DAQ-2024-004561

1
DAQC-CI118290001-23
Site ID 11829 (B1)

MEMORANDUM

TO: FILE – DETROIT DIESEL REMANUFACTURING, LLC

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: November 1, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Tooele County

INSPECTION DATE: September 28, 2023

SOURCE LOCATION: 100 South Lodestone Way
Tooele, UT 84074
DIRECTIONS: From I-80 west bound, take Exit 94, continue on State Road 179
to Lodestone Way.

SOURCE CONTACTS: Derek Terry, EHS Engineer
435-843-6034 [e-mail]

OPERATING STATUS: Operating normally.

PROCESS DESCRIPTION: Detroit Diesel Remanufacturing, LLC receives, disassembles,
cleans, and remanufactures diesel engines and engine
components. The engines, engine parts, and components such as
turbo chargers, oil pumps, injectors, and water pumps are
trucked to the facility where they are inspected and
disassembled, then cleaned and remanufactured utilizing various
machining and repair processes such as: baking, glass beading,
shot blasting, grinding, sanding, honing, welding, and
machining. The remanufactured components are then assembled,
painted, and packaged for shipping to the distribution network.
Some complete engines are also tested prior to shipping. The
engines are tested by mounting them in a DYNO test cell and
operating the engine for a prescribed time under various loads
and speeds and recording the engine performance. The majority
of these test runs are about 1 hour in duration but some last for
several hours. The emissions resulting from these tests are
exhausted through engine muffler systems and exhausted out
stacks mounted on the roof of the building. Cameras are focused
on the stack vents to monitor emissions. Paint booths are
equipped with particulate arrestor filters and are exhausted out
the roof of the building. Welding, sand blasting,
and grinding operations are all controlled by dust collecting
baghouses.

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APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN118290014-20, dated
December 24, 2020
MACT (Part 63) - CCCCCC: National Emission Standards for
Hazardous Air Pollutants for Source Category: Gasoline
Dispensing Facilities – no longer applicable,
UAC R307-325 Ozone Nonattainment and Maintenance Areas:
General Requirements
UAC R307-335 Degreasing and Solvent Cleaning Operations
UAC R307-350 Miscellaneous Metal Pars and Products Coatings

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Detroit Remanufacturing LLC - Engine
Maintenance Facility

13400 Outer Drive West 100 South Lodestone Way
Detroit, MI 48239 Tooele, UT 84074

SIC Code: 7538: (General Automotive Repair Shops)

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]

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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 with conditions I.1 through 1.6 at the time of this inspection. No
Emissions Inventory has yet been required for this source. The requirement to provide a
startup notification for new equipment was discussed at the time of this inspection and the
previous February 28, 2022, inspection (DAQC-1306-22). An ongoing point of confusion for
startup notifications remains for this site as not all of the equipment submitted on the July
2020, NOI for the December 24, 2020, AO, was actually included on the permitted list. See
the status for Section II for more information. A NOI is in process at the time of this
inspection to include all of the submitted equipment. A full startup notification is expected
following the completion of the corrected AO.

Section II: SPECIAL PROVISIONS

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

II.A.1 Detroit Diesel Remanufacturing, LLC

II.A.2 Maintenance Cartridge Dust Collector
Controls fumes from MIG welding

II.A.3 Once Box Cartridge Dust Collector
Controls fumes from plasma cutting

II.A.4 Glass Beader Baghouse
Controls emissions from 6 glass bead abrasive blaster units

II.A.5 Spinner/Hanger External Dust Collector

II.A.6 Double Table Blaster External Dust Collector

II.A.7 Tumble Blasters
2 units (vent to internal dust collector)

II.A.8 Steel Shot Blaster
Vents to internal dust collector

II.A.9 Various Degreasing Tanks
Contents: solvent based cleaner

II.A.10 Engine Test Cells
Fourteen (14) total /six (6) operational

II.A.11 Thermal Cleaning Ovens
3 units, equipped with afterburners
Maximum rating: 2.25 MMbtu/hr (each)
Fuel: Natural Gas

