The URL can be used to link to this page

Home My WebLink AboutDAQ-2024-0079681 DAQC-436-24 Site ID 10270 (B1) MEMORANDUM TO: FILE – ALIGN PRECISION (Building 1) – Formerly Known as METALCRAFT TECHNOLOGIES THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: April 24, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Iron County INSPECTION DATE: March 27, 2024 SOURCE LOCATION: 526 Aviation Way, Cedar City, Utah 84721 SOURCE CONTACT(S): Eric Lewis, Environmental Engineer: 435-586-3871 Eric.lewis@alignprecision.com OPERATING STATUS: Operating PROCESS DESCRIPTION: This is an aircraft parts fabrication plant. Metals of different types and sizes are brought in by truck. The parts are first sent through a series of cutters, formers, welders, and grinders. Most of these machines do not produce emissions with the exception of the welders which vent directly to the air. The parts are then heat treated in one of three ovens according to size and temperatures needed. The ovens are natural gas or electric fired. The electric ovens have small vents on the top which vent directly to the inside air. The natural gas ovens have discharge vents which go to the roof and vent to the outside air. The ovens are used to treat the metal and no coatings are applied prior to the use of the ovens. The parts once treated are shipped to another building for further processing. APPLICABLE REGULATIONS: Approval Order DAQE-412-00, dated July 6, 2000. SOURCE EVALUATION: General Conditions: Condition 1. This Approval Order (AO) applies to the following company: Site Office Metalcraft Technologies, Inc. 498 North 2774 West Cedar City, Utah 84720 Phone Number (435) 586-3871 Fax Number (435) 586-0289 0 0 2 The equipment listed in this AO shall be operated at the following location: PLANT LOCATION 498 North 2774 West, Cedar City, Utah, Iron County Universal Transverse Mercator (UTM) Coordinate System: 4,172.9 kilometers Northing, 314.7 kilometers Easting, Zone 12 Status: In compliance. The telephone number and fax number are current but the source is now located at 526 Aviation Way, Cedar City, UT 84721. The source was also purchased by and is now named Align Precision. Condition 2. Definitions of terms, abbreviations, and references used in this AO conform to those used in the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of Federal Regulations (40 CFR). These definitions take precedence, unless specifically defined otherwise herein. Status: In compliance. Condition 3. Metalcraft Technologies, Inc., shall install and operate the two passivation tanks and shall conduct its operations of the aircraft parts manufacturing facility in accordance with the terms and conditions of this AO, which was written pursuant to Metalcraft’s Notice of Intent submitted to the Division of Air Quality (DAQ) on October 28, 1999 and additional information submitted to the DAQ on March 3, 2000. Status: In compliance. The two passivation tanks have been removed from the source. See status of condition 5 for additional information. Condition 4. This AO shall replace the AO dated December 1, 1999 (DAQE-937-99). Status: In compliance. Only the current AO was used to determine compliance. Condition 5. The approved installations shall consist of the following equipment or equivalent*: A. Natural Gas Curing Oven Design Capacity: 700,000 BTU/hr B. Natural Gas Paint Burn-Off Oven Design Capacity: 800,000 BTU/hr C. Natural Gas Treatment Oven #1 Design Capacity: 3,400,000 BTU/hr D. Natural Gas Treatment Oven #2 Design Capacity: 3,200,000 BTU/hr E. Seven Paint Booths with particulate filters F. Two Alodine Lines G. One Titanium Etching Line 3 H. One Anodizing Line (including a sulfuric acid tank, and a sulfuric boric acid tank) I. Water Treatment System (including seven holding tanks, three purification tanks, a clarifier, and a filter press). J. One Sunstrand Parts Maker (with 2,200 acfm filter collection system) K. Two Natural Gas Air Make-up Heaters Design Capacity: 5,000,000 BTU/hr each L. Space Heaters Design Capacity: 350,000 BTU/hr each M. Passivation Tank (225 gallon) * Tank Dimensions: 47"x42"x27" (assuming 4" freeboard) Nitric Acid Concentration: 61-74 oz per gallon Evaporation Rate: 3% N. Passivation Tank (100 gallon) * Tank Dimensions: 36"x28"x29" (assuming 4" freeboard) Nitric Acid Concentration: 32-57 oz per gallon Evaporation Rate: 3% * Equivalency shall be determined by the Executive Secretary. Any future changes or modifications to the equipment and processes approved by this AO that could affect emissions covered by this AO must be approved in accordance with R307-401-1, UAC. Status: In compliance. Most of the equipment listed in this condition has been removed or is currently not in use. Items A, C, D, E (one small paint hood only), and L are still in use. All remaining equipment has been relocated to