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HomeMy WebLinkAboutDAQ-2025-000006 DAQE-AN109190024-24 {{$d1 }} Mike Jones Kimberly-Clark Corporation 2010 North Rulon White Boulevard Ogden, UT 84404-7802 mdjones@kcc.com Dear Mr. Jones: Re: Approval Order: Modification to Approval Order DAQE-AN109190023-23 to Add Equipment and Increase Emissions Project Number: N109190024 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on September 13, 2024. Kimberly-Clark Corporation must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Stockton Antczak, who can be contacted at (385) 306-6724 or santczak@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:SA:jg cc: Weber-Morgan Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 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 December 27, 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-AN109190024-24 Modification to Approval Order DAQE-AN109190023-23 to Add Equipment and Increase Emissions Prepared By Stockton Antczak, Engineer (385) 306-6724 santczak@utah.gov Issued to Kimberly-Clark Corporation - Ogden Plant Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality December 27, 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 ................................................................................................. 4 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 8 PERMIT HISTORY ................................................................................................................... 12 ACRONYMS ............................................................................................................................... 13 DAQE-AN109190024-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Kimberly-Clark Corporation Kimberly-Clark Corporation - Ogden Plant Mailing Address Physical Address 2010 North Rulon White Boulevard 2010 North Rulon White Boulevard Ogden, UT 84404-7802 Ogden, UT 84404-7802 Source Contact UTM Coordinates Name: Mike Jones 415,874 m Easting Phone: (801) 786-2318 4,571,869 m Northing Email: mdjones@kcc.com Datum NAD83 UTM Zone 12 SIC code 2676 (Sanitary Paper Products) SOURCE INFORMATION General Description Kimberly-Clark Corporation (KCC) operates a diaper manufacturing plant in Ogden, Weber County. The KCC Ogden plant is a disposable garment manufacturing facility. Various components are purchased from suppliers and are shipped to the plant by truck. Absorbent fluff (made from cellulose and polymer), a protective liner, and an outer plastic shell enter an automated assembly line to form various garments. The fluff material enters the form machine at the front of the line and is uniformly shredded and mixed. The combined fluff moves by conveyor through a compression stage to form the absorbent bulk of the garment. Once the fluff has been shaped, the protective inside liner and plastic outer shell are added. When all three components have been combined, the final shape is cut and the garment is sealed. The finished garments are stacked and packaged by an automated machine and are conveyor-transported to the loading dock/warehouse area for shipment or storage. The production lines are all vented to cyclones and/or baghouses to control particulate emissions and recycle material. This facility has a reclaim system where rejected garments and fluff are separated and either baled into fluff bricks, fluff bales, or tailings bales. All processed waste material is sold. NSR Classification Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Weber County DAQE-AN109190024-24 Page 4 Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Description KCC plans to modify the Ogden Plant to add the capability to produce a new type of product. The process change includes additional vacuum conveyors with a vacuum fan. Exhaust air from the fan will be routed through the existing U8 Machine Dust Bag filter rack assembly. Additionally, KCC is requesting to add two (2) sets of cooling towers to the permit. The addition of the cooling towers will result in an increase in PM10 and PM2.5 emissions. 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 0 19016.41 Carbon Monoxide 0 8.46 Nitrogen Oxides 0 12.99 Particulate Matter - PM10 5 41.53 Particulate Matter - PM2.5 3.80 40.33 Sulfur Dioxide 0 0.06 Volatile Organic Compounds 0 39.91 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Cresols/Cresylic Acid (Isomers And Mixture) (CAS #1319773) 0 280 Generic HAPs (CAS #GHAPS) 0 128 Methylene Chloride (Dichloromethane) (CAS #75092) 0 700 Change (TPY) Total (TPY) Total HAPs 0 0.55 DAQE-AN109190024-24 Page 5 SECTION I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the Utah Administrative Code (UAC) Rule 307 (R307) and Title 40 of the Code of Federal Regulations (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 in accordance with UAC R307-401. [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. Inventories, Testing and Monitoring. [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 Kimberly-Clark Corporation Diaper Manufacturing Plant II.A.2 Forming Baghouse #1 Controls: Lines U1, U2, and U8 Max. Rating: 37,000 acfm DAQE-AN109190024-24 Page 6 II.A.3 Forming Baghouse #2 Controls: Lines U3 and U4 Max. Rating: 25,000 acfm II.A.4 Forming Baghouse #3 Controls: Lines U5 and U6 Max. Rating: 28,000 acfm II.A.5 Forming Baghouse #4 Controls: Line U7 Max. Rating: 31,000 acfm II.A.6 Collector Baghouses #5 and #8 Controls: Emissions from Forming Baghouse #1 through #4 and Reclaiming Unit Baghouse #6 Max. Rating: 25,000 acfm II.A.7 Reclaiming Unit Baghouse #6 Controls: Reclaiming Unit Max. Rating: 27,500 acfm II.A.8 Forming Baghouse #9 Controls: Line U10, U11, and U12 Max. Rating: 36,300 acfm II.A.9 Forming Baghouse #13 Controls: Line U13 Max. Rating: 48,200 acfm II.A.10 Collector Baghouse #10 and #11 Controls exhaust from Forming Baghouse #9 and #13 Max. Rating: 25,000 acfm II.A.11 Two (2) Vacuum Pulse Jet Baghouses Two (2) vacuum system vents Controls the central vacuum system II.A.12 Two (2) Boilers Maximum Rated Capacity: 13.39 MMBtu/hr each Fuel: Natural Gas NSPS Applicability: Subpart Dc II.A.13 One (1) Adhesive Shop Adhesive removal process, classified as a cold cleaning process. Includes hot oil bath, solvent tank, two (2) electric ovens, and a parts cleaner. II.A.14 Twenty-two (22) Adhesive Melters Electric-powered adhesive melters for liquefying adhesive II.A.15 Two (2) Emergency Generator Engines Rating: One (1) 195 hp and one (1) 354 hp Fuel: Natural Gas MACT Applicability: Subpart ZZZZ DAQE-AN109190024-24 Page 7 II.A.16 One (1) Emergency Generator Engine Rating: 530 hp Fuel: Natural Gas NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.17 One (1) Fire Pump Engine Rating: 255 hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.18 One (1) Reclaim Bale Opener II.A.19 Eleven (11) Machine Air Wall Louvers Included for informational purposes II.A.20 One (1) Laboratory Fume Exhaust Hood II.A.21 3D Printer HP Jet Fusion 3D Printer II.A.22 Various Heaters and Boilers Maximum Rated Capacity: 5.0 MMBtu/hr each Fuel: Natural Gas Source Category Exemption under R307-401-10 II.A.23 Baby Care (BC) Chiller Cooling Tower Ceramic Cooling Tower Company Model: PL-4-450-40A counterflow cooling tower Consists of four (4) cells Total GPM required: 6,300 Tower pumping head: 11 ft. Drift loss: 0.0005% (based on DriAir 80 drift eliminators from Evaptech) II.A.24 Baby Care (BC) Compressor Cooling Tower Baltimore Aircoil Company Model: FXV-1212C-36T-P Flow rate: 580 GPM Drift loss: 0.005% II.A.25 Child Care (CC) Chiller Cooling Tower Consists of two (2) cells Total flow rate: 7,500 GPM Drift loss: 0.001% II.A.26 Child Care (CC) Compressor Cooling Tower One (1) unit Flow rate: 694 GPM Drift loss: 0.001% DAQE-AN109190024-24 Page 8 SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Facility-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. Baghouse #1, #2, #3, #4, #5 - 20% opacity B. All other baghouses and cooling towers - 10% opacity C. Reclaim and Central Vacuum System vents - 5% opacity D. All natural gas heaters, boilers, and emergency generator engines - 10% opacity E. All other points - 20% opacity. [R307-401-8] II.B.1.a.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.b The owner/operator shall control the following manufacturing operations with the applicable baghouses listed below. Operation Baghouse Lines U1, U2, and U8 Forming Baghouse #1 Lines U3 and U4 Forming Baghouse #2 Lines U5 and U6 Forming Baghouse #3 Line U7 Forming Baghouse #4 Emissions from Forming Collector Baghouses Baghouses #1, #2, #3, #4 #5 and #8 and Reclaiming Baghouse #6 Reclaiming Unit Forming Baghouse #6 Lines U10, U11, and U12 Forming Baghouse #9 Line U13 Forming Baghouse #13 Exhaust from Forming Collector Baghouses Baghouses #9 and #13 #10 and #11 [R307-401-8] II.B.1.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The baghouse shall operate within the static pressure range recommended by the manufacturer. The monitoring device shall measure in one (1) inch water column increments or less. [R307-401-8] DAQE-AN109190024-24 Page 9 II.B.1.c.1 Pressure drop readings shall be recorded at least once during each day of operation while the baghouse is operating. Records documenting the pressure drop shall be kept in a log and shall include the following: A. Unit Identification; B. Manufacturer-recommended pressure drop for the unit; C. Daily pressure drop readings; D. Date of reading. [R307-401-8] II.B.1.c.2 The owner/operator shall monitor the pressure drop with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8] II.B.1.c.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8] II.B.2 VOC and HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 39.91 tons per rolling 12-month period of VOCs 0.55 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] II.B.2.a.2 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] DAQE-AN109190024-24 Page 10 II.B.2.b The owner/operator shall comply with all applicable requirements of UAC R307-342. [R307-342, R307-401-8] II.B.2.c The owner/operator shall comply with all applicable requirement for UAC R307-335. [R307-355, R307-401] II.B.3 Stack Testing Conditions II.B.3.a PM10 emissions to the atmosphere from the indicated emission points shall not exceed the following rates and concentrations: Source lbs/hr grains/dscf Baghouse #1 2.5 0.01 Baghouse #2 1.63 0.01 Baghouse #3 1.83 0.01 Baghouse #4 2.39 0.01 Baghouse #5 1.63 0.01 Baghouse #6 1.85 0.01 Baghouse #8 1.63 0.01 Baghouse #9 1.07 0.005 Baghouse #10 0.29 0.005 Baghouse #11 0.29 0.005 Baghouse #13 1.63 0.005 [R307-401-8] II.B.3.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.3.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. This AO required the owner/operator to stack test Forming Baghouse #1 because it is directly controlling new machines. Collector Baghouse #5 and Collector Baghouse #8 are also required to stack test because additional emissions are being vented through these baghouses and need to be tested to ensure emissions limits are not exceeded. [R307-165-2] II.B.3.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) 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. [R307-401-8] II.B.3.a.4 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.3.a.5 Testing & 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] DAQE-AN109190024-24 Page 11 II.B.3.a.6 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.3.a.7 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.3.a.8 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.3.b 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.3.b.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.3.b.2 PM10 The following methods shall be used to measure filterable particulate emissions: 40 CFR 51, Appendix M, Method 201, Method 201A, or other EPA-approved testing methods, as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. The portion of the filterable particulate emissions considered PM10 shall be based on information in Appendix B of the fifth edition of the EPA document, AP-42, or other data acceptable to the Director. The following methods shall be used to measure condensable particulate emissions: 40 CFR 51, Appendix M, Method 202, or other EPA-approved testing methods, as acceptable to the Director. The condensable particulate emissions shall not be used for compliance demonstration but shall be used for inventory purposes. [R307-401-8] II.B.4 Boiler, Heater, and Internal Combustion Engine Requirements. II.B.4.a The owner/operator shall use only natural gas as primary fuel and propane as a backup fuel in the heaters, boilers, and the emergency generator engines (except the fire pump engine). [R307-401-8] II.B.4.b The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel additives) in the fire pump engine. All diesel burned shall meet the requirements of 40 CFR 80.510(c). [40 CFR 63 Subpart ZZZZ] DAQE-AN109190024-24 Page 12 II.B.4.c To demonstrate compliance with the fuel oil requirements, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [40 CFR 63 Subpart ZZZZ] II.B.4.d The owner/operator shall not operate each internal combustion engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. [R307-401-8] II.B.4.d.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 internal combustion engine shall be kept in a log and shall include the following: A. The date the internal combustion engine was used B. The duration of operation in hours C. The reason for the internal combustion engine usage. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN109190023-23 dated October 27, 2023 Incorporates NOI dated September 13, 2024 DAQE-AN109190024-24 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 DAQE-IN109190024-24 November 18, 2024 Mike Jones Kimberly-Clark Corporation 2010 North Rulon White Blvd. Ogden, UT 84404 -7802 mdjones@kcc.com Dear Mr. Jones: Re: Intent to Approve: Modification to Approval Order DAQE-AN109190023-23 to Add Equipment and Increase Emissions Project Number: N109190024 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, Stockton Antczak, as well as the DAQE number as shown on the upper right-hand corner of this letter. Stockton Antczak can be reached at (385) 306-6724 or santczak@utah.gov if you have any questions. Sincerely, {{$s }} Jon L. Black, Manager New Source Review Section JLB:SA:jg cc: Weber-Morgan Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director * ) ' & — * 1 @ @ v A ? A C A @ w A A ˜ STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN109190024-24 Modification to Approval Order DAQE-AN109190023-23 to Add Equipment and Increase Emissions Prepared By Stockton Antczak, Engineer (385) 306-6724 santczak@utah.gov Issued to: Kimberly-Clark Corporation - Ogden Plant Issued On November 18, 2024 {{$s }} New Source Review Section Manager Jon L. Black {{#s=Sig_es_:signer1:signature}} * ) ' & — * 1 @ @ v A ? A C A @ w A A ˜ 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............................................................................................... 5 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ..................................................................................... 8 PERMIT HISTORY ................................................................................................................... 13 ACRONYMS ............................................................................................................................... 14 DAQE-IN109190024-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Kimberly-Clark Corporation Kimberly-Clark Corporation - Ogden Plant Mailing Address Physical Address 2010 North Rulon White Blvd. 2010 North Rulon White Blvd. Ogden, UT 84404-7802 Ogden, UT 84404-7802 Source Contact UTM Coordinates Name: Mike Jones 415,874 m Easting Phone: (801) 786-2318 4,571,869 m Northing Email: mdjones@kcc.com Datum NAD83 UTM Zone 12 SIC code 2676 (Sanitary Paper Products) SOURCE INFORMATION General Description Kimberly-Clark Corporation (KCC) operates a diaper manufacturing plant in Ogden, Weber County. NSR Classification Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Weber County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines DAQE-IN109190024-24 Page 4 Project Description KCC plans to modify the Ogden Plant to add capability to produce a new type of product. The process change includes additional vacuum conveyors with a vacuum fan. Exhaust air from the fan will be routed through the existing U8 Machine Dust Bag filter rack assembly. Additionally, KCC is requesting to add two (2) sets of cooling towers to the permit. The addition of the cooling towers will result in an increase in PM10 and PM2.5 emissions. Process Description The KCC Ogden plant is a disposable garment manufacturing facility. Various components are purchased from suppliers and are shipped to the plant by truck. Absorbent fluff (made from cellulose and polymer), a protective liner, and an outer plastic shell enter an automated assembly line to form various garments. The fluff material enters the form machine at the front of the line and is uniformly shredded and mixed. The combined fluff moves by conveyor through a compression stage to form the absorbent bulk of the garment. Once the fluff has been shaped, the protective inside liner and plastic outer shell are added. When all three components have been combined, the final shape is cut and the garment is sealed. The finished garments are stacked and packaged by an automated machine and are conveyor-transported to the loading dock/warehouse area for shipment or storage. The production lines are all vented to cyclones and/or baghouses to control particulate emissions and recycle material. This facility has a reclaim system where rejected garments and fluff are separated and either baled into fluff bricks, fluff bales, or tailings bales. All processed waste material is sold. 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 0 19016.41 Carbon Monoxide 0 8.46 Nitrogen Oxides 0 12.99 Particulate Matter - PM10 5 41.53 Particulate Matter - PM2.5 3.80 40.33 Sulfur Dioxide 0 0.06 Volatile Organic Compounds 0 39.91 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Cresols/Cresylic Acid (Isomers And Mixture) (CAS #1319773) 0 280 Generic HAPs (CAS #GHAPS) 0 128 Methylene Chloride (Dichloromethane) (CAS #75092) 0 700 Change (TPY) Total (TPY) Total HAPs 0 0.55 DAQE-IN109190024-24 Page 5 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 Ogden Standard Examiner on November 20, 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. 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 Utah Administrative Code (UAC) Rule 307 (R307) and Title 40 of the Code of Federal Regulations (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 in accordance with UAC R307-401. [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. Inventories, Testing and Monitoring. [R307-150] DAQE-IN109190024-24 Page 6 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 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 Kimberly-Clark Corporation Diaper Manufacturing Plant II.A.2 Forming Baghouse #1 Controls: Lines U1, U2, and U8 Max. Rating: 37,000 acfm II.A.3 Forming Baghouse #2 Controls: Lines U3 and U4 Max. Rating: 25,000 acfm II.A.4 Forming Baghouse #3 Controls: Lines U5 and U6 Max. Rating: 28,000 acfm II.A.5 Forming Baghouse #4 Controls: Line U7 Max. Rating: 31,000 acfm II.A.6 Collector Baghouses #5 and #8 Controls: Emissions from Forming Baghouse #1 through #4 and Reclaiming Unit Baghouse #6 Max. Rating: 25,000 acfm II.A.7 Reclaiming Unit Baghouse #6 Controls: Reclaiming Unit Max. Rating: 27,500 acfm II.A.8 Forming Baghouse #9 Controls: Line U10, U11, and U12 Max. Rating: 36,300 acfm II.A.9 Forming Baghouse #13 Controls: Line U13 Max. Rating: 48,200 acfm II.A.10 Collector Baghouse #10 and #11 Controls exhaust from Forming Baghouse #9 and #13 Max. Rating: 25,000 acfm DAQE-IN109190024-24 Page 7 II.A.11 Two (2) Vacuum Pulse Jet Baghouse Two (2) vacuum system vents Controls the central vacuum system II.A.12 Two (2) Boilers Maximum Rated Capacity: 13.39 MMBtu/hr each Fuel: Natural Gas NSPS Applicability: Subpart Dc II.A.13 One (1) Adhesive Shop Adhesive removal process, classified as a cold cleaning process. Includes a hot oil bath, solvent tank, two (2) electric ovens, and a parts cleaner. II.A.14 Twenty-two (22) Adhesive Melters Electric-powered adhesive melters for liquefying adhesive II.A.15 Two (2) Emergency Generator Engines Rating: One (1) 195hp and one (1) 354hp Fuel: Natural Gas MACT Applicability: Subpart ZZZZ II.A.16 One (1) Emergency Generator Engine Rating: 530hp Fuel: Natural Gas NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.17 One (1) Fire Pump Engine Rating: 255hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.18 One (1) Reclaim Bale Opener II.A.19 Eleven (11) Machine Air Wall Louvers Included for informational purposes II.A.20 One (1) Laboratory Fume Exhaust Hood II.A.21 3D Printer HP Jet Fusion 3D Printer II.A.22 Various Heaters and Boilers Maximum Rated Capacity: 5.0 MMBtu/hr each Fuel: Natural Gas Source Category Exemption under R307-401-10 II.A.23 Baby Care (BC) Chiller Cooling Tower Ceramic Cooling Tower Company Model: PL-4-450-40A counterflow cooling tower Consists of four (4) cells Total GPM required: 6,300 Tower pumping head: 11 ft. Drift loss: 0.0005% (based on DriAir 80 drift eliminators from Evaptech) DAQE-IN109190024-24 Page 8 II.A.24 Baby Care (BC) Compressor Cooling Tower Baltimore Aircoil Company Model: FXV-1212C-36T-P Flow rate: 580 GPM Drift loss: 0.005% II.A.25 Child Care (CC) Chiller Cooling Tower Consists of two (2) cells Total flow rate: 7,500 GPM Drift loss: 0.001% II.A.26 Child Care (CC) Compressor Cooling Tower One (1) unit Flow rate: 694 GPM Drift loss: 0.001% 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 Facility-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. Baghouse #1, #2, #3, #4, #5 - 20% opacity. B. All other baghouses and cooling towers - 10% opacity. C. Reclaim and Central Vacuum System vents - 5% opacity. D. All natural gas heaters, boilers, and emergency generator engines - 10% opacity. E. All other points - 20% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] DAQE-IN109190024-24 Page 9 II.B.1.b The owner/operator shall control the following manufacturing operations with the applicable baghouses listed below. Operation Baghouse Lines U1, U2, and U8 Forming Baghouse #1 Lines U3 and U4 Forming Baghouse #2 Lines U5 and U6 Forming Baghouse #3 Line U7 Forming Baghouse #4 Emissions from Forming Collector Baghouses Baghouses #1, #2, #3, #4 #5 and #8 And Reclaiming Baghouse #6 Reclaiming Unit Forming Baghouse #6 Lines U10, U11, and U12 Forming Baghouse #9 Line U13 Forming Baghouse #13 Exhaust from Forming Collector Baghouses Baghouses #9 and #13 #10 and #11 [R307-401-8] II.B.1.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The baghouse shall operate within the static pressure range recommended by the manufacturer. The monitoring device shall measure in one (1) inch water column increments or less. [R307-401-8] II.B.1.c.1 Pressure drop readings shall be recorded at least once during each day of operation while the baghouse is operating. Records documenting the pressure drop shall be kept in a log and shall include the following: A. Unit Identification; B. Manufacturer-recommended pressure drop for the unit; C. Daily pressure drop readings; D. Date of reading. [R307-401-8] II.B.1.c.2 The owner/operator shall monitor the pressure drop with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8] II.B.1.c.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8] DAQE-IN109190024-24 Page 10 II.B.2 VOC and HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site: 39.91 tons per rolling 12-month period of VOCs. 0.55 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th of each month using data from the previous 12 months. The owner/operator shall use a mass balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] II.B.2.a.2 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material. B. The maximum percent by weight of VOCs and each HAP in each material used. C. The density of each material used. D. The volume of each VOC- and HAP-emitting material used. E. The amount of VOCs and the amount of each HAP emitted from each material. F. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] II.B.2.b The owner/operator shall comply with all applicable requirements of Utah Administrative Code (UAC) R307-342. [R307-342, R307-401-8] II.B.2.c The owner/operator shall comply with all applicable requirements for Utah Administrative Code (UAC) R307-335. [R307-355, R307-401] DAQE-IN109190024-24 Page 11 II.B.3 Stack Testing Conditions II.B.3.a PM10 emissions to the atmosphere from the indicated emission points shall not exceed the following rates and concentrations: Source lbs/hr grains/dscf Baghouse #1 2.5 0.01 Baghouse #2 1.63 0.01 Baghouse #3 1.83 0.01 Baghouse #4 2.39 0.01 Baghouse #5 1.63 0.01 Baghouse #6 1.85 0.01 Baghouse #8 1.63 0.01 Baghouse #9 1.07 0.005 Baghouse #10 0.29 0.005 Baghouse #11 0.29 0.005 Baghouse #13 1.63 0.005 [R307-401-8] II.B.3.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.3.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. This AO required the owner/operator to stack test Forming Baghouse #1 because it is directly controlling new machines. Collector Baghouse #5 and Collector Baghouse #8 are also required to stack test because additional emissions are being vented through these baghouses and need to be tested to ensure emissions limits are not exceeded. [R307-165-2] II.B.3.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) 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. [R307-401-8] II.B.3.a.4 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.3.a.5 Testing & 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.3.a.6 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.3.a.7 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] DAQE-IN109190024-24 Page 12 II.B.3.a.8 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.3.b 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.3.b.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.3.b.2 PM10 The following methods shall be used to measure filterable particulate emissions: 40 CFR 51, Appendix M, Method 201, Method 201A, or other EPA-approved testing methods, as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. The portion of the filterable particulate emissions considered PM10 shall be based on information in Appendix B of the fifth edition of the EPA document, AP-42, or other data acceptable to the Director. The following methods shall be used to measure condensable particulate emissions: 40 CFR 51, Appendix M, Method 202, or other EPA-approved testing method, as acceptable to the Director. The condensable particulate emissions shall not be used for compliance demonstration but shall be used for inventory purposes. [R307-401-8] II.B.4 Boiler, Heater, and Internal Combustion Engine Requirements. II.B.4.a The owner/operator shall use only natural gas as primary fuel and propane as a backup fuel in the heaters, boilers, and the emergency generator engines (except the fire pump engine). [R307-401-8] II.B.4.b The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel additives) in the fire pump engine. All diesel burned shall meet the requirements of 40 CFR 80.510(c). [40 CFR 63 Subpart ZZZZ] II.B.4.c To demonstrate compliance with the fuel oil requirements, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [40 CFR 63 Subpart ZZZZ] II.B.4.d The owner/operator shall not operate each internal combustion engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. [R307-401-8] DAQE-IN109190024-24 Page 13 II.B.4.d.