II.A.12 Paint Booths
2 units

II.A.13 Proceco Parts Washer

II.A.14 Various Heaters
Includes: Parts Washer heater
Maximum rating: less than 5.00 MMBtu/hr (each)
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II.A.15 Various Non-volatile Degreasing Tanks
For informational purposes only

II.A.16 TAC Welding Operations
For informational purposes only

II.A.17 Waste Water Treatment
For informational purposes only

II.A.18 Cooling Tower
Rating: 250 Gal/min
Controls: High Efficiency Drift Eliminator

II.A.19 Four (4) HVAC units
Rating: 10 MMBtu/hr each
Fuel: Natural Gas

II.A.20 Two (2) Storage Tanks
Storage Tank 1
Capacity: 7,000 gallons
Contents: Diesel Fuel

Storage Tank 2
Capacity: 150 Gallons
Contents: Gasoline
MACT Applicability: Subpart CCCCCC

II.A.21 Four (4) Blow off Tables

II.A.22 Four (4) Dust Collectors
Controls emissions from blow off tables

II.A.23 Miscellaneous Combustion Equipment
Rating: <5MMBtu/hr

*Included for informational purposes only

Status: In Compliance. The equipment referenced has been installed and is operating
with the following exceptions: II.A.8, the Steel Shot Blaster has been removed.
II.A.11, should have permitted a total of 6 Thermal Cleaning Ovens, plus 2
Drying Ovens as submitted on the 2020 NOI. See the attached 2020 NOI
reference pages. Each oven is equipped with an afterburner to control
emissions. Each oven has a digital gauge that indicates the temperature of both
the oven and the afterburners (See the attached 2020 NOI statement and the
Recommendations for NSR Permitting Review). II.A.20, Storage Tank #2 is
now only used for diesel fuel, no gasoline is stored on site. II.A.22, the four (4)
Dust Collectors, should indicate 5 dust collectors, however, all the collectors
vent internally and may not require a permit. Other additional process
information includes: II.A.9, the Various Degreasing Tanks, are equipped with
lids that remain closed when not in use. The tanks use Zep Tec-Sol as a solvent.
II.A.12, the Paint Booths are equipped with magnehelic gauges to indicate
proper air flow for the filters.

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II.B Requirements and Limitations

II.B.1 Detroit Diesel Remanufacturing, LLC shall be subject to the following

II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any stationary or fugitive emission source on site to exceed 10 percent opacity. [R307-401-8]

Status: In Compliance. No visible emissions were observed from any point during the
inspection. The four dust collectors vent internally. The heaters and ovens are powered by
natural gas.

II.B.1.a.1 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. The observations were conducted in a manner consistent with
Method 9. See the attached VEO.

II.B.1.b The owner/operator shall use only natural gas as a primary fuel and propane as a backup fuel in
the building space/process heating. Appropriate fuels may be used in equipment being tested and
in small auxiliary mobile equipment associated with the facility. [R307-401-8(1)(a)]

Status: In Compliance. Only natural gas is used as primary fuel and propane as a backup
fuel.

II.B.1.c The owner/operator shall not exceed the following site-wide fuel limitations per rolling 12-month
period:

A. Natural gas - 40 MMscf

B. Propane -10,000 gallons. [R307-401-8]

Status: In Compliance. Fuel invoices and rolling 12-month totals were reviewed on site.
Total natural gas use for the period of September 2022, through the end of August of 2023,
was 34.50111 MMscf. New ports for the meters showing the gas use for the Tooele County
Offices, that share the complex space, allow Detroit Diesel Remanufacturing to separate the
gas consumption of the independent operations. The applicable 12-month total portion of
the gas use spreadsheet was printed out as a submission. Propane use for the same
12-month period was reported as 7,344 gallons. See the attached "Fuel Use, Limits, and
Calibration record”.

