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HomeMy WebLinkAboutDAQ-2024-0077531 DAQC-CI121320001-24 Site ID 12132 (B1) MEMORANDUM TO: FILE – MOM BRANDS – Cereal Breakfast Food Manufacturing Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Daniel Riddle, Environmental Scientist DATE: April 16, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Box Elder County INSPECTION DATE: February 22, 2024 SOURCE LOCATION: 1135 North 1000 West Tremonton, UT 84337 SOURCE CONTACTS: Bob Lambert, Manager rclambert@postholdings.com Ross Peterson, Manager rjpeterson@postholdings.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: MOM Brands produces Ready to Eat (RTE) cereal. Ingredients used in the cereal manufacturing process are brought in by railcar and truck. The mill operates 4 production lines: Line 1: bake oven process producing shredded RTE cereal. Line 2: produces gun puffed product after it has been extruded and formed into shape. Line 3: produces sheeted products which are flash extruded then milled into a sheet then cut to size. Line 4: produces milled and flaked products which are milled into a thin flake then puffed to size. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN113580016-22, dated February 23, 2022 NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: MOM Brands - Cereal Breakfast Food Manufacturing Plant 20802 Kensington Boulevard 1135 North 1000 West Lakeville, MN 55044 Tremonton, UT 84337 SIC Code: 2043: (Cereal Breakfast Foods) Section I: GENERAL PROVISIONS I.1 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.2 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.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. No limits set forth in this AO appear to have been exceeded. The source stated that there have been no modifications to the equipment or processes. The equipment appeared to be properly operated and maintained according to manufacturer recommendations. Records are kept as required and were made available after the inspection. No breakdowns have been reported since the previous inspection. This source is not required to submit an emissions inventory at this time. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Cereal Breakfast Food Manufacturing Plant 3 II.A.2 ID: B1 and B2 Two (2) Boilers Capacity: 25.1 MMBtu/hr Fuel: Natural gas Control: low-NOx burners II.A.3 ID: HW-1 (NEW) One (1) direct-fired water heater Capacity: 12.5 MMBtu/hr Fuel: Natural gas Control: low-NOx burners II.A.4 ID: HW-4 One (1) direct-fired water heater Capacity: 14.1 MMBtu/hr Fuel: Natural gas II.A.5 ID: 1-1 One (1) dryer Capacity: 5.0 MMBtu/hr Fuel: Natural gas II.A.6 ID: 1-2 and 1-3 Two (2) baking ovens Capacity: 21.6 MMBtu/hr Fuel: Natural gas II.A.7 ID: 1-4 and 1-5 Two (2) general aspiration hoods Control: baghouse each Capacity: 4,657 dscfm for the general aspiration hood, 1,124 dscfm for the vacuum hood. II.A.8 ID: 2-1 One (1) extruders/dryers/coolers II.A.9 ID: 2-2 One (1) puffer superheaters Capacity: 0.56 MMBtu/hr each Fuel: Natural gas II.A.10 ID: 2-3 One (1) puffer units Capacity: 1.5 MMBtu/hr Fuel: Natural gas Control: two (2) cyclones in series II.A.11 ID: 2-4 One (1) puffer aspiration hoods Control: baghouse Rating: 3,747 cfm II.A.12 ID: 2-5 One (1) sugar concentrator II.A.13 ID: 2-7 One (1)sugar coat dryer Capacity: 6 MMBtu/hr Fuel: Natural gas 4 II.A.14 ID: 2-8 One (1) sugar coat cooler II.A.15 ID: 2-9, 2-10 Two (2) general aspiration systems Control: baghouse each (2 total) Rating: Unit 2-9: 899 cfm Unit 2-10: 3,747 cfm II.A.16 ID: 2-11 One (1) preheater Capacity: 1.5 MMBtu/hr Fuel: Natural gas Control: cyclone Rating: 2,143 cfm II.A.17 ID: 