DAQ-2025-004207

DAQE-AN106440006-25

{{$d1 }}

Luke Freeman
Pitman Farms
1075 North Avenue
Sanger, CA 93657
[e-mail]

Dear Mr. Freeman:

Re: Approval Order: Modification to the Approval Order DAQE-AN106440005-23 to Add a
Pelletizer and Increase Production
Project Number: N106440006

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on February
10, 2025. Pitman Farms must comply with the requirements of this AO, all applicable state requirements
(R307), and Federal Standards.

The project engineer for this action is Tad Anderson, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as
the DAQE number shown on the upper right-hand corner of this letter. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:TA:jg

cc: Central Utah 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

August 15, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN106440006-25
Modification to the Approval Order DAQE-AN106440005-23 to
Add a Pelletizer and Increase Production

Prepared By
Tad Anderson, Engineer
[phone]
[e-mail]

Issued to
Pitman Farms - Moroni Feed Mill

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

August 15, 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 ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 9

DAQE-AN106440006-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Pitman Farms Pitman Farms - Moroni Feed Mill

Mailing Address Physical Address
1075 North Avenue 15 East 1900 South Feed Mill Road
Sanger, CA 93657 Moroni, UT 84646

Source Contact UTM Coordinates
Name: Mike Vance 449,940 m Easting
Phone: [phone],372,543 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2048 (Prepared Feed & Feed Ingredients for Animals & Fowls, Except Dogs & Cats)

SOURCE INFORMATION
General Description
Pitman Farms (Pitman) operates the Moroni Feed Mill. The feed mill operates to support local turkey
farms. The Moroni Feed Mill takes in raw materials from truck deliveries, such as corn, soybeans, grains,
oils, poultry and meat meal, and feed supplements. These materials are offloaded via belly dump trucks
into underground storage hoppers or at a bulk material storage shed. The material is then conveyed via
belts and augers to an appropriate silo storage bin or sent to processing equipment. Processing includes
grinding dry grain and mixing it with oils and feed supplements to produce the desired product feed.
Ground and mixed materials are also processed into pellets using steam from a natural gas-fired boiler.
Finished products are stored in bins before being loaded into trucks for hauling to various animal and
poultry feed operations.

NSR Classification
Minor Modification at Minor Source

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

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-AN106440006-25
Page 4

Project Description
Pitman has requested a modification to AO DAQE-AN106440005-23 to add an additional pellet mill (one
30-TPH) controlled by a cyclone and transition feed production to pelletized feed. With the addition of
the new pellet mill, the limit of grains processed through the pelletizer will increase (20,800 tons to
159,250 tons of grains processed through the pelletizers per 12 months).

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 8717.00
Carbon Monoxide 0 6.14
Nitrogen Oxides 0 5.33
Particulate Matter - PM10 22.60 32.38
Particulate Matter - PM2.5 0 0.89
Sulfur Dioxide 0 0.10
Volatile Organic Compounds 0 0.43

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 0 200
Generic HAPs (CAS #GHAPS) 0 4
Hexane (CAS #110543) 0 260
Change (TPY) Total (TPY)
Total HAPs 0 0.23

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two years. [R307-401-8]
DAQE-AN106440006-25
Page 5

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Moroni Feed Mill
II.A.2 One Boiler Fuel: Natural Gas Rating: 8.4 MMBtu/hr Control: Low- NOx (<30 ppm) II.A.3 One Boiler Fuel: Natural Gas Rating: 8.4 MMBtu/hr
II.A.4 One Emergency Generator Capacity: 245 hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.5 One Roller Mill
II.A.6 Two Pellet Mills (NEW) PM1 (NEW) Rating: 30-TPH Pellet Mill Control: Cyclone PM2 Rating: 5-TPH Pellet Mill Control: Cyclone II.A.7 Various Storage Silos All Controlled by Bin Vents located at the top of silos

DAQE-AN106440006-25
Page 6

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a Visible emissions from the following emission points shall not exceed the following values:

A. Natural gas boilers - 10% opacity

B. Diesel Generator - 20% opacity

C. All silo emission points - 10% opacity

D. All drop points - 20% opacity

E. Cyclones - 10% opacity.

[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3]
II.B.1.b The following operation and production limits shall not be exceeded:

A. 250,000 tons of received grains per rolling 12-month period

B. 150,000 tons of shipped grains per rolling 12-month period

C. 150,000 tons of grains processed through the roller mill per rolling 12-month period

D. 159,250 tons of grains processed through the Pellet Mills per rolling 12-month period.

[R307-401-8]

II.B.1.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the last day of each month using data from the previous 12 months. Records of production shall be kept for all periods when the plant is in operation. Production shall be determined by scale house records, vendor receipts, or operational logs. The records of production shall be kept on a daily basis. [R307-401-8]
II.B.2 Boiler Requirements
II.B.2.a The owner/operator shall only utilize natural gas as fuel in the boiler. [R307-401-8]
II.B.3 Emergency Generator Requirements
II.B.3.a The owner/operator shall not operate the emergency generator engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
DAQE-AN106440006-25
Page 7

II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the last day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.3.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.3.b The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel oil additives) as a fuel source for the emergency engine on site. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD) and contain no more than 15 ppm sulfur. [R307-401-8]
II.B.3.b.1 To demonstrate compliance with the diesel fuel requirements, the owner/operator shall keep and
maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content
from the fuel supplier. [R307-401-8]

II.B.4 Haul Road and Fugitive Dust Requirements II.B.4.a Visible Emissions from the haul roads and other operational areas shall not exceed 20% opacity.
[R307-401-8]

II.B.4.a.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-401-8] II.B.4.b For paved and unpaved roads, the owner/operator shall spray with water all applicable haul roads
and operational areas on site to maintain the opacity limits listed in this AO. If the temperature is
below freezing, the owner/operator may stop spraying the haul roads with water. [R307-401-8]
II.B.4.b.1 For haul roads, records of water spraying shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of water applied C. Rainfall amount received, if any D. Records of temperature, if the temperature is below freezing. [R307-401-8]

PERMIT HISTORY

DAQE-AN106440006-25
Page 8

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN106440005-23 dated March 10, 2023 Is Derived From NOI dated February 10, 2025

DAQE-AN106440006-25
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

Sanpete Messenger
Publication Name:
Sanpete Messenger
Publication URL:
Publication City and State:
Manti, UT
Publication County:
Sanpete
Notice Popular Keyword Category:
Notice Keywords:
pitman
Notice Authentication Number:
202506261017398114268
2273419277
Notice URL:
Back
Notice Publish Date:
Thursday, June 26, 2025
Notice Content
A Notice of lntent for the following project submitted in accordance with R307-401-l, Utah Administrative Code (UAC), has been received for
consideration by the Director:
Company Name: Pitman Farms
Location: Pitman Farms - Moroni Feed Mill -
15 East 1900 South Feed Mill Road, Moroni, UT
Project Description:
Pitman Farms (Pitman) operates the Moroni Feed Mill in Sanpete County. The feed mill operates to support local turkey farms. The Moroni
Feed Mill takes in raw materials from truck deliveries such as com, soybeans, grains, oils, poultry and meat meal, and feed supplements. A
natural gas-fired boiler is operated to process products. Processing includes grinding dry grain and mixing it with oils and feed supplements
to produce the desired product feed. Pitman has requested a modification to Approval Order DAQE-ANJ 06440004-23 to add a new pellet mill
and increase production. The proposed change will result in an increase in PM10 emissions.
The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air
quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period.
The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same
address on or before July 26, 2025, will be considered in making the final decision on the approval/disapproval of the proposed project. Email
comments will also be accepted at [e-mail].
If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-
401-7, UAC.
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Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory
proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the
Director to fully consider the substance
and significance of the issue. Date of Notice: June 26, 2025
Published in the Sanpete Messenger June 26, 2025
Back
6/26/25, 9:17 AM utahlegals.com/(S(gvt1atrdwlgy44luocenjns0))/DetailsPrint.aspx?SID=gvt1atrdwlgy44luocenjns0&ID=215417
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DAQE-

RN106440006 December 28, 2023 Luke Freeman
Pitman Farms 1075 North Avenue Sanger, CA 93657
[e-mail] Dear Luke Freeman,
Re: Engineer Review: Modification to the Approval Order DAQE-AN106440005-23 to increase pelletizer use Project Number: N106440006 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Pitman Farms should complete this review within 10 business days of receipt. Pitman Farms should contact Sarah Foran at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Sarah Foran at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Pitman Farms does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Pitman Farms has concerns that cannot be resolved and the project
becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________
(Signature & Date)
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N106440006 Owner Name Pitman Farms Mailing Address 1075 North Avenue
Sanger, CA, 93657 Source Name Pitman Farms - Moroni Feed Mill
Source Location 15 East 1900 South Feed Mill Road Moroni, UT 84646
UTM Projection 449,940 m Easting, 4,372,543 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2048 (Prepared Feed & Feed Ingredients for Animals & Fowls, Except Dogs & Cats) Source Contact Mike Vance Phone Number [phone] Email [e-mail] Billing Contact Luke Freeman
Phone Number [phone] Email [e-mail]
Project Engineer Sarah Foran, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 30, 2023 Date of Accepted Application No date entered

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 2
SOURCE DESCRIPTION General Description
Pitman Farms (Pitman) operates the Moroni Feed Mill. The feed mill operates to support local turkey farms. The Moroni Feed Mill takes in raw materials from truck deliveries such as corn, soybeans, grains, oils, poultry and meat meal, and feed supplements. These materials are
offloaded via belly dump trucks into underground storage hoppers or at a bulk material storage shed. The material is then conveyed via belts and augers to an appropriate silo storage bin or sent to processing equipment. Processing includes grinding dry grain and mixing with oils and feed supplements to produce the desired product feed. Ground and mixed materials are also processed into pellets using steam from a natural gas-fired boiler. Finished products are stored in bins before being loaded into trucks for hauling to various animal and poultry feed operations. NSR Classification: Minor Modification at Minor Source Source Classification
Located in Attainment Area, Sanpete County Airs Source Size: B
Applicable Federal Standards
Project Proposal Modification to the Approval Order DAQE-AN106440005-23 to increase pelletizer use
Project Description Pitman has requested a modification to AO DAQE-AN106440004-23 to add a two additional pellet mills, one 30-TPH and one 20-TPH manufacturer rating mill for a total of three mills. Both new pellet mills be controlled by cyclones. There will be no additional grain received onsite. However, an increased amount of pellets will be generated and shipped. Condition II.B.1.b will be updated to reflect a 50,000 ton per year increase in grains processed through the roller mill and grain shipped. The new pellet mills will allow for 100% of grains received to be pelletized. This will increase Pellet Mill processing to 250,000 tons per year.
EMISSION IMPACT ANALYSIS sent for evaluation [Last updated December 28, 2023]

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 3
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY)
Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Change (TPY) Total (TPY)
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 4
Review of BACT for New/Modified Emission Units BACT review regarding New Pellet Mills
NOT COMPLETED! [Last updated December 28, 2023]

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):
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
emissions covered by this AO must be reviewed and approved. [R307-401-1]
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]
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]
[R307-107]
150]

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 5
to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
II.A.1
II.A.2 Fuel: Natural Gas Rating: 8.4 MMBtu/hr Control: Low- NOx (<30 ppm)
One Boiler Fuel: Natural Gas Rating: 8.4 MMBtu/hr
One Emergency Generator Capacity: 245 hp Fuel: Diesel MACT Applicability: Subpart ZZZZ
One Roller Mill
Three Pellet Mills PM1 (NEW) Rating: 30-TPH Pellet Mill Control: Cyclone PM2 Rating: 5-TPH Pellet Mill Control: Cyclone
PM3 (NEW)
Rating: 20-TPH Pellet Mill Control: Cyclone
Various Storage Silos

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 6
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.1
II.B.1.a Visible emissions from the following emission points shall not exceed the following values:
A. Natural gas boilers - 10% opacity B. Diesel Generator - 20% opacity C. All silo emission points - 10% opacity D. All drop points - 20% opacity E. Cyclone - 10% opacity
[R307-401-8]
CFR 60, Appendix A, Method 9. [R307-201-3]
NEW A. 250,000 tons of received grains per rolling 12-month period B. 200,000 tons of shipped grains per rolling 12-month period C. 200,000 tons of grains processed through the roller mill per rolling 12-month period D. 250,000 tons of grains processed through the Pellet Mills per rolling 12-month period [R307-401-8]
new 12-month total by the last day of each month using data from the previous 12 months. Records of production shall be kept for all periods when the plant is in operation. Production shall be determined by scale house records, vendor receipts, or operational logs. The records of production shall be kept on a daily basis. [R307-401-8]
Boiler Requirements
Emergency Generator Requirements
100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 7
new 12-month total by the last day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall
include the following:
1. The date the emergency engine was used
2. The duration of operation in hours
3. The reason for the emergency engine usage [40 CFR 63 Subpart ZZZZ, R307-401-8]
meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]
fuel source for the emergency engine on site. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm sulfur. [R307-401-8]
and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur
content from the fuel supplier. [R307-401-8]
Haul Road and Fugitive Dust Requirements
opacity. [R307-401-8]
equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-401-8]
roads and operational areas on site to maintain the opacity limits listed in this AO. If the temperature is below freezing, the owner/operator may stop spraying the haul roads with water. [R307-401-8]

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 8
operation. The records shall include the following items: A. Date and time treatments were made B. Number of treatments made and quantity of water applied
C. Rainfall amount received, if any
D. Records of temperature, if the temperature is below freezing.
[R307-401-8]

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 9
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

REVIEWER COMMENTS

2. Pellet Mills: Emissions were based on the PM EF (0.2095 lb/ton) from AP-42 Table 9.9.1-2 Particulate Emission Factors for Grain Processing Facilities with a Cyclone. 50% of PM filterable and condensible emissions were assumed to be PM10. Total throughput assumed was 250,000 tons per year. Roller Mill: Emissions were based on PM10 EF (0.0008 lb/ton) from AP-42 Table 9.9.1-2 Particulate Emission Factors for Grain Processing Facilities. Total throughput assumed was 200,000 tons per year.
Grain Shipping:
Emissions were based on the PM EF (0.024 lb/ton) from AP-42 Table 9.9.1-2 Particulate Emission Factors for Grain Processing Facilities with a Cyclone. 50% of PM emissions were assumed to be PM10. Total throughput assumed was 200,000 tons per year. [Last updated December 28, 2023]
Comment regarding Title V and Federal Subpart Applicability: There are no changes in federal applicability as a result of this modification. [Last updated December 28, 2023]

Engineer Review N106440006: Pitman Farms - Moroni Feed Mill December 28, 2023 Page 10
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:

DAQC-Cr106440001-23
Site ID 10644 (B1)
MEMORANDUM
TO: FILE - PITMAN FARMS -Moroni Feed Mill
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager C G
FROM: Jordan Garahana, Environmental Scientist }{
DATE: August 27,2023
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Sanpete County
INSPECTION DATE: May 25,2023
SOURCE LOCATION: 15 East 1900 South Feed Mill Road
Moroni,84646
DIRECTIONS: The feed mill is located at the large stack in Moroni.
SOURCE CONTACTS: Luke Freeman, Technical Services Director
435 436-821 I [e-mail]
OPERATING STATUS: Operating normally at the time of inspection.
PROCESS DESCRIPTION: The Moroni Feed Mill takes in raw materials from truck
deliveries such as corr, soybeans, grains, oils, poultry and meat
meal, and feed supplements. These materials are offloaded via
dump trucks into underground storage hoppers or at a bulk
material storage shed. The material is then conveyed via belts
and augers to an appropriate silo storage bin or sent to
processing equipment. Processing includes grinding dry grain
and mixipg with oils and feed supplements to produce the
desired product feed. Ground and mixed materials are also
processed into pellets using steam supplied from a natural gas-
fired boiler. Finished products are stored in bins before being
loaded into trucks for hauling to various animal and poultry feed
operations.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN106440005-23, dated March
10,2023
MACT (Part 63) - ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating lnternal
Combustion Engines
DAQ-2023-006747
SOURCE EVALUATION:
Name of Permittee:
Pitman Farms - Moroni Feed Mill
1075 North Avenue
Sanger, C493657
SIC Code:
Permitted Location:
15 East 1900 South Feed Mill Road
Moroni, 84646
2048: (Prepared Feed and Feed Ingredients for Animals and
Fowls, Except Dogs and Cats)
Section I: GENERAL PROYISIONS
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]
The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
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-l]
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]
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]
The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifuing the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]
Status: Out of Compliance. Source is out of compliance with I.2 and I.3 as they have been
operating a second, large pelletizer that is not on the approved equipment list. The usage of
the unapproved pelletizer put them over their allowed production limits for grains to be
processed through the pelletizer. The source was issued a CA and an ESA for the operation
of the unapproved second, larger pelletizer. See DAQC-60G23 and DAQC-758-23 for
additional information. Source sent initial notification within the l8-month period. No
emission inventory is required at this site.
I.1
r.2
r.3
r.4
I.5
1.6
t.7
L8
II.A
II.A.1
II.A.2
TI.A.3
II.A.4
II.A.5
II.A.6
II.A.7
^; 4 ltl !.
Section II: SPECIAL PROVISIONS
The approved installations shall consist of the following equipment:
Moroni Feed Mill
One Boiler (NE\D
Fuel: Natural Gas
Rating: 8.4 MMBtu/tr
Control: Low-NO* (<30 ppm)
One Boiler
Fuel: Natural Gas
Rating: 8.4 MMBtU/hr
One Emergency Generator
Capacity: 245hp
Fuel: Diesel
MACT Applicability: Subpart ZZZZ
One Roller Mill
One Pelletizer
Controlled by Cyclone
Various Storage Silos
All Controlled by Bin Vents located at the top of silos
Status: Out of Compliance. The source was operating a second_, larger unapproved
pelletizer at the timG of inspection. A CA and ESA was issued for the unapproved
iquipment and the exceeda-nce of their production timits_. The source has initiated the
Nbl^process to receive a new AO that cbvers the new pelletizer. See DAQC-606-23 and
DAQC-758 -23 for additional information.
II.B Reqqirements and Limitations
Site Wide Requirements
Visible emissions from the following emission points shall not exceed the following values:
A. Natural gas boilers - l0% opacity
B. Diesel Generator -20% opacitY
C. All silo emission points - l0% opacity
D. A11 drop points - 20% opacity
E. Cyclone - I0% opacity
1R307-401-81
Opacity observations of emissions from statioqary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3]
Status: In Compliance. No visible emissions were observed.
II.B.1
II.B.1.a
II.B.1.a.1
II.B.1.b
II.B.1.b.l
II.B.2
ll.B.2.a
II.B.3
II.B.3.a
ILB.3.a.l
The following operation and production limits shall not be exceeded:
A. 250,000 tons of received grains per rolling 12-month period
B. 150,000 tons of shipped grains per rolling 12-month period
C. I 50,000 tons of grains processed through the roller mill per rolling l2-month period
D. 20,800 tons of grains processed through the pelletizer per rolling 12-month period
1R307-401-81
T-o determine compliance with a rolling l2-month total the owner/operator shall calculate a'newl2-month total by the last day of each month using data from the previous 12 months. Records of
production shall be kept for all periods when the plant is in operatlon. Production shall be
dete_rmined !y qc.ale house records, vendor receipts, or operafional logs. The records of
production shall be kept on a daily basis. [R307-401-8] -
Status: Out of_Compliance. The rolling l2-month production rates from l lay 2022,to May2023, are as follows:
A. 96,831.71 tons of grains received
B. ll1,861.22tons of grains shipped
C. 107,502 tons of grains processed through the roller mill
D,92,780 tons of grains processed through the pelletizer
The source operated a second, large pelletizer thatwas not permitted. In the smaller,permitted pelletizer the source processed 25r73A tons of grain through the pelletizer, which
is over the allowed rolling l2-month timit. The second, lirger unapproved lleiletizerprocessed 671050 tons of grain during that same timeframe. A Compliance Advisory and an
Ea_rly Settleme-nt Agreement were issued to the source for the operation of the unafprovedpelletizer and for exceeding their approved limits in the AO. See DAQC-606-23 and-DAQC-758-23 for additional information.
Boiler Requirements
The owner/operator shall only utilize natural gas as fuel in the boiler. [R307-401-8]
status: In compliance. The source only utilizes natural gas in the boilers.
Emergency Generator Requirements
The owner/operator shall not operate the emergency generator engine on site for more than 100
hours-per rolling 12-month period during non-emeigency situations. There is no time limit on the
use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307401-8]
T-o determine compliance with a rolling l2-month total, the owner/operator shall calculate a newl2-month total by the last day of each month using data from the previous 12 months. Records
do.cumenting the operation of the emergency engine shall be keptin a log and shall include thefollowing:
l. The date the emergency engine was used
2. The duration of operation in hours
11.8.3.a.2
rr.B.3.b
rr.B.3.b. r
II.B.4
II.B.4.a
II.B.4.a.1
II.B.4.b
rI.B.4.b.l
3. The reason for the emergency engine usage
[40 CFR 63 Subpart ZZZZ, R307-401-8]
Status: In Compliance. The rolling l2-month emergency generator hours are as follows:
Less than 5 minutes. The source only runs the generator once per year according to Mr.
Freeman for maintenance and testing.
To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]
Status: In Compliance. There is a non-resettable meter installed on the generator.
The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel oil additives) as a fuel
source for the emergency engine on site. All diesel bumed shall meet the definition of ultra-low
sulfur diesel (ULSD), and contain no more than l5 ppm sulfur. [R307401-8]
To demonstrate compliance with the diesel fuel requirements the owner/operator shall keep and
maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel
meets the ULSD requirements, or the owner/operator shall obtain certification of sulfi.r content
from the fuel supplier. [R307-401-8]
Status: In Compliance. According to the fuel invoice from RelaDyne, the source uses #2
and #l ultra-low sulfur diesel fuel.
Haul Road and Fugitive Dust Requirements
Visible Emissions from the haul roads and other operational areas shall not exceed 20o/o opacity.
1R307-401-81
Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile
equipment in operational areas shall use procedures similar to Method 9. The normal requirement
for observations to be made at l5-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 l/2 vehicle length behind the vehicle and not less than ll2the height of the vehicle.
1R307-401-81
For paved and unpaved roads, the owner/operator shall spray with water all applicable haul roads
and operational areas on site to maintain the opacity limits listed in this AO. If the temperature is
below freezing, the owner/operator may stop spraying the haul roads with water. [R307-401-8]
For haul roads, records of water spraying shall be kept for all periods when the plant is in
operation. The records shall include the following items:
A. Date and time treatments were made
B. Number of treatments made and quantity of water applied
C. Rainfall amount received, if any
D. Records of temperature, if the temperature is below freezing.
1R307-401-81
Status: In Compliance. No visible emissions were observed from the haul road at the time
ofthe inspection. The haul roads are covered in gravel and are only utilized by the trucks
that are loading the grains to be sent to other facilities. The source indicated that water
trucks have not been needed as the visible emissions limit has never been exceeded. That
area is smaller and surrounded by buildings, so the trucks are not able to go speeds higher
than 10 MPH.
Section III: APPLICABLE FEDERAL REOUIR-EMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.
MACT (Part 63) - A: General Provisions
Status: Compliance with Subpart A is determined by compliance with applicable federal subparts.
In compliance with Subpart ZZZZ.
MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Status: In Compliance. Compliance with MACT 63 ZZZZ is satisfied by compliance with II.B.3 of this
AO. The generator is only run once annually for maintenance purposes.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
Emission Standards: Sulfrr Content of Fuels [R307-203]
Status: In Compliance. The source utilizes ULSD diesel fuel onsite.
Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]
Status: In Compliance. The source did not have fugitive dust emissions above the allowed limit
during the time of inspection. The source has not needed to utilize any water on any unpaved roads
onsite as they are not heavily trafficked. See condition II.B.4.b.1 for additional information.
National Emission Standards for Hazardous Air Pollutants [R307-214]
Status: In Compliance. Compliance with R307-214 is satisfied by compliance with Sections II.B.3 and
III of this AO.
EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Pitman Farms -
Moroni Feed Mill on the Approval Order (AO) DAQE-AN106440005-23, dated March 10,2023. efE)
are suppliedfor supplemental purposes only.
Criteria Pollutant PTE tons/yr
COz Equivalent 8717.00
Carbon Monoxide 6.t4
Nitrogen Oxides 5.33
Particulate Matter - PMro 9.78
Particulate Matter - PMz.s 0.89
Sulfur Dioxide 0.10
Volatile Organic Compounds 0.43
llazardous Air Pollutant PTE lbs/yr
Formaldehyde (CAS #50000)200
Generic HAPs (CAS #GHAPS)4
Hexane (CAS #l10543)260
PREVIOUS ENFORCEMENT
ACTIONS:
COMPLIANCE STATUS &
RECOMMENDATIONS:
HPV STATUS:
RECOMMENDATION FOR
NEXT INSPECTION:
NSR RECOMMENDATIONS:
ATTACHMENTS:
No enforcement actions within the past five years.
In regard to Approval Order (AO) DAQE-AN106440005-23,
dated March 10,2023: Out of compliance with conditions I.2,
I.3,II.A, and II.B.1.b-D of the AO. The source operated a second
unapproved, large pelletizer that exceeded their permitted
production limits. A Compliance Advisory was issued for the
exceedance of their production limits and the operation of
unapproved equipment. An Early Settlement Agreement was
issued and signed, with the source applying for a new AO to
include that new pelletizer. See DAQC-606-23, DAQC-758-23,
and DAQC-891-23 for additional information on the Compliance
Advisory, the Early Settlement Agreement and the Signed Early
Settlement Agreement.
In compliance with the rest of the conditions in the AO.
Not Applicable.
The source is in the process of obtaining a new AO that includes
this second, large pelletizer. Inspect after this new AO has been
finalized.
Applicable Supporting Documentation Included
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
EPA METHOD 9 - VISIBLE EMISSION OBSERVATION FORM
Page _ of _
'BSERVAT,N
DArE: 5l zS I L3
City/County: (Ko- rn; , 9.-,^ OLR-
Street address: lf Itd S'.-l'"Start time: il. (Jo Stop time: ll . I (
f,i.vJ>
Site rD: l0G
Equipment/Process: 5.llerr. ltnnaalqr
Control Equipment: ta.-- t-..v.rt - , CvC tonrua
Emission Point:
Sky Conditions: Clear [ ]
Precipitation: No I j Yes
Wind: Direction:
Ambient Temp: of
Height Relative to Observer:
Distance From Observer:
Partly
tl
Speed: mph
RH:-%
Cloudy []Overcast []
Condensed Water Vapor Present: No [ ] Yes [ ]
Attached[] Detached[]
Length of Condensed Water Vapor Plume:
Background:
Sketch process unit: indicate observer position relative to
source; indicate potential emission points and/or actual
emission points.
sun $ wind )
Observer Position x
Observer's Signature:
Emission Point with Plume C)_]
I have received a
SIGNATURE:
these observations:
sec 0 15 30 45
1 ,A
2 I
3 \'(-'o ' -l )J.l -)
4 Olrc Ver/
5
6
7
I
I
10
11
12
COMMENTS:
T .ff' )ocn'u*d-a-t-,,rn o( t\rJ'r^t ol
17'r^.n )1*.t
g,g.j.b+'')finu,^r< hr
i v\w,-I lrw 6/L' rr
lLB.4 .b.t ' rca,oJ of;,^b