II.B.1.c.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 consumption shall be kept for all periods when the plant is in operation. The consumption
shall be determined by billing statements from a utility company. The records of billing
statements shall be kept on a monthly basis. [R307-401-8]

Status: In Compliance. The reported rolling 12-month totals are based on invoices and are
tabulated into a spreadsheet as required.

II.B.1.d The owner/operator shall not emit more than the following from evaporative sources (painting,
printing, coating, and/or cleaning) on site:

15.8 tons per rolling 12-month period of VOCs
1.57 tons per rolling 12-month period of all HAPs combined. [R307-401-8]

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

2.0651 tons of VOCs
0.929 tons of all HAPs combined
See the attached "Fuel Use, Limits, and Calibration record”.
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II.B.1.d.1 The owner/operator shall calculate a new 12-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 emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]

Status: In Compliance. The current EHS contact is familiar with this requirement and uses
the calculations as required.

II.B.1.d.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.1.d.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. This facility initially had some historical versus current product
recording issues. A spreadsheet of all the current products used at this facility is now kept
at the main office. The totals for all VOC containing products used each month have
always been recorded as required.

II.B.1.e The owner/operator shall cover solvent tanks when not in use. [R307-401-8]

Status: In Compliance. All solvent tanks are covered as required when not in use.

II.B.1.f The owner/operator shall conduct all degreasing operations in accordance with the requirements
of R307-335. [R307-335]

Status: In Compliance. Solvent tanks are closed when not in use. The Parts Washer
Solvent, Product Code, 128-PWS, 5-PWS, 55-PWS, has reportedly not been changed since
the previous February 28, 2022, inspection. The SDS sheet for this product was attached to
the memo DAQC-1306-22.

II.B.1.g The paint spray booths shall be equipped with a set of paint arrestor particulate filters, or
equivalent, to control particulate emissions. Air exiting the booths shall pass through this control
system before being vented to the atmosphere (outside building/operation). [R307-401-8]

Status: In Compliance. The paint spray booths were equipped with particulate filters at the
time of this inspection. The air from this operation passes through the filters prior to being
vented to the atmosphere.

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II.B.1.h The owner/operator shall install all fuel storage tanks with submerged fill pipes. The
owner/operator shall operate the storage tanks in a way that minimizes working and breathing
losses from the tank. [R307-401-8]

Status: Not Applicable. The storage tanks are reportedly fitted with submerged fill pipes.
The EHS contact stated that Storage Tank 2 referenced by Condition II.A.20, does not
contain gasoline and instead stores only diesel. The requirement to use a submerged fill
pipe typically applies only to gasoline storage tanks.

II.B.2 All blaster cleaners on site shall be subject to the following

II.B.2.a The owner/operator shall control particulate emissions with the applicable dust collection
equipment indicated in the equipment list at all times when blasting is taking place. [R307-401]

Status: In Compliance. The steel shot blaster described by Condition II.A.8 has been
removed. The two tumble blasters vent to the internally venting dust collector.

II.B.3 All engine test cells on site shall be subject to the following

II.B.3.a The approved engine test cells shall consist of four 600 hp Dyno engines and two 4,000 hp Dyno
engines. Only one of the 4,000 hp Dyno engines shall run at any one time. [R307-401]

Status: In Compliance. Four 600 hp Dyno engines are still on site and are operational. One
of the 4,000 hp Dyno engines has been converted to electric.

II.B.3.b The owner/operator shall use #1, #2 or a combination of #1 and #2 diesel fuel as fuel in the
engine test cells. [R307-401]

Status: In Compliance. Only #2 Ultra Low Sulfur diesel is currently used. A recent invoice
from Rhinehart Oil, which certifies the product as ULS #2 was reviewed on site.

