Loading...
HomeMy WebLinkAboutDAQ-2024-0109841 DAQC-CI126630001-24 Site ID 12663 (B1) MEMORANDUM TO: FILE – DFA DAIRY BRANDS ICE CREAM, LLC dba MEADOW GOLD – Ice Cream Manufacturing Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: September 17, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Washington County INSPECTION DATE: August 15, 2024 SOURCE LOCATION: 1310 East Commerce Drive St. George, UT 84790 SOURCE CONTACTS: Tracy Ginger, Plant Manager tracy.ginger@dfamilk.com Sone Phimsouay, Plant Engineer 435-218-2358, sone.phimsouay@dfamilk.com Matt Hitch, Quality Supervisor OPERATING STATUS: Operating normally. PROCESS DESCRIPTION: DFA Dairy Brands Ice Cream, dba Meadow Gold operates an ice cream plant in St. George. Dairy products such as milk and cream are combined in mixers with sweeteners and flavorings to form a homogenized ice cream product. A steam boiler with a low-NOx burner is used to heat the blending process and the dairy products, as well as heating various parts of the plant. The mixture is flash frozen to a soft-serve ice cream consistency. At that consistency, the ice cream is mixed with nuts, fruit, fudge, etc. Once mixed, the ice cream is pressed into square or round packages depending on the product line. The packaged product is then flash frozen to 20 degrees Fahrenheit and stored until it is shipped offsite by truck. A wet cooling tower is used to evaporate heat from the chillers in the refrigeration process. Wastewater from the plant is collected and treated at the wastewater treatment plant. Gases from the bacterial digesting of the waste in the wastewater treatment plant are collected. These gases are used to operate the boiler that controls the temperature for the wastewater in the storage tank. 0 0 2 Bio-solids are collected from the wastewater storage tank bottom and shipped offsite to a landfill. Treated water is released in the city wastewater stream. A flare is used at the wastewater treatment plant in the event that the gas pressure exceeds the set level, before it can be used in the biogas boiler. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN126630006-22, dated June 10, 2022 NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units SOURCE EVALUATION: Name of Permittee: Permitted Location: DFA Dairy Brands Ice Cream, LLC dba Meadow Gold – Ice Cream Manufacturing Facility 1310 East Commerce Drive 1310 East Commerce Drive St. George, UT 84790 St. George, UT 84790 SIC Code: 2024: (Ice Cream & Frozen Desserts) 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] 3 I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. No limits appear to have been exceeded. No modifications have been made to equipment or process. Records are maintained. Equipment is well maintained. No reportable breakdowns have occurred in the last 12 months. An emission inventory is not required by this source at this time. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 DFA Dairy Brands Ice Cream dba Meadow Gold Ice Cream Manufacturing Facility II.A.2 One (1) 350 HP Boiler Rating: 11.72 MMBtu/hr Fuel: Natural Gas NSPS Subpart Dc II.A.3 Sugar System One (1) Granular Sugar System including: One (1) storage silo One (1) bin vent One (1) baghouse II.A.4 Cooling Towers Two (2) Wet Cooling Towers II.A.5 Storage Tank One (1) Storage Tank Capacity: 6,000 gallons Service: diesel fuel II.A.6 Wastewater Treatment Plant One (1) Wastewater Treatment Plant Including One (1) bio-gas boiler One (1) WWTP flare Status: In Compliance. Item II.A.2's name plate indicated that the boiler is rated at 14.3 MMBtu, but was installed in 2002 at the time the original AO was issued (DAQE-AN2663001-02, dated May 28, 2002). The boiler in the wastewater treatment plant is rated <5 MMBtu. The 6,000 gallon diesel storage tank has not been in use for many years. No unapproved equipment was observed. 4 II.B Requirements and Limitations II.B.1 Plant-wide Requirements II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any emission unit on site to exceed 10% opacity. [R307-401-8] II.B.1.a.1 Unless otherwise specified in this AO, 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 Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed 20% opacity. [R307-401-8] II.B.1.b.1 Visible emissions determinations for traffic sources 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. Six points, distributed along the length of the haul road or in the operational area, shall be chosen by the Director or the Director's representative. An opacity reading shall be made at each point when a vehicle passes the selected points. Opacity readings shall be made not less than one-half (1/2) the vehicle length behind the vehicle and not less than one-half (1/2) the height of the vehicle. The accumulated six readings shall be averaged for the compliance value. [R307-205-5, R307-401-8] Status: In Compliance. The only road on site that is not paved is the road to the wastewater treatment plant which has very little