DAQ-2024-004614

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DAQC-CI102980002-23
Site ID 10298 (B1)

MEMORANDUM

TO: FILE – NRP JONES, LLC – Rubber Hose Manufacturing Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: November 22, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Juab County

INSPECTION DATE: November 16, 2023

SOURCE LOCATION: 255 West 1100 North
Nephi, UT 84648
SOURCE CONTACTS: Neil Cook, Manager
435-623-1740; [e-mail]

OPERATING STATUS: Operating normally at time of inspection.

PROCESS DESCRIPTION: Manufactures 3 1/16" and 22" ID rubber hoses. A long pipe or
twisted piece of wire, called a mandrel, is lubricated with a
nonhazardous product TM505 (perchloroethylene is no longer
used). A heated tube of rubber is then drawn over the mandrel
with the aid of a vacuum. The tube is then cooled, coated, and
braided with different types of metal or fabric thread, providing
strength to the hose. The hose is then given another coat of
rubber and threading. A black hose dye is then added. The hose
is wrapped with nylon by a wrapping machine and placed in a
vulcanizing oven, where it is heated to over 3,000 F. The nylon
is stripped off the hose and the mandrel blown out. The hose is
then pressure tested, cut to the desired length, and coiled for
shipment.

Hand-made Production: Synthetic rubber and various additives,
such as toluene, are mixed together in the Banbury mixer (black
rubber) or the Colored Mill mixer (colored rubber). The mixture
is then run through a mill that shapes and cuts the mixture into
flat, rectangular sheets. Theses sheets are wrapped around the
mandrels by hand. Any other threading, coating, and/or
wrapping are also done by hand. The hose is then wrapped with
nylon and vulcanized. After vulcanization, the hose is stripped of
the nylon, pressure tested, and prepared for shipment. The
Banbury mixer is connected to the new dust collector. The new
boilers heat the vulcanizing ovens and provide comfort heat
during the winter.

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APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN102980006-15, dated March
25, 2015
NSPS (Part 60) -Dc : Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units,

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

NRP Jones, LLC - Rubber Hose
Manufacturing Facility

1300 Post Oak Boulevard, Suite 800 255 West 1100 North
Houston, TX 77056 Nephi, UT 84648

SIC Code: 3021: (Rubber & Plastics Footwear)

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]

Status: In Compliance. Each condition from Section I was reviewed and determined to be
in compliance. The source is not currently required to submit an Emission Inventory.

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Section II: SPECIAL PROVISIONS

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

II.A.1 NRP Jones, Inc.
Manufacturer of high-pressure hoses

II.A.2 Unit # 3 and #4, CleaverBrooks boilers (new)
Natural gas-fired boilers, model number CBI 200-500-150, each rated at 20.411 MMBtu/hr

II.A.3 A dust collector (new) attached to rubber mixers
The collector contains 24 canisters. Each canister is 36 inches long and 21 inches in
diameter, made of cellulose material. The maximum air flow rate is 20,000 acfm and air-to-
cloth ratio is 1.75 to 1.

II.A.4 Unit #1, Banbury mixer (Grandfathered unit)
Banbury mixers used to mix synthetic rubber and various additives

II.A.5 Unit #2, Colored mixer (Grandfathered unit)
Colored mixer used to mix synthetic rubber and various additives

Status: In Compliance. No unapproved equipment was observed at the time of
inspection. A small diesel tractor is on site and infrequently used.

II.B Requirements and Limitations

II.B.1.a NRP Jones shall notify the Director in writing when the new equipment has been installed and
has become operational. To ensure proper credit when notifying the Director, send your
correspondence to the Director, attn: Compliance Section. If the installation has not been
completed within 18 months from the date of this AO, the Director shall be notified in writing on
the status of the installation. At that time, the Director shall require documentation of the
continuous installation of the operation and may revoke the AO. [R307-401-18]

Status: In Compliance. A previous inspection memo (DAQC-308-17) indicates that the
required notification was received.

II.B.1.b Visible emissions from any stationary point or fugitive emission source associated with the
source or with the control facilities shall not exceed 10% opacity. [R307-401-8]

II.B.1.b.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. No visible emissions were observed at the time of inspection. Refer
to the VEO form in the attachments.

II.B.1.c The dust collector shall control process streams from the Banbury and Colored Mill rubber
mixers. All exhaust air from the rubber mixers shall be routed through the dust collector before
being vented to the atmosphere. [R307-401-8]

Status: In Compliance. Exhaust from the rubber mixers is channeled to the dust collector.