II.B.3.c The owner/operator shall not exceed the following diesel fuel limitations for engine testing per
rolling 12-month period:

A. 600 hp engines - 47,000 gallons (combined)

B. 4,000 hp engines - 100,000 gallons(combined). [R307-401-8]

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

600 hp engines: 8,726.00 gallons
4,000 hp engine: 4.49 gallons

The source stated that one of the 4,000 hp engines had been converted to electricity and
that the remaining diesel powered 4,000 hp engine is only used sporadically.

II.B.3.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th of each month using data from the previous 12 months. Fuel
consumption for the engine test cells shall be determined by the use of operations records.
[R307-401-8]

Status: In Compliance. Records are tabulated monthly as required. See the attached Fuel
Use, Limits, and Calibration record for more information.

II.B.3.d The owner/operator shall not allow visible emissions from any stationary engine on site to
exceed 20 percent opacity. [R307-201]

Status: Not Observed. The engine test cells were not operating at the time of the inspection.
The engine test cells are equipped with cameras at the stack emission point in order to
monitor opacity when the cells are in operation.
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II.B.4 All thermal cleaning ovens on site shall be subject to the following

II.B.4.a The thermal cleaning ovens shall operate up to a temperature of 1,100 degrees Fahrenheit as
needed. Each oven shall be equipped with an afterburner. The operating temperature of the
afterburner shall be no less than 1,400 degrees Fahrenheit. Each afterburner shall operate
whenever parts are being baked. [R307-401]

Status: In Compliance. One of the thermal cleaning ovens was operating during the
inspection. The temperature rating of the oven registered at 1,048 Fahrenheit at the time of
the observation. The afterburner for that oven was observed operating at 1,800 Fahrenheit.

II.B.4.a.1 The temperatures cited in the above condition shall be monitored on all three ovens with
equipment located such that an inspector can, at any time, safely read the output. All readings
shall be accurate to within plus or minus 15 degrees Fahrenheit. All instruments shall be
calibrated against the manufacturer's specification at least once every 12-month period.
[R307-401]

Status: In Compliance. The ovens are equipped with digital gauges showing the
temperature for each oven and afterburner. The gauges are installed in a position that can
easily be read. The cleaning ovens and afterburner gauges were last calibrated on January
25, 2023, and on June 20, 2023.

II.B.5 The Proceco parts washer shall be subject to the follow

II.B.5.a The Proceco parts washer shall not exceed an operating temperature of 210 degrees Fahrenheit.
[R307-401-8]

Status: Not Observed. The Proceco parts washer has not operated since March of 2020.

II.B.5.a.1 The temperatures cited in the above condition shall be monitored with equipment located such
that an inspector or operator can, at any time, safely read the output. All readings shall be
accurate to within plus or minus 15 degrees Fahrenheit. All instruments shall be calibrated
against the manufacturer's specification at least once every 12-month period. [R307-401]

Status: Not Observed. The Proceco Parts Washer has not been used since March of 2020.
The current EHS Manager stated that the DAQ will be contacted if Detroit Diesel has plans
to start this equipment again.

II.B.6 Cooling Tower Requirements

II.B.6.a The owner/operator shall install and operate high efficiency drift eliminators to control
particulate matter from the cooling tower. [R307-401-8]

Status: In Compliance. The EHS contact stated that the cooling tower is equipped with a
high efficiency drift eliminator.

II.B.7 Dust Collector Requirements

II.B.7.a The owner/operator shall route all emissions from the blowoff tables to a baghouse or dust
collector. [R307-401-8]

Status: In Compliance. All blow off table emissions are routed to a dust collector prior to
venting to the outside air.

II.B.7.b The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static
pressure drop across each baghouse system. Each Baghouse system shall operate within the static
pressure range recommended by the manufacturer for normal operations. [R307-401-8]

Status: In Compliance. A pressure gauge operates for each baghouse system. The EHS
contact stated that the staff is aware of the required ranges.