Distrib: white-file; cana -inspector; pink-owner/operator
Title: 1!.f vtt rtl Qlun* ),rcr4,"^
GleaverBKDoks'
Business Proposal
Norbest - 25ohp Boiler - 9 PPM NOx
To: Mike Christensen
Pitman Farms
350 So 300 W
Moroni, UT 84646
From: Jason Hansen
Servco lndustrial Equipment, LLC
1580 S Pioneer Rd
Salt Lake City, UT 84104 United State
801 509-0918
i hansen@hol brookservco.com
I p,;.
Thursday, July 14,2022 GleaverBrooks'&
Dear Norbest,
Through a steadfast commitment to research, development, strategic acquisitions, and a focus on providing boiler room
solutions for more than 80 years, Cleaver-Brooks is the sole provider of integrated boiler, burner, and controls solutions.
With the #1 market share in North America, Cleaver-Brooks is the global leader in designing and manufacturing integrated
boiler room systems, and the Cleaver-Brooks brand is globally synonymous with the highest quality, best reliability, and
creative innovation in boiler room solutions. lndustry-leading proprietary burners, controls, components, and accessories
engineered by Cleaver-Brooks perform together seamlessly at peak energy and emissions efficiency.
Cleaver-Brooks offers the broadest range of integrated boiler room systems, subsystems, components and accessories in
the market, giving it a distinct competitive advantage as a complete solutions provider across commercial, industrial, and
institutional markets. A principal component of the Cleaver-Brooks strategy is to offer the most advanced and completely
integrated boiler room systems that satisfy diverse energy demands, high-efficiency performance, ultra-low emissions,
safety, reliability, and convenience from utilizing a single-source manufacturer.
From the Power of Total lntegration, Cleaver-Brooks offers boiler room systems including mission-critical subsystems
performing water treatment, heat recovery, exhaust management, integrated system controls, and maintained by a
worldwide dedicated sales and service representative network. All sales and service representatives employ trained
technicians to provide first-class routine maintenance and repair services in accordance with national, state/provincial,
and local codes and standards.
As a Cleaver-Brooks Representative Association (CBRA) member near you, Servco lndustrial Equipment, LLC has
produced this proposal from your system requirements and equipment specifications. At your convenience, please review
this proposal, and contact me regarding any questions or comments.
Sincerely,
Jason Hansen
Servco lndustrial Equipment, LLC
1580 S Pioneer Rd
Salt Lake City, UT 84104 United State
801 801-50918
i hanse n @ ho I brookservco.com
GteaverBroo*Di,System Requirements
Proposal Number: 06792429 / Proposal Date:0711422
Job Name: Norbest - 250hp Boiler Replacement / Project Name: Norbest-Moroni-Norbest 250 HP-----Eoiier
Application:Steam
Fuel Series:!atural Gas
Boiler caDaciw:250 HP
Desiqn Pressure:'t50tb sT
Operatinq Pressuret 125 osio
Safetv Valve Setpointr 1501b psiq
Gas NOx Emissions Leve!:3 oom
Oil NOx Emissions Level:NA
Gas GO Emissions Level:50 oom
Oil NOx Emissions Level:{A
Available Site Voltaqe:160/3/60
Available Site Gas Pressure:138.5 in. w.c.
Aooroximate Site Altitude:1500 ft. ASL
lnsurance Requirements:ISD-1 2011 (XL-Gao). FM
Page3/9
GhaverBroo*$h Quote Summary
Proposal Number: 06792429 / Proposal Date:07114122
Job Name: Norbest - 250hp Boiler Replacement / Project Name: Norbest-Moroni-Norbest 250 HP--Eoiler
#1 Firetube Boiler Model: CBLE-4W
Project Market: United States
Boiler Capacity (Output) at 4500 ft: 250HP
Gas (NOx) Emissions Level: 9 ppm
Oil (NOx) Emissions Level: NA
Application Environment: lndoor - Typical Boiler Room
Project NEMA Rating (Panels Only): NEMA 12
Fuel: Natural Gas
Customer Site Gas Pressure: 138.5 in. w.c. (5 psig)
Design Pressure: 1501b ST
Operating Pressure: 125 psig
Voltage: 46013160
Control and Entrance Panel Configuration: Centre
lnsurance Requirement: CSD-I
lnsurance Requirement: FM
Package Boiler UL Requirements: UL
Confiquration Check: Standard Selections
#2 1 Product Pricing Basis: June22 Price Book in use based on 0G11312022 effective date for this product confrguration. (12579
exchange rate in effect for USD/CAD conversions.) Pricino valid for 30 davs. Exoiration: 711312022.
#3 1 Steel surcharge
#4 1 Burner Model: lntegral
Burner Output Capacity: 250 HP
Altitude: 450ffi
#5 I Blower Motor: 30 HP TEFC (460/3/60) with VSD Motor Starter
#6 1 Primary Gas Train for Natural Gas:
Nema Rating: NEMA 1; Piping Material: Carbon Steel
Primary Gas Train Mounting Location: Left Side
Customer Site Gas Pressure: 138.5 in. w.c. (5 psig)
Components from Customer Connection to Burner:
Vlanual Valve #1: 1.25in Butterball
Safety Shutoff Valves: Siemens Dual Motorized with 't POC
SSOV Double Valve: 1.25in
Manual Valve #2: 2in Butterball
3utterfly Valve: 3in
Sustomer Connection: 1.25in
#7 1 atura! Gas Pilot Train
#8 afety Valve #1: 2in HPS
#9 1 afety Valve #2: I ll2inHPS
#'to 1 itack Connection: 20in Flanqed
#1'l 1 Steam Nozzle Connection: 6in Flanoed 3001b. R.F.
#12 1 Feedwater Connection: 2in NPT
#13 2 Blowdown Connection: 1.Sin NPT (Bottom)
#14 1 Surface Blowoff Connection: 1in NPT Too Mounted
#'15 1 Chemical Feed Connection Tvoe: 1in NPT
#16 1 Seismic Design - Seismic Design Code: IBC 2018
Formal Calculations:
Calculation lnfo.: Zip Code: 84646, Site Class: D (Soil Analysis Not Available), Ss: .627, Fa: 1.2, ap: 1.0 For Boilers, lp: 1 (All other
Facilities), Equip. heiqht z: 0. Roof heioht h: 15. SDS: 0.502
#17 1 Seismic Design Construction
#18 2 Quick Blowdown Valve: 1.5in NPT Class 200 (Factorv Piped)
#19 Slow Blowdown Valve: Single Seat 1.5in NPT Class 200 (Factory Piped)
#20 3lowdown Valve(s) Pipins: 2 Quick / 1 Slow 1.Sin (Location: Riqht)
#21 1 =eedwater Globe Valve: 1.Sin (Factorv Pioed)
#22 1 :eedwater Check Valve: 1.Sin (Factory Piped)
#23 1 :eedwater Valve(s) Pipinq: Globe Check 1.Sinin (Location: Left)
Page4/9
GleaverBroo*$F Quote Summary
Proposal Number: 06792429 / Proposal Date:07114122
Job Name: Norbest - 250hp Boiler Replacement / Project Name: Norbest-Moroni-Norbest 250 HP
Eoiler
#24 1 Steam Valve ArranEement:
Steam Valve Arrangement: Anangement 5
Steam Valves: One Non-Return & One Stop Valve
Non Return Valve: Ship Loose Davis Angle 3inin Flanged 2501b. R.F.
Steam Piping Options: Spool Between Nozzle and First Valve, Expansion Spool
Steam Spool Piece 1: 6in x 3in x 36in
Non-Return Valve: 3in Davis Angle Flanged 2501b. R.F. (Ship Loose
Valve Min Flow:4329 pph
Boiler Min Flow: 866 pph
Pressure Drop: 8.32 psi (Ship Loose)
WARNING: 3in valve selection may chatter at boiler minimum flow. Make sure to review operating conditions, boiler turndown,
and valve selection carefully for proper operation.
Steam Stop Valve: 6in Flanged 3001b. R.F. (Ship Loose)
Steam Spool Piece 2: 3in x 6in x 12.875in
Free Blow Drain Valve Mounted on Expansion Spool: 0.5in NPT (Factory Piped)
#25 1 Surface Blowoff
#26 1 Surface Blowoff Manual Stoo Valve: 0.75in NPT (Factorv Piped)
#27 Samole Cooler - Water Samole. Factorv Pioed (250 osiq ratino)
#28 1 Secondarv Hvdrostatic Test
#29 1 Vain Low Water Cut-Off: McD-M 193 Automatic Reset On/Off Float with Carbon Steel Piping (Nema 1
#30 1 V'lain Low Water Column Ball Check Gauqe Cocks
#31 1 \uxillarv Low Water Cut-Off: MCDM1575 Manual Reset On/Off External Probe with Carbon Steel (Nema 1)
#32 1 Stack Thermometer: 5in Dial
#33 1 Pressure Gauoe: 6in Dial
#34 1 Primarv Gas Train Hioh Gas Pressure Switch (Standard Switches)
#35 1 Primarv Gas Train Low Gas Pressure Switch (Standard Switches)
#36 1 Primary Gas Train Valve Plusqed Leakage Test Cock(s): 0.25in (Standard)
#37 1 Pilot Gas Train Natural Gas Gas Pressure Requlator: Maxitrol 325-3
#38 1 Pilot Gas Train Manual Shutoff Cock (Standard)
#39 1 Pilot Gas Train Solenoid Valve (Standard)
#40 1 Pilot Gas Train Reoulator Outlet Pressure Gauoe: 2.Sin (Standard)
#41 1 Parallel Positionino Primarv Fuel Actuator
#42 1 Parallel Positionino Air Actuator
#43 Parallel Positionino FGR Actuator
#44 1 Modulatino Control: Transmitter (Pressure)
#45 Ooeratino Pressure Limit Control
#46 1 Hioh Limit Control: Steam
#47 1 f,ressure Control Pipinq and Fittinqs: 0.75in Carbon Steel
#48 1 f,2 Trim Svstem: Cleaver Brooks
M9 1 lawk VSD Blower Motor Control
#50 1 3AS Svstem: BACnet l/P (ProtoNode / No Talk with MasterPanel)
#51 3AS Svstem Communication RC Panel
#52 1 )rometha loT Gatewav to be Provided in Master or PT Panel
#53 1 \dd 8-Port Ethernet Switch
#54 1 -lawk1000 Packaoe Boiler Panel Ethernet Hub: 5 Port
#55 1 3AS Svstem RC Panel Ethernet Hub: 5 Port
#56 1 3ombustion Safeouard Control: CB780EUV
#57 1 Remote Emeroencv Shutoff: Terminals Onlv
#58 1 Additional Analoo lnouts: 4 Additional (Reouires Exoanded Annunciation)
#59 1 Expanded Annunciation: Hawk (700 Series)
#60 1 Hawk Packaqe Stack Temp Transmitter
#61 1 Hawk Packaoe Water Temoerature Transmitter for Hot Standbv / Cold Startup
#62 1 Hawk Packaqe Combustion Air Temperature Transmifter
#63 1 Control Circuit Trahsformer: (Control / Burner Panel)
#64 1 lVlain Power Distribution: Fused Disconnect (Factorv Mounted)
#65 1 Control / Burner Panel Enclosure Confiouration - Side Mounted (NEMA 12)
#66 1 J-Box Panels for complete boiler: NEMA 1
#67 1 Geooraohical Startuo Allowance (Miles Roundtrio: 200)
#68 Labor Startuo Allowance included
#69 Submittals - ASME Data Reoort (CBLE4W)
#70 1 lubmiftals - Dimensional Diaoram (CBLE-4W)
#71 1 Submittals - Test Fire Report (CBLE4W)
#62 1 irrbmittals - Wirino Diacrram {CBLE-4WI
#63 Vlanuals: 750-00452-000/750-00455-000/750-00234-000/
Page5/9
GleaverBrcoks'$
Job Name: Norbest - 250hp Boiler
Quote Summary
Proposal Number: 06792429 / Proposal Datez 07114122
Replacement / Project Name: Norbest-Moroni-Norbest 250 HP
Boiler
Subtotal Price to Customer (USD):
Freight (EXW - Ex Works Factory) Cost (USD):
Total Price to Customer (USD):
CLEAVER.BROOKS OFFERING
qeneralizod erDressions such as'oer olans and sDecifimtions.'
CLEAVER-BROOKS PRICE ADJUSTMENT POLICY
fraction thereof that shipment is deferred beyond six (6) months from the date of the Companv's ProDosl or @ntracl doomsnt.
PROPOSED PAYMENT TERMS
Amount At or Exceeds $250,000: No
Payment Terms:
Terms Description:
Note: May require Cloaver-Brcoks review if other than 20o/o/30W50% referenced in .n 1b).
PROPOSED SHIPPING TERMS
lxl EXW - Ex Works Factory
[ ] CIP - Carriage and lnsurance Paid to
[ ] oTHER:
Freight Allowed To Location:
BUYER OF CLEAVER.BROOKS EQUIPMENT CLEAVER.BROOKS SALES REPRESENTATIVE
Jason Hansen
Buyor Representativo - Printed FiBt and Last Nam€Salss Repressntativo - Printod First and Last Namo
Servco lndustrial Equipment, LLC
1580 SOUTH PIONEER ROAD
SALT LAKE CITY, UT 84104
US
Buyer Reprosonlativo - Gompany Add.ess, Stats/Province, Area Codo, and Country Sal6E R.pi.sanlativa - Company Addros!, StalorProvince, Area Cod., and Country
801 509-0918
Buyer Represontativo - Phone Number SaloE Roprssontativo - Phone Number
Buyor Representatlvo - Slgnature
I
Sales Reprosentatlvs - Signaturg
I
Buyar Representatlve - Dato Acceptsd (MM/DD/YYYY)Sales Reprcsentatlve - Date Offered (iIM/DD/YYYY)
CLEAVER.BROOKS TERMS AND CONDITIONS OF SALE ON NEXT PAGE
Page6/9
cleanerBrco*"$,Terms and Conditions of Sale
Date Revised: July 9,2021
,|
2
4
5
6
7I
't0
11
12
13
14
15
16
17
18
19
20
2',!
22
24
25
26
27
29
30
(e)
(f)
(s)
(h)
(i)
THE CLEAVER.BROOKS COMPANY INC. GENERAL TERMS AND CONDITIONS OF SALE
1. OFFERANDCONTRACT
Price") on these terms and conditions of sale.(b) UPON WRITTEN ACCEPTANCE OF THE PROPOSAL BY THE BUYER. THE PROPOSAL AND THESE TERI\4S CONSTITUTE THE COMPLETE AGREEMENT BETWEEN THE COMPANY ANO
THE BUYER ('THIS AGREEMENT). ANY ADDITIONAL OR DIFFERENT TERMS ARE REJECTED UNLESS AGREED TO BY THE COMPANY IN A SIGNED AMENDMENT AFTER REVIEW AT
THE PROOUCT GROUP HOME OFFICE.
(d) ThePurchas€PrieandanydeliverydatesofthisProposalaresubjecttopriorsalosthatoccurboforowrittenacceptancsbythoBuyorandincreasodmaterialcosts.(e) Orders received are scheduled for production as proposals are accepted in writing by the Buyer.
2. TERMS AND PRICES
may require a lettor of credit from the Buyer.
prepaid freight, will be added to the Purchase Price and invoiced separately.
changes mused thereby.
performan@ milestones are accomplished.
The Buyer shall reimburse lhe Company for all @sts incurred in collecting any late payments, including, without limitation, attomey's fees.
otheMise. The Company shall not be liable for any claim by the Buyer unless and until such claim is finally adjudicated through the dispute resolution process.
The Purchase Price is subject to increase before written a@ptan@ of the Proposal by ths Buyer based upon an increase of tho CRU USA Midwest FOB Mill index.
manufaclure and/or deliverV of anv Equioment if the Buyer tails to pay any Company invoice within thirty (30) days of tho date of the invoie.
DELIVERY
Unless otheMise offered in lhis Proposl, delivery is Ex Works (INCOTERMS@ (most recent version)), at the Product Group manufacturing location ("the Oelivery Point").
arangement drawings within ten (10) business days of receipl.
TITLE AND RISK OF LOSS
Unifom
LIMITATION OF LIABILITY; LIMITED WARRANTY; WARRANTY DISCLAIMER
THE COMPANY SHALL NOT BE LIABLE FOR ANY SPECIAL, INCIDENTAL, INDIRECT, EXEMPLARY, PUNITIVE, OR CONSEQUENTIAL DAMAGES (INCLUDING WITHOUT LII\IIT LOST
PROFITS, PRODUCTIVIry LOSSES, ECONOI\4IC LOSSES, OR BUSINESS DOWNTIME) OR FOR ANY SUCH LOSS, DAMAGE, EXPENSE, DIRECTLY OR INDIRECTLY ARISING FROI\4 THE
USE OF THE EQUIPMENT, SERVICES, SPARE OR REPLACEMENT PARTS, OR FROM ANY OTHER CAUSE WHETHER BASED IN WARMNTY, NEGLIGENCE, TORT, CONTMCT OR
OTHERWISE, AND REGARDLESS OF ANY ADVICE OR RECOMMENDATION THAT MAY HAVE BEEN RENOEREO CONCERNING THE PURCHASE, INSTALLATION OR USE OF THE
