DAQ-2024-009601

DAQE-AN118410010-24

{{$d1 }}

Wesley McGhee
Pepperidge Farm Inc.
901 North 200 West
Richmond, UT 84333-1499
[e-mail]

Dear Mr. McGhee:

Re: Approval Order: Modification to Approval Order DAQE-AN118410009-23 to Update Equipment
Project Number: N118410010

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August
15, 2023. Pepperidge Farm Inc. must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Christine Bodell, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received on
this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:CB:jg

cc: Bear River Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

July 26, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN118410010-24
Modification to Approval Order DAQE-AN118410009-23
to Update Equipment

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Pepperidge Farm Inc. - Commercial Bakery

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

July 26, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12

DAQE-AN118410010-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Pepperidge Farm Inc. Pepperidge Farm Inc. - Commercial Bakery

Mailing Address Physical Address
901 North 200 West 901 North 200 West
Richmond, UT 84333-1499 Richmond, UT 84333-1499

Source Contact UTM Coordinates
Name: Wesley McGhee 432,484 m Easting
Phone: [phone],643,210 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 2052 (Cookies & Crackers)

SOURCE INFORMATION
General Description
Pepperidge Farm, Inc. (Pepperidge Farm) owns and operates a commercial baking plant in Richmond,
Cache County. Emissions are generated through ingredient mixing, cooking, heating, and baking.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Cache County
Airs Source Size: SM

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

DAQE-AN118410010-24
Page 4

Project Description
Pepperidge Farm has requested to modify AO DAQE-AN118410009-23 with the following changes:

1. Add a new manufacturing line (Line 11) containing one (1) 16.5 MMBtu/hr, natural gas-fired oven.
2. Add one (1) 1 MMBtu/hr, natural gas-fired catalytic oxidizer to control VOC emissions from the
baking process.
3. Add one (1) cooling tower.
4. Remove one (1) 10.5 MMBtu/hr natural gas-fired boiler (Equipment ID II.A.8 in AO
DAQE-AN118410009-23).
5. Remove one (1) 5.3 MMBtu/hr natural gas-fired oven due to the decommissioning of cookie line 7
(Equipment ID II.A.6 in AO DAQE-AN118410009-23).
6. Update the facility-wide potential to emit (PTE) to include emissions from various natural gas-fired
comfort heaters.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 44638 70912.00
Carbon Monoxide 26.95 48.43
Nitrogen Oxides 32.24 57.81
Particulate Matter - PM10 3.38 5.32
Particulate Matter - PM2.5 3.02 4.96
Sulfur Dioxide 0.21 0.36
Volatile Organic Compounds -29.07 69.93

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 3143 9340
Generic HAPs (CAS #GHAPS) -4883 100
Hexane (CAS #110543) 0 2080
Change (TPY) Total (TPY)
Total HAPs 0.17 5.76

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]

DAQE-AN118410010-24
Page 5

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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Pepperidge Farm Incorporated
Commercial Baking Plant

II.A.2 Process Line No. 1
Natural gas/propane-fired oven
Maximum rating: 3.2 MMBtu/hr

II.A.3 Process Line No. 2
Natural gas/propane-fired oven
Maximum rating: 3.2 MMBtu/hr

II.A.4 Process Line No. 3
Natural gas/propane-fired oven
Maximum rating: 5.2 MMBtu/hr
Emissions control device: 1.0 MMBtu/hr catalytic oxidizer for VOC (ethanol) destruction

Radio frequency dryer - Removes excess moisture from product line

DAQE-AN118410010-24
Page 6

II.A.5 Process Line No. 5
Natural gas/propane-fired oven
Maximum rating: 9.9 MMBtu/hr
Emissions control device: 1.0 MMBtu/hr catalytic oxidizer for VOC (ethanol) destruction

Radio frequency dryer - Removes excess moisture from product line

II.A.6 Process Line No. 10
Natural gas/propane-fired oven
Maximum rating: 12.5 MMBtu/hr
Emissions control device: 1.6 MMBtu/hr catalytic oxidizer for VOC (ethanol) destruction

Radio frequency dryer - Removes excess moisture from product line

II.A.7 Process Line No. 11
Natural gas/propane-fired oven
Maximum rating: 16.5 MMBtu/hr
Emissions control device: 1.0 MMBtu/hr Catalytic oxidizer for VOC (ethanol) destruction

II.A.8 Pan Washer and Dryer
Natural gas/propane-fired heater
Maximum rating: 0.8 MMBtu/hr

II.A.9 Storage Silos
Five (5) External Flour Storage Silos
Emissions control device: bin vents for flour dust during transfer operations

Miscellaneous storage silos that vent inside the silo building

II.A.10 Emergency Pump Engines
Manufactured Pre-1996
Fuel: Diesel Fuel

Ratings:
0.17 MMBtu/hr
0.38 MMBtu/hr
0.44 MMBtu/hr

MACT Applicability: Subpart ZZZZ

II.A.11 One (1) Cooling Tower

II.A.12 Propane Tanks
Two (2) 30,000-gallon propane storage tanks, each
One (1) 1,000-gallon propane vapor tank

II.A.13 Various Boilers
Fuel: Natural Gas
Rating: <5 MMBtu/hr, each

II.A.14 Miscellaneous Equipment
Four (4) vegetable/soy oil tanks that are each 7,000 gallons or less
Three (3) diesel oil tanks that are less than 400 gallons each
Refrigeration system
Label printer
Small sandblasting cabinet

DAQE-AN118410010-24
Page 7

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not consume more than the following:

A. 1,151,900 decatherms total of natural gas and/or propane combined per rolling
12-month period.

B. 723 gallons of diesel fuel per rolling 12-month period for stationary equipment.

[R307-401-8]

II.B.1.a.1 The owner/operator shall:

A. Determine natural gas/propane fuel consumption with billing statements.

B. Determine diesel fuel consumption with billing records, dipstick measurements, or other
appropriate methods.

C. Record both natural gas/propane and diesel fuel consumption on a monthly basis.

D. Use the consumption data to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months for both natural gas/propane and
diesel.

E. Keep the consumption records for all periods the plant is in operation.

[R307-401-8]

II.B.1.b The owner/operator shall not exceed a throughput of more than 110,508 tons of wet dough per
rolling 12-month period. [R307-401-8]

II.B.1.b.1 The owner/operator shall:

A. Determine throughput with batch scales.

B. Record throughput on a daily basis.

C. Use the throughput data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months.

D. Keep the throughput records for all periods the plant is in operation.

[R307-401-8]

DAQE-AN118410010-24
Page 8

II.B.1.c The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Natural gas/propane combustion stacks - 10% opacity.

B. Ovens and catalytic oxidizers - 10% opacity.

C. Silo bin vents and silo enclosure ventilation - 10% opacity.

D. Cooling tower - 10% opacity.

E. Diesel engines - 20% opacity.

F. All other points - 10% opacity.

[R307-401-8]

II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.d The owner/operator shall install a cooling tower that is certified to meet a drift rate of 0.001% or
less. [R307-401-8]

II.B.1.d.1 To demonstrate compliance with the drift rate, the owner/operator shall keep a record of the
manufacturer's certification of the drift rate. The record shall be kept for the life of the
equipment. [R307-401-8]

II.B.2 Catalytic Oxidizer Requirements
II.B.2.a The owner/operator shall not emit more than the following VOC rates from the indicated
Catalytic Oxidizer Outlets:

Process Line lb/hr
Process Line Number 3 0.95
Process Line Number 5 2.38
Process Line Number 10 3.45
Process Line Number 11 3.45

[R307-401-8]

II.B.2.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-165-2, R307-401-8]

II.B.2.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of Process Line 11. [R307-165-2]

II.B.2.a.3 Test Frequency
The owner/operator shall conduct a stack test on the emission unit within three (3) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

DAQE-AN118410010-24
Page 9

II.B.2.b.1 Testing and Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.2.b.2 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.2.b.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.2.b.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.2.b.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.2.c Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.2.c.1 Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K).

B. Pressure - 29.92 in Hg (101.3 kPa).

C. Averaging Time - As specified in the applicable test method.

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.2.c.2 VOC
40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A,
Method 320; or other EPA-approved testing method as acceptable to the Director.
[R307-401-8]

II.B.2.d The owner/operator shall route all emissions from each baking process through an oxidation
catalyst before being vented to the atmosphere. [R307-401-8]

II.B.2.e The owner/operator shall operate each oxidation catalyst according to the manufacturer's
recommendations. [R307-401-8]

II.B.2.f At all times while operating the oxidation catalysts, the owner/operator shall maintain a
temperature at or above 700oF at each oxidation catalyst inlet and maintain a temperature rise at
or above 55oF across each oxidation catalyst. [R307-401-8]

II.B.2.f.1 The owner/operator shall monitor the catalyst inlet temperature and catalyst temperature rise with
thermocouples permanently located at each catalyst inlet and outlet. The thermocouples shall be
located such that an inspector/operator can safely read the output at any time. [R307-401-8]

DAQE-AN118410010-24
Page 10

II.B.2.f.2 The owner/operator shall monitor and record the catalyst inlet temperature and catalyst
temperature rise of each catalyst each operating day. Temperature rise shall be based on a 3-hour
rolling average of data collected every ten minutes. [R307-401-8]

II.B.2.f.3 The owner/operator shall calibrate all temperature monitoring equipment according to the
manufacturer's instructions at least once every six (6) months. [R307-401-8]

II.B.3 VOC Requirements
II.B.3.a The owner/operator shall not emit more than 66.75 tons of total VOC emissions combined from
Process Line No. 3, Process Line No. 5, Process Line No. 10, and Process Line No. 11 per
rolling 12-month period. [R307-401-8]

II.B.3.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 the following equations with
applicable units to calculate VOC emissions:

Process Line No. 3, Process Line No. 5, Process Line No. 10, and Process Line No. 11 Total
VOC Emissions
= Oven Emissions + Fugitive Emissions

1) Oven Emissions
= (Fugitive Emissions) + [((Oven VOC E.F.) x (ton finished product) - (Fugitive Emissions)) *
(0.05)]
Oven VOC E.F. = 23.08 lbs/ton finished product

2) Fugitive Emissions
= (Fugitive E.F.) x (ton product dough)
Fugitive E.F. = 0.3970

[R307-401-8]

II.B.3.b The owner/operator shall maintain records of VOC emissions for all periods when the plant is in
operation. [R307-401-8]

II.B.4 Fuel Requirements
II.B.4.a The owner/operator shall only use natural gas as a primary fuel and propane as a backup fuel in
all on-site ovens, catalytic oxidizers, boilers, and heaters. [R307-203]

II.B.4.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as
fuel in each diesel-fired emergency pump engine. [R307-401-8]

II.B.4.c The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ]

II.B.4.c.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

II.B.5 Emergency Pump Engine Requirements
II.B.5.a The owner/operator shall not operate each emergency pump engine on site for more than 100
hours per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the pump engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

DAQE-AN118410010-24
Page 11

II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency pump engine shall be kept in a log and shall
include the following:

A. The date the emergency pump engine was used.

B. The duration of operation in hours.

C. The reason for the emergency pump engine usage.

[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.5.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency pump engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.5.b The owner/operator shall not operate any emergency pump engine for maintenance and readiness
testing before 8:00 am or after 6:00 pm each day. [R307-401-8]

II.B.5.b.1 The owner/operator shall keep and maintain the following records for all periods each emergency
pump engine is in operation for maintenance and testing purposes:

A. Time operations begin each day.

B. Time operations end each day.

[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN118410009-23 dated July 20, 2023
Is Derived From NOI dated August 15, 2023
Incorporates Additional Information dated February 20, 2024
Incorporates DAQE-MN118410010-24 dated March 18, 2024
Incorporates Additional Information dated April 16, 2024
Incorporates Additional Information dated June 10, 2024

DAQE-AN118410010-24
Page 12

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN118410010-24

June 20, 2024

Wesley McGhee
Pepperidge Farm Incorporated
901 North 200 West
Richmond, UT 84333-1499
[e-mail]

Dear Mr. McGhee:

Re: Intent to Approve: Modification to Approval Order DAQE-AN118410009-23 to Update
Equipment
Project Number: N118410010

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Christine Bodell, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Christine Bodell, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:CB:jg

cc: Bear River Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN118410010-24
Modification to Approval Order DAQE-AN118410009-23
to Update Equipment

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Pepperidge Farm Incorporated - Commercial Bakery

Issued On
June 20, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 8
PERMIT HISTORY ................................................................................................................... 12
ACRONYMS ............................................................................................................................... 13

DAQE-IN118410010-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Pepperidge Farm Incorporated Pepperidge Farm Incorporated - Commercial
Bakery

Mailing Address Physical Address
901 North 200 West 901 North 200 West
Richmond, UT 84333-1499 Richmond, UT 84333-1499

Source Contact UTM Coordinates
Name: Wesley McGhee 432,484 m Easting
Phone: [phone],643,210 m Northing
Email: Wesley [e-mail] Datum NAD83
UTM Zone 12

SIC code 2052 (Cookies & Crackers)

SOURCE INFORMATION
General Description
Pepperidge Farm Incorporated (Pepperidge Farm) owns and operates a commercial baking plant in
Richmond, Cache County. Emissions are generated through ingredient mixing, cooking, heating, and
baking.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Cache County
Airs Source Size: SM

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

DAQE-IN118410010-24
Page 4

Project Description
Pepperidge Farm Incorporated (Pepperidge Farm) has requested to modify AO DAQE-AN118410009-23
with the following changes:

1. Add a new manufacturing line (Line 11) containing one (1) 16.5 MMBtu/hr, natural gas-fired oven.
2. Add one (1) 1 MMBtu/hr, natural gas-fired catalytic oxidizer to control VOC emissions from the
baking process.
3. Add one (1) cooling tower.
4. Remove one (1) 10.5 MMBtu/hr, natural gas-fired boiler (Equipment ID II.A.8 in AO
DAQE-AN118410009-23).
5. Remove one (1) 5.3 MMBtu/hr, natural gas-fired oven due to the decommissioning of cookie line 7
(Equipment ID II.A.6 in AO DAQE-AN118410009-23).
6. Update the facility-wide potential to emit (PTE) to include emissions from various natural gas-fired
comfort heaters.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 44638 70912.00
Carbon Monoxide 26.95 48.43
Nitrogen Oxides 32.24 57.81
Particulate Matter - PM10 3.38 5.32
Particulate Matter - PM2.5 3.02 4.96
Sulfur Dioxide 0.21 0.36
Volatile Organic Compounds -29.07 69.93

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 3143 9340
Generic HAPs (CAS #GHAPS) -4883 100
Hexane (CAS #110543) 0 2080
Change (TPY) Total (TPY)
Total HAPs 0.17 5.76

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in The Herald Journal on June 22, 2024. During the public comment
period the proposal and the evaluation of its impact on air quality will be available for the public to
review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will
be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the
location of the source. Any comments received during the public comment period and the hearing will be
evaluated. The proposed conditions of the AO may be changed as a result of the comments received.
DAQE-IN118410010-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

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]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

DAQE-IN118410010-24
Page 6

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.A THE APPROVED EQUIPMENT

II.A.1 Pepperidge Farm Incorporated

Commercial Baking Plant

II.A.2 Process Line No. 1

Natural gas/propane-fired oven
Maximum rating: 3.2 MMBtu/hr

II.A.3 Process Line No. 2

Natural gas/propane-fired oven
Maximum rating: 3.2 MMBtu/hr

II.A.4 Process Line No. 3

Natural gas/propane-fired oven
Maximum rating: 5.2 MMBtu/hr
Emissions control device: 1.0 MMBtu/hr catalytic oxidizer for VOC (ethanol) destruction

Radio frequency dryer: removes excess moisture from product line

II.A.5 Process Line No. 5

Natural gas/propane-fired oven
Maximum rating: 9.9 MMBtu/hr
Emissions control device: 1.0 MMBtu/hr catalytic oxidizer for VOC (ethanol) destruction

Radio frequency dryer: removes excess moisture from product line

II.A.6 Process Line No. 10

Natural gas/propane-fired oven
Maximum rating: 12.5 MMBtu/hr
Emissions control device: 1.6 MMBtu/hr catalytic oxidizer for VOC (ethanol) destruction

Radio frequency dryer: removes excess moisture from product line

II.A.7 Process Line No. 11

Natural gas/propane-fired oven
Maximum rating: 16.5 MMBtu/hr
Emissions control device: 1.0 MMBtu/hr Catalytic oxidizer for VOC (ethanol) destruction

II.A.8 Pan Washer and Dryer

Natural gas/propane-fired heater
Maximum rating: 0.8 MMBtu/hr

DAQE-IN118410010-24
Page 7

II.A.9 Storage Silos

Five (5) External Flour Storage Silos
Emissions control device: bin vents for flour dust during transfer operations

Miscellaneous storage silos that vent inside the silo building

II.A.10 Emergency Pump Engines

Manufactured Pre-1996
Fuel: Diesel Fuel

Ratings:
0.17 MMBtu/hr
0.38 MMBtu/hr
0.44 MMBtu/hr

MACT Applicability: Subpart ZZZZ

II.A.11 One (1) Cooling Tower

II.A.12 Propane Tanks

Two (2) 30,000-gallon propane storage tanks, each
One (1) 1,000-gallon propane vapor tank

II.A.13 Various Boilers

Fuel: Natural Gas
Rating: <5 MMBtu/hr, each

II.A.14 Miscellaneous Equipment

Four (4) vegetable/soy oil tanks that are each 7,000 gallons or less
Three (3) diesel oil tanks that are less than 400 gallons each
Refrigeration system
Label printer
Small sandblasting cabinet

DAQE-IN118410010-24
Page 8

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not consume more than the following:

A. 1,151,900 decatherms total of natural gas and/or propane combined per rolling
12-month period.

B. 723 gallons of diesel fuel per rolling 12-month period for stationary equipment.

[R307-401-8]

II.B.1.a.1 The owner/operator shall:

A. Determine natural gas/propane fuel consumption with billing statements.

B. Determine diesel fuel consumption with billing records, dipstick
measurements, or other appropriate methods.

C. Record both natural gas/propane and diesel fuel consumption on a
monthly basis.

D. Use the consumption data to calculate a new rolling 12-month total
by the 20th day of each month using data from the previous 12 months
for both natural gas/propane and diesel.