the company’s new building (Building 2). This site (Building 1) now serves as the fabrication source. All manufacturing and finishing work is completed in Building 2. Condition 6. Metalcraft shall notify the Executive Secretary in writing when the installation of the equipment listed in Condition #5.M & 5.N has been completed and is operational, as an initial compliance inspection is required. To insure proper credit when notifying the Executive Secretary, send your correspondence to the Executive Secretary, Attn: Compliance Section. If installation has not been completed within eighteen months from the date of this AO, the Executive Secretary shall be notified in writing on the status of the installation. At that time, the Executive Secretary shall require documentation of the continuous installation of the operation and may revoke the AO in accordance with R307-401-11, UAC. Status: In compliance. Notifications were sent and are in the main source file. This condition could be considered not applicable for further inspections since items M and N have been permanently removed from the source. 4 Condition 7. Visible emissions from the following emission points shall not exceed the following values: A. All paint booths exhaust stacks - 5% opacity B. Passivation tank exhaust stack - 5% opacity C. All natural gas combustion stacks - 10% opacity D. All other points - 20% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Visible emissions from mobile sources and intermittent sources shall use procedures similar to Method 9, but the requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. Any time-interval with no visible emissions shall not be included. Status: In compliance. No visible emissions were observed from any point during the inspection. Condition 8. The consumption limits of the following materials shall not be exceeded without prior approval in accordance with R307-401, UAC: A. Alodine 1200S or equivalent* - 85 pounds per rolling 12-month period. B. Sodium Chromate - 4 pounds per rolling 12-month period. C. Hydrofluoric Acid - 125 gallons per rolling 12-month period. D. Nova Coat 1100 or equivalent* - 135 gallons per rolling 12-month period. E. Acidic Chromated Deoxidizer - 125 pounds per rolling 12-month period. Records of consumption shall be kept for all periods when the plant is in operation. The consumption shall be determined by sales invoices or by any other method as acceptable to the Executive Secretary or representatives of the Executive Secretary. Records of consumption, shall be made available to the Executive Secretary or representatives of the Executive Secretary upon request. Status: Not applicable. None of these materials are consumed any longer at this location. All material consuming processes have been moved to Building 2. This site is used only as a fabrication source. Condition 9. The owner/operator shall use only natural gas as fuel. If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC. Status: In compliance. Natural gas lines to remaining equipment in use at the site were verified during the inspection. Condition 10. The paint spray booths shall be equipped with sets of paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting the booth shall pass through this control system before being vented to the atmosphere (outside building/operation). Equivalency determinations, when requested by the owner/operator, shall be submitted to the Executive Secretary for approval. Status: In compliance. One small paint hood remains in use at the facility. Very little painting is conducted, most of which is touch up painting with a spray can. Filters were in place and in good condition. Lid was present on paint cans, and a HPLV nozzle is utilized. Rags appear to be properly stored in closed lid containers. 5 Condition 11. The plant-wide emissions of VOCs and HAPs from the paint booths, Alodine lines, titanium etching line, anodizing line and associated operations shall not exceed: 14.43 tons per rolling 12-month period for VOCs 40.00 pounds per rolling 12-month period for chromium compounds 627.42 pounds per rolling 12-month period for ethyl benzene 1,222.00 pounds per rolling 12-month period for ethylene glycol 6.41 pounds per rolling 12-month period for hydrofluoric acid 0.22 pounds per rolling 12-month period for lead 1,721.44 pounds per rolling 12-month period for methyl ethyl ketone 1,547.30 pounds per rolling 12-month period for methyl isobutyl ketone 112.38 pounds per rolling 12-month period for methyl amul keytone 0.12 pounds per rolling 12-month period for nickel oxide 319.92 pounds per rolling 12-month period for nitric acid 6.75 pounds per rolling 12-month period for potassium ferricyanide 155.30 pounds per rolling 12-month period for toluene 555.50 pounds per rolling 12-month period for triethylamine 1,377.00 pounds per rolling 12-month period for Xylene 3.85 tons total per rolling 12-month period for all HAPs combined This value shall not be exceeded without prior approval, in accordance with R307-401, UAC. 