2-13 One (1) rejects receiver filter Rating: 700 cfm II.A.18 ID: 3-1 One (1) rotary dryer Capacity: 2 MMBtu/hr Fuel: Natural gas Control: Cyclone Rating: 4,711 cfm II.A.19 ID: 3-2 One (1) rotary dryer Steam-heated Control: cyclone Rating: 3,456 cfm II.A.20 ID: 3-3 One (1) rotary dryer Steam-heated Control: cyclone Rating: 3,452 cfm II.A.21 ID: 3-4 One (1) rotary puffer/toaster dryer Capacity: 5 MMBtu/hr Fuel: Natural gas Control: cyclone Rating: 751 cfm II.A.22 ID: 3-5 One (1) rotary puffer/toaster cooler Control: baghouse Rating: 4,565 cfm II.A.23 ID: 3-8 One (1) aspiration filter Rating: 2,510 cfm 5 II.A.24 ID: 3-9 One (1) vacuum filter Control: baghouse Rating: 1,114 cfm II.A.25 ID: 3-10 One (1) aspiration system Control: baghouse Rating: 4,657 cfm II.A.26 ID: 3-11 One (1) mixer transfer filter Control: baghouse Rating: 594 cfm II.A.27 ID: 3-12 One (1) blower filter Control: baghouse Rating: 2,037 cfm II.A.28 ID: 4-1 One (1) mill room aspiration filter Rating: 12,484 cfm II.A.29 ID: 4-2 One (1) mill room dryer II.A.30 ID: 4-3 One (1) puffer/toaster unit Capacity: 5.4 MMBtu/hr Fuel: Natural gas Control: four (4) external dust suppression units Rating: 4,000 cfm II.A.31 ID: 4-4 One (1) sugar coat steam-heated dryer II.A.32 ID: 4-5 One (1) sugar coat cooler II.A.33 ID: 4-6 One (1) sugar concentrator II.A.34 ID: 4-7 One (1) sugar coat aspiration filter Control: baghouse Rating: 7,018 cfm II.A.35 ID: 4-8 One (1) general aspiration system Control: baghouse Rating: 757 cfm II.A.36 ID: 4-9 Line 4 bulk bin vent system Control: baghouse Rating: 1,150 cfm 6 II.A.37 ID: 4-10 One (1) cooling belt Control: two-stage dust separator Rating: 11,000 cfm II.A.38 ID: 4-11 One (1) grain receiving aspiration Control: baghouse Rating: 7,000 cfm II.A.39 ID: 4-12 One (1) grain recovery Control: baghouse Rating: 1,223 cfm II.A.40 ID: 4-13 One (1) grain suction Control: baghouse Rating: 1,223 cfm II.A.41 ID: 4-14 and 4-15 Two (2) puffer toaster exhaust vents Rating: 4,000 cfm each II.A.42 ID: 4-16 One (1) sugar coat enrobing feeder Rating: 4,000 cfm II.A.43 Baghouses Grain loading of 0.005 grains/dscf or less, each II.A.44 ID: F1 Animal feed collection and loadout of unused grains Control: baghouse Ratings: -feed collection - 713 cfm, 446 cfm, 847 cfm, 1,115cfm -feed loadout filter - 4,788 cfm II.A.45 Various Equipment Various ancillary equipment and activities, including office and lab operations, maintenance activities, etc. II.A.46 Miscellaneous Forklift Trucks Miscellaneous propane or compressed natural gas-fueled forklift trucks. For informational purposes only. II.A.47 Emergency Pump Engine Fuel: natural gas Capacity: 18hp NSPS Subpart IIII MACT Subpart ZZZZ 7 II.A.48 Various Boilers, Space Heaters, and Air Units Fuel: Natural gas Capacity: less than 5.0 MMBtu/hr each Source category exempt equipment under R307-410-10. Status: In Compliance. No unapproved equipment was observed on site. Both boilers in Condition II.A.2 were manufactured in 1999. The emergency engine in Condition II.A.47 is no longer on site, so this site is no longer subject to 40 CFR Part 60 Subpart IIII or Part 63 Subpart ZZZZ. Burner ratings for most ovens and dryers were not printed directly on the equipment, so ratings were sent electronically and are attached below. Some ratings from the manufacturers are not consistent with the ratings on the AO: however, no ratings were above those listed on the AO, so no compliance action is recommended. The source plans to update all ratings with their next AO modification. See the attached correspondence below. ·Condition II.A.5 - the dryer is rated at 1.8 MMBtu/hr ·Condition II.A.10 - these