DAQ-2024-011810

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DAQC-CI104490002-24
Site ID 10449 (B1)

MEMORANDUM

TO: FILE – LDS CHURCH PRINTING CENTER – Salt Lake Printing Center – LDS
Church

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Irene Tucker, Environmental Scientist

DATE: October 31, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: June 12, 2024

SOURCE LOCATION: 1980 West Industrial Circle
Salt Lake City, UT 84104
SOURCE CONTACTS: Stacy Nisogi, EHS Manager, 801-353-1307, C-801-385-8199,
stacy.nisogi@churchof jesuschrist.org

Lyle Va Orman, Safety and Health Environmental Coordinator,
801-353-1307, [e-mail]

Duane Gottling, Sr. SHE Manager for Materials Management
Division, 801-240-0806, [e-mail]

Bradley Reed, Facilities Manager, 801-514-0029
Andrew Wuthrich, Equipment Maintenance MMD,
[phone], [e-mail]

OPERATING STATUS: Operating

PROCESS DESCRIPTION: The LDS Church Printing Center prints various items including
periodicals on the Lithoman IV, the Timson T-32, the two Man
Roland Printing Presses, and other miscellaneous printing
presses. Plates pickup and deliver ink to paper. The inks can be
heat set, air dried, or light cured. Emissions from the Lithoman
and the Timson Printing Presses are passed through a
regenerative thermal oxidizer before being released to the
atmosphere through a stack. Paper and paper dust emissions
from the cutting room are transferred to one of four baghouses
by negative pressure ducts. Baghouses vent onto the roof under
the units.

/ :
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APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN104490010-18, dated January
24, 2018
NSPS (Part 60) IIII - Standards of Performance for Stationary
Compression Ignition Internal Combustion Engine
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:

LDS Church Printing Center - Salt Lake Printing
Center - LDS Church

1980 W Industrial Circle 1980 W Industrial Circle
Salt Lake City, UT 84104 Salt Lake City, UT 84104

SIC Code: 2759: (Commercial Printing, 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]
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]

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I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: Out of Compliance for ongoing use of unapproved equipment. According to DAQC-1307-19, a Notice of Intent (NOI) was submitted to the DAQ by the LDS Church Printing Center on September 25, 2018, to add a 30-kW natural gas emergency engine. The LDS Church Printing Center submitted another NOI to the DAQ, to add an HP Digital Printing Press on July 15, 2021. Records reviewed at the LDS Church Printing Center also indicated that another NOI was submitted to the DAQ to add a 2019 Cummins, 755 hp diesel-fueled emergency generator, on October 25, 2019. According to DAQC-CI104490002-22, an NOI was also submitted in November 2019, requesting a change in the monitoring of the baghouse to reflect the current operation of the baghouse. No further action is required at this time. The LDS Church Printing Center is currently working with an assigned NSR engineer to address these concerns. See the email communication in the attachment. The LDS Church Printing Center has not exceeded any limits set forth in this Approval Order. The LDS Church Printing Center maintains records for at least two years, and maintains records of maintenance activities performed on approved equipment. According to the LDS Church Printing Center, there has been no breakdowns resulting in an emissions event. According to the 2022 Emissions Inventory Report, the emissions indicated compliance with the PTEs of this Approval Order.
Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Salt Lake Printing Center
II.A.2 One (1) Lithoman IV Printing Press Heater Rating: 7.5 MMBtu/hr Fuel: Natural Gas
II.A.3 One (1) Timson T-32 Printing Press Heater Rating: 4.0 MMBtu/hr Fuel: Natural Gas
II.A.4 Two (2) Man Roland Printing Presses Models: 704 & 705
II.A.5 Miscellaneous Printing Presses
II.A.6 One (1) Regenerative Thermal Oxidizer Rating: 1.5 MMBtu/hr Capacity: 9,000 scfm
II.A.7 One (1) Paint Booth Rating: 24,000 acfm Control: Fabric Filters
II.A.8 Four (4) Baghouses Capacities: 25,575 acfm 15,410 acfm 20,000 acfm 9,500 acfm Control vacuum system for paper shredding
II.A.9 Three (3) Boilers Maximum Total Capacity: less than 5.0 MMBtu/hr each Fuel: Natural Gas
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II.A.10 One (1) Emergency Generator Rating: 242 hp Fuel: Diesel MACT Applicability: ZZZZ
II.A.11 Miscellaneous Maintenance Areas Includes: small spray booth, welding areas, grinding area, etc.
Status: Out of Compliance. The 30-kW natural gas emergency engine, the HP Digital Printing Press, and the 755 hp diesel-fueled emergency generator still remains unapproved. According to DAQC-CI104490002-22, an NOI was also submitted in November 2019, requesting a change in the monitoring of the baghouse to reflect the current operation of the baghouse. No further action required. NSR is currently working with the LDS Church Printing Center to address these concerns. The emergency generator in AO Condition II.A.10 is no longer onsite.