EOUIPMENT, SERVICES, SPARE OR REPLACEMENT PARTS WHETHER OR NOT HAVING BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
THE BUYER HEREBY RELEASES THE COMPANY OF ANY SUCH LIABILITY AND COVENANTS NOT TO SUE THE COMPANY FOR ANY SUCH DAMAGES.
IN NO EVENT SHALL THE COI\,IPANY'S AGGREGATE LIABILITY UNDER ANY CIRCUMSTANCES EXCEED AN AMOUNT EQUAL TO THE PURCHASE PRICE OF THE EQUIPMENT.
one (1) year of shipment for any spare parts shipped under an Equipment order.
The Buyer must make any warranty claim by written notlco to lhe Produci Grcup home office within thirty (30) days of the discovery of any defect or the claim is deemed waived.
install or bo liable for the installation of such parts.
Expenses incurred by the Buyer in replacement, repair or return of the Equipment, or of any parts, will only be reimbursed if preauthorized by the Company.
Equipment.
Warranty adjustments or roplacomonts shall not extend the initial warranty period.
THE WARMNry IS IN LIEU OF ALL OTHER WARMNTIES OR REPRESENTATIONS, OML, EXPRESS, OR IMPLIED, INCLUDING WITHOUT LIMIT WARMNTIES THAT EXTEND BEYOND
THE OESCRIPTION OF THE EOUIPMENT. THERE ARE NO EXPRESS WARRANTIES OTHER THAN THOSE CONTAINED IN PARAGMPH 5 (,LIMITATION OF LIABILITY; LIMITED
WARRANTY; WARRANTY DISCLAIMER) AND TO THE EXTENT PERMITTEO BY LAW THERE ARE NO IMPLIED WARMNTIES OF MERCHANTABILIry OR FITNESS FOR A PARTICULAR
PURPOSE.
elements, abuse, misuse, temporary heat, overloading, erosive or @rosive substanes, or the alien presonce of oil, grease, s€le, d€posits or other @ntaminants.
and, if th€ Equipment uses water, with proper water @nditioning.
manufacturing location maintenance).
md is waffanted only to be installed as specifred and the refractory is specifically excluded from any other wananty.
bv lhe ComDanv
TERMINATION
Orders are not cancolable.
Materials paid for will be available "As ls' to the Buyer without waranty; however, partially completed products are not available for completion by others.
oolion, mav cancel this Aqreement without liability.
3'r
32
33
?4
35
36
37
38
39
40
41
42
43
44
45
46
47
{8
3.
(a)
(b)
(c)
4.
(a)
6.
(a)
(b)
(c)
49
50
51
52
53
54
55
56
57
58
59i0
61
e3
54
65
cb
67
38
59
70
71
72
74
75
t6
t7
78
79
BO
31
92
33
34
35
36
a7
38
B9
5.
(a)
(b)
(c)
(d)
(e)
(0
(s)
(h)
(i)
0)
(k)
0)
(m)
(n)
(o)
(p)
PageT/9
GbaverBrook$Terms and Conditiohs of Sale
Date Revised: July 9,2021
THE CLEAVER-BROOKS COMPANY, lNC. GENERAL TERMS AND CONDITIONS OF SALE (continued)90
91
92
94
95
96
98
99
00
01
02
03
c4
J5
c6
07
08
09
't4
'15
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17
'18
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22
23
24
25
26
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29
30
40
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5'l
52
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62
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64
65
66
68
69
70
7',!
72
7.
(a)
(b)
EXCUSED DELAY ("FORCE MAJEURE")
option, may cancel this Agreement without liability.
INSURANCE
nrocccds of slrch insrrrence shall he aDDlic.l first ld the msl of rcoairind and raolacind thc Folrinmpnt end work .iestroved or alameded
BACKCHARGES
in attendan@. Costs claimed for work done withoul shall not be
10. TECHNICAL SUPPORT
and demonstration of
11. WORK BY OTHERS: ACCESSORY AND SAFETY DEVICES; USE BEFORE START UP
defend. and hold the harmless from all @sts and
12. COMPLIANCE WITH THE LAW(a) The Buyer shall comply with all applicable laws, regulations and ordinances.(b) The Buyer shall maintain in effect all the li@nsas, permissions, authorizations, @nsents and permits that it needs to erry out its obligations under this Agreement.(c) The Buyer shall comply with all export and import laws of all countries involved in the sale of the Equipment under this Agreement or any resale of the Equipment by the Buyer.(d) The Buyer assumes all responsibility for shipments of the Equipment requiring any government import cloarane.(e) The Company may cancel this Agreement if any govemmental authority imposes antidumping or countervailing duties or any other penalties on the Equipment.
13. LIMITED LICENSE
trademarks or other intellectual orooertv riohts owned or controlled bv the Comoanv. exceot as necessary for the Buver to use the Eouioment in ac@rdance with this Aoreement-
14. CONFIDENTIAL INFORMATION
performing under this Agreoment and may not be disclosd or copied unless aulhorized in advance by the Company in writing.(b) Upon the Company's request, the Euyer shall promptly retum all documents and other materials received from the Company.
Buysr on a nonronfidential basis from a third party.
bo ontitled to relief for violation of this IOENTIAL INFORMA
1 5. INTELLECTUAL PROPERTY
Buyer, (iii) modify the Equipment so that it bemmes non-infringing, or (iv) refund the then market value of the Equipment.
reason of any real or alleged infringement.
@nfldential and be used onlv for of the conlract-
16. RELATIONSHIP OF THE PARTIES
or equitable right, benefit or remedy of any nature whatsoever under or by r6ason of this Agreement.
RESOLUTION OF DISPUTES
Any waiver by a party of any right shall not be considered a continuing waiver in any other instance.
be entered in any court having jurisdiction thereof.
A^raamant
18. RECOVERY OF FEES AND EXPENSES
incurred in connection therewith.
19. BUY AMERICAN(a) lf this purchase is subject to a mandatory'Buy Amerien" clause, lhe applicable clause must be provided for review by the company before @mpliance may be affimed.(b) Products ofthe Comoanv mav oriqinate in the USA. Canada. or Liechlenstein.
8.
(a)
9.
(a)
10
't1
't2
13
31
32
33
34
35
36
38
39
17.
(a)
(b)
t3
74
20.
(a)
INTERNATIONAL CONVENTION
The United Nations Convention on Contracts for the Intemational Sale of Goods (1 980) shall not apply to international, cross border sales of the Company.
PageS/9
GleaverBrco*$1,Terms and Gonditions of Sale
Date Revised: July 9,2021
26.
(a)
(b)
75
76
t7
78
79
80
8't
s2
83
B4
85
86
87
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90
91
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00
01
02
03
c4
c5
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15't6
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32
JJ
34
35
36
37
38
THE CLEAVER.BROOKS COMPANY. INC. GENERAL TERMS AND CONDITIONS OF SALE (CONti
21. MISCELLANEOUS
(A) THIS AGREEMENT IS THE COMPLETE AGREEMENT BETWEEN THE COMPANY AND THE BUYER AND NO ADOITIONAL OR DIFFERENT TERM OR CONDITION STATED BY THE BUYER
SHALL BE BINDING UNLESS AGREED BY THE COMPANY IN WRITING.(b) No @urse of prior dealings and no usage of the trade shall be relevant to supplemsnt or explain any terms used herein.
those of the State of Georgia.
provision of this Agreement or invalidate or render unenforc€able such tem or provision in any other.iurisdiction.
22, PRODUCT GROUP CONDITIONS(a) Supplemental @nd
SUPPLEMENTAL CONDTTIONS for the PAGKAGED BOILER SYSTEMS PRODUCT GROUP
Tnese provlslons amend the Indlcated articles of THE CLEAVER-BROOKS COMPANY, lNC. GENERAL TERMS AND CONDIT|ONS OF SALE (above)
[Add to 2. TERMS AND PRICES]
(i) Upon lssuance of Submittals: ........................ -.............................20% ofthe Contract Price (Net 30 Days)
(iD upon Retease for Production: ............... ........30% of the contract Price (Net 30 Days)
(iii) Upon Readiness for Shipment: ...................................................................................50% of the Contract Price (Net 30 Days)
[Add to 6. TERMINATIONI
23. CANCELLATION SCHEDULE(a) The mn@llation schedule for projecls is as follows unless otheMise indimted in the Proposal to which these conditions are attached:
SUPPLEMENTAL CONDITIONS for the ENGINEERED BOILER SYSTEMS PRODUCT GROUP
These provislons amend the indicated anicles ofTHE CLEAVER€ROOKS COMPANY, lNC. GENERAL TERMS AND CONDITIONS OF SALE (above)
[Add to 2. TERMS AND PRICES]
(i) Upon Reeipt of Purchase Ordsr: . ...... .........10% of the Contract Pri@ (Net 30 Days)
(ii) Upon lssuan@ of Drawing Submittals (Mechanicat GA and P&lD Orawings):............30% oI the Contracl Price (Net 30 Days)
(iii) Upon Completion of Hydroslatic Test:......................... .................35% of the Contract Price (Nst 30 oays)
(iv) upon Readiness for shipment:........................ ............................25% ofthe contract Price (Net 30 Days)
date of quotation shall be added to the Purchase Price.
[Add to 3. DELIVERYI
inadto2.tr'lThecomoanvwillendeavortomakeshiomentoforderSasScheduled:however.allshiomentdateSareapproximateonly'andthecompanyIeserueslh@
24. CANCELLATION SCHEDULE(a) The cancellation schedule for prcjects is as follows unless otheMise indi€ted in the Proposalto which these conditions aro attached
(i) Up to 14 Days After Receipt of Purchase Order: ........................................................0% of the Contract Price (Net 30 Days)
tii) Over '14 Oays After Receipt of Purchase Ordsr: .................... ......25% of the Contract Price (N€t 30 Days)
(iii) Upto30DaysAfterDrawingApproval:......................... ...............45%oftheContractPrice(Net30Days)(iv) 3160DaysAftorDrawingApprovat:............... .............................55%ofthecontractPrice(Net30Days)(v) 61-90 Days After Drawing Approval: .... .........75% of the Contract Price (Net 30 Days)(vi) Overg0DavsAfterDrawinoAooroval: ........................ ................100%ofthsContractPrice(Net30Oays)
25. FOUNDATIONS(a) The Company shall provide the Buyer with General Arrangement drawings showing the Equipment with reference to foundations, including loading diagrams.
due time by the Buyer.
SUPPORTING STEEL
be designed in a@rdance with the latest Rules of the American lnstitute of Steel Construction.
loadinos imDosed by the Buver, lhe Buyer shall reimburse the Company for the additional steel and work required.
Page9/9
ll$rtp,r
1Y Pitman Farms, Utah Division
P.O. Box 308
350 South 300 West
Moroni, Utah84646
Telephone: (a35) 436-8211
Fax: [phone]
Mary 26,2023
To: Sarah Foran
Environmental Engineer
Department of Air Quality
Department of Environmental Quality
State of Utah
Re: Documentation of Status of Construction (I.8), permit DAQE-AN106440005-23
Sarah,
This letter is provided as documentation to comply with section I.8 of the updated air quality
permit, DAQE-AN I 06440005 -23 , for our Moroni Feed Mill of our Pitman Farms, Utahcom,an,'
*i}'r&,{Aru FAItht$
Following receipt of the permit, we completed d6flStruction of the boiler and set-up at the end of
April / beginning of May and have initiated and begun use of the boiler. The boiler is working as
intended, with no issues noted.
We also had an inspection by Jordan Garahana, yesterday with no issues found.
Please contact us ifyou have any questions.
Sincerely,
Luke Freeman
Technical Services Director
Pitman Farms, Utah
Pitman Farms, Utah Division PO Box 308 Moroni, UT 84646 www.norbest.com
Lii.'. 8121123,11:36AMffi State otUtah Mail - PFU -'DAQE-AN100440005.23 ' DCSr " j
Jordan Garahana <[e-mail]>
PFU . DAQE.AN106440005.23 - DCS
2 messages
Luke Freeman <[e-mail]> Fri, May 26,2023 at 9:44 AM
Cc:'[e-mail]" <[e-mail]>
Sarah,
We have completed the construction of our new boiler at our Moroni Feed Mill, as part of the updated DAQE-
AN106440005-23 permit. ln accordance with 1.8 of said permit, attached is our letter for documentation of that
construction. lf you have any questions, comments or concerns, please let me know.
Thank you,
Luke Freeman lTechnical Services Director
Pitman Farms, Utah Division
Office: [phone] ext. 13028
www.norbest.com
This e-mail may contain information that is confidential, proprietary, or "non-public personal information". The Confidential
lnformation is disclosed conditioned upon your agreement that you will treat it confidentially and in accordance with
applicable law, ensure that such data isn't used or disclosed except for the limited purpose for which it's being provided
and will notify and cooperate with us regarding any requested or unauthorized disclosure or use of any Confidential
lnformation.
From: Mike Va nce <M [e-mail]>
Sent: Monday, March L3,2023 9:54AM
To: Luke Freeman <[e-mail]>
Subject: FW: Division of Air Quality Notice
IEXTERNAL MESSAGE]
From: Jeree Greenwood <[e-mail]>
Sent: Monday, March t3,2023 7:49 AM
To: Mike Vance <[e-mail]>
Subject: Division of Air Quality Notice
Attached please find your copy of DAQE-AN106440005-23, notice for Pitman Farms.
https://mail.google.com/mail/u/0/?ik=038c40753gyisvv=pt&search;all&permthid=thread-f:1766972050712853997&simpl=msg-f:17669720507128539... 113
8121123, 11 :36 AM State of Utah Mail - PFU - DAQE-AN106440005-23 - DCS
lf you have any questions please contact the engineer listed on the document.
An invoice for this project will be sent to this email address in a few weeks. Please confirm this is a good email address
for you, otherwise, please provide a good email address for the invoice to be sent to.
Thank you
AIR OUALITY
Jeree Greenwood
Office Technician II I Minor NSR Section
M: (S8S) 306-6514
airquality.utah.gov
gr €tlvr
fl,Q
ffim
DOCS MFM NB - 5-2023.pdf
Chad Gilgen <[e-mail] Tue, May 30,2023 at 12:55 PM
To: Sarah Foran <[e-mail]>
Cc: Jeree Greenwood <[e-mail]>, Jordan Garahana <[e-mail]>
HiSarah,
Thanks for forwarding this to my attention. These types of notiflcations need to be added to D2 as well as the source file
per the requirements of condition 1.8 which is as follows:
; The owner/operator shall submit documentation of the status of construction or modification to the Director within 18' months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from
PFU
43K
hftps://mail.google.com/mail/u/O/?ik=038c401/539v;gvv=pt&search=all&permthid=thread-f:'1766972050712853997&simpl=msg-f:17669720507128539.
