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Home My WebLink AboutDAQ-2024-0120041 DAQC-CI132510001-24 Site ID 13251 (B1) MEMORANDUM TO: FILE – DAIRY FARMERS OF AMERICA – Cheese & Condensed Milk Processing Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jordan Garahana, Environmental Scientist DATE: November 27, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Beaver County INSPECTION DATE: August 1, 2024 SOURCE LOCATION: 330 West 300 South Beaver, UT 84713 DIRECTIONS: Dairy Farmers of American (DFA) is the building south of the Beaver Creamery on the same lot. SOURCE CONTACTS: Andrea Blackburn, Inspection Contact OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Dairy Farmers of America operates a milk processing plant out of Beaver. The plant processes up to 10,000 pounds of cheese and 160,000 pounds of condensed milk per day. This facility operates two boilers for steam generation. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN132510003-23, dated June 14, 2023 NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, NSPS (Part 60) A: General Provisions, MACT (Part 63) -A : General Provisions, MACT (Part 63) JJJJJJ : National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources SOURCE EVALUATION: Name of Permittee: Permitted Location: Dairy Farmers of America Cheese & Condensed Milk Processing Plant P.O. Box 1087 330 West 300 South Beaver, UT 84713 Beaver, UT 84713 SIC Code: 2023: (Dairy Products - Dry, Condensed & Evaporated) 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 five (5) 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. No limits were exceeded, and no breakdowns have occurred. The source submitted their 2023 Emission Inventory by the April 15, 2024, deadline. See the attachments section for additional information. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Milk Processing Plant II.A.2 One (1) Boiler NSPS applicability: Subpart Dc MACT applicability: Subpart JJJJJJ Fuel: Natural Gas, Diesel Rating: 21.382 MMBtu/hr II.A.3 One (1) Boiler MACT Applicability: Subpart JJJJJJ Fuel: Natural Gas, Diesel Rating: 16.737 MMBtu/hr *Listed for informational purposes, boiler was installed in 1967 and is a Grandfathered unit. Status: In Compliance. No unapproved equipment was observed at the time of inspection. Both boilers onsite had the same rating as listed above. 3 II.B Requirements and Limitations II.B.1 Site Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions to exceed 10% opacity from any stationary point or fugitive emission source on site. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9. [40 CFR 60 Subpart A, R307-401-8] Status: In Compliance. No visible emissions were observed at the time of inspection. See the attached VEO form for additional information. II.B.1.b The owner/operator shall use natural gas as a primary fuel and diesel fuel (#2 fuel oil) as a backup fuel in the boilers. Diesel fuel shall only be used in the event there is an interruption in the supply of natural gas, or for periodic maintenance of the boilers. [R307-401-8] Status: In Compliance. Natural gas is the primary fuel source utilized in the boilers. Diesel fuel is only used in the case of curtailment of natural gas. Diesel fuel has not operated in the boilers within the last 2 years. II.B.1.c The sulfur content of any fuel oil or diesel burned shall not exceed 0.5 percent by weight for diesel fuels consumed in all equipment. [R307-401-8] II.B.1.c.1 The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent. Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. [R307-401-8] Status: In Compliance. According to a fuel invoice viewed at the time of inspection, the diesel fuel purchased and utilized onsite is classified as ULSD. 