II.B Requirements and Limitations
II.B.1 Site Wide Requirements II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary point on site to exceed 10 percent 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. There were no visible emissions observed during this inspection from any stationary point. The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9. II.B.1.b The owner/operator shall use natural gas as fuel for all stationary equipment. [R307-401-8] Status: In Compliance. According to the LDS Church Printing Center, natural gas is used for all stationary equipment. II.B.1.c The owner/operator shall use best working practices to reduce fugitive VOC emissions from the facility. This shall include closing containers that hold VOC rich material, covering bins or cans that are used to hold rags used for wiping VOC laden material, as well as other best working practices. [R307-401-8] Status: In Compliance. The LDS Church Printing Center stores VOC laden rags in closed containers. II.B.2 Printing Press Requirements II.B.2.a All exhaust fumes produced by the Lithoman and Timson printing presses shall be controlled by the regenerative thermal oxidizer before being vented to the atmosphere. [R307-401-8] Status: In Compliance. All exhaust fumes produced by the Lithoman and Timson Printing Presses are routed to the regenerative thermal oxidizer (RTO) before being vented to the atmosphere. II.B.2.b The regenerative thermal oxidizer shall be operated at a temperature between 1,350 - 1,700 degrees fahrenheit. [R307-401-8] Status: In Compliance. During this inspection, the regenerative thermal oxidizer (RTO) was reading between 1,485-1,501 degrees Fahrenheit. The RTO system is designed to shut down automatically if the temperature is not within the operating temperature range.
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II.B.2.b.1 To demonstrate compliance the regenerative thermal oxidizer shall: A. Ensure instrumentation is located such that an inspector or operator can safely read it at any time. B. Keep a daily computer log showing the high and low air temperatures of the exhaust stream on a daily basis. C. Operate with no visible emissions. [R307-401-8] Status: In Compliance. The control panel displaying the RTO temperature readings can be easily viewed and read. During this inspection, the RTO was reading between 1,485-1,501 degrees Fahrenheit. RTO temperature data are electronically and continuously recorded. There were no visible emissions observed from the RTO stack. See the computer logs of the RTO operating temperatures in the attachment. II.B.2.b.2 A manufacture-approved preventative maintenance schedule shall be performed on the thermal oxidizer at least once annually. [R307-401-8] Status: In Compliance. The annual PM of the RTO was conducted by the TANN Corporation on March 15, 2024. See the attachment for additional information. II.B.2.c The VOC and HAP emissions associated with the printing press inks, paint booth paints, and other chemicals shall not exceed the following: 32.02 tons of VOC's per rolling 12-month total 2.28 tons of combined HAP's per rolling 12-month total [R307-401-8] Status: In Compliance. In a rolling 12-month period from June 2023 to May 2024, the emissions were as follows: 4.04 tons of VOCs per rolling 12-month total 0.06 tons of combined HAP's per rolling 12-month total See the attachment for additional information. II.B.2.c.1 To demonstrate compliance, the owner/operator shall calculate a 12-month rolling total for emissions from press inks and chemicals. A new 12-month total will be calculated using data from the previous 12 months no later than the twentieth day of each month. [R307-401-8] II.B.2.c.2 The VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP emitting inks and chemicals used each month. The records shall include the following for each material used: A. Name of ink or chemical being used (material) B. Gallons or weight of material used C. Density of material in pounds per gallon, if applicable D. Percent by weight of all VOC and HAP components in each material
