HomeMy WebLinkAboutDAQ-2024-0051311
DAQC-CI101910001-24
Site ID 10191 (B1)
MEMORANDUM
TO: FILE – BONNELL ALUMINUM (CLEARFIELD), INC. – Aluminum Specialties
Plant
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Irene Tucker, Environmental Scientist
DATE: February 7, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Davis County
INSPECTION DATE: December 14, 2023
SOURCE LOCATION: Building H-11 Freeport Center
Clearfield, UT 84016
SOURCE CONTACT: Jason Wilkins, Anodizing Engineer, 801-774-3212,
Jason.Wilkins@bonnellaluminum.com
OPERATING STATUS: In operation.
PROCESS DESCRIPTION: Bonnell Aluminum operates an aluminum extrusion and
fabrication facility. First, aluminum billets are heated in one of
two billet heaters. The billets are then placed into a ram which
pushes the heated billet through an extruder die. Thus, allowing
the aluminum to be made into desired shapes. Next, the extruded
aluminum is cut to certain lengths and cooled. Once cooled the
pieces are processed according to customer specifications, which
include sawing, buffing, hammering, punching, and bending.
Some of the extruded aluminum requires anodizing which is
performed in tanks of Phosphoric and Sulfuric acid. These tanks
vent to the north and middle scrubbers before venting to the
atmosphere. The anodizing process also entails tubs of hot water
used for rinsing. The water vapor is vented directly outside
through the vent labeled south scrubber. The aluminum may also
be heat-aged in an oven to increase hardness. The aluminum is
cleaned from the steel dies by reaction with caustic soda or
sodium hydroxide. Emissions from this cleaning process are
vented outside through the two northern scrubbers. Finally, the
completed product is packaged and shipped.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN101910016-20, dated
September 30, 2020
/ :
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SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Bonnell Aluminum (Clearfield), Inc.
Aluminum Specialties Plant
Building H-11 Freeport Center
P.O. Box 160350
Building H-11 Freeport Center
Clearfield, UT 84016 Clearfield, UT 84016
SIC Code: 3354: (Aluminum Extruded Products)
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. [R307-401-18]
Status: In Compliance. There were no modifications to the equipment or processes
approved by this AO. Bonnell Aluminum maintains records for a minimum of two years.
Bonnell Aluminum maintains records of maintenance activities performed on authorized
equipment of this AO. Bonnell Aluminum reported a fan malfunction on the Bright Dip
Scrubber to the DAQ on January 4, 2024. Bonnell Aluminum is not registered in SLEIS,
therefore, not required to submit an Emissions Inventory Report at this time. Bonnell
Aluminum sent a notification letter to DAQ dated September 19, 2023, following the
installation and operation of the BD Trimere Process Tank Wet Scrubber.
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SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
II.A.1 Aluminum Specialties Plant
Aluminum extrusions, anodizing and fabrication
II.A.2 O Billet Heater
Fuel: Natural Gas Rating: 7.5 MMBtu/hr
II.A.3 U Billet Heater
Fuel: Natural Gas Rating: 5.8 MMBtu/hr
II.A.4 One (1) Boiler
Fuel: Natural Gas Rating: 6.695 MMBtu/hr
II.A.5 OG Aging Oven
Fuel: Natural Gas Rating: 3.0 MMBtu/hr
II.A.6 B Aging Oven
Fuel: Natural Gas Rating: 2.5 MMBtu/hr
II.A.7 G Aging Oven
Fuel: Natural Gas Rating: 3.0 MMBtu/hr
II.A.8 Etch Trimere (Wet Scrubber)
Scrubber type: cyclonic
Scrubbing medium: aqueous sodium hydroxide solution
II.A.9 BD Trimere (Wet Scrubber) (new)
Scrubber type: two-stage
Scrubbing medium: aqueous sodium hydroxide solution
II.A.10 Anodic Trimere (Wet Scrubber)
Scrubber type: cyclonic
Scrubbing medium: aqueous sodium hydroxide solution
II.A.11 Sealing Process Exhaust Fan
converted scrubber to remove steam from the facility
Included for informational purposes only
Status: In Compliance. There was no new or unapproved equipment observed
onsite.
SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 The Aluminum Specialties Plant Requirements
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II.B.1.a The owner/operator shall not process more than 5,300,000 ft2 of aluminum through the BD tank
per rolling 12-month period. [R307-401-8]
Status: In Compliance. The rolling 12-month Aluminum production from December 2022
to November 2023 indicated 1,594,074 ft2. See the attachment for additional information.
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 20th day of each month using data from the previous 12 months. Records
of BD tank aluminum throughput shall be kept for all periods when the plant is in operation. BD
tank aluminum throughput shall be determined by examination of process records. The BD tank
aluminum throughput processing records shall be kept on a daily basis. [R307-401-8]
Status: In Compliance. Daily BD tank aluminum throughput was reviewed during this
inspection. Bonnell Aluminum maintains records of daily BD tank aluminum throughput.
II.B.1.b Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions on
site to exceed 20% opacity. [R307-201-3]
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. There were no visible emissions observed during this inspection.
See the attachment for additional information. The opacity observations were conducted
according to 40 CFR 60, Appendix A, Method 9.
II.B.2
II.B.2.a
HAP Limitations:
The owner/operator shall not use hydrochloric acid in the process tanks or the associated
processes on site. [R307-401-8]. [R307-401-8]
Status: In Compliance. Bonnell Aluminum no longer uses hydrochloric acid in the process
tanks. Bonnell Aluminum uses phosphoric acid, nitric acid, sulfuric acid in the scrubbers.
