HomeMy WebLinkAboutDAQ-2024-0120771
DAQC-CI103690001-24
Site ID 10369 (B1)
MEMORANDUM
TO: FILE – BIMBO BAKERIES USA, INC. – Salt Lake City Bakery
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Jared James, Environmental Scientist
DATE: December 11, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County
INSPECTION DATE: December 5, 2024
SOURCE LOCATION: 3475 South 300 West,
P.O. Box 65487
Salt Lake City, UT 84115
SOURCE CONTACTS: Becky Millar, Quality Food Safety Manager
801-487-4677 ext. 5628, rebecca.millar@grupobimbo.com
OPERATING STATUS: Operating normally.
PROCESS DESCRIPTION: Bakery manufacturer. Sliced bread, hot dog, and hamburger
buns, and other baked goods are produced in a line from the
dough-mixing process, through rising, baking, and packaging.
The catalytic oxidizer is used to reduce VOCs created from the
three natural gas ovens. Two natural gas boilers are present
onsite.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN103690015-17, dated
April 25, 2017
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Bimbo Bakeries USA, Inc.
Salt Lake City Bakery
3475 South 300 West,
3475 South 300 West P.O. Box 65487
Salt Lake City, UT 84115 Salt Lake City, UT 84115
SIC Code: 2051: (Bread & Other Bakery Products, Except Cookies & Crackers)
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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. No limits set forth in this AO appear to have been exceeded. No
modifications to equipment or processes have been made. Equipment appeared to be well
maintained and operated properly. Records are kept as required and were made available
for review during the inspection. No breakdowns have occurred in the last 12 months. A
2023 emission inventory was submitted to DAQ.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Bakery
A bakery which produces various ready-to-eat goods
II.A.2 Natural gas-fired oven
A bread oven made by Lanham rated at 7.0 MMBtu per hour, routed through the catalytic oxidizer
II.A.3 Natural gas-fired oven
A bun oven made by Readco rated at 4.7 MMBtu per hour, routed through the catalytic oxidizer
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II.A.4 Natural gas-fired oven A bread oven made by Chubco Hearth rated at 3.0 MMBtu per hour, routed through the catalytic
oxidizer
II.A.5 Natural gas-fired boiler
A boiler made by Cleaver Brooks rated at 3.4 MMBtu per hour
II.A.6 Natural gas-fired boiler
A boiler made by Superior Boiler Company rated at 3.4 MMBTU per hour
II.A.7 Storage and transfer systems
Five flour storage and transfer systems equipped with panel filters
II.A.8 Natural gas-fired heaters
Miscellaneous equipment rated at less than one MMBtu per hour each
II.A.9 Fitzmill It is operated by electricity to grind bread crumbs. There are no applicable requirements for this unit. It is listed for identification purposes only.
II.A.10 Catalytic oxidizer
CSM catalytic oxidizer rated at 4.6 MMBtu per hour
Status: In Compliance. The above equipment is present onsite and was observed during the
inspection. No unapproved equipment was observed at the time of inspection. The
Fitzmill from II.A.9 is no longer in use. A parts washer was present onsite in the
engineering maintenance shop.
II.B Requirements and Limitations
II.B.1 Source-wide requirements.
II.B.1.a The owner/operator shall notify the Director in writing when the installation of the catalytic
oxidizer (II.A.10) has been completed and is operational, as an initial compliance inspection is
required. To ensure proper credit when notifying the Director, send your correspondence to the
Division of Air Quality, attn: Compliance Section.
If the installation has not been completed within 18 months from the date of this AO, the
Director shall be notified in writing on the status of the installation. At that time, the Director
shall require documentation of the continuous installation of the operation and may revoke the
AO in accordance with R307-401-18. [R307-401-18]
Status: In Compliance. Notification of installation was received in 2018, and was included
on the inspection report from the February 2018 inspection.
II.B.1.b Visible emissions from the following emission points shall not exceed the following values: A. Natural gas fired equipment - 10% opacity B. Flour storage and transfer systems - 20% opacity C. All other points - 20% opacity. [R307-401-8]
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II.B.1.b.1 Opacity observations of emissions from the 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.c The emissions from all three (3) natural gas fired ovens shall be routed through the catalytic
oxidation system prior to being exhausted to the atmosphere. The catalytic oxidizer shall operate
during all periods when any of the ovens are baking product. [R307-401-8(1)(a)]
Status: In Compliance. This is the current emissions pathway for the natural gas ovens.
The oxidizer operates at all times when the ovens are baking product.
II.B.1.d During operation of the catalytic oxidizer, the owner/operator shall maintain the inlet gas
temperature to the oxidizer at a minimum of 600 oF. The temperature shall be continuously
monitored and recorded at all times during baking operations. [R307-401-8(1)(a)]
Status: In Compliance. A digital monitor records the temperatures on a continuous basis.
The monitor read 627 degrees F. The source indicated that baking would automatically
shut down if the catalytic oxidizer temperature were to fall below 600 degrees F.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
Commercial Cooking [R307-303]
Status: In Compliance. The source has installed and maintains a catalytic oxidizer to control
emissions, and performs regular maintenance. Maintenance was last performed in December of
2023, with the next annual inspection and maintenance scheduled for December 9, 2024. No visible
emissions were observed from the oxidizer. No breakdowns have occurred in the last 12 months.
Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]
Status: In Compliance. No visible emissions were observed during the inspection.
Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]
Status: In Compliance. No VOC containing materials were observed to be spilled, discarded, or
stored in open containers.
Degreasing and Solvent Cleaning Operations [R307-335]
Status: In Compliance. The small parts washer has a lid that is easily operated with one hand. The
lid was closed at the time of inspection. Excess Safety-Kleen solvent and waste drains into a covered
container. The waste tank and containers had no visible leaks and appeared to be in good operating
condition. The spray is a solid fluid stream, with no excessive splashing. The source stated that
maintenance is performed weekly on the parts washer. Operation instructions were posted on the
inside of the lid.
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EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Bimbo Bakeries USA, Inc. – Salt Lake
City Bakery. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN103690015-17, dated April 25, 2017, is provided. PTE are supplied for supplemental
purposes only.
Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 17040.00
Carbon Monoxide 11.55 2.4096
Nitrogen Oxides 13.75 2.8686
Particulate Matter - PM10 2.62 0.5169
Particulate Matter - PM2.5 2.62 0.2180
Sulfur Dioxide 0.08 0.0172
Volatile Organic Compounds 45.00 9.4778
Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 1
Formaldehyde (CAS #50000) 20
Generic HAPs (CAS #GHAPS) 1378
PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN103690015-17,
dated April 25, 2017, the overall status is: In Compliance. The
facility appeared to be well maintained and operated properly.
Required records were current and provided for review during
the inspection.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect at regular frequency. Hard hat, safety glasses, and steel-
toed boots are required. Hair and beard net are provided. Prior to
entering the production area, the inspector may need to complete
a safety briefing with a short quiz.
NSR RECOMMENDATIONS: Remove the Fitzmill (item II.A.9) and include the parts washer
with any AO modification.
ATTACHMENTS: VEO Form.