DAQ-2025-001278

GRAIN CRAFT
November 18,2022
Chad Gilgen & Sarah Malluche
Utah Department of Environmental Quality
Division of Air Quality - Minor Source Compliance Section
195 North 1950 Street West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Email: [e-mail]
Email: [e-mail]
Re: Utah DAQ's Compliance Advisory Dated November 3, 2022 r A
Grain Craft, Inc., DAQE-ANT10g360006-11, Ogden, Weber Coiwtyl,on.r Sr;,rtrs: -LlL
Dear Mr. Gilgen and Ms. Malluche:
Grain Craft is writing in response to the above captioned Compliance Advisory (CA) from the
Utah Division of Air Quality (DAQ) which was received on November 10, 2022. The CA
alleges that pressure drop (dP) records for several baghouses at Grain Craft's Ogden facility
reflected instances where the dP's recorded exceeded limits established in the facility's Approval
Order (AO). The baghouses in question are identified in the AO as Unit #10 (the hammermill
suction baghouse), Unit #18 (the "C" mill pneumatics baghouse), and Unit #28 (the "C" mill
general suction baghouse). The CA also alleges the facility may have failed to take appropriate
corrective actions (including performing maintenance) in response to out of range dP readings.
Upon its receipt of the CA, Grain Craft conducted a thorough investigation into DAQ's
allegations and into the operation and maintenance of the baghouses identified in the CA. The
findings of our investigation are as follows:
Unit #10. The facility's AO requires that the dP across Unit #10 be maintained
between 2 and 6 inches of water column. DAQ is believed to have observed dP
records indicating exceedances of these dP limits. As part of its investigation,
Grain Craft determined that the magnehelic pressure gauge failed on a date yet to
be determined. The gauge failure resulted in a series of dP readings that Grain
Craft reasonably believes were not representative of actual dP's across Unit #10.
The failed magnehelic gauge was replaced on l0lll22 and is functioning properly
now.
The facility's corrective actions include retraining of operators responsible for
observing and recording baghouse dP readings and updating the dP log sheets for
each baghouse with both permitted dP ranges and the appropriate steps to be
taken immediately if a dP reading is observed to be outside of permitted limits.
The training was completed on 1111612022, and the logs will be updated and
introduced on l2lll22.
UTAH DEPABTMENT OF
ENVIRONMENTAL QUALIry
i'i0v 2 S 20??
DIVISION OF AIR OUALITY
REVIEWED
201 West Main Street, Suite 203 Chattanoog4 TN 37408 423.265.2313 www.graincraft.com
Unit #18. The facility's AO requires that the dP across Unit #18 be maintained
between 0.5 and 6 inches of water column. DAQ is believed to have observed dP
records indicating readings in excess of 6 inches of water column. Grain Craft
attributes these "high" readings to be the result of filter bags in Unit # I 8
becoming "blinded" (or partially blinded) due to normal operations. The filter
bags were ultimately changed. Unfortunately, the bags were not changed quickly
enough to avoid dP exceedances. As noted above, we will be retraining all of our
operators responsible for monitoring baghouse dP readings to react immediately
to low and/or high readings to ensure that proper maintenance (including
replacing blinded filter bags) is completed in accordance with the expectations of
the facility's AO.
Unit #28. The facility's AO requires that the dP across Unit #28 be maintained
between 2 and 6 inches of water column. DAQ is believed to have observed dP
records indicating exceedances of these limits. As was the case with Unit #18
above, we attribute these high readings to be the result of filter bags becoming
blinded or partially blinded due to normal operations. Although the filter bags
were changed, the bags were not changed quickly enough to avoid dP
exceedances. As noted above, we will be retraining all of our operators
responsible for monitoring baghouse dP readings to react immediately to low
and/or high readings to ensure that proper maintenance (including replacing
blinded filter bags) is completed in accordance with the expectations of the
facility's AO.
In conjunction with our response to DAQ's CA, Grain Craft is currently exploring
whether the facility's AO could be modified to incorporate dP ranges for the facility's
baghouses (some or all) that better reflect proper, real world operation of these units. In
the event that Grain Craft chooses to pursue this option, we will contact DAQ to initiate a
discussion.
If you have any questions concerning any of the above-listed corrective actions in response to
DAQ's CA, please do not hesitate to contact me. Please understand that Grain Craft takes
environmental compliance very seriously. It is our intention to fully comply with each of the
terms and conditions of the Ogden facility's AP at all times. We look forward to cooperating
with DAQ in order to make this happen.
Thank you.
Steve Mosier
Plant Manager
Grain Craft
Ogden, Utah
201 West Main Street. Suite 203 Chattanooga TN 37408 423.265.23t3 www.graincraft.com