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Home My WebLink AboutDAQ-2024-0109721 DAQC-CI108120002-24 Site ID 10812 (B1) MEMORANDUM TO: FILE – NESTLE USA PREPARED FOODS DIVISION INC. – Prepared Foods Processing Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Conner Kijowski, Environmental Scientist DATE: September 6, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Utah County INSPECTION DATE: June 26, 2024 SOURCE LOCATION: 815 West Raymond Klauck Way Springville, UT 84663 SOURCE CONTACTS: Shannon Carr, Regional Environmental Specialist 586-718-3339, shannon.carr@us.nestle.com Melissa Wall, HSE Manager 801-830-6806, melissa.wall1@us.nestle.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Nestle is a frozen food producer. Food ingredients and premanufactured packaging materials are shipped in by truck and off-loaded into the receiving/storage areas with electric forklifts. Food is processed in batches (lots). After a lot has been produced, the equipment is washed, sanitized, and set up for the next production lot. Each lot is produced as follows: ingredient handlers load ingredients, by weight, into large carts and push the carts to the appropriate food processing line where, depending on the recipe, the ingredients are sliced, diced, chopped, mixed, cooked/baked, and/or blanched. The processed food is packaged on an automated packaging line. Immediately following packaging, the food is conveyed on a conveyor belt through a large ammonia freezer unit. The packaged food remains in freezer units for 4 hours. The frozen food exits the freezer, is placed on pallets for shipment, and placed in cold storage to await customer shipment. Baking is done in four natural gas-fired Heat & Control, Model E, multipurpose baking ovens, each rated at 5.0 MMBTU/hr. Prepared food is placed on each oven's conveyor belt, carried through the oven, and exits (cooked). Each oven is equipped with two 12"-diameter exhaust stacks which vent to the atmosphere 43' above ground level. 2 Steam is produced for the steam kettles by two natural gas-fired English Boiler Company 89.61 MMBtu/hr fire tube steam boilers. Water is circulated through burner-heated tubes inside the boilers and converted to steam. The steam is then pumped through the facility's steam kettles to cook the food. The cooled steam/condensed water from the kettles is then recirculated back to the boilers for reheating. Each of the boilers is equipped with 30"-diameter exhaust stacks which vents to the atmosphere 43' above ground level. If needed, the ovens and boilers can be fired using the facility's two-day emergency supply of propane. There are two Ford emergency diesel generators that supply the facility with electricity for emergency lighting only during power outages. Emissions from the diesel generators are vented through 6"-diameter exhaust vents on the roof. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN108120010-21, dated May 5, 2021 NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: Name of Permittee: Permitted Location: Nestle USA Prepared Foods Division Inc. - Prepared Foods Processing Plant 815 West Raymond Klauck Way 815 West Raymond Klauck Way Springville, UT 84663 Springville, UT 84663 SIC Code: 2038: (Frozen Specialties, NEC) 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] 3 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] Status: In Compliance. Each condition from Section I was reviewed with the source and appeared to be in compliance. The 2023 Emission Inventory was submitted by the required date. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Prepared Foods Processing Plant Source Wide II.A.2 Four (4) Ovens Fuel Type: Natural Gas, or Propane Heating Capacity: 5.0 MMBtu/hr - each II.A.3 Two (2) Boilers Fuel Type: Natural Gas, or Propane Heating Capacity: 89.61 MMBtu/hr - each II.A.4 Two (2) Emergency Generator Engines Fuel Type: Natural Gas, or Propane Electrical Output: 100 kW - each II.A.5 One (1) Fire System Pump Engine (**NEW**) Fuel Type: Diesel Maximum Rating: 400 hp NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.6 One (1) Emergency Generator Engine Fuel Type: Diesel Power Output: 35 hp II.A.7 One (1) Fabric Filter Baghouse Manufacturer: Torit & Day II.A.8 Two (2) Fabric Filter Baghouses Manufacturer: Semco