superheaters are rated at 486,000 Btu/hr ·Condition II.A.11 - this puffer unit is rated at 1.4 MMBtu/hr ·Condition II.A.13 - the sugar coat dryer is rate 3.5 MMBtu/hr ·Condition II.A.18 - the dryer is rated at 1.5 MMBtu/hr ·Condition II.A.21 - the dryer is rated at 2.5 MMBtu/hr ·Condition II.A.30 - the dryer is rated at 3.5 MMBtu/hr II.B Requirements and Limitations II.B.1 The Tremonton Cereal Breakfast Food Manufacturing Plant shall be subject to the following: II.B.1.a The owner/operator shall not produce more than 105,120 tons of cereal per rolling 12-month period. [R307-401-8] II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the last day of each month using data from the previous 12 months. Records of production shall be kept for all periods when the plant is in operation. Cereal production shall be determined by production records or sales records. The records of production shall be kept on a daily basis. [R307-401-8] Status: In Compliance. For the rolling 12-month period from February 2023 - January 2024, a total of 60,658.2 tons of cereal were produced. See the attached table. II.B.1.b Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions on site to exceed 20 percent opacity. [R307-401-8] II.B.1.b.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] Status: In Compliance. No visible emissions were observed from any point at the time of inspection. Method 9 was utilized to verify opacity limits. See attached VEO form. II.B.2 The Natural Gas-Fired Equipment Requirements II.B.2.a The owner/operator shall not allow visible emissions from natural gas-fired equipment (including extruders, dryers, & coolers) on site to exceed 10 percent opacity. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point at the time of inspection. See attached VEO form. 8 II.B.2.b The owner/operator shall not consume more than 850 million cubic feet of natural gas per rolling 12-month period. [R307-401-8] II.B.2.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the last day of each month using data from the previous 12 months. Records of natural gas consumption shall be kept for all periods when the plant is in operation. The amount of natural gas consumed shall be determined by the monthly gas bill. The records of natural gas consumption shall be kept on a monthly basis. [R307-401-8] Status: In Compliance. For the rolling 12-month period from February 2023 - January 2024, a total of 293.5 million cubic feet of gas were consumed at this site. See the attached table for more information. II.B.3 Baghouse Requirements II.B.3.a The owner/operator shall not allow visible emissions from any baghouse or fabric filter on site to exceed 10 percent opacity. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point at the time of inspection. See attached VEO form. II.B.3.b The pressure drop across the externally-venting baghouse shall not be less than 0.5 inches of water column nor more than 10.0 inches of water column. [R307-401-8] II.B.3.b.1 The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the measurement of the change in pressure of the gas stream through each externally-venting baghouse. The monitoring equipment shall be located such that the operator can safely read the output at any time. The monitoring device shall be calibrated at least annually according to the manufacturer's instructions. The owner/operator shall maintain records of monitoring device calibrations. Continuous or discrete recording of the monitoring device is not required. [R307-401-8] Status: In Compliance. Magnehelic readings were within the prescribed ranges at the time of inspection. All magnehelic gauges have