DAQ-2024-011812

1
DAQC-CI116910001-24
Site ID 11691 (B1)

MEMORANDUM

TO: FILE – MONDI BAGS USA, LLC – Salt Lake City Bag Manufacturing Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Irene Tucker, Environmental Scientist

DATE: September 11, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: June 6, 2024

SOURCE LOCATION: 2357 South 900 West
South Salt Lake, UT 84119
SOURCE CONTACTS: Matthew Hale, SHE Manager, 801-978-3855, 385-977-4425,
[e-mail]

Jamie Pappas, Plant Manager, 330-340-8512,
[e-mail]

OPERATING STATUS: In operation

PROCESS DESCRIPTION: Mondi Bags manufactures bags and liners utilizing three
different presses. Each press has a different number of inks that
are applied to the paper. All equipment operates using natural
gas, including two boilers. Many of the bags are used for human
and animal products; therefore, only food grade materials are
used in this building following the American Institute of Baking
guidelines

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN116910015-24, dated March
25, 2024

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Mondi Bags USA, LLC- Salt Lake City Bag
Manufacturing Plant

2357 South 900 West 2357 South 900 West
Salt Lake City, UT 84119 South Salt Lake, UT 84119

SIC Code: 2759: (Commercial Printing, NEC)

/ :
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]

Status: In Compliance. Mondi has not exceeded any limits set forth in this Approval Order. Mondi maintains records for at least two years, and maintains records of maintenance
activities performed on approved equipment. According to Mondi, there has been no
breakdowns resulting in an emissions event. According to the 2023 Emissions Inventory Report, the emissions indicated compliance with the PTEs of this Approval Order.

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT:

II.A.1 Bag Printing Facility
II.A.2 One (1) Flexographic Printing Press Make: Soma Model: Optima 2 1300-1270-8 WGM One (1) attached burner rated 0.4 MMBtu/hr
II.A.3 One (1) Flexographic Printing Press Make: Windmoeller & Hoelscher Model: Miraflex Eight (8) color printers Three (3) attached dryers rated 0.2, 0.4 and 0.6 MMBtu/hr each.
II.A.4 Two (2) Ancillary Equipment Lines Ancillary equipment includes tubers with inline tail-end printers.
3
II.A.5 One (1) Flexographic Plate Machine Controls: integrated catalytic oxidizer
II.A.6 One (1) Natural Gas-Fired Boiler Non-operational Rating: 18 MMBtu/hr *listed for informational purposes only
II.A.7 Various Boilers and Heaters Fuel: Natural Gas Rating: <5MMBtu/hr Each *listed for informational purposes only Status: In Compliance. There was no new or unidentified equipment observed onsite. During this inspection, the printer in AO Condition II.A.2 had not yet been installed. The boiler in AO Condition II.A.6 is still onsite but not functional or in operation. SECTION II. SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site Wide Conditions
II.B.1.a Visible emissions from any stationary point or fugitive emission source associated with the
source shall not exceed 10% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from a stationary source shall be conducted in accordance
with 40 CFR 60, Appendix A, Method 9. [40 CFR 60 Subpart A]
Status: In Compliance. There were no visible emissions observed during this inspection.
The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9.
See additional information in the attachment.
II.B.2 VOC & HAP Requirements
II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting,
printing, coating, and/or cleaning) on site:
10.81 tons per rolling 12-month period of VOCs
1.44 tons per rolling 12-month period of Vinyl Acetate
1.95 tons per rolling 12-month period of all HAPs combined. [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:
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]
HAP = [% HAP 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 and HAPs
reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8]

4
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- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] Status: In Compliance. The rolling 12-month emissions from July 2023 to June 2024, is as follows: 10.81 tons per rolling 12-month period of VOCs 1.44 tons per rolling 12-month period of Vinyl Acetate 1.95 tons per rolling 12-month period of all HAPs combined. [R307-401-8] See additional information in the attachment. II.B.2.b The owner/operator shall use only water-based inks and water-based lacquers in the flexographic printing presses and ancillary equipment lines. [R307-351, R307-401-8] Status: In Compliance. Mondi uses only water-based inks and water-based lacquers in the flexographic printing presses and ancillary equipment lines. See the SDSs in the attachment. II.B.2.c The facility shall comply with all applicable requirements in R307-351 Graphic Arts. [R307-351] Status: In Compliance. Mondi uses only water-based inks and water-based lacquers in the flexographic printing presses and ancillary equipment lines from Doneck Euroflex Inks & Coatings Worldwide. See the attachments for additional information. According to Mondi, the VOC content of the pH Corrector, categorized as Flexographic-Ink-Non-Porous-Substrate is 42 g/L. This is in compliance with and also below the VOC Content Limit of 300 g/L in Table 1 of R307-351-5(1). See the email attachments for additional information.

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.

There are no applicable Federal rules to the processes at Mondi.

5
AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

R307-351 - Graphic Arts
Status: In Compliance. Mondi uses only water-based inks and water-based lacquers in the flexographic printing presses and ancillary equipment lines from Doneck Euroflex Inks & Coatings Worldwide. See the attachments for additional information. According to Mondi, the VOC content of the pH Corrector, categorized as Flexographic-Ink-Non-Porous-Substrate is 42 g/L. This is in compliance with and also below the VOC Content Limit of 300 g/L in Table 1 of R307-351-5(1). See the email attachments for additional information. EMISSION INVENTORY: Status: 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 Mondi Bags USA, LLC - Salt Lake City
Bag Manufacturing Plant. A comparison of the estimated total potential emissions (PTE) on Approval
Order (AO) DAQE-AN116910015-24, dated March 25, 2024. PTE are supplied for supplemental
purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 1693.00 ---
Carbon Monoxide 1.18 0.145
Nitrogen Oxides 1.41 0.173
Particulate Matter - PM10 0.10 0.013
Particulate Matter - PM2.5 0.10 0.013
Sulfur Dioxide 0.01 0.001
Volatile Organic Compounds 10.87 5.71

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Acrylic Acid (CAS #79107) 42
Generic HAPs (CAS #GHAPS) 6
Glycol Ethers (CAS #EDF109) 360
Hydroquinone (CAS #123319) 412
Methanol (CAS #67561) 154
Methyl Methacrylate (CAS #80626) 16
Styrene (CAS #100425) 26
Vinyl Acetate (CAS #108054) 2884

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

COMPLIANCE STATUS &
RECOMMENDATIONS: Mondi Bags is in compliance with the conditions in Approval
Order (AO) DAQE-AN116910015-24, dated March 25, 2024.
Mondi maintains good housekeeping practices.

HPV STATUS: Not Applicable.
6
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Required PPE includes safety glasses, steel-toe
boots, ear plugs, hair net, and reflective vest.
NSR RECOMMENDATIONS: The boiler in AO Condition II.A.6 is still onsite but not functional or in operation.

ATTACHMENTS: Applicable Supporting Documentation Included