DAQ-2024-004550

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DAQC-CI101810001-23
Site ID 10181 (B1)

MEMORANDUM

TO: FILE – COMPANION SYSTEMS INCORPORATED – Bank Teller Machine
Production Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: November 15, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Davis County

INSPECTION DATE: September 27, 2023

SOURCE LOCATION: 645 West 200 North
North Salt Lake, UT 84054
DIRECTIONS: Drive north on Redwood Road to 200 North

SOURCE CONTACTS: Aaron Lee, Cost Accountant
801-956-8082 ext 364, [e-mail]

OPERATING STATUS: Operating normally.

PROCESS DESCRIPTION: Companion Systems has been recently acquired by CSI
Acquisitions Corporation, but is still doing business using the
original name as stated on their current AO. This facility
manufactures custom modular mini-banking branches,
backdrops, enclosures, and wall surrounds for ATMs out of
fiberglass, wood, using some metal frames, and formed plastics.

Mold fabrication: A wooden tooling is constructed to the design
and shape of the required product. The tooling is moved to the
tooling gelcoat booth and coated. Once cured, wax is applied to
the tooling to ease separation of the parts. The waxed tooling is
sprayed with gelcoat and moved into the lamination room.
Ceramic barrier coat, chop, and resin are applied in multiple
layers until the desired thickness is achieved. After the mold
cures at room temperature, the mold and tooling are separated.
The mold is prepared for use in production by grinding in the
tooling grinding booth.

Product fabrication - Gelcoat: The mold is prepared for the
application of gelcoat, the surface coat of the finished product.
The requested color of gelcoat is mixed and applied to the mold
surface. The gel coated mold is then moved to the barrier coat
and laminating area.

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Product Fabrication - Barrier coat and laminating: The barrier
coat is applied to the gel coated surface. Then the mold is moved
to laminating where the chop strand is mixed with the resin to
the desired thickness. The chop/resin mixture is then rolled onto
the surface of the mold to take the mold shape. The mold is
moved to the cure area to allow chemicals to harden at room
temperature.

Mold Removal, Cleanup, and Assembly: The fabricated part is
removed from the mold and moved to the main building's
grinding area to remove rough edges and prepare it for painting.
The grinding area is controlled with a Torit filter cartridge dust
collector. Body work is performed on the part to repair any
imperfections.

Paint Booth: The surface is prepared by cleaning it with solvent.
The primer coat and several coats of paint are applied to obtain
the desired color and surface texture.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN101810009-17, dated
December 6, 2017
SOURCE EVALUATION:
Name of Permittee: Permitted Location:

Companion Systems Incorporated - Bank Teller
Machine Production Plant

645 West 200 North
P.O. Box 540636
North Salt Lake, UT 84054

645 West 200 North
North Salt Lake, UT 84054

SIC Code: 3578: (Calculating & Accounting Machines, Except Electronic Computers)

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
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maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

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

Status: In Compliance. No limits set forth in this AO 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 during the
inspection. Inspections for the equipment referenced on this AO date back to 2020. No
breakdowns have been reported since the previous inspection. The source stated that filters
on all the paint booths are changed every 3-6 months. An emissions inventory was
submitted for the 2020 activity year. A SLEIS Summary Report is attached for reference.
The 2023 activity year report will be due on April 15, 2024.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Companion Systems Inc.
Manufacturer of Enclosures of Bank Teller Machines

II.A.2 Tooling Gelcoat Booth
Equipment: Air, airless, air assist and HVLP spray guns; two (2) exhaust stacks

II.A.3 Tooling Laminating
Equipment: One (1) internal mix airless chop gun and one (1) spray gun; two (2) exhaust stacks

II.A.4 Gelcoat/Paint Booths
Gelcoat/paint booth
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack
Paint booth with 1 MMBtu/hr natural gas-fired roof-mounted heater - new equipment
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.5 Production Fabrication Area
Barrier coat and lamination (Chop Booth)
Equipment: One (1) flow coat chop gun; one (1) internal mix gun, one (1) spray gun, and three (3)
exhaust stacks

