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Home My WebLink AboutDAQ-2024-0051361 DAQC-CI101630001-24 Site ID 10163 (B1) MEMORANDUM TO: FILE – KROGER COMPANY – Layton Manufacturing Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: January 16, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Davis County INSPECTION DATE: December 14, 2023 SOURCE LOCATION: 500 North Sugar Street Building #4 Layton, 84041-0527 SOURCE CONTACT: Jan Callister, Safety Regulatory Manager, 801-552-6447, Cell: 801-498-0431, jan.callister@kroger.com OPERATING STATUS: In operation PROCESS DESCRIPTION: This is a dairy and bakery products facility. The dairy facility has two steam boilers and the dough bakery has one boiler. All the boilers are fired on natural gas. The boilers also generate process steam and space heat for the dairy and bakery. One emergency generator is located in the "grocery" building. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN101630003-22, dated July 8, 2022 SOURCE EVALUATION: Name of Permittee: Permitted Location: Kroger Company, Layton Manufacturing - Layton Manufacturing Plant 500 North Sugar Street, Building. 4 500 North Sugar Street Building #4 Layton, UT 84041-0527 Layton, UT 84041-0527 SIC Code: 5461: (Retail Bakeries) Section I: GENERAL PROVISIONS I.1 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.2 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] / : 2 I.3 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.4 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.5 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.6 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.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. There are no modifications to the equipment or processes approved by this AO. Kroger maintains records of maintenance activities performed on approved equipment. There were no breakdowns that resulted in an emissions event. Kroger is not required to submit an Emissions Inventory Report at this time. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Kroger Company Layton Manufacturing Plant II.A.2 One (1) Dairy Boiler Fuel: Natural Gas Rating: 25.2 MMBTU/hr Type: Low-NOx Location: Dairy (building #3) With Flue Gas Recirculation II.A.3 One (1) Dairy Boiler Fuel: Natural Gas Rating: 25.2 MMBTU/hr Type: Low-NOx Location: Dairy (building #4) With Flue Gas Recirculation II.A.4 One (1) Bakery Boiler Fuel: Natural Gas Rating: 8.37 MMBTU/hr Location: Dairy (building #5) II.A.5 Miscellaneous Natural Gas-Fired Equipment Rating: each individual unit less than 10 MMBTU/hr Includes: Ovens, Fryers, Space Heaters, and Water Heaters 3 II.A.6 One (1) Emergency Generator Fuel: Natural Gas Output: 30KW Status: In Compliance. There was no new or unapproved equipment observed onsite during this inspection. SECTION II: SPECIAL PROVISIONS II.B II.B.1 REQUIREMENTS AND LIMITATIONS The Kroger Company Layton Manufacturing Plant shall be subject to the following: II.B.1.a The owner/operator shall not allow visible emissions from any stationary point or from the control facilities associated with the source to exceed 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. There were no visible emissions observed during this inspection. The opacity observations were conducted in accordance with 40 CFR 60, Appendix A, Method 9. II.B.2 Fuel Requirement II.B.2.a.1 The owner/operator shall use only natural gas as fuel in all boilers, water heaters, comfort heaters, and the emergency generator. [R307-401-8] Status: In Compliance. Kroger uses only natural gas as fuel in all boilers, water heaters, comfort heaters, and the Emergency Generator. II.B.2.b The owner/operator shall not consume more than 730 MMscf of natural gas per rolling 12-month period. [R307-401-8] Status: In Compliance. The rolling 12-month natural gas consumption from January to December 2023, indicated 72.1931 MMscf. II.B.2.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Install a flow meter on each boiler larger than 10 MMBTU/hr B. Record natural gas consumption based on monthly billings C. Use the consumption data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. [R307-401-8] Status: In Compliance. Kroger operates two boilers larger than 10 MMBTU/hr, and each boiler is equipped with a flow meter. See the pictures of the flow meters in the attachment. Kroger records the natural gas consumption based on monthly billings. II.B.3 Emergency Engine Requirement II.B.3.a The owner/operator shall not operate each emergency 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 engines during emergencies. [40 CFR 60 Subpart ZZZZ] Status: In Compliance. Kroger operates one 1986, 40 hp Onan, natural gas, Emergency Generator Engine. The rolling 12-month Emergency Generator usage hours from January to December 2023, indicated 34.4 hours. 4 II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall: A. Determine operational hours by examination of operational records B. Record operation hours in a log with date, hours of use, and reason for usage C. Use the operational hour data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. [40 CFR 60 Subpart ZZZZ] Status: In Compliance. The rolling 12-month total was determined from a record of logged hours of operation. II.B.3.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 60 Subpart ZZZZ] Status: In Compliance. The Emergency Generator is equipped with a non-resettable hour meter. 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. 40 CFR Part 60, Subpart Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Status: In Compliance. Kroger operates two 25.2 MMBTU/hr boilers on natural gas. The rolling 12-month natural gas consumption from January to December 2023, indicated 72.1931 MMscf. MACT (Part 63), ZZZZ: NESHAP for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. Kroger operates one 1986, 40 hp Onan, natural gas Emergency Generator Engine. This emergency generator is equipped with a non-resettable hour meter. The rolling 12-month Emergency Generator usage hours from January to December 2023, indicated 34.4 hours. According to Kroger, this Emergency Generator engine is maintained and operated according to the specifications of the manufacturer. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-210 - Standards of Performance for New Stationary Sources Status: In Compliance. This area source rule is applicable to 40 CFR Part 60, Subpart Dc. See Section III for compliance with this requirement. R307-214 - National Emission Standards for Hazardous Air Pollutants Status: In Compliance. This area source rule is applicable to MACT (Part 63), ZZZZ. See Section III for compliance with this requirement. 5 R307-335 – Degreasing Status: In Compliance. Kroger operates two Safety Kleen Parts-Washers to clean equipment parts using the Safety-Kleen Premium Solvent. This solvent is not applied to rags. The spent solvent is transported and disposed offsite by Safety Kleen. See the SDS and the email communication in the attachment. EMISSION INVENTORY: Kroger is not required to submit an Emissions Inventory Report at this time. Listed before are the Actual Emissions Inventory provided from Kroger Company, Layton Manufacturing, Layton Manufacturing Plant. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN101630003-22 dated July 8, 2022. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 30643.00 ---- Carbon Monoxide 28.34 N/A Nitrogen Oxides 15.50 N/A Particulate Matter - PM10 2.35 N/A Particulate Matter - PM2.5 2.35 N/A Sulfur Dioxide 0.32 N/A Volatile Organic Compounds 1.70 N/A Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: The Kroger Company is in compliance with the conditions in Approval Order (AO) DAQE- AN101630003-22 dated July 8, 2022. The Kroger Company maintained good housekeeping practices. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. Required PPE includes steel-toe boots and safety glasses. RECOMMENDATIONS FOR NSR: None at this time. ATTACHMENTS: Applicable Supporting Documentation Included