DAQ-2024-004856

1
DAQC-CI117980001-24
Site ID 11798 (B1)

MEMORANDUM

TO: FILE – CINTAS – Industrial Laundry

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: January 16, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: November 15, 2023

SOURCE LOCATION: 1671 South 4370 West
Salt Lake City, UT 84104
SOURCE CONTACTS: Casey Davis, Manager
801.972.4697 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Industrial laundry services. The facility utilizes water washing
techniques to clean uniforms and other work items such as mats,
rugs, and maintenance towels (shop and printer).

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN117980010-15, dated October
21, 2015.
NSPS (Part 60) Dc: Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units,

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Cintas - Industrial Laundry
27 Whitney Drive 1671 South 4370 West
Milford, OH 45150 Salt Lake City, UT 84104

SIC Code: 7218: (Industrial Launderers)

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]

2
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]

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

I.6 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

Status: Out of Compliance. Unapproved equipment was observed at the time of inspection.
See Section II below for more details. No limits set forth in this AO appear to have been
exceeded. The equipment appeared to be properly operated and maintained according to
manufacturer recommendations. Records are kept as required and were made available
after the inspection. No breakdowns have been reported since the previous inspection. An
emissions inventory was submitted for 2022, and emissions data are reported below.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Industrial Laundry

II.A.2 Boiler #1
Capacity: 5.23 MMBtu/hr
Manufacturer: Cleaver-Brooks
Model: CB200-125
Includes: Stack Economizer

II.A.3 One (1) Steam Tunnel*
Capacity: less than 5 MMBtu/hr

II.A.4 Washer #1
Capacity: 900 lbs (Clean Dry Basis)

II.A.5 Washer #2
Capacity: 675 lbs (Clean Dry Basis)

II.A.6 Washer #3*
Capacity: 800 lbs (Clean Dry Basis)

II.A.7 Washer #4*
Capacity: 800 lbs (Clean Dry Basis)

II.A.8 Washer #5
Capacity: 800 lbs (Clean Dry Basis)
3
II.A.9 Washer #6
Capacity: 800 lbs (Clean Dry Basis)

II.A.10 Washer #7*
Capacity: 60 lbs (Clean Dry Basis)

II.A.11 Washer #8
Capacity: 85 lbs (Clean Dry Basis)

II.A.12 Washer #9
Capacity: 675 lbs (Clean Dry Basis)

II.A.13 Washer #10
Capacity: 125 lbs (Clean Dry Basis)

II.A.14 Washer #11*
Capacity: 450 lbs (Clean Dry Basis)

II.A.15 Dryer #1
Capacity: 120 lbs (Clean Dry Basis)

II.A.16 Dryer #2
Capacity: 120 lbs (Clean Dry Basis)

II.A.17 Dryer #3
Capacity: 600 lbs (Clean Dry Basis)

II.A.18 Dryer #4
Capacity: 600 lbs (Clean Dry Basis)

II.A.19 Dryer #5
Capacity: 600 lbs (Clean Dry Basis)

II.A.20 One (1) Air Make-Up Unit
Capacity: 5.225 MMBtu/hr
Manufacturer: Rapid Engineering
Model: SA-60

II.A.21 Six (6) Space Heaters
Capacity: 0.105 MMBtu/hr each

II.A.22 Six (6) Space Heaters
Capacity: 0.09 MMBtu/hr each

II.A.23 Four (4) Roof-Top HVAC Units
Capacity: 0.065 MMBtu/hr each

* New or modified equipment

Status: Out of Compliance. Unapproved equipment was observed at the time of inspection. 2
extra space heaters for a total of 14, and 2 extra HVAC units for a total of 6, were
observed at the time of inspection. Additionally, the input ratings listed on the AO do
not match all of the manufacturer's plates on the space heaters. A Compliance
Advisory was sent on December 7, 2023 (see DAQC-1311-23). The source responded
on December 21, 2023. An Early Settlement Agreement (ESA) was issued on January
12, 2024 (see DAQC-027-24). No further action is recommended at this time.

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II.B Requirements and Limitations

II.B.1 The Industrial Laundry shall be subject to the following:

II.B.1.a The owner/operator shall notify the Director in writing when the new or modified equipment
listed in this AO has been installed and is operational. To ensure proper credit when notifying the
Director, send your correspondence to the Director, attn: Compliance Section.