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 two boilers apply to this federal subpart. The boilers mainly operate on natural gas, with diesel fuel as a backup in case of natural gas curtailment. Both boilers did not operate on diesel within the last 2 years. A record of the hours of operation were viewed at the time of inspection. The diesel that is available for use in the boilers is classified as ULSD according to a fuel invoice from RelaDyne viewed onsite at the time of inspection. NSPS (Part 60) A: General Provisions Status: In Compliance. Compliance with Subpart A is determined by compliance with applicable federal subparts. In compliance with Subpart Dc. MACT (Part 63) -A: General Provisions Status: In Compliance. Compliance with Subpart A is determined by compliance with applicable federal subparts. In compliance with Subpart JJJJJJ. 4 MACT (Part 63) JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources Status: In Compliance. The two boilers apply to this federal subpart. The boilers mainly operate on natural gas, with diesel fuel as a backup in case of natural gas curtailment. Both boilers did not operate on diesel within the last 2 years. A record of the hours of operation were viewed at the time of inspection. The diesel that is available for use in the boilers is classified as ULSD according to a fuel invoice from RelaDyne viewed onsite at the time of inspection. Source was notified of requirements of stack testing should they exceed 48 hours of diesel fuel operation, as well as installing a continuous emission monitoring system (CEMS) should they exceed that limit to meet the established emission limits within Subpart JJJJJJ. 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. According to a fuel invoice viewed at the time of inspection, the diesel fuel purchased and utilized onsite is classified as ULSD. EMISSION INVENTORY: Listed below are the Actual Emissions Inventory provided from Dairy Farmers of America Cheese & Condensed Milk Processing Plant. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN132510003-23, dated June 14, 2023, is provided. The 2023 Emission Inventory is listed below and can be found in the attachments section. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 19642.00 Carbon Monoxide 13.83 3.42 Nitrogen Oxides 17.10 4.07 Particulate Matter - PM10 1.42 0.30 Particulate Matter - PM2.5 1.42 0.30 Sulfur Dioxide 0.57 0.02 Volatile Organic Compounds 0.91 0.22 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Formaldehyde (CAS #50000) 25 6.6 Hexane (CAS #110543) 590 154.32 PREVIOUS ENFORCEMENT ACTIONS: This is the initial inspection of this facility. COMPLIANCE STATUS & RECOMMENDATIONS: In regard to Approval Order (AO) DAQE-AN132510003-23, dated June 14, 2023: In compliance with conditions listed within this AO. The facility is well maintained, and records were made available upon request. 5 HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect at the normal frequency. NSR RECOMMENDATIONS: None at this time. ATTACHMENTS: Applicable supporting documentation included. 2023 Emissions Inventory Report Dairy Farmers of America- Cheese & Condensed Milk Processing Plant (13251) Emissions Summary CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS Pollutant Code/CAS #Pollutant Name Emissions (tons, excluding tailpipe) Tailpipe Emissions (tons) Total Emissions (tons)* PM10-PRI PM10 Primary (Filt + Cond)0.30995 <.00001 0.30995 PM10-FIL PM10 Filterable 0.07748 <.00001 0.07748 PM25-PRI PM2.5 Primary (Filt + Cond)0.30994 <.00001 0.30994 PM25-FIL PM2.5 Filterable 0.07748 <.00001 0.07748 PM-CON PM Condensible 0.23245 <.00001 0.23245 SO2 Sulfur Dioxide 0.02521 <.00001 0.02521 NOX Nitrogen Oxides 4.07825 <.00001 4.07825 VOC Volatile Organic Compounds 0.22429 <.00001 0.22429 CO Carbon Monoxide 3.42557 <.00001 3.42557 7439921 Lead 0.00002 <.00001 0.00002 NH3 Ammonia 0.1305 <.00001 0.1305 HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions (tons)* 7440382 Arsenic (HAP)PM 0.00001 71432 Benzene (HAP)VOC 0.00009 7440417 Beryllium (HAP)PM <.00001 7440439 Cadmium (HAP)PM 0.00004 7440473 Chromium (HAP)PM 0.00006 7440484 Cobalt (HAP)PM <.00001 50000 Formaldehyde (HAP)VOC 0.00306 110543 Hexane (HAP)VOC 0.0734 7439965 Manganese (HAP)PM 0.00002 7439976 Mercury (HAP)- 0.00001 91203 Naphthalene (HAP)VOC 0.00002 7440020 Nickel (HAP)PM 0.00009 7782492 Selenium (HAP)PM <.00001 108883 Toluene (HAP)VOC 0.00014 91576 2-Methylnaphthalene (HAP)PM <.00001 *Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated. 1/2