II.A.6 Production Grinding
Two (2) booths, mold removal, clean up and assembly
Equipment: one (1) dust collector

II.A.7 Front Shop North Paint Booths (total 5 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth

II.A.8 Back Shop South Paint Booths (total 2 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth
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II.A.9 Acetone Recycling

II.A.10 Back Shop Enclosed Paint Booth

Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.11 Back Shop Enclosed Paint Booth
Natural gas heater rated at 1 MMBtu/hr
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks

II.A.12 Eight (8) Closed Dip Tanks
Located at:
Tooling gelcoat booth (1)
Tooling laminating area (1)
Production gelcoating area (1)
Laminating area (2)
Chop booth (1)
North paint area (1)
Back shop paint area (1)

II.A.13 One (1) Cut and Buff Booth (Back Shop)
This booth is equipped with two (2) air cleaners. Both vent back to the building
II.A.14
Dust Collectors (for information only)
One (1) Pattern Shop Torit dust collector (vents back into the building)
One (1) Tooling Dust Collector (vents back into the building)

Status: In Compliance. The equipment has been installed as described with the exception of
II.A.9 which is a process no longer being done at the facility. No other changes or
additions were found during the inspection.

II.B Requirements and Limitations

II.B.1 Companion Systems Incorporated shall comply with the following requirements

II.B.1.a The Pattern Shop Torit shall vent back into the building. [R307-401-8]

Status: In Compliance. The Pattern Shop Torit system vents back into the building and not
to the outside air.

II.B.1.b The Tooling Dust Collector shall vent back into the building. [R307-401-8]

Status: In Compliance. The Tooling Dust Collector vents back into the building.

II.B.1.c All filters installed in the work areas in II.A.2 through II.A.5 and II.A.7 through II.A.11 shall
control process streams from their respective processes. All exhaust air from the work areas shall
be routed through their respective filters before being vented to the atmosphere. The filters shall
be maintained and replaced in accordance with manufacturer's recommendations or instructions.
[R307-401-8]

Status: In Compliance. The filters installed in the referenced areas process streams as
described. The filters were observed in place and appeared to be in good condition. Filter
change out records are kept at each booth. Most filters are replaced every 3 to 6 months.

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II.B.1.d Visible emissions from the following emission points shall not exceed the following:

A. All filters and dust collectors - 10% opacity
B. All paint booths - 10% opacity
C. All natural gas combustion - 10% opacity. [R307-401-8]

Status: In Compliance. No visible emissions were observed from any point or vent.

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

Status: In Compliance. The observations were performed as per the requirements of
Method 9. See the attached VEO.

II.B.1.e The following production limits shall not be exceeded:

A. 20 hours per calendar day and 360 operating days per rolling 12-month period for mold
fabrication.
B. 20 hours per calendar day and 360 operating days per rolling 12-month period for production
gelcoat.
C. 20 hours per calendar day and 360 operating days per rolling 12-month period for barrier
coat/ laminating.
D. 20 hours per calendar day and 360 operating days per rolling 12-month period for painting.
[R307-401-8]

Status: In Compliance. The site contact stated that the facility is typically open for only 8
hours each day with a few 3 to 6 hour shifts occurring on Saturdays. The interviewed cost
accountant, who was the facility contact at the time of this inspection, stated that not all of
the hours that the facility is open are actually spent on the above production tasks and that
the daily production line averages around 6 hours a day.

II.B.1.e.1 The owner/operator shall calculate total hours in a calendar day by adding all operating hours
from midnight to midnight. 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 of production shall be kept for all periods when the plant
is in operation. The records of production shall be kept on a daily basis. Hours of operation shall
be determined by the supervisor who is monitoring and maintaining the operations log.
[R307-401-8]

Status: In Compliance. The site contact stated that the average employee numbers varied
substantially during the 12-month rolling period of September 2022, through August 2023,
due to staffing changes that occurred with the parent company changes, but that the total
hours of time spent working at the Condition II.B.1.e listed tasks never exceeded 20 hours
per day, as no more than two employees worked on the above defined tasks for more than 6
hours during any given day.

