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Home My WebLink AboutDAQ-2024-0077521 DAQC-CI129190001-24 Site ID 12919 (B1) MEMORANDUM TO: FILE – TREEHOUSE FOODS, INC. THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: April 10, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Weber County INSPECTION DATE: April 4, 2024 SOURCE LOCATION: 215 North 700 West Ogden, UT 84404 DIRECTIONS: The office is located at 400 North and 700 West, Building 5-D. On the south side of 400 North there is a parking area in between the brown building and the white building. The office is at the south end of the parking lot. SOURCE CONTACTS: Jerine Price, Environmental, Health and Safety Manager 801-706-2530 jerine.price@treehousefoods.com OPERATING STATUS: Operating normally. PROCESS DESCRIPTION: TreeHouse Foods, Inc. produces baked goods such as cookies and waffles. Flower and sugar are brought in by truck and pneumatically fed into the facility's seven silos. Each silo is equipped with a bin vent. The source operates 12 baking lines each with a natural gas oven. There is also one natural gas oven used for research and development. There are three baghouses that capture flour and sugar particles, but all three vent internally. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN129190008-18, dated February 28, 2018. MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, SOURCE EVALUATION: Name of Permittee: Permitted Location: TreeHouse Foods, Inc. 215 North 700 West 215 North 700 West Ogden, UT 84404 Ogden, UT 84404 SIC Code: 2052: (Cookies & Crackers) 0 0 2 Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 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 notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] Status: In Compliance. No limits appear to have been exceeded. No modifications have been made to equipment or process. Maintenance is conducted following a PM schedule and records are maintained. No reportable breakdowns have occurred since the previous inspection. A 2023 emission inventory has been submitted to DAQ. The previous inspector confirmed all equipment had been installed within the 18-month notification period. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 TreeHouse Foods, Inc. Bakery Products II.A.2 Ovens 1 - 4 Rating: 6.0 MMBtu/hr each Fuel: Natural Gas Four burners each II.A.3 Ovens 5 - 6 Rating: 3.0 MMBtu/hr each Fuel: Natural Gas Two burners each 3 II.A.4 Ovens 7 - 8 Rating: 4.5 MMBtu/hr each Fuel: Natural Gas Three burners each II.A.5 Ovens 9 - 10 Rating: 1.74 MMBtu/hr each Fuel: Natural Gas One burner each II.A.6 Oven 11 Rating: 1.2 MMBtu/hr Fuel: Natural Gas II.A.7 Oven 14 (New) Rating: 2 MMBtu/hr Fuel: Natural Gas II.A.8 Research & Development Oven Rating: 0.065 MMBtu/hr Fuel: Natural Gas II.A.9 Miscellaneous Boilers and Heaters Maximum Rated Capacity: less than 5.0 MMBtu/hr each Fuel: Natural Gas II.A.10 Three (3) Flour Silos Control: 1,570 acfm bin vent and fabric filter II.A.11 Four (4) Sugar Silos Control: 750 acfm bin vent and cartridge paper filters II.A.12 Two (2) Water Heaters Rating: 5.5 MMBtu/hr each Fuel: Natural Gas II.A.13 Emergency Generator Engine Maximum electrical output: 20 kW Fuel: Diesel MACT Subpart ZZZZ II.A.14 Two (2) Parts Washers (listed for informational purposes only) II.A.15 Three (3) Baghouses Baghouses for general dust control inside the building that exhaust inside the building (listed for informational purposes only) Status: In Compliance. The equipment observed on site is consistent with that listed. At the time of inspection, the Oven 14 line was not operating due to lack of demand. 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 opacities: A. All diesel engines - 20% B. All baghouses and bin vents that vent to the atmosphere- 5% 4 C. All other points including fugitive emissions - 5%. [R307-305-3, 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] Status: In Compliance. No visible emissions were observed from any point during the inspection. II.B.1.b The owner/operator shall only use leavening agents (such as baking powder) and/or liquid oils that do not produce VOC emissions in the baking processes. [R307-401-8] Status: In Compliance. The source indicated that only leavening agents such as baking powder and/or liquid oils are used in the baking process. II.B.1.c The owner/operator shall not use fermentation in its baking process. [R307-401-8] Status: In Compliance. The source stated that no fermentation is used in the baking process. II.B.1.d VOC and/or HAPs containing materials shall be stored in covered containers (except when in use). VOC and/or HAPs laden rags shall also be stored in covered containers. [R307-401-8] Status: In compliance. All VOC/HAPs containing materials are stored in closed containers. VOC/HAPs soiled rags are kept in containers with closed lids. II.B.2 Fuel Limitations. II.B.2.a