been calibrated within the past year. See the attached log showing the dates of completion. Note: 14 of the 20 baghouses vent externally, and the rest vent internally. II.B.4 VOC and HAP Limitations. II.B.4.a The owner/operator shall not emit more than the following from cereal flavorings, inks, and cleaning chemicals at the site: 45.00 tons per rolling 12-month period for VOCs 0.59 tons per rolling 12-month period for HAPs (This does not include VOCs or HAPs from combustion or from process sources (i.e VOCs from drying, puffing, handling, etc.). This cap is only for cereal flavorings, inks, and cleaning chemicals containing VOCs and/or HAPs). [R307-401-8] II.B.4.a.1 The owner/operator shall calculate a new12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emission from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [(%VOC other than propylene glycol by weight) + (%VOC of propylene glycol x 0.3)] x [Density] x [Volume Consumed] HAP = [%HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] 9 II.B.4.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] II.B.4.a.3 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 amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. 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] Status: In Compliance. For the rolling 12-month period from February 2023 - January 2024, emissions are as follows: 31.4439 tons of VOCs 0.0000 tons of HAPs See the attached table for more information. 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. The boilers only use natural gas, supplied by the local utility. Natural gas usage is recorded - see the attached table. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Stationary Sources [R307-210] Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal Requirements NSPS (Part 60) Subpart Dc. See Section III above for more information. 10 EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from MOM Brands - Cereal Breakfast Food Manufacturing Plant on the Approval Order (AO) DAQE- AN113580016-22, dated February 23, 2022. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 51967.00 Carbon Monoxide 45.10 Nitrogen Oxides 48.31 Particulate Matter - PM10 49.37 Particulate Matter - PM2.5 49.37 Sulfur Dioxide 0.27 Volatile Organic Compounds 59.37 Hazardous Air Pollutant PTE lbs/yr Benzene (Including Benzene From Gasoline) (CAS #71432) 2 Formaldehyde (CAS #50000) 64 Generic HAPs (CAS #GHAPS) 40 Hexane (CAS #110543) 1530 Toluene (CAS #108883) 3 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE- AN113580016-22, dated February 23, 2022: in compliance at the time of inspection. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect at typical frequency for this type of source. Steel-toed boots, safety glasses, ear plugs, and a hard hat will be required PPE. The source will also ask you to place booties on your shoes, remove any jewelry, and wear sanitized lab coats. NSR RECOMMENDATIONS: Verify and change burner ratings on the next AO. Remove the emergency pump engine from Condition II.A.47 from the AO. Update language in Condition II.B.3.b and the equipment list to clarify which baghouses vent internally vs. externally. ATTACHMENTS: VEO Form, email correspondence, emissions, magnehelic calibration, burner ratings 4/16/24, 10:47 AM State of Utah Mail - 12132 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r1842393189119966169&simpl=msg-a:r-15392494376727…1/5 Daniel Riddle <driddle@utah.gov> 12132 - Follow up to air quality inspection 12 messages Daniel Riddle <driddle@utah.gov>Fri, Feb 23, 2024 at 10:56 AM To: mihansell@postholdings.com, rclambert@postholdings.com, rjpeterson@postholdings.com, kjlarsen@postholdings.com