TBS Bag Collection Systems 4 II.A.9 Miscellaneous Equipment Items - listed for informational purposes only - Two (2) Fabric Filter Baghouses (one attached to the semolina flour receiving tank - exhaust directed to interior equipment (the sifter device); one attached to the base ingredients room - exhaust directed to other interior food production areas) Assorted shop equipment items Status: In Compliance. No unpermitted equipment was observed. Additional Information: II.A.2: One oven has been replaced with a fully electric oven. Three Safety Kleen solvent parts washers were observed during the inspection, one in the maintenance shop, and two in the port truck shop. II.B Requirements and Limitations II.B.1 The Prepared Foods Processing Plant shall be subject to the following: II.B.1.a Visible emissions from the following emission points shall not exceed the following values: A. Baghouses which exhaust to the atmosphere - 10% opacity B. Boilers - 10% opacity C. Ovens - 10% opacity D. Engines - 10% opacity E. All other emission points - 20% 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. [R307-305-3] Status: In Compliance. No visible emissions were observed from any of the listed emission points. Only steam was observed. Refer to the VEO form in the attachments for more details. II.B.1.b The owner/operator shall not allow emissions of NOx from all combustion-related operations to exceed 65 tons per rolling 12-month period. To demonstrate compliance with this NOx limitation, the owner/operator shall multiply natural gas consumption by an emission factor to determine total NOx emissions according to the following equation: NOx - EF * N Where: N = rolling 12-month total natural gas usage EF = 50 lb NOx/106 standard cubic feet (scf) natural gas consumed (1,000 scf = 1 decatherm; therefore, 106 scf = 1,000 decatherms) The owner/operator shall maintain a record of natural gas consumption on a monthly basis. Natural gas consumption shall be determined by billing records from the natural gas supplier. By the 20th day of each month a rolling 12-month total shall be determined using data from the previous 12 months. [R307-401-8] 5 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 twentieth 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. The records of natural gas consumption shall be kept on a monthly basis. Natural gas consumption shall be determined by examination of fuel supplier billing records. [R307-401-8] Status: In Compliance. The rolling 12-month NOx emissions from all combustion-related operations from June 2023 - May 2024, indicated 10.4 tons. Calculations are made according to this condition. The rolling 12-month total natural gas consumption from June 2023 - May 2024, indicated 411,855 decatherms. See the attachment for additional information. Nestle maintains records of monthly natural gas consumption from fuel supplier billing records as required by this AO. II.B.2 Engine Requirement II.B.2.a The owner/operator shall not operate each emergency engine or fire pump 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, R307-401-8] II.B.2.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 each emergency engine or fire pump engine shall be kept in a log and shall include the following: A. The date the emergency engine or fire pump engine was used B. The duration of operation in hours C. The reason for the emergency engine or fire pump engine usage. [40 CFR 60 Subpart ZZZZ, R307-401-8] II.B.2.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine and fire pump engine. [40 CFR 60 Subpart ZZZZ, R307-401-8] Status: In Compliance. Each engine operated less than 100 hours for the rolling 12-month period. Logs are kept detailing the date, duration, and reason for engine usage. Refer to the attachments for more details. Each engine is equipped with a non-resettable hour meter which was viewed during the inspection. II.B.3 Baghouse Requirements II.B.3.a The Torit & Day baghouse shall control process streams from the dry ingredients room. All exhaust air from the dry ingredients room shall be routed through the Torit & Day baghouse before being vented to the atmosphere. [R307-401-8] Status: In Compliance. All the exhaust air from the dry ingredients room is routed through the Torit and Day Baghouse before venting to the atmosphere as required by this condition. II.B.3.b The two Semco baghouses shall control process streams from the two Semolina flour receiving storage silos. All exhaust air from the flour storage silos shall be routed through the Semco baghouses before being vented to the atmosphere. [R307-401-8] Status: In Compliance. All exhaust air from the flour storage silos are routed to the Semco Baghouses before venting to the atmosphere as required by this condition. 