DAQ-2024-011000

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DAQC-CI103120001-24
Site ID 10312 (B1)

MEMORANDUM

TO: FILE – MOUNTAINVIEW MUSHROOMS

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: October 11, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Millard County

DATE OF INSPECTION: November 16, 2023

SOURCE LOCATION: 550 South 1100 West, Fillmore

DIRECTIONS: Take 2nd Fillmore exit (#163) from I-15 south. Turn west then north on
frontage road (1100 West) to 550 South.

SOURCE CONTACT: Carey Cramer, Facility Manager
435-214-4951, [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Mushroom farm. Compost components (alfalfa seed hull, gypsum,
straw, and dried poultry waste (DPW)) are delivered to the plant. The
compost, used to grow the mushrooms, is made on-site from the above
mentioned ingredients. The compost is placed in containers ~ 8-10”
deep, 4’ wide and 8’ long. The containers are put in a pasteurizing
room which is heated to 140° and then allowed to cool slowly (for as
long as 6 days). Pasteurization kills unwanted organisms in the
compost. The pasteurized containers are taken to a process room
where the contents are mixed with spore inoculated wheat grains. The
containers are then placed in a warm moist room for ~10 days,
allowing the fruiting body to grow. The containers are then covered
with a 1” layer of peat moss and placed into a room where the
temperature is lowered to cause fruiting, then raised to allow for
mushroom growth. The containers are harvested in an artificial fall
environment approximately 3 times over the course of 21 days. Once
the final harvest is made, the spent compost is returned to the spent
compost pile. The expected mushroom yield is 5 pounds per square
foot per harvest. Harvested mushrooms are classified according to
size, color, and quality and placed in plastic bins. The mushrooms are
then trucked throughout the state and surrounding areas. All heat is
provided by steam boilers. The boilers are fueled by natural gas or
diesel fuel #2 and are equipped with
low-NOx burners.

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APPLICABLE REGULATIONS: Approval Order (AO) DAQE-1027-92, dated October 29, 1992

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

The equipment listed in condition #2 of this AO shall be operated at the following location:

PLANT LOCATION:
400 South Park Avenue
Fillmore, UT 84631-9704

UTM: 4,313,500 Northing; 385,000 Easting

1. PictSweet shall install and operate a Cleaver Brooks 600 Horsepower gas fired boiler according to
the information submitted in the Notice of Intent dated March 13, 1992.

A copy of this Approval Order (AO) shall be posted on site. The AO shall be available to the
employees who operate the air emission producing equipment. These employees shall receive
instruction as to their responsibilities in operating the equipment in compliance with all of the
relevant conditions listed below.

Status: In Compliance. The 600 hp Cleaver Brooks gas fired boiler is not currently
operational (requiring replacement parts) and has been disconnected from the natural gas
line. A copy of the 1992 AO is kept on-site. All new employees receive instructions in proper
equipment operation.

The company is now owned and operated by Mountainview Mushrooms. The address is 550
South 1100 West in Fillmore.

2. The approved installations shall consist of the following equipment:

A. One Cleaver Brooks, 600 HP Natural gas-fired boiler, Serial Number L-88842 -
This boiler shall be equipped with low NOX burners and tail gas recirculating
system.

B. One Cleaver Brooks Model CP-200-300 oil/gas fired boiler - This boiler shall be
used for emergency purposes only. The standby boiler shall burn only natural gas
if available and #2 fuel oil if necessary.

Status: Out of Compliance. The equipment listed above was observed on site. The 600 hp
boiler (25 MMBtu/hr.) has been disconnected from the natural gas line, and requires
replacement parts prior to operating again.

The 300 hp boiler (12 MMBtu/hr.) appeared to be properly operated and maintained, and is
now considered the primary boiler. A Compliance Advisory (DAQC-1348-23) was issued as
this boiler is permitted for emergency purposes only. The source submitted a
Notice-Of-Intent (NOI) to include this equipment as the primary boiler and a Warning Letter
(DAQC-988-24) was issued to resolve the Compliance Advisory. It was confirmed by the
source that this boiler has only operated on natural gas for at least the previous two years.