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E. Amount of VOCs and HAPs emitted monthly by each material used shall be calculated with the following equation: VOC or HAP Emissions = (% VOC or HAP by weight) * (weight used) * (control efficiency if applicable) D. VOCs or HAPs from the Timson and Lithoman presses are controlled by the thermal oxidizer and shall be accounted for assuming a 98% control efficiency [R307-401-8] Status: In Compliance. The LDS Church Printing Center determined the VOC and HAP emissions by maintaining monthly records of VOC and HAP emitting inks and chemicals used. II.B.3 Baghouse Requirements II.B.3.a The owner/operator shall control all paper shredding operations with the four baghouses on site. [R307-401-8] Status: In Compliance. The LDS Church Printing Center controls all paper shredding operations with the four baghouses. II.B.3.b The pressure drop on the baghouses shall not be less than 4.0 inches of water column or more than 6.0 inches of water column. [R307-401-8] II.B.3.b.1 The pressure drop shall be monitored and recorded once daily, while the baghouses are operating. [R307-401-8] II.B.3.b.2 The pressure drop shall be monitored with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8] Status: Not applicable to the current baghouses and to the ranges in AO Condition II.B.3.b. According to DAQC-CI104490002-22, an NOI was also submitted in November 2019, requesting a change in the monitoring of the baghouses to reflect the current operation of the baghouses. See the description of the baghouses in the attachment. This is also one of the issues that NSR will be addressing in the new AO. During this inspection, the readings from the magnehelic gauges indicated the following: A: 0.3 B: 0.9 C: 2.0 D: Not running These readings are consistent with the daily pressure drop records. See the attachment for additional information. II.B.3.b.3 All instruments shall be calibrated according to the manufacturer's instructions at least once every 12 months. [R307-401-8] Status: In Compliance. According to the records reviewed, all the calibration was conducted by Western States Calibration on December 6, 2023. See the Certificate of Calibration in the attachments. II.B.3.c Quarterly preventive maintenance records shall be kept on all four of the baghouses to insure they are operating per the manufacture specifications. [R307-401-8] Status: In Compliance. See records of quarterly PM of all four baghouses in the attachment.
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II.B.3.c.1 Maintenance records for each baghouse shall be kept to verify the quarterly preventative maintenance evaluation was performed and detail any work that was completed. [R307-401-8] Status: In Compliance. See records of quarterly PM of all four baghouses in the attachment. II.B.4 Emergency Generator Requirements II.B.4.a The owner/operator shall use only diesel as fuel in the emergency generator. [R307-401-8] Status: Out of Compliance for continuing use without prior approval from NSR. There are two emergency generators at the LDS Church Printing Center; the 30-kW natural gas emergency generator, located at the Fine Arts Building, and the 2019 Cummins, 755 hp diesel-fueled emergency generator, located at the Main Printing Facility. II.B.4.b The sulfur content of any diesel burned on site shall not exceed 15 ppm by weight. [R307-401-8] Status: In Compliance. The sulfur content is characterized as Ultra Low Sulfur Diesel according to a delivery ticket from Pilot Thomas Logistics. See the attachment for additional information. II.B.4.b.1 The sulfur content shall be determined by ASTM Method D-4294-89, or approved equivalent. Certification of fuels shall be either by source's own testing, or test reports from the fuel marketer. [R307-401-8] Status: In Compliance. The sulfur content is characterized as Ultra Low Sulfur Diesel according to a Delivery Ticket from Pilot Thomas Logistics. See the attachment for additional information. II.B.4.c Visible emissions from the emergency generator shall not exceed 20% opacity at any time. [R307-401-8] Status: In Compliance. There were no visible emissions observed from the emergency generators during this inspection. II.B.4.d The emergency generator engine shall be limited to 100 hours per rolling 12-month period for regular maintenance, testing, and other allowed non-emergency uses listed in 40 CFR 63 Subpart ZZZZ. There is no restriction on use during emergency situations. [R307-401-8] II.B.4.d.1 Records documenting generator usage shall be kept in a log with the following information: A. Date the generator was used B. Duration in hours of the generator use C. Reason for generator use [R307-401-8] II.B.4.d.2 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. [R307-401-8] Status: In Compliance. The rolling 12-month usage of the 2019 Cummins, 755 hp diesel-fueled emergency generator from June 2023 to May 2024, indicated 50.5 hours. The rolling 12-month usage of the 30 kW emergency generator from June 2023 to May 2024, indicated 42.9 hours. See the attachment for additional information. The hours of generator usage were recorded and kept in a log. Both emergency generators were each equipped with a non-resettable meter. See the attachment for additional information.