E. Keep the consumption records for all periods the plant is in operation .

[R307-401-8]

II.B.1.b The owner/operator shall not exceed a throughput of more than 110,508 tons of wet dough per
rolling 12-month period. [R307-401-8]

II.B.1.b.1 The owner/operator shall:

A. Determine throughput with batch scales.

B. Record throughput on a daily basis.

C. Use the throughput data to calculate a new rolling 12-month total by the 20th
day of each month using data from the previous 12 months.

D. Keep the throughput records for all periods the plant is in operation.

[R307-401-8]

DAQE-IN118410010-24
Page 9

II.B.1.c The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Natural gas/propane combustion stacks - 10% opacity.

B. Ovens and catalytic oxidizers - 10% opacity.

C. Silo bin vents and silo enclosure ventilation - 10% opacity.

D. Cooling tower - 10% opacity.

E. Diesel engines - 20% opacity.

F. All other points - 10% opacity.

[R307-401-8]

II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.d The owner/operator shall install a cooling tower that is certified to meet drift rate of 0.001% or
less. [R307-401-8]

II.B.1.d.1 To demonstrate compliance with the drift rate, the owner/operator shall keep a record of the
manufacturer's certification of the drift rate. The record shall be kept for the life of the
equipment. [R307-401-8]

II.B.2 Catalytic Oxidizer Requirements
II.B.2.a The owner/operator shall not emit more than the following VOC rates from the indicated
Catalytic Oxidizer Outlets:

Process Line lb/hr
Process Line Number 3 0.95
Process Line Number 5 2.38
Process Line Number 10 3.45
Process Line Number 11 3.45

[R307-401-8]

II.B.2.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-165-2, R307-401-8]

II.B.2.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of Process Line 11. [R307-165-2]

II.B.2.a.3 Test Frequency
The owner/operator shall conduct a stack test on the emission unit within three (3) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

DAQE-IN118410010-24
Page 10

II.B.2.b.1 Testing and Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.2.b.2 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.2.b.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.2.b.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.2.b.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.2.c Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.2.c.1 Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K).

B. Pressure - 29.92 in Hg (101.3 kPa).

C. Averaging Time - As specified in the applicable test method.

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.2.c.2 VOC
40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A,
Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

II.B.2.d The owner/operator shall route all emissions from each baking process through an oxidation
catalyst before being vented to the atmosphere. [R307-401-8]

II.B.2.e The owner/operator shall operate each oxidation catalyst according to the manufacturer's
recommendations. [R307-401-8]

II.B.2.f At all times, while operating the oxidation catalysts, the owner/operator shall maintain a
temperature at or above 700oF at each oxidation catalyst inlet and maintain a temperature rise at
or above 55oF across each oxidation catalyst. [R307-401-8]

II.B.2.f.1 The owner/operator shall monitor the catalyst inlet temperature and catalyst temperature rise with
thermocouples permanently located at each catalyst inlet and outlet. The thermocouples shall be
located such that an inspector/operator can safely read the output at any time. [R307-401-8]

DAQE-IN118410010-24
Page 11

II.B.2.f.2 The owner/operator shall monitor and record the catalyst inlet temperature and catalyst
temperature rise of each catalyst each operating day. Temperature rise shall be based on a 3-hour
rolling average of data collected every ten (10) minutes. [R307-401-8]

II.B.2.f.3 The owner/operator shall calibrate all temperature monitoring equipment according to the
manufacturer's instructions at least once every six (6) months. [R307-401-8]

II.B.3 VOC Requirements
II.B.3.a The owner/operator shall not emit more than 66.75 tons of total VOC emissions combined from
Process Line No. 3, Process Line No. 5, Process Line No. 10, and Process Line No. 11 per
rolling 12- month period. [R307-401-8]

II.B.3.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 the following equations with
applicable units to calculate VOC emissions.

Process Line No. 3, Process Line No. 5, Process Line No. 10, and Process Line No. 11 Total
VOC Emissions
= Oven Emissions + Fugitive Emissions

1) Oven Emissions
= (Fugitive Emissions) + [((Oven VOC E.F.) x (ton finished product) - (Fugitive Emissions)) *
(0.05)]
Oven VOC E.F. = 23.08 lbs/ton finished product

2) Fugitive Emissions
= (Fugitive E.F.) x (ton product dough)
Fugitive E.F. = 0.3970

[R307-401-8]

II.B.3.b The owner/operator shall maintain records of VOC emissions for all periods when the plant is in
operation. [R307-401-8]

II.B.4 Fuel Requirements
II.B.4.a The owner/operator shall only use natural gas as a primary fuel and propane as a backup fuel in
all on-site ovens, catalytic oxidizers, boilers, and heaters. [R307-203]

II.B.4.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as
fuel in each diesel-fired emergency pump engine. [R307-401-8]

II.B.4.c The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ]

II.B.4.c.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

II.B.5 Emergency Pump Engine Requirements
II.B.5.a The owner/operator shall not operate each emergency pump engine on site for more than 100
hours per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the pump engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

DAQE-IN118410010-24
Page 12

II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency pump engine shall be kept in a log and shall
include the following:

A. The date the emergency pump engine was used.

B. The duration of operation in hours.

C. The reason for the emergency pump engine usage.

[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.5.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency pump engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.5.b The owner/operator shall not operate any emergency pump engine for maintenance and readiness
testing before 8:00 am or after 6:00 pm each day. [R307-401-8]

II.B.5.b.1 The owner/operator shall keep and maintain the following records for all periods each emergency
pump engine is in operation for maintenance and testing purposes:

A. Time operations begin each day.

B. Time operations end each day.

[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN118410009-23 dated July 20, 2023
Is Derived From NOI dated August 15, 2023
Incorporates Additional Information dated February 20, 2024
Incorporates DAQE-MN118410010-24 dated March 18, 2024
Incorporates Additional Information dated April 16, 2024
Incorporates Additional Information dated June 10, 2024

DAQE-IN118410010-24
Page 13

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Herald Journal
Publication Name:
Herald Journal
Publication URL:
Publication City and State:
Logan, UT
Publication County:
Cache
Notice Popular Keyword Category:
Notice Keywords:
pepperidge farm
Notice Authentication Number:
202406241041504190228
1761527914
Notice URL:
Back
Notice File:Notice Publish Date:
THJ-ClassAd-527937-1.pdf Saturday, June 22, 2024
Notice Content
PLEASE NOTE: The following text was electronically converted from the PDF document above, and may not be 100% accurate. Because of this, please view the PDF for
the most accurate information.
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Pepperidge Farm Incorporated Location: Pepperidge Farm Incorporated-
Commercial Bakery – 901 North 200 West, Richmond, UT Project Description: Pepperidge Farm Incorporated (Pepperidge Farm) owns and
operates a commercial baking plant in Richmond, Cache County. Emissions are generated through ingredient mixing, cooking, heating, and
baking. Pepperidge Farm has requested to modify Approval Order (AO) DAQE-AN118410009-23 with the following changes: 1. Add a new
manufacturing line (Line 11) containing one (1) 16.5 MMBtu/hr, natural gas-fired oven. 2. Add one (1) 1 MMBtu/hr natural gas-fired catalytic
oxidizer to control VOC emissions
Web display limited to 1,000 characters. Please view the PDF for the complete Public Notice.
Back

DAQE-NN118410010-24

June 20, 2024

The Herald Journal
Legal Advertising Dept
1068 W 130 S
Logan, UT 84321

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in The Herald Journal on June
22, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Cache County
cc: Bear River Association of Governments

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN118410010-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Pepperidge Farm Incorporated
Location: Pepperidge Farm Incorporated- Commercial Bakery – 901 North 200 West,
Richmond, UT
Project Description: Pepperidge Farm Incorporated (Pepperidge Farm) owns and operates a
commercial baking plant in Richmond, Cache County. Emissions are generated
through ingredient mixing, cooking, heating, and baking. Pepperidge Farm has
requested to modify Approval Order (AO) DAQE-AN118410009-23 with the
following changes:

1. Add a new manufacturing line (Line 11) containing one (1) 16.5 MMBtu/hr,
natural gas-fired oven.
2. Add one (1) 1 MMBtu/hr natural gas-fired catalytic oxidizer to control VOC
emissions from the baking process.
3. Add one (1) cooling tower.
4. Remove one (1) 10.5 MMBtu/hr, natural gas-fired boiler (Equipment ID II.A.8
in AO DAQE-AN118410009-23).
5. Remove one (1) 5.3 MMBtu/hr, natural gas-fired oven due to the
decommissioning of cookie line 7 (Equipment ID II.A.6 in AO DAQE-
AN118410009-23).
6. Update the facility-wide potential to emit (PTE) to include emissions from
various natural gas-fired comfort heaters.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before July 22, 2024, will be considered in making the
final decision on the approval/disapproval of the proposed project. Email comments will also be accepted
at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of this
notice, a hearing will be held in accordance with
R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: June 22, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-GN118410010-23

{{$d1 }}

Wesley McGhee
Pepperidge Farm Incorporated
901 North 200 West
Richmond, UT 84333
[e-mail]

Dear Mr. McGhee:

RE: Replacement-in-Kind of the Line 10 Catalytic Oxidizer at Pepperidge Farm’s Richmond Bakery
(Approval Order DAQE-AN118410009-23)
Project Number: N118410010

The Utah Division of Air Quality (UDAQ) received your notification, dated August 22, 2023, concerning
the Replacement-in-Kind (RIK) of the Line 10 catalytic oxidizer at Pepperidge Farm Incorporated
(Pepperidge Farm)’s Richmond Bakery. The Utah Division of Air Quality has determined that the
exchange of the catalytic oxidizers satisfies the eligible criteria outlined in R307-401-11.

The UDAQ is currently modifying Approval Order DAQE-AN118410009-23 in response to Pepperidge
Farm’s request to add an additional manufacturing line (Line 11). The new Line 10 catalytic oxidizer
compliance requirements will be updated in the new Approval Order.

The only charge for this project is the time spent by all UDAQ staff. If you have any questions, please
contact Christine Bodell who can be reached at [phone] or [e-mail]

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:CB:jg
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#s=Sig_es_:signer1:signature}}
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — + E v A ? A B @ E w D B ˜
"-1"*"L ߥ ÛÙÛÜ
Adding
Goldfish Baking LINE 11
EF
23.08 lb/ton product Acetaldehyde
6120 lb/hr product line 11 0.070364 of VOCs
Oven +Fug
lb/hr tpy lb/hr tpy
70.625 309.336624 4.969435 21.76613
EF
Fug 0.397 lb/ton dough
8500 lb/hr dough
lb/hr tpy lb/hr tpy
1.6873 7.390155 0.118721 0.52
Oven 301.946469 21.24613
Controlled 15.09732345 1.062306
Total 22.49 1.58
**increase as a result of adding Line 11
Line Type Line #VOC CO NOx PM10 PM2.5
Cracker Line 3 Oven 4.17
Cracker Line 5 Oven 10.44
TPY
Cracker Line 10 Oven 15.1
Cracker Line 11 Oven 15.1
Cracker Line 3 Fugitive 2.04
Cracker Line 5 Fugitive 5.11
Cracker Line 10 Fugitive 7.39
Cracker Line 11 Fugitive 7.39
Cookie Line 1 NG-Oven 0.07 1.12 1.33 0.1 0.1
Cookie Line 2 NG-Oven 0.07 1.12 1.33 0.1 0.1
Cracker Line 3 NG-Oven 0.12 1.82 2.17 0.16 0.16
Cracker Line 5 NG-Oven 0.23 3.47 4.13 0.31 0.31
Cookie Line 7 NG-Oven 0.12 1.86 2.21 0.17 0.17
Cracker Line 10 NG-Oven 0.29 4.38 5.21 0.4 0.4
Cracker Line 11 NG-Oven 0.38 5.78 6.88 0.52 0.52
Cracker Line 3 NG - Cata. Ox 0.02 0.35 0.42 0.03 0.03
Cracker Line 5 NG - Cata. Ox 0.02 0.35 0.42 0.03 0.03
Cracker Line 10 NG - Cata. Ox 0.04 0.56 0.67 0.05 0.05
Cracker Line 11 NG - Cata. Ox 0.02 0.35 0.42 0.03 0.03
Diesel Fired Pumps (3)0 0.01 0.03 0 0
Misc NG Combus 1.98 30.23 35.98 2.73 2.73
Cooling Towers (2)0.49 0.11
Sorage of Cookies/Crackers Bin Vents 0.43 0.08
Total (New)70.1 51.4 61.2 5.55 4.82
Increase 24.87 36.36 43.28 3.28 3.28
Updated Calcs 70.10 51.40 61.20 5.55 4.82
Updated NOI 70.12 51.4 61.21 6.85 6.85
Permitted 99 21.48 25.57 1.94 1.94
28.88 -29.92 -35.64 -4.91 -4.91
Adding Adding
NG Oven 16.5 MMBtu/hr Catal. Ox.1
Max use of NG =138 MMscf/year Max use of
AP42, Table 1.4 AP42, Table
Criteria
Pollutant
Emission
Factor
(lb/10^6 scf)Tpy
Criteria
Pollutant
Emission
Factor
(lb/10^6
scf)
NOX 100 6.9 NOX 100
CO 84 5.80 CO 84
PM10 7.6 0.52 PM10 7.6
PM2.5 7.6 0.52 PM2.5 7.6
SO2 0.6 0.04 SO2 0.6
VOC 5.5 0.38 VOC 5.5
Lead 0.0005 0.00 Lead 0.0005
HAP 0.13 HAP
Removing Adding
NG Boiler 10.5 MMBtu/hr Misc
Max use of NG =88 MMscf/year Max use of
AP42, Table 1.4 AP42, Table
Criteria
Pollutant
Emission
Factor
(lb/10^6 scf)Tpy
Criteria
Pollutant
Emission
Factor
(lb/10^6
scf)
NOX 100 4.4 NOX 100
CO 84 3.70 CO 84
PM10 7.6 0.33 PM10 7.6
PM2.5 7.6 0.33 PM2.5 7.6
SO2 0.6 0.03 SO2 0.6
VOC 5.5 0.24 VOC 5.5
Lead 0.0005 0.00 Lead 0.0005
HAP 0.08 HAP
SO2
0.01
0.01
0.01
0.02
0.01
0.03
0.04
0
0
0 PM10
0 Table B-14 1.25 Current
0.52 Proporsed
0 1.77
0.22
**source used pm10 for both
**source used PM, not PM10 or PM2.5
0.35
0.26
3.61
0.35
0.37
0.15
-0.22
Adding
MMBtu/hr Cooling Tower
f NG =8.4 MMscf/year
e 1.4 AP42, Table 1.4
Tpy
Criteria
Pollutant lb/hr tpy
0.42 PM10 0.11 0.49
0.35 PM2.5 0.11 0.49
0.03
0.03
0.00 *not physically adding, but not in permit
0.02
0.00
0.01
MMBtu/hr TOTAL
f NG =720 MMscf/ye TOTAL
e 1.4
Tpy
36
30.24
2.74
2.74
0.22
1.98
0.00
0.68
8/16/23, 7:11 AM secure.utah.gov/cart-admin/viewOrder.html?id=DV1dN890jP
https://secure.utah.gov/cart-admin/viewOrder.html?id=DV1dN890jP 1/1
Division of Air Quality Order 9927554
Approval Order Notice of Intent
Order Date: 08/15/2023
Ship Date: 08/16/2023
Price Per Item: $2,800.00
Quantity Purchased: 1
Subtotal: $2,800.00
Item Note: Pepperidge Farm Project Finn Notice of Intent Application Richmond UT
Order Total: $2,800.00
Ship To:
Preston Pond Pepperidge Farms
,
Phone: [phone]
Email: [e-mail]
Notes:
Download Attachments
Pepperidge Farm / Project Finn
Trinity Consultants
NOTICE OF INTENT FOR PROJECT FINN
Pepperidge Farm Inc. – Richmond, Utah
Prepared by:
TRINITY CONSULTANTS
4525 Wasatch Boulevard
Suite 200
Salt Lake City, Utah 84104
[phone]
Prepared for:
Pepperidge Farms Inc.
901 N. 200W
Richmond, Utah 84333
(435)-750-8450
August 15, 2023
Project XXXXXX