traffic, and no visible emissions were observed on this road during the inspection. All other trucking and operation areas are paved. II.B.1.c The owner/operator shall use only natural gas as fuel in the 350 hp boiler. [R307-401-8] Status: In Compliance. Only natural gas is used as fuel in the 350 hp boiler. II.B.1.d The owner/operator shall use only biogas or natural gas from the wastewater treatment plant as fuel in the WWTP flare and boiler. [R307-401-8] Status: In Compliance. Only biogas is routed to the flare, and the boiler operates on biogas and natural gas. The wastewater treatment boiler is <5 MMBtu. II.B.2 VOC & HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (printing and cleaning) on site: 12.00 tons per rolling 12-month period of VOCs. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: 5 VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs reclaimed. The owner/operator shall subtract the amount of VOCs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs. [R307-401-8] II.B.2.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC-emitting material B. The maximum percent by weight of VOCs in each material used C. The density of each material used D. The volume of each VOC-emitting material used E. The amount of VOCs emitted from each material F. The amount of VOCs reclaimed and/or controlled from each material G. The total amount of VOCs emitted from all materials (in tons). [R307-401-8] Status: In Compliance. The 12-month rolling total of VOC emissions from printing was 0.015 tons. 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 boiler operates solely on natural gas. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205] Status: In Compliance. See status of conditions II.B.1.a and II.B.1.b. Stationary Sources [R307-210] Status: In Compliance. See status for NSPS (Part 60) Dc. 6 EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from DFA Dairy Brands Ice Cream, LLC dba Meadow Gold – Ice Cream Manufacturing Facility on the Approval Order (AO) DAQE-AN126630006-22, dated June 10, 2022. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 6075.00 Carbon Monoxide 18.00 Nitrogen Oxides 12.00 Particulate Matter - PM10 8.00 Particulate Matter - PM2.5 8.00 Sulfur Dioxide 10.00 Volatile Organic Compounds 12.00 Hazardous Air Pollutant PTE lbs/yr PREVIOUS ENFORCEMENT ACTIONS: None in the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN126630006-22, dated June 10, 2022, the overall status is: In Compliance. The facility appeared to be well maintained and operated properly. VOC records were supplied by email post inspection. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Check to see if the source has obtained a Small Source Exemption. Otherwise, inspect as normal. NSR RECOMMENDATIONS: Some of the staff believed the source had a Small Source Exemption (SSE) but upon further investigation it was discovered that only the Salt Lake plant had filed for an SSE. The source was directed to the SSE page on the DAQ website. Provided data of emissions indicate the source may qualify for the SSE. Item II.A.2's name plate indicated that the boiler is rated at 14.3 MMBtu, but was installed in 2002 at the time the original AO was issued (DAQE-AN2663001-02, dated May 28, 2002). This should be updated if the source updates their AO. ATTACHMENTS: VEO Form, VOC record, Emails. Jared James <jsjames@utah.gov> VOC Emissions 12 month report 2 messages Tracy Ginger <tracy.ginger@dfamilk.com>Wed, Sep 11, 2024 at 2:42 PM To: "jsjames@utah.gov" <jsjames@utah.gov> Cc: Doug Hampton <doug.hampton@dfamilk.com> I hope this is what you need, See attached. Thank You 20240911140345000.pdf 70K Jared James <jsjames@utah.gov>Wed, Sep 11, 2024 at 2:49 PM To: Tracy Ginger <tracy.ginger@dfamilk.com> Received, thank you. [Quoted text hidden] -- Jared James | Environmental Scientist | Minor Source Compliance Phone:385-306-6501 email: jsjames@utah.gov 195 North 1950 West, Salt Lake City, UT 84116 9/17/24, 4:17 PM State of Utah Mail - VOC Emissions 12 month report https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-f:1809933752220990866&simpl=msg-f:180993375222099086…1/1 Jared James <jsjames@utah.gov> Small Source Exemption - Air Quality 1 message Jared James <jsjames@utah.gov>Tue, Oct 1, 2024 at 1:48 PM To: Tracy Ginger <tracy.ginger@dfamilk.com>, Sone.phimsouay@dfamilk.com Cc: Alan Humpherys <ahumpherys@utah.gov> Tracy and Sone Here is Alan Humpherys information if you want to pursue obtaining a Small Source Exemption for the St. George plant: Alan Humpherys, New Source Review Section Manager 385-306-6520 ahumpherys@utah.gov -- Jared James | Environmental Scientist | Minor Source Compliance Phone:385-306-6501 email: jsjames@utah.gov 195 North 1950 West, Salt Lake City, UT 84116 10/1/24, 1:48 PM State of Utah Mail - Small Source Exemption - Air Quality https://mail.google.com/mail/u/0/?ik=2b4d965f6e&view=pt&search=all&permthid=thread-a:r9136689546240597067&simpl=msg-a:r-124319529407940…1/1