HomeMy WebLinkAboutDAQ-2024-0049891
DAQC-105-24
Site ID 10478 (B1)
MEMORANDUM
TO: FILE – SANDY CITY ANIMAL SERVICES
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Irene Tucker, Environmental Scientist
DATE: December 29, 2023
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County
INSPECTION DATE: December 27, 2023
SOURCE LOCATION: 8715 South 700 West, Sandy, UT 84070
SOURCE CONTACT: Director Ian William, 801-352-4455, Cell: 801-913-2201
iwilliam@sandy.utah.gov
OPERATING STATUS: Not operating. The incinerator has not been in operation since
2022.
PROCESS DESCRIPTION: Sandy City Animal Services operates a pathological incinerator.
Animals that are not adopted are euthanized via injection and
frozen in large freezers. The animals are incinerated to reduce
remains to the basic elements of bone and ash through flame,
heat and vaporization. Pathological waste incinerators can
produce emissions of fly ash, smoke, gases, and odors. Proper
mixing, temperature, and residence time will help keep
emissions minimal. Dead animals (from road kills, etc.) are also
incinerated.
APPLICABLE REGULATIONS: Approval Order DAQE-AN0104780004-10, dated September
14, 2010.
SOURCE EVALUATION:
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]
/ :
2
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 Executive Secretary or Executive Secretary'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 Executive Secretary 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: Unavoidable
Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Inventories, Testing and
Monitoring. [R307-150]
Status: In Compliance. The Sandy City Animal Services did not exceed any limits
set forth in this AO. There have been no modifications made to the equipment or
process of this AO. The Sandy City Animal Services maintains records for a
minimum of two years, and also maintains records for maintenance activities
performed on equipment authorized by this AO. The Sandy City Animal Services is
currently not required to submit an Emissions Inventory Report.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Sandy City Pathological Incinerator
II.A.2 Pathological Incinerator
Crawford C-500P, 75 pound per hour, Pathological Waste Incinerator or equivalent.
Status: In Compliance. There was no new or unapproved equipment observed
onsite. The Sandy City Animal Services indicated that the incinerator has not been
in operation since 2022.
II.B Requirements and Limitations
II.B.1 The pathological incinerator shall be subject to the following
II.B.1.a A copy of this AO shall be posted on site. The AO shall be available to the employees who
operate the air emission producing equipment. These employees shall receive instruction as to
their responsibilities in operating the equipment in compliance with all of the relevant
conditions listed below. [R307-401-8]
Status: In compliance. The Sandy City Animal Services maintains a copy of this AO
in the Crematory Log Book.
3
II.B.1.b Emissions of PM10 to the atmosphere from the incinerator shall not exceed the following rates
and concentrations:
A. 0.21 lbs/hr
B. 0.032 grains/dscf (68°F, 29.92 in Hg)
[R307-401-8]
II.B.1.b.1 Stack testing to show compliance with the emission limitations stated in condition #6 shall be
performed as specified below:
Emission Point Pollutant Testing Status Test Frequency
Incinerator Stack PM10 * @.
[R307-401-8]
II.B.1.b.2 Testing Status (To be applied above)
* No initial testing is required. However, the Executive Secretary may require testing at
any time in accordance with R307-1-3.4.1, UACR. The source shall be tested if
directed by the Executive Secretary.
@ Test if directed by the Executive Secretary. Tests may be required if the source is
suspected to be in violation with other conditions of this AO. [R307-401-8]
II.B.1.b.3 Notification
The applicant shall provide a notification of the test date at least 45 days prior to the test. A
pretest conference shall be held if directed by the Executive Secretary. It shall be held at least
30 days prior to the test between the owner/operator, the tester, and the Executive Secretary.
The emission point shall be designed to conform to the requirements of 40 Code of Federal
Regulation (CFR) 60, Appendix A, Method 1, and Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA) approvable
access shall be provided to the test location. [R307-401-8]
II.B.1.b.4 PM10
For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR
51, Appendix M, Methods 201 or 201a. The back half condensibles shall also be tested using
the method specified by the Executive Secretary. All particulate captured shall be considered
PM10.