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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1-1
2. GENERAL INFORMATION 2-1
2.1 Source Identification Summary ............................................................................... 2-1
2.2 Source Information and General Location ................................................................ 2-1
2.3 Source Size Determination ....................................................................................... 2-1
2.4 Notice of Intent Forms ............................................................................................. 2-1
2.5 Notice of Intent Fees ............................................................................................... 2-2
3. DESCRIPTION OF PROJECT AND PROCESS 3-1
3.1 Description of Project .............................................................................................. 3-1
3.2 Description of Process ............................................................................................. 3-1
3.2.1 Line 11 .................................................................................................................... 3-2
3.2.2 Removal of Plant Boiler ............................................................................................. 3-3
3.2.3 Cooling Towers ........................................................................................................ 3-3
4. EMISSIONS RELATED INFORMATION 4-1
4.1 Manufacturing Emissions ......................................................................................... 4-1
4.2 Combustion Emissions ............................................................................................. 4-2
4.2.1 Natural Gas ............................................................................................................. 4-2
4.2.2 Diesel Generators ..................................................................................................... 4-2
4.3 Cooling Towers ........................................................................................................ 4-3
4.4 Bin Filters ................................................................................................................ 4-3
5. BEST AVAILABLE CONTROL TECHNOLOGY 5-1
5.1 Oven VOC Emissions ................................................................................................ 5-1
5.1.1 Step 1 – Identify All Available Control Technologies .................................................... 5-1
5.1.2 Step 2 – Assess Technical Feasibility .......................................................................... 5-2
5.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ....................... 5-4
5.1.4 Steps 4 and 5 – Evaluate Most Effective Controls and Select BACT ............................... 5-5
5.2 Fugitive (Proofing) Emissions .................................................................................. 5-5
5.2.1 Step 1 – Identify All Available Control Technologies .................................................... 5-5
5.2.2 Steps 2 and 3 – Eliminate Technically Infeasible Options ............................................. 5-5
5.2.3 Step 4 – Economic and Environmental Considerations ................................................. 5-6
5.2.4 Step 5 – Select BACT ................................................................................................ 5-7
5.3 Oven Combustion Emissions .................................................................................... 5-7
5.3.1 Step 1 – Identify All Available Controls ....................................................................... 5-7
5.3.2 Step 2 – Eliminate Technically Infeasible Options ........................................................ 5-8
5.3.3 Steps 3-5 Select BACT .............................................................................................. 5-9
5.3.4 Other Criteria Pollutants ............................................................................................ 5-9
5.4 PM10 and PM2.5 Ingredient Transfer ......................................................................... 5-9
5.4.1 Step 1 – Identify All Available Controls ..................................................................... 5-10
5.4.2 Steps 2-4 – Eliminate Technically/Economically Infeasible Options .............................. 5-10
5.4.3 Step 5 – Select BACT .............................................................................................. 5-10
5.5 Cooling Towers ...................................................................................................... 5-10
5.5.1 Step 1 – Identify All Available Controls ..................................................................... 5-10
5.5.2 Step 2-5 – Select BACT ........................................................................................... 5-11

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5.6 Other Small Combustion Sources ........................................................................... 5-11
5.6.1 NOX Technologies ................................................................................................... 5-11
5.6.2 Other Criteria Pollutants .......................................................................................... 5-13
6. EMISSION IMPACT ANALYSIS 6-1
7. NONATTAINMENT/MAINTENACE AREAS – OFFSETTING 7-1
8. APPLICABLE REGULATIONS 8-1
8.1 UDAQ Air Quality Rules ............................................................................................ 8-1
8.1.1 UAC R307-165: Emission Testing ............................................................................... 8-4
8.1.2 UAC R307-230 Permits: NOX Emission Limits for Natural Gas-Fired Water Heaters ......... 8-5
8.1.3 UAC R307-303: Commercial Cooking .......................................................................... 8-5
8.1.4 UAC R307-315: NOX Emission Limits for Natural Gas-Fired Boilers, Steam Generators, and
Process Heaters; 2.0-5.0 MMBtu .......................................................................................... 8-5
8.1.5 UAC R307-316: NOX Emissions for Natural Gas-Fired Boilers Greater Than 5.0 MMBtu.... 8-5
8.1.6 UAC R307-342: Adhesives and Sealants ..................................................................... 8-5
8.1.7 UAC R307-406: Visibility ........................................................................................... 8-5
8.2 Federal Rules: National Emission Standards for Hazardous Air Pollutants ................ 8-5
8.2.1 Subpart A – General Provisions .................................................................................. 8-6
8.2.2 Subpart Q – Industrial Process Cooling Towers ........................................................... 8-6
8.3 Federal Rules: New Source Performance Standards ................................................. 8-6
APPENDIX A. FORMS A-1
APPENDIX B. EMISSION CALCULATIONS B-1

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1. EXECUTIVE SUMMARY
Pepperidge Farm owns and operates a commercial bakery in Richmond, Utah. The bakery is located in an
area that is in attainment for all pollutants except PM2.5 and its precursors, for which it has been designated
as a maintenance area. The Logan UT-ID nonattainment area was previously designated as moderate
nonattainment for PM2.5 and redesignated into a maintenance area in 2021. The Richmond Plant is
permitted as a minor source under Utah approval order (AO) (i.e., air permit) No. DAQE-AN118410009-23.

At this time, Pepperidge Farm is proposing to add an additional manufacturing line, similar in size to line 10
which is currently in operation at the Richmond Bakery. This line (Line 11) will have combustion emissions
associated with an oven and VOC emissions associated with yeast. An additional Catalytic Oxidizer to control
VOC emissions from the baking process as well as cooling towers are included in the project scope. Finally,
Pepperidge Farm is proposing to remove one (1) 10.5 MMBtu/hr boiler. This capital project referred to as
“Project Finn.”

Additionally, Pepperidge Farm is taking this opportunity to bring a list of emission sources onsite into
accordance with current UDAQ guidance. Pepperidge Farm has included all existing and proposed minor
sources, bin filters, and cooling towers within the proposed potential to emit (PTE) for the Richmond Plant.
This NOI application has been developed pursuant to Utah Administrative Code (UAC) R307-401-5 and
Utah’s application guidance including but not limited to:

► NOI Forms and Fees;
► Process Description;
► PTE Calculations;
► Best Available Control Technology (BACT) Analysis;
► Applicable Requirements; and
► Emission Impact Analysis Applicability.

Pepperidge Farm is also submitting a letter for a Replacement in Kind for the Catalytic Oxidizer for Line 10.
While the existing oxidizer used for line 10 will be used for Line 11 this replacement is being addressed
separately due to project needs.

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2. GENERAL INFORMATION
The following section contains the information requested under the “Source Identification Information”
section of UDAQ Form 1 Notice of Intent (NOI) Application Checklist.
2.1 Source Identification Summary
► Company Name: Pepperidge Farm Incorporated
► Address: 901 N 200 W, Richmond, UT, 84333
► County: Cache County
► UTM Coordinates: Easting: 432,484 m, Northing: 4,643,210 m, Zone 12
► Primary SIC Code: 2051 (Bread & Other Bakery Products, Except Cookies &
Crackers)
► Area Designation: Maintenance for PM2.5
► Source Size Determination: Minor Source
► Current AO: DAQE-AN118410009-23

All correspondence regarding this submission should be addressed t o:

Wesley McGhee
Environmental Manager
Pepperidge Farm Incorporated Commercial Bakery
Phone: [phone]
[e-mail]

2.2 Source Information and General Location
The facility is located in Cache County at 901 N 200 W, Richmond UT. Cache County is in attainment with
the National Ambient Air Quality Standards (NAAQS) for all criteria pollutants with the exception of PM 2.5. In
2021 portions of Cache County were designated as maintenance areas for PM2.5. As such, the major source
thresholds for PM2.5 and its precursors (NOX, SO2, VOCs, and Ammonia (NH3)) in this location are 100 tons
per year (tpy).1 Currently, the facility is permitted in accordance with Approval Order No. DAQE -
AN118410009-23.
2.3 Source Size Determination
As presented in Appendix B, Table B-1, site-wide emissions are within the major source threshold (MST) for
PM2.5 and NOx, and VOCs as precursors. As such, Pepperidge Farm is classified as a minor source under
Non-attainment New Source Review (NNSR).
2.4 Notice of Intent Forms
The following UDAQ forms have been included with the NOI application:

1 Utah Nonattainment/Maintenance Status for Each County by Year for All Criteria Pollutants | Green Book | US EPA

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► Form 1 – Notice of Intent Application Checklist;
► Form 2 – Source Identification Information;
► Form 4 – Project Information; and
► Form 5 – Emissions Information Criteria/GHGs/HAPs.
2.5 Notice of Intent Fees
Pepperidge Farm will use the UDAQ’s Payment Portal to prepay the following UDAQ NOI fees associated
with this submittal:

“Application Filing Fee” for the “New Minor Source or Minor Modification at Minor or Major Source” category
= $500

“Application Review Fee” for the “New Minor Source or Minor Modification at Minor or Major Source”
category in maintenance or non-attainment areas = $2,300

Total UDAQ fees = $2,800

Pepperidge Farm understands that the total permit review fee is based on the total actual time spent by
UDAQ staff processing this NOI. Upon issuance of the AO, if the total review time is more than 20 standard
hours, UDAQ will invoice P&G at $115 per hour for the additional time above 20 standard hours.

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3. DESCRIPTION OF PROJECT AND PROCESS
3.1 Description of Project
In response to growing demand for Goldfish® crackers, Pepperidge Farm is proposing to add an additional
Goldfish® manufacturing line, line 11, similar in size to line 10 which is currently in operation at the
Richmond Bakery. Line 11 will result in combustion emissions associated with an oven, as well as VOC
emissions associated with yeast. An additional Catalytic Oxidizer to control VOC emissions from the baking
process will be installed as well as three (3) additional cooling towers. Finally, Pepperidge Farm is proposing
to remove one (1) 10.5 MMBtu/hr boiler.

Additionally, Pepperidge Farm is taking this opportunity to bring a list of emission sources onsite into
accordance with current UDAQ guidance. Previously omitted emission sources includes all existing and
proposed minor sources (HVAC units, humidifiers, process heaters, etc.), bin filters, and cooling towers
within the proposed potential to emit (PTE) for the Richmond Plant. As a result, a plant wide PTE is
presented in Appendix B.
3.2 Description of Process
As previously discussed, Pepperidge Farm is proposing the addition of one (1) new cracker line. This section
provides additional description of the manufacturing process and a process flow diagram (PFD) is presented
in Figure 3-1.

Upon installation of the new proposed line, raw ingredients will be fed into a mixer to create cracker dough.
The dough is then transferred to a proofing room where the yeast is allowed to ferment and cause the
dough to rise. Once the dough has finished proofing, it runs through a se ries of rollers which both laminates
and shapes the dough into thin sheets. The dough is cut and sent to bake in an oven which is heated using
natural gas burners. Once out of the oven, the crackers are heat sealed in packaging and ready for
shipment.

Throughout the process small process heaters, air conditioning units, and humidifiers are utilized to
maintain the correct temperature and humidity for production. The raw ingredients are received onsite from
either bulk trucks or totes. Solid ingredients are stored in silos which are controlled with bin vent filters.
Packaging material is received in pre-made sheets.

Emissions attributed to each step in the production line are outlined in the PFD and following sections.
Further detail regarding each step is provided in subsequent sections.

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Figure 3-1. New Cracker Line PFD

3.2.1 Line 11
3.2.1.1 Mixing
This step results in an increase in combustion emissions from the mixing room. In the mixing step, dry
ingredients are combined with water, then transferred to a trough full of flour. This trough has a lid with
rotating blades which is lowered, and the thickened dough is fully mixed. Because the emissions from these
steps are attributed only to the process heaters and humidifiers, the emissions will be removed using small
stacks.
3.2.1.2 Proofing
In this step, fugitive VOC emissions are released when the surface of the risen cracker dough is broken.
After the dough has been fully mixed, it is transferred to a warm, humidity-controlled environment and
allowed to rise. During this fermenting process, yeast inside of the dough creates CO2, which is contained
within the dough until the surface of the dough is manually disturbed before moving on to the
laminating/shaping step. This fermenting process results in an increase in VOC emissions with the increased
production of cracker dough. This step also leads to an increase in combustion emissions from the Line 11
Humidifier, Tote Wash Steam Generator, and Trough Wash Steam Generator. Both combustion and VOC
emissions are negligible in amount, thus allowing for the emissions to be removed using small stacks.
3.2.1.3 Laminating/Shaping
In the laminating/shaping step, dough is layered and flattened as it passes through industrial rollers. The
flattened dough then passes through a die which cuts the dough into individual crackers. Because the
emissions from these steps are attributed only to the process heaters and humidifiers, the emissions will be
removed using small stacks.
3.2.1.4 Baking
Ethanol, created as a product of fermentation within the cracker dough, evaporates at approximately zone
three (3) in the oven, emitting VOCs. This results in an increase in VOC emissions with the increased

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production of crackers. The new line 11 oven burners will also produce combustion emissions as they heat
the oven.

VOC emissions from the ethanol released during baking are captured by an internal oven vent with 100%
capture efficiency. These emissions are then passed through a catalytic oxidizer with a control efficiency of
95%.
3.2.1.5 Packaging
After passing through the oven, the crackers are heat-sealed into their pre-made packaging. This step
results in an increase in combustion emissions from the Finished Goods Warehouse, Tote Storage Room,
Palletizer, Packaging, and Utility Pump Room.
3.2.2 Removal of Plant Boiler
It is proposed that one (1) utility boiler should be removed. This boiler has a rating of 10.5 MMBtu/hr, and
its removal will cause a decrease combustion emissions.
3.2.3 Cooling Towers
Pepperidge Farm currently operates one cooling tower consisting of two (2) cooling cells. In addition to the
new cracker line, Pepperidge Farm is proposing to install three (3) eco-Air Series V-configuration Industrial
Adiabatic Coolers to support this operation. Due to the adiabatic method of cooling, these cooling towers
are anticipated to have no emissions.

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4. EMISSIONS RELATED INFORMATION
This section details the methodology used to calculate controlled and uncontrolled emissions for criteria
pollutants, greenhouse gases, and HAPs associated with each new unit and its associated fugitives as
regulated by R307-401-5(2)(b). Detailed emission calculation tables are included in Appendix B.
4.1 Manufacturing Emissions
Pepperidge Farm utilizes yeast to produce Goldfish crackers. This yeast ferments and produces carbon
dioxide that gives the crackers their indicative texture. Ethanol and Acetaldehyde are produced as
byproducts of this fermentation. Ethanol is classified as a VOC and Acetaldehyde is classified as both a VOC
and HAP.

Over the past several years Pepperidge Farm has been evaluating emissions from its cracker lines. As a
critical step toward ensuring fugitive emissions were representative of the process, Pepperidge Farm
conducted stack testing to further define fugitive emission rates from a cracker line at a similar facility in
Willard, Ohio. Using the stack test data, Pepperidge Farm developed updated overall line emission rates,
further defined fugitive emission rates, and confirmed the control efficiency of control equipment.

Uncontrolled total emissions are the sum of fugitive emissions from the fermentation process and oven
emissions which result from baking the crackers and are controlled by a catalytic oxidizer. Pepperidge Farm
developed an emission factor which encompasses both fugitive and oven emission through stack testing
conducted in Denver, PA in 1998. This factor is based on finished product throughput and the equation is as
follows:

Uncontrolled Total Emissions (lb VOC
hr )
=Overall Emission Factor (lb VOC
ton goldfish)∗Product Throughput (lb goldfish
hr )
∗(ton
2000 lb)

Where:
Overall Emission Factor =23.08 (lb VOC
ton goldfish)

During the mixing, proofing, sheeting, and laminating process steps , a small amount of the ethanol and
acetaldehyde have the potential to evaporate into the manufacturing space. These emissions are fugitive in
nature, uncontrolled, and released via air vents within the manufacturing building. This fugitive emission
factor used was obtained through testing in the Willard, OH Proof Room in 2020 and is based on tons of wet
dough. Potential fugitive emissions were calculated as follows:

Fugitive Emissions (lb VOC
hr )
=Fugitive Emission Factor (lb VOC
ton dough)∗Dough Throughput (lb dough
hr )∗(ton dough
2000 lb dough)

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Where:
Fugitive Emission Factor =0.397 (lb VOC
ton dough)

In order to quantify the emissions produced within the oven the uncontrolled fugitives are subtracte d from
the total uncontrolled emissions.

Uncontrolled Oven Emissions (lb VOC
hr )
=(Uncontrolled Total Emissions (lb VOC
hr )−Fugitive Emissions (lb VOC
hr ))

Oven emissions result from the yeasted product being baked in the oven . During baking the ethanol and
acetaldehyde produced by the yeast reach their boiling points and thus evaporate into the oven chamber.
The boiling point for each of these pollutants is reached within the center of the oven which allows for a
100% capture efficiency. These emissions are controlled with a catalytic oxidizer and the controlled
emission rate for the oven is calculated as follows:

Controlled Oven Emissions = Uncontrolled Oven Emissions (lb VOC
hr )∗(1 −Control Efficiency (%))

Total process emissions are the sum of the controlled oven emissions and the fugitive emissions:

Total Process Emissions =Controlled Oven Emissions +Fugitive emissions
4.2 Combustion Emissions
4.2.1 Natural Gas
This section includes Criteria Pollutants, HAPs, and GHGs resulting from the modification. These emissions
are produced by the oven burners, plant boiler, pan washer and dryer, catalytic oxidizer, and any minor
sources. All potential emissions for this section have been calculated using standard EPA emission factors for
natural gas combustion found in AP-42 Section 1.4 and 40 CFR 98 Subpart C tables C-1 and C-2 with global
warming potentials from 40 CFR 98 table A-1. 1050 Btu/scf was used as the high heating value of natural
gas, in accordance with plant records. The general format for all provided emission factors is consistent, and
total emissions have been calculated as follows:

Total Emissions (tpy)=Emission Factor (lb
MMBtu)∗Heat Input (MMBtu
hr )∗Annual Operation (hr
yr)∗1 ton
2000 lb

Where:
Heat Input =1050 (MMBtu
hr )

4.2.2 Diesel Generators
Emission calculations were performed for each of the generators, with a proposed cap of 100 hours of
operation per year per generator, inclusive of testing and maintenance. Calculations for each of the criteria

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pollutants are based on the annual hours of operation at the maximum power output of each engine.
Emission factors (EF) for diesel-fired operation were obtained from AP-42 Section 3.3.

The following calculations were carried out for each generator for NO X, CO, PM10, PM2.5, SO2, and VOCs.