A 100 hp (4 MMBtu/hr.) Seller’s natural gas boiler (installed in 2008 or 2009) is used as a
backup boiler. The Sellers boiler does not have to be permitted as it is less than 5 MMBtu/hr.
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3. The two existing Kewanee 250 Horsepower coal-fired boilers shall be removed from service.

Status: In Compliance. Both Kewanee coal-fired boilers have been removed.

4. This AO shall replace the AO’s dated March 20, 1984 and May 7, 1992.

Status: In Compliance. Only this AO was used to determine compliance.

5. The owner/operator shall use only natural gas as a primary fuel and #2 fuel oil for backup in the
standby boiler only if necessary. If any other fuel is to be used, an AO shall be required in
accordance with R307-1-3.1, UAC.

Status: In Compliance. The boilers have only operated on natural gas for at least the last two
years. No natural gas curtailments have occurred. No other fuels are used.

6. The sulfur content of any fuel oil burned shall not exceed 0.85 pounds of sulfur per million BTU
heat input as determined by ASTM Method D-4294-89 or approved equivalent. The sulfur content
shall be tested if directed by the Executive Secretary.

Status: In Compliance. Ultra-low sulfur diesel (ULSD) is delivered by RelaDyne. A recent
fuel purchase invoice provided by RelaDyne verified ULSD is utilized.

7. Emissions to the atmosphere from the exhaust stacks for the 600 HP replacement boiler shall not
exceed the following rates and concentrations:

A. NOx
1) 40 ppmdv (7% oxygen, dry)
2) 0.13 lb/hr

B. CO
1) 100 ppmdv (7% oxygen, dry)
2) 0.19 lb/hr

Status: Compliance Not Determined. The source has not been directed to perform stack
testing.

8. Stack Testing

Stack testing to show compliance with the emission limitations of condition #7 shall be performed
as specified below:

Emission Point Pollutant Testing Test
Status Frequency
Boiler Stack NOx * **
CO * **

Testing Status (To be applied above)
* No initial stack testing is required. However, the Executive Secretary may require
testing at any time in accordance with R307-1-3.4.1, UAC. The source shall be
tested if directed by the Executive Secretary.
** Test if directed by the Executive Secretary

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Notification

The applicant shall provide a notification of the test date at least 45 days prior to the test. A
pretest conference shall be held if directed by the Executive Secretary. It shall be held at
least 30 days prior to the test between the owner/operator, the tester, and the Executive
Secretary. The emission point shall be designed to conform to the requirements of 40 CFR
60, Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA)
or Mine Safety and Health Administration (MSHA) approvable access shall be provided to
the test location.

Sample Location

40 CFR 60. Appendix A, Method 1, if required by test method used

Volumetric flow rate

40 CFR 60, Appendix A, Method 2, if required by test method used

Nitrogen oxides

40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E

Carbon monoxide (CO)

40 CFR 60, Appendix A, Method 10

Calculations

To determine mass emission rates (lbs/hr, etc.), the pollutant concentration as determined
by the appropriate methods above shall be multiplied by the volumetric flow rate and any
necessary conversion factors determined by the Executive Secretary to give the results in
the specified units of the emission limitation.

Source Operation

The production rate during all compliance testing shall be no less than 38,200 lb/hr steam
produced.

Status: Compliance Not Determined. The source has not been directed to perform stack
testing.

9. Visible emissions from the boiler stack shall not exceed 10% opacity. Opacity observations of
emissions shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9.

Status: In Compliance. No visible emissions were observed from the 300 hp boiler stack. Only
steam was observed throughout the duration of the inspection. Refer to the VEO Form in the
attachments.