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II.B.7.b.1 The owner/operator shall record the static pressure drop readings at least once daily, while the
baghouse is operating. Records shall be kept in a log and shall include the following:

A. Unit identification;

B. Manufacturer recommended static pressure drop for the unit;

C. Daily static pressure drop readings; and

D. Date of last bag replacement. [R307-401-8]

Status: In Compliance. A new paper log form has been developed for each dust collector.
The recorded information includes the unit name, a notation of the desired range, daily
actual reading, and bag replacement date.

II.B.7.b.2 The pressure gauge shall be located such that an inspector/operator can safely read the indicator
at any time. [R307-401-8]

Status: In Compliance. Pressure gauges are located so that the indicators can be easily
read.

II.B.7.b.3 The pressure gauges shall be calibrated in accordance with the manufacturer's instructions or
recommendations or replaced at least once every 12 months. Documentation of calibrations shall
be maintained. [R307-401-8]

Status: In Compliance. The pressure gauges are calibrated once a year and are indicated
by a label affixed to the gauge. The most recent calibration occurred on November 26,
2022.
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.

MACT (Part 63) -CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category:
Gasoline Dispensing Facilities

Status: Not Applicable. Derek Terry, the current EHS contact for this company states that the fuel tank
identified as Storage Tank #2, is no longer used for gasoline and is only used for diesel.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Solvent Cleaning [R307-304]

Status: Not Applicable. Exempt. Sources subject to R307-350 are exempt from R307-304 as per
R307-304-3(1) with solvent cleaning regulated by R307-350-7(2).

Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. This area source rule is satisfied by compliance with AO conditions II.B.1.a
and II.B.3.d.

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Ozone Nonattainment and Maintenance Areas: General Requirements [R307-325]

Status: In Compliance. All VOC containing products are applied and managed properly. All
products are stored in sealed containers. VOC containing waste cloths are sealed and disposed of as
required.

Degreasing and Solvent Cleaning Operations [R307-335]

Status: In Compliance. This area source rule is satisfied by compliance with condition II.B.1.f of the
AO.

Miscellaneous Metal Parts and Products Coatings [R307-350]

Status: In Compliance. Historical spreadsheets for paints plus paint SDS sheets submitted for the
February 28, 2022, inspection were reviewed during this inspection. Devin Furner, the current EHS
Engineer, requested additional time to consult staff and the head office for this facility to determine
which paints are still in use and which paints qualified as exempt safety coatings. An updated
spreadsheet of used coatings was submitted on October 30, 2023. See the attached paint product
spreadsheet. Products no longer in use were highlighted in yellow. Products used for safety-indicating
coatings were highlighted in orange. Exempt canned aerosol coating products were identified by the
"cans make a gallon" column K. The remaining used applicable products were identified as follows:
Rust-oleum DTM Waterbourne Primer (Red and Grey), Iron Guard Black, Valspar TB 550 Poly
Enamel Paint, and Valspar Au 544 Activator. These listed products were all reported as having a
certification of 2.80 pounds of VOC per gallon, which meet the limit as per the General One
Component Table 1 limit of R307-350-5. The SDS sheets for these products were included on the
attachment for DAQC-1306-22.

R307-350-7 Work Practices was met by storing all VOC containing products in closed containers
when not in use, minimizing spills, and not atomizing cleaning solvents. All spent solvent is captured
in closed containers. R307-350-7(2) is met by using a product with a vapor pressure of 0.62 torr = .08
kPa at 68 degrees F. The SDS sheet was attached to DAQC-1306-22.

EMISSION INVENTORY:
An Emissions Inventory has not yet been required for this site.