Annual Emission Rate (tpy)
=Emission Factor (lb
MMBtu)× Heating Value of Diesel (MMBtu
lb )× Denstity of Diesel (lb
gal)
× Disel Usage (gal
hr )Hours of Operation (hrs
yr )× (1 ton
2000 lbs)
4.3 Cooling Towers
An increase in PM2.5 and PM10 emissions will result from the addition of the existing two (2) cell cooling
tower. Potential hourly emissions from the cooling towers were calculated using the methodology outlined in
the Fifth Edition (1995) of AP-42 Section 13.4-1:

PM (lb
hr)=Drift (%)∗TDS (ppm)∗Density (lb
gal)∗Flowrate (gal
min)∗1
106 ∗60 (min
hr )
PM (tpy)=PM (lb
gal)∗Annual Operation (hr
yr)∗(1 ton
2000 lb)

Where:
PM = PM10 or PM2.5 emissions
Drift = Percentage of recirculating water that is lost as drift (%)
Flowrate = Recirculation rate of water in the cooling tower (gal
min)
TDS = Total dissolved solids of recirculating water (ppm)
Density = Density of water (8.34) (lb
gal)
4.4 Bin Filters
The proposed storage silo will be controlled by nine (9) bin filters (baghouses). The emissions from the bin
filters consist of PM10 and PM2.5. Emissions are based on the annual throughput of grain storage and
estimated particulate emission factors for storage bin vents per AP 42 Section 9.9.1.2

PM (lb
yr)=Annual Throughput (ton
yr )∗PM Emission Factor (lb
ton)
PM (tpy)=PM (lb
yr)∗(1 ton
2000 lb)

Where:
PM =PM, PM10 or PM2.5 emissions

2 AP 42 Section 9.9.1, Grain Elevators and Processes, Table 9.9.1-1. AP-42 9.9.1 Grain Elevators And Processes (epa.gov)

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PM Emission Factor =0.25 (lb
ton)
PM10 Emission Factor =0.0063 (lb
ton)
PM2.5 Emission Factor =0.0011 (lb
ton)

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5. BEST AVAILABLE CONTROL TECHNOLOGY
In the State of Utah, under R307-401-5(2)(d), Notice of Intent, every facility, operation, or process that
proposes any activity that would emit an air contaminant into the air, must consider BACT for a proposed
new source or modification.3 The below BACT analysis only addresses units which will be modified, installed,
or otherwise addressed in this NOI.

The UDAQ NOI Guide details the requirements to achieve BACT as required in the State of Utah permitting
process. The proposed BACT must be based on the most effective engineering techniques and control
equipment to minimize emission of air contaminants into the outside env ironment from its process.
5.1 Oven VOC Emissions
Oven emissions are produced as the yeast uses sugars added to the dough or converts starches in the
dough to sugars to support the generation of new yeast cells. This conversion occurs under anaerobic
conditions and results in the generation of ethanol and other by-products within the dough. When the
dough is baked in an oven the internal temperature of the product exceeds the boiling point of ethanol and
the ethanol is vaporized, resulting in VOC emissions. Typically, ethanol is vaporized after the dough has
been baking for several minutes, has reached the appropriate internal temperature, and is located in Zone 3
of the oven. These emissions are directed to centralized stacks and controlled with a catalytic oxidizer. This
section of the BACT analysis focuses on the VOC emissions resulting from baking within an oven.
5.1.1 Step 1 – Identify All Available Control Technologies
The first step in the BACT analysis is to identify all available control technologies. VOC control technologies
were identified from Trinity’s search based on the following references:

► South Coast Air Quality Management District (SCAQMD);
► Search of the RACT/BACT/LAER Clearinghouse (RBLC), for Process Code 70.55 – Bakeries and Snack
Food, was conducted on March 9, 2023.
From this review, Trinity identified six available control technologies:
► Carbon adsorption unit;
► Thermal oxidizer;
► Catalytic oxidizer;
► Condensation unit;
► Wet packed bed scrubber; and
► Good Work Practices.

The identified controls are further described below.

3 UAC R307-401-4

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5.1.2 Step 2 – Assess Technical Feasibility
Carbon Adsorption Unit
A carbon adsorption unit is a means of emission control that consists of one to several beds of activated
carbon, through which exhaust passes. Activated carbon adsorbs the VOCs in the exhaust onto its large
surface area, resulting in clean air for emission. Over time, the bed or beds become saturated as the VOCs
fill in carbon surface area, reducing efficiency. The carbon beds are regenerated by passing steam through
them, stripping the VOCs from the carbon particles. VOCs are recovered from the steam by condensing the
mixture, allowing for disposal or recovery. Carbon adsorption units typically achieve up to 95% VOC
reduction efficiencies.

Carbon adsorption control units are considered technologically infeasible for bakery ovens for several
reasons. First, ethanol is the primary organic gas present in exhaust from natural-gas bakery ovens; ethanol
has a high affinity to carbon, meaning that it is not easily stripped from the activated carbon particles. This
leads to lower control efficiencies, which continue to decrease the more the particles are used. In addition,
oils and fats present in oven will clog the pores of the carbon particles. This also reduces the life and utility
of the carbon. Carbon adsorption units are therefore technologically infeasible for bakery ovens and are not
considered a viable control technology for Pepperidge Farm.4
Thermal Oxidizer
Thermal oxidizers (TOs) regularly achieve up to 98% destruction efficiencies because of the inherent
efficiency of the combustion processes.5 TOs typically consist of an enclosed combustion chamber with an
auxiliary burner fired with a conventional fuel. The firing rate of the burner is automatically controlled to
maintain a preset combustion-chamber temperature. TOs provide maximum operating flexibility because
they can handle CO and most known VOCs at a wide range of concentrations and f lows. However, TOs
require relatively high fuel input because of operating temperatures. Heat recovery is frequently used with
TO systems to minimize the fuel operating cost, especially with low concentrations of VOC. Heat recovery
devices used in VOC systems are most commonly indirect recuperative heat exchangers or thermal mass
regenerative heat exchangers.

The three main types of TO systems include direct flame, regenerative TO, and recuperative TO, which are
differentiated by the type of heat recovery equipment used.

► Direct Flame: A direct flame thermal oxidizer consists of only a combustion chamber with no heat
recovery equipment.
► Regenerative Thermal Oxidizers: Each oxidizer contains several large “cells” which are filled with ceramic
packing. These systems employ a large thermal mass to collect heat and return it to the incoming fume.
The cells are alternated from heat-up to cool-down cycles for fume preheating by a series of dampers
and ducts on the outlet side of the system. These units can achieve high removal efficiencies (95 - 98%)
at temperatures from 1,400-1,500°F because of the thorough mixing in the ceramic packing sections.

4 From RBLC, BAAQMD, SCAQMD, and searches, January 2022.
5 Per EPA Air Pollution Control Technology Fact Sheet, Thermal Incinerator. EPA-452/F-03-022.

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These systems are more maintenance-intensive than recuperative types because of the mechanical
system that performs the alternating of cells.
► Recuperative Thermal Oxidizers: These systems employ an indirect heat exchanger device to preheat
the VOC and CO-laden fume. They are applied to oxidizers that operate at temperatures as high as
1,800°F. The maximum design efficiency is usually dictated by the exchanger outlet temperature and
the VOC content in the stream.
In general, TOs are less efficient at treating waste gas streams with highly variable flow rates, since the
variable flow rate results in varying residence times, combustion chamber temperature, and poor mixing.

Based on available information, thermal oxidizing controls are considered technologically feasible and will be
further considered for Pepperidge Farm.
Catalytic Oxidizer
Catalytic oxidation is the process of oxidizing organic contaminants in a waste gas stream within a heated
chamber containing a catalyst bed in the presence of oxygen for sufficient time to completely oxidize the
organic contaminants to carbon dioxide and water. The catalyst is used to lower the activation energy of the
oxidation reaction. The residence time, temperature, flow velocity, mixing, oxygen concentration, and type
of catalyst used in the combustion chamber affect the oxidation rate and destruction/conversion efficiency.
Catalytic oxidizers typically require combustion of an auxiliary fuel (e.g., natural gas) to maintain a
combustion chamber temperature high enough to completely oxidize the contaminant gases, and as w ith
the thermal oxidizers, fume preheating devices are commonly used to minimize operating costs. Catalytic
oxidizers are typically designed to have a residence time of 0.5 seconds or less and combustion chamber
temperatures between 600 and 1,200 degrees Fahrenheit (°F).

This is considered technologically feasible for the ovens, and is the most commonly used control technology
found in the aforementioned RBLC and California air quality districts search . Pepperidge Farm currently
operates three catalytic oxidizers, installed on lines 3, 5, and 10, and has observed a control efficiency of
95-96%.
Condensation Unit
Emissions sources that have low flow rates of high -concentration VOCs (up to 100%), such as tank vents,
are ideal applications for refrigerated and cryogenic condensers. The condensed liquid is returned to the
process, and non-condensable liquids (with low levels of VOCs) are vented to the atmosphere.

Single stage condensing systems, which can reduce the vented gas stream to minus 20°F, can be use d for
high boiling compounds (such as gasoline tank vapors from tank transfer operations), and can achieve 90 -
95% control efficiencies. High control efficiencies require lower temperatures and more complexity, such as
multiple stages and pumping systems.

Cascade (multi-stage) condensing systems use cryogenics that can produce temperatures as low as minus
120°F. These systems are required for lower molecular weight VOCs with high vapor pressures, or for vent
streams with significant condensable components, such as nitrogen from air.
Emissions sources that have low flow rates of high concentration VOCs (up to 100%) such as tank vents are
ideal applications for refrigerated and cryogenic condensers. Because the ovens release a high air flow, a

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condensation unit is not an optimal control technology. From the RBLC search, condensation has not proven
technologically feasible for the control of VOCs in bakery/snack ovens. Additionally, there is an added
difficulty of the treatment and disposal of the resulting wastewater. For these reasons, condensation units
are not considered feasible control technology.
Wet Packed-Bed Scrubber
A wet packed-bed scrubber is an air pollution control device that rem oves VOCs from stationary point source
waste streams. VOCs are primarily removed through the impaction, diffusion, interception, and/or
absorption of the pollutant onto droplets of liquid. This weighs the droplets down, such that they fall back to
the surface of the packed bed. Wet packed-bed scrubbers can typically attain removal efficiencies greater
than 80% for VOCs in general.

Wet packed-bed scrubbers are considered technologically feasible as a control method for VOC emissions
from the oven. However, the use of scrubbing control technology introduces problems associated with
substantial water needs and wastewater production/disposal. The process produces wastewater that
requires the use or installation of a wastewater treatment plant or ethanol recover y unit, arguably
outweighing the benefits from its VOC absorption. This waste must be properly handled, treated, and
disposed of at a waste treatment facility or landfill. For these reasons, wet packed-bed scrubbers as VOC
control technologies have been eliminated from further consideration.

Good Work Practices
Good work practices include the performance of regular cleaning operations, in accordance with the
standard that has been found in the RBLC search. Specifically, the work includes:

► Regular Cleaning:
• Removal of dough and/or bread from the oven by scraping and sweeping, or otherwise.
• Wiping off the interior of the ovens where necessary;
• Removal of oil, dough, bread, or other accumulated waste from the interior and exterior of the
ovens.

Good work practices are currently implemented at Pepperidge Farm.
5.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
Pepperidge Farm ranked the potential control technologies presented above based on control efficiencies
documented in EPA’s Fact Sheets, as described in Table 5-1, below.
Table 5-1. Summary for Oven Emission Control
Control Technologies Rank Percent
Control
Catalytic Oxidizer 1 95-98
Thermal Oxidizer 1 95
Good Work Practices 2 Inherent

Catalytic Oxidizers and thermal oxidizers have been given the same control ranking because they have
comparable control efficiencies. However, thermal oxidizers operate at higher operating temperatures than

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catalytic oxidizers, which requires higher volumes of natural gas consumption. The higher volumes of
natural gas result in not only a higher cost but a higher overall emission rate when combustion emissions
are considered. Since thermal oxidizers are less established within the industry, have a comparable control
efficiency, result in a larger economic impact, and produce a larger environmental impact, thermal oxidizers
are not further considered.
5.1.4 Steps 4 and 5 – Evaluate Most Effective Controls and Select BACT
Pepperidge Farm proposes that the use of a catalytic oxidizer with a control efficiency of 95% in addition to
good work practices is BACT.
5.2 Fugitive (Proofing) Emissions
Minimal amounts of fugitive VOC emissions result from mixing, proofing, sheeting, and laminating process
steps. VOC emissions resulting from these steps are the result of yeast activity, primarily in the proofing
process. During the proofing process, the dough is kept at a specific temperature and relative humidity to
allow yeast to grow and release ethanol and carbon dioxide which in turn develops product crumb structure,
texture, and volume.

In order to ensure product quality and minimize the energy load required for production, care is taken to
minimize exhausts from these rooms, thereby minimizing the cost of heating and humidifying them.6
Significant VOC emissions do not result from this process as the ethanol developed remains primarily in a
liquid state until it reaches elevated temperatures in the baking process.
5.2.1 Step 1 – Identify All Available Control Technologies
VOC control technologies were identified based on review of the RBLC and BACT determinations published
by the South Coast Air Quality Management District (SCAQMD).7 Neither of these sources provided any
indication that the proof boxes were controlled by a standalone device. As a result, this BACT analysis
focuses on the capture of VOC generated from proofing and the resulting gas stream characteristics with
the understanding that VOC must be captured and gas stream characteristics must be compatible prior to
further control.
5.2.2 Steps 2 and 3 – Eliminate Technically Infeasible Options
In order to implement a standalone control device, emissions must first be captured and routed to a central
location. The standard capture methods for product manufacturing can be broadly described as specified
pick-up vents and enclosures.

Pick-up Vents
Specified pick-up vents generally consist of a vacuum strategically placed over the VOC emitting process.
For example, a fan located over a process tank, or a pick-up point located next to a printer. These pick-up
vents generally have a high-capture efficiency because the emission rate at that location is constant.
Proofing is conducted for large amounts of dough over several hours during which minimal VOC evaporation
will occur and thus rendering the use of a pick-up vent technically infeasible.

6 Alternative Control Technology Document for Bakery Oven Emissions, EPA-453/R-92-017
7 RBLC data was pulled for Bakeries and Snack Products on 01/05/2022

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Enclosure
An enclosure entails confining the emissions with physical boundaries. Enclosures generally work by drawing
more air out of the enclosure than enters it, thus evacuating the VOC from the area with exhaust gases.
This imbalance in air flow creates a negative pressure within the enclosure. Enclosures come in many forms
but are generally effective when the VOC emissions are generated within a relatively small space.
Manufacturing examples include ovens or other process-specific equipment.

VOC emissions from proofing are generated as the dough lies in troughs open to the room at an
inconsistent rate. Table 5-2 compares the known operating limits of the previously evaluated control
technologies. Additionally, this table identifies established technical infeasibility documented under the stack
emission analysis contained in Section 5.1 of this report.
Table 5-2. Summary for Oven VOC Emission Control
Control Technology Control Technology
Concentration
Requirement
Other Technical
Feasibility
Technically Feasible?
Carbon Absorbers 50 to 2,000 ppm8 Ethanol clogs activated
carbon particles
No
Catalytic Oxidation Low Concentrations9 Not Applicable Yes
Condensation Unit High Concentrations10 Not Applicable No
Thermal Incineration 1,500 to 3,000 ppm11 Not Applicable No
Wet Packed Scrubber 250 to 10,000 ppm12 Wastewater disposal No

Table 5-2 demonstrates that only catalytic oxidation may be technically feasible. Catalytic oxidation has not
been applied to the control of proofing emissions within the industry and thus technical feasibility is
theoretical and would need to be further discussed with a manufacturer. For completeness catalytic
oxidation has been considered further.
5.2.3 Step 4 – Economic and Environmental Considerations
While the available information demonstrates the use of catalytic oxidation may be technically feasible the
concentration to be treated is at the lower extreme of feasible concentration range. The low volume of VOC
to be treated leads to environmental concerns.

Catalytic oxidizers operate at temperatures between 600 ºF to 800 ºF and thus require an external heat
source, such as a natural gas burner. The combustion of natural gas emits additional criteria pollutants

8 EPA’s Technical Bulletin, Choosing an Adsoption System for VOC: Carbon, Zeolite, or Polymers?, published may 1999 EPA
445/F-99-004
9 EPA’s Air Pollution Control Technology Fact Sheet, Catalytic Incinerator, EPA-452/F-03-018, Does document Down to 1 ppm
as lower concentrations and operating flow rates. However, Pepperidge Farm has seen control efficiencies at 95 -96% which is
between 4-12 ppm based on the typical inlet concentrations.
10 EPA’s Technical Bulletin, Refigerated Condensors for the Control of Organic Air Emissions, published Decemeber 2001, EPA -
456/R-01-004
11 EPA’s Air Pollution Control Technology Fact Sheet, Thermal Incinerator, EPA-452/F-03-022
12 EPA’s Air Pollution Control Technology Fact Sheet, Packed-Bed/Packed-Tower Wet Scrubber, EPA-452/F-03-015

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which increases the potential environmental impact. Given the low emission rate anticipated, it is likely that
emissions resulting from the control device will negate the control effectiveness of the device.
5.2.4 Step 5 – Select BACT
Due to the technical, and environmental difficulties associated with the capture of VOCs, the control of
fugitive emissions through the use of a centralized control device, such as a catalytic oxidizer, has been
determined to be technically infeasible and eliminated from BACT. No feasible BACT options are available.
5.3 Oven Combustion Emissions
The proposed line will contain an oven rated at 16.5 MMBtu/hr. This unit is several meters long and as a
result the heat load is distributed through six (6) different zones each with a burner over the conveyor and
another under the conveyor, this configuration results in twelve (12) individual burners fired on natural gas.
The use of natural gas allows for a small emission profile, generally the most significant emission rate is that
of NOx, thus this BACT section focuses on NOx.

NOx formed during combustion results from two (2) major mechanisms: thermal NO x and fuel NOx.
Because natural gas is relatively free of fuel-bound nitrogen, the contribution of NOx emissions in natural
gas-fired equipment is minimal, leaving thermal NOx as the main source of NOx emissions. Thermal NOx
formation is a function of residence time, oxygen level, and flame temperature, and can be minimized by
controlling these elements in the design of the combustion equipment.