i't:.:" . i;8127123; 11;86AM
, i the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the
i Oirector, send the documentation to the Director, attn.: NSR Section. [R307401-18]
This is something we rely on when scheduling compliance inspections. Especially for new equipment because it lets us
know it's installed and we should schedule them for an inspection to ensure the new equipment meets the requirements
of theAO.
This documentation used to be sent to the attention of the compliance section but NSR changed the language in the AO's
to have it be sent to NSR a few years ago. l've tried to get it changed back to compliance but NSR has not been willing to
make that change.
Thanks,
Chad
Chad Gilgen I Manager I Minor Source Compliance
385-306-6500 (cell)
Q[il:;ii"i',r''"
Emails to and from this emait address may be considered public records and thus subject to Utah GRAMA requirements.
On Fri, May 26, 2023 al l0:58AM Sarah Foran <[e-mail]> wrote:
Not sure what we do with these for filing purposes. But here is an r8-month notification
Thanks!
Sarah Foran, PE
Environmental Engineer I Major NSR
M: (SBS) 3o6-6724
airquality.utah.gov*L<o
AIR OUALITY
Emails to and from this email address may be considered public records and thus subject to Utah GMMA
requirements.
lQuoted text hiddenl
Gl
https://mail.google.com/mail/u/0/?ik=038c40f/b3&view=pt&sear*h=alBpermtniO=thread-f:1766972050712853997&simpl=msg'f:.17669720507128539... 3/3
8121123, 1 'l :35 AM State of Utah Mail - Pitman Farms Data - AN 1 06440005-23, follow up lo 512512023 site visit / audit
Jordan Garahana <[e-mail]>
Pitman Farms Data - AN106440005-23, follow up to 5/25/2023 site visit / audit
28 messages
Luke Freeman <[e-mail]>
To: "[e-mail]" <[e-mail]>
Jordan,
Fri, May 26,
Thank you for your time on the audit yesterday. I sent in a letter, for compliance with section I.8, this moming to Sara and cc'd you. On the remaining materials requester
1. This is the boiler data from 112022 to present. The Old Boiler (HOO) is the hour meter read with the zse column the hours used (the current month's hour read sub
the previous month's). With that, we used 7,162 hours from May 2022 to May 2023, under the allowed 8,760 hours of the permit. The rolling twelve hours are also
side:
2023
2021
2023
2023
2023
Janray
February
Mrch
April
May
Jrme
July
August
Septeober
Octobcr
Noveober
Deceobcr
lwy
fceuay
tt[acb
Aprf
lvfty
12,580
13,159
13,591
14,356
14,902
15,383
16,053
t6,463
t7,036
17,548
18,103
18.672
19,411
20,088
20,712
21,465
21.518
Hor Meter
Horr Metet
Hour Meter
HourMaer
Hc,ur Metcr
Hcrr Meter
Hcnr Macr
HorMaer
Horr Meter
Hour Mcter
HqrMaer
Hcnrr Meter
8.768.9
9,356.9
9,951.6
10,526.(
1 t,l0.l.(
11,671.(
t2,2t8.:
r2,804-r
13,3 82.1
13,959.(
14,529."
15.093.1
15,653.1
16,2?3.(
16,800.:
t7,393.1
17.986":
Pitnan Farms
Technicel Servlces
Boiler Operation Worksheet
Moroni Feed Mill
632.N
579.00
,132.00
755 00
516.00
481.00
670.00
410.00
573.00
512.00
555.00
569.00
739_00
677.00
624.00
753.00
53.00
Gencral o,perabo tests
Geoeral test for firnctioo
Gcacral tcst for f,rctim
HourMaer
HorMacr
HourMeta
Hour Meter
Hcnr Meter
7
7
7
7
7
7
7
7
/
7
7
,
2. For the boiler, as I noted during the audit, we do not really use the boiler but tum it on at least annually to test it. This is our record:
Pitnan Fanus
Technical SeMces
Emergencl' Generator Operation Worksheet
Moroni Feed Mill
8,,19!2020
8i3/202 I
8t5!2022
8 hours
less th- 5 oimtes
hss 6an 5 cimrtes
Yes
Yes
Yes
2022
2022
2022
2022
2022
2022
2022
2022
2022
2022
2022
This is our last invoice for the fuel used in the generator:
https:/imail.google.comimail/u l0l?ik=O38d0f753gv;gvv=pt&search=all&permthid=thread-f:1766974738665805765&simpl=msg-f:17669747386658057.1t8
i :' : \i,' /.1." 1 $127:128, ( 1 :95 AM State of Utah Mail ;P,itrnan Farms'Data - AN106440005'r?3;.fullowr,trp to 51251202? sitQ vistt / qudit
tNvotcE
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Rdd)yne tt sr LLC
Po Bor 954030
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ffi d G*dvrt tu-dt Edffi a. td lfir(Faa
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PITMAN FARMS INC
PO BOX 368
MORONT UT 84646
txi. rt tclt[bf
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TW PITMAN FARMS
350 S 300W
MORONT UT 84646
FEBALEGE€TAI.GL
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I believe that is all of the information you requested. However, if I missed anything or if you have any questions, comments or concems, please let me know'
Thank you,
Luke Freeman I Technical Services Director
Pitman Farms, Utah Division
Office: (435) 436-821 I ext. 13028
www.norbest.com
agreement that you will treat it confidentially and in accoidance with applicable law, ensure that such data isn't used or disclosed except for the limited purpose for which
piovided and will notiff and cooperatc with us regarding any requested or unauthorized disclosure or use ofany Confidential Information.
Jordan Garahana <[e-mail]>
To: Luke Fresman <[e-mail]>
Luke,
Fri, May 25, 2023 at 10:32 AM
low NOx or has a low NOx burner on it. Do you have the specs for either the boiler itself or the burner that states that? OtheMise I have everything else I need.
Thanks,
Jordan
louotod toxt hiddenl
Jqdan Garahana
Environmental Scientist I Minor Sourco Compliance
* (385't271-2871
airquality.utah.gov
https://mail.google.com/mail/u/0/?ik=038c40f/0r*u;"yy=pt&SgarQh-all&permthid=thread-f:'1766974738665805765&simpl=msg-f:17669747386658057...2t8
{:),:t:'' - (1. 812t123, 11:33AM Statd of Utah Mail - Pitman Farms Data - AN106440005-23, follov up lo 5125t2023 site visit / audit
atH sualtrY
I
I
I
Emails to and from this email address may be considered public records and thus
subiect to Utah GMMA requirements.
Luke Froeman <[e-mail]>
To: Jordan Garahana <[e-mail]>
Jordan,
Correct, a 9 ppm NOx bumer. Attached is what we put in.
If you have any questions, comments or concems, please let me know.
Thank you,
Luke Freeman I Technical Services Director
Pitman Farms, Utah Division
Office: (435) 436-821I ext. 13028
www.norbest.com
This e-mail may contain information that is confidential, proprietary, or "non-public personal infomration". The Confidential Information is disclosed conditioned
upon your agreement that you will treat it confidentially and in accordance with applicable law, ensure that such data isn't used or disclosed except for the limited
purpose for which it's being provided and will notiry and cooperate with us regarding any requested or unauthorized disclosure or use of any Confidential
Information.
From: Jordan Garahana <[e-mail]>
Sent: Friday, May 26, 2023 10:32 AM
To: Luke Freeman <[e-mail]>
Subject: Re: Pitman Farms Data - AN'10&140005-23, follow up to 5/2512023 site visit / audit
[EXTERNAL MESSAGEI
lorctod t€xt hiddenl
fr1 06792429-2250 HP Boller Proposal 9 PPM NOx.pdfE 3z8r
Fn,May 26,2023 at 10:56 AM
Jordan Garahana <[e-mail]>
To: Luke Freeman <[e-mail]>
Luke,
Thank you for sending me this and everything else I needed. I appreciate your help!
Thanks,
Jordan
[Ouoted toxt hiddenl
Fri, May 26, 2023 at 10:58 AM
Jordan Garahana <[e-mail]> Thu, Jun 1, ZO23 al j1:25 AM
To: Luke Freeman <[e-mail]>
Luke.
roller mill in the last rolling 1z-months.
Thanks,
Jordan
{Ouoted loxt hiddBnl
Luke Freeman <[e-mail]>
To: Jordan Garahana <[e-mail]>
Jordan,
Thu, Jun 1,2023 at 11:49AM
I am out ofthe ofiice today but will aim to obtain the information you need and provide tomorrow - Ijust need to review with the Mill staffand then I can follow up.
https://mail.google.com/mail/u lOl?ik=O38dOf7b3&view=pt&search=all&permthid=thread-f:1766974738665805765&simpl=msg-f:17669747386658057... 3/8
8121,123i11:3$,AM
louotod t6xt hidd€nl
State of Utah.Mail'Pitman.Farns Data . AN106440005.23, follow up to 512512023 site visit / audit
Luko Froeman <[e-mail]>
To: Jordan Garahana <[e-mail]>
Jordan,
The following data is pulled from 512022 to the end of 512023
1, Grains Received:
2. Grains Shipped:
3. Grains Processed through the Roller Mill
4. Grains Processed through the Pelletizer:
96,831.71 tons
I I 1.861.217 tons
107,502 tons
92,780 tons (25,730 and 67,050)
Fn, Jun 2,2023 al 11:50 AM
So, as I went through the permit again, to obtain the data, I found an issue that I must have overlooked and I apologize. The permit has us listed for one
pelletizer with a 20,800 tons limit but we agtually have two pellet2ers, one small and one larger with the larger added on last year and apparently did not get it
added to the permit, for which I apologize. All roller milled feed is now run through these pelletizers, before it becomes final feed. The 92,780 tons above is
the total (from 512022 ta 512023\ pelleted with 25,730 on the small and 67,050 on the large.
I reached out to Sarah with permitting, to review the issue and discuss correction, and will be putting together an updated NOI for their review, with this we
will also review all of our points to see if we need to update further.
I called and left you a voicemail on this as well and ifyou have any questions, please respond to this email or call me on my cell phone [phone]) and I will be
happy to review with you.
lo@ted text hidd€nl
Jordan Garahana <[e-mail]>
To: Luke Freeman <[e-mail]>
Luke,
Wed, Jun 7, 2023 at 7:39 AM
Thanks for sending me this. I have a question about the new pelletizer that is nol in your cunent AO. ls it routed through a cyclone or baghouse like the other pellotizer?
Thanks,
Jordan
lQuot€d text hk d€nl
Luke Froeman <[e-mail]>
To: Jordan Garahana <[e-mail]\r,
Jordan,
The new pellet mill does have a cyclone and there is a baghouse through the process but not sure if there is a baghouse with the cyclone at the pellet mill itself.
lf you have any questions, comments or concerns, please let me know.
Thank you,
Luke Freeman I Technical Services Director
Pitman Farms, Utah Division
Ofrce: (435) 4364211 ext. 1 3028
wW.norbest.com
Wed, Jun 7, 2023 at 8:23 AM
trom: Jordan Garahana <[e-mail]>
Sent: Wednesday, June 7, 2023 9:39:09 AM
louoted text hldden]
[Q@ted text hidden]
Jordan Garahana <[e-mail]>
To: Luke Freeman <[e-mail]>
Hey Luke,
Tue, Jun 1 3, 2023 at 9:14 AM
ls the contact info on the first page of the AO accurate? I am confirming that information is accurate because we are sending a Complianco Advisory because of what occured with the
unapproved p€ll€tizer and the €xceeded production limits.
Thanks,
https://mail.google.com/mail/u/0/?ik=038c407b3&view=pt&search=all&permthid=thread-f:1766974738665805765&simpl=msg-f:17669747386658057...4t8
ErturnEdtZIE*rffililM
, Jodan
[O@Ld text hkldrn]
::.q9(9-of urah MailrPlffi,f FaHilrDafri.':AM0idl;i@u{;ry,se&oidul6p0a8#trvG1t.raiHit
Luke Freomen <]he€man@norb$t@m>
To: Jordan Garahana <[e-mail]
Iordan,
Yes, that is the address for the Mill. However as this will comc to me, the best location to send the advisory will be to me:
Piman Farms
Attn: Luke Freeman
Box 308
350 South 300 West
Moroni, Utah 84646
That will ensure I receive it quicker and caa follow up
louobdtat Hdd€n)
Tue, Jun 13, 2023at9:19AM
Jordan Gerahrn. <[e-mail] Tue, Jun 1 3, 2023 at 9:22 AM
To: Luke Fr€eman <tfreeman@norbestcom>
Sounds good. Thanks for lsting mo kno,v. lf you havo any quoslions about th6 compllance advlsory when you receive lt, f€el free to contact m€.
Thank6.
Jordan
lordod lld hl&€ol
Luke Frcomu Tue, Jun 13, 2023 et 9:28 AM
To: Jordan Garahana
Jordan,
Will do, I appreciate the help here. Would it be possible to obtain a digital copy, via eorail, as well?
IO@bdbdhddol
Jordrn Garahana <[e-mail] Tu6, Jun 13,2023 at 11:l4AM
To: Luke Fl€gman <ltreeman@no6€st.com>
Hey Luke,
You will r€coive a copy of the complianca advisory by cortifiod mail. I can sond you an emall with tho compfianc. advisory onco lf3 approved and finalizod.
Thanks,
Jordan
louobd to|d hldds]
Luk Fru.mrn <lfro6man@norbestcom>
To: Jordan Garahana <[e-mail]>
Jordan,
Perfect thank you.
[Olotcd ien hk d€nl
Tue. Jun 13,2023 at 11:15AM
Jordln Garihan. <[e-mail],
To: Luke Fr€oman <lheeman@nortestcom>
Luke,
Here ls an 6l6cfionlc copy of the Compliance Advisory that is baing s€nt to Pitnan Farms. Please let me knovy if t ou havo any questions.
Thanks,
Jordan
[Ouobd icf hlddal
Tua, Jun 20, 2023 at 3:00 PM
https://rnail.google.com/maiUr.r/0/?ik=038c407b3&view=pt&searchriall8pernlhid=threa&f:1766974738665805765&simpl=msg-f:17669747386658057... 5/8
;.,( f ,, g/2rM23, r{1:35 AM State of Utah Mait- Pitman Fanhs Data - AN{00_449005.23},F,ltouupto 512512023:strtevisit /:audit
A 3.11t" 'srsned'Pdf
Luke Freoman <[e-mail]>
To: Jordan Garahana <[e-mail]>
Jordan.
Tue, Jun 20, 2023 at 3:07 PM
Received and thank you for sending this. I will have a response to you, within the ten day period. Is the ten day response time started with receipt of this digital letter
or when I receive the hardcopy?
Iouoted len hiddenl
Jordan Garahena <[e-mail]\r>
To: Luke Freeman <[e-mail]>
Luke,
It is from wtren you receive the hard copy through the mail.
Thanks,
Jordan
louotsd text hiddenl
Tue, Jun 20, 2023 at 3:31 PM
Luke Freeman <lhe6man@norb€st.com>
To: Jordan Garahana <[e-mail]>
Jordan,
Mon. Jun 26,2023 at 3:39 PM
I received the hard copy letter on 6 12212023 and attached is our response. Please let me know if you have any questions or bomments and I will be happy to follow
up. Would you like me to send a hard copy of the response as well?
If you have any questions, comments or concems, please let me know
Thank you,
Luke Freeman lTechnical Services Director
Pitman Farms, Utah Division
Office: [phone] ext. 13028
www.norbest.com
This e-mail may contain information that is confidential, proprietary, or "non-public personal information". The Confidential Information is disclosed conditioned
