms, Utah