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10. The natural gas fuel consumption limit of 224 X 106 cubic feet of natural gas per 12-month period
shall not be exceeded without prior approval in accordance with R307-1-3.1, UAC.

Compliance with the annual limitation shall be determined on a rolling 12-month total. Based on
the first day of each month a new 12-month total shall be calculated using the previous 12 months.
Records of fuel consumption shall be kept for all periods when the plant is in operation. Records of
fuel consumption shall be made available to the Executive Secretary or his representative upon
request and shall include a period of two years ending with the date of the request. Fuel
consumption shall be determined by examination of fuel purchasing records. The records shall be
kept on a monthly basis.

Status: In Compliance. The source consumed 62.148 MMcf of natural gas for the 12-month
period ending in October 2023. Consumption is recorded monthly and was reviewed during
the inspection.

11. Executive Secretary shall be notified in writing upon start-up of the installation, as an initial
compliance inspection is required. Eighteen months from the date of this AO the Executive
Secretary shall be notified in writing of the status of construction/installation if
construction/installation is not completed. At that time the Executive Secretary shall require
documentation of the continuous construction/installation of the operation and may revoke the AO
in accordance with R307-1-3.1.5, UAC.

Status: In Compliance. An initial notification was not available in the source file. However,
an initial inspection was conducted in 1993 and ensuing inspections indicated that the
permitted equipment has been installed.

12. All records referenced in this AO or in an applicable NSPS or NESHAP, which are required to be
kept by the owner/operator, shall be made available to the Executive Secretary or his representative
upon request.

Status: In Compliance. All requested records were provided for review during the inspection.

13. All installations and facilities authorized by this AO shall be adequately and properly maintained.
The owner/operator shall comply with R307-1-3.5 and 4.7, UAC. R307-1-3.5, UAC addresses
emission inventory reporting requirements. R307-1-4.7, UAC addresses unavoidable breakdown
reporting requirements. The owner/operator shall calculate/estimate the excess emissions whenever
a breakdown occurs. The sum total of excess and normal emissions shall be reported to the
Executive Secretary as directed for each calendar year.

Status: In Compliance. The equipment appeared to be properly maintained and operated at
time of the inspection. Fuel oil #2 has not been used for at least two years in the 300 hp boiler.
No visible or fugitive emissions were observed. Boiler maintenance records are kept in the
boiler room. The boilers are tested semi-annually to check for efficiencies. PM checks are
performed at least twice a month. All required records are maintained and were provided
upon request. There have been no unavoidable breakdowns since the last inspection.

NSPS Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Stream
Generating Units

Status: In Compliance. NSPS Subpart Dc standards have been met through the use of
natural gas as a primary fuel and maintaining records of fuel usage.

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AREA SOURCE RULES

R307-203. Emission Standards: Sulfur Content of Fuels

Status: In Compliance. RelaDyne supplies diesel fuel to Mountainview Mushrooms. The fuel
is ULSD, with a sulfur content that does not exceed 15 ppm.

EMISSION INVENTORY: The source has not been required to submit an emission
inventory. Calculated emissions from the engineering review
are as follows:

Pollutants Tons/Yr
PM10 0.6
SO2 5.1
NOx 1.0
CO 1.1
VOC 0.3

PREVIOUS ENFORCEMENT
ACTIONS: None in the last 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-1027-92, dated
October 29, 1992: Out of Compliance. The source operates the
emergency boiler listed in Condition 2B as the primary boiler.
A Compliance Advisory (DAQC-1348-23) was issued to
address the noncompliance. The source submitted a NOI and a
subsequent Warning Letter (DAQC-988-24) was issued. The
remaining conditions appeared to be in compliance and the
source appeared to be well maintained and operated. Records
were current and made available during the inspection.

RECOMMENDATION FOR
NEXT INSPECTION: Look for a new AO to include the emergency boiler as the
primary boiler. Inspect at the regular interval. A high visibility
vest is recommended as the operational area is dark and
forklifts are present.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, Source Compliance Advisory Response