II.B.1.f The owner/operator shall only use natural gas as a fuel. [R307-401-8]

Status: In Compliance. Only natural gas is used as fuel.

II.B.1.g The owner/operator shall comply with applicable requirements in R307-342, 350, 353 and 357.
[R307-342, R307-350]

Status: In Compliance. See the area rules section below. The inspection memo
DAQC-207-22, quoted a statement from NSR Engineer, Enqiang He, that R307-357:
Consumer Products, does not apply to this operation and that the reference should be
removed from the AO the next time a permit modification occurs.

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II.B.1.h The plant-wide emissions of VOCs and HAPs from the paint booths, degreasers, contact cement
applicators, etc. and associated operations shall not exceed:

15.00 tons per rolling 12-month period for VOCs
0.25 tons per rolling 12-month period for dimethylphalate
0.50 tons per rolling 12-month period for ethyl benzene
0.02 tons per rolling 12-month period for glycol ether
0.02 tons per rolling 12-month period for methanol
0.40 tons per rolling 12-month period for methyl methacrylate
0.22 tons per rolling 12-month period for methylene chloride
0.30 tons per rolling 12-month period for methyl isobutyl ketone
7.50 tons per rolling 12-month period for styrene
0.50 tons per rolling 12-month period for toluene
1.25 tons per rolling 12-month period for xylene
0.01 tons per rolling 12-month period for cadmium compound
0.01 tons per rolling 12-month period for chromium compound
0.04 tons per rolling 12-month period for lead chromate, and
11.02 tons per rolling 12-month period for all HAPs combined. [R307-401-8]

Status: In Compliance. 12-month rolling totals for the period of September 2022, through
August 2023, were reported as follows:

VOC = 2.1965 tons (4393 lbs)
dimethylphalate = 0
ethyl benzene = 0.05 tons (101.00 lbs)
glycol ether = 0
methanol = 0
methyl methacrylate = 0.01 (11.86 lbs)
methylene chloride = 0
methyl isobutyl ketones = 0
styrene = 0.46 tons (924.58 lbs)
toluene = 0.08 tons (157.00 lbs)
xylene = 0.28 tons (564.00 lbs)
cadmium compound = 0
chromium compound = 0
lead chromate = 0
combined HAPs = 1 ton (2009.63 lbs)

See the attached "Rolling 12-month Inventory 09/01/2022 to 8/31/2023, Form
F1:Hazardous Air Pollutants Calculations".

II.B.1.h.1 Compliance with each limitation shall be determined on a rolling 12-month total. No later than
20 days after the end of each month, a new 12-month total shall be calculated using data from the
previous 12 months. [R307-401-8]

Status: In Compliance. Calculations based on product use and the recommended emission
factors. See the attached "Rolling 12-month Inventory 09/01/2022 to 8/31/2023, Form F1:
Hazardous Air Pollutants Calculations".

II.B.1.h.2 The VOC and HAP emissions shall be determined by maintaining a record of VOC- and HAP-
emitting materials used each month. The record shall include the following data for each material
used:

A. Name of the VOC- and HAPs-emitting material, such as: paint, adhesive, solvent,
thinner, reducers, chemical compounds, toxics, isocyanates, etc.
B. Density of each material used (pounds per gallon)
C. Percent by weight of all VOC and HAP in each material used
D. Gallons of each VOC- and HAP-emitting material used
E. The amount of VOC and HAP emitted monthly by each material used shall be calculated
by the following procedure:
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VOC = % VOC by Weight x [Density ( lb )] x Gal Consumed x 1 ton
(100) (gal) 2000 lb

HAP = % HAP by Weight x [Density ( lb )] x Gal Consumed x 1 ton
(100) (gal) 2000 lb

F. The amount of VOC or HAP emitted monthly from all materials used.
G. The amount of VOCs or HAPs reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above to provide the monthly total VOC or
HAP emissions. [R307-401-8]

Status: In Compliance. See the attached "Rolling 12-month Inventory 09/01/2022 to
8/31/2023, Form F1: Hazardous Air Pollutants Calculations".