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 internal combustion engine shall be kept in a log and shall include the following: A. The date the internal combustion engine was used. B. The duration of operation in hours. C. The reason for the internal combustion engine usage. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN109190023-23 dated October 27, 2023 Incorporates NOI dated September 13, 2024 DAQE-IN109190024-24 Page 14 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 Kimberly-Clark Corporation 10919 0024 - Page 1 of 2 FILER Jeree Greenwood jereeg@utah.gov (801) 536-4000 FILING FOR Standard-Examiner Columns Wide:2 Total Column Inches:7.68 Number of Lines:31 Ad Class:Legals INTERIM AD DRAFT This is the proof of your ad scheduled to run in Standard-Examiner on the dates indicated below. If changes are needed, please contact us prior to deadline at (801) 625-4302. Notice ID: Zt6qrjbYHoxy8frzvmRg | Proof Updated: Nov. 18, 2024 at 09:14am MST Notice Name: Kimberly-Clark Corporation 10919 0024 This is not an invoice. Below is an estimated price, and it is subject to change. You will receive an invoice with the final price upon invoice creation by the publisher. 11/20/2024: Custom 276.47 Base Affidavit Fee 12.00 Subtotal $288.47 Tax $0.00 Processing Fee $28.85 Total $317.32 See Proof on Next Page Kimberly-Clark Corporation 10919 0024 - Page 2 of 2 Standard Examiner Publication Name: Standard Examiner Publication URL: www.standard.net Publication City and State: Ogden, UT Publication County: Weber Notice Popular Keyword Category: Notice Keywords: kimberly Notice Authentication Number: 202411200957586886355 1761527881 Notice URL: Back Notice Publish Date: Wednesday, November 20, 2024 Notice Content 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: Kimberly-Clark Corporation Location: Kimberly-Clark Corporation - Ogden Plant - 2010 North Rulon White Boulevard, Ogden, UT Project Description: Kimberly-Clark Corporation (KCC) is a diaper manufacturing facility in Ogden, Weber County. KCC has requested a minor modification to add two sets of existing cooling towers to the permit and add capability to produce a new type of product. These changes will result in an increase in PM10 and PM2.5 emissions. 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 December 20, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at santczak@utah.gov. 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: November 20, 2024 Legal Notice 13445 Published in the Standard Examiner on November 20, 2024 Back DAQE-NN109190024-24 November 18, 2024 Ogden Standard Examiner Legal Advertising Dept. P.O. Box 12790332 Standard Way Ogden, UT 84412 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Ogden Standard Examiner on November 20, 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 (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Weber County cc: Wasatch Front Regional Council 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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-NN109190024-24 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: Kimberly-Clark Corporation Location: Kimberly-Clark Corporation - Ogden Plant – 2010 North Rulon White Boulevard, Ogden, UT Project Description: Kimberly-Clark Corporation (KCC) is a diaper manufacturing facility in Ogden, Weber County. KCC has requested a minor modification to add two sets of existing cooling towers to the permit and add capability to produce a new type of product. These changes will result in an increase in PM10 and PM2.5 emissions. 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 December 20, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at santczak@utah.gov. 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: November 20, 2024 {{#s=Sig_es_:signer1:signature}} DAQE- RN109190024 October 23, 2024 Mike Jones Kimberly-Clark Corporation 2010 North Rulon White Blvd Ogden, UT 84404 mdjones@kcc.com Dear Mike Jones, Re: Engineer Review: Modification to Approval Order DAQE-AN109190023-23 to Add Equipment and Increase Emissions Project Number: N109190024 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Kimberly-Clark Corporation should complete this review within 10 business days of receipt. Kimberly-Clark Corporation should contact Stockton Antczak at (385) 306-6724 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Stockton Antczak at santczak@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Kimberly-Clark Corporation does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Kimberly-Clark Corporation has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N109190024 Owner Name Kimberly-Clark Corporation Mailing Address 2010 North Rulon White Blvd Ogden, UT, 84404 Source Name Kimberly-Clark Corporation - Ogden Plant Source Location 2010 North Rulon White Boulevard Ogden, UT 84404-7802 UTM Projection 415,874 m Easting, 4,571,869 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2676 (Sanitary Paper Products) Source Contact Mike Jones Phone Number (801) 786-2318 Email mdjones@kcc.com Billing Contact Mike Jones Phone Number (801) 786-2318 Email mdjones@kcc.com Project Engineer Stockton Antczak, Engineer Phone Number (385) 306-6724 Email santczak@utah.gov Notice of Intent (NOI) Submitted September 13, 2024 Date of Accepted Application September 24, 2024 Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 2 SOURCE DESCRIPTION General Description Kimberly-Clark Worldwide Incorporated (KCC) operates a diaper manufacturing plant in Ogden, Weber County. NSR Classification: Minor Modification at Minor Source Source Classification Located in , Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Weber County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal Modification to Approval Order DAQE-AN109190023-23 to Add Equipment and Increase Emissions Project Description KCC plans to modify the Ogden Plant to add capability to produce a new type of product. The process change includes additional vacuum conveyors with a vacuum fan. Exhaust air from the fan will be routed through the existing U8 Machine Dust Bag filter rack assembly. Additionally, KCC is requesting to add two sets of cooling towers to the permit. The addition of the cooling towers will result in an increase in PM10 and PM2.5 emissions. Process Description: The KCC Ogden plant is a disposable garment manufacturing facility. Various components are purchased from suppliers and are shipped to the plant by truck. Absorbent fluff (made from cellulose and polymer), a protective liner, and an outer plastic shell enter an automated assembly line to form various garments. The fluff material enters the form machine at the front of the line and is uniformly shredded and mixed. The combined fluff moves by conveyor through a compression stage to form the absorbent bulk of the garment. Once the fluff has been shaped, the protective inside liner and plastic outer shell are added. When all three components have been combined the final shape is cut and the garment is sealed. The finished garments are stacked and packaged by an automated machine and are conveyor-transported to the loading dock/warehouse area for shipment or storage. The production lines are all vented to cyclones and/or baghouses to control particulate emissions and recycle material. Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 3 This facility has a reclaim system where rejected garments and fluff are separated and either baled into fluff bricks, fluff bales, or tailings bales. All processed waste material is sold. EMISSION IMPACT ANALYSIS The increases in PM10 and PM2.5 are below the thresholds of UAC R307-410 that would require modeling. No modeling is required. [Last updated October 2, 2024] Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 4 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 0 19016.41 Carbon Monoxide 0 8.46 Nitrogen Oxides 0 12.99 Particulate Matter - PM10 5 41.53 Particulate Matter - PM2.5 3.80 40.33 Sulfur Dioxide 0 0.06 Volatile Organic Compounds 0 39.91 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Cresols/Cresylic Acid (Isomers And Mixture) (CAS #1319773) 0 280 Generic HAPs (CAS #GHAPS) 0 128 Methylene Chloride (Dichloromethane) (CAS #75092) 0 700 Change (TPY) Total (TPY) Total HAPs 0 0.55 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 5 Review of BACT for New/Modified Emission Units . BACT review regarding New Vacuum Conveyors and Fan The use of a baghouse and a 20% opacity is BACT for controlling PM10 and PM2.5 emissions from the exhaust air of this process. The existing U8 machine dust baghouse will be used to control emissions from the exhaust air. [Last updated October 2, 2024] . BACT review regarding Cooling Towers Drift eliminators with a maximum drift loss of 0.005% or better and a 10% opacity are considered BACT for the cooling towers. The compressor cooling towers, chiller cooling towers currently have drift eliminators installed. [Last updated October 2, 2024] 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. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the Utah Administrative Code (UAC) Rule 307 (R307) and Title 40 of the Code of Federal Regulations (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 in accordance with UAC R307-401. [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] Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 6 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. Inventories, Testing and Monitoring. [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 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. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Kimberly-Clark Corporation Diaper Manufacturing Plant II.A.2 Forming Baghouse #1 Controls: Lines U1, U2, and U8 Max. Rating: 37,000 acfm II.A.3 Forming Baghouse #2 Controls: Lines U3 and U4 Max. Rating: 25,000 acfm II.A.4 Forming Baghouse #3 Controls: Lines U5 and U6 Max. Rating: 28,000 acfm II.A.5 Forming Baghouse #4 Controls: Line U7 Max. Rating: 31,000 acfm II.A.6 Collector Baghouses #5 and #8 Controls: Emissions from Forming Baghouse #1 through #4 and; Reclaiming Unit Baghouse #6 Max. Rating: 25,000 acfm II.A.7 Reclaiming Unit Baghouse #6 Controls: Reclaiming Unit Max. Rating: 27,500 acfm Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 7 II.A.8 Forming Baghouse #9 Controls: Line U10, U11, and U12 Max. Rating: 36,300 acfm II.A.9 Forming Baghouse #13 Controls: Line U13 Max. Rating: 48,200 acfm II.A.10 Collector Baghouse #10 and #11 Controls exhaust from Forming Baghouse #9 and #13 Max. Rating: 25,000 acfm II.A.11 Two (2) Vacuum Pulse Jet Baghouse Two (2) vacuum system vents Controls the central vacuum system II.A.12 Two (2) Boilers Maximum Rated Capacity: 13.39 MMBtu/hr each Fuel: Natural Gas NSPS Applicability: Subpart Dc II.A.13 One (1) Adhesive Shop Adhesive removal process, classified as a cold cleaning process. Includes hot oil bath, solvent tank, two (2) electric ovens, and a parts cleaner. II.A.14 Twenty-two (22) Adhesive Melters Electric powered adhesive melters for liquefying adhesive II.A.15 Two (2) Emergency Generator Engines Rating: One (1) 195hp and one (1) 354hp Fuel: Natural Gas MACT Applicability: Subpart ZZZZ II.A.16 One (1) Emergency Generator Engine Rating: 530hp Fuel: Natural Gas NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.17 One (1) Fire Pump Engine Rating: 255hp Fuel: Diesel MACT Applicability: Subpart ZZZZ II.A.18 One (1) Reclaim Bale Opener II.A.19 Eleven (11) Machine Air Wall Louvers Included for informational purposes Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 8 II.A.20 One (1) Laboratory Fume Exhaust Hood II.A.21 3D Printer HP Jet Fusion 3D Printer II.A.22 Various Heaters and Boilers Maximum Rated Capacity: 5.0MMBtu/hr each Fuel: Natural Gas Source Category Exemption under R307-401-10 II.A.23 NEW Baby Care (BC) Chiller Cooling Tower Ceramic Cooling Tower Company Model: PL-4-450-40A counterflow cooling tower Consists of four (4) cells. Total GPM required: 6,300 Tower pumping head: 11 ft. Drift loss: 0.0005% (based on DriAir 80 drift eliminators from Evaptech) II.A.24 NEW Baby Care (BC) Compressor Cooling Tower Baltimore Aircoil Company Model: FXV-1212C-36T-P Flow rate: 580 GPM Drift loss: 0.005% II.A.25 NEW Child Care (CC) Chiller Cooling Tower Consists of two (2) cells Total flow rate: 7,500 GPM Drift loss: 0.001% II.A.26 NEW Child Care (CC) Compressor Cooling Tower One (1) unit. Flow rate: 694 GPM Drift loss: 0.001% 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. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Facility-Wide Requirements Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 9 II.B.1.a NEW The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. Baghouse #1, #2, #3, #4, #5 - 20% opacity B. All other baghouses and cooling towers - 10% opacity C. Reclaim and Central Vacuum System vents - 5% opacity D. All natural gas heaters, boilers, and emergency generator engines - 10% opacity E. All other points - 20% opacity [R307-401-8] II.B.1.a.