If the owner/operator has not notified the Director in writing within 18 months from the date of
this AO on the status of the construction and/or installation, the Director shall require
documentation of the continuous construction and/or installation of the operation. If a continuous
program of construction and/or installation is not proceeding, the Director may revoke the AO.
[R307-401-8]

Status: In Compliance. On November 6, 2017, the source submitted a notice to change the
company name to Cintas Corporation from G & K Services Inc. The notification included
that the plant is now operating under the current Approval Order.

II.B.1.b The owner/operator shall not exceed 65 million standard cubic feet of natural gas consumed for
the entire plant 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
consumption shall be kept for all periods when the plant is in operation. Natural gas consumption
shall be determined by billing statements. [R307-401-8]

Status: In Compliance. For the rolling 12-month period from October 2022 - September
2023, a total of 21.066 million cubic feet of natural gas was consumed.

II.B.1.c The owner/operator shall not allow visible emissions from any stationary point or fugitive
emission source on site to exceed 10 percent opacity. [R307-401-8]

II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9. [R307-305-3]

Status: In Compliance. No visible emissions were observed from any point at the time of
inspection. Method 9 was utilized to verify opacity limits. See attached VEO form.

II.B.1.d The owner/operator shall use only natural gas as fuel in the boiler, the dryers, the heaters, the
steam tunnel, and the air makeup unit. [R307-401-8]

Status: In Compliance. Only natural gas is used in the boiler, dryers, heaters, steam tunnel,
and air makeup unit.

II.B.2 VOC and HAP Limitations.

II.B.2.a Prior to laundering, the owner/operator shall store the soiled print towels in appropriate
containers with closed lids and in a designated location. [R307-401-8]

Status: In Compliance. Towels are stored properly in closed containers with lids. Soiled
shop towels are stored in waste bags or 55-gallon drums in a designated area until
processed. Print towels are not currently laundered at this facility at this time.

II.B.2.b The plant-wide emissions of VOCs and HAPs from the washing and drying of industrial wipers
shall not exceed:

65.91 tons per rolling 12-month period for VOCs
3.99 tons per rolling 12-month period for any individual HAP
7.04 tons per rolling 12-month period for all HAPs combined
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The HAPs stated above include benzene, cumene, dichlorobenzene, ethyl benzene,
formaldehyde, hexane, methanol, methylene chloride, naphthalene, toluene, and xylenes.
[R307-401-8]

II.B.2.b.1 Compliance with each limitation shall be determined on a rolling 12-month total. Based on the
last day of each month, a new 12-month total shall be calculated using data from the previous
twelve months. Monthly calculations shall be made no later than the last day after the end of each
calendar month. [R307-401-8]

II.B.2.b.2 The VOC and HAP emissions shall be determined by maintaining a record of VOC- and HAP-
emitting materials used each month. The record shall include the following data for each material
used:

A. The quantity (in pounds) of soiled shop towels and soiled print towels

B. The amount of VOC shall be calculated using the following values:

11 lbs of VOC per 1000 lbs of soiled shop towels
101 lbs of VOC per 1000 lbs of soiled print towels

(The weight of the towels used for calculation purposes shall be the weight when
received and not the laundered weight.)

C. HAP emission factors are based on test results and are listed in the NOI submitted in
March, 2015.

D. The amount of VOC or HAPs emitted monthly from all materials used. [R307-401-8]

Status: In Compliance. All emissions are currently only from shop towels. The source
stated that they no longer wash print towels. For the rolling 12-month period from October
2022 - September 2023, emissions are as follows.

VOCs: 1.3831125 tons
HAPs: 0.3581004 tons

Total HAP emissions are less than 3.99 tons, so no individual HAP exceeded 3.99 tons for
emissions. See the attached spreadsheet for more details.

Section III: APPLICABLE FEDERAL REQUIREMENTS

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.

NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units

Status: In Compliance. The applicable requirement associated with this subpart is to maintain records
of natural gas use. This requirement is satisfied as all-natural gas consumed at the source location is
provided by a local natural gas utility.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. No visible emissions were observed at the time of inspection. See the attached
VEO form for more information.

Standards of Performance for New Stationary Sources [R307-210]

Status: Compliance with this area source rule is satisfied by compliance with Federal Requirements
NSPS (Part 60) Subpart Dc. See Section III above for more information.