upon your agreement that you will treat it confidentially and in accordance with applicable law. ensure that such data isn't used or disclosed except for the limited
purpose for which it's being provided and will notifu and cooperate with us regarding any requested or unauthorized disclosure or use of any Confidential
Information.
From: Jordan Garahana <[e-mail]>
Scnt: Tuesday, June 20, 2023 3:01 PM
[o@t d ton hddenl
lQrcted toxt hiddenl
g PFU CAR SOU DAQ .6r023.pdfU 96K
Jordan Garahana <[e-mail] Mon, Jun 26, 2023 at 3:50 PM
To: Chad Gilgen <[e-mail]>
Hey Chad,
Here is the response letter from Luke at Pitman Farms. I will let him know he should send a hard copy of that letter through the mail. Please let me know if you have any questions and
what steps w€ need to lak6 next.
Thanks,
Jordan
lQ@ted text hi,ld€n]
E 55,1 "o* tou DAQ ' 6'2023'Pdr
Jordan Garahana <[e-mail]> Tue, Jun 27, 2023al1:17 PM
https://mail.google.com/mail/u/0/?ik=038c4Ofl/b3&viewrpt&.search=all&permthid=thread-f:1766974738665805765&simpl=msg-f:17669747386658057... 6/8
<'';'. t';1u)8lz1l23if f:06Afu1 State of Utah Mait:Fitindrr Fhitrrs Data - AN106440005-E;,f6[tiW vftto 5l25l2AQ9 6[td vislt laddit
To: Luke Freeman <[e-mail]>
Luke,
Thanks for sending me the response through email. Please send a hard copy through mail for our records. I will reach out if I have any other questions about the letter
Thanks,
Jordan
lQuoted ten hHden]
Luke Freeman <[e-mail]>
To: Jordan Garahana <[e-mail]>
Jordan,
Understood, I will send a copy today, to the address on the envelope received. Once I have it ready for shipment (FedEx) I will give you the tracking number
lf you have any questions, comments or concerns, please let me know.
Thank you,
Luke Freeman I Technacal Services Director
Pitman Farms, Utah Division
Office: (435) 436€21l ext. 13028
www.norbest.com
Tue, Jun 27,2023 at 1:19 PM
From: Jordan Garahana <[e-mail]>
Sent: Tuesday, June 27, 2023 1:17:45 PM
(Ouoted text hiddenl
Iouoted text hlddenl
Luke Freeman <][e-mail]>
To: Jordan Garahana <[e-mail]>
Jordan,
The hard copy is shipping out today via FedEx on tracking number 772576751740 for delivery tomonow.
I have it to Chad's attention. lf you have any questions or would like additional information, please let me know. We are actively working on the permit update now,
lf you have any questions, comments or conc€rns, please l€t me know.
Thank you,
Luk6 Freoman I Technicel Sorvices Director
Pitman Farms, Utah Division
Ofiice: (435) 436{211 ext. 13028
www.norbest.com
Tue, Jun 27, 2023 at 2:03 PM
From: Jordan Garahana <[e-mail]>
Sent: Tuesday, Jun e 27, 2OZ3 1:17:45 PM
louoted text hiddonl
louoted te( hiddenl
Chad Gilgen <[e-mail]> Thu, Jun 29, 20?3 at2:46 PM
To: Jordan Garahana <[e-mail]>
Thanks, Jordan.
Luke doesn't need to submit a hard copy of this letter. We can accept the email since it has a formal response attached. The next step will be to draf up an Early Settlement Agreement
for the observed violations. Let me know when you would like to put the penalty together and I can help out.
Thanks,
Chad
Chad Gllgen I Manager I Minor Source Compliance
iil,,,'
Emails to and frcm this email addre$ mdy be considered public r€cords and thus subjecl to Uldh GP/MA rcquirem€nts.
louotod text hk don]
Jordan Garahana <[e-mail] Fri, Jun 30,2023 at9:11 AM
To: Chad Gilgen <€[e-mail]>
Hoy Chad,
Sounds good. H€ already ssnt a physical copy through the mail so we will now have a s€cond copy. That sounds like a good plan. Let me know what n6eds to be done to get the Early
Settlement Agreement going so we can get this completed.
Thanks,
Jordan
https://mail.google.com/mail/ul0l?ik=038c4017 b3&view=pt&search+all&permthid=thread-f:1766974738665805765&simpl=msg-f:17669747386658057... 718
i/" 'i,t:i:'8n21l28;51i334M
louoted bn hiddonl
State of Utah.Mail",,8fuifli Firris Data'iAN10$$q0054&lfclbmtrp to 5/25l2023.si!g visit faudit
Chad Gilgen <[e-mail]>
To: Jordan Garahana <[e-mail]\r,
Thu, Jul 6, 2023 al 11:28 AM
Hi Jordan,
Thanks for the updat6. Th€ Early Settlemenl penalty is prepared using the attached spreadsheet. That information is then added into th€ tabl6 on page 6 of the attach€d Early
Settlement Agreement 2021d document. I have also attach€d a few recent ESAS for your review.
Please let me know if you would like to set up a time to do a Google Meet to further review or answer any questions you may have. l'm available pretty much anytime lomonow or
Monday.
Thanks,
Chad
Ched Gilgen I llanager I Minor Source Compllanc€
38s,3064500 (cell)
7l I t-1,rLri..r/-v!!LNI ),_ I L\, i ,;! rL.trA ,) rr:,.f!( G'.;o.,"
Emails to and lrcm this email eddre$ may be Msidered public recods aN thus su@ct to Ulah GRAMA requirements.
louotod text hlddsnl
4 attachments
6 C€flt-23.pdfs 396K
6 C{15-23.pdfu 622K
B ?3i,1"'"""3heetrg
B *[v Settloment Agreomont 2o2ld.docr
Jordan Garahana <[e-mail]>
To: Chad Gilgen <[e-mail]>
Hey Chad,
Monday would work great for me to go over this. Thanks for providing me with some previous ESAS as well as with the the penalty worksheet. I will take a look at this soon.
Thanks,
Jordan
louoted ten hidd6nl
Thu, Jul 6, 2023 at 3:13 PM
Chad Gilg€n <[e-mail]>
To: Jordan Garahana <[e-mail]>
Hi Jordan,
Let's plan to revi€w on Monday at 11am. l'll send you a calondar invit6.
Thanks,
Chad
Chad Gilgen I lilanager I tllnor Source compliance
38$30&6500 (cell)
Fri, Jul 7, 2023 at 1:00 PM
4il,;;
Emails to and from this email address may be @nsldered public ffitds aN thus subjed lo t/,,ah GRAMA requirements.
lQ@ted text hHdenl
https://mail.google.com/maiUu/0/?ik=038c407b3&vjep=pJ&qearch=all&permthid=thread-f:1766974738665805765&simpl=msg-'t:17669747386658057.8/8
PITMAN FA,RMS
Re:
ir' .1f,-,jirrr r',-,.,.i 1,..
Pitman Farms, Utah Division
P.O. Box 308
350 South 300 West
Moroni, Utah84646
Telephone: [phone] |
Fax: [phone]
June26,2023
To:Chad Gilgen, Manager
Minor Source Compliance Section
Division of Air Qualiry
Department of Environmental Quality
State of Utah
DAQC-606-23, Site ID 10644(81) - Compliance Advisory - Pitman Farms - Moroni Feed Mill,
Utah Administrative Code (UAC) R307-401, Approval Order (AO) DAQE-ANI06440005-23,
Sanpete County
This letter is provided as the requested written response to the compliance advisory letter received on
612212023. On 512512023 an inspection of our Feed Mill under approval order DAQE-AN106440005-23
was conducted by Jordan Garahana with the Department of Air Quality. During that inspection, data
pertinent to the permit was requested and was provided the following day,512612023.
On 6ll/2023, additional information was requested. During review for that additional information, two
issues were found. First, it was found that we had inadvertently exceeded our permitted tons of grain
per our pelletizer by 4,930 tons for the year. Second, we found that we had inadvertently overlooked
adding a second pelletizer added in2022, to the permit. This pelletizer processed approximately 67,050
tons of grain through the mill over 2022.Immediately following these finds on 61212023, notification
was given, along with the data requested, to Jordan Garahana.
We apologize for these two issues as well as our oversight here, it was not our intent to not comply with
the permit and we are working to resolve these issues. When the permit was updated, moving from
Norbest to Pitman Farms ownership, the permit was updated to reflect the operation of the Mill at that
time. Since that time, it has been determined that, for the health of our birds, all feed produced would
eventually need to be pelletized, which is where the increase of the tons on the existing pelletizer come
from as well the addition of the new pelletizer. Both pelletizers have dust collection and control
equipment on them, as part of our efforts to control any emissions from our process, with the equipment
reviewed and maintained during any operation of the pelletizers.
When we found the issues, we immediately contacted Jordan and notified him of the issue. We then
began actions to resolve the issue. We contacted Sarah Foran with the Department of Air Quality who is
our contact on permitting. We reviewed the issues found and discussed how to correct, which was
determined to be completion of a notice of intent (NOI) for the Mill reflecting our equipment and needs.
We then contacted our third-party contractor, RMEC, used for such environmental permitted issues and
explained the permit and issues found and resolution needed. Following discussion with the contractor,
we reviewed all of our equipment and planned production over the next few years. Information on the
equipment was then obtained (611312023) and provided to the contractor for work on the NOI, which is
in process.
Pitman Farms, Utah Division PO Box 308 Moroni, UT 84646 www.norbest.com
1,.:ir:t'"''.: ','
Once work on the NOI is completed, we will submit it to permitting with the Department of Air Quality
for review and approval. To further control any potential future permit issues, once the issues were
found, they were also reported to our division Vice President and the Feed Mill Manager. We will now
have additional, internal, oversight of the permit and our processes to help ensure that compliance to the
permit is maintained as well as proper communication between us and the Department of Air Quality.
If you have any questions or would like additional information, please contact me via the information
below.
Sincerely,
Luke Freeman
Technical Services Director
Pitman Farms, Utah
Email:
Offrce:
Cell:
[e-mail]
[phone] ext. 13028
(43s) 3t4-9862
Pitrran Farms, Utah Division PO Box 308 Moroni, UT 84646 www.norbest.com
8121123, 11:34AM stete of utdh Mait - pFu DA0c:75b-23EA,,8]7-2023
Jordan Garahana <[e-mail]>
PFU DAQC-758-23 SA - 8-7-2023
3 messages
Luke Freeman <[e-mail]>
To: Chad Gilgen <[e-mail]>, Jordan Garahana <[e-mail]>
Chad and Jordan,
Mon, Aug 7,2023 at 1:26 PM
I received the DAQC-758-23 settlement agreement in regards to the approval order for our Moroni Feed
Mill. I have signed the agreement (first attachment) and I paid the penalty amount via your online portal
with attachments two through four showing receipt. We have submitted the updated NOI to the DAQ and
have been assigned an engineer and are waiting comment from her. Thank you for your help in resolving
this matter and if you need anything else, for this, please let me know.
If you have any questions, comments or concerns, please let me know.
Thank you,
Luke Freeman I Technical Services Director
Pitman Farms, Utah Division
Office: [phone] ext.13028
www.norbest.com
This e-mail may contain information that is confidential, proprietary, or 1'non-public personal information".
The Confidential [nformation is disclosed conditioned upon your agreement that you will treat it
confidentially and in accordance with applicable law, ensure that such data isn't used or disclosed except for
the limited purpose for which it's being provided and will notify and cooperate with us regarding'any
requested or unauthorized disclosure or use of any Confidential Information.
Forwarded message
From: "[e-mail]" <[e-mail]>
To: Luke Freeman <[e-mail]>
Cc:
Bcc:
Date: Mon, 7 Au1202319:20:15 +0000
Subject: Online Payment Receipt
[EXTERNAL MESSAGE]
Credit Gard Payment Receipt
Your payment was successfully processed.
https://mail.google.com/mail/u l0l?ik=038cA0f7539y;s\iv=pt&search=all&permthid=thread-f:1773599624536326863&simpl=msg-f:17735996245363268. ". 114
8121123,11:34 AM State of Utah Mail - PFU DAQC-758'23 SA- 8-7-2023
Item QuantitY ltem Amount Total
PENALTY PAYMENT
Must enter DAQ) or DAQA number to identify the penatty payment.l $1'166'00 $1'166'00
TotalAmount: $1,166.00
Payment Processing Details
Order Number: 5755804
Date of Transaction: AugT,2023
Amount Paid: $1,166.00
Cardholder's Name: Luke R Freeman
Gredit Card Number' ******t********6000
Credit Card Type: American Express
AmountCharged: $1,166.00
Fonvarded message
From: "[e-mail]" <[e-mail]>
To: Luke Freeman <[e-mail]>
Cc:
Bcc:
Date: Mon, 7 Aug 2023 19:20:14 +0000
Subject: Order confirmation
[EXTERNAL MESSAGE]
Your order 5755804 for the amount of $1,166.00 has been successfully processed.
Order Details
Order Number: 5755804
Order Date: AugT,2023
Product Name Quantity Price Each
PENALTY PAYMENT 1 $1,166.00
Notes:
Your uploaded file(s):
Thank you for your purchase.
4 attachments
+r PFU MFM DAQC-758-23 -8-7-2023.pdtE oszox
US DEQ DAQ DAQC-758-23 Receipt - 8-7-2023.pdf
8'tK
I Online Payment Receipt.emlu tot<
rr Order confirmation.emlU tox
Chad Gilgen <[e-mail]>
To: Luke Freeman <[e-mail]>
Cc: Jordan Garahana <[e-mail]>
Wed, Aug 9,2023 at 3:08 PM
hftps://mail.google.com/mail/u/0/?ik=038c401/53gu1gvv=pt&search=all&permthid=thread-f:1773599624536326863&simpl=msg-f:17735996245363268... 214
8121123, 11:34 AM
Hello Luke,
The DAQ is in receipt of your payment for the Early Settlement Agreement. Thank you for letting us know. You should be
receiving a Signed Early Settlement Agreement letter within the next 10-14 business days closing out this compliance
action.
Thanks and please let me know if you have any questions.
Chad
Ghad Gilgen I Manager I Minor Source Compliance
385-306-6s00 (cell)
i i'.lr rt,!.,{. :.. -t:
i::ii 1i,.i.r:t"i ;r..,
AIR
AUALITY
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
0
Luke Freeman <[e-mail]>
To: Chad Gilgen <[e-mail]>
Cc: Jorda n Garahana <jordangarahana@utah. gov>
Chad,
Wed, Aug 9,2023 at 3:11 PM
Acknowledged, thank you. I will look for the letter in a week or so, appreciate the update.
If you have any questions, comments or concerns, please let me know.
Thank you,
Luke Freeman I Technical Services Director
Pitman Farms, Utah Division
Office: [phone] ext.l3028
www.norbest.com
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RMEC PP21E-4223