For stacks in which liquid drops are present, methods to eliminate the liquid drops should be
explored. If no reasonable method to eliminate the drops exists, then the following methods
shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The back half
condensibles shall also be tested using the method specified by the Executive Secretary. The
portion of the front half of the catch considered PM10 shall be based on information in AP-42,
Appendix C or other data acceptable to the Executive Secretary.
The back half condensibles shall not be used for compliance demonstration but shall be used
for inventory purposes. [R307-401-8]
II.B.1.b.5 Sample Location
40 CFR 60. Appendix A, Method 1. [R307-401-8]
4
II.B.1.b.6 Volumetric flow rate
40 CFR 60, Appendix A, Method 2. [R307-401-8]
II.B.1.b.7 Calculations
To determine mass emission rates (lbs/hr, etc.), the pollutant concentration as determined by
the appropriate methods above shall be multiplied by the volumetric flow rate and any
necessary conversion factors determined by the Executive Secretary to give the results in the
specified units of the emission limitation. [R307-401-8]
II.B.1.b.8 Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the production rate listed in this AO or established in a pretest conference. If
the maximum AO allowable production rate has not been achieved at the time of the test, the
following procedure shall be followed:
1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate. This new allowable maximum production rate shall remain in
affect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at
no less than 90% of the higher rate shall be conducted. A new maximum production
rate (110% of the new rate) will then be allowed if the test is successful. This process
may be repeated until the maximum AO production rate is achieved. [R307-401-8]
Status: Not applicable. The Sandy City Animal Services has not been required to
perform a stack test.
II.B.1.c
The following parameters shall be maintained within the indicated ranges:
A. Temperature indicators shall be installed that continuously measure the temperatures in
the primary and secondary chambers.
The incinerator shall not be charged until the temperature in the secondary chamber is
1800oF or higher as shown on the indicators. The incinerator shall not operate with a
secondary chamber temperature below 1800oF for more than 5 minutes in any 60-minute
period as shown on this indicator. The temperature shall be monitored with equipment
located such that an inspector can at any time safely read the output.
The readings shall be accurate to within plus or minus 15oF. All instruments shall be
calibrated against a primary standard at least once every 180 days. The primary
standard shall be established by the owner/operator and shall be submitted to the
Executive Secretary for approval.
Status: In Compliance. Although the incinerator was not in operation during this
inspection, the incinerator has temperature indicators that continuously measure the
temperatures in the primary and secondary chambers. All monitoring equipment is
calibrated every 180 days as required by this AO Condition.
5
B. The secondary chamber burner shall continuously operate until all material charged into
the primary chamber is fully incinerated. The secondary burner rating shall not be less
than 1,000,000 BTU/hr (Two 500,000 BTU/hr is considered equivalent to 1,000,000
BTU/hr).
Status: In Compliance. During this inspection, the incinerator was not in operation.
Records maintained by the Sandy City Animal Services indicated that when the
incineration was in operation, the secondary burner rating was not below 1,000,000
BTU/hr. Sandy City Animal Services indicated that a safety switch would be triggered if
the secondary burner rating was low.
C. There shall be no glass, metals, plastics, or material other than biohazardous material in
the incinerator without prior approval.
Status: In Compliance. Sandy City Animal Services indicated that only biological and
biohazardous materials are incinerated, however, the incinerator has not been in
operation since 2022.
D. Ash shall be handled in enclosed containers.
Status: In Compliance. According to the Sandy City Animal Services the ash is
transferred from the burn chamber to a receptacle – a biohazard drum lined with a
thick-filmed plastic bag, however, the incinerator has not been in operation since 2022.
E. The operator(s) shall receive instructions on the proper operation of the incinerator. The
manufacturer's operating instructions shall be located on site and provided to the DAQ
inspectors if requested. [R307-401-8]
Status: In Compliance. The Sandy City Animal Services provide instructions on the
proper operation of the incinerator to the operators. The manufacturer's operating
instructions is located onsite as required by this AO Condition.
II.B.1.d
Visible emissions from the incinerator stack shall not exceed 10% opacity. [R307-401-8]
II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted in accordance
with 40 CFR 60, Appendix A, Method 9. [R307-305-3]
Status: Compliance undetermined. The incinerator was not in operation during this
inspection. According to the Sandy City Animal Services the incinerator has not
been in operation since 2022.
