HomeMy WebLinkAboutDAQ-2024-0079791
DAQC-CI101810001-24
Site ID 10181 (B1)
MEMORANDUM
TO: FILE – COMPANION SYSTEMS INCORPORATED
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Irene Tucker, Environmental Scientist
DATE: April 22, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Davis County
INSPECTION DATE: December 15, 2023, and April 3, 2024
SOURCE LOCATION: 645 West 200 North
North Salt Lake, UT 84054
SOURCE CONTACT: Aaron Lee, Cost Accountant, 801-936-8082 Ext. 364,
alee@companionsystems.com
OPERATING STATUS: Operating normally at time of inspection
PROCESS DESCRIPTION: Companion Systems manufactures modular mini-banking
branches, backdrops, and enclosures for ATMs out of fiberglass,
wood, metal, and formed plastics.
Mold fabrication: A wooden tooling is constructed to the design
and shape of the required product. The tooling is moved to the
tooling gelcoat booth and coated. Once cured, wax is applied to
the tooling to ease separation of the parts. The waxed tooling is
sprayed with gelcoat and moved into the lamination room.
Ceramic barrier coat, chop, and resin are applied in multiple
layers until the desired thickness is achieved. After the mold
cures at room temperature, the mold and tooling are separated.
The mold is prepared for use in production by grinding in the
tooling grinding booth.
Product fabrication - Gelcoat: The mold is prepared for the
application of gelcoat, the surface coat of the finished product.
The requested color of gelcoat is mixed and applied to the mold
surface. The gel coated mold is then moved to the barrier coat
and laminating area.
Product Fabrication - Barrier coat and laminating: The barrier
coat is applied to the gel coated surface. Then the mold is
moved to laminating where the chop strand is mixed with the
resin to the desired thickness. The chop/resin mixture is then
rolled onto the surface of the mold to take the mold shape.
/ :
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The mold is moved to the cure area to allow chemicals to harden
at room temperature.
Mold Removal, Cleanup, and Assembly: The fabricated part is
removed from the mold and moved to the main building's
grinding area to remove rough edges and prepare it for painting.
The grinding area is controlled with a Torit filter cartridge dust
collector. Body work is performed on the part to repair any
imperfections.
Paint Booths: The surface is prepared by cleaning it with solvent.
The primer coat and several coats of paint are applied to obtain
the desired color and surface texture.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN101810010-24, dated
February 1, 2024
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Companion Systems Incorporated
645 West 200 North
P.O. Box 540636
645 West 200 North
North Salt Lake, UT 84054 North Salt Lake, UT 84054
SIC Code: 3578: (Calculating & Accounting Machines, Except Electronic Computers)
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
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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 limits exceeded as set forth in this AO. According to
Companion Systems, there have been no modifications to their processes. Companion
Systems maintains records for at least two years, and also maintains records of
maintenance activities conducted on approved equipment. There were no breakdowns that
resulted in an emissions event. According to the 2020 Emissions Inventory Report, the
emissions indicate compliance with the PTEs of this AO. The 2024 Emissions Inventory
Report has not yet been uploaded into SLEIS.
SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
II.A.1 Companion Systems Inc.
Manufacturer of Enclosures of Bank Teller Machines
II.A.2 Tooling Gelcoat Booth
Equipment: Air, airless, air assist and HVLP spray guns; two (2) exhaust stacks
II.A.3 Tooling Laminating
Equipment: One (1) internal mix airless chop gun and one (1) spray gun; two (2) exhaust stacks
II.A.4 Gelcoat/Paint Booths
Gelcoat/paint booth
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack
Paint booth with 1 MMBtu/hr natural gas-fired roof-mounted heater
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks
II.A.5 Production Fabrication Area
Barrier coat and lamination (Chop Booth)
Equipment: One (1) flow coat chop gun; one (1) internal mix gun, one (1) spray gun, and three (3)
exhaust stacks
II.A.6 Production Grinding
Two (2) booths, mold removal, clean up and assembly
Equipment: one (1) dust collector
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II.A.7 Front Shop North Paint Booths (total 5 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth
II.A.8 Back Shop South Paint Booths (total 2 booths)
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack per booth
II.A.9 Back Shop Enclosed Paint Booth
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks
II.A.10 Back Shop Enclosed Paint Booth
Natural gas-fired heater rated at 1 MMBtu/hr
Equipment: air, airless, and air assist and HVLP spray guns; two (2) exhaust stacks
II.A.11 Back Shop Enclosed Paint Spray Booth - new
Natural gas-fired heater rated at 2.5 MMBtu/hr
Equipment: air, airless, and air assist and HVLP spray guns; one (1) exhaust stack
II.A.12 Eight (8) Closed Dip Tanks
Located at:
Tooling gelcoat booth (1)
Tooling laminating area (1)
Production gelcoating area (1)
Laminating area (2)
Chop booth (1)
North paint area (1)
Back shop paint area (1)
II.A.13 Dust Collectors (for information only)
One (1) Pattern Shop Torit dust collector (vents back into the building)
One (1) Tooling Dust Collector (vents back into the building)
Status: In Compliance. There were no new or unapproved equipment observed onsite
during this inspection. The equipment in AO Condition II.A.11 has not yet been
installed. Companion System was made aware of their requirement to submit a
notification to the DAQ per AO Condition 1.8 when the equipment is installed or
provide a status notification 18 months from the date of this AO.
SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Companion Systems Incorporated shall comply with the following requirements
II.B.1.a The owner/operator shall vent the air streams from the Pattern Shop Torit back into the building.
[R307-401-8]
Status: In Compliance. Companion Systems confirmed that the Pattern Shop Torit vents
back into the building.
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II.B.1.b The owner/operator shall vent the air streams from the Tooling Dust Collector back into the
building. [R307-401-8]
Status: In Compliance. Companion Systems confirmed that the Tooling Dust Collector
vents back into the building.
II.B.1.c The owner/operator shall install filters in the work areas in II.A.2 through II.A.5 and II.A.7
through II.A.11 to control process streams from their respective processes. All exhaust air from
the work areas shall be routed through their respective filters before being vented to the
atmosphere. The filters shall be maintained and replaced in accordance with manufacturer's
recommendations or instructions. [R307-401-8]
Status: In Compliance. During this inspection, filters were noted to have been installed in
their respective work areas, and all exhaust air from the work areas was routed through
the filters before being vented to the atmosphere. Companion Systems indicated that the
filters were replaced as necessary.
II.B.1.d The owner/operator shall not allow visible emissions from the following emission points to
exceed the following limits:
A. All filters and dust collectors - 10% opacity
B. All paint booths - 10% opacity
C. All natural gas combustion units - 10% opacity. [R307-401-8]
II.B.1.d.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]
Status: In Compliance. There were no visible emissions observed during this inspection.
The opacity observations were conducted according to 40 CFR 60, Appendix A, Method 9.
See the attachment for additional information.
II.B.1.e The owner/operator shall not exceed 20 hours per calendar day for each of the following
processes:
A. Mold fabrication
B. Production gelcoat
C. Barrier coat/ laminating
D. Painting. [R307-401-8]
Status: In Compliance. According to all the data reviewed, Companion Systems did not
exceed 20 hours per calendar day for mold fabrication, production gelcoat, barrier
coat/laminating, and painting processes. Companion Systems operates from 8am-5pm,
Monday through Friday, and occasionally on Saturday as needed. According to
Companion Systems, there is 6.86 hours per employee per day in a 280-day work schedule.
See the email attachment for additional information.
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II.B.1.e.1 The owner/operator shall calculate total hours in a calendar day by adding all operating hours
from midnight to midnight. Hours of operation shall be kept in an operations log by a supervisor.
[R307-401-8]
Status: In Compliance. The hours of operation are kept in an operations log. According to
Companion Systems, there was a total of 223,038 hours worked by 116 employees from
January - December 2023, with an average of 1,922.75 average hours per employee. See the
email attachment for additional information.
II.B.1.f The owner/operator shall not exceed 360 operating days per rolling 12-month period for each of
the following processes:
A. Mold fabrication
B. Production gelcoat
C. Barrier coat/ laminating
D. Painting. [R307-401-8]
Status: In Compliance. According to Companion Systems, there was a total of 223,038
hours worked by 116 employees from January - December 2023, with an average of
1,922.75 average hours per employee in a 280-day work schedule. See the email attachment
for additional information.
II.B.1.f.1 The owner/operator shall:
A. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months
B. Determine operating days by the supervisor monitoring and maintaining the operations
log
C. Keep the records of operation on a daily basis
D. Keep the records of operation for all periods when the plant is in operation.
[R307-401-8]
Status: In Compliance. According to all the data reviewed, Companion Systems did not
exceed 20 hours per calendar day for mold fabrication, production gelcoat, barrier
coat/laminating, and painting processes. Companion Systems operates from 8am-5pm,
Monday through Friday, and occasionally on Saturday as needed, and keeps daily records
of when the plant is in operation. According to Companion Systems, there is 6.86 hours per
employee per day in a 280-day work schedule. See the email attachment for additional
information.
II.B.1.g The owner/operator shall only use natural gas as a fuel. [R307-401-8]
Status: In Compliance. Companion Systems only uses natural gas as fuel.
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II.B.1.h The owner/operator shall comply with applicable requirements in R307-342, 350, and 353.
[R307-342, R307-350, R307-353]
Status: In Compliance. Coating is conducted in Spray Booths equipped with fabric filters
which are replaced as needed. The coatings are stored in one-gallon drums on shelves.
During this inspection, the coatings were covered when not in use. The coatings are applied
using High Volume Low Pressure (HVLP) Spray Guns for maximum distribution
efficiency. The Spray Guns are lined with disposal liners for the cleaning of the guns with
Acetone. See the SDS in the attachment. See the section on Area Source Rules for the
compliance determination with respect to R307-342 and R307-353. According to
Companion Systems, their processes are not applicable to R307-350.