II.B.3 Heaters, Boilers, and Oven Requirements
II.B.3.a The owner/operator shall not allow visible emissions from any stationary source combusting
natural gas to exceed 10% opacity. [R307-401-8]
Status: In Compliance. There were no visible emissions observed from the boilers and
ovens during this inspection.
II.B.4 Scrubber Requirements
II.B.4.a The owner/operator shall route all exhaust air from the Etch Trimere process through the Etch
Trimere Process Tanks Wet Scrubber before being vented to the atmosphere. [R307-401-8]
Status: In Compliance. All exhaust air from the Etch Trimere process goes through the
Etch Trimere Process Tanks Wet Scrubber before being vented to the atmosphere as
required by this AO Condition.
II.B.4.b The owner/operator shall route all exhaust air from the BD Trimere process tank through the BD
Trimere Process Tank Wet Scrubber before being vented to the atmosphere. [R307-401-8]
Status: In Compliance. All exhaust air from the BD Trimere process goes through the BD
Trimere Process Tanks Wet Scrubber before being vented to the atmosphere as required
by this AO Condition.
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II.B.4.c The owner/operator shall route all exhaust air from the Anodic Trimere process tanks through the
Anodic Process Tanks Wet Scrubber before being vented to the atmosphere. [R307-401-8]
Status: In Compliance. All exhaust air from the Anodic Trimere process goes through the
Anodic Process Tanks Wet Scrubber before being vented to the atmosphere as required by
this AO Condition.
II.B.4.d The owner/operator shall maintain the operating parameters for the Etch Process Tanks Wet
Scrubber and the Anodic Trimere Process Tank Wet Scrubber within the following indicated
ranges:
1. The pressure drop shall not be less than 1.5 inches of water column or more than 4.0 inches
of water column.
2. The liquid flow rate shall not be less than 20 gallons per minute or more than 28 gallons per
minute. [R307-401-8]
Status: In Compliance. During this inspection the pressure drop of the Etch Process Tanks
Wet Scrubber read 1.78 inches of water column with a flow rate of 27.7 gallons per minute.
The Anodic Trimere Process Tank Wet Scrubber read 2.73 inches of water column with a
flow rate of 27.3 gallons per minute. See the attachment for additional information.
II.B.4.d.1
II.B.4.e
II.B.4.e.1
The owner/operator shall monitor the operating parameters for each scrubber with equipment
located such that an inspector/operator can safely read the output any time. The monitoring
devices shall measure within the following increments:
A. One-inch water column increments or less for pressure drop
B. 2.4 gallons per minute increments or less for liquid flow rate
The owner/operator shall record the readings each operational day. [R307-401-8]
Status: In Compliance. During this inspection, the flow rate and the inches of water
column were within the given increments.
The owner/operator shall operate the BD Trimere Process Tank Wet Scrubber within the
manufacturer's recommended parameters at all times the BD tank is actively used. [R307-401-8]
Status: In Compliance. Bonnell Aluminum confirmed that the operation of the BD
Trimere Process Tank Wet Scrubber was in accordance with the recommended parameters
by the manufacturer.
The owner/operator shall retain documents from the BD Trimere Process Tank Wet Scrubber
manufacturer indicating the manufacturer's recommended pressure drop range across the
scrubber and the recommended minimum flow rate of scrubbing liquid through the scrubber.
[R307-401-8
Status: In Compliance. Bonnell Aluminum retains the manufacturer’s manual with the
recommended pressure drop range across the scrubber and the recommended minimum
flow rate of the scrubbing liquid through the scrubber.
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II.B.4.e.2 The owner/operator shall install, calibrate, maintain, and operate monitoring devices for the
continuous measurement of the scrubbing liquid flow rate and the pressure drop across the BD
Trimere Process Tank Wet Scrubber. The owner/operator shall calibrate the monitoring devices
on an annual basis. The owner/operator shall record and maintain daily readings of the liquid
flow rate and pressure drop on the scrubber once per operational day. [R307-401-8]
Status: In Compliance. The records reviewed indicated that the Flow meters were
calibrated on January 19, 2023, and the Pressure Gauge on the Trimer Manometer was
calibrated on November 8, 2023.
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.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
R307-309: Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive
Dust
Status: In Compliance. There were no fugitive emissions and dust observed during this inspection.
EMISSION INVENTORY: Status: Not Applicable at this time.
Listed before are the Actual Emissions Inventory provided from Bonnell Aluminum (Clearfield), Inc. –
Aluminum Specialties Plant. A comparison of the estimated total potential emissions (PTE) Approval
Order (AO) DAQE-AN101910016-20, dated September 30, 2020. PTE are supplied for supplemental
purposes only.
Criteria Pollutant PTE tons/yr Actuals tons/yr
Ammonia
CO2 Equivalent 14773.00
Carbon Monoxide 10.28
Nitrogen Oxides 12.51
Particulate Matter - PM10 4.08
Particulate Matter - PM2.5 4.08
Sulfur Dioxide 0.07
Volatile Organic Compounds 0.67
Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Hexane (CAS #110543) 440
Generic HAPs (CAS #GHAPS) 40
Total HAPs 0.24
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PREVIOUS ENFORCEMENT
ACTIONS: CA issued on February 13, 2019, for exceeding production
limits. See DAQC-0183-19 for additional information.
COMPLIANCE STATUS &
RECOMMENDATIONS: Bonnell Aluminum is in compliance with the conditions in
Approval Order (AO) DAQE-AN101910016-20, dated
September 30, 2020. Bonnell Aluminum maintained good
housekeeping practices.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Be ready to watch a Safety Video. Required
PPE includes a hard hat, safety glasses with side shields, arm
coverings, long sleeve shirt, long pants, and steel-toe boots.
NSR RECOMMENDATIONS: None at this time.
ATTACHMENTS: Applicable Supporting Documentation Included