Davis and Salt Lake Counties and Ozone Nonattainment Areas: Ozone Provisions [R307-325]

Status: In Compliance. No VOC containing materials were observed spilled, discarded, stored in
open containers, or handled in any other way that would result in greater evaporation.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Cintas - Industrial Laundry from the
2022 emissions reporting year. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN117980010-15, dated October 21, 2015, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 3923.00 N/A
Carbon Monoxide 2.73 0.91594
Nitrogen Oxides 3.25 3.38823
Particulate Matter - PM10 23.97 0.07208
Particulate Matter - PM2.5 23.97 0.07208
Sulfur Dioxide 0.02 0.00049
Volatile Organic Compounds 65.91 1.59619

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 N/A
Cumene (CAS #98828) 520 N/A
Dichlorobenzene (CAS #25321226) 0 N/A
Ethyl Benzene (CAS #100414) 2040 N/A
Formaldehyde (CAS #50000) 5 N/A
Generic HAPs (CAS #GHAPS) 0 N/A
Hexane (CAS #110543) 149 N/A
Methanol (CAS #67561) 606 N/A
Methylene Chloride (Dichloromethane) (CAS #75092) 32 N/A
Naphthalene (CAS #91203) 11 N/A
Tetrachloroethylene (Perchloroethylene) (CAS #127184) 1300 N/A
Toluene (CAS #108883) 5260 N/A
Trichloroethylene (CAS #79016) 100 N/A
Xylenes (Isomers And Mixture) (CAS #1330207) 5382 N/A

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PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN117980010-15,
dated October 21, 2015: Not in compliance at the time of
inspection. A Compliance Advisory was issued on December 7,
2023 (see DAQC-1311-23). An ESA was issued on January 12,
2024 (see DAQC-027-24). No further action is recommended at
this time.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect again with new AO to ensure all space heaters and
HVAC units are accounted for on the AO.

NSR RECOMMENDATIONS: New AO will need to account for all space heaters and HVAC
units. Ensure that space heaters input ratings match the plates.
Remove print towels from Condition II.B.2.b.2 as these are no
longer used at the facility.

ATTACHMENTS: VEO form, email correspondence, VOC and HAP emissions
1/16/24, 9:28 AM State of Utah Mail - 11798 - follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-1094330771337207098&simpl=msg-a:r-1555373790655…1/2
Daniel Riddle <[e-mail]>
11798 - follow up to air quality inspection
4 messages
Daniel Riddle <[e-mail]>Mon, Nov 20, 2023 at 10:36 AM
To: [e-mail], [e-mail]
Casey and Mike,
I met with Mike last week for an air quality inspection. As discussed, these are the records I will require to complete my inspection report:
From AO DAQE-AN117980010-15:
Condition II.B.1.b - natural gas consumption (Oct 22 - Sept 23)
Condition II.B.2.b - VOC & itemized HAP emissions (Oct 22 - Sept 23)
We observed that there are 14 heaters on site, with only 12 permitted, and the output does not match the AO. We also noted 6 HVAC units on the
roof, with only 4 permitted. I will discuss with my manager about the difference in equipment present vs. what's permitted. You may need to eventually
renew your permit to accurately represent your equipment.
Please provide these records by November 28, 2023. Let me know if you have any questions.
Best,
Daniel
--
Daniel Riddle (he/him)
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Davis, Casey <[e-mail]>Fri, Nov 24, 2023 at 12:48 PM
To: Daniel Riddle <[e-mail]>
Cc: "Koehler, Stephen" <[e-mail]>
Daniel,

Attached is the calculator for the emissions on shop towels. We no longer wash inker towels on site.

Natural gas calculations from our gas bills so that we used 21.066 Million Cubic feet of natural gas.

Thank you

Casey Davis | Maintenance Supervisor
Cintas Corporation #14K
office 801.972.4697 | cell 801.580.7912
1671 S 4370 W Salt Lake City, UT 84104
[e-mail] | cintas.com
1/16/24, 9:28 AM State of Utah Mail - 11798 - follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r-1094330771337207098&simpl=msg-a:r-1555373790655…2/2

From: Daniel Riddle <[e-mail]>
Sent: Monday, November 20, 2023 10:37 AM
To: Burns, Michael <[e-mail]>; Davis, Casey <[e-mail]>
Subject: 11798 - follow up to air quality inspection