II.B.2 VOC & HAP Requirements
II.B.2.a The owner/operator shall not emit more than the following from evaporative sources (painting,
coating, and/or cleaning) on site:
15.00 tons per rolling 12-month period for VOCs
0.25 tons per rolling 12-month period for dimethylphalate
0.50 tons per rolling 12-month period for ethyl benzene
0.02 tons per rolling 12-month period for glycol ether
0.02 tons per rolling 12-month period for methanol
0.40 tons per rolling 12-month period for methyl methacrylate
0.22 tons per rolling 12-month period for methylene chloride
0.30 tons per rolling 12-month period for methyl isobutyl ketone
7.50 tons per rolling 12-month period for styrene
0.50 tons per rolling 12-month period for toluene
1.25 tons per rolling 12-month period for xylene
0.01 tons per rolling 12-month period for cadmium compound
0.01 tons per rolling 12-month period for chromium compound
0.04 tons per rolling 12-month period for lead chromate, and
11.02 tons per rolling 12-month period for all HAPs combined. [R307-401-8]
Status: In Compliance. In a rolling 12-month from December 2022 - November 2023, the
emissions indicated the following:
2.3 tons of VOC
0.00 tons of dimethylphalate
0.05 tons of ethyl benzene
0.01 tons of glycol ether
0.00 tons of methanol
0.01 tons of methyl methacrylate
0.00 tons of methylene chloride
0.01 tons of methyl isobutyl ketone
0.61 tons of styrene
0.12 tons of toluene
0.33 tons of xylene
0.00 tons of cadmium compound
0.00 tons of chromium compound
0.00 tons of lead chromate
0.85 tons of combined HAPs
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II.B.2.a.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]
II.B.2.a.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.2.a.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. Companion Systems used these formulas as required by this AO
Condition.
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.
Not Applicable. There are no Federal Rules applicable to this facility.
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AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
R307-325: Ozone Nonattainment and Maintenance Areas
Status: In Compliance. There were no VOC containing materials observed in open containers, and
there were no spills noted during this inspection.
R307-342: Adhesives and Sealants
Status: In Compliance. According to Companion Systems, the Acrylic Adhesive is used to bond
acrylic to acrylic or metal to acrylic. The VOC content of this adhesive indicated compliance with
Other Plastic Cement Welding in Table 1 of R307-342-5. See the SDS in the attachment.
R307-350: Miscellaneous Metal Parts and Products Coatings
Status: Not applicable. According to Companion Systems, the processes at Companion Systems are
not applicable to this Area Rule.
R307-353: Plastic Parts Coatings
Status: In Compliance. According to Companion Systems, the VOC content of the product SC280
Satin Clear closely corresponds to the Air-Dried Coating – Exterior Parts - Top Coat-Base of 5.0
lb/gal in R307-353-5(1). See the SDS in the attachment.
EMISSION INVENTORY:
Status: In Compliance. According to the 2020 Emissions Inventory Report, the emissions indicate
compliance with the PTEs of this AO. The 2024 Emissions Inventory Report has not yet been
uploaded into SLEIS.
The emissions listed below are an estimate of the total potential emissions from Companion Systems
Incorporated on the Approval Order (AO) DAQE-AN101810010-24, dated February 1, 2024. The
following information was supplied for supplemental purposes only. PTE are supplied for supplemental
purposes only.
Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 1722.00 ---
Carbon Monoxide 1.10 ---
Nitrogen Oxides 1.36 ---
Particulate Matter - PM10 3.24 ---
Particulate Matter - PM2.5 0.12 ---
Volatile Organic Compounds 15.06 3.535
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Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Cadmium Compounds (CAS #CAE750) 20 ---
Chromium Compounds (CAS #CMJ500) 20 ---
Dimethyl Phthalate (CAS #131113) 500 ---
Ethyl Benzene (CAS #100414) 1000 ---
Glycol Ethers (CAS #EDF109) 40 ---
Hexane (CAS #110543) 40 ---
Lead Chromate (CAS #18454121) 80 ---
Methanol (CAS #67561) 40 ---
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 600 ---
Methyl Methacrylate (CAS #80626) 800 ---
Methylene Chloride (Dichloromethane) (CAS #75092) 440 ---
Styrene (CAS #100425) 15000 4.213
Toluene (CAS #108883) 1000 ---
Xylenes (Isomers And Mixture) (CAS #1330207) 2500 0.182
PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: Companion Systems is in compliance with the conditions of AO
DAQE-AN101810010-24 dated February 1, 2024, at the time of
inspection. Companion Systems maintains good housekeeping
practices. The facility appears to be well maintained and
operated.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual. Required PPE includes Safety Glasses.
NSR RECOMMENDATIONS: For AO Condition II.B.1.h, consider changing R307-350 to
R307-353, and consider removing R307-350 applicability in this
AO.
ATTACHMENTS: Applicable Supporting Documentation Included