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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) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engine
Status: In Compliance. The 2019 Cummins, 755 hp diesel-fueled emergency generator is located in
the Main Printing Facility, and is applicable to NSPS Part 60, Subpart IIII. See the annual PM and
the EPA Tier 2 Exhaust Emission Compliance Statement in the attachment.
NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Status: Not in Compliance. The 2017 Cummins 30 kW natural gas emergency generator is located in the
Fine Arts Building. This generator is unapproved. NSR is currently working on a new AO to address
this issue. No further action required at this time. See the annual PM and the Exhaust Emission
Compliance Statement in the attachment.
MACT (Part 63) - ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Status: In Compliance. The emergency generators were each equipped with a non-resettable meter. The sulfur content is characterized as Ultra Low Sulfur Diesel according to a delivery ticket from Pilot Thomas Logistics. See the attachment for additional information.
AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

R307-203 Emission Standards: Sulfur Content of Fuels
Status: In Compliance. The sulfur content is characterized as Ultra Low Sulfur Diesel according to a delivery ticket from Pilot Thomas Logistics. See the attachment for additional information.

R307-214 - National Emission Standards for Hazardous Air Pollutants

Status: In Compliance. This area source rule is applicable to 40 CFR Part 63, Subpart ZZZZ. See
Section III for compliance with this requirement.

R307-305 - Nonattainment and Maintenance Areas for PM10: Emission Standards

Status: In Compliance. There were no visible emissions observed during this inspection. See the
attachment for additional information.

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R307-325 - Ozone Nonattainment and Maintenance Areas: General Requirements

Status: In Compliance. During this inspection, the VOC laden rags were stored in closed containers,
and also meets compliance with AO Condition II.B.1.c.

R307-351 - Graphic Arts

Status: In Compliance. The inks used for the printing presses are categorized as Heatset Web Offset
Lithographic Ink with a VOC content of 400 g/l. The emissions are further routed through the
regenerative thermal oxidizer (RTO) with a destruction efficiency greater than 90%. See the
attachment for additional information. All the cleaning materials indicated compliance with the
requirements of R307-351-5(4) with a VOC composite vapor pressure less than 10 mmHg at 68
degrees Fahrenheit. See the attachments for additional information.

EMISSION INVENTORY: In Compliance. According to the 2023 Emissions Inventory Report,
the emissions indicated compliance with the PTEs of this Approval Order.

Listed below are the Actual Emissions Inventory provided from LDS Church Printing Center- Salt Lake
Printing Center - LDS Church. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN104490010-18, dated January 24, 2018 is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 14234.00 ---
Carbon Monoxide 10.03 1.50
Nitrogen Oxides 12.23 1.85
Particulate Matter - PM10 26.71 17.21
Particulate Matter - PM2.5 13.82 8.69
Sulfur Dioxide 0.10 0.02
Volatile Organic Compounds 32.67 3.33

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Acetaldehyde (CAS #75070) 0
Benzene (Including Benzene From Gasoline) (CAS #71432) 1
Cumene (CAS #98828) 155
Ethylene Glycol (CAS #107211) 1536
Formaldehyde (CAS #50000) 18
Hexane (CAS #110543) 427
Polycyclic Organic Matter (CAS #246) 2709
Toluene (CAS #108883) 1
Xylenes (Isomers And Mixture) (CAS #1330207) 157

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PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: LDS Church Printing Center is out of compliance with Approval
Order (AO) DAQE-AN104490010-18, dated January 24, 2018,
for operating unapproved equipment to include the 30 kW
natural gas emergency generator, the 2019 Cummins, 755 hp
diesel-fueled emergency generator, and the HP Digital Printing
Press has not been approved. No further action required at this
time. An assigned NSR engineer is currently working with the
LDS Church Printing Center to address these issues through a
new AO.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Look for new AO to include an update of the baghouse ranges in
AO Condition II.B.3.b; the 2017, 30 kW natural gas emergency
generator engine, the 2019 Cummins, 755 hp diesel-fueled
emergency generator, and the HP Digital Printing Press.
Required PPE includes steel toe boots and safety glasses.

NSR RECOMMENDATIONS: The new AO should address the NOI submitted to the DAQ on
September 25, 2018, to add a 30-kW natural gas emergency
engine, NOI to add an HP Digital Printing Press on July 15,
2021, and NOI to add the 2019 Cummins, 755 hp diesel-fueled
emergency generator, on October 25, 2019. According to
DAQC-CI104490002-22, an NOI was also submitted in
November 2019, requesting a change in the monitoring of the
baghouses to reflect the current operation of the baghouses.

Consider including a condition for R307-351.

The emergency generator in AO Condition II.A.10 is no longer
onsite.

ATTACHMENTS: Applicable Supporting Documentation Included