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.b NEW The owner/operator shall control the following manufacturing operations with the applicable baghouses listed below. Operation Baghouse Lines U1, U2, and U8 Forming Baghouse #1 Lines U3 and U4 Forming Baghouse #2 Lines U5 and U6 Forming Baghouse #3 Line U7 Forming Baghouse #4 Emissions from Forming Collector Baghouses Baghouses #1, #2, #3, #4 #5 and #8 And Reclaiming Baghouse #6 Reclaiming Unit Forming Baghouse #6 Lines U10, U11, and U12 Forming Baghouse #9 Line U13 Forming Baghouse #13 Exhaust from Forming Collector Baghouses Baghouses #9 and #13 #10 and #11 [R307-401-8] II.B.1.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across each baghouse. The baghouse shall operate within the static pressure range recommended by the manufacturer. The monitoring device shall measure in one (1) inch water column increments or less. [R307-401-8] Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 10 II.B.1.c.1 Pressure drop readings shall be recorded at least once during each day of operation while the baghouse is operating. Records documenting the pressure drop shall be kept in a log and shall include the following: A. Unit Identification; B. Manufacturer-recommended pressure drop for the unit; C. Daily pressure drop readings; D. Date of reading [R307-401-8] II.B.1.c.2 The owner/operator shall monitor the pressure drop with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8] II.B.1.c.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8] II.B.2 VOC and HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting, printing, coating, and/or cleaning) on site; 39.91 tons per rolling 12-month period of VOCs 0.55 tons per rolling 12-month period of all HAPs combined. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 11 II.B.2.a.2 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP- emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons) [R307-401-8] II.B.2.b NEW The owner/operator shall comply with all applicable requirements of Utah Administrative Code (UAC) R307-342. [R307-342, R307-401-8] II.B.2.c NEW The owner/operator shall comply with all applicable requirement for Utah Administrative Code (UAC) R307-335. [R307-355, R307-401] II.B.3 Stack Testing Conditions II.B.3.a NEW PM10 Emissions to the atmosphere from the indicated emission points shall not exceed the following rates and concentrations: Source lbs/hr grains/dscf Baghouse #1 2.5 0.01 Baghouse #2 1.63 0.01 Baghouse #3 1.83 0.01 Baghouse #4 2.39 0.01 Baghouse #5 1.63 0.01 Baghouse #6 1.85 0.01 Baghouse #8 1.63 0.01 Baghouse #9 1.07 0.005 Baghouse #10 0.29 0.005 Baghouse #11 0.29 0.005 Baghouse #13 1.63 0.005 [R307-401-8] II.B.3.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] Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 12 II.B.3.a.2 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. This AO required the owner/operator to stack test Forming Baghouse #1 because it is directly controlling new machines. Collector Baghouse #5 and Collector Baghouse #8 are also required to stack test because additional emissions are being vented through these baghouses and need to be tested to ensure emissions limits are not exceeded. [R307-165-2] II.B.3.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (5) 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. [R307-401-8] II.B.3.a.4 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.3.a.5 Testing & 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.3.a.6 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.3.a.7 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.3.a.8 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.3.b 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] Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 13 II.B.3.b.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.3.b.2 PM10 The following methods shall be used to measure filterable particulate emissions: 40 CFR 51, Appendix M, Method 201, Method 201A, or other EPA-approved testing methods, as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10. The portion of the filterable particulate emissions considered PM10 shall be based on information in Appendix B of the fifth edition of the EPA document, AP-42, or other data acceptable to the Director. The following methods shall be used to measure condensable particulate emissions: 40 CFR 51, Appendix M, Method 202, or other EPA-approved testing method, as acceptable to the Director. The condensable particulate emissions shall not be used for compliance demonstration, but shall be used for inventory purposes. [R307-401-8] II.B.4 Boiler, Heater, and Internal Combustion Engine Requirements. II.B.4.a NEW The owner/operator shall use only natural gas as primary fuel and propane as a backup fuel in the heaters, boilers, and the emergency generator engines (except the fire pump engine). [R307-401-8] II.B.4.b The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel additives) in the fire pump engine. All diesel burned shall meet the requirements of 40 CFR 80.510(c). [40 CFR 63 Subpart ZZZZ] II.B.4.c To demonstrate compliance with the fuel oil requirements, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [40 CFR 63 Subpart ZZZZ] II.B.4.d The owner/operator shall not operate each internal combustion engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. [R307-401-8] Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 14 II.B.4.d.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 internal combustion engine shall be kept in a log and shall include the following: A. The date the internal combustion engine was used B. The duration of operation in hours C. The reason for the internal combustion engine usage. [R307-401-8] Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 15 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN109190023-23 dated October 27, 2021 Incorporates NOI dated September 13, 2024 REVIEWER COMMENTS 1. Comment regarding Summary of Changes: KCC plans to add the capability to produce a new type of product at their facility. These changes include: adding additional vacuum conveyors and a vacuum fan; routing the exhaust air through the currently unused U8 Machine Dust Bag filter rack assembly; adding two sets cooling towers to the permit. As part of the modification, the U8 Machine Dust Bag filter rack assembly will be moved into Forming Dust Baghouse #1 that is fed by the U1 and U2 machines. The clean air will be exhausted through the same stack that the Forming Baghouse #1 currently exhausts through. The air flow through the relocated U8 Machine Dust Bag filter rack assembly will be a maximum of 12,000 cfm. As such, the clean air exhaust flow rate through the Forming Baghouse #1 stack will increase from 25,000 acfm to 37,000 acfm. Dirty air from both the Forming Baghouse #1 and the relocated U8 Machine Dust Bag filter rack assembly will continue to be exhausted to either Collector Baghouse #5 or #8. There will be no increase in the exhaust flow rate to either Collector Baghouse #5 or #8, which have an existing air flow rate of 25,000 acfm. Kimberly-Clark is requesting to add two sets of cooling towers to the permit, the Baby Care (BC) chiller and compressor cooling towers and the Child Care (CC) chiller and compressor cooling towers. The BC Chiller cooling tower consists of four cells and the BC compressor cooling tower consists of one cell. The CC Chiller cooling tower consists of two cells and the CC compressor cooling tower consists of one cell. The BC Chiller cooling towers are currently undergoing an upgrade and will be equipped with drift eliminators capable of achieving a drift loss as low as 0.0005%. The BC compressor cooling tower is equipped with a drift eliminator which achieves a drift loss of 0.005%. The CC Chiller and CC compressor cooling towers are equipped with drift eliminators which achieve 0.001% drift loss. [Last updated October 2, 2024] 2. Comment regarding Emissions Increase Calculations: This project will result in an increase in PTE for PM10 and PM2.5, which will increase by 5 tpy and 3.8 tpy. Emissions from the baghouse were calculated using the same grain loading as is currently exhausted through Forming Baghouses #1, #2, or #4. This rate is 0.01 grain/dscf. The flow rate is estimated to be 37,000 acfm with 8,760 hours of operation per year. This results in an increase of 3.81 tpy of PM10 and PM 2.5. PM10 emissions from the cooling towers were calculated using a conservative maximum drift loss percentage of 0.005%. 8,760 hours of operation per year was used along with the maximum rated water flow rate for each of the towers. The values for the flow rates can be found in the equipment list. The concentrations of different particulate sizes were estimated using a distribution based on the methodology discussed in "Calculating Realistic PM10 Emissions from Cooling Towers" by Joel Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 16 Reisman and Gordon Frisbie. These calculations resulted in a 1.15 tpy increase in PM10 emissions as a result of operating the cooling towers. [Last updated October 2, 2024] 3. Comment regarding NSPS and MACT Applicability: This source is subject to 40 CFR 63 Subpart ZZZZ and 40 CFR 60 Subparts Dc and JJJJ. 40 CFR 60 (NSPS) Subpart Dc applies to steam generating units that are between 10 MMBtu/hr and 100 MMBtu/hr in size. The source operates two (2) boilers within this size range. Therefore, Subpart Dc applies to this source. 40 CFR 60 (NSPS) Subpart JJJJ and 40 CFR 63 (MACT) applies to the diesel-fired generator engines that are operated at this facility. Therefore, both NSPS Subpart JJJJ and MACT Subpart ZZZZ apply to this source. [Last updated September 27, 2024] 4. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants 4. Any Title IV affected source This facility is not a major source and is not a Title IV source; however, the facility is subject to 40 CFR 60 NSPS Subparts A, Dc, and JJJJ, and 40 CFR 63 MACT Subparts A and ZZZZ regulations. NSPS Subpart JJJJ and MACT Subpart ZZZZ exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. NSPS Subpart Dc does not exempt sources from the obligation to obtain a Title V permit; however, under NSPS Subpart Dc, the source is only subject to record-keeping requirements, not a numerical standard. Therefore, the source is not subject to Title V requirements. [Last updated September 27, 2024] Engineer Review N109190024: Kimberly-Clark Corporation - Ogden Plant October 23, 2024 Page 17 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 EPA 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 - 40 CFR 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 UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour 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 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 October 23, 2024 Mike Jones Kimberly-Clark Corporation 2010 North Rulon White Blvd Ogden, UT 84404 mdj ones@kcc .com Dear Mike Jones, RN109190024 Re: Engineer Review: Modification to Approval Order DAQE-AN109190023-23 to Add Equipment and Increase Emissions Project Number: N109190024 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Kimberly-Clark Corporation should complete this review within 10 business days of receipt. Kimberly-Clark Corporation should contact Stockton Antczak at (385) 306-6724 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Stockton Antczak at santczak@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Kimberly-Clark Corporation does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Kimberly-Clark Corporation has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature ____________///7 ______________________ (Signature & Date) 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper 405 S. 8th St, Ste 331, Boise, ID 83702 / P 208.472.8837 / F 678.441.9978 / trinityconsultants.com HEADQUARTERS 12700 Park Central Dr, Ste 2100, Dallas, TX 75251 / P 800.229.6655 / P 972.661.8100 / F 972.385.9203 September 13, 2024 Attn: Permitting Mr. Alan Humpherys Utah Division of Air Quality 195 North 1950 West Salt Lake City, UT 84116 RE: Kimberly Clark Corporation Ogden Facility Notice of Intent Cover Letter Dear Mr. Humpherys: Trinity Consultants Inc. (Trinity) respectfully submits this Notice of Intent (NOI) on behalf of Kimberly Clark Corporation (Kimberly-Clark). Kimberly-Clark operates a diaper manufacturing plant located in Ogden, Utah (Ogden facility). Kimberly-Clark plans to modify the Ogden Plant to add capability to produce a new type of product. The process change includes additional vacuum conveyors with a vacuum fan. Exhaust air from the fan will be routed through the existing but unused U8 Machine Dust Bag filter rack assembly. Additionally, Kimberly-Clark is requesting to add two sets of existing, unpermitted cooling towers to the permit. Enclosed with this submittal is the UDAQ Form 2 which includes a certification by Kimberly-Clark, as well as project information Form 4, emissions information Form 5, and fabric filter Form 10. Kimberly-Clark will be submitting a $3,075 payment via the UDAQ online portal for the application fee comprising of a $575 filing fee and $2,500 review fee. Kimberly-Clark and Trinity are requesting your review and approval of this NOI. If you have any questions or require additional information or wish to discuss further, please do not hesitate to call me at (208) 472-8837. Sincerely, Trinity Consultants Shannon Manoulian, P.E. Senior Consultant Enclosures: UDAQ Forms NOI Application ATTACHMENT 1 UDAQ Forms 1 of 1 Form 2 Date Company Information/Notice of Intent (NOI) Utah Division of Air Quality New Source Review Section Application for: □ Initial Approval Order □Approval Order Modification General Owner and Source Information 1.Company name and mailing address: ____________________________ ____________________________ ____________________________ Phone No.: ( ) Fax No.: ( ) 2.Company** contact for environmental matters: ____________________________ Phone no.: ( ) Email: _______________________ ** Company contact only; consultant or independent contractor contact information can be provided in a cover letter 3.Source name and physical address (if different from above):____________________________ ____________________________ ____________________________ Phone no.: ( ) Fax no.: ( ) 4.Source Property Universal Transverse Mercator coordinates (UTM), including System and Datum: UTM:_________________________ X:____________________________ Y:____________________________ 5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC) __ __ __ __ 7.If request for modification, AO# to be modified: DAQE AN109190023-23____ 8.Brief (50 words or less) description of process. Electronic NOI 9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black (jlblack@utah.gov) or Alan Humpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal Electronic Copy Submittal □ Both Authorization/Singnature I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on reasonable inquiry made by me and to the best of my knowledge and belief. Signature: Title: _______________________________________ Name (Type or print) Telephone Number: ( ) Email: Date: Kimberly-Clark Corporation 2010 North Rulon White Blvd. Ogden, UT 84404 Mike D. Jones 801 786-2318 mdjones@kcc.com Ogden Plant (address same as above) 801 782-2500 801 786-2428 NAD 83, Zone 12 415,000 m Easting 4,572,000 m Northing Weber 2676 X Diaper and pant manufacturing plant - Process changes with additional vacuum conveyors and vacuum fan and incorporation of existing cooling towers into the permit. U8 Machine Dust Bag filter rack assembly will be moved into Forming Baghouse #1. 