The owner/operator shall not combust more than 643,202 decatherms of natural gas per rolling 12-month period. [R307-401-8] II.B.2.a.1 Compliance with the natural gas limitation shall be determined on a rolling 12-month total. No later than 20 days after the end of each month, a new 12-month total shall be calculated 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 records. [R307-401-8] Status: In Compliance. Natural gas is supplied by Dominion Energy. The 12-month rolling total was 84,973.5 decatherms of natural gas. Natural gas consumption is determined from billing records. II.B.3 Silo Limitation. II.B.3.a All exhaust air from the flour and sugar silos shall be routed through a bin vent filter before being vented to the atmosphere. [R307-401-8] Status: In Compliance. Each silo is equipped with a bin vent. Air only flows through the bin vents when the silos are being loaded. Bin vent filters were changed at the end of June 2023. A PM schedule is followed for filters. II.B.4 Emergency Generator Engine Requirements II.B.4.a The owner/operator shall not operate the 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 engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th 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: 5 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] Status: In Compliance. The emergency generator operated for 18.5 hours during the rolling 12-month period. The generator has a non-resettable hour meter which read 719.2 at the time of inspection. The source maintains a log with the required information. II.B.4.b The sulfur content of any fuel oil or diesel burned in any emergency generator engines shall not exceed 15 ppm by weight. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.b.1 The sulfur content shall be determined by ASTM Method D2880-71, D4294-89, or approved equivalent. Certification of fuels shall be either the owner/operator's own testing, or test reports from the fuel marketer. [R307-203-1] Status: In Compliance. The generator operates on ultra-low sulfur diesel fuel which is delivered by Power Systems West which purchases it from Maverick Oil. 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. MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. The emergency generator operated 18.5 hours for testing and maintenance during the 12-month rolling period. Regular maintenance is conducted. The generator is equipped with a non-resettable hour meter. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. Ultra-low sulfur diesel fuel is used in the emergency generator. Fuel is purchased from Maverick Oil. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. This rule is met by compliance with MACT (Part 63), ZZZZ. Solvent Cleaning [R307-304] Status: In Compliance. The source uses Safety-Kleen Premium which has a vapor pressure of <1 mm Hg at 20 C which is under the required 8 mm Hg at 20 C. Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305] Status: In Compliance. No visible emissions were observed from any point during the inspection. 6 Degreasing [R307-335] Status: In Compliance. The source has two parts washers and both have lids and instructions posted on the inside of the lid. Lids are kept closed when not in use and waste rags are stored in closed containers. EMISSION INVENTORY: Listed are the Actual Emissions Inventory provided from TreeHouse Foods, Inc. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN129190008-18, dated February 28, 2018. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 37628.00 Carbon Monoxide 26.49 3.8587 Nitrogen Oxides 31.14 4.6018 Particulate Matter - PM10 4.91 4.6562 Particulate Matter - PM2.5 4.91 0.3497 Sulfur Dioxide 0.19 0.0283 Volatile Organic Compounds 18.44 0.2534 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Benzene (Including Benzene From Gasoline) (CAS #71432) 1 <0.00001 Dichlorobenzene (CAS #25321226) 1 Formaldehyde (CAS #50000) 47 0.00345 Hexane (CAS #110543) 1136 0.08263 Toluene (CAS #108883) 2 0.00016 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN129190008-18, dated February 28, 2018: the source should be considered in compliance. Records were made available at the time of inspection for review. The facility appeared to be well maintained and properly operated. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. Be prepared to present credentials to include Driver's License Card and State of Utah Badge. Be ready to review a Safety Training Video. No finger nail polish, fake fingernails, and fake eyelashes are allowed. Additional PPE will also include hair nets provided by the source, safety glasses with protective shields, a shirt provided by the source. Follow all handwashing instructions as directed. Contact the environmental staff prior to the inspection so they can be on the lookout for you. 7 NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: VEO Form.