CO emissions are often related to NOx emissions in that the same air-to-fuel ratios that affect the NOx
emission rate also determine the CO emission rate. SO2, VOC, PM2.5, and PM10 emissions are generally
considered low when combusting natural gas. As a result, no additional technologies, beyond good
combustion practices, have been identified for these pollutants. As discussed in Section 5.3.3 Pepperidge
Farm proposes to utilize good combustion practices.
5.3.1 Step 1 – Identify All Available Controls
Available control technologies for NOx were identified via the search of SCAQMD, SJVAPCD, and RBLC on
March 9, 2023. The RBLC search did not contain any NO x control technologies for bakeries. The results of
this search are contained in table 5-3.

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Table 5-3. Research for Oven NOx Emission Control
Table B-1. NOX BACT Research Results
Source and
Location
NOX Total
Emissions Rate Oven Size Controls
Permit
Date
Install
Date
San Joaquin Valley
Unified Air Pollution
Control District
5 ppmvd @ 3% O2
(0.0062 lb/MMBtu)
5< but <20
MMBtu/hr
11/30/2022

Sacramento
Metropolitan AQMD
40 ppmv @ 3% O2
(0.049 lb/MMBtu) 10/25/2018

Glasso's Bakery,
Mira Loma, CA,
SCAQMD
40 PPM 5.4 MMBtu/hr Catalytic
Oxidizer 10/6/2016

Frito-Lay, Inc.,
Rancho Cucamonga,
CA, SCAQMD
54 PPMV @ 3% O2 5.774 MMBtu/hr
No add-on
control
equipment
9/15/2009 3/17/2014

Frito-Lay, Inc.,
Rancho Cucamonga,
CA, SCAQMD
25 PPMV @ 3% O2 1.6 MMBtu/hr
No add-on
control
equipment
9/15/2009 4/15/2008

It is important to note that these sources contain a wide range of emission guarantees and do not require
the implementation of a consistent technology. In an effort to be comprehensive Pepperidge Farm is
reviewing the use of the following control strategies:

► Selective Catalytic Reduction (SCR);
► Burner Design; and
► Good combustion practices.
5.3.2 Step 2 – Eliminate Technically Infeasible Options
Selective Catalytic Reduction
SCR has been applied to stationary source, fossil fuel-fired, combustion units for emission control since the
early 1970s. It has been applied to large (>250 MMBtu/hr) utility and industrial boilers, process heaters, and
combined cycle gas turbines. SCR can be applied as a stand-alone NOX control or with other technologies
such as combustion controls. The reagent reacts selectively with the flue gas NOX within a specific
temperature range and in the presence of the catalyst and oxygen to reduce the NO X into molecular
nitrogen (N2) and water vapor (H2O).13 The optimum operating temperature is dependent on the type of
catalyst and the flue gas composition. Generally, the optimum temperature ranges from 480 °F to 800°F.14 In
practice, SCR systems operate at efficiencies in the range of 70% to 90%.15 The oven to be installed for line
11 will operate at a temperature significantly lower than required 480°F, as a result this technology is
considered technically infeasible.

13 Ibid.
14 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/424/B-02-001 (https://www.epa.gov/economic-and-
cost-analysis-air-pollution-regulations/cost-reports-and-guidance-air-pollution); January 2002
15 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/424/B-02-001 (https://www.epa.gov/economic-and-
cost-analysis-air-pollution-regulations/cost-reports-and-guidance-air-pollution)); January 2002

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Burner Design
NOx emissions are primarily impacted by burner design, specifically the design of the fuel injection nozzles
as well as the air to fuel ratio. Control of both of these parameters results in the lowest available NOx
emission rate. The industry standard for bakery ovens is to utilize a ribbon burners along the length of the
industrial oven. Specifically, the oven proposed utilizes six (6) different zones each with a burner over the
conveyor and another under the conveyor. These 3/8 inch wide burners have been tuned by the
manufacturer to distribute heat as efficiently as possible and minimize emissions. The use of well designed
burners which optimize efficiency are technically feasible and utilized in the proposed oven.

Air and fuel are pre-mixed on a burner specific basis and combustion products are utilized by the oven to
provide the needed heat. The exhaust is then released through a centralized stack. This design standard
eliminates the ability recirculate air and create distinct combustion zones. Air recirculation and distinct
combustion zones are the engineering principles used to reduce NOx in technologies such as flue gas
recirculation, low NOx burners, and ultra-low NOx burners. Furthermore, re-design of these burners to
include air recirculation has been known to cause a “flame out” condition, in which the fuel valves remain
open but the burner remains unlit. The accumulation of unburnt fuel presents an unacceptable safety
hazard. As a result, the use of these technologies is technically infeasible for bakery ovens.
Good Combustion Practices
Good combustion practices include proper equipment design, proper maintenance of equipment, good
house-keeping, and general operating practices that follow manufacture’s recommendations where
appropriate. Good combustion practices are standard in the industry and necessary for food production.
Good combustion practices are considered technologically feasible.
5.3.3 Steps 3-5 Select BACT
Pepperidge Farm proposes to utilize all technologically feasible control technologies, namely good burner
design, and good combustion practices. While the manufacturer cannot provide an emission guarantee, as it
is highly process dependent, conversations with the manufacturer indicated that through the use of these
technologies Pepperidge Farm would be able to achieve a NOx emission rate consistent between 25 and 90
ppm, which is consistent with the research conducted in Step 1.
5.3.4 Other Criteria Pollutants
Natural gas is the cleanest fossil fuel and is a highly efficient form of energy. It is composed mainly of
methane and its combustion results in less PM2.5, PM10, VOC, and SO2 in comparison to other fossil fuels.
Use of ultra low sulfur natural gas for the proposed oven is considered technically feasible. No other control
technologies are established for the control of these pollutants for ovens, as a result Pepperidge proposes
the use of good combustion practices meets BACT.
5.4 PM10 and PM2.5 Ingredient Transfer
Pepperidge Farm is proposing to include dry ingredient silos in the permit. Dry ingredients will be
transferred from truck to silo via pneumatic hose. Each of the silos contains several bin vent filters that are
inherent to the design of the silo. These filters are designed to vent the air utilized to deliver the raw
materials as well as retain the raw material within the silo. Any raw materials not contained by the bin vent
filters is emitted as PM10 and PM2.5. Since bin vent filters are inherent to the process they have not been
evaluated as BACT.

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5.4.1 Step 1 – Identify All Available Controls
Control technologies identified for PM10 and PM2.5 emissions from drops are as follows, based on July 20,
2023, review of relevant entries in EPA’s RBLC:

► Baghouse/Fabric Filter
► Bin vent filter (not evaluated since it is currently inherent to the process)
5.4.2 Steps 2-4 – Eliminate Technically/Economically Infeasible Options
5.4.2.1 Baghouse/Fabric Filter
Fabric filters (Baghouses) are used for medium and low gas-flow streams with high particulate
concentrations. The typical baghouse has a control efficiency between 95% to 99.9%16. A bin filter is
already installed on the silos to control all ingredient transfer and thus the installation of an additional
baghouse is the focus of this analysis.

Costs are primarily driven by the waste stream volumetric flow rate and pollutant loading.17 In general, a
small unit controlling a low pollutant loading will not be as cost effective as a large unit controlling a high
pollutant loading.18 Given that the emission rate for PM10 is less than 0.5 tpy and PM2.5 is less than 0.1 tpy
and these emissions are distributed between 14 silos Pepperidge has determined that the installation of
baghouses is economically infeasible.
5.4.3 Step 5 – Select BACT
Bin filters are inherent to the process and all other technologies have been ruled out as technically or
economically infeasible. As a result, Pepperidge Farm proposes that the silos meet BACT as designed.
5.5 Cooling Towers
The cooling towers onsite are part of a multi-cell, mechanical induced draft cooling tower that will be used
to reject heat from plant water using cooling water. There are currently two (2) cooling tower cells to
support the processes. The three (3) additional cell cooling towers proposed for the site use adiabatic
cooling and produces no emissions. Using the RBLC search and permit review results, potentially applicable
PM10 and PM2.5 control technologies for cooling towers were identified. Drift is the common measure of the
effectiveness of the design of a cooling tower to reduce emissions. A drift eliminator will be used as the
control measure to reduce drift.
5.5.1 Step 1 – Identify All Available Controls
Drift/mist eliminators reduce the amount of PM entrained on the water droplets of th at are released into the
atmosphere of the exit stream of the cooling tower thereby reducing the drift of the cooling tower. A drift of
0.001%, as specified by the vendor, is being identified as BACT.

16 From EPA Air Pollution Control Technology Fact Sheet for baghouses, EPA-452/F-03-025.
17 From EPA Air Pollution Control Technology Fact Sheet for baghouses, EPA-452/F-03-025
18 From EPA Air Pollution Control Technology Fact Sheet for baghouses, EPA-452/F-03-025

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5.5.2 Step 2-5 – Select BACT
Technically feasible technology includes a drift eliminator on the cooling tower. Based on established control
efficiencies for these technologies, the drift eliminator is considered the most effective control technology.
Thus, the implementation of the drift eliminator technology, with a drift of 0.001% has been selected as
BACT for the control of PM10 and PM2.5 emissions.
5.6 Other Small Combustion Sources
The Richmond Facility operates additional smaller emitting units which are solely natural gas fired. Primarily,
these units are HVAC units, process heaters, and humidifiers. These units have not been included in the
historic permit and are being added at this time to ensure all boilers/process heaters that may be covered
by R307-315 are included within the site PTE and equipment list. While the minor sources may not meet the
definition of a boiler, as contained in R307-315, this rule has been used as a BACT comparison. The
applicability of R307-315 is addressed in section 8.19

These smaller units combust under five (5) MMBtu/hr of fuel with exception to one unit which combusts
5.71 MMBtu/hr of fuel. As many of the existing units are each rated at less than the 5 MMBtu/hr exemption
limit in R307-401-10(1), and exempt per UDAQ guidance, Source Category Exemption published March 6,
2017, a BACT analysis is not required for this equipment. The following BACT has been performed for the
combustion emissions of the 5.71 MMBtu/hr unit.
5.6.1 NOX Technologies
The NOX that will be formed during combustion is from two major mechanisms: thermal NO X and fuel NOX.
Since natural gas is relatively free of fuel-bound nitrogen, the contribution of this second mechanism to the
formation of NOX emissions in natural gas-fired equipment is minimal, leaving thermal NOX as the main
source of NOX emissions. Thermal NO X formation is a function of residence time, oxygen level, and flame
temperature, and can be minimized by controlling these elements in the design of the combustion
equipment.
5.6.1.1 Step 1 – Identify all Available Controls
Pepperidge Farm has reviewed the following sources to ensure all available control technologies have been
identified. While not all the units evaluated in this section meet the definition of a boiler, natural gas
controls for equipment of this size are widely published under boiler regu lations and titles. As a result, the
reviewed sources often list control technologies for boilers that may not be applicable to all natural gas
minor sources.

► UDAQ rule R307-316, NOx Emission Controls for Natural-Gas Fired Boilers greater than 5 MMBtu/hr;
► EPA’s RBLC Database for Natural Gas External Combustion Units (process type 13.31);20
► EPA’s Air Pollution Technology Fact Sheets;
► EPA’s CATC Alternative Control Techniques Document – NO X Emissions from Utility Boilers;
► NESHAP DDDDD – Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters;
► NESHAP JJJJJJ – Industrial, Commercial, and Institutional Boilers at Area Sources;
► SCAQMD LAER/BACT Determinations;

19 R307-315 is used for comparison, but does not apply because Pepperidge Farm’s Plant is not located in Salt Lake, Davis,
Weber, and Tooele Counties.
20 Database accessed January 13, 2023

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► SJVAPCD BACT Clearinghouse;
► BAAQMD BACT/TBACT Workbook; and
► Permits available online.

The results of these searches are summarized in the table below:

Pollutant Control Technologies
NOX Replacement Burner
Flue Gas Recirculation
Selective Catalytic Reduction
Good Combustion Practices

The control efficiencies, as well as technically and economically feasible emission rates are established for
natural gas boilers units in UDAQ rule R307-315 NOx Emission Controls for Natural Gas-Fired Boilers 2.0-5.0
MMBtu and R307-316, NOx Emission Controls for Natural-Gas Fired Boilers greater than 5 MMBtu/hr. In
general these rules require natural gas boilers to achieve the following:

► NOx Emission Rate of 9 ppmv;21 and
► Operate and Maintain (O&M) in accordance with manufacturer's instruction.22
While these standards may not apply all units evaluated in this section they are generally accepted as
potential controls for small natural gas fired equipment.
5.6.1.2 Step 1 – Eliminate Technically Infeasible Options
To demonstrate a complete analysis, Pepperidge Farm has evaluated the following technologies including
both replacement burners and add-on controls.
5.6.1.2.1 Replacement Burner
ULNB and LNB technology use advanced burner design to reduce NOX formation through the restriction of
oxygen, flame temperature, and/or residence time. ULNB technology uses additional internal FGR which
involves recirculating the hot O2 depleted flue gas from the heater into the combustion zone using burner
design features and fuel staging to reduce NOX. An ULNB can achieve an emission rate of approximately 9
ppm, or 0.011 pounds per million British thermal units (lb/MMBtu), when used in conjunction with FGR. An
emission rate of 9ppm is established as BACT within R307-315 and is thus considered technically feasible for
the boilers evaluated under this section. Since the exact purpose of each unit evaluated under this section is
variable a further evaluation of a replacement burner has been conducted.
5.6.1.2.2 Flue Gas Recirculation
FGR is frequently used with both LNB and ULNB burners. FGR involves the recycling of post -combustion air
into the air-fuel mixture to reduce the available oxygen and help cool the burner flame. This control
technology is technically infeasible for retrofitting the existing units, as it has not been adapted to units of
this size.

21 UDAQ’s proposed rules are intended for new installations and not retrofitting existing boilers.
22 Neither R307-315 or 316 require the retrofit of existing units to meet the established standards.

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5.6.1.2.3 Selective Catalytic Reduction
SCR systems introduce a reducing agent such as ammonia or urea into the flue gas stream before a
catalyst. The catalyst reduces the temperature needed to initiate the reaction between the reducing agent
and NOX to form nitrogen and water. An SCR can achieve NOX reduction efficiencies between 70 and 90%.23
However, SCR systems are generally applied to natural-gas fired combustion equipment ranging in size from
50 to 8,000 MMBtu/hr.24 Due to the size of the existing units, SCR is considered technically infeasible.
5.6.1.2.4 Combustion Practices
The use of good combustion practices usually includes the following components: (1) proper fuel mixing in
the combustion zone; (2) high temperatures and low oxygen levels in primary zone; (3) Overall excess
oxygen levels high enough to complete combustion while maximizing unit efficiency, and (4) sufficient
residence time to complete combustion. Good combustion practices are accomplished through unit design
as it relates to time, temperature, and turbulence, and boiler operation as it relates to excess oxygen levels.
5.6.1.3 Steps 3-5 – Select BACT
Pepperidge Farm has installed units which met the most stringent emission standards possible at the time of
installation. In reviewing the proposed rules, R307-315 and 316, no retrofit requirements are established.
Additionally, UDAQ estimates a cost difference of approximately $19,000 for replacing a 3.34MMBtu
standard boiler burner with an Ultra-Low NOx boiler rated at 9 ppmv.25 This cost is economically infeasible.
As a result, Pepperidge Farm proposes the implementation of GCP as BACT.
5.6.2 Other Criteria Pollutants
Natural gas is the cleanest fossil fuel and is a highly efficient form of energy. It is composed mainly of
methane and its combustion results in less PM2.5, PM10, VOC, and SO2 in comparison to other fossil fuels.
Use natural gas for the proposed units is considered technically feasible. No other control technologies are
established for the control of these pollutants for process heaters, as a result Pepperidge proposes the use
of good combustion practices meets BACT.

23 Air Pollution Control Technology Fact Sheet, SCR, EPA-452/F-03-032.
24 Ibid.
25 Proposal for final adoption of New Rule R307-315. NOx emission controls for Natural Gas-Fired Boilers 2-5 MMBtu.

Pepperidge Farm / Project Finn
Trinity Consultants 6-1
6. EMISSION IMPACT ANALYSIS
Table 6-1 compares criteria pollutant total proposed emissions to applicable modeling thresholds contained in R307 -403-4 through 7, and
R307-410-4. Project Finn is a standalone project.

Table 6-1. Total Annual Criteria Pollutant Emissions

a. Major modification thresholds are defined in R307-101-2.
b. Major source thresholds are defined in 40 CFR Section 51.165(a)(1)(iv)(A).
c. Total HAP thresholds are given in 40 CFR Section 63.2 under definition of a Major Source.
d. Modeling limits are given in UDAQ Emissions Impact Assessment Guidelines in Table 1: Total Controlled Emission Rates for New Sources, or Emissions
Increase.