1/3/2022 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. Page 1 of 1 Company___________________________ Site _____________________________ Form 5 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 NOTICE OF INTENT SAM Application Fan Installation and Cooling Tower Incorporation Kimberly-Clark Corporation / Ogden Plant Prepared By: Shannon Manoulian – Senior Consultant Marina Cartlidge – Consultant TRINITY CONSULTANTS 405 South 8th Street Suite 331 Boise, ID 83702 208.472.8837 September 2024 Project 241301.0063 Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 1-1 TABLE OF CONTENTS TABLE OF CONTENTS 1-1 LIST OF TABLES 1-2 1. EXECUTIVE SUMMARY 1-3 2. DESCRIPTION OF PLANT AND PROPOSED PROJECT 2-1 2.1 SITE PLAN ................................................................................................................... 2-1 3. SOURCE SIZE DETERMINATION AND OFFSET REQUIREMENTS 3-1 4. EMISSION CALCULATIONS 4-1 4.1 BAGHOUSE EMISSIONS .............................................................................................. 4-1 4.2 COOLING TOWER EMISSIONS .................................................................................... 4-1 5. BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS 5-3 5.1 INTRODUCTION .......................................................................................................... 5-3 5.2 BACT ANALYSIS FOR U8 Machine Dust Baghouse ...................................................... 5-3 5.2.1 Identify All Control Technologies ................................................................................ 5-3 5.2.2 Eliminate Technically Infeasible Options ..................................................................... 5-3 5.2.3 Rank Remaining Control Technologies by Control Effectiveness .................................... 5-4 5.2.4 Evaluate Most Effective Controls and Document Results .............................................. 5-4 5.2.5 Select BACT ............................................................................................................. 5-5 5.3 BACT ANALYSIS FOR COOLING TOWERS .................................................................... 5-5 5.4 BACT Conclusion ......................................................................................................... 5-5 6. FEDERAL/STATE APPLICABLE REQUIREMENTS 6-6 6.1 NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) ......................................... 6-6 6.2 TITLE V (PART 70) OPERATING PERMIT .................................................................... 6-6 6.3 NEW SOURCE REVIEW (NSR) REQUIREMENTS .......................................................... 6-7 6.4 NEW SOURCE PERFORMANCE STANDARDS (NSPS) ................................................... 6-7 6.5 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) .. 6-7 6.6 ACID RAIN REQUIREMENTS ....................................................................................... 6-8 6.7 STATE REGULATORY APPLICABILITY ......................................................................... 6-8 6.7.1 General Requirements-Breakdowns ............................................................................ 6-8 6.7.2 Emission Inventories ................................................................................................. 6-8 6.7.3 Solvent Cleaning ....................................................................................................... 6-8 6.7.4 Nonattainment and Maintenance Areas ...................................................................... 6-8 6.7.5 Adhesives and Sealants ............................................................................................. 6-8 6.7.6 Permit: New and Modified Sources ............................................................................. 6-9 6.7.7 Permit Requirements for New and Modified Sources in Nonattainment Areas and Maintenance Areas .............................................................................................................. 6-9 7. EMISSION IMPACT ANALYSIS 7-1 7.1 HAZARDOUS AIR POLLUTANTS ................................................................................... 7-1 Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 1-2 LIST OF TABLES Table 4-2. Forming Baghouse #1 Particulate Matter Emissions 4-1 Table 4-4. Cooling Tower Emissions 4-2 Table 5-1. Summary of BACT Determinations 5-3 Table 6-1. Federal and State Regulatory Requirements 6-6 Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 1-3 1. EXECUTIVE SUMMARY Kimberly-Clark Corporation (Kimberly-Clark) operates a diaper and pant manufacturing plant located in Ogden, Utah (Ogden Plant). Kimberly-Clark plans to modify the Ogden Plant to add capability to produce a new type of product. The process change includes additional vacuum conveyors with a vacuum fan. Exhaust air from the fan will be routed through the existing but unused U8 Machine Dust Bag filter rack assembly. Additionally, Kimberly-Clark is requesting to add two sets of existing, unpermitted cooling towers to the permit. This report serves as the Notice of Intent (NOI) application for submittal to the Utah Division of Air Quality (UDAQ). The application includes the following elements: Section 2: Description of Plant Section 3: Source Size Determination and Offset Requirements Section 4: Emission Calculations Section 5: Best Available Control Equipment Section 6: Air Pollution Control Equipment Section 7: Federal/State Applicable Requirements Section 8: Emissions Impact Analysis Appendix A: Process Information Forms and Data Sheets Appendix B: Plant Plot Plan Appendix C: Manufacturer Data Sheets Appendix D: Emissions Calculations The application demonstrates that the Plant meets the requirements for a Notice of Intent application under Utah Administrative Code (UAC) R307-401. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 2-1 2. DESCRIPTION OF PLANT AND PROPOSED PROJECT Kimberly-Clark operates a diaper manufacturing plant in Ogden, Utah under approval order DAQE- AN109190023-23 issued on October 27, 2023. Kimberly-Clark plans to modify the Ogden Plant to add capability to produce a new type of product. The process change includes additional process vacuum conveyors and a vacuum fan. The new product will utilize fluff pulp and Super Absorbent Material (SAM), which will enter the new fan’s airstream and will require the air to be exhausted rather than recirculated inside the building. Exhaust air from the fan will be routed through the existing but unused U8 Machine Dust Bag filter rack assembly. The U8 Machine Baghouse is currently routed to exhaust clean air through a wall louver and dirty air to either Collector Baghouse #5 or Collector Baghouse #8. As part of the modification, the U8 Machine Dust Bag filter rack assembly will be moved into Forming Baghouse #1 that is fed by the U1 and U2 machines. The clean air will be exhausted through the same stack that Forming Baghouse #1 exhausts through. The Forming Baghouse #1 exhaust stack will have an increased air flow rate from the clean air from the relocated U8 Machine Dust Bag filter rack assembly. The dirty air from relocated U8 Machine Dust Bag filter rack assembly will continue to be routed to Collector Baghouse #5 or #8 and there will be no increase in the exhaust flow rate to those units. Additionally, Kimberly-Clark is requesting to add two sets of existing, unpermitted cooling towers to the permit. Company Name: Kimberly-Clark Corporation Mailing Address: 2010 North Rulon White Blvd, Ogden, UT 84404 Physical Address: 2010 North Rulon White Blvd, Ogden, UT 84404 Telephone Number: 801.786.2318 Company Contact: Mike D. Jones, Plant Safety and Environmental Coordinator Mailing Address: 2010 North Rulon White Blvd, Ogden, UT 84404 Telephone Number: 801.786.2318 Source Coordinates: 415,000 m Easting, 4,572,000 m Northing, UTM Zone 12 SIC Code: 2676 (Sanitary Paper Products) 2.1 SITE PLAN A site plan of the Ogden Plant is included in Appendix B, which shows the location of the proposed modification and the cooling towers. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 3-1 3. SOURCE SIZE DETERMINATION AND OFFSET REQUIREMENTS The Ogden Plant is located in Weber County which is designated as a serious non-attainment area for PM2.5. The Plant is located within the Wasatch Front ozone non-attainment area. According to Utah Administrative Rule R307-403. Permits: New and Modified Sources in Nonattainment Areas and Maintenance Areas, offsets are required for any new major stationary source or major modification that is major for the pollutant or precursor pollutant for which the area is designated nonattainment under section 107(d)(1)(A)(i) of the Clean Air Act, if the stationary source or modification would locate anywhere in the designated nonattainment area. The Ogden Plant is defined as a minor source and the modification to allow for the production of a new type of product and the addition of the two cooling towers does not constitute a major modification. A major modification would occur if there was an emissions increase equal or greater than 10 tons per year (tpy) of direct PM2.5, 40 tpy of sulfur dioxide, 40 tpy of nitrogen oxides, or 40 tpy of volatile organic compounds (VOC). Therefore, offsets are not required. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 4-1 4. EMISSION CALCULATIONS 4.1 BAGHOUSE EMISSIONS As part of the modification, the U8 Machine Dust Bag filter rack assembly will be moved into Forming Dust Baghouse #1 that is fed by the U1 and U2 machines. The clean air will be exhausted through the same stack that the Forming Baghouse #1 currently exhausts through. The air flow through the relocated U8 Machine Dust Bag filter rack assembly will be a maximum of 12,000 cfm. As such, the clean air exhaust flow rate through the Forming Baghouse #1 stack will increase from 25,000 acfm to 37,000 acfm. Dirty air from both the Forming Baghouse #1 and the relocated U8 Machine Dust Bag filter rack assembly will continue to be exhausted to either Collector Baghouse #5 or #8. There will be no increase in the exhaust flow rate to either Collector Baghouse #5 or #8, which have an existing air flow rate of 25,000 acfm. The addition of the new product is expected to result in increased emissions through the existing Forming Baghouse #1 exhaust stack. Emissions associated with the new product line are anticipated to have the same or less grain loading as is currently exhausted through Forming Baghouses #1, #2, or #4. As such, emissions from the U8 Machine Dust Bag filter rack were calculated based on the current permitted limit for Forming Baghouse #1 of 0.01 grains/dscf and a flow rate of 37,000 acfm. As such, Kimberly-Clark is proposing to keep the existing emission limit of 0.001 gr/dscf for Forming Baghouse #1 outlined in permit condition II.B.3.a. The exhaust flow rate for Forming Baghouse #1 will increase to 37,000 acfm which results in an emission rate of 2.50 lb/hr and 10.95 tpy, which will result in an emission increase of 0.87 lb/hr and 3.81 tpy, as shown in Table 4-2 below. Emissions from existing Collector Baghouses #5 and #8 are not expected to increase. Table 4-1. Forming Baghouse #1 Particulate Matter Emissions Equipment PM10 gr/dscf Exhaust Flow Rate acfm PM10 lb/hr PM10 tpy Existing FBH-1 Stack 0.01 25,000 1.63 7.14 FBH-1 + U8 Machine Baghouse Stack 0.01 37,000 2.50 10.95 Emissions Increase n/a 12,000 0.87 3.81 4.2 COOLING TOWER EMISSIONS Kimberly-Clark is requesting to add two sets of existing, unpermitted cooling towers to the permit, the Baby Care (BC) chiller and compressor cooling towers and the Child Care (CC) chiller and compressor cooling towers. The BC Chiller cooling tower consists of four cells and the BC compressor cooling tower consists of one cell. The CC Chiller cooling tower consists of two cells and the CC compressor cooling tower consists of one cell. Kimberly-Clark provided the circulating water flow and total dissolved solids for each cooling tower component. The BC Chiller cooling towers are currently undergoing an upgrade and will be equipped with drift eliminators capable of achieving a drift loss as low as 0.0005%. The BC compressor cooling tower is equipped with a drift eliminator which achieves a drift loss of 0.005%. The CC Chiller and CC compressor cooling towers are equipped with drift eliminators which achieve 0.001% drift loss. Manufacturer Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 4-2 information for the drift eliminators is located in Appendix C. Emissions calculations from the cooling towers were calculated using a conservative Best Available Control Technology drift loss of 0.005%. PM10 and PM2.5 emissions are estimated based on the particulate size distribution interpolated from data.1 The total estimated increase in emissions from the cooling towers is shown in Table 4-4. Table 4-2. Cooling Tower Emissions Equipment PM10 Emissions (lb/hr) PM10 Emissions (tpy) PM2.5 Emissions (lb/hr) PM2.5 Emissions (tpy) BC Chiller, Cell 1 0.03 0.12 1.17E-04 5.15E-04 BC Chiller, Cell 2 0.03 0.12 1.17E-04 5.15E-04 BC Chiller, Cell 3 0.03 0.12 1.17E-04 5.15E-04 BC Chiller, Cell 4 0.03 0.12 1.17E-04 5.15E-04 BC Compressor 0.01 0.04 3.56E-05 1.56E-04 CC Chiller, CT1 0.07 0.29 2.80E-04 1.23E-03 CC Chiller, CT2 0.07 0.29 2.80E-04 1.23E-03 CC Compressor 0.01 0.05 5.18E-05 2.27E-04 1 Calculating Realistic PM10 Emissions from Cooling Towers by Joel Reisman and Gordon Frisbie, 2002. Detailed derivation of PM10/PM2.5 fractions are discussed in Table B-7. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 5-3 5. BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS 5.1 INTRODUCTION Utah regulation R307-401-5(2)(d) requires that Best Available Control Technology (BACT) be applied to all regulated air pollutants emitted from a Plant. A BACT determination is made on a case-by-case basis, with consideration given to technological practicability and economic reasonableness. In all cases BACT must establish emission limitations or specific design characteristics at least as stringent as applicable New Source Performance Standards. This section includes a BACT analysis for the U8 Machine Baghouse and the BC and CC cooling towers. The BACT analysis for PM10/PM2.5 for the proposed changes is presented in the subsequent sections. BACT determinations are summarized in Table 5-1. Table 5-1. Summary of BACT Determinations Source Pollutant Control Technology U8 Machine Dust Baghouse PM10/PM2.5 Baghouse Control, Good Operating Practices BC Cooling Towers PM10/PM2.5 Drift Loss of 0.005% CC Cooling Towers PM10/PM2.5 Drift Loss of 0.005% 5.2 BACT ANALYSIS FOR U8 Machine Dust Baghouse Trimming and other associated processing steps produce particulate. Kimberly-Clark proposes to control this particulate through a baghouse system. Alternative control configurations are discussed in this analysis to demonstrate this approach meets the intent of BACT. 5.2.1 Identify All Control Technologies Based on the review of RBLC database, SJVAPCD guidelines, TCEQ established BACT, and similar operations, Kimberly-Clark has identified the following control technologies that would be applicable for controlling particulate emissions from the proposed source. • Fabric Filter (Dust Collector) • Wet Electrostatic Precipitator (ESP) • Wet Scrubber • Cyclone 5.2.2 Eliminate Technically Infeasible Options Baghouse Baghouses remove particulates by collecting particulates on the filter bag as the exhaust stream passes through the baghouse. Baghouses typically cannot withstand high exhaust temperatures (greater than 500 °F). Fabric filter technology is a well-established particulate control technology that has historically been established as BACT. Baghouses have been shown to obtain a particulate collection efficiency up to 99.5% for PM10, and up to 99% capture for PM2.5. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 5-4 Kimberly-Clark is proposing to use an existing unused baghouse, the U8 Machine Dust Baghouse to capture particulate from the new SAM application fans. The air stream from these fans is mostly clean and is therefore anticipated to have the same or less grain loading than the existing Forming Baghouse #1, #2 and #4, which have a permitted grain loading of 0.01 gr/dscf. Wet ESP As part of this analysis, the possibility of using a Wet Electrostatic Precipitator (ESP) was reviewed. Wet ESP technology removes particulates by electrically charging the particles and collecting the charged particles on plates. The collected particulate is washed off the plates and collected in hoppers at the bottom of the ESP. High efficiency ESPs have been shown to achieve control of particulates up to 99.5% for PM10, and up to 95% capture for PM2.5. The Ogden Plant anticipates systematic failure of an ESP due to the presence of small consumer fiber filaments from the absorbency materials. Specifically, the very fine fibers in the process gas stream would likely adhere to the plates on the ESP. Based on this technical infeasibility, the Ogden Plant is not considering this control technology for this application. Additionally, the selected fabric filter technology provides similar control efficiency as the ESP for the anticipated particle size distribution contained in the gas stream. Wet Scrubber Wet gas scrubber (WGS) technology was also evaluated for us as a particulate control technology for the proposed gas stream. A WGS reduces particulate emissions by mixing flue gas with scrubber liquid to remove particulate. The purge stream containing the collected particulate exits the bottom of the WGS to be further treated as wastewater. High efficiency wet scrubbers have been shown to achieve 99% capture for PM10, but only up to 90% capture for PM2.5. This type of control is infeasible because the super absorbent material would react with the water and adhere to all surfaces causing rapid plugging of the system. Cyclone Cyclones use centrifugal force and inertia to remove particles from a gas stream. The inertia of the particles resists the change in direction of the gas, and they move outward under the influence of centrifugal force until they strike the walls of the cyclone. At this point, the particles are caught in a thin laminar layer of air next to the cyclone wall and are carried downward by gravity where they are collected in hoppers. Cyclones are capable of removing in excess of 90 percent of the larger diameter (> 30 μm) PM. However, their efficiency decreases with smaller particles. 5.2.3 Rank Remaining Control Technologies by Control Effectiveness Technically feasible technologies are baghouse and cyclone. Based on established control efficiencies high efficacy filtration systems, such as baghouses, are considered the most effective control technologies. The U8 Machine Dust Collector will operate consistent with the existing Forming Baghouse #1, #2, and #4 and will exhaust through the same stack as existing Forming Baghouse #1. 5.2.4 Evaluate Most Effective Controls and Document Results Because the highest ranked controls have been applied as BACT for this gas stream, no detailed economic, energy, and environmental impact evaluations were conducted. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 5-5 5.2.5 Select BACT The selected BACT for PM10 and PM2.5 emissions from the proposed processes is the use of a baghouse. This technology has been established as the most effective, and published BACT guidance widely accepts this technology for the control of particulate emissions from this type of process. 5.3 BACT ANALYSIS FOR COOLING TOWERS The Ogden Plant has two sets of existing, unpermitted cooling towers (BC Chiller and compressor cooling towers and CC Chiller and compressor cooling towers) which were constructed in the mid-1980’s. Some of the liquid water passing through the cooling tower may be entrained in the air stream and be carried out of the tower as "drift" droplets. Therefore, cooling towers can be sources of particulate emissions due to the particulate matter constituent of the drift droplets. Based on the review of RBLC database, control technology employed to reduce PM emissions from cooling towers is drift eliminators with a drift loss of 0.005%. The BC Chiller cooling towers are currently undergoing an upgrade and will be retrofitted with drift eliminators from Evaptech. Information provided by Evaptech for the BC Chiller drift eliminators indicates drift loss as low as 0.0005%. The BC compressor cooling towers and CC Chiller and compressor cooling towers currently have drift eliminators installed. Information from BAC for the BC Compressor cooling tower drift eliminators indicates a drift loss of 0.005%. Information from Evapco for the CC Chiller and CC Compressor drift eliminators indicates a drift loss of 0.001%. The drift rates for all drift eliminators at the Ogden Plant are at or below the BACT drift loss rate of 0.005%, therefore BACT for the cooling towers is already employed, and no further analysis is required. 5.4 BACT Conclusion Kimberly-Clark proposes that BACT for the new SAM application fans particulate is the routing of emissions through the U8 Machine Dust Baghouse and existing Forming Baghouse #1 exhaust stack. Kimberly-Clark proposes that BACT for emissions of PM from the cooling towers is drift eliminators. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 6-6 6. FEDERAL/STATE APPLICABLE REQUIREMENTS A review of federal and state air quality regulations is provided in Table 6-1. Each regulation is described in the following sections. Table 6-1. Federal and State Regulatory Requirements Federal Regulations Regulatory Citation Applicable 6.1 National Ambient Air Quality Standards (NAAQS)- (dispersion modeling) 40 CFR Part 50 No 6.2 Title V Operating Permit 40 CFR Part 70 No 6.3 New Source Review (NSR) 40 CFR Part 52 Yes 6.4 New Source Performance Standards (NSPS) 40 CFR Part 60 No 6.5 Air Pollutants (NESHAPs) 40 CFR Parts 61, 63 No 6.6 Acid Rain Requirements 40 CFR Parts 72–78 No 6.7 State Rules 6.7.1 General Requirements - Breakdowns UAC [R307-107] Yes 6.7.2 Emission Inventories UAC [R307-150] Yes 6.7.3 Solvent Cleaning UAC [R307-304] Yes 6.7.4 Nonattainment and Maintenance Areas UAC [R307-324] Yes 6.7.5 Adhesives and Sealants UAC [307-342] Yes 6.7.6 Permit Requirements for New and Modified Sources UAC [R307-401] Yes 6.7.7 Permit Requirements for New and Modified Sources in Nonattainment Areas and Maintenance Areas UAC [R307-403] No 6.1 NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) Primary National Ambient Air Quality Standards (NAAQS) are identified in 40 CFR Part 50 and define levels of air quality, which the United States Environmental Protection Agency (USEPA) deems necessary to protect the public health. Secondary NAAQS define levels of air quality which the USEPA judges necessary to protect public welfare from any known or anticipated adverse effects of a pollutant. Examples of public welfare include protecting wildlife, buildings, national monuments, vegetation, visibility, and property values from degradation due to excessive emissions of criteria pollutants. Specific standards for the following pollutants have been promulgated by USEPA: PM10, SO2, NOX, CO, ozone, lead, and PM2.5. The Ogden Plant emits PM10, PM2.5, SO2, NOX, CO, and VOCs, a precursor to ozone. The emissions increase from the project does not exceed any of the UDAQ modeling thresholds, therefore, modeling is not required. 6.2 TITLE V (PART 70) OPERATING PERMIT Title V of the Clean Air Act (CAA) created the federal operating permit program. These permitting requirements are codified in 40 CFR Part 70. These permits are required for major sources with a Potential to Emit (PTE) (considering federally enforceable limitations) greater than 100 tpy for any criteria pollutant, 25 tpy for all hazardous air pollutants (HAPs) in aggregate, or 10 tpy of any single HAP. The Ogden Plant is considered a minor source because the PTE of each criteria pollutant is less than 100 tons per year, and the HAPs thresholds are also not exceeded. Greenhouse gas emissions are also estimated to be less than 100,000 tons per year CO2e. Therefore, a Title V Operating permit is not needed for the Kimberly-Clark Ogden Plant. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 6-7 6.3 NEW SOURCE REVIEW (NSR) REQUIREMENTS The Ogden Plant is located in Weber County which is designated as a non-attainment area for PM2.5. The Plant is located within the Wasatch Front ozone non-attainment area. According to Utah Administrative Rule R307-403-5, offsets are required for new major sources or major modifications to existing sources which are located in or would impact a PM2.5 nonattainment area. The Ogden Plant is a minor source, and the project does not constitute a major modification, therefore, the Plant will not be required to obtain offsets. The prevention of significant deterioration (PSD) regulations codified in 40 CFR Part 52 could potentially apply to the Plant. The PSD rule applies to: (1) a new major source that has the potential to emit 100 tons per year or more for any criteria pollutant for a Plant that is one of the 28 industrial source categories listed in 40 CFR § 52.21(b)(1)(i)(a); or (2) a new major source that has the potential to emit 250 tons per year or more if the Plant is not on the list of industrial source categories; or (3) a modification to an existing major source that results in a net emission increase greater than a PSD significant emission rate as specified in 40 CFR § 52.21 (b)(23)(i); or (4) a modification to an existing minor source that is major in itself. The permitting action does not trigger any PSD actions since the Plant is not a listed source and the potential to emit is less than 250 tons per year. 6.4 NEW SOURCE PERFORMANCE STANDARDS (NSPS) New Source Performance Standards (NSPS) in 40 CFR Part 60 are applicable to new, modified, or reconstructed stationary sources that meet or exceed specified applicability thresholds. No standards are applicable to the new equipment at the Ogden Plant. 