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Home My WebLink AboutDAQ-2024-0079691 DAQC-439-24 Site ID 12202 (B1) MEMORANDUM TO: FILE – ALIGN PRECISION (Building 2) – Formerly 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: 597 North 1500 West, 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 manufacturing and finishing operation. Machined parts from a separate process are brought in by truck. These parts go through one of several processes. Most go through a chemical process line which includes anodizing, alodine process, and etching. The process consists of a series of dip tanks. The parts are placed on a manual controlled overhead conveyor or hand dipped if small enough. There is one main line which incorporates the three processes. The line has two hot water tanks followed by an alodine solution tank, a chromate solution tank, an acid cleansing tank, an acid bath tank, a sizing tank, a second acid bath tank, a sulfuric acid tank, a boric acid tank, and then several water or treatment tanks. The parts are placed in the tanks as needed for the process they are going through. Not all parts are dipped in each tank. All the treatment tanks are in the same line and each tank has a duct above it which feeds to a main exhaust system which feeds to roof mounted scrubbers. The scrubber uses feed water only and the emissions go through the stack to the outside air. The building also has a water treatment system which includes a chromium treat tank (chemical separation), two neutralization tanks, a flocculation tank, a clarifier, filter press for solids, reject holding tank, a sand filter, and sand filter feed tank. The water is discharged into the local water discharge system while the solids are collected and disposed of through a local company. The site also includes multiple space heaters. The site has five paint booths. Two enclosed booths/ovens have been installed and are 0 0 2 operational. One is a large (automotive type) booth with a combined oven and several filter banks which exhaust to the air. The paint booth/oven is fired on natural gas only. The plant has two natural gas make up air heaters to provide make up air to the remaining paint booths. The other three paint booths are wall booths with a back wall filter bank. Air is drawn through the banks by roof top fans and discharged to the ambient air. All the booths have pressure assistant spray heads. Two booths are currently completely installed and operational. The other one is only partially installed and was not operational for this inspection. Instead these booths are used for the drying and storage of parts. All of the parts are shipped off site by truck. This plant is a new plant and will be used in conjunction with the older, existing plant. This plant will be used to finish the manufactured parts from the other plant. Much of the equipment has, or will be, moved from the other plant. Each plant has a separate AO and AIRs number. APPLICABLE REGULATIONS: Approval Order DAQE-817-01, dated October 4, 2001. SOURCE EVALUATION: General Conditions: Condition 1. This AO applies to the following company: Site Office Corporate Office Location Metalcraft Technologies, Inc. Metalcraft Technologies, Inc. 597 North 1500 West 498 North 2774 West Cedar City, Utah 84720 Cedar City, Utah 84720 Phone Number (435) 586-3871 (435) 586-3871 Fax Number (435) 586-0289 (435) 586-0289 The equipment listed in this AO shall be operated at the following location: PLANT LOCATION: 597 North 1500 West, Cedar City, Utah, Iron County Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27 4,172.9 kilometers Northing, 316.4 kilometers Easting, Zone 12 Status: In compliance. Phone and fax numbers are as listed. The source now goes by the name Align Precision (the name of the company which purchased Metalcraft Technologies), and the office is located at 526 Aviation Way, Cedar City, Utah 84721. 3 Condition 2. All definitions, terms, abbreviations, and references used in this AO conform to those used in the Utah Administrative Code (UAC) Rule 307 (R307), and Title 40 of the Code of Federal Regulations (40 CFR). Unless noted otherwise, references cited in these AO conditions refer to those rules. Status: In compliance. Condition 3. The limits set forth in this AO shall not be exceeded without prior approval in accordance with R307-401. Status: In compliance. No limits appear to have been exceeded. Condition 4. Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be approved in accordance with R307-401-1. Status: In compliance. No modifications have been made to equipment or process. Condition 5. All records referenced in this AO which are required to be kept by the owner/operator, 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. All records shall be kept for a minimum period of two years. Emission inventories shall be kept for a period of five years from the due date of each emission statement or until the next inventory is due, whichever is longer. Status: In compliance. The facility appeared to be well maintained. A PM schedule is followed. Maintenance records were provided at the time of inspection for review. Condition 6. Metalcraft shall install and operate the anodize/alodine process line and shall conduct its operations of the aircraft parts manufacturing facility accordance with the terms and conditions of this AO, which was written pursuant to Metalcraft’s NOI submitted to the Division of Air Quality (DAQ) on May 1, 2001, and additional information submitted to the DAQ on August 10, 2001. Status: In compliance. Align Precision appears to operate the anodize/Alodine process line according to the conditions of the AO. Condition 7. This AO shall replace the AO (DAQE-134-01) dated February 22, 2001. Status: In compliance. Only the current AO was used to determine compliance. Condition 8. The approved installations shall consist of the following equipment: A. One (1) Enclosed Paint Booth Size: 15x30x9 ft Filter Medium: Three Stage Filter System Air Flow: 13,500 acfm 4 B. One (1) Open Faced Paint Booth Size: 28x11x9 ft Filter Medium: Three Stage Filter System Air Flow: 25,200 acfm C. Three (3) Open Faced Paint Booths Size: 14x11x9 ft Filter Medium: Three Stage Filter System Air Flow: 12,600 acfm D. Natural Gas Fired Heater Heating Capacity: 1.00 x 106 BTU/hr E. Natural Gas Fired Walk-In-Oven Heating Capacity: 0.70 x 106 BTU/hr F. Natural Gas Fired Bake Oven Heating Capacity: 1.05 x 106 BTU/hr G. Natural Gas Fired Boiler Heating Capacity: 0.1875 x 106 BTU/hr H. Natural Gas Fired Boiler Heating Capacity: 2.52 x 106 BTU/hr I. Natural Gas Fired Boiler Heating Capacity: 2.10 x 106 BTU/hr J. Natural Gas Fired Make-up Air Heater Heating Capacity: 9.5 x 106 BTU/hr K. One (1) Passivation/Brass Bright Dip Chemical Process Line L. Two (2) Anodize/Alodine Chemical Process Lines i. One (1) 500 gallon Electropolish Tank M. One (1) Zinc/Phosphate Descale Process Line N. Two (2) Ceilcote Wet Scrubbers (for chemical process lines) Flow Rate: 35,000 acfm each scrubber O. Miscellaneous Natural Gas Radiant and Space Heaters 5 P. One (1) Wastewater Treatment Plant i. Chromium treatment tank ii. Neutralization tank 1 iii. Neutralization tank 2 iv. Flocculation tank v. Clarifier vi. Filter press vii. Sludge drier viii. Reject holding tank ix. Sand filter feed tank x. Sand filter Q. One (1) Wet Scrubber (for wastewater treatment plant) Status: In compliance. Equipment observed on site was consistent with that listed. No unapproved equipment was observed on site. Items G, Li, M, and Pvii have been permanently removed from the source. Several items are also known by other names; D is known as F-20, E as F-7, H as U-26014, and L as U-26013. Condition 9. The Ceilcote wet scrubbers shall control the process streams from the three chemical process lines. The wet scrubbers shall each be sized to handle at least 35,000 acfm for the existing conditions. All exhaust air from the chemical process lines shall be routed through the wet scrubbers before being vented to the atmosphere. Status: In compliance. The two Ceilcote wet scrubber’s ratings were confirmed at 35,000 acfm of flow. The exhaust from the chemical processes was observed going through the scrubbers before being vented into the ambient air. Scrubber #1 is used to control pollutants from the Automated line and the Wastewater Treatment Plant (WWTP). Scrubber #2 is used to control pollutants from the Manual line and Hard Metal (HM) line. Condition 10. The following operating parameters shall be maintained within the indicated ranges: A. Ceilcote Air Pollution Control Scrubbers. (1) The liquid flow rate shall not be less than 108 gallons per minute (gpm) or more than 144 gpm. They shall be monitored with equipment located such that an inspector/operator can safely read the output any time. The readings shall be accurate to within the following ranges: 1) Liquid flow rate - Plus or minus 5 gpm. Status: In compliance. The flow meters for both scrubbers are located, about seven feet up, on a wall near the automated process line. Meters were reading approximately 111 (#1) and 128 (#2) gallons per minute (gpm) at time of the inspection. Readings from both flow meters are recorded weekly. The flow rate floats were replaced on August 1, 2023. 6 Condition 11. Metalcraft shall notify the Executive Secretary in writing when the installation of the equipment listed in Condition #8.L. 