In order to ensure a complete analysis was conducted Pepperidge Farm also compared the new site totaled to the currently permitted PTE.
EMMISION UNIT ID VOC CO NOX PM SO2
Total
HAP CO2e
Manufacturing 44.26 0.00 0.00 0.00 0.00 3.10 0.00
Combustion 1.23 18.72 22.31 1.70 0.14 0.43 27,485.52
Cracker Line 11 - Manufacturing 22.49 0.00 0.00 0.00 0.00 1.57 0.00
Cracker Line 11 - Combustion
(Oven and Oxidizer)0.40 6.13 7.30 0.55 0.04 0.14 8,975.57
Minor Sources 1.98 30.23 35.98 2.73 0.22 0.67 44,244.42
Cooling Towers 0.00 0.00 0.00 0.49 0.00 0.00 0.00
Bin Vents 0.00 0.00 0.00 1.71 0.00 0.00 0.00
Boiler 0.24 3.68 4.38 0.33 0.03 0.08 5,385.34
Project Change 24.63 32.68 38.90 5.16 0.23 2.30 47,834.65
Modeling thresholds3 40 100 40 15 40 --------
Modeling Required?No No No No No No No
Currently Permitted Operations
Proposed Operations (New Construction + Equipment Inclusions)
Currently Permitted and to be Removed

Pepperidge Farm / Project Finn
Trinity Consultants 6-2
Table 6-2. Comparison of Project Finn to Current PTE

EMMISION UNIT ID VOC CO NOX PM SO2 Total
HAP CO2e
New Site Totals 70.12 51.40 61.21 6.85 0.37 5.82 75,320.18
Current Permitted PTE 99.00 21.48 25.57 1.94 0.15 5.59 26,274.00
Proposed Change in PTE -28.88 29.92 35.64 4.91 0.22 0.23 49,046.18
Major Source Thresholds2 100 100 100 100 100 25 -----
Exceeding Major Source Thresholds? No No No No No No No
Modeling Thresholds3 40 100 40 15 40 ---- ----
Modeling Required? No No No No No No No

The proposed modification associated with Project Finn emissions increase will not exceed UDAQ’s modeling thresholds and an air
dispersion modeling analysis will not be required to demonstrate the impacts of the pollutant emissions from the proposed change.

Table 6-2 compares HAP emission increases to applicable modeling thresholds as regulated by R307-410-5. For this project, Pepperidge
Farm conservatively determined that the most applicable Emission Threshold Values (ETV) are those representative of vertically
unrestricted releases within 50 meters of the property boundary. HAP modeling will not be required for this project.

Pepperidge Farm / Project Finn
Trinity Consultants 6-3
Table 6-2. Total Annual HAPs Emissions
a. Emission factors are defined in AP 42 sections 1.4 (natural gas) and 3.3 (diesel).
b. Emission Threshold Values (ETV) defined in UDAQ Emissions Impact Assessment Guidelines Table 2: Emission Threshold Factors (ETF) for Hazardous Air
Pollutants. ETV which conservatively assumed an unrestricted vertical release within 50 meters of the property boundary were used.
Pollutant CAS Number Facility Total PTE
Before Project
Facility Total PTE
After Project
Change in Facility
Total PTE
Modeling
Required?
Acenaphthene 83-32-9 4.17E-07 1.11E-06 6.94E-07 ----
Acenaphthylene 208-96-8 4.41E-07 1.14E-06 6.94E-07 ----
Acetaldehyde 75070 3.10 4.67 1.57 No
Anthracene 120-12-7 5.55E-07 1.48E-06 9.26E-07 No
Benz(a)anthracene 56-55-3 4.18E-07 1.11E-06 6.94E-07 ----
Benzene 71-43-2 4.81E-04 1.29E-03 8.10E-04 No
Benzo(a)pyrene 50-32-8 2.73E-07 7.35E-07 4.63E-07 No
Benzo(b) flouranthene 205-911-9 4.08E-07 1.10E-06 6.94E-07 No
Benzo(k)fluoranthene 207-08-9 4.08E-07 1.10E-06 6.94E-07 ----
Benzo(g,h,I)perylene 191-24-2 2.75E-07 7.37E-07 4.63E-07 ----
Chrysene 218-01-9 4.09E-07 1.10E-06 6.94E-07 No
Dibenzo(a,h)anthracene 53-70-3 2.75E-07 7.38E-07 4.63E-07 No
Dichlorobenzene 95-50-1 2.71E-04 7.34E-04 4.63E-04 No
7,12-Dimethylbenz(a)anthracene 57-97-6 3.62E-06 9.79E-06 6.17E-06 ----
Fluoranthene 206-44-0 7.30E-07 1.89E-06 1.16E-06 No
Fluorene 86-73-7 8.31E-07 1.91E-06 1.08E-06 No
Formaldehyde 50-00-0 1.70E-02 4.59E-02 2.89E-02 No
Hexane 110-54-3 0.41 1.10 0.69 No
Indeno(1,2,3-cd)pyrene 193-39-5 4.10E-07 1.10E-06 6.94E-07 No
3-Methylchloranthrene 56-49-5 4.07E-07 1.10E-06 6.94E-07 ----
2-Methylnapthylene 91-57-6 5.43E-06 1.47E-05 9.26E-06 ----
Naphthalene 91-20-3 1.38E-04 3.73E-04 2.35E-04 No
Phenanathrene 85-01-8 4.04E-06 1.06E-05 6.56E-06 ----
Pyrene 129-00-0 1.16E-06 3.09E-06 1.93E-06 No
Toluene 108-88-3 7.71E-04 2.08E-03 1.31E-03 No
3.52 5.82 2.30 NoTotal

Pepperidge Farm / Project Finn
Trinity Consultants 7-1
7. NONATTAINMENT/MAINTENACE AREAS – OFFSETTING
As the Richmond Plant is an existing minor source modifying its approval order, applicability with R307 -403-
2(1) needs to be determined. R307-403 applies to major modifications resulting in emission increases in
excess of significant emission rates (SERs). As the PTE increase presented in Appendix B demonstrates,
PM2.5 and its precursors as defined in R307-403-1(4)(c) [i.e., SO2, NOX, VOCs, and NH3] are less than the
major source thresholds. Thus, this permitting action is a minor modification. As a result, the installation
associated with the Project Finn is not subject to the offset requirements of R307-403.

Pepperidge Farm / Project Finn
Trinity Consultants 8-1
8. APPLICABLE REGULATIONS
8.1 UDAQ Air Quality Rules
Pepperidge Farm has evaluated the applicability of each rule under the Utah Administrative Code (UAC) Title
R307 (Air Quality Rules) for Project Finn. Additional rules are applicable to Pepperidge Farm and listed in its
current approval order but not applicable to this project; therefore, they have not been addressed in this
application.
Table 8-1. Evaluation of UDAQ Air Quality Rules
Reference Regulation Name Applicability
Yes No
R307-1011 General Requirements X
R307-1021

General Requirements: Broadly Applicable
Requirements X
R307-103 Administrative Procedures X
R307-104 Conflict of Interest X
R307-105

General Requirements: Emergency controls X
R307-1071

General Requirements: Breakdowns X
R307-1101

General Requirements: State Implementation
Plan X
R307-115 General Conformity X
R307-120
General Requirements: Tax Exemption for Air
Pollution Control Equipment X
R307-121 General Requirements: Clean Air and Efficient
Vehicle Tax Credit X
R307-122
General Requirements: Heavy Duty Vehicle Tax
Credit X
R307-123
General Requirements: Clean Fuels and Vehicle
Technology Grant and Loan Program X
R307-124
General Requirements: Conversion to Alternative
Fuel Grant Program X
R307-125
Clean Air Retrofit, Replacement, and Off-Road
Technology Program X
R307-130 General Penalty Policy X
R307-135
Enforcement Policy for Asbestos Hazard
Emergency Response Act X
R307-1501 Emission Inventories X
R307-165

Emission Testing X
R307-170 Continuous Emission Monitoring Program X

Pepperidge Farm / Project Finn
Trinity Consultants 8-2
Reference Regulation Name Applicability
Yes No
R307-2011
Emission Standards: General Emission Standards X
R307-202 Emission Standards: General Burning X
R307-203

Emission Standards: Sulfur Content of Fuels X
R307-204 Emission Standards: Smoke Management X
R307-205 Emission Standards: Fugitive Emissions and
Fugitive Dust X
R307-206 Emission Standards: Abrasive Blasting X
R307-207
Residential Fireplaces and Solid Fuel Burning
Devices X
R307-208 Outdoor Wood Boilers X
R307-2101

Standards of Performance for New Stationary
Sources X
R307-2141

National Emission Standards for Hazardous Air
Pollutants X
R307-220 Emission Standards: Plan for Designated
Facilities X
R307-221 Emission Standards: Emission Controls for
Existing Municipal Solid Waste Landfills X
R307-222
Emission Standards: Existing incinerator for
Hospital, Medical, Infectious Waste X
R307-223
Emission Standards: Existing Small Municipal
Waste Combustion Units X
R307-224
Mercury Emission Standards: Coal Fired Electric
Generating Units X
R307-230

NOX Emission Limits for Natural Gas-Fired Water
Heaters X
R307-250 Western Backstop Sulfur Dioxide Trading
Program X
R307-301
Utah and Weber Counties: Oxygenated Gasoline
Program as a Contingency Measure X
R307-302 Solid Fuel Burning Devices X
R307-303 Commercial Cooking X
R307-304

Solvent Cleaning X
R307-305
Nonattainment and Maintenance Areas for PM10:
Emission Standards X
R307-306
PM10 Nonattainment and Maintenance Areas:
Abrasive Blasting X
R307-307

Road Salting and Sanding X

Pepperidge Farm / Project Finn
Trinity Consultants 8-3
Reference Regulation Name Applicability
Yes No
R307-3091
Nonattainment and Maintenance Areas for PM10
and PM2.5: Fugitive Emissions and Fugitive Dust X
R307-310
Salt Lake County: Trading of Emission Budgets
for Transportation Conformity X
R307-311
Utah County: Trading of Emission Budgets for
Transportation Conformity X
R307-312
Aggregate Processing Operations for PM2.5
Nonattainment Areas X
R307-315
NOX Emission Limits for Natural Gas-Fired
Boilers, Steam Generators, and Process Heaters;
2.0-5.0 MMBtu
X
R307-316
NOX Emission Controls for Natural Gas-Fired
Boilers Greater Than 5.0 MMBtu X
R307-320

Ozone Maintenance Areas and Ogden City:
Employer Based Trip Reduction X
R307-325

Ozone Nonattainment and Maintenance Areas:
General Requirements X
R307-326
Ozone Nonattainment and Maintenance Areas:
Control of Hydrocarbon Emissions in Petroleum
Refineries
X
R307-327
Ozone Nonattainment and Maintenance Areas:
Petroleum Liquid Storage X
R307-328

Gasoline Transfer and Storage X
R307-335

Degreasing X
R307-341

Ozone Nonattainment and Maintenance Areas:
Cutback Asphalt X
R307-342

Adhesives and Sealants X
R307-343 Wood Furniture Manufacturing Operations X
R307-344 Paper, Film, and Foil Coatings X
R307-345 Fabric and Vinyl Coatings X
R307-346 Metal Furniture Surface Coatings X
R307-347 Large Applicable Surface Coatings X
R307-348 Magnet Wire Coatings X
R307-349 Flat Wood Panel Coating X
R307-350 Misc. Metal Parts and Product Coating X
R307-351

Graphic Arts X
R307-352 Metal Container, Closure, and Coil Coatings X
R307-353 Plastic Parts Coatings X

Pepperidge Farm / Project Finn
Trinity Consultants 8-4
Reference Regulation Name Applicability
Yes No
R307-354 Automotive Refinishing Coatings X
R307-355
Aerospace Manufacture and Rework Facilities X
R307-356 Appliance Pilot Light X
R307-357 Consumer Products X
R307-361

Architectural Coatings X
R307-4011 Permit: New and Modified Sources X
R307-4031
Permits: New and Modified Sources in
Nonattainment and Maintenance Areas X
R307-405
Permits: Major Sources in Attainment or
Unclassified Areas (PSD) X
R307-406

Visibility X
R307-4101

Permits: Emission Impact Analysis X
R307-4141

Permits: Fees for Approval Orders X
R307-4151

Permits: Operating Permit Requirements X
R307-417

Permits: Acid Rain Sources X
R307-420

Permits: Ozone Offset Requirements in Salt Lake
County and Utah County X
R307-421

Permits: PM10 Offset Requirements in Salt Lake
County and Utah County X
R307-424 Permits: Mercury Requirements for Electric
Generating Units X
R307-501 to
505
Oil and Gas Industry X
R307-801

Utah Asbestos Rule X
R307-840

Lead-Based Paint Program Purpose, Applicability,
and Definitions X
R307-841
Residential Property and Child-Occupied Facility
Renovation X
R307-842

Lead-Based Paint Activities X
1. The subject rule is applicable to the P&G’s operations; however, is not associated with changes
described in this NOI application and is not addressed in the subsequent sections.
8.1.1 UAC R307-165: Emission Testing
Because the modification introduces emission units with established emission limitations specified in AO No.
DAQE-AN118410009-23, Pepperidge Farm will comply with the standards outlined in R307-165. This rule
establishes the requirements for stack testing of all such emission units. Pepperidge Farm will perform stack
testing according to the frequency, conditions, and reporting outlined in R307-165.

Pepperidge Farm / Project Finn
Trinity Consultants 8-5
8.1.2 UAC R307-230 Permits: NOX Emission Limits for Natural Gas-Fired Water
Heaters
UAC defines a “Natural gas-fired water heater” as “a device that heats water by the combustion of natural
gas to a thermostatically-controlled temperature not exceeding 210 degrees F (99 degrees C) for use
external to the vessel at pressures not exceeding 160 psig”.26 Because the steam generators associated with
the modification exceed 210 oF, the standards outlined in R307-230 are not applicable.
8.1.3 UAC R307-303: Commercial Cooking
Although the Richmond Bakery is located within Cache County and includes commercial cooking equipment,
there are no charbroilers on-site. As such, Pepperidge Farm does not apply to the standards outlined in
R307-303.
8.1.4 UAC R307-315: NOX Emission Limits for Natural Gas-Fired Boilers, Steam
Generators, and Process Heaters; 2.0-5.0 MMBtu
The Richmond Facility is located outside of the Salt Lake, Davis, Weber, and Tooele Counties and as such is
not applicable to rule R307-315.
8.1.5 UAC R307-316: NOX Emissions for Natural Gas-Fired Boilers Greater Than
5.0 MMBtu
Because the Richmond Facility is located outside of the Salt Lake, Davis, Weber, and Tooele Counties, R307-
316 is not applicable.

8.1.6 UAC R307-342: Adhesives and Sealants
Within the packaging step, Pepperidge Farm applies a solid adhesive which contains no VOC. As a result
R307-342 is not applicable.
8.1.7 UAC R307-406: Visibility
Project Finn is a minor modification at a minor source. Because of this, the Richmond Facility is exempt from
rule R307-406.
8.2 Federal Rules: National Emission Standards for Hazardous Air
Pollutants
The National Emission Standards for Hazardous Air Pollutants (NESHAP), federal regulations found in Title
40 Part 61 and 63 of the Code of Federal Regulations (CFR), are emission standards for HAPs. The Part 61
NESHAP standards do not apply to operations at the Richmond Facility.

Part 63 NESHAP are applicable to both major sources of HAPs (facilities that exceed the major source
thresholds of 10 tpy of a single HAP and 25 tpy of any combination of HAPs from stationary sources) as well
as non-major sources (termed “area sources”). Part 63 NESHAP apply to sources in specifically regulated

26 UAC R307-230 under definition of a Natural Gas-Fired Water Heater

Pepperidge Farm / Project Finn
Trinity Consultants 8-6
industrial source classifications (Clean Air Act Section 112(d)) or on a case -by-case basis (Clean Air Act
Section 112(g)) for facilities not regulated as a specific industrial source type.

The Richmond Plant is an area source under US EPA’s Part 63 NESHAP program. As such, this document
only addresses regulatory applicability for area sources and does not include standards for major sources.
8.2.1 Subpart A – General Provisions
40 CFR Part 63 Subpart A, General Provisions, contains national emission standards for HAPs defined in
Section 112(b) of the Clean Air Act. All affected sources which are subject to anothe r Part 63 NESHAP are
subject to the general provisions of NESHAP Subpart A, unless specifically excluded by the source specific
NEHSAP. Subpart A requires initial notification, performance testing, recordkeeping, and monitoring,
provides NESHAP reference methods, and mandates general control device requirements for all other
subparts. The following sections detailing each subpart requirements also includes requirements that are
referenced to Subpart A.
8.2.2 Subpart Q – Industrial Process Cooling Towers
Because Pepperidge Farm is permitted as a minor source under Utah AO No. DAQE-AN118410009-23, the
Richmond facility is exempt to the standards outlined in 40 CFR Part 63 Subpart Q.

8.3 Federal Rules: New Source Performance Standards
New Source Performance Standards (NSPS) require new, modified, or reconstructed sources to control
emissions to the level achievable by the best demonstrated technology as specified in the applicable
provisions. Any source subject to an NSPS is also subject to the general provisions of NSPS Subpart A,
except as specified by rule. There are no NSPS rules that apply to the proposed sources to be installed with
Project Finn at the Richmond Bakery.