6.5 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) NESHAPs have been established in 40 CFR 61 and 63 to control the emissions of Hazardous Air Pollutants (HAPs). The first NESHAP regulations were developed under the auspices of the original CAA. These standards are codified in 40 CFR Part 61, and address a limited number of pollutants and industries. 40 CFR Part 61 regulations do not apply to this Plant. NESHAP regulations codified in 40 CFR 63 establish Maximum Achievable Control Technology (MACT) standards for specific types of equipment at qualifying facilities. MACT regulations typically apply to facilities that are major sources. Under 40 CFR 63, a major source is defined in 40 CFR 63.2 as: “…any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any HAP or 25 tons per year or more of any combination of HAP…” The Ogden Plant’s PTE of HAP is below the 10 tpy and 25 tpy thresholds. Therefore, it is an area source with regard to NESHAP applicability. No NESHAP standards are applicable to the new equipment at the Ogden Plant. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 6-8 6.6 ACID RAIN REQUIREMENTS The acid rain requirements codified in 40 CFR Parts 72-78 apply to utilities and other facilities that combust fossil fuel and generate electricity for wholesale or retail sale. Phase II of the Title IV Acid Rain Program applies to all new generator units constructed after 2000 with a nameplate capacity greater than 25MW. The new equipment at the Ogden Plant does not generate electricity and therefore is not subject to these requirements. 6.7 STATE REGULATORY APPLICABILITY The Utah Division of Administrative Rules (DAR) promulgates several emissions regulations that apply to the Ogden Plant in addition to those listed above. 6.7.1 General Requirements-Breakdowns UAC R307-107 indicates the applicable general requirements for breakdown events. Breakdowns will be reported within 24 hours of an incident with a written description of the event. Kimberly-Clark will comply with the procedures and requirements outlined in R307-107 and submit the necessary information and reports to UDAQ related to excess emissions due to startup, shutdown, scheduled maintenance, safety measures, upsets and breakdowns. 6.7.2 Emission Inventories UAC R307-150 establishes requirements for emission inventory submittals. Kimberly-Clark will comply with this rule where appropriate. 6.7.3 Solvent Cleaning UAC R307-304 establishes general requirements for limiting volatile organic compound (VOC) emissions from solvent cleaning operations for sources located in within Box Elder, Cache, Davis, Salt Lake, Tooele, Utah or Weber counties. The regulation applies to owners and operators who use more than 55 gallons per year of VOC containing solvent products. Kimberly-Clark uses IPA for cleaning production machines, but there is no change to the solvent usage at the Ogden Plant associated with this NOI. 6.7.4 Nonattainment and Maintenance Areas UAC R307-325 establishes general requirements for all sources located in any nonattainment or maintenance area for ozone. No person shall allow or cause volatile organic compounds (VOCs) to be spilled, discarded, stored in open containers, or handled in any other manner that would result in greater evaporation of VOCs than would have if reasonably available control technology (RACT) had been applied. Kimberly-Clark will comply with this rule where appropriate. 6.7.5 Adhesives and Sealants UAC R307-342 establishes VOC limits for any Plant that manufactures, sells, supplies, or applies adhesive, sealant, adhesive primer, or sealant primer in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah, or Weber counties manufactured on or after September 1, 2014. The Ogden Plant is located in Weber County and applies adhesive during the manufacturing process and is therefore subject to the requirements of R307- 342-5(3). The VOC limit applicable to the Plant falls under other adhesives, which cannot exceed 420 g VOC/liter (3.505 lb/gal). Kimberly-Clark will comply with these standards. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 6-9 UAC R 307-342-6 established the allowed equipment to apply and remove adhesives and sealants. The Ogden Plant applies the adhesive with high-volume, low-pressure spray equipment operated in accordance with the manufacturer’s specifications. Removal of adhesive is performed using solvents with a composite vapor pressure less than or equal to 9.5 mm Hg at 20 degrees Celsius, complying with R307-342-6 (2)(c). The Plant also keeps all solvent containers closed except when adding parts to or removing parts from the container. 6.7.6 Permit: New and Modified Sources UAC R307-401 establishes the permitting requirements for any new or modified sources. Kimberly-Clark will comply with any permitting requirements as defined in the rule and that applies to the Approval Order. 6.7.7 Permit Requirements for New and Modified Sources in Nonattainment Areas and Maintenance Areas UAC R307-403 establishes the permitting requirements for any new or modified sources in nonattainment areas for major sources as required by 40 CFR 51.165 and provides provisions for some non-major sources in PM10 nonattainment areas. Kimberly-Clark will comply with any permitting requirements as defined in the rule and that applies to the Approval Order. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants 7-1 7. EMISSION IMPACT ANALYSIS The Ogden Plant is located in Weber County which is designated as a non-attainment area for PM2.5. The Plant is also in the Wasatch Front ozone non-attainment area. The UDAQ has established minimum emission rate increase levels for new sources or modified sources located in attainment areas, above which modeling is required to be performed as part of a complete NOI. The UDAQ currently does not require sources to perform dispersion modeling for pollutants that are not in attainment of the NAAQS, if that source is located in an area that is non-attainment for that pollutant. This would apply to PM2.5 for the Ogden Plant. 7.1 HAZARDOUS AIR POLLUTANTS The UAC R307-410-5 requires sources to compare proposed HAP emission increases to the emissions threshold value (ETV). If the maximum hourly HAP emissions exceed the ETV, the HAP emissions must be modeled. There will be no increase to HAP emissions due to this modification. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants A-1 APPENDIX A. PROCESS INFORMATION FORMS AND DATA SHEETS Utah Division of Air Quality New Source Review Section Company _______________________ Site/Source _____________________ Form 10 Date __________________________ Fabric Filters (Baghouses) Baghouse Description 1. Briefly describe the process controlled by this baghouse: Gas Stream Characteristics 2. Flow Rate (acfm):4. Particulate Loading (grain/scf) Design Max Average Expected 3. Water Vapor Content of Effluent Stream (lb. water/lb. dry air) Inlet Outlet 5. Pressure Drop (inches H2O) High ___7"_____ Low ___2"_____ 6.Gas Stream Temperature (°F):7. Fan Requirements (hp) (ft 3/min) Equipment Information and Filter Characteristics 8. Manufacturer and Model Number: 10. Bag Diameter (in.) 11. Bag Length (ft.)12. Number of Bags:13. Stack Height _____43______ feet Stack Inside Diameter _____36____ inches 9.Bag Material: □Nomex nylon □X Polyester □Acrylics □Fiber glass □Cotton □Teflon □___________ 14.Filtering Efficiency Rating: _99___% 15.Air to Cloth Ratio: __11.6 : 1 16. Hours of Operation: Max Per day ___24__ Max Per year 8760___ 17.Cleaning Mechanism: □Reverse Air □ Shaker □X Pulse Jet □ Other: ______________________ Emissions Calculations (PTE) 18. Calculated emissions for this device PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate) Submit calculations as an appendix. Page 1 of 2 Kimberly-Clark Corporation Ogden Facility 8/1/24 SAM Application Fans 12,000 acfm 0.01 2.5 10.95 2.5 10.95 75 F 71.7 hp @ 12,000 acfm Menardi Filter Elements, P/N: 97806368 24.5"242"8 1% 1.0 Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants B-1 APPENDIX B. PLANT PLOT PLAN o U8 M/icHine. Oust DISTRIBUTION OFFICES FINISHED PRODUCT WAREHOUSE NORTH lJU'1 PARTSSTORAGE SHED FINISHED PRODUCT WAREHOUSE SOUTH I. Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants C-1 APPENDIX C. MANUFACTURER DATA 1.0 SCOPE - Supply Four (4) Model. PL-4-450-40A counterflow cooling tower. 2.0 .APPLICABLE SPECIFICATIONS AND DRAWINGS 11 A. General Arrangement: Drawing No. PL-17 3-S1 B. Support Design Loads: Drawing No. PL-173-S2 3.0 DESIGN CONDITIONS A. Outside tower dimensions L x W (Ft.) 361 -1" x 491-1 1/2" B.No.of Towers Four (4) C.Total GPM required 6300 D.GPM per tower 1 575 E.HWT 96.4 °F .......F" 57. °F F.CWT 85 . °F 52 °F G.WBT 67 °F 46 °F ' H.Evaporation Loss at Design 1% Design Flow I. Drift Loss .02% Design Flow J. Tower Pumping Head (Ft.), 11 Ft. NOTE: Tower Pump Head represents static pressure and friction loss from the top of basin lip to centerline of the distribution piping plus normal nozzle operating pressure. It is the responsibility of Others to calculate required pumping head for piping system to cooling tower. / /f &A &~( 5ECT,ON revision CERAMIC COOLING TOWER COMPANY jobnoPL~173 7 /9A /Qzl Q subsidiary Justin Industries, Inc. o >7 DATE FORT WORTH, TEXAS PAGe J OF ' From:Thompson, Kevin B To:Shannon Manoulian; Jones, Mike D; Melissa Armer Cc:Thorne, Kevin; Scharff, Andrew Z Subject:RE: P&E Proposal: BC Cooling Tower Rebuild Phase 1 Date:Thursday, July 25, 2024 7:53:56 AM Attachments:image001.jpg And here is the response from BAC on our new BC compressor cooling tower: And this tower does have drift eliminators. "BAC offers very low levels that are typical for crossflow and counterflow designs. The standard drift rate for crossflow cooling towers is 0.005%. Kevin B.Thompson KC Ogden Technical Services (801) 786-2435 K-C Internal Only Mechanical Specifications Customer: Project: Purchase Order No: Engineer: BAG Order # V O BROTHERS Kimberly Clark BCO_KCC_22393_92322 Mike DallonU222248803 All Information is per Unit Quantity: 1 Model FXV-1212C-36T-P CLOSED CIRCUIT COOLING TOWER CTI Certification: The thermal performance of this BAG unit has been certified through performance tests conducted by the Cooling Technology Institute in accordance with their standard STD-201 RS. Your equipment may be selected for factory-testing to verify CTI certified performance. Such certification by an independent third party assures engineers and users that the published thermal capacities accurately reflect the actual unit performance. CTI certification eliminates the additional costs of on-site, individual unit testing, oversizing the equipment or operating cost penalties from deficient equipment. > Materials of Construction: All structural steel components are constructed from G-235 (Z700 metric) hot-dip galvanized steel protected by a thermosetting hybrid polymer. The distribution system is constructed of Schedule 40 PVC. Polypropylene metering orifices are provided to assure even distribution of water over the coil surface. The thermosetting hybrid polymer applied by Baltimore Aircoil Company consists of: 1) G-235 (Z700 metric) hot-dip galvanized steel components 2) parts prepared in a four-step (clean, pretreat, rinse, dry) process 3) electrostatically sprayed thermosetting hybrid polymer, fuse bonded to the hot-dip galvanized substrate during a thermally activated curing stage 4) quality assurance inspection program including 23 steps throughout polymer application and unit fabrication. The cold water basin includes a depressed section with drain/clean-out connection and the area under the fill sections is sloped toward the depressed section for easy cleaning. The cold water basin shall be protected with the TriArmor® Corrosion Protection System. This system consists of: 1) G-235 (Z700 metric) hot-dip galvanized steel components 2) electrostatically sprayed thermosetting hybrid polymer, fuse bonded to the hot-dip galvanized substrate during a thermally activated curing stage 3) Polyurethane system creating an air and watertight armor. The air inlet louvers are constructed of PVC honeycomb shape louver which also act as an air inlet screen and block sunlight to the basin and the front of the fill. Fan Type: The unit is provided with the standard fan to maximize the capacity. The fan is driven by the BALTIDRIVE Power Train. This drive system consists of cast aluminum sheaves located on minimum shaft centerline distances. A premium efficient fan motor provides maximum performance and is backed by BAC's comprehensive 5-year motor and fan drive warranty. Fan Guard(s): A heavy gauge, G-235 (Z700 metric) hot-dip galvanized steel wire fan guard is provided over each fan cylinder. Fill: The BACross® Fill and integral drift eliminators are formed from self-extinguishing (per ASTM D-568) polyvinyl chloride (PVC), having a flame spread rating of 5 per ASTM Standard E84-77a, and are impervious to rot, decay, and fungus or biological attack. The fill is elevated above the cold water basin floor to facilitate