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Home My WebLink AboutDAQ-2025-0023091 DAQC-CI116520001-25 Site ID 11652 (B1) MEMORANDUM TO: FILE – DANONE US, LLC – West Jordan Dairy Food Processing Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: March 11, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: December 19, 2024 SOURCE LOCATION: 6165 West Dannon Way (9280 S) West Jordan, UT 84081 SOURCE CONTACT: Andrew Peedle EHS Manager, 801-332-0145, andrew.peedle@danone.com OPERATING STATUS: In operation PROCESS DESCRIPTION: Danone produces yogurt from cultured milk. Milk is trucked in from a local supplier. It is then heated and fermented. When the growth of the culture is at an optimum taste and texture, the fermentation is stopped by quick cooling. The cooled product is then homogenized. Different flavorings such as fruit, essences, coloring, and sugars are added before packaging and shipping. The heating process utilizes three natural gas boilers. Two natural gas emergency generator engines, near the boiler room, are available to provide emergency lighting. A wet particle dust collector is used as part of the wastewater treatment process. A diesel emergency generator engine is also located at the wastewater treatment plant to provide electricity to the process during power interruptions. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN116520005-22, dated September 28, 2022 NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. / : 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Danone US, LLC - West Jordan Dairy Food Processing Plant 6165 West Dannon Way 6165 West Dannon Way (9280 S) West Jordan, UT 84081 West Jordan, UT 84081 SIC Code: 2026: (Milk, Fluid) SECTION I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] 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. [R307-401-8] Status: In Compliance. Danone has not exceeded any limits set forth in this approval order. Danone maintains records for at least two years, and maintains records of maintenance activities performed on approved equipment. According to Danone, there has been no breakdowns resulting in an emissions event. According to the 2023 Emissions Inventory Report, the emissions released indicated compliance with the PTEs of this AO. A notification to the DAQ regarding the installation of boiler 4 was received on August 31, 2023. See the attachment for additional information. 3 SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 West Jordan Plant Dairy Food Processing Plant II.A.2 Boilers Boiler 1: One (1) rated at 20.9 MMBtu/hr Boiler 2: One (1) rated at 16.738 MMBtu/hr Boiler 3: One (1) low NOx rated at 20.9 MMBtu/hr Low NOx: 30 ppm Fuel: natural gas Boiler 4: One (1) Ultra-low NOx rated at 32.715 MMBtu/hr (NEW) Ultra-low NOx: 9 ppm Fuel: natural gas NSPS Subpart Dc II.A.3 Emergency Generator Engines One (1) rated at 35 kW (new) Fuel: natural gas Manufactured in 2013 One (1) rated at 125 kW Fuel: natural gas Manufactured in 1996 One (1) rated at 563 kW Fuel: diesel or fuel oil Manufactured in 2011 NSPS Subpart IIII or Subpart JJJJ MACT Subpart ZZZZ II.A.4 Dust Collector One (1) wet particle collector - internally vented For information purposes. Status: In Compliance. There was no new or unapproved equipment observed onsite during this inspection. Danone was provided a link to the new boiler rules in R307-316, with an emphasis on Boilers 1, 2, and 3 with a NOx limit of 30 ppm in AO Condition II.A.2. Additional equipment according to DAQC-CI116520001-23: - One Cintas SafeWasher water-based parts cleaner - One completely enclosed Econoline media blaster 4 SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source associated with the source or with the control facilities to exceed the following: A. All boilers - 10% opacity B. The 35 kW and 125 kW emergency generator engines - 10% opacity C. All other points - 20% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. There were no visible emissions observed during this inspection. The opacity observations were conducted in accordance with 40 CFR 60, Appendix A, Method 9. See the attachment for additional information. II.B.1.b The owner/operator shall install the low-NOx boiler (Boiler 3) that is specified to meet a NOx emission concentration of 30 ppm, or less. [R307-401-8] II.B.1.b.1 The owner/operator shall keep a record of the manufacturer's specification of the emission concentration. The record shall be kept for the life of the equipment. [R307-401-8] Status: In Compliance. Danone has installed a low-NOx boiler in Boiler 3, specified to meet a NOx concentration of 30 ppm, or less. Records of the combustion analyses indicates compliance with the NOx concentration. See the attachment for additional information. Danone plans to keep a record of the manufacturer's specification of the emission concentration for the life of the equipment. II.B.1.c The owner/operator shall install an ultra low-NOx burner on Boiler 4 that is specified to meet a NOx emission concentration of 9 ppm, or less. [R307-401-8] II.B.1.c.1 The owner/operator shall keep a record of the manufacturer's specification of the emission concentration. The record shall be kept for the life of the equipment. [R307-401-8] Status: In Compliance. Danone has installed an ultra low-NOx burner on Boiler 4, specified to meet a NOx concentration of 9 ppm, or less. Records of the combustion analyses indicates compliance with the NOx concentration. See the attachment for additional information. Danone plans to keep a record of the manufacturer's specification of the emission concentration for the life of the equipment. II.B.1.d The owner/operator shall install and operate an internal flue gas recirculation system on Boiler 4. [R307-401-8] Status: In Compliance. See a picture of the flue gas recirculation on Boiler 4 in the attachment. II.B.1.e The owner/operator shall only use natural gas as fuel in all boilers. [R307-401-8] Status: In Compliance. All the boilers at Danone use natural gas as fuel. 5 II.B.2 Emergency Engine Requirements II.B.2.a The owner/operator shall use only natural gas in the 35 kW and 125 kW emergency generator engines. [R307-401-8] Status: In Compliance. Danone uses only natural gas in the Cummins 35 kW and the Generac 125 kW emergency generator engines. See the attachment for additional information. II.B.2.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 563 kW emergency generator engine. [R307-401-8] Status: In Compliance. Danone uses only diesel in the Cummins 400 kW (not 563 kW as indicated in AO II.A.3) emergency generator engine. See the attachment for additional information. II.B.2.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.2.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In Compliance. According to the certificate of analysis by HF Sinclair, the sulfur content of the diesel indicated 7.6 parts per million (ppm). See the attachment for additional information. II.B.2.c The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. The hours of operation in a rolling 12-month period from December 2023, to November 2024, indicated the following: Cummins 35 kW Emergency Generator: 47.1 Generac 125 kW Emergency Generator: 5.3 Cummins 400 kW (not 563 kW as indicated in AO II.A.3) Emergency Generator: 21.9 See the attachment for additional information. II.B.2.c.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. All three emergency generators are each equipped with a non-resettable hour meter. 6 Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: In Compliance. All four boilers use natural gas. Boiler #1 burner was upgraded on October 13, 2024. See the attachment for additional information. NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. The 2011 diesel-fueled Cummins is actually 400 kW (not 563 kW as indicated in AO II.A.3), emergency generator is applicable to this Subpart, and certified as EPA NSPS Stationary Emergency Tier 2. This emergency generator is also equipped with a non-resettable hour meter. Preventive maintenance inspections were conducted on March 5, 2024, and November 5, 2024. According to the certificate of analysis by HF Sinclair, the sulfur content of the diesel indicated 7.6 parts per million (ppm). See the attachment for additional information. NSPS (Part 60) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Status: In Compliance. The 2013 natural gas-fueled Cummins 35 kW emergency generator is applicable to this subpart. This emergency generator is also equipped with a non-resettable hour meter. Preventive maintenance inspections were conducted on March 5, 2024, and on November 4, 2024. See the attachment for additional information. NESHAP (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. Status: In Compliance. All the emergency generators are applicable to this subpart. They are all equipped with a non-resettable timer. Preventive maintenance inspection was conducted on March 5, 2024. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-203 – Sulfur Content of Fuels: Emissions Standards Status: In Compliance. According to the certificate of analysis by HF Sinclair, the sulfur content of the diesel indicated 7.6 ppm. See the attachment for additional information. R307-335 - Degreasing and Solvent Cleaning Operations Status: Not applicable. Danone uses a water-based heavy-duty degreasing solution called SW-4 OzzyJuice. See the SDS and other additional information in the attachment. 7 R307-316 - NOx and CO Emission Controls for Natural Gas-Fired Boilers Greater Than 5.0 MMBtu Status: In Compliance. All four boilers are applicable to this rule. Since these boilers were installed before the compliance date of May 2024, and have not undergone any modifications or burner replacements, Danone is in compliance. Danone was provided a link to the new boiler rules in R307-316, with special emphasis on Boilers 1, 2, and 3 with a NOx limit of 30 ppm in AO Condition II.A.2. Danone was also notified that going forward, all boiler replacements and burners would be subject to the NOx and CO requirements of this rule. EMISSION INVENTORY: Status: In Compliance. According to the 2023 Emissions Inventory Report, the emissions released indicated compliance with the PTEs of this AO. Listed below are the Actual Emissions Inventory provided from Danone US, LLC - West Jordan Dairy Food Processing Plant. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN116520005-22, dated September 28, 2022, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 47115.37 ---- Carbon Monoxide 24.04 8.19 Nitrogen Oxides 27.87 7.08 Particulate Matter - PM10 3.06 0.74 Particulate Matter - PM2.5 3.06 0.74 Sulfur Dioxide 0.31 0.06 Volatile Organic Compounds 1.99 1.65 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Formaldehyde (CAS #50000) 81 Hexane (CAS #110543) 1425 PREVIOUS ENFORCEMENT ACTIONS: CA issued on January 11, 2019, for operating unpermitted equipment (see DAQC-0041-19). ESA was issued and finalized (see DAQC-058-20). Another CA was issued due to a discrepancy in the NOx emissions for boiler 3 (see DAQC-667-21). This was resolved with a No Further Action letter (see DAQC-1564-21). COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN116520005-22, dated September 28, 2022, Danone is in compliance with all the AO Conditions. The records were made available in a timely manner. Danone maintains good housekeeping practices, and the facility appears well maintained. HPV STATUS: Not Applicable. 8 RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. Required PPE includes steel-toe boots, safety glasses, ear plugs, and a lab coat (provided by the facility). NSR RECOMMENDATIONS: Consider changing the rating of the emergency generator in AO Condition II.B.2.b to 400 kW (not 563 kW as also indicated in AO II.A.3) Consider adding one Cintas SafeWasher water-based parts cleaner and one completely enclosed Econoline media blaster ATTACHMENTS: Applicable Supporting Documentation Included