Section III: APPLICABLE FEDERAL REQUIREMENTS

No Federal Subparts currently apply to this operation.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Ozone Nonattainment and Maintenance Areas [R307-325]

Status: In Compliance. The current AO has a reference to this Area Source Rule on Condition
II.B.1.g, with the statement that the owner/operator shall comply with the applicable requirements.
VOC containing materials are stored in sealed containers. The source contact stated that in the event
that a spill should occur it would be minimized and immediately cleaned.

Adhesives and Sealants [R307-342]

Status: Not applicable. The current AO has a reference to this Area Source Rule on Condition
II.B.1.g, with the statement that the owner/operator shall comply with the applicable requirements.
The source uses an acrylic adhesive sold in commercially available 400 ml (13.525 ounce) caulk tubes.
Hand application methods are used. R-307-342-3(1)(d) exempts "Adhesives, sealants, adhesive
primer or sealant primers that are sold or supplied by the manufacturer in containers with a net
volume of 16 fluid ounces of less or that have a new weight of one pound or less, except plastic cement
welding adhesives and contact adhesives".

Miscellaneous Metal Parts and Products Coatings [R307-350]

Status: Not currently applicable. The AO has a reference to this Area Source Rule on Condition
II.B.1.g, with the statement that the owner/operator shall comply with the applicable requirements.
Companion Systems, cost accountant, stated that paints that are used on metal surfaces are tinted
with small amounts of a commercially available metallic product, but the resulting paints are used
for design emblems and letter stenciling. Stencil applications are exempt from this rule as per
R307-350-3(2)(a).

Plastic Parts Coatings [R307-353]

Status: Not currently applicable. The gel and ceramic coatings referenced on the emissions spreadsheet
are used for the shapes created from the wood and fiberglass molds. The plastic used in the custom
barriers are pre-formed sheets.

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EMISSION INVENTORY:

An Emission Inventory for the 2020 activity year has been recorded in SLEIS. See the attached SLEIS
Inventory Summary Report. The next Inventory will be due on April 15, 2024.

A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN101810009-17, dated
December 6, 2017, is provided.
PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 432.00
Carbon Monoxide 0.20
Nitrogen Oxides 0.28
Particulate Matter - PM10 3.16
Particulate Matter - PM2.5 0.04
Volatile Organic Compounds 15.00

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Cadmium Compounds (CAS #CAE750) 20
Chromium Compounds (CAS #CMJ500) 20
Dimethyl Phthalate (CAS #131113) 500
Ethyl Benzene (CAS #100414) 1000
Glycol Ethers (CAS #EDF109) 40
Lead Chromate (CAS #18454121) 80
Methanol (CAS #67561) 40
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 600
Methyl Methacrylate (CAS #80626) 800
Methylene Chloride (Dichloromethane) (CAS #75092) 440
Styrene (CAS #100425) 15000
Toluene (CAS #108883) 1000
Xylenes (Isomers And Mixture) (CAS #1330207) 2500

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Companion Systems Incorporated should be considered to be in
compliance with the AO AN101810009-17, dated December 6,
2017, at the time of this inspection.

HPV STATUS: Not Applicable.

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RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual maintaining the same targeting frequency. This
facility is a secure operation with limited staff. It is
recommended that inspections are pre-scheduled as the front
door is typically locked and will require a site contact to gain
entrance. This operation, while still doing business as
Companion Systems Incorporated, was recently acquired by CSI
Acquisitions Corporation. Most of the staff at the time of this
inspection were recently hired and a new permanent EHS
manager had yet to be assigned. The information for this
compliance review was provided by the organization's cost
accountant. While the information provided by this contact
appeared to be accurate, the VOC product lines and the
described process should be reviewed again during the next
inspection when a new environmental manager contact is
available. Previous inspections for this operation stated that the
VOC containing coatings were compliant with the above
referenced State Rules, but the memos did not include attached
MSD Sheets. The memos also did not provide a description of
which material substrates were applied with the paints or
coatings.

NSR RECOMMENDATIONS: Review the applicability of UAC R307-342, R307-350, and
R307-353. NSR Engineer, Enqiang He, has previously stated
that R307-357 for Commercial Products does not apply and
should be removed as a reference on Condition II.B.1.g.