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. Status: In compliance – The installation and operation notice for the two Anodize/Alodine Chemical Process Line (#8.L.) was received by DAQ on November 12, 2001. The initial compliance inspection was conducted on November 19, 2001. Limitations and Tests Procedures Condition 12. Visible emissions from the following emission points shall not exceed the following values: A. All heaters and boilers - 10% opacity B. Paint booth exhaust stacks - 5% opacity C. All scrubber exhaust stacks - 15% 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. Status: In compliance. No visible emissions were observed from the roof stacks, or any other point, during the inspection. Fuels Condition 13. The owner/operator shall use only natural gas as fuel. Status: In compliance. The source verified that natural gas is the only fuel used on site for the boilers and ovens. Natural gas lines were observed as the only sources of fuel connected to equipment during the inspection. Volatile Organic Compound (VOC) and Hazardous Air Pollutants (HAPs) Limitations Condition 14. The paint spray booths shall be equipped with a set 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). Status: In compliance. Filters were observed on all operating paint booths during the inspection. 7 Condition 15. The plant-wide emissions of VOCs and HAPs from the paint booth operations shall not exceed: 15.04 tons per rolling 12-month period for VOCs 0.50 tons per rolling 12-month period for Toluene 2.00 tons per rolling 12-month period for Xylene 2.50 tons per rolling 12-month period for Methyl Ethyl Ketone 1.00 tons per rolling 12-month period for Methyl Isobutyl Ketone 2.84 pounds per rolling 12-month period for Chromium Compounds 810.00 pounds per rolling 12-month period for Ethylene Glycol 10.00 pounds per rolling 12-month period for Hexamethylene-1, 6-diisocynate 111.60 pounds per rolling 12-month period for Hydrochloric Acid (HCL) 18.39 pounds per rolling 12-month period for Hydrofluoric Acid 1000.00 pounds per rolling 12-month period for Methylene Chloride 1638.00 pounds total per rolling 12-month period for all other HAPs 7.80 tons total per rolling 12-month period for all HAPs combined Compliance with each/the 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 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 each E. The amount of VOC and HAP emitted monthly by each material used shall be calculated by the following procedure: 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. 8 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. Status: In compliance. Records were reviewed at the time of inspection and contained all required information. VOCs and HAPs totals for the 12-month period of March 2023 – February 2024 are: 3.67 tons for VOCs 0.10 tons for Toluene 0.55 tons for Xylene 0.52 tons for Methyl Ethyl Ketone 0.18 tons for Methyl Isobutyl Ketone 1.09 pounds for Chromium Compounds 0.0 pounds for Ethylene Glycol 0.0 pounds for Hexamethylene-1, 6-diisocynate 0.0 pounds for Hydrochloric Acid (HCL) 1.17 pounds for Hydrofluoric Acid 0.00 pounds for Methylene Chloride 495.22 pounds for all other HAPs 4.76 tons for all HAPs combined Records & Miscellaneous Condition 16. 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 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. Status: In compliance. All equipment appeared to be well maintained. No emissions were observed from the roof stacks, or any other point, during the inspection. All records were furnished upon request. The source has an in house database called Maintain IT Pro which is used to maintain preventative maintenance (PM) records and track equipment repairs. Condition 17. The owner/operator shall comply with R307-150 Series, Inventories, Testing and Monitoring. Status: Not applicable. This source is not currently required to submit an emission inventory to DAQ. 9 Condition 18. The owner/operator shall comply with R307-107. General Requirements: Unavoidable Breakdowns. Status: In compliance. No reportable breakdowns have occurred since the previous inspection. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-205. Emission Standards: Fugitive Emissions and Fugitive Dust. Status: In compliance. This area source rule is satisfied by compliance with condition 12 of the AO. EMISSION INVENTORY: This source is not required to submit an emissions inventory to the DAQ. The potential to emit (PTE) for this source from the AO is as follows: Pollutant Tons/yr PM10 ................................. 0.73 SO2 ................................. 0.06 NOx ................................. 9.37 CO ................................. 6.91 VOC ............................... 15.04 Chromium compounds ..... ...0.001 Ethylene glycol ................ ...0.005 HCL ……………………0.056 Hexamethylene-1, 6-diis .. ...0.005 Hydrofluoric Acid ............ ...0.009 Methyl ethyl ketone ......... ...2.50 Methyl isobutyl ketone .... ...1.000 Methylene Chloride ......... ...0.500 Toluene ............................ ...0.500 Xylene ...…………………..2.000 Misc. HAPs ...................... ...0.819 Total HAPs ...................... ...7.80 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-817-01, dated October 4, 2001 at the time of inspection. The facility appeared to be well maintained and operated properly. Records were provided for review at the time of inspection. 10 RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. Inspect the source in conjunction with Align Precision (Metalcraft Technologies) Building #1 (10270) and AO dated July 6, 2000 (DAQE-412-00). ATTACHMENTS: VEO Form.