II.B.1.d The following consumption limits shall not be exceeded:

A. 17,520,000 pounds of rubber products produced through the Banbury rubber mixer per
rolling 12-month period
B. 4,300,000 pounds of materials processed through the Colored mill mixer per rolling 12-
month period
C. 464 gallons of xylene used per rolling 12-month period
D. 3120 hours of operation on the Banbury rubber mixer per rolling 12-month period.
[R307-401-8]
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II.B.1.d.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months.
Records of consumption/hours of operation shall be kept for all periods when the plant is in
operation. Consumption of materials to produce rubber, including consumption of toluene,
xylene and MEK, shall be determined by materials purchased. Hours of operation of the Banbury
rubber mixer shall be determined by supervisor monitoring and maintaining of an operations log.
[R307-401-8]

Status: In Compliance. The rolling 12-month consumption totals ending in October 2023,
were as follows:

A. 1,602,496 pounds of rubber products produced through the Banbury mixer.
B. Zero pounds of material processed through the Colored mill mixer.
C. 0.40 gallons of xylene used.
D. 746 hours of operation on the Banbury mixer.

II.B.1.e The owner/operator shall use natural gas as fuel in the boilers. [R307-401-8]

Status: In Compliance. The source only uses natural gas to fuel the boilers. Natural gas is
purchased from Nephi City.

II.B.1.f The plant-wide emissions of HAPs from the solvents and associated operations shall not exceed:

3.13 tons per rolling 12-month period for toluene (fugitive and stationary)
7.31 tons per rolling 12-month period for combined HAPs (fugitive and stationary)
(including toluene). [R307-401-8]

II.B.1.f.1 Compliance with each limitation shall be determined on a rolling 12-month total. Based on the
twentieth day of each month, a new 12-month total shall be calculated using data from the
previous 12 months.

The HAP emissions shall be determined by maintaining a record of HAP emitting materials used
each month. The record shall include the following data for each material used: name of the HAP
emitting material, such as: adhesive, solvent, thinner, reducers, chemical compounds, etc., and
density of each material used (pounds per gallon)

A. Percent by weight of all HAP in each material used

B. Gallons of each HAP emitting material used

C. The amount of HAP emitted monthly by each material used shall be calculated by the
following procedure:

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

D. The amount of HAP emitted monthly from all materials used.

E. The amount of HAP reclaimed for the month shall be similarly quantified and subtracted
from the quantities calculated above to provide the monthly total HAP emissions. The amount of
HAP reclaimed for the month shall be similarly quantified and subtracted from the quantities
calculated above to provide the monthly total HAP emissions. [R307-401-8]

Status: In Compliance. Values are calculated according to the information provided in this
AO. Plant-wide emissions of HAPs from the solvents and associated operations for the
12-month rolling period ending in October 2023, are as follows:

• 0.02 tons of toluene
• 0.70 for combined HAPs

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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. This subpart is applicable to the natural gas-fired boilers in Section II.A.2.
Compliance is satisfied by the source utilizing natural gas. The source indicated that natural gas is
tracked and purchased from Nephi City.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Sulfur Content of Fuels [R307-203]
Status: In Compliance. A fuel purchase invoice provided by the fuel supplier, RelaDyne, indicated
the source utilizes #2 ultra-low sulfur diesel. The source infrequently operates a small diesel tractor
using the provided fuel.

Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

Status: In Compliance. No fugitive emissions or dust were observed during the inspection. The site
is mostly paved.

Stationary Sources [R307-210]

Status: In Compliance. This rule is satisfied by compliance with 40 CFR Part 60 Subpart Dc. Refer
to the Federal Requirements Section for more details.

EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from NRP Jones, LLC -
Rubber Hose Manufacturing Facility on the Approval Order (AO) DAQE-AN102980006-15, dated
March 25, 2015. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
Carbon Monoxide 16.88
Nitrogen Oxides 8.74
Particulate Matter - PM10 17.37
Particulate Matter - PM2.5 8.74
Sulfur Dioxide 0.17
Volatile Organic Compounds 30.27

Hazardous Air Pollutant PTE lbs/yr
Formaldehyde (CAS #50000) 20
Generic HAPs (CAS #GHAPS) 14620
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PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN102980006-15,
dated March 25, 2015: In Compliance. The facility appears to be
well maintained and operated. Required records were current and
made available during the inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: The source does not operate on Fridays. Inspect as normal.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, Production Totals, Natural Gas Verification, Fuel
Purchase Invoice, and Certificate of Analysis