ATTACHMENTS: VEO, Form F1: Hazardous Air Pollutants Calculations, and
SLEIS Emission Inventory Summary Report.
Rolling 12 Month Inventory 09/01/2022 to 08/31/2023
Form F1: Hazardous Air Pollutants Calculations
CSI Acquisitions Corp D.B.A. Companion Systems
Fiberglass Manufacturing
Process Pt. Source Chemical Name Weight of Chemical X Emission Factor (lb/yr)"="Emissions (lb/yr)
ID Used (lb/yr)
Paint 1-5, 13-15,20,21 Chromium Compounds 0 1 0.00
Glycol Ethers 0 1 0.00
Hexamethylene-1,6-diisocyanate 0 1 0.00
Methyl Ethyl Ketone (2-Butanone)251.18 1 251.18
Toluene 157 1 157.00
Xylenes 564 1 564.00
Ethyl Benzene 101 1 101.00
Methyl Isobutyl Ketone 0 1 0.00
(stack)Gelcoat 6-8 Styrene 1005 0.325 326.63
Dimethyl Phthalate 0 0.0004 0.00
Methyl Ethyl Ketone (2-Butanone)0 0.325 0.00
Methyl Methacrylate 11.08 0.75 8.31
Methyl Isobutyl Ketone 0 1 0.00
(stack)Chop 9 Styrene 4640.24 0.107 496.51
Dimethyl Phthalate 0.00 0.0004 0.00
Methyl Ethyl Ketone (2-Butanone)0.00 0.325 0.00
(stack)Ceramic 10 Styrene 0 0.13 0.00
Dimethyl Phthalate 0.00 0.0004 0.00
Methyl Ethyl Ketone (2-Butanone)0.00 0.325 0.00
(fugitive)Laminating B1-12 Styrene 580.03 0.169 98.03
Dimethyl Phthalate 0.00 0.0004 0.00
Methyl Ethyl Ketone (2-Butanone)0.00 0.325 0.00
Adhesive 11 Toluene 0 1 0.00
(stack)Tool Gelcoat 16 Styrene 0 0.325 0.00
Dimethyl Phthalate 0 0.325 0.00
Methyl Ethyl Ketone (2-Butanone)0 0.325 0.00
Methyl Methacrylate 0 0.037 0.00
(stack)Tooling 18-19 Styrene 26.365 0.13 3.43
Dimethyl Phthalate 0.00 0.0004 0.00
Methyl Ethyl Ketone (2-Butanone)0.00 0.325 0.00
RTM Styrene 0 0.01 0.0000
Dimethyl Phthalate 0.00 0.0004 0.0000
Methyl Ethyl Ketone (2-Butanone)0.00 0.01 0.0000
Adhesive B3-6 Methyl Methacrylate 96 0.037 3.55
Methylene Chloride 0 1 0.00
Methanol Methanol 0 1 0.00
Total Pounds 2009.63
Total Tons 1.00
Rolling 12 Month Total
HAP 12 mo. Lbs 12 mo. Tons LIMITS (tons)Balance
Glycol Ethers 0.00 0.00 0.02 -0.02
Cadmium Compound 0.00 0.00 0.01 -0.01
Toluene 157.00 0.08 0.5 -0.42
Xylenes 564.00 0.28 1.25 -0.97
Ethyl Benzene 101.00 0.05 0.5 -0.45
Methyl Isobutyl Ketone 0.00 0.00 0.3 -0.30
Styrene 924.58 0.46 7.5 -7.04
Dimethyl Phthalate 0.00 0.00 0.25 -0.25
Methyl Methacrylate 11.86 0.01 0.4 -0.39
Methylene Chloride 0.00 0 0.22 -0.22
Methanol 0.00 0 0.02 -0.02
VOC 4393 2.1965 15 -12.8035
2020 Emissions Inventory Report
Emissions Summary for Companion Systems Incorporated- Fiberglass Manufacturing (10181)
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons, excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
VOC Volatile Organic Compounds 3.53552 <.00001 3.53552

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
100425 Styrene (HAP)VOC 4.213
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.182

*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
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