cleaning. This fill is suitable for a maximum entering water temperature of 130°F (54.44°C). The eliminators are designed to effectively strip entrained moisture from the leaving airstream with a minimum of air resistance. Coil Type: I The coil is suitable for cooling fluids compatible with carbon steel in a closed system. The coil(s) will be constructed with continuous 1.05" O.D. all prime surface steel tubes continuously formed and bent in a serpentine shape, encased in steel framework. The entire assembly is hot-dip galvanized after fabrication. Coil will be designed for free liquid drainage. Coil has a maximum allowable working pressure of 300 psig (2170 l<Pa) and is tested at 375 psig (2585 kPa) air pressure under water. The system should have a vent placed at the highest point in the installation to facilitate filling and drainage (provided and installed by others). Corporate Headquarters: 7600 Dorsey Run Road, Jessup, MD 20794 - Tele: (410) 799-6200 / Fax: (410) 799-6416 version: Baltimore Aircoil Company Closed Circuit Product Selection Report 7.8.11 NAAugust 09, 2022 Thermal performance at design conditions and total standard fan motor power is certified by the Cooling Technology Institute (CTI). Product data correct as of: Project Name: Selection Name: Project State/Province:Maryland Project Country:United States Date:September 29, 2022 Model Information Design Conditions Product Line:FXV Fluid:Water Model:FXV-1212C-36T-P Flow Rate:580.00 USGPM Number of Units:1 Entering Fluid Temp.:105.0Q°F Wet Coil Type:Standard Coil Leaving Fluid Temp.:80.00 °l= Coil Finning:None Wet Bulb Temp.:67.00 °F Fan Type:Standard Fan Fan Motor:(1)40.00 = 40.00 HP/Unit Total Standard Fan Power:Full Speed, 40.00 BHP/Unit Heat Rejection:7,247,100 BTUH Total Pump Motor Power:(1)7.50 = 7.50 HP/Unit Fluid Pressure Drop:4.22 psi Intake Option:None Reserve Capability at 40.00 HP:5.93% Internal or Const. Option:None Discharge Option:None Engineering Data, per Unit Unit Length: 12’ 00.00" + 01' 06.00" (Pump) =13' 06.00"(Total) Unit Width:IT 10.00" Unit Height:19' 05.50" Approximate Shipping Weight:18,294 lbs Heaviest Section:13,577 lbs Approximate Operating Weight:29,111 lbs Approximate Remote Sump Operating Weight: 25,840 lbs Air Flow:110,390 CFM Spray Water Flow:859 USGPM Coil Volume:432 U.S. gallons Coil Connections: (1) 6” Coil Inlet and Outlet, Based on 580.00 USGPM Flow per Unit Remote Sump Connections:(1) 10" Heater kW Data (Optional) 0°F (-17.8°C) Ambient Heaters:(1)12 kW -20°F (-28.9°C) Ambient Heaters:(1)16 kW Minimum Distance Required: From Solid Wall:7.5 ft. From 50% Open Wall:5.5 ft. Energy Rating: 28.32 USGPM/HP perASHRAE 90.1, ASHRAE 189 and CA Title 24. Note: These unit weights and dimensions account for the selected fan type for the standard cataloged drive configuration, but they do not account for other options/accessories. Please contact your local BAG sales representative for, weights and dimensions of units with other options/accessories. ' Page 1/3 From:Thompson, Kevin B To:Shannon Manoulian; Jones, Mike D; Melissa Armer Cc:Thorne, Kevin; Scharff, Andrew Z Subject:RE: P&E Proposal: BC Cooling Tower Rebuild Phase 1 Date:Monday, July 22, 2024 10:45:02 AM Attachments:image001.jpg I have contacted Evapco on our Child Care Cooling towers and they forwarded this from the data sheet on these towers: Drift Eliminators : “Drift eliminators shall be constructed entirely of Polyvinyl Chloride (PVC) in easily handled sections. Design shall incorporate three changes in air direction and limit the water carryover to a maximum of 0.001% of the recirculating water rate.” Kevin B.Thompson KC Ogden Technical Services (801) 786-2435 K-C Internal Only DriAir 80TM Drift Eliminators remove carry-over water droplets from today’s counterflow and crossflow cooling towers. Better air quality is a snap with these high performance drift eliminators. Technology for the Future, Available Today DriAir 80 Drift Eliminator 8331 Nieman Road | Lenexa, KS 66214 | 913.322.5165 | marketing@evaptech.com | www.evaptech.com Technology for the Future, Available Today 8331 Nieman Road | Lenexa, KS 66214 | 913.322.5165 | marketing@evaptech.com | www.evaptech.com DriAir 80 Eliminator Features: n Pack Construction – Eliminator packs are made from thermoformed PVC sheets that are UV inhibited. The wave shape of the packs strip water droplets from the exit airflow. n Low Drift Rate – DriAir 80 eliminators can achieve guaranteed drift rates as low as 0.0005% of water flow rate. n Custom Lengths – DriAir 80 eliminators use various PVC sheet thicknesses to achieve pack span requirements. n Perimeter Air Seals – Specially designed air seals are used with DriAir 80 eliminator packs to prevent any drift bypass at penetrations and the perimeter of the cooling tower. n Crossflow Packs – DriAir XF eliminator packs are used with crossflow towers. A special exit feature turns air directly to the fan for optimum performance. Molded drain boards send water back into the cooling tower. DriAir 80 Eliminator Benefits: n Clean Environment – Replace your old worn- out drift eliminators and prevent spread of biological and chemical contamination around the cooling tower. n Less Water Spotting – Prevent constant water spotting on vehicles and infrastructure near the cooling tower. n Help With Permits – Achieve discharge permit requirements with DriAir 80 drift eliminators. n Stop Ice Buildup – Improve cold weather working conditions on top of and around the cooling tower. Reduce ice buildup for a safer environment. From:Melissa Armer To:Shannon Manoulian Subject:Fwd: P&E Proposal: BC Cooling Tower Rebuild Phase 1 - Kimberly-Clartk Date:Wednesday, July 3, 2024 4:35:21 PM Attachments:image002.png image003.jpg KC- Ogden Melissa Armer, P.E. Managing Consultant Trinity Consultants, Inc. P: 208.472.8837 M: 208.870.3215 New Address: 405 S. 8th St. Ste 331, Boise, ID 83702 Email: marmer@trinityconsultants.com Begin forwarded message: From: "Thorne, Kevin" <kevin.thorne@chemtreat.com>Date: July 3, 2024 at 3:27:12 PM MDTTo: "Thompson, Kevin B" <kbthomps@kcc.com>Cc: "Jones, Mike D" <mdjones@kcc.com>, Melissa Armer<marmer@trinityconsultants.com>Subject: RE: P&E Proposal: BC Cooling Tower Rebuild Phase 1 - Kimberly-Clartk  Babycare Chiller CT1 750-850 TDS BabyCare Compressor CT2 600-700 TDS ChildCare Chiller CT 1/2 750-850 TDS ChildCare Compressor CT3 750-850 TDS Kevin Thorne Account Manager (mobile) 801-608-7348 kevin.thorne@chemtreat.com www.chemtreat.com Kimberly-Clark Corporation / Notice of Intent – Modification for New Product Trinity Consultants D-1 APPENDIX D. EMISSIONS CALCULATIONS Table 1. Summary of the Project Emissions Increase PM 5.2 15 PM10 5.0 15 PM2.5 3.8 10 SO2 N/A 40 NOX N/A 40 VOC N/A 40 CO N/A 100 HAPs N/A NA Pollutant Total Emission Increase (tpy) 1 Significant Emissions Increase Threshold (tpy) 1. Emissions increase is equal to the PTE for Forming Baghouse #1 after the U8 machine baghouse increase minus the permitted PTE for Forming Baghouse #1 KCC Ogden NOI_U8 SAM emissions_v1.0 Table 2. U8 Machine Baghouse Potential To Emit (PTE) Emissions Grain Loading1 Flow Rate Flow Rate2 (gr/dscf)(acfm)(dscfm) (lb/hr) (ton/yr) FBH-1 U8 Machine BH 0.010 37,000 29,165 2.50 10.95 1 Baghouse grain loading of 0.01 based on permitted grain loading for Forming Baghouses #1, #2, and #4. 2 dscfm = acfm x (460 R + 68 F)/(460 R + temp in F) x (actual P/ 14.7 psi) x (1- volumetric fraction of water vapor); Temp = 105 oF; Press. = 12.52443 psi; Moisture = 1% (0.01). 3 Annual emission rate based on 8,760 hours of operation Table 3. U8 Machine Baghouse Potential to Emit (PTE) Emissions Grain Loading1 Flow Rate Flow Rate2 (gr/dscf)(acfm)(dscfm) (lb/hr) (ton/yr) FBH-1 U8 Machine BH 0.0005 37,000 29,165 0.12 0.55 1 Baghouse grain loading of 0.0005 gr/dscf based on maximum value measured from June 2019 stack test on Forming Baghouses #1, #2, and #4. 2 dscfm = acfm x (460 R + 68 F)/(460 R + temp in F) x (actual P/ 14.7 psi) x (1- volumetric fraction of water vapor); Temp = 105 oF; Press. = 12.52443 psi; Moisture = 1% (0.01). 3 Annual emission rate based on 8,760 hours of operation Source Description Associated Equipment PM10/PM2.5 Emission Rate3 Source Description Associated Equipment PM10/PM2.5 Emission Rate3 KCC Ogden NOI_U8 SAM emissions_v1.0 Table 4. Cooling Tower Potential Emissions Circulating Water Flow1 Total Dissolved Solids1 Drift Loss2 Drift Mass Flow Rate3 (gpm) (mg/L) (%) (gal/hr) (lb/hr) (tpy) (lb/hr) (tpy) (lb/hr) (tpy) BC Chiller, Cell 1 1575 850 0.005% 5 0.03 0.15 0.03 0.12 1.17E-04 5.15E-04 BC Chiller, Cell 2 1575 850 0.005% 5 0.03 0.15 0.03 0.12 1.17E-04 5.15E-04 BC Chiller, Cell 3 1575 850 0.005% 5 0.03 0.15 0.03 0.12 1.17E-04 5.15E-04 BC Chiller, Cell 4 1575 850 0.005% 5 0.03 0.15 0.03 0.12 1.17E-04 5.15E-04 BC Compressor 580 700 0.005% 2 0.01 0.04 0.01 0.04 3.56E-05 1.56E-04CC Chiller, CT1 3750 850 0.005% 11 0.08 0.35 0.07 0.29 2.80E-04 1.23E-03CC Chiller, CT2 3750 850 0.005% 11 0.08 0.35 0.07 0.29 2.80E-04 1.23E-03CC Compressor 694 850 0.005% 2 0.01 0.06 0.01 0.05 5.18E-05 2.27E-04 1 Circulating water flow provided by Kevin Thompson (KCC) on 4/9/24. TDS provided by Kevin Thorne (ChemTreat) on 7/3/24. 2 3 Drift mass flow rate (gal/hr) = Cooling tower capacity (gpm) × 60 min/hour × Drift loss (%). 4 Hourly PM emission rate (lb/hr) = Drift mass flow rate (gal/hr) × TDS (mg/L) × 3.78541 (L/gal) × 2.2045E-06 (lb/mg) 5 Annual PM emission rate (ton/yr) = Hourly emission rate (lb/hr) × 8,760 (hours/yr)/2,000 (lb/ton). 6 Emission Source Filterable PM Emissions4,5 Total PM10 Emissions6 Total PM2.5 Emissions6 PM10 and PM2.5 emissions are estimated based on the particulate size distribution below, interpolated from data in Calculating Realistic PM10 Emissions from Cooling Towers by Joel Reisman and Gordon Frisbie, 2002. Detailed derivation of PM10/PM2.5 fractions are discussed in Table B-7. Conservatively use proposed BACT limit of 0.005%. Information provided by Evaptech for the BC Chiller drift eliminators indicates drift loss as low as 0.0005%. Information from BAC for the BC Compressor cooling tower drift eliminators indicates a drift loss of 0.005%. Information from Evapco for the CC Chiller and CC Compressor drift eliminators indicates a drift loss of 0.001%. Trinity Consultants 1 of 2 KCC Ogden NOI_U8 SAM emissions_v1.0 Cooling Tower Table 5. Derivation of PM10/PM2.5 Fraction1 Drift Droplet Diameter (Dd) Drift Droplet Volume2 (Vdroplet) Drift Droplet Mass3 (Mdroplet) Droplet Particle Mass4 (MTDS) Solid Particle Diameter5 (DTDS) EPRI Cumulativ e % Mass Smaller6 Interpolatio n Value for PM2.57 Interpolatio n Value for PM107 (µm) (µm 3)(µg)(µg) (µm) (%) (%) (%) 0 0.00E+00 0.00E+00 0.00E+00 0.000 0 -- --10 5.24E+02 5.24E-04 4.45E-07 0.728 0 -- --20 4.19E+03 4.19E-03 3.56E-06 1.457 0.196 -- --30 1.41E+04 1.41E-02 1.20E-05 2.185 0.226 -- --40 3.35E+04 3.35E-02 2.85E-05 2.913 0.514 0.351 --50 6.54E+04 6.54E-02 5.56E-05 3.642 1.816 -- --60 1.13E+05 1.13E-01 9.61E-05 4.370 5.702 -- -- 70 1.80E+05 1.80E-01 1.53E-04 5.098 21.348 -- -- 90 3.82E+05 3.82E-01 3.24E-04 6.555 49.812 -- -- 110 6.97E+05 6.97E-01 5.92E-04 8.012 70.509 -- -- 130 1.15E+06 1.15E+00 9.78E-04 9.468 82.023 -- -- 150 1.77E+06 1.77E+00 1.50E-03 10.925 88.012 -- 84.209 180 3.05E+06 3.05E+00 2.60E-03 13.110 91.032 -- --210 4.85E+06 4.85E+00 4.12E-03 15.295 92.468 -- --240 7.24E+06 7.24E+00 6.15E-03 17.480 94.091 -- --300 1.41E+07 1.41E+01 1.20E-02 21.850 96.288 -- --350 2.24E+07 2.24E+01 1.91E-02 25.492 97.011 -- --400 3.35E+07 3.35E+01 2.85E-02 29.133 98.34 -- --450 4.77E+07 4.77E+01 4.06E-02 32.775 99.071 -- -- 600 1.13E+08 1.13E+02 9.61E-02 43.700 100 -- -- 1 2 Vdroplet = 4/3 π (Dd /2)3 [Equation 2 of the Document] 3 Mdroplet = density (ρw) of water * Vdroplet = ρw * 4/3 π (Dd /2)3 ρw =1.00E-06 μg/μm3 4 MTDS = TDS * Mdroplet [Equation 3 of the Document, with TDS in units of ppm] TDS =850 mg/L Total Dissolved Solids Per Table B-6 TDS =850 ppm 5 MTDS = (ρTDS) (VTDS) = (ρTDS) (4/3)π (DTDS /2)3 [Equation 5 of the Document] Therefore, the equation can be solved for DTDS:DTDS = {MTDS/[(ρTDS)* 4/3 * π]}1/3 × 2 Assume solid particulates have the same density (ρTDS) as sodium chloride per the Document:2.20E-06 μg/μm3 6 7 Based on the methodology discussed in "Calculating Realistic PM10 Emissions from Cooling Towers" by Joel Reisman and Gordon Frisbie, 2002 (the Document). https://yosemite.epa.gov/r9/air/epss.nsf/6924c72e5ea10d5e882561b100685e04/44841bd36885b15e882579f80062a144/$FILE/Cooling%20Tower%20PM%20Emissions.pdf Assumptions/helpful equation Based on drift eliminator test data from a test conducted by Environmental Systems Corporation (ESC) at the Electric Power Research Institute (EPRI) test facility in Houston, Texas in 1988 (Aull, 1999) as documented in Table 1 of the Document. DTDS represents the particle size of collected material in droplet. The EPRI cumulative % mass smaller indicates the percentage of material in that specific water droplet size that has a diameter smaller than DTDS. Therefore, linear interpolation between calculated DTDS is necessary to ascertain the specific mass percentages to estimate PM10 and PM2.5 emissions. For example, at 1,000 mg/L TDS: %MassPM10 = %Mass Less than 10 DTDS + [ (10 - DTDS Less Than 10) / (DTDS Greater Than 10 - DTDS Less Than 10) ] * (%Mass Greater than 10 DTDS - %Mass Less than 10 DTDS) i.e. 82.041% = 82.023% + [ (10 - 9.995) / (11.533 - 9.995) ] * (88.012% - 82.023%) ‐20 0 20 40 60 80 100 120 0.000 5.000 10.000 15.000 20.000 25.000 30.000 35.000 40.000 45.000 50.000 Percentage of Drift PM at 1,000 mg/L Trinity Consultants 2 of 2 KCC Ogden NOI_U8 SAM emissions_v1.0 Cooling Tower