The emissions listed below are an estimate of the total potential emissions (PTE) from Detroit
Remanufacturing LLC - Engine Maintenance Facility on the Approval Order (AO)
DAQE-AN118290014-20 dated December 24, 2020. (PTE) are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 10798.00
Carbon Monoxide 10.58
Nitrogen Oxides 38.19
Particulate Matter - PM10 6.12
Particulate Matter - PM2.5 6.12
Sulfur Dioxide 1.09
Volatile Organic Compounds 17.06

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Hazardous Air Pollutant PTE lbs/yr
Chromium Compounds (CAS #CMJ500) 134
Ethyl Benzene (CAS #100414) 3140
Generic HAPs (CAS #GHAPS) 140
Manganese Compounds (CAS #MAR500) 30
Nickel Compounds (CAS #NDB000) 60

PREVIOUS ENFORCEMENT
ACTIONS: A Compliance Advisory (CA) for exceeding the natural gas limit
as per II.B.1.c.A. was issued on May 5, 2022, DAQC-566-22.
A No Further Action Letter to resolve the above CA was issued
without penalty on September 21, 2022, DAQC-1164-22.

COMPLIANCE STATUS &
RECOMMENDATIONS: The AO DAQE-AN118290014-20 dated December 24, 2020,
did not include the three Thermal Cleaning Ovens and two
Drying Ovens brought in from their Kansas facility as submitted
on their 2020 NOI. See the attached NOI equipment reference.
The facility was otherwise in compliance with the above AO and
UAC R307-325, R307-335, and R307-350. MACT CCCCCC is
no longer applicable as the facility no longer stores or transfers
gasoline.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Target for inspection following the issuance of the corrected AO.
The VOC containing products should be reviewed for
compliance with R307-350 during the next inspection due to the
uncertainty of historical versus current product record keeping
issue. Safety glasses and steel-toed boots are required PPE to
tour the source operations.

NSR RECOMMENDATIONS: The equipment added to AN118290014-20 did not include the
equipment brought in from their closed Kansas plant as per the
submitted 2020 NOI. See the attached “Description of Project
and Source Process”, that was found in the DAQ electronic 2020
NOI file. It is recommended that the three (3) Thermal Cleaning
Ovens and two (2) natural gas drying ovens be added as an
Administrative Amendment. Condition II.B.2.a, the Steel Shot
Blaster, may need to be removed as the equipment is no longer
on site. The reference to II.A.20 #2 Gasoline Tank should be
removed as the site’s EHS Manager states that they no longer
store gasoline.

ATTACHMENTS: VEO, Natural Gas Consumption monthly breakdown
spreadsheet, All Fuel, VOC, and HAPs Consumption Report,
October 30, 2023, email description of current VOC containing
product spreadsheet, color coded spreadsheet of VOC containing
products, “Description of Project and Source Process” from the
2020 NOI electronic DAQ files.
10/31/23, 8:03 PM State of Utah Mail - Paints no longer in use
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1781192374280592964%7Cmsg-f:1781192374280592964&…1/1
Susan Weisenberg <[e-mail]>
Paints no longer in use
1 message
Terry, Derek (696) <[e-mail]>Mon, Oct 30, 2023 at 8:50 AM
To: Susan Weisenberg <[e-mail]>
Susan:
Aached is the form for the paint usage from our paint department. Yellow Highlighted products are no
longer in use in the facility, the Orange Highlighted products are only used as Safety related coangs for
various poles/floor markings throughout the facility which I believe Form R307-350-3 lists Safety-Indicang
Coangs as Exempons.
Thank you,
Derek Terry
Aermarket Soluons Tooele
100 S Lodestone Way
Tooele UT, 84074
435-843-6034 (Office)
385-235-0967 (Cell)
[e-mail]
If you are not the addressee, please inform us immediately that you have received this e-mail by mistake, and delete it.
We thank you for your support.
Paint no longer in use.xlsx
23K
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• OP 200 involves three (3) Steelman natural gas burn-off ovens
•OP210 has a blow off table that is connected to one (1) 2x2 Donaldson Torrit
dust collector
•OP220 wash filter has an internally venting dust collector
•OP230 is a blow off table with an internal venting dust collector
•OP240 involves two (2) natural gas fired drying ovens
•OP250 are blow tables connected to three 3x3 Donaldson Torrit dust collectors.