February 10, 2025

Bryce Bird
Director
Utah Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
SUBJECT: REVISED PERMIT MODIFICATION REQUEST
Re: Pitman Farms – Moroni Feed Mill
UDAQ Approval Order: DAQE-AN106440002-21
15 East 1900 South Feed Mill Road
Moroni, UT 84646
Dear Mr. Bird:
On behalf of Pitman Farms, RMEC Environmental, Inc. (RMEC) is hereby providing the Utah
Division of Air Quality (UDAQ) with the following revised modification request regarding the
above-referenced Approval Order (AO). This modification is for an increase in pelletized feed
production, including the addition of a new pellet mill. These modifications will result in an
increase of particulate matter (PM10) emissions.
MODIFICATION DETAILS
Approved equipment under the current AO for the site includes one (1) pelletizer, or pellet mill,
which has a manufacturer’s production capacity rating of 5-tons per hour (TPH). Pitman Farms is
transitioning feed production operations at the Moroni Feed Mill (MFM) to 100% pelletized feed
and is requesting to add a second pellet mill with a 30-TPH rating, which will be connected to a
cyclone for emission control purposes.
Section II.B.1.b of the current AO for the MFM stipulates the following operation and production
limits:
A. 250,000 tons of received grains per rolling 12-month period
B. 150,000 tons of shipped grains per rolling 12-month period
C. 150,000 tons of grains processed through the roller mill per rolling 12-month period
D. 20,800 tons of grains processed through the pelletizer per rolling 12-month period
More of the grain received at the MFM will be processed into pellets, as identified in condition D,
above. In a change from the initial modification notice, the facility will not be adding a third pellet
mill, nor will they be increasing the grain storage, roller mill processing, or shipping capacity, as
identified under conditions A-C, above.

Mr. Bird/UDAQ RMEC PJ21E-4223
Page 2 of 4 February 10, 2025

The approved 5-TPH pellet mill was added to the MFM AO in response to a Notice of Intent (NOI)
dated October 8, 2018, by Kleinfelder. As with the new proposed pellet mills, emissions from the
existing 5-TPH pellet mill are controlled by a cyclone. For operational purposes, Pitman Farms
would like the pellet mills to be identified in the AO as follows:
▪ PM1: 30-TPH Pellet Mill (controlled by a cyclone)
▪ PM2: 5-TPH Pellet Mill (controlled by a cyclone and is included in the current AO)
Based on the manufacturer ratings of these units, the combined pellet mill production capacity of
the MFM will be 35 TPH. Accounting for 24-hour/day operations five (5) day per week, along with
maintenance and startup operations, Pitman estimates the maximum runtime for the pellet mills
will be 4,550 hours per year.
A summary of total estimated annual throughput and associated PM10 emission increases for each
of the pellet mills is provided in the attached Table 1. As indicated in Table 1, the addition of the
PM1 and increased production hours will result in 138,450-ton increase in pelletized feed
production. Accounting for the 20,800 tons per year of thruput currently allotted under the AO,
Pitman hereby requests to that condition D of Section II.B.1.b be revised to reflect “159,250 tons
of grains processed through the pelletizers per rolling 12-month period”.
As indicated in the attached Table 1, the increased pellet mill production will result in a 14.50 TPY
increase in PM10 emissions.
SUMMARY OF EMISSION LIMIT MODIFICATIONS
Table 2, below, provides a summary of the total emission adjustments for the MFM facility based
on the current permit limits and the proposed modifications:
Table 2: Current and Proposed Criteria Pollutant Emission Levels
HOURS OF
OPERATION
EMISSIONS (Tons per Year)
CO NOx SO2 VOCs PM10 PM2.5 HAPs CO2e
Proposed Net
Emission Increase - - - - 14.50 - - -
Current Permitted
Emission Levels1 6.14 5.33 0.10 0.43 9.78 0.89 0.14 8,717
New Requested
Permit Level 6.14 5.33 0.10 0.43 32.38 0.89 0.14 8,717
1 Current permitted emission levels are based on amounts proposed in modification request dated
July 20, 2022. The revised AO associated with the modification has not been issued as of the date of
this letter.

Mr. Bird/UDAQ RMEC PJ21E-4223
Page 3 of 4 February 10, 2025

PM10 BACT ANALYSIS
Technological Feasibility
The PM1 Pellet Mill is an asset that is being transferred from another Pitman Farms facility and
included a cyclone. A high-efficiency cyclone is the next technologically feasible control option.
A comparison of the PM10 emissions from the operation of the PM1 unit with a standard and high
efficiency cyclone is provided in the attached Table 3. As indicated in Table 3, the total PM10
emissions from 136,500 tons of thruput for PM1 with would be 7.13 tons per year, yielding a 7.17
ton-per-year reduction from the standard cyclone.
Economic Analysis for Upgrading PM1 to a High Efficiency Cyclone
With regard to the economic analysis, the asset being transferred to the MFM already has a
standard cyclone; therefore, economic analysis is evaluated based on the upgrade to the high
efficiency option. A quote from CPM and J.Blackwell for the high efficiency upgrade for this unit
is provided in Exhibit A. Based on information from Pitman Farms, the high efficiency package
uses a softer metal that will require frequent repairs and would result in an additional $3,500 in
annual maintenance costs and materials in comparison to the current standard cyclone.
The annualized cost of PM10 removal over a 10-year period was calculated using the equations
provided in UAC R307-101:
A = (B + C)/D
Where:
A = Annualized cost expressed in dollars per ton of pollutant (PM10) removed
B = Annualized equipment cost in $/year = PV{i/[1-(1 + i)-n]
Where:
PV = present day cost of the equipment and installation
i = the interest rate at which Pitman Farms can borrow the money for the
high efficiency cyclone and installation (assumed to be 8.5%)
n = Number of years of life in the equipment (assumed to be 15 years)
C = Annual operating cost of the equipment
D = Amount of emission reduction due to the installation and operation of the
pollution control equipment
Cost for a high efficiency cyclone and required upgrades to the pellet mill = $447,302. Annual
maintenance costs are as follows (Pitman Farms–supplied data):
Annual Operating Costs (maintenance, parts, etc.) - $3,500
The cost analysis is as follows:
▪ Cost of high efficiency cyclone installed (PV) …………………………..….......$447,302
▪ Interest Rate for borrowing )………………………………………..………………...8.5%
▪ Life of Equipment (n)……………………….……………….…...........10 years (n=0.152)
▪ B=PV{i/[1-(1 + i)-n]}……………………………………………….……….…….$68,172
▪ Annual Operating Costs (C)…………………………………….……………….......$3,500
Mr. Bird/UDAQ RMEC PJ21E-4223
Page 4 of 4 February 10, 2025

▪ Emission Reduction (D)…………………………………………………………....7.17 tpy

Applying the BACT analysis equation provided in UAC R307-101, the annualized cost (A) per
ton of VOC removed:
A = (B + C) / D
= ($68,172 + $3,500) / 7.17 tons
= $10,001 / ton
Based on this BACT analysis equation, the 15-year amortized cost for the high efficiency control
option for PM2 Pellet Mill amounts to an annual cost of $10,001 per ton of PM10 removed. The
overall cost of this control option is not considered to be economically feasible, particularly
considering the site is not within a PM10 “non-attainment area”.
CLOSING
Thank you for your attention to this request. If you have any questions or need additional
information, please contact me at 801.467.3661 or by email at [e-mail].

Sincerely,

Daryl Hancock, CHMM, CEM
Principal Scientist
RMEC ENVIRONMENTAL, INC.

Attachments:

Tables
Table 1: Summary of PM10 Emissions for Grains Processed Through Pellet Mills
Table 3: Summary of PM10 Emissions for Grains Processed Through Pellet Mills

Exhibits
Exhibit A: Quote for Upgrade of PM1 to High Efficiency Cyclone

Cc: Luke Freeman, Pitman Farms (electronic copy)

Table 1: Summary of PM10 Emissions for Grains Processed
Through Pellet Mills
Rating Annual Runtime Revised Total Thruput Current Permitted Thruput Increased Thruput Total
(tons per hour)(hours)(tons/year)(tons/year)(tons/year)
PM1 30 4,550 136,500 0 136,500
PM2 5 4,550 22,750 20,800 1,950
159,250 20,800 138,450
Throughput PM (filterable) Emission
Factor
PM (condensible)
Emission Factor Total PM Emission Factor Total PM10 Emission Factor Total Increased PM10
Emissions
(tons/year)(lb/ton)1 (lb/ton)1 (lb/ton)2 (lbs/ton)3 (tons/year)4
PM1 136,500 0.36 0.059 0.419 0.2095 14.30
PM2 1,950 0.36 0.059 0.419 0.2095 0.20
14.50
1. Pellet Cooler with a cyclone (SCC-3-02-008-16) Table 9.9.1-2 Particulate Emission Factors For Grain Processing Facilities.
2. Total PM EF = PM (filterable) EF + PM (condensible) EF
3. Note g of Table 9.9.1-2 allows for 50% factor for estimating emission factor for PM10 from PM.
4. Annual Emissions (tons/year)= Throughput (ton/yr) x Emission factor (lb/ton) x 1/2000 (ton/pound)
PM1 136,500 0.15 0.059 0.209 0.1045 7.13
7.37
PM10
(tons/year)
Increased Emissions:14.50
Current AO Permitted Limit:9.78
Total PM10 Emissions 24.28
Total Increased PM10 Emissions
High Efficiency Cylcone Emission Factor
Comparitive Reduction Standard Cyclone vs. High Efficiency Cyclone:
Unit ID
Table 1: Summary of PM10 Emissions for Grains Processed Through Pellet Mills
Total Pelletized Feed Production Total
Unit ID

Table 3: Summary of PM10 Emissions for Grains Processed
Through Pellet Mills

Increased Pellet Mill
Thruput Total PM10 Emission Factor PM10 Emissions Total PM10 Emission Factor PM10 Emissions
(tons per year)(lbs/ton)3 (tons/year)4 (lbs/ton)3 (tons/year)4
PM1 136,500 0.2095 14.30 0.1045 7.13
BER 14.30
AER 7.13
ER 7.17
E 50%
Feasible
Effective
Feasible
Most Effective
Step 2: Rank options by tech. feasibility and control effectiveness.
Baseline Emissions Rate - est. reduction in PM10 emissions from base case. (tons/year)
Allowable Emissions Rate - projected tons/year after implementation of control (tons/year)
Emissions Reduction. ER = BER-AER (tons/year)
Overall pollution reduction efficiency (%) (E = (ER/BER)*100)
Table 3: Summary of Economic Analysis of Upgrading to High Efficiency Cyclone
Unit ID
Feasibility
Control Effectiveness
Cyclone (base case)High-Efficiency Cyclone (upgrade)Control Technology
Step 1: Best available control technologies

