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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) 0 0 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. 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 3 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] 4 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. 5 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.