Pepperidge Farm / Project Finn
Trinity Consultants A-1
APPENDIX A. FORMS
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data -For Modification/Amendment ONLY
1. Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2. Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3. Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4. Does new emission unit affect existing
permitted process limits?
Yes No
5. Condition(s) Changing:
6. Description of Permit/Process Change**
7. New or modified materials and quantities used in process. **
Material Quantity Annually
8. New or modified process emitting units **
Emitting Unit(s)Capacity(s)Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
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Pepperidge Farm
Richmond Bakery
DAQE-AN118410009-23
Goldfish Cracker Manufacturing Line 11
Goldfish Crackers
✔
✔
II.A.8 - Removal of plant boiler
II.A - Addition of Process Line No 11, and cooling towers
✔
II.B.2 VOC limits
The addition of one Goldfish manufacturing line, similar in size to line 10 which is
currently in operation, is proposed. An additional catalytic oxidizer will also be installed.
Finally, it is proposed that one (1) 10.5 MMBtu/hr boiler be removed.
Page 1 of 1
Company___________________________
6LWH_____________________________
Form 
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants**(**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
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Pepperidge Farm
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Pepperidge Farm / Project Finn
Trinity Consultants B-1
APPENDIX B. EMISSION CALCULATIONS

Richmond Plant - Facility Wide Potential to Emit
Value Unit
24 (hr/day)
365 (day/yr)
100 (hr/yr)
Value
1050
19300
7.1
2000
0.07
60
1000000
a. Plant Specific
b. AP 42 Section 3.3
c. AP 42 Section 3.4
Table B-1. Facility Operating Parameters
lbs to ton conversion
Acetaldehyde Ratio
lb/ton
MMBtu/MMscf
ton Acetaldehyde/ton VOC
High Heating Value of Natural Gas a
Description
Potential Daily Operating Hours
Potential Annual Operating Days
Tabel B-2. Conversions
UnitsParameter
Potential Annual Operating Hours (Diesel Fire Pumps)
ppm conversion
High Heating Value of Diesel b Btu/lb
Density of Diesel c lb/gal
ppm/1
hr to min conversion min/hr
Pepperidge Farm Page 1 of 18 Trinity Consultants
Richmond Plant - Facility Wide Potential to Emit
EMMISION UNIT ID VOC CO
NOX PM SO2
Total
HAP CO2e
Manufacturing 66.75 0.00 0.00 0.00 0.00 4.67 0.00
Combustion 3.37 51.40 61.21 4.65 0.37 1.15 75,320.18
Cooling Towers 0.00 0.00 0.00 0.49 0.00 0.00 0.00
Bin Vents 0.00 0.00 0.00 1.71 0.00 0.00 0.00
Total 70.12 51.40 61.21 6.85 0.37 5.82 75,320.18
EMMISION UNIT ID VOC CO
NOX PM SO2
Total
HAP CO2e
Manufacturing 44.26 0.00 0.00 0.00 0.00 3.10 0.00
Combustion 1.23 18.72 22.31 1.70 0.14 0.43 27,485.52
Cracker Line 11 - Manufacturing 22.49 0.00 0.00 0.00 0.00 1.57 0.00
Cracker Line 11 - Combustion
(Oven and Oxidizer)0.40 6.13 7.30 0.55 0.04 0.14 8,975.57
Minor Sources 1.98 30.23 35.98 2.73 0.22 0.67 44,244.42
Cooling Towers 0.00 0.00 0.00 0.49 0.00 0.00 0.00
Bin Vents 0.00 0.00 0.00 1.71 0.00 0.00 0.00
Boiler 0.24 3.68 4.38 0.33 0.03 0.08 5,385.34
Project Change 24.63 32.68 38.90 5.16 0.23 2.30 47,834.65
Modeling thresholds3 40 100 40 15 40 ---- ----
Modeling Required?No No No No No No No
EMMISION UNIT ID VOC CO
NOX PM SO2
Total
HAP CO2e
New Site Totals 70.12 51.40 61.21 6.85 0.37 5.82 75,320.18
Current Permitted PTE 99.00 21.48 25.57 1.94 0.15 5.59 26,274.00
Proposed Change in PTE -28.88 29.92 35.64 4.91 0.22 0.23 49,046.18
Major Source Thresholds2 100 100 100 100 100 25 -----
Exceeding Major Source Thresholds?No No No No No No No
Modeling Thresholds3 40 100 40 15 40 ---- ----
Modeling Required?No No No No No No No
Currently Permitted Operations
Table B-3. Post Project Plant Wide Emissions Summary (tpy)
Table B-4. Current Units + Proposed Project
Table B-5. New Site Wide PTE vs. Permitted PTE
Proposed Operations (New Construction + Equipment Inclusions)
Currently Permitted and to be Removed
Pepperidge Farm Page 2 of 18 Trinity Consultants
Richmond Plant - Facility Wide Potential to Emit
Table B-6. Project Annual HAP Emissions
Pollutant CAS Number
Facility Total PTE
Before Project
Facility Total PTE After
Project
Change in Facility
Total PTE
Modeling
Required?
Acenaphthene 83-32-9 4.17E-07 1.11E-06 6.94E-07 ----
Acenaphthylene 208-96-8 4.41E-07 1.14E-06 6.94E-07 ----
Acetaldehyde 75070 3.10 4.67 1.57 No
Anthracene 120-12-7 5.55E-07 1.48E-06 9.26E-07 No
Benz(a)anthracene 56-55-3 4.18E-07 1.11E-06 6.94E-07 ----
Benzene 71-43-2 4.81E-04 1.29E-03 8.10E-04 No
Benzo(a)pyrene 50-32-8 2.73E-07 7.35E-07 4.63E-07 No
Benzo(b) flouranthene 205-911-9 4.08E-07 1.10E-06 6.94E-07 No
Benzo(k)fluoranthene 207-08-9 4.08E-07 1.10E-06 6.94E-07 ----
Benzo(g,h,I)perylene 191-24-2 2.75E-07 7.37E-07 4.63E-07 ----
Chrysene 218-01-9 4.09E-07 1.10E-06 6.94E-07 No
Dibenzo(a,h)anthracene 53-70-3 2.75E-07 7.38E-07 4.63E-07 No
Dichlorobenzene 95-50-1 2.71E-04 7.34E-04 4.63E-04 No
7,12-Dimethylbenz(a)anthracene 57-97-6 3.62E-06 9.79E-06 6.17E-06 ----
Fluoranthene 206-44-0 7.30E-07 1.89E-06 1.16E-06 No
Fluorene 86-73-7 8.31E-07 1.91E-06 1.08E-06 No
Formaldehyde 50-00-0 1.70E-02 4.59E-02 2.89E-02 No
Hexane 110-54-3 0.41 1.10 0.69 No
Indeno(1,2,3-cd)pyrene 193-39-5 4.10E-07 1.10E-06 6.94E-07 No
3-Methylchloranthrene 56-49-5 4.07E-07 1.10E-06 6.94E-07 ----
2-Methylnapthylene 91-57-6 5.43E-06 1.47E-05 9.26E-06 ----
Naphthalene 91-20-3 1.38E-04 3.73E-04 2.35E-04 No
Phenanathrene 85-01-8 4.04E-06 1.06E-05 6.56E-06 ----
Pyrene 129-00-0 1.16E-06 3.09E-06 1.93E-06 No
Toluene 108-88-3
7.71E-04 2.08E-03 1.31E-03 No
3.52 5.82 2.30 NoTotal
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Tabel B-7. Goldfish Baking Emissions
Throughput of
Finished Product
Potential VOC Emissions -
Uncrontrolled (tpy)
Potential Acetaldehyde
Emissions- Uncontrolled (tpy)
1692 85.52 5.99
4234 214.01 14.98
6120 309.34 21.65
6120 309.34 21.65
18166 918.20 64.27
Tabel B-9. Fugitive VOC Emissions for Goldfish
Throughput of Wet
Dough (lbs/hr)
Potential VOC Emissions -
Uncrontrolled (tpy)
Potential Acetaldehyde
Emissions- Uncontrolled (tpy)
2350 2.04 0.14
5880 5.11 0.36
8500 7.39 0.52
8500 7.39 0.52
25230 21.94 1.54
1. Emission factor was obtained from the 1998 Denver, PA source testing - permit
application
1. Emission factor was obtained from the 2020 TTE testing in Willard, OH Proof Room
Cracker Line Line 11
Cracker Line Line 3
Permitting Status Process Source
Unit
Unit
Total
CURRENT Cracker Line Line 5
CURRENT Cracker Line Line 5
Permitting Status Process Source
CURRENT Cracker Line Line 3
Emission
Factor1Pollutant
VOC 23.08
Pollutant Emission
Factor1
VOC
CURRENT Cracker Line Line 10
PROPOSED
lbs/ton of
Finished
Product
Total
lbs/ton of
Dough
Table B-10. Fugitive Emissions
Table B-8. Total Uncontrolled Emissions (Fugitive + Oven)
0.397
Cracker Line Line 11
CURRENT
CURRENT Cracker Line Line 10
PROPOSED
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Tabel B-11. Cataliytic Oxidizer Control Efficiency
1. Control efficiency is the CatOx minimum required destruction efficiency
Potential VOC
Emissions -
Potential Acetaldehyde
Emissions- Uncontrolled
Potential VOC Emissions -
Crontrolled (tpy)
Potential Acetaldehyde
Emissions- Controlled (tpy)
83.48 5.84 4.17 0.29
208.90 14.62 10.44 0.73
301.95 21.14 15.10 1.06
301.95 21.14 15.10 1.06
896.27 62.74 44.81 3.14
Table B-13. Total Emissions (Fugitive + Controlled Oven)
Potential VOC
Emissions -
Potential Acetaldehyde
Emissions- Controlled
6.22 0.44
15.56 1.09
22.49 1.57
22.49 1.57
66.75 4.67
Total
Permitting Status Process
Line 11
CURRENT Cracker Line
CURRENT Cracker Line Line 10
Line 5
PROPOSED Cracker Line
CURRENT Cracker Line
Source
Permitting Status Process Source
Line 3
Pollutant %
Control1
VOC
CURRENT Cracker Line Line 3
CURRENT Cracker Line Line 5
Total
CURRENT Cracker Line Line 10
PROPOSED Cracker Line Line 11
Table B-12. Oven Emissions
95.00%
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VOC CO
NOX PM SO2 VOC CO
NOX PM SO2
5.5 84 100 7.6 0.6 3.2
26.70 0.07 1.12 1.33 0.10 0.01
5.5 84 100 7.6 0.6 3.2
26.70 0.07 1.12 1.33 0.10 0.01
5.5 84 100 7.6 0.6 5.2
43.38 0.12 1.82 2.17 0.16 0.01
5.5 84 100 7.6 0.6 9.9
82.59 0.23 3.47 4.13 0.31 0.02
5.5 84 100 7.6 0.6 5.3
44.22 0.12 1.86 2.21 0.17 0.01
5.5 84 100 7.6 0.6 12.5
104.29 0.29 4.38 5.21 0.40 0.03
5.5 84 100 7.6 0.6 16.5
137.66 0.38 5.78 6.88 0.52 0.04
1. Emission factors are defined in AP 42 Section 1.4.Total 465.53 1.28 19.55 23.28 1.77 0.14
Maximum Usage
(MMscf/yr)
VOC CO
NOX PM SO2 VOC CO
NOX PM SO2
5.5 84 100 7.6 0.6 10.5
87.60 0.24 3.68 4.38 0.33 0.03
1. Emission factors are defined in AP 42 Section 1.4.Total 87.60 0.24 3.68 4.38 0.33 0.03
VOC CO
NOX PM SO2 VOC CO
NOX PM SO2
5.5 84 100 7.6 0.6 1
8.34 0.02 0.35 0.42 0.03 0.00
5.5 84 100 7.6 0.6 1
8.34 0.02 0.35 0.42 0.03 0.00
5.5 84 100 7.6 0.6 1.6
13.35 0.04 0.56 0.67 0.05 0.00
5.5 84 100 7.6 0.6 1
8.34 0.02 0.35 0.42 0.03 0.00
1. Emission factors defined in AP 42 Section 1.4 Total 38.38 0.11 1.61 1.92 0.15 0.01
VOC CO
NOX PM SO2 VOC CO
NOX PM SO2
0.049331 0.13 0.604 0.0425 0.04 0.17
17.00 0.00 0.00 0.01 0.00 0.00
0.049331 0.13 0.604 0.0425 0.04 0.38
38.00 0.00 0.00 0.01 0.00 0.00
0.049331 0.13 0.604 0.0425 0.04 0.44
44.00 0.00 0.00 0.01 0.00 0.00
1. Emission factors defined in AP 42 Section 3.3 Total 99.00 0.00 0.01 0.03 0.00 0.00
Cookie Line 1
Potential Emissions (tpy)Emission Factors1 (lb/mmscf)
CURRENT
CURRENT
PROPOSED
Cracker Line 10
Cracker Line 11
CURRENT
CURRENT
CURRENT
CURRENT
Cookie Line 2
Cracker Line 3
Cracker Line 5
Cookie Line 7
Permitting
Status Emission Unit ID MmBtu/hr
Rating
Maximum Usage
(MMscf/yr)
Emission Factors1 (lb/mmscf)Potential Emissions (tpy)
CURRENT Oxidizer Line 3
CURRENT Oxidizer Line 5
Potential Emissions (tpy)Emission Factors1 (lb/mmscf)
TO BE REMOVED Plant Boiler
Permitting
Status Emission Unit ID MmBtu/hr
Rating
Permitting
Status Emission Unit ID MmBtu/hr
Rating
Maximum Usage
(MMscf/yr)
Potential Emissions (tpy)
CURRENT Diesel Fire Pump
CURRENT Diesel Fire Pump
Diesel Fire PumpCURRENT
Emission Factors1 (lb/gal)Permitting
Status Emission Unit ID gal/hr
Rating
Maximum Usage
(gal/yr)
CURRENT Oxidizer Line 10
PROPOSED Oxidizer Line 11
Table B-14. Natural Gas Baking Ovens
Table B-15. Natural Gas Boilers
Table B-16. Natural Gas Catalytic Oxidizers
Table B-17. Diesel-Fired Pumps
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VOC CO
NOX PM SO2 VOC CO
NOX PM SO2
5.5 84 100 7.6 0.6 0.8 6.67 0.02 0.28 0.33 0.03 0.00
5.5 84 100 7.6 0.6 4.08
34.04 0.09 1.43 1.70 0.13 0.01
5.5 84 100 7.6 0.6
2.45 20.44 0.06 0.86 1.02 0.08 0.01
5.5 84 100 7.6 0.6 2.45
20.44 0.06 0.86 1.02 0.08 0.01
5.5 84 100 7.6 0.6
2.45 20.44 0.06 0.86 1.02 0.08 0.01
5.5 84 100 7.6 0.6
4.08 34.04 0.09 1.43 1.70 0.13 0.01
5.5 84 100 7.6 0.6
1.96 16.35 0.04 0.69 0.82 0.06 0.00
5.5 84 100 7.6 0.6 2.45
20.44 0.06 0.86 1.02 0.08 0.01
5.5 84 100 7.6 0.6 5.71
47.64 0.13 2.00 2.38 0.18 0.01
5.5 84 100 7.6 0.6 4.08
34.04 0.09 1.43 1.70 0.13 0.01
5.5 84 100 7.6 0.6 4.9
40.88 0.11 1.72 2.04 0.16 0.01
5.5 84 100 7.6 0.6 4.08
34.04 0.09 1.43 1.70 0.13 0.01
5.5 84 100 7.6 0.6 2.45
20.44 0.06 0.86 1.02 0.08 0.01
5.5 84 100 7.6 0.6 4.08
34.04 0.09 1.43 1.70 0.13 0.01
5.5 84 100 7.6 0.6 2.45
20.44 0.06 0.86 1.02 0.08 0.01
5.5 84 100 7.6 0.6 0.41
3.42 0.01 0.14 0.17 0.01 0.00
5.5 84 100 7.6 0.6 0.49
4.09 0.01 0.17 0.20 0.02 0.00
5.5 84 100 7.6 0.6 4.08
34.04 0.09 1.43 1.70 0.13 0.01
5.5 84 100 7.6 0.6 4.9
40.88 0.11 1.72 2.04 0.16 0.01
5.5 84 100 7.6 0.6 4.07
33.96 0.09 1.43 1.70 0.13 0.01
5.5 84 100 7.6 0.6 3.67
30.62 0.08 1.29 1.53 0.12 0.01
5.5 84 100 7.6 0.6 1.63
13.60 0.04 0.57 0.68 0.05 0.00
5.5 84 100 7.6 0.6 3.26
27.20 0.07 1.14 1.36 0.10 0.01
5.5 84 100 7.6 0.6 0.2
1.67 0.00 0.07 0.08 0.01 0.00
5.5 84 100 7.6 0.6 1.08
9.01 0.02 0.38 0.45 0.03 0.00
5.5 84 100 7.6 0.6 0.71
5.92 0.02 0.25 0.30 0.02 0.00
5.5 84 100 7.6 0.6 1.321
11.02 0.03 0.46 0.55 0.04 0.00
5.5 84 100 7.6 0.6 1.242
10.36 0.03 0.44 0.52 0.04 0.00
5.5 84 100 7.6 0.6 0.52
4.34 0.01 0.18 0.22 0.02 0.00
5.5 84 100 7.6 0.6 0.52
4.34 0.01 0.18 0.22 0.02 0.00
5.5 84 100 7.6 0.6 0.612
5.11 0.01 0.21 0.26 0.02 0.00
5.5 84 100 7.6 0.6 3.409
28.44 0.08 1.19 1.42 0.11 0.01
5.5 84 100 7.6 0.6 2.394
19.97 0.05 0.84 1.00 0.08 0.01
5.5 84 100 7.6 0.6 0.03
0.25 0.00 0.01 0.01 0.00 0.00
5.5 84 100 7.6 0.6 0.03
0.25 0.00 0.01 0.01 0.00 0.00
5.5 84 100 7.6 0.6 0.03