Kim, Bob, Ross, and Maria, I met yesterday with Kim for your air quality inspection. As discussed, here are the records I require to complete my inspection report: From AO DAQE-AN121320016-22 Condition II.B.1.a - cereal production (Feb 23 - Jan 24) Condition II.B.2.b - natural gas consumption (Feb 23 - Jan 24) Condition II.B.3.b1 - annual gauge calibration Condition II.B.4.a - VOC & HAP emissions (Feb 23 - Jan 24) Additionally, we could not verify the natural gas ratings for most of the burners on the dryers, toasters, and ovens for the 4 product lines - please send me a screenshot or other verification from the manufacturer for the burner ratings for all equipment that has a MMBTU rating on lines 1-4. Please provide these records by March 1, 2024. Let me know if you have any questions. Best, Daniel -- Daniel Riddle (he/him) Environmental Scientist | Minor Source Compliance M: (385) 222-1357 airquality.utah.gov Bob Lambert <rclambert@postholdings.com>Fri, Feb 23, 2024 at 12:08 PM To: Daniel Riddle <driddle@utah.gov>, Maria Hansell <mihansell@postholdings.com>, Ross Peterson <rjpeterson@postholdings.com>, Kimberly Larsen <kjlarsen@postholdings.com> Cc: Christine Deedon <cjdeedon@postholdings.com>, Robby Groll <rkgroll@postholdings.com> Thank you Daniel. Our EHS leadership at the site will pull this together and will share this with you by 3/1. We appreciate it. Bob Lambert Sr. Director - EHS| Post Consumer Brands 20802 Kensington Blvd Lakeville, MN 55044 Direct 952.322.8278 Cell 952.200.7118 From: Daniel Riddle <driddle@utah.gov> Sent: Friday, February 23, 2024 11:57 AM To: Maria Hansell <mihansell@postholdings.com>; Bob Lambert <rclambert@postholdings.com>; Ross Peterson <rjpeterson@postholdings.com>; Kimberly Larsen <kjlarsen@postholdings.com> Subject: 12132 - Follow up to air quality inspection 4/16/24, 10:47 AM State of Utah Mail - 12132 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r1842393189119966169&simpl=msg-a:r-15392494376727…2/5 You don't often get email from driddle@utah.gov. Learn why this is important ATTENTION: This email came from OUTSIDE our organization. Use caution when clicking links or opening attachments. [Quoted text hidden] This message and any attachments are intended only for the addressee(s) and may contain privileged or confidential information. Any unauthorized disclosure is strictly prohibited. If you have received this message in error, please notify us immediately so that we may correct our internal records. Please then permanently delete the original message including any attachments and any copies that may have been made. Daniel Riddle <driddle@utah.gov>Mon, Feb 26, 2024 at 8:28 AM To: Bob Lambert <rclambert@postholdings.com> Cc: Maria Hansell <mihansell@postholdings.com>, Ross Peterson <rjpeterson@postholdings.com>, Kimberly Larsen <kjlarsen@postholdings.com>, Christine Deedon <cjdeedon@postholdings.com>, Robby Groll <rkgroll@postholdings.com> Sounds good, thank you. [Quoted text hidden] Christine Deedon <cjdeedon@postholdings.com>Fri, Mar 1, 2024 at 3:06 PM To: Bob Lambert <rclambert@postholdings.com>, Daniel Riddle <driddle@utah.gov>, Maria Hansell <mihansell@postholdings.com>, Ross Peterson <rjpeterson@postholdings.com> Cc: Robby Groll <rkgroll@postholdings.com>, Mark Suchan <mwsuchan@postholdings.com>, Kimberly Larsen <kjlarsen@postholdings.com> Hi Daniel, Attached you’ll find the requested documents. I’ve also included a legend detailing where to find burner ratings for applicable equipment (see below). Please let me know if you have any questions! Thank you, Christine J. Deedon HSES Manager | Post Consumer Brands 