Casey and Mike, I met with Mike last week for an air quality inspection. As discussed, these are the records I will require to complete my inspection report: From AO DAQE-AN117980010-15: Condition II. B. 1. b - natural gas consumption (Oct 22
[Quoted text hidden]
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Copy of 14K Air Permit Compliance Calculator.xlsx
15K
Daniel Riddle <[e-mail]>Wed, Dec 6, 2023 at 11:29 AM
To: "Davis, Casey" <[e-mail]>
Cc: "Koehler, Stephen" <[e-mail]>
Casey,
It looks like the formula came through incorrectly. You have reported washing shop towels, but the VOC and HAP emissions are all 0, even though
the factor is 11 lbs of VOC per 1000 lbs of soiled shop towels. Could you please send a corrected spreadsheet?
[Quoted text hidden]
Davis, Casey <[e-mail]>Thu, Dec 7, 2023 at 1:00 PM
To: Daniel Riddle <[e-mail]>
Attached is the corrected spread sheet.
[Quoted text hidden]
[Quoted text hidden]
14K Air Permit Compliance Calculator_corrected.xlsx
22K
Emission Factor [lb/1000 lbs Soiled Shop Towels Laundered]
Month Pounds Shop Towels Pounds Print Towels Rolling 12 VOC [tonsRolling 12 HAP [tons
Oct-22 16947 0
Nov-22 13299 0
Dec-22 20061 0
Jan-23 20569 0
Feb-23 20641 0
Mar-23 26377 0
Apr-23 19201 0
May-23 22587 0
Jun-23 23380 0
Jul-23 20899 0
Aug-23 25610 0
Sep-23 21904 0 1.3831125 0.3581004
11 0.011 0.005 0.045 0.127
VOC [lbs]Methyl Chloride [lbs n-Hexane [lbs]1,2-Dichloroethane Trichloroethene [lbs
186.417 0.186417 0.084735 0.762615 2.152269
146.289 0.146289 0.066495 0.598455 1.688973
220.671 0.220671 0.100305 0.902745 2.547747
226.259 0.226259 0.102845 0.925605 2.612263
227.051 0.227051 0.103205 0.928845 2.621407
290.147 0.290147 0.131885 1.186965 3.349879
211.211 0.211211 0.096005 0.864045 2.438527
248.457 0.248457 0.112935 1.016415 2.868549
257.18 0.25718 0.1169 1.0521 2.96926
229.889 0.229889 0.104495 0.940455 2.654173
281.71 0.28171 0.12805 1.15245 3.25247
240.944 0.240944 0.10952 0.98568 2.781808
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0.837 1.134 0.068 0.214 0.214
Toluene [lbs]Tetrachloroethene [Ethylbenzene [lbs]m-Xylene [lbs]p-Xylene [lbs]
14.184639 19.217898 1.152396 3.626658 3.626658
11.131263 15.081066 0.904332 2.845986 2.845986
16.791057 22.749174 1.364148 4.293054 4.293054
17.216253 23.325246 1.398692 4.401766 4.401766
17.276517 23.406894 1.403588 4.417174 4.417174
22.077549 29.911518 1.793636 5.644678 5.644678
16.071237 21.773934 1.305668 4.109014 4.109014
18.905319 25.613658 1.535916 4.833618 4.833618
19.56906 26.51292 1.58984 5.00332 5.00332
17.492463 23.699466 1.421132 4.472386 4.472386
21.43557 29.04174 1.74148 5.48054 5.48054
18.333648 24.839136 1.489472 4.687456 4.687456
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0.059 0.013 0.011 0 0.06
o-Xylene [lbs]Cumene [lbs]Napthalene [lbs]Benzene [lbs]4-Methyl-2-pentano
0.999873 0.220311 0.186417 0 1.01682
0.784641 0.172887 0.146289 0 0.79794
1.183599 0.260793 0.220671 0 1.20366
1.213571 0.267397 0.226259 0 1.23414
1.217819 0.268333 0.227051 0 1.23846
1.556243 0.342901 0.290147 0 1.58262
1.132859 0.249613 0.211211 0 1.15206
1.332633 0.293631 0.248457 0 1.35522
1.37942 0.30394 0.25718 0 1.4028
1.233041 0.271687 0.229889 0 1.25394
1.51099 0.33293 0.28171 0 1.5366
1.292336 0.284752 0.240944 0 1.31424
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0 0 0 0 0
0.05 0
Methanol [lbs]Methylene Diphenyl Isocyanate [lbs]
0.84735 0
0.66495 0
1.00305 0
1.02845 0
1.03205 0
1.31885 0
0.96005 0
1.12935 0
1.169 0
1.04495 0
1.2805 0
1.0952 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0