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 plant-wide emissions of VOCs and HAPs emitted to the atmosphere shall be determined by maintaining a record of VOC potential and HAP potential contained in materials used each month. The record shall include the following data for each item used: A. Name of the VOC and HAPs emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, isocyanates, etc. B. The weight and use location (name of paint booth or plant facility) of the VOC potential and HAP potential of the material(s) listed in A, in pounds per gallon. C. Percent by weight of all VOC potential and HAP potential for each individual material listed in A. The percent by weight of the VOC and HAP potentials can be obtained from the manufacturers' MSDSs. The owner/operator can obtain MSDS data from the manufacturers of the materials and retain the information on-site. D. Amount and location of materials containing VOCs and HAPs used on a monthly basis and summed for every location and for the entire plant each month. E. To calculate the above potentials contained in the material listed in D, use the following procedure: VOC or HAPs = % Volatile by Weight x [Density ( lb )] x Gal Consumed x 1 ton (100) (gal) 2000 lb 6 F. The amount of VOC content potential (potential air emissions) and HAP potential (potential air emissions) in pounds contained in materials deposited as solid or hazardous waste for the month shall be quantified and subtracted from the quantities calculated above. This is done to allow quantification by the source of the total VOCs and HAPs emissions. (The assumption is that all the two above-potentials of the materials applied to a product evaporate and are therefore considered emissions). G. Records of consumption of VOCs and HAPs shall be kept for all periods when the plant is in operation. Records of consumption 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. Status: In compliance. All VOC and HAP-containing materials have been moved from this source to Building 2. Records were reviewed at the time of inspection and contained all required information. VOCs were recorded as 0.35 tons/year, toluene was recorded with 0.02 tons/year, and 0.12 tons/year of HAPs for the 12 month period. Condition 12. 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 Approval Order 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, and the records shall be maintained for a period of two years. Maintenance records 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. Status: In compliance. All equipment appeared to be maintained and no emissions were observed from any point during the inspection. All records were furnished upon request. Condition 13. The owner/operator shall comply with R307-107, UAC. This rule addresses unavoidable breakdown reporting requirements. The full text of UAC R307-107 General Requirements, Unavoidable Breakdown, is included as Appendix A. However, to be in compliance, this facility must operate in accordance with the most current version of the UAC, R307-107. Status: In compliance. No reportable breakdowns have occurred since last inspection. 7 AREA SOURCE RULES EVALUATION: No area source rules were determined to be applicable to the facility during this inspection except for R307-205 which was addressed by condition 7. EMISSION INVENTORY: Potential to emit for this source from the AO is as follows: Pollutant Tons/yr PM10 ................................. 0.48 SO2 ................................. 1.00 NOx ................................. 2.40 CO ................................. 0.41 VOC ............................... 14.43 HAPs consist of the following amounts in Pounds/Year. Chromium compounds…….40.00 Ethyl benzene…………….627.42 Ethylene glycol……….. ..1,222.00 Hydrofluoric Acid…………...6.41 Lead…. ……………………...0.22 Methyl ethyl ketone…… .1,721.44 Methyl isobutyl ketone….1,547.30 Methyl amul keytone……...112.38 Nitric Acid…………………319.92 Nickel oxide…………………..0.12 Potassium ferricyanide………..6.75 Toluene……………………..155.30 Triethylamine……………….555.50 Xylene……………………..1,377.00 PREVIOUS ENFORCEMENT ACTIONS: None in the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Align Precision should be considered in compliance with the conditions of the AO DAQE-412-00, dated July 6, 2000, at the time of inspection. The facility appears to be well maintained and operated properly. All records were provided for review at the time of inspection. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. Inspect the source with Align Precision (Metalcraft Technologies) Building #2 (Site ID 12202) with the AO dated October 4, 2001 (DAQE-817-01). ATTACHMENTS: VEO Form.