II.B.1.e
The following production limits shall not be exceeded without prior approval:
A. 75 pounds of biohazardous material charged per hour
B. 8 hours per day
C. 2088 hours per 12-month period
[R307-401-8]
6
II.B.1.e.1 Compliance with the annual limitations shall be determined on a rolling 12-month total. Based
on the first day of each month, a new 12-month total shall be calculated using the previous 12
months. Records of hours of operation and charging rates shall be kept for all periods when
the plant is in operation. Records of hours of operation and charging rates shall be made
available to the Executive Secretary or a representative upon request and shall include a period
of two years ending with the date of the request. Hours of operation and charging rates shall
be determined by examination of the owner/operator's records of the amount and time that
material is charged. The records shall be kept on a daily basis. Hours of operation shall be
determined by supervisor monitoring and maintaining an operations log. [R307-401-8]
Status: In Compliance. These production limits were not exceeded. According to
the Sandy City Animal Services the incinerator has not been in operation since
2022.
II.B.1.f The owner/operator shall use only natural gas as a primary fuel and liquid petroleum gas as a
backup fuel in the incinerator. [R307-401-8]
Status: In compliance. The Sandy City Animal Services only uses natural gas as
fuel.
II.B.1.g The owner/operator shall install, calibrate, maintain, and operate a continuous monitoring
system on the incinerator stack for measuring the opacity of emissions. The opacity monitor
shall be installed so as to trigger an alarm to signal the operator that the stack emissions have
exceeded 20% opacity. At the signal of the alarm, the operator shall shut off the primary
chamber burner for a minimum of 3.5 minutes; and the burner shall remain shut off until stack
opacity drops below 20% opacity. The operator shall remain within audible range of the
incinerator alarm during the entire time period in which the incinerator is in operation. An
automatic control system which performs the same control to the primary chamber's burner
shall be considered as equivalent. [R307-401-8]
Status: In compliance. The incinerator stack is equipped with a continuous
monitoring system which triggers an alarm when there is a potential problem.
II.B.1.h All installations and facilities authorized by this AO shall be adequately and properly
maintained. All pollution-control, vendor-recommended equipment shall be installed,
maintained, and operated. Vendor's instructions or established maintenance practices that
maximize pollution control shall be used. All necessary equipment control and operating
devices, such as; pressure gauges, amp meters, volt meters, flow rate indicators, temperature
gauges, CEMs, etc., shall be installed and operated properly and easily accessible to
compliance inspectors. [R307-401-8]
Status: In Compliance. The Sandy City Animal Services is adequately and properly
maintained, and all pollution-control and maintenance practices to control pollution
are being followed.
7
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
R307-222. Emission Standards: Existing Incinerators for Hospital, Medical, Infectious Waste
Status: Not Applicable. The Sandy City Animal Services incinerator is used primarily as a
pathological incinerator, therefore, not subject to R307-222(2)(a).
R307-305. Nonattainment and Maintenance Areas for PM10: Emission Standards
Status: Compliance undetermined. Sandy City Animal Services is subject to R307-305, however,
during this inspection, the incinerator was not in operation. According to the Sandy City Animal
Services, the crematory has not been in operation since 2022.
EMISSION INVENTORY: Sandy City Animal Services is not required to submit an
emissions inventory. The following Potential to Emit (PTE)
calculations from the AO are as follows:
Pollutant Tons/yr
1. Particulate .............................................. 0.31
2. PM10 ...................................................... 0.22
3. NOx ........................................................ 0.12
4. SO2 ........................................................ 0.00
5. CO ......................................................... 0.00
6. VOCs ..................................................... 0.00
7. Aldehydes .............................................. 0.00
PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: The Sandy City Animal Services is in compliance with the
Approval Order DAQE-AN0104780004-10, dated September
14, 2010.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Look for new AO after the replacement of the
crematory.
RECOMMENDATION FOR
NSR: The Sandy City Animal Services plans to replace the crematory,
and are aware to contact NSR for a permit revocation/small
source exemption, but prefer to get the new equipment approved
through NSR when the time comes, before taking any further
action.
ATTACHMENT: Email communication