0.25 0.00 0.01 0.01 0.00 0.00
5.5 84 100 7.6 0.6 0.03
0.25 0.00 0.01 0.01 0.00 0.00
5.5 84 100 7.6 0.6 0.03
0.25 0.00 0.01 0.01 0.00 0.00
Emission Factors1 (lb/mmscf)
Table B-18. Minor Sources
Potential Emissions (tpy)Permitting
Status Emission Unit ID MmBtu/hr
Rating
Maximum Usage
(MMscf/yr)
PROPOSED AC-12
AC-13
PROPOSED AC-1
PROPOSED Line 7 Pan Washer
and Dryer
PROPOSED AC-5
PROPOSED AC-11
PROPOSED AC-8
PROPOSED AC-9
PROPOSED AC-10
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
AC-44
AC-45
AC-32
AC-33
AC-34
AC-35
AC-37
AC-30
AC-31
MAU-5
PROPOSED
PROPOSED
PROPOSED
AC-42
AC-43
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
IRH-3
IRH-4
IRH-5
MAU-6
IRH-1
IRH-2
Table B-18. Minor Sources
AC-38
AC-41
AC-20
AC-21
AC-25
PROPOSED
PROPOSED
AC-14
AC-15
PROPOSED
PROPOSED
PROPOSED
PROPOSED AC-7
PROPOSED AC-2
PROPOSED AC-3
PROPOSED AC-4
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VOC CO
NOX PM SO2 VOC CO
NOX PM SO2
5.5 84 100 7.6 0.6 0.03
0.25 0.00 0.01 0.01 0.00 0.00
5.5 84 100 7.6 0.6 0.03
0.25 0.00 0.01 0.01 0.00 0.00
5.5 84 100 7.6 0.6 0.03
0.25 0.00 0.01 0.01 0.00 0.00
5.5 84 100 7.6 0.6 0.03
0.25 0.00 0.01 0.01 0.00 0.00
5.5 84 100 7.6 0.6 1.083
9.04 0.02 0.38 0.45 0.03 0.00
5.5 84 100 7.6 0.6 0.962
8.03 0.02 0.34 0.40 0.03 0.00
5.5 84 100 7.6 0.6 0.962
8.03 0.02 0.34 0.40 0.03 0.00
1. Emission factors defined in AP 42 Section 1.4 Total 719.70 1.98 30.23 35.98 2.73 0.22
IRH-9
Humidifier
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED
PROPOSED Steam Generator
Steam Generator
IRH-6
IRH-7
IRH-8
Permitting
Status Emission Unit ID
Emission Factors1 (lb/mmscf)MmBtu/hr
Rating
Maximum Usage
(MMscf/yr)
Potential Emissions (tpy)
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Table B-19. Cooling Towers
Permitting
Status
Emission Unit
ID
Number
of Cells Drift %Total Flowrate
(gal/min)
TDS
(ppm)
Density
(lb/gal)PM10 (lb/hr) PM2.5 (lb/hr) PM10 (tpy) PM2.5 (tpy)
CURRENT Cooling Tower 1 2 1.00E-03 4500 5000 8.34 0.11 0.11 0.49 0.49
FUTURE Cooling Tower 2 3 0 2200 0 8.34 0000
Total 0.11 0.11 0.49 0.49
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Table B-20. Bin Filters
PM PM10 PM2.5 PM PM10 PM2.5
CURRENT Crackers 79567.08 0.025 0.0063 0.0011 0.994589 0.250636 0.043762
CURRENT Cookies 56940 0.025 0.0063 0.0011 0.71175 0.179361 0.031317
1.706339 0.429997 0.075079
1. Emission factors are defined in AP 42 Section 9.9.1 table 9.9.1‐1 under "storage bin (vent)".
Potential Emissions tpyEmission Factors1 (lb/ton)
Total
Permitting Status Overall Emission
Unit ID
Annual
Throuput (tpy)
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Table B-21. Project Annual HAP Emissions
Acenaphthene 83-32-9 1.80E-06
Acenaphthylene 208-96-8 1.80E-06
Acetaldehyde 75070 -
Anthracene 120-12-7 2.40E-06
Benz(a)anthracene 56-55-3 1.80E-06
Benzene 71-43-2 2.10E-03
Benzo(a)pyrene 50-32-8 1.20E-06
Benzo(b) flouranthene 205-911-9 1.80E-06
Benzo(k)fluoranthene 207-08-9 1.80E-06
Benzo(g,h,I)perylene 191-24-2 1.20E-06
Chrysene 218-01-9 1.80E-06
Dibenzo(a,h)anthracene 53-70-3 1.20E-06
Dichlorobenzene 95-50-1 1.20E-03
7,12-Dimethylbenz(a)anthracene 57-97-6 1.60E-05
Fluoranthene 206-44-0 3.00E-06
Fluorene 86-73-7 2.80E-06
Formaldehyde 50-00-0 7.50E-02
Hexane 110-54-3 1.8
Indeno(1,2,3-cd)pyrene 193-39-5 1.80E-06
3-Methylchloranthrene 56-49-5 1.80E-06
2-Methylnapthylene 91-57-6 2.40E-05
Naphthalene 91-20-3 6.10E-04
Phenanathrene 85-01-8 1.70E-05
Pyrene 129-00-0 5.00E-06
Toluene 108-88-3 3.40E-03
TOTAL
1., 2. Emission factors are defined in AP 42 sections 1.4 (natural gas) and 3.3 (diesel).
3. Emission Threshold Values (ETV) defined in UDAQ Emissions Impact Assessment Guidelines Table 2: Emission Threshold Factors (ETF) fo
Pollutant CAS Number Natural Gas Emission Factor1 (lb/MMscf)
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Table B-21. Project Annual HAP Emissions
Acenaphthene
Acenaphthylene
Acetaldehyde
Anthracene
Benz(a)anthracene
Benzene
Benzo(a)pyrene
Benzo(b) flouranthene
Benzo(k)fluoranthene
Benzo(g,h,I)perylene
Chrysene
Dibenzo(a,h)anthracene
Dichlorobenzene
7,12-Dimethylbenz(a)anthracene
Fluoranthene
Fluorene
Formaldehyde
Hexane
Indeno(1,2,3-cd)pyrene
3-Methylchloranthrene
2-Methylnapthylene
Naphthalene
Phenanathrene
Pyrene
Toluene
TOTAL
1., 2. Emission factors are defined in AP 42 sections 1.4 (natural
3. Emission Threshold Values (ETV) defined in UDAQ Emissions I
Pollutant
1.42E-06 8.79E-08
5.06E-06 8.79E-08
6.67E-04 0
1.87E-06 1.17E-07
1.68E-06 8.79E-08
9.33E-04 1.02E-04
1.88E-07 5.86E-08
9.91E-08 8.79E-08
1.55E-07 8.79E-08
4.89E-07 5.86E-08
3.53E-07 8.79E-08
5.83E-07 5.86E-08
0 5.86E-05
0 7.81E-07
7.61E-06 1.46E-07
2.92E-05 1.37E-07
1.18E-03 3.66E-03
0 8.79E-02
3.75E-07 8.79E-08
0 8.79E-08
0 1.17E-06
0 2.98E-05
2.94E-05 8.30E-07
4.78E-06 2.44E-07
4.09E-04 1.66E-04
0.09
r Hazardous Air Pollutants. ETV which conservatively assumed an unrestricted vertica
Current Cookie Lines (3)Diesel Emission Factor2 (lb/MMBtu)
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Table B-21. Project Annual HAP Emissions
Acenaphthene
Acenaphthylene
Acetaldehyde
Anthracene
Benz(a)anthracene
Benzene
Benzo(a)pyrene
Benzo(b) flouranthene
Benzo(k)fluoranthene
Benzo(g,h,I)perylene
Chrysene
Dibenzo(a,h)anthracene
Dichlorobenzene
7,12-Dimethylbenz(a)anthracene
Fluoranthene
Fluorene
Formaldehyde
Hexane
Indeno(1,2,3-cd)pyrene
3-Methylchloranthrene
2-Methylnapthylene
Naphthalene
Phenanathrene
Pyrene
Toluene
TOTAL
1., 2. Emission factors are defined in AP 42 sections 1.4 (natural
3. Emission Threshold Values (ETV) defined in UDAQ Emissions I
Pollutant
2.07E-07 0 2.70E-08
2.07E-07 0 2.70E-08
03.100
2.76E-07 0 3.60E-08
2.07E-07 0 2.70E-08
2.42E-04 0 3.15E-05
1.38E-07 0 1.80E-08
2.07E-07 0 2.70E-08
2.07E-07 0 2.70E-08
1.38E-07 0 1.80E-08
2.07E-07 0 2.70E-08
1.38E-07 0 1.80E-08
1.38E-04 0 1.80E-05
1.84E-06 0 2.40E-07
3.45E-07 0 4.51E-08
3.22E-07 0 4.20E-08
8.63E-03 0 1.13E-03
2.07E-01 0 2.70E-02
2.07E-07 0 2.70E-08
2.07E-07 0 2.70E-08
2.76E-06 0 3.60E-07
7.02E-05 0 9.16E-06
1.96E-06 0 2.55E-07
5.76E-07 0 7.51E-08
3.91E-04 0 5.11E-05
0.22 3.10 0.03
al release within 50 meters of the property boundary were used.
Current Cracker Lines (3)Current Cracker Line
Manufacturing (Lines 3, 5 & 10)
Current
Oxidizers (3)
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Table B-21. Project Annual HAP Emissions
Acenaphthene
Acenaphthylene
Acetaldehyde
Anthracene
Benz(a)anthracene
Benzene
Benzo(a)pyrene
Benzo(b) flouranthene
Benzo(k)fluoranthene
Benzo(g,h,I)perylene
Chrysene
Dibenzo(a,h)anthracene
Dichlorobenzene
7,12-Dimethylbenz(a)anthracene
Fluoranthene
Fluorene
Formaldehyde
Hexane
Indeno(1,2,3-cd)pyrene
3-Methylchloranthrene
2-Methylnapthylene
Naphthalene
Phenanathrene
Pyrene
Toluene
TOTAL
1., 2. Emission factors are defined in AP 42 sections 1.4 (natural
3. Emission Threshold Values (ETV) defined in UDAQ Emissions I
Pollutant
7.88E-08 6.01E-09 1.24E-07 0
7.88E-08 6.01E-09 1.24E-07 0
00 0 1.57
1.05E-07 8.01E-09 1.65E-07 0
7.88E-08 6.01E-09 1.24E-07 0
9.20E-05 7.01E-06 1.45E-04 0
5.26E-08 4.00E-09 8.26E-08 0
7.88E-08 6.01E-09 1.24E-07 0
7.88E-08 6.01E-09 1.24E-07 0
5.26E-08 4.00E-09 8.26E-08 0
7.88E-08 6.01E-09 1.24E-07 0
5.26E-08 4.00E-09 8.26E-08 0
5.26E-05 4.00E-06 8.26E-05 0
7.01E-07 5.34E-08 1.10E-06 0
1.31E-07 1.00E-08 2.06E-07 0
1.23E-07 9.34E-09 1.93E-07 0
3.29E-03 2.50E-04 5.16E-03 0
7.88E-02 6.01E-03 1.24E-01 0
7.88E-08 6.01E-09 1.24E-07 0
7.88E-08 6.01E-09 1.24E-07 0
1.05E-06 8.01E-08 1.65E-06 0
2.67E-05 2.04E-06 4.20E-05 0
7.45E-07 5.67E-08 1.17E-06 0
2.19E-07 1.67E-08 3.44E-07 0
1.49E-04 1.13E-05 2.34E-04 0
0.08 0.01 0.13 1.57
Proposed Cracker
Line 11
Plant Boiler To
Be Removed
Pan Washer and
Dryer
Proposed Cracker Line 11
Manufacturing
Pepperidge Farm Page 14 of 18 Trinity Consultants
Richmond Plant - Facility Wide Potential to Emit
Table B-21. Project Annual HAP Emissions
Acenaphthene
Acenaphthylene
Acetaldehyde
Anthracene
Benz(a)anthracene
Benzene
Benzo(a)pyrene
Benzo(b) flouranthene
Benzo(k)fluoranthene
Benzo(g,h,I)perylene
Chrysene
Dibenzo(a,h)anthracene
Dichlorobenzene
7,12-Dimethylbenz(a)anthracene
Fluoranthene
Fluorene
Formaldehyde
Hexane
Indeno(1,2,3-cd)pyrene
3-Methylchloranthrene
2-Methylnapthylene
Naphthalene
Phenanathrene
Pyrene
Toluene
TOTAL
1., 2. Emission factors are defined in AP 42 sections 1.4 (natural
3. Emission Threshold Values (ETV) defined in UDAQ Emissions I
Pollutant
7.51E-09 9.63E-09 6.42E-07
7.51E-09 3.43E-08 6.42E-07
000
1.00E-08 1.27E-08 8.56E-07
7.51E-09 1.14E-08 6.42E-07
8.76E-06 6.33E-06 7.49E-04
5.01E-09 1.28E-09 4.28E-07
7.51E-09 6.72E-10 6.42E-07
7.51E-09 1.05E-09 6.42E-07
5.01E-09 3.32E-09 4.28E-07
7.51E-09 2.39E-09 6.42E-07
5.01E-09 3.95E-09 4.28E-07
5.01E-06 0.00E+00 4.28E-04
6.67E-08 0.00E+00 5.70E-06
1.25E-08 5.16E-08 1.07E-06
1.17E-08 1.98E-07 9.98E-07
3.13E-04 8.00E-06 2.67E-02
7.51E-03 0.00E+00 6.42E-01
7.51E-09 2.54E-09 6.42E-07
7.51E-09 0.00E+00 6.42E-07
1.00E-07 0.00E+00 8.56E-06
2.54E-06 0.00E+00 2.17E-04
7.09E-08 1.99E-07 6.06E-06
2.09E-08 3.24E-08 1.78E-06
1.42E-05 2.77E-06 1.21E-03
0.01 0.00 0.67
Diesel Fire Pumps (3) Proposed Minor SourcesProposed Line 11 Oxidizer
Pepperidge Farm Page 15 of 18 Trinity Consultants
Richmond Plant - Facility Wide Potential to Emit
Table B-21. Project Annual HAP Emissions
Acenaphthene
Acenaphthylene
Acetaldehyde
Anthracene
Benz(a)anthracene
Benzene
Benzo(a)pyrene
Benzo(b) flouranthene
Benzo(k)fluoranthene
Benzo(g,h,I)perylene
Chrysene
Dibenzo(a,h)anthracene
Dichlorobenzene
7,12-Dimethylbenz(a)anthracene
Fluoranthene
Fluorene
Formaldehyde
Hexane
Indeno(1,2,3-cd)pyrene
3-Methylchloranthrene
2-Methylnapthylene
Naphthalene
Phenanathrene
Pyrene
Toluene
TOTAL
1., 2. Emission factors are defined in AP 42 sections 1.4 (natural
3. Emission Threshold Values (ETV) defined in UDAQ Emissions I
Pollutant
4.17E-07 1.11E-06
4.41E-07 1.14E-06
3.098316177 4.672439668
5.55E-07 1.48E-06
4.18E-07 1.11E-06
4.81E-04 1.29E-03
2.73E-07 7.35E-07
4.08E-07 1.10E-06
4.08E-07 1.10E-06
2.75E-07 7.37E-07
4.09E-07 1.10E-06
2.75E-07 7.38E-07
2.71E-04 7.34E-04
3.62E-06 9.79E-06
7.30E-07 1.89E-06
8.31E-07 1.91E-06
1.70E-02 4.59E-02
4.07E-01 1.10E+00
4.10E-07 1.10E-06
4.07E-07 1.10E-06
5.43E-06 1.47E-05
1.38E-04 3.73E-04
4.04E-06 1.06E-05
1.16E-06 3.09E-06
7.71E-04 2.08E-03
3.52 5.82
Facility Total PTE Before Project Facility Total PTE After Project
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Richmond Plant - Facility Wide Potential to Emit
Table B-21. Project Annual HAP Emissions
Acenaphthene
Acenaphthylene
Acetaldehyde
Anthracene
Benz(a)anthracene
Benzene
Benzo(a)pyrene
Benzo(b) flouranthene
Benzo(k)fluoranthene
Benzo(g,h,I)perylene
Chrysene
Dibenzo(a,h)anthracene
Dichlorobenzene
7,12-Dimethylbenz(a)anthracene
Fluoranthene
Fluorene
Formaldehyde
Hexane
Indeno(1,2,3-cd)pyrene
3-Methylchloranthrene
2-Methylnapthylene
Naphthalene
Phenanathrene
Pyrene
Toluene
TOTAL
1., 2. Emission factors are defined in AP 42 sections 1.4 (natural
3. Emission Threshold Values (ETV) defined in UDAQ Emissions I
Pollutant
6.94E-07 ---- ----
6.94E-07 ---- ----
1.574123492 1.266 No
9.26E-07 0.275 No
6.94E-07 ---- ----
8.10E-04 0.0180675 No
4.63E-07 0.0180675 No
6.94E-07 0.0180675 No
6.94E-07 ---- ----
4.63E-07 ---- ----
6.94E-07 1.309 No
4.63E-07 0.036135 No
4.63E-04 2.604 No
6.17E-06 ---- ----
1.16E-06 0.036135 No
1.08E-06 0.036135 No
2.89E-02 0.036135 No
6.94E-01 1.972 No
6.94E-07 0.036135 No
6.94E-07 ---- ----
9.26E-06 ---- ----
2.35E-04 1.895 No
6.56E-06 ---- ----
1.93E-06 1.972 No
1.31E-03 2.723 No
2.30
ETV3 (tpy)Modeling Required?Change in Facility Total PTE
Pepperidge Farm Page 17 of 18 Trinity Consultants
Richmond Plant - Facility Wide Potential to Emit
Table B-22. Annual Greenhouse Gas Emissions
CO2 CH4 N2OCO2eCO2CH4N2OCO2e
Current & Proposed 53.06 1.00E-03 1.00E-04 5.31E+01 55.80 28,589.71 0.54 0.05 28,619.24
Removed 53.06 1.00E-03 1.00E-04 5.31E+01 10.50 5,379.78 0.10 0.01 5,385.34
Current & Proposed 53.06 1.00E-03 1.00E-04 5.31E+01 4.60 2,356.86 0.04 0.00 2,359.29
Current 73.96 3.00E-03 6.00E-04
7.42E+01 0.14 96.88 0.00 0.00 97.22
Current & Proposed 53.06 1.00E-03 1.00E-04 5.31E+01 86.27 44,198.78 0.83 0.08 44,244.42
157.30 75,242.23 1.42 0.14 75,320.18Total Current and Proposed Emissions (tpy)
Minor Sources
Emission Factors1 (kg/MMBtu)Potential Emissions (tpy)
Diesel Fire Pumps (3)
Natural Gas Catalytic Oxidizers
Natural Gas Baking Ovens
Natural Gas Boilers
Status EMMISION UNIT ID Total MMBtu/hr
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