Exhibit A: Quote for Upgrade of PM1 to High Efficiency
Cyclone

Document Date
Customer No.
Page
26/Jan/2024 1/2
Your Reference
EmailShip To:
▌SALES QUOTATION
Document Number
QU 1020043725
Bill To:
Shipping Via:Incoterms:
-
[e-mail]
Sales Rep
Brian Austin
US Shipping Terms
FOB Origin
CPM Contact
Matthew Schams
Pitman Farms
[e-mail]
PO Box 308
Moroni, UT 84646
US
Moroni Turkey Processing
Plant
Moroni Turkey Processing
Plant
350 S 300 W
Moroni, UT 84646
US
Merrimack, NH, 03054
Crawfordsville, IN, 47933
Waterloo IA, 50703
St. Charles, MO. 63301
U.S.
Tax ID - 06-1612491
Product: Turkey Feed
Pellet size: 11/64"
Estimated capacity: 40 TPH
This quote replaces quote 1020042757 dated 22 / November / 2023
Currency: USD
Description Quantity TotalPriceItem No.
Counterflow Cooler 19-480-4 182,508.00 182,508.00001 1FEA01603
RF 14 x 36 Rotary Feeder - constructed of 304 SS
1 hp, 3 phase 460 volt TEFC gearmotor wirh coupling and safety shield
Bliss Leveler with 2HP, 3 Phase 460 volt TEFC motor,drive, and safety shield
304 Stainless Steel top and walls with Mild Steel construction on fixed grid, and louver discharge
Hinged Service Door
(2) Inspection Windows
Fixed Grid
(3) Rotary Level Sensors
Air Management Ring
Louver Discharge operated by (1) Air Cylinder
Custom Discharge Hopper with bolted service panel
Micro Safety Switch on Service Door
423.00 423.00002 1Extra Rotary Level Sensor for additional product
9,128.00 9,128.00003 1Electric Control Panel “to operate cooler only” NEMA 12
Enclosure
5,654.00 5,654.00004 1Air Control Damper at cooler exhaust w/air cylinder and
solenoid valve
A VFD on the fan motor is recommended and would replace the Air Control Damper
895.00 895.00005 1Explosion Proof 100 Watt Light Fixture in cooler with conduit to
outside
RTD Temp Snsr 9" -328 To 400F
316SS Sheath, 1/2NPT Fitting
344.00 1,032.00006 310114102
Temperature probes for pellet temperature, ambient temperature, and duct temperature
007
Required air is 27,000 ACFM at 20" static pressure drop008
2/2
Page
26/Jan/2024
Document Date
▌SALES QUOTATION
Document Number
1020043725
Merrimack, NH, 03054
Crawfordsville, IN, 47933
Waterloo IA, 50703
St. Charles, MO. 63301
U.S.
Tax ID - 06-1612491
Currency: USD
Description Description Quantity TotalPriceItem No.
009
83,492.00 83,492.00010 1TCF RTF 360 Class 23, Fan
Includes 150 HP motor
motor mount
damper
011
91,957.00 91,957.00012 1MAC3HE43SS Dust Collector
High Efficiency 3 unit cyclone with
ducting to a common inlet.
Stainless Steel Construction
Full Welded Exterior
Expansion chamber with 8" inspection point
CW inlet rotation is standard
9" gathering auger at discharge is included
19,453.00 19,453.00013 1MAC MD40 Series Rotary Airlock Stainless Steel
Payment Term 50% Down, Balance Before Ship
Quotation Valid Until: 29/Feb/2024
Estimated lead time: 20 weeks after receipt of signed approval drawings
Lead time subject to change based on timing of order
CPM Equipment to be painted Oyster White; Black/Grey
Subject To CPM Standard Terms and Conditions Of Sale Unless Otherwise Agreed In Writing
Estimate
Date
4/22/2024
Work order #
643
Name / Address
Pitman Family Farm
Processing Plant
Moroni, Utah
Ship To Or Install location
Feed Mill
Attn. Jason Carr
Pellet Cooler
J. Blackweld
Hc 13 box 3203
Chester, UT 84623
P.O. No.Terms
Net 10 days
Rep FOB Project Contact phone
Signature _____________________________________
Phone #
435-436-8042
Fax #
435-436-8042
E-mail
[e-mail]
Total
Subtotal
Sales Tax (0.0%)
Description Qty Cost Color Total
PELLET COOLER INSTALL: Remove the old Cyclone
and frame, Remove old ducting, Remove both coolers,
Modify the stainless steel upper drag, Assemble and
install the new cooler, Add to the legs of the new cooler
to create the correct elevation for flow to the output drag,
Create a transition from the from the new cooler to the
output drag, Build a structure to support the new
cyclones, Connect the cyclones to the dust drag, Install
compressed air lines to support the cooler, Fabricate a fan
stand for the new large fan on the roof.
52,760.00 52,760.00
The equipment ; cooler ;cyclone and dust drag to be
supplied by others.
The duct work is not included in this estimate, their are to
many unknown's; like the size and type of the ducting;
insulation type; location of the duct path.
Page 1
Estimate
Date
4/22/2024
Work order #
643
Name / Address
Pitman Family Farm
Processing Plant
Moroni, Utah
Ship To Or Install location
Feed Mill
Attn. Jason Carr
Pellet Cooler
J. Blackweld
Hc 13 box 3203
Chester, UT 84623
P.O. No.Terms
Net 10 days
Rep FOB Project Contact phone
Signature _____________________________________
Phone #
435-436-8042
Fax #
435-436-8042
E-mail
[e-mail]
Total
Subtotal
Sales Tax (0.0%)
Description Qty Cost Color Total
Note: The removal and installation of the new equipment
along with all of the necessary connections could take up
to 7 days. This is due partly to the fact that we need to
remove equipment that is in service to place the new
equipment. Anything that can be prepared before a shut
down will be, but some components will have to be built
in place. The 7 days of install is not a hard number every
effort would be made to minimize that number.
Page 2
$52,760.00
$52,760.00
$0.00
476 WEST 325 SOUTH, BOUNTIFUL, UTAH 84010
TEL: [phone] EMAIL: [e-mail] WEB: RMEC.NET
RMEC PP21E-4223
June 30, 2023
Bryce Bird
Director
Utah Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
SUBJECT: PERMIT MODIFICATION REQUEST
Re: Pitman Farms – Moroni Feed Mill
UDAQ Approval Order: DAQE-AN106440002-21
15 East 1900 South Feed Mill Road
Moroni, UT 84646
Dear Mr. Bird:
On behalf of Pitman Farms, RMEC Environmental, Inc. (RMEC) is hereby providing the Utah
Division of Air Quality (UDAQ) with the following modification request regarding the above-
referenced Approval Order (AO). This modification is for the increase in roller mill and grain
shipping operations along with the addition of two (2) new pellet mills to support increased
pelletized feed production. The proposed modifications will result in an increase of particulate
matter (PM) emissions.
MODIFICATION DETAILS
Approved equipment under the current AO for the site includes one (1) pelletizer, or pellet mill,
which has a manufacturer’s production capacity rating of 5-tons per hour (TPH). Pitman Farms is
transitioning feed production operations at the Moroni Feed Mill (MFM) to 100% pelletized feed
and is requesting to add a second pellet mill with a 30-TPH rating along with a third pellet mill
having a 20-TPH manufacturer rating. Both pellet mills be connected to cyclones for emission
control purposes.
Section II.B.1.b of the current AO for the MFM stipulates the following operation and production
limits:
A.250,000 tons of received grains per rolling 12-month period
B.150,000 tons of shipped grains per rolling 12-month period
C.150,000 tons of grains processed through the roller mill per rolling 12-month period
D.20,800 tons of grains processed through the pelletizer per rolling 12-month period
More of the grain received at the MFM will be processed into pellets, but the facility will not be
increasing the grain storage capacity. As such, the increased pellet production capacity is not
anticipated to impact the amount of grain received (identified under condition A above). However,
with the added pellet mills and increased pellet production capacity (condition D above) the MFM
Mr. Bird/UDAQ RMEC PJ21E-4223
Page 2 of 5 June 30, 2023

476 WEST 325 SOUTH, BOUNTIFUL, UTAH 84010
TEL: [phone] EMAIL: [e-mail] WEB: RMEC.NET

will be increasing the amount of grains shipped (condition B above) and grains processed through
the roller mill (condition C above). Both conditions will be increased from 150,000 to 200,000 tons
per 12-month rolling period.
Increased Emissions from Additional Pellet Mills
The approved 5-TPH pellet mill was added to the MFM AO in response to a Notice of Intent (NOI)
dated October 8, 2018, by Kleinfelder. As with the new proposed pellet mills, emissions from the
existing 5-TPH pellet mill are controlled by a cyclone. For operational purposes, Pitman Farms
would like the pellet mills to be identified in the AO as follows:
§ PM1: 30-TPH Pellet Mill (controlled by a cyclone)
§ PM2: 5-TPH Pellet Mill (controlled by a cyclone and is included in the current AO)
§ PM3: 20-TPH Pellet Mill (controlled by a cyclone)
Based on the manufacturer ratings of these three (3) units, the combined pellet mill production
capacity of the MFM will be 55 TPH. Given that 100% of feed will be converted to a pelletized
mix, the total volume of pellet mill processing (condition D of AO Section II.B.1.b) should not
exceed the 250,000-ton constraint on grain receiving (condition A of AO Section II.B.1.b). The
total runtime for each feed mill will vary depending on the various types of feed pellets being
produced within each 12-month period. For emission estimation purposes, the runtime for each unit
can be approximated by assuming parity between the units and dividing the 250,000-ton constraint
by the combined pellet mill production capacity (55 TPH). This approximation equates to a total
of 4,545.45 hours of runtime for each pellet mill.
A summary of total throughput for the pellets mills is provided in the Table 1, below:
Table 1: Summary of Total Pellet Mill Throughput
Unit ID Rating
(tons per hour)
Estimated
Annual Runtime
(hours)1
Estimated Throughput Total
(tons/year)1
PM1 30 4,545.45 136,364
PM2 5 4,545.45 22,727
PM3 20 4,545.45 90,909
Total Pellet Production Limitation 250,000
1 The runtime and balance of throughput for each unit may vary from the amounts estimated above;
however, the total combined throughput of the units will not exceed 250,000.
A summary of PM10 emissions for each pellet mill is provided in Table 2, on the following page,
based on these total throughput estimates.

Mr. Bird/UDAQ RMEC PJ21E-4223
Page 3 of 5 June 30, 2023

476 WEST 325 SOUTH, BOUNTIFUL, UTAH 84010
TEL: [phone] EMAIL: [e-mail] WEB: RMEC.NET

Table 2: Summary of Total PM10 Emissions from Pellet Mill Operations
Unit ID Throughput
(tons/year)
PM
(filterable)
Emission
Factor
(lb/ton)1
PM
(condensible)
Emission
Factor
(lb/ton)1
Total PM
Emission
Factor
(lb/ton)2
Total PM10
Emission
Factor
(lb/ton)3
PM10
Emissions
(tons/year)4
PM1 136,364 0.36 0.059 0.419 0.2095 14.28
PM2 22,727 0.36 0.059 0.419 0.2095 2.38
PM3 90,909 0.36 0.059 0.419 0.2095 9.52
Total PM10 Emissions 26.19
1 Pellet Cooler with a cyclone (SCC-3-02-008-16) Table 9.9.1-2 Particulate Emission Factors For Grain
Processing Facilities. 2 Total PM EF = PM (filterable) EF + PM (condensible) EF.
3 Note g of Table 9.9.1-2 allows for 50% factor for estimating emission factor for PM10 from PM.
4 Annual Emissions (tons/year) = Throughput (ton/yr) x Emission factor (lb/ton) x 1/2000 (ton/pound)
Table 8 of the 2018 NOI estimates that total PM10 emissions from the pellet mill process at 4.36
tons per year (TPY) based on an annual throughput of 20,800 TPY. This method of calculation is
consistent with the calculations provided above; however, it appears that the total PM emission
factor was used instead of the PM10 emission factor. As a result, the estimated PM10 emissions
provided in the 2018 NOI for the pellet mill were estimated at double the intended amount. The
correct PM10 emission estimate for the current throughput of 20,800 TPY should be 2.18 instead of
4.36 TPY. Based on the current permit allotment of 4.36 TPY, the addition of the two (2) pellet
mills and increased throughput from 20,800 TPY to 250,000 will result in a 21.83 TPY increase
in PM10 emissions (26.19 TPY – 4.36 TPY).
Increased Emissions from Additional Grain Shipping
Table 3, below, provides an updated estimate of PM10 emissions based on 200,000 TPY of grain
shipment throughput:
Table 3: Summary of Total PM10 Emissions from Increased Grain Shipping
Unit ID Throughput
(tons per year)
Total PM10
Emission Factor
(lb/ton)1
Throughput Total
(tons/year) 2
Grain Shipping 200,000 0.0008 0.08
Total PM10 Emissions 0.08
1 Feed shipping (SCC 3-02-008-03) PM10 emission factor obtained from AP-42 Table 9.9.1-2 Particulate
Emission Factors for Grain Processing Facilities.
2 Annual Emissions (tons/year) = Throughput (ton/yr) x Emission factor (lb/ton) x 1/2000 (ton/pound)
As presented in Table 5 of the 2018 NOI, PM10 emission associated 150,000 tons of grain shipping
were estimated at 0.06 TPY. The 50,000 TPY increase in grain shipping will result in a total
increase of 0.02 TPY of PM10 emissions (0.08 TPY- 0.06 TPY).
Mr. Bird/UDAQ RMEC PJ21E-4223
Page 4 of 5 June 30, 2023

476 WEST 325 SOUTH, BOUNTIFUL, UTAH 84010
TEL: [phone] EMAIL: [e-mail] WEB: RMEC.NET

Increased Emissions from Additional Roller Mill Processing
Table 4, below, provides an updated estimate of PM10 emissions based on 200,000 TPY of roller
mill processing throughput:
Table 4: Summary of Total PM10 Emissions from Increased Roller Mill Processing
Unit ID Throughput
(tons/year)
PM
(filterable)
Emission
Factor
(lb/ton)1
Total PM10
Emission
Factor with
Cyclone
(lb/ton)2
Total PM 10
Emission
Factor
Adjustment
w/out
Cyclone
(lb/ton)3
Total PM10
Emission
Factor
Adjustment
for Enclosure
(lb/ton)4
PM10
Emissions
(tons/year)5
Roller
Mill 200,000 0.024 0.012 0.060 0.030 3.00
Total PM10 Emissions 3.00
1 Grain cracker (SCC 3-02-008-19) with Cyclone PM emission factor from AP-42 Table 9.9.1-2 Particulate
Emission Factors for Grain Processing Facilities.
2 Note g of Table 9.9.1-2 allows for 50% factor for estimating emission factor for PM10 from PM.
3 Back-calculated uncontrolled emission factor by assuming cyclone provides control efficiency = 80%
4 Since chopper equipment is located within a partial enclosure, a control factor was assumed to be = 50%
5 Annual Emissions (tons/year) = Throughput (ton/yr) x Emission factor (lb/ton) x 1/2000 (ton/pound)
As presented in Table 7 of the 2018 NOI, PM10 emission associated 150,000 tons of grain
processing in the roller mill was estimated at 2.25 TPY. The 50,000 TPY increase in grain shipping
will result in a total increase of 0.75 TPY of PM10 emissions (3.00 TPY- 2.25 TPY).
SUMMARY OF EMISSION LIMIT MODIFICATIONS
As presented in the prior section, the following emission limitation adjustments are being
proposed:
§ 21.83 TPY increase in PM10 emissions from increased pellet mill production
§ 0.02 TPY increase in PM10 emissions from increased grain shipping
§ 0.75 TPY increase in PM10 emissions from increased roller mill processing
The proposed modification results in a total of 22.60 tons of increased PM10 emissions.
Table 5, on the following page, provides a summary of the total emission adjustments for the
MFM facility based on the current permit limits and the proposed modifications:

Mr. Bird/UDAQ RMEC PJ21E-4223
Page 5 of 5 June 30, 2023

476 WEST 325 SOUTH, BOUNTIFUL, UTAH 84010
TEL: [phone] EMAIL: [e-mail] WEB: RMEC.NET

Table 5: Current and Proposed Criteria Pollutant Emission Levels
HOURS OF
OPERATION
EMISSIONS (Tons per Year)
CO NOx SO2 VOCs PM10 PM2.5 HAPs CO2e
Proposed Net
Emission Increase - - - - 22.60 - - -
Current Permitted
Emission Levels1 6.14 5.33 0.10 0.43 9.78 0.89 0.14 8,717
New Requested
Permit Level 6.14 5.33 0.10 0.43 32.38 0.89 0.14 8,717
1 Current permitted emission levels are based on amounts proposed in modification request dated
July 20, 2022. The revised AO associated with the modification has not been issued as of the date of
this letter.
CLOSING
Thank you for your attention to this request. If you have any questions or need additional
information, please contact me at 801.467.3661 or by email at [e-mail].

Sincerely,

Daryl Hancock, CHMM, CEM
Principal Scientist
RMEC ENVIRONMENTAL, INC.

Attachments:

Cc: Luke Freeman, Pitman Farms (electronic copy)