6 II.B.4 Fuel Requirements. II.B.4.a The owner/operator shall use only natural gas as primary fuel and propane as back-up fuel in the two boilers, four ovens and two 100 kW emergency generators listed in the equipment list. [R307-401-8] Status: In Compliance. The two boilers, three ovens, and two 100kW emergency generator engines only use natural gas as the primary fuel. One oven has been replaced by a fully electric oven. II.B.4.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the diesel-fired emergency engines and fire pump engine. 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.4.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, 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] Status: In Compliance. Only ultra-low sulfur diesel fuel is used in the diesel-fired emergency engines and fire pump engine. This was determined by a fuel purchase invoice provided by the supplier, Rhinehart Oil. This invoice was viewed during the site visit. 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. Nestle operates two natural gas 89.61 MMBtu/hr boilers constructed in 2001. The boilers can also be fired with propane in the event of a natural gas curtailment. The rolling 12-month total natural gas consumption from June 2023 - May 2024, indicated 411,855 decatherms. Propane was not used during this period. See the attachment for additional information. NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. The 2010, 35 hp Cummins diesel-fueled emergency generator and the 2019, 400 hp Clark/John Deere fire pump are characterized as constructed after July 11, 2005, and manufactured after April 1, 2006. According to the Exhaust Emission Compliance Statement, the 2010, 35 hp Cummins is considered EPA Tier 4. Refer to the previous inspection memo for more details (DAQC-1138-23). Nestle maintains records of maintenance activities performed on the emergency generators. Refer to the attachments for more details. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Status: In Compliance. The 2013, 134 hp Cummins natural gas-fueled emergency generator is characterized as greater than or equal to 100 hp that commenced construction after June 12, 2006, and manufactured on or after January 1, 2009. The EPA Exhaust Emission Compliance Statement can be referred to in the previous inspection memo (DAQC-1138-23). 7 MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. The 1987, 134 hp Onan natural gas-fueled emergency generator is characterized as an existing stationary engine less than 500 hp located at Area Source of HAP Emergency Spark Ignition before June 12, 2006. Each emergency generator engine and fire pump engine are equipped with a non-resettable hour meter. Ultra-low sulfur fuel is utilized and was verified during the site visit. Maintenance is performed according to manufacturer recommendations and recorded. 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. Fuel was verified to be ultra-low sulfur according to a fuel purchase invoice provided by the supplier, Rhinehart Oil. This invoice was viewed during the site visit. Stationary Sources [R307-210] Status: In Compliance. This area source rule is satisfied through compliance with NSPS Subpart IIII, Subpart JJJJ, and Subpart Dc listed above. Refer to the Federal Requirements section for more details. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. This area source rule is satisfied through compliance with MACT Subpart ZZZZ. Refer to the Federal Requirements section for more details. Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. No fugitive emissions or dust were viewed during the inspection. The site is fully paved and the potential for fugitive emissions are low. Degreasing and Solvent Cleaning Operations [R307-335] Status: In Compliance. Three parts washers were observed on site. R307-335-4 requires the lid to be closed except during actual loading, unloading, or handling of parts. The parts washer lids were closed, had instructions posted, and used solvent was stored in a tank beneath the washer. All equipment appeared to be in good operating condition and no leaks were observed. 8 EMISSION INVENTORY: Listed below are the 2023 Actual Emissions Inventory provided from Nestle USA Prepared Foods Division Inc. - Prepared Foods Processing Plant. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN108120010-21, dated May 5, 2021, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 82034.00 N/A Carbon Monoxide 48.31 16.84 Nitrogen Oxides 65.00 10.11 Particulate Matter - PM10 3.35 1.54 Particulate Matter - PM2.5 3.35 1.54 Sulfur Dioxide 1.83 0.12 Volatile Organic Compounds 2.61 1.11 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Generic HAPs (CAS #GHAPS) 2380 N/A PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions in the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN108120010-21, dated May 5, 2021, the overall status is: In Compliance. The source appears to be well maintained and operated. Records were current and provided in a timely manner. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect at the regular interval. Required PPE includes steel-toe boots, reflective vest, and safety glasses. NSR RECOMMENDATIONS: Evaluate the removal of one oven listed in II.A.2 Add the three parts washers to the next AO during the next modification ATTACHMENTS: VEO form, email attachment which includes: NOx emission totals, natural gas consumption, emergency engine operating hours, and logs. STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY Page _of_ EPA METHOD 9 -VISIBLE EMISSION OBSERVATION FORM Source Name: fv&stl.-~ fq,.J.s bcuss,~ I/Mt: Street Address: ~\'5 W &••f MOid \C\11udc' ltJ11y City/County: S~f:i~ille, /vttY.. Phone: ?o\-iZo-(pful, Site ID: 1(}8:\1..-: Facility: ~ t>«:od,,d-,on Equipment/Process: Q\JU\S, Soilu:S I Gttuc,\ot-Eq,•tt.S Control Equipment: b~ Emission Point: :,~c>c.s Sky Conditions: Clear [ ] Partly Cloudy [ ] Overcast ( ] Precipitation: No [ ] Yes [ ] Wind: Direction: __ _ Speed: __ _ mph Ambient Temp: _____ °F RH: __ _ % Height Relative to Observer: Distance From Ob~..:irver: Cond~nsed 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. 0 IJr..i"' nonh ..i,u,~ • observer --------=-- Sun ♦ Wind ► Emission Point with Plume (_),____, Observer Position X Observer's Signature: Oistrib: white-file; canary-inspecto , pink-owner/operator OBSERVATION DATE: ft;, l'U lZ<!'I Start time: \ \ 'v&J Stop time: II:'"¾ sec 0 15 30 45 min 1 ---~ -2 3 // I,.,,' 4 1/ -~ J 5 /., .....__,,, 6 ,/ 7 8 9 10 11 12 , , ·.,~., .. ; . ,,. ., , 1'olh~ 12--~ Pt.,.;oo1 ~IL ~~-M0v. 1 ZO~- COMMENTS'! ' :n:-. &-1 bi T°"' of A/0,c c,"1:\\fol for: o:,w,., 1,z..-~~ 1t=,6.'.7reJ\. ~ E.Mt.ro""j ~We:/ ho:-A,,....r E.~,i!Q. 0 ?.u-a lry H OUd I have received a co o ese observ • s: SIGNATU Title: Springville Nestle USA 815 Raymond Klauck Way Springville, UT 84663 Dear Mr. Connor Kijowski, In regard to your documentation request, please see below: Condition II.B.1.b: Tons of NOx emitted for the rolling 12-month period (June 2023 - May 2024); monthly natural gas consumption records During the time period requested, and based on our fuel consumption, we have a total of 10.4 tons of NOx emitted. Monthly natural gas records: Condition II.B.2.a: Each emergency engine and fire pump engine total operating hours for the rolling 12- month period Fire pump engine: diesel, 23.4 hours Emergency NH3 generator: diesel, 46.1 hours Emergency generator mezzanine: natural gas, 34.9 hours Emergency generator ESR-1: natural gas, 33.6 hours Condition II.B.2.a.1: Each engine's operation log which includes the date, duration and reason for usage. Please see log. Equipment First date Log time (hrs) Last date Log time (hrs) Duration (hrs) Reason for usage Fire pump engine 6/2/2023 101.3 5/26/2024 124.7 23.4 PMs- weekly Emergency NH3 generator 5/11/2023 139.5 5/12/2024 185.6 46.1 PMs- 4 weeks Emergency generator mezzanine 6/26/2023 160 5/27/2024 194.9 34.9 PMs- 4 weeks Emergency generator ESR-1: 6/13/2023 690.5 5/24/2024 724.1 33.6 PMs- 4 weeks Please don’t hesitate to reach out via email or phone 586-718-3339. Thank you, Shannon Carr