1135 N 1000 W Tremonton, UT 84337 Office (435) 257-9213 4/16/24, 10:47 AM State of Utah Mail - 12132 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r1842393189119966169&simpl=msg-a:r-15392494376727…3/5 Cell (661) 877-6257 [Quoted text hidden] [Quoted text hidden] 12 attachments ID.B2_Boiler Burner MMBtu.jpg 2568K ID.B1_Boiler Burner MMBtu.jpg 1470K ID.HW-4_Water Heater Burner MMBtu.jpg 210K ID.2-11_L2 Predryer Burner_MMBtu.JPG 3685K PCB Tremonton Air Permit Emission Tracking_Feb23-Jan24.pdf 83K Annual Baghouse Magnehelic Calibration PM Report.pdf 82K ID.HW-1_QuikWater Heater Spec Sheet_MMBtu.pdf 377K ID.1-1_L1 Dryer Burner BOM_MMBtu.pdf 2172K ID.1-2,1-3, 2-11, 3-1, 3-4, 4-3_OvenPak 400 Gas Burners Tech Catalog_MMBtu.pdf 1287K ID.2-2_Evapco Burner Drawing_MMBtu.pdf 86K ID.2-3_Super Heater Burner Spec Sheet_MMBtu.pdf 731K 4/16/24, 10:47 AM State of Utah Mail - 12132 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r1842393189119966169&simpl=msg-a:r-15392494376727…4/5 ID.2-7_L2 SC Dryer Burner Data Sheet_MMBtu.pdf 91K Daniel Riddle <driddle@utah.gov>Tue, Mar 5, 2024 at 8:24 AM To: Christine Deedon <cjdeedon@postholdings.com> Cc: Bob Lambert <rclambert@postholdings.com>, Maria Hansell <mihansell@postholdings.com>, Ross Peterson <rjpeterson@postholdings.com>, Robby Groll <rkgroll@postholdings.com>, Mark Suchan <mwsuchan@postholdings.com>, Kimberly Larsen <kjlarsen@postholdings.com> Thank you for sending this. I'll let you know if I need anything else. [Quoted text hidden] Daniel Riddle <driddle@utah.gov>Tue, Mar 5, 2024 at 10:08 AM To: Christine Deedon <cjdeedon@postholdings.com> Cc: Bob Lambert <rclambert@postholdings.com>, Maria Hansell <mihansell@postholdings.com>, Ross Peterson <rjpeterson@postholdings.com>, Robby Groll <rkgroll@postholdings.com>, Mark Suchan <mwsuchan@postholdings.com>, Kimberly Larsen <kjlarsen@postholdings.com> Christine - it appears that some of the burner ratings are actually lower than what is listed on the AO? For example, 1-1 is rated at 5 MMBtu/hr. However, on the document you sent, the burner capacity has a rating of 1.8 MMBtu/hr The puffer superheater in 2-2 is rated at .56 MMBtu/hr, but is listed as .486 MMBtu/hr on the Evapco sheet. For the Ovenpak 400 document - which inches of water column are you referring to for each of the ratings? It appears that even if you use the highest rating (lowest inches of water column), these burners are rated below the totals on the AO. There are several others - nothing seems to be higher than the AO, so excess emissions aren't an issue, but am I missing something? If these numbers are incorrect, we should try to fix them on your next Approval Order modification. Best, Daniel [Quoted text hidden] Christine Deedon <cjdeedon@postholdings.com>Tue, Mar 5, 2024 at 4:24 PM To: Daniel Riddle <driddle@utah.gov> Cc: Bob Lambert <rclambert@postholdings.com>, Maria Hansell <mihansell@postholdings.com>, Ross Peterson <rjpeterson@postholdings.com>, Robby Groll <rkgroll@postholdings.com>, Mark Suchan <mwsuchan@postholdings.com>, Kimberly Larsen <kjlarsen@postholdings.com> Hi Daniel, We see that there appears to be disagreement in the heat input data in the instances you noted below. Post will review all data and update information as applicable at the time of the next permit modification/renewal. Appreciate your diligence, [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] Daniel Riddle (he/him) Environmental Scientist | Minor Source Compliance M: (385) 222-1357 airquality.utah.gov 4/16/24, 10:47 AM State of Utah Mail - 12132 - Follow up to air quality inspection https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r1842393189119966169&simpl=msg-a:r-15392494376727…5/5 This message and any attachments are intended only for the addressee(s) and may contain privileged or confidential information. Any unauthorized disclosure is strictly prohibited. If you have received this message in error, please notify us immediately so that we may correct our internal records. Please then permanently delete the original message including any attachments and any copies that may have been made. [Quoted text hidden] Daniel Riddle <driddle@utah.gov>Wed, Mar 6, 2024 at 10:37 AM To: Christine Deedon <cjdeedon@postholdings.com> Cc: Bob Lambert <rclambert@postholdings.com>, Maria Hansell <mihansell@postholdings.com>, Ross Peterson <rjpeterson@postholdings.com>, Robby Groll <rkgroll@postholdings.com>, Mark Suchan <mwsuchan@postholdings.com>, Kimberly Larsen <kjlarsen@postholdings.com> Alright - that should be sufficient. I'll let you know if my manager has any other recommendations here. [Quoted text hidden] Christine Deedon <cjdeedon@postholdings.com>Tue, Apr 2, 2024 at 4:58 PM To: Daniel Riddle <driddle@utah.gov> Hi Daniel, Just wanted to clarify, do you want us to include baghouses with pressure relief discs in the total count of outside venting baghouses? [Quoted text hidden] [Quoted text hidden] Daniel Riddle <driddle@utah.gov>Wed, Apr 3, 2024 at 5:49 AM To: Christine Deedon <cjdeedon@postholdings.com> Any baghouse that is on your Approval Order - if it eventually vents externally, let me know. Thank you [Quoted text hidden] Christine Deedon <cjdeedon@postholdings.com>Wed, Apr 3, 2024 at 5:17 PM To: Daniel Riddle <driddle@utah.gov> Cc: Bob Lambert <rclambert@postholdings.com>, Maria Hansell <mihansell@postholdings.com>, Ross Peterson <rjpeterson@postholdings.com>, Robby Groll <rkgroll@postholdings.com>, Mark Suchan <mwsuchan@postholdings.com>, Kimberly Larsen <kjlarsen@postholdings.com> Hi Daniel, Following up on our phone conversation. From what I’ve gathered, we have 14 baghouses that vent directly outside. Please let me know if you need anything else, [Quoted text hidden] [Quoted text hidden] Daniel Riddle <driddle@utah.gov>Thu, Apr 11, 2024 at 10:39 AM To: Christine Deedon <cjdeedon@postholdings.com> Cc: Bob Lambert <rclambert@postholdings.com>, Maria Hansell <mihansell@postholdings.com>, Ross Peterson <rjpeterson@postholdings.com>, Robby Groll <rkgroll@postholdings.com>, Mark Suchan <mwsuchan@postholdings.com>, Kimberly Larsen <kjlarsen@postholdings.com> Thanks for the update. [Quoted text hidden] W:\HR\HSES\Environmental\TRE AIR\TRE Air Permit Tracking\Tremonton 2024 Air Permit Tracking Post Consumer Brands - Tremonton Plant LIMIT= 105,120 LIMIT= 850 LIMIT= 45 LIMIT= 0.59 Production Production 12 Month Gas Use Nat Gas 12 Month Monthly 12 Month Monthly 12 Month Year Month Pounds Tons Rolling Total dth million ft3 Rolling Total Tons Rolling Total Tons Rolling Total 2023 Jan 9,824,647 4912.3 61,513.0 27,303 27.303 255.6 4.97315 42.1061 0.00000 0.0312 2023 Feb 9,518,968 4759.5 61,432.7 24,265 24.265 257.3 1.64579 40.2420 0.00000 0.0312 2023 Mar 8,126,925 4063.5 60,333.5 24,592 24.592 260.9 2.73324 39.5615 0.00000 0.0232 2023 Apr 9,686,683 4843.3 60,088.4 21,331 21.331 262.0 1.93456 38.2823 0.00000 0.0232 2023 May 10,528,886 5264.4 59,559.1 20,028 20.028 261.1 1.84244 37.0901 0.00000 0.0147 2023 Jun 11,222,632 5611.3 59,894.5 19,413 19.413 262.0 2.65105 36.5029 0.00000 0.0072 2023 Jul 10,195,312 5097.7 59,536.5 18,994 18.994 263.5 4.50235 36.9098 0.00000 0.0072 2023 Aug 10,409,546 5204.8 59,211.3 24,927 24.927 269.2 2.34463 35.7597 0.00000 0.0063 2023 Sept 10,662,560 5331.3 59,242.9 24,899 24.899 275.4 2.98822 36.4465 0.00000 0.0063 2023 Oct 11,359,965 5680.0 60,396.5 28,149 28.149 282.4 2.93927 35.4421 0.00000 0.0046 2023 Nov 9,046,567 4523.3 59,959.4 28,296 28.296 287.1 2.69376 35.3846 0.00000 0.0042 2023 Dec 9,293,915 4647.0 59,938.3 30,431 30.431 292.6 2.68506 33.9335 0.00000 0.0000 2024 Jan 11,264,466 5632.2 60,658.2 28,184 28.184 293.5 2.48358 31.4439 0.00000 0.0000 2024 Feb 0.0 55,898.7 0 0.000 269.2 0.00000 29.7981 0.00000 0.0000 2024 Mar 0.0 51,835.3 0 0.000 244.7 0.00000 27.0649 0.00000 0.0000 2024 Apr 0.0 46,991.9 0 0.000 223.3 0.00000 25.1303 0.00000 0.0000 2024 May 0.0 41,727.5 0 0.000 203.3 0.00000 23.2879 0.00000 0.0000 2024 Jun 0.0 36,116.2 0 0.000 183.9 0.00000 20.6369 0.00000 0.0000 2024 Jul 0.0 31,018.5 0 0.000 164.9 0.00000 16.1345 0.00000 0.0000 2024 Aug 0.0 25,813.7 0 0.000 140.0 0.00000 13.7899 0.00000 0.0000 2024 Sept 0.0 20,482.5 0 0.000 115.1 0.00000 10.8017 0.00000 0.0000 2024 Oct 0.0 14,802.5 0 0.000 86.9 0.00000 7.8624 0.00000 0.0000 2024 Nov 0.0 10,279.2 0 0.000 58.6 0.00000 5.1686 0.00000 0.0000 2024 Dec 0.0 5,632.2 0 0.000 28.2 0.00000 2.4836 0.00000 0.0000 12 month rolling totals Cereal Production HAP EmissionsVOC EmissionsNatural Gas Use (mmcf) totals KKG Post Consumer Brands - Tremonton Baghouse Pressure Monitoring Device Annual Calibration Report Sched. Start Date Work Order Equipment Type Description Status Est Hrs Date Reported Date Completed 2/10/2024 1488372 33051-002 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 8/3/2023 11:34 2/14/2024 7:34 12/6/2023 1512781 30037-002 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 11/30/2023 10:08 1/28/2024 13:36 9/15/2023 1488373 33052-002 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 8/3/2023 11:34 10/2/2023 16:04 8/18/2023 1480668 10199 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 8/3/2023 11:34 9/13/2023 10:48 8/27/2023 1483558 30269-001 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 8/3/2023 11:34 9/13/2023 10:47 7/14/2023 1463394 33053-002 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 5/18/2023 6:56 7/18/2023 8:58 7/14/2023 1465077 33054-002 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 6/5/2023 10:23 7/18/2023 8:56 7/14/2023 1465078 33025-003 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 6/5/2023 10:23 7/18/2023 8:56 6/15/2023 1462589 10490 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 5/11/2023 13:29 6/12/2023 10:26 6/15/2023 1462590 30224-002 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 5/11/2023 13:29 6/12/2023 10:26 6/30/2023 1464951 10427 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 6/5/2023 10:23 6/12/2023 10:26 6/14/2023 1462405 30028-114 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 5/10/2023 16:49 6/7/2023 11:09 5/6/2023 1439767 30050-001 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 4/27/2023 15:49 5/12/2023 10:39 5/6/2023 1439766 10112 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 4/27/2023 15:49 5/12/2023 9:10 5/10/2023 1440405 30445-001 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 4/27/2023 15:49 5/12/2023 9:08 5/12/2023 1440707 11987 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 4/17/2023 7:20 5/12/2023 9:08 5/10/2023 1440404 30426-001 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 4/27/2023 15:49 5/11/2023 11:44 5/12/2023 1440706 30470-001 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 4/27/2023 15:49 5/2/2023 10:31 4/28/2023 1438218 30030-002 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 3/31/2023 12:44 4/25/2023 10:13 4/29/2023 1438455 10108 PM(Preventive Maint) BAGHOUSE MAGNEHELIC GUAGE CALIBRATION 